HomeMy WebLinkAboutStaff Report 3200
City of Palo Alto (ID # 3200)
Finance Committee Staff Report
Report Type: Action ItemsMeeting Date: 11/14/2012
City of Palo Alto Page 1
Summary Title: Resolution to Continue Palo Alto CLEAN Program
Title: Utilities Advisory Commission Recommendation that Council Adopt a
Resolution Approving the Continuation of the Palo Alto Clean Local Energy
Accessible Now (CLEAN) Program
From: City Manager
Lead Department: Utilities
Recommendation
Staff and the Utilities Advisory Commission (UAC) recommend that the Finance Committee
recommend that the City Council adopt a resolution (Attachment A) approving the continuation
of the Palo Alto CLEAN program, with a review of the program by the UAC in one year.
Executive Summary
In March 2012 the Council adopted Palo Alto CLEAN, a CLEAN (Clean Local Energy Accessible
Now program (also commonly referred to as a feed-in tariff, or FIT, program). The program was
designed to complement the City of Palo Alto Utilities (CPAU’s) existing photovoltaic (PV)
Partners solar rebate program, which was established in 1999 and which has one of the highest
participation levels per customer in the country. Palo Alto CLEAN created an additional
alternative for property owners by enabling them to build a new solar system and sell the
energy to CPAU under a long-term, fixed-rate contract rather than participate in the PV
Partners program and use the energy on site.
Though a large number of solar developers have expressed interest in Palo Alto CLEAN, no
project applications have been submitted to date. Staff believes the current price (14 cents per
kilowatt-hour (¢/kWh) for a 20 year contract) is insufficient at this time to f acilitate the most
common business model used by project developers, which involves a 3rd party investor
leasing roof space from a property owner. It may, however, be sufficient to provide a moderate
return to a property owner who owns and finances a sola r system without the involvement of a
third party investor. A property owner using this business model is participating in Marin
Energy Authority’s FIT, which is priced at roughly 13.7 ¢/kWh.
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Staff therefore recommends continuing Palo Alto CLEAN at the current price and making it
available to any property owner interested in participating. CPAU staff would increase its
marketing efforts to commercial customers and property owners, both for the PV Partners
program and Palo Alto CLEAN, and will also investigate ways to help commercial customers
decrease the cost of installing solar. Staff expects that most growth in commercial solar
installations over the next 2-3 years will come from customers participating in the PV Partners
program, with Palo Alto CLEAN participation increasing slowly as property owners are educated
about how to make the program work for them. Palo Alto CLEAN will be available to residential
customers as well, but staff expects PV Partners will continue to be their preferred program.
When it was adopted, Palo Alto CLEAN was considered nearly cost neutral, since the 14 ¢/kWh
price was close to 13.55 ¢/kWh, staff’s estimate of the cost of buying renewable energy outside
Palo Alto and transmitting it here. However, since the program was adopted, the price of
renewable energy delivered to Palo Alto has dropped to roughly 11.6 ¢/kWh. Based on its
experience and research, staff believes that 14 ¢/kWh is the lowest price that can make local
solar projects viable. This means that buying energy from 4 MW of local solar projects through
the Palo Alto CLEAN program will cost about $158,000 per year more than buying the same
energy outside of Palo Alto. This is equivalent to a 0.1% increase in the electric utility’s costs.
At its October 2012 meeting, the UAC supported the proposal to continue the Palo Alto CLEAN
Program at the same price.
Background
CPAU has a long history of supporting solar power. It initiated the PV Partners program in
1999, and in 2007 the program was expanded to meet the requirements of the State’s Million
Solar Roofs Bill (Senate Bill 1, 2006). Under the PV Partners program CPAU provides rebates to
residential and commercial customers who install solar for their own use. The program has
been successful at stimulating solar development, with more than 3.4 megawatts (MW) of local
solar capacity installed by nearly 500 participants over the program’s life. New participants
have entered the program at a rate of 50-100 per year in recent years, and Palo Alto is one of
the top ten utilities nationwide in installations per customer.
Through PV Partners CPAU already provides substantial financial support for local solar. The
total CPAU SB1 program budget for 2008-2017 is $13 million and the total program goal is 6.6
MW. When this goal is achieved the energy generated by the program annually will be 11.2
GWh (1.1% of Palo Alto load). The average annual cost to ratepayers of these rebate payments
is roughly $1.1 million per year, which does not include the cost of administration or the lost
distribution system revenue associated with net metering. The rate impact of this program is
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roughly 1-1.5% per year while rebates are being paid. Once all rebates have been paid the rate
impact of lost revenue due to net metering will continue to be 0.3-0.5% per year. Due to SB1,
PV Partners is now a state mandated program, and regardless of the rate impact, CPAU is
required to offer it.
In April 2012 CPAU expanded its support for local distributed generation by launching Palo Alto
CLEAN. That program expanded the options available to property owners by enabling them to
sell energy directly to CPAU under a long term contract instead of using the energy on site. This
business model facilitates certain types of projects that could not happen otherwise, such as
installations by property owners who have no use for on -site solar energy or whose tenants are
uninterested in using the energy. It also can lower certain project costs. For example, banks
consider publicly owned utilities to be good counterparties for energy purchases so project
owners can more easily obtain financing.
In the first few months Palo Alto CLEAN generated a high level of interest from solar developers
who wanted to lease rooftops in Palo Alto in order to build a solar system and sell the energy to
CPAU. There was also some interest from property owners looking to invest in a system on
their own rooftops. It soon became apparent, though, that the 14 ¢/kWh price was insufficient
to enable 3rd party developers to earn their target returns while still offering attractive rooftop
lease rates. The property owners who have investigated the program to -date either chose not
to participate or chose to evaluate projects under the PV Partners program instead. The level
of new interest has decreased, though staff still regularly receives new inquiries from
developers and property owners.
Despite the lack of participation, there have been some positive results from the program. By
adopting the program CPAU prompted developers to take a serious look at the cost of
developing solar projects in Palo Alto, and some of them shared that information with CPAU
staff. Staff has gained considerable insight into the cost of building large solar systems in Palo
Alto. The program also created new excitement around local solar, prompting several property
owners to evaluate whether solar could be feasible for them. At least one large property owner
is expected to proceed with a PV Partners application as a result. In addition, many p ublic
utilities across the country have called to discuss how to follow Palo Alto’s lead and develop a
CLEAN program in their own service areas.
There are encouraging indications that Palo Alto CLEAN, as currently priced, will generate some
participation in the future. As mentioned above, the 14 ¢/kWh price was insufficient to enable
a business model involving a 3rd party developer, but if a property owner invested in a system
partially financed with debt, a project could generate a reasonable return. I n Marin County the
owner of the San Rafael Airport recently chose to participate in Marin Energy Authority’s (MEA)
FIT program by installing a 1 MW project on the rooftop of his hangers. The property owner
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financed the project himself, assisted by a loan from a local bank. With those terms the project
generated a modest return at the FIT price MEA offered, 13.7 ¢/kWh, and showed that a
project can work at that price when properly structured. MEA’s FIT program commenced in
late 2010, but the San Rafael Airport project did not get started until 2012. A similar project
may work in Palo Alto, but as in Marin, it may take some time to find the right site or collection
of sites.
Based on staff’s analysis and the result of the MEA FIT, staff believes 14 ¢/kW h is a reasonable
price for the program. Still, even if it is possible to see results at the current Palo Alto CLEAN
price of 14 ¢/kWh, the City must decide whether to seek out such projects. At the program’s
inception the Palo Alto CLEAN price was considered nearly cost-neutral, but the results of
CPAU’s recent renewable RFP, as well as publicly available data from other renewable
procurements in the state, has revealed that the price of renewable energy has dropped since
staff’s original calculations. Staff now estimates the cost of buying renewable energy outside of
Palo Alto and transmitting it here to be 11.6 ¢/kWh, compared to the Palo Alto CLEAN price of
14 ¢/kWh.
Discussion
The first Palo Alto CLEAN program year expires on December 31, 2012, an d staff has no
authority to make purchases after that date. Staff recommends that Council authorize the
program’s continuation, but rather than changing the price, staff recommends giving the
program time to work at the current price. The attached resolution (Attachment A) would
extend the program deadline until the 4 MW program capacity is filled. Staff also recommends
removing the minimum project size of 100 kW. If Council adopts this strategy, staff predicts
that program participation will increase slowly, with a modest impact on utility costs (see
“Program Cost,” below). In 2013 and 2014 there might be minimal or no uptake. During this
time growth in local distributed generation would come primarily from the PV Partners
program, which still has over 4 MW of capacity available. Meanwhile, staff would reach out to
local property owners and educate them on the benefits of investing in a Palo Alto CLEAN
project while looking for opportunities to help customers lower the cost of installation. Staff
believes this recommendation represents the best compromise between two competing
objectives: 1) expanding support for local distributed generation and 2) pursuing the least
costly method of fulfilling the CPAU electric portfolio objectives.
Program Cost
Buying the energy from 4 MW of local solar generating systems through Palo Alto CLEAN would
be more expensive than buying the same amount of renewable energy from solar projects
outside of Palo Alto, but because the amount of energy is small, the total impact on the utility’s
costs would also be small. Using the cost of renewable energy as a baseline, and assuming the
full program capacity is used, the City’s cost of renewable energy would be an additional
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$158,000 per year. This is equivalent to a 0.1% increase in the electric utility’s costs. See
Table 2 in the following section for examples of bills for various customer types and how those
costs compare to their monthly bills.
This represents a change from CPAU staff’s original assessment of the program. When the price
for the 2012 Palo Alto CLEAN program was adopted, it was determined to be nearly cost
neutral. In late 2011, the cost of buying renewable energy outside of Palo Alto and transmitting
it here was estimated to be 13.55 ¢/kWh. This price is referred to as the City’s “avoided cost,”
since these costs are avoided by buying local renewable energy. Council approved a
0.45 ¢/kWh adder to bring the Palo Alto CLEAN program price to 14 ¢/kWh (for a 20 year
contract term). The adopted Palo Alto CLEAN price was so close to the CPAU avoided costs that
the program could be considered to have negligible impact on the utility’s costs. Since then,
however, prices for renewable energy have fallen considerably as evidenced by proposals
submitted into the last Request for Proposals (RFP) for renewable energy. Based on that
indication of the cost of renewable energy outside of Palo Alto, the avoided costs are about
11.6 ¢/kWh. This means that the Palo Alto CLEAN price of 14 ¢/kWh is 2.4 ¢/kWh higher than
the cost of buying renewable energy outside of Palo Alto and paying the transmission and other
related costs to bring it here.
There are several reasons that local solar projects are more expensive than remote solar
projects:
1. Palo Alto does not have developable open land, and installing solar on rooftops is more
expensive than installing it on the ground.
A number of solar developers have noted that the cost associated with leasing a roof is
higher than the cost of purchasing open land. Many large solar projects outside of Palo Alto
are located on disturbed land (marginal farmland) outside of urban areas. The land costs
associated with these projects are far lower than the lease costs associated with a rooftop.
2. Owners of office space require a higher rate of return for the use of their rooftops than
owners of warehouses or other similar facilities.
Most of the facilities in California that host large wholesale commercial solar installations
are warehouses or similar facilities with large rooftops, little rooftop equipment, and low
lease rates. The revenue owners of these facilities receive for hosting a solar system is
small but substantial when compared to the revenue from leasing the facility itself. In Palo
Alto, however, Class A office facilities command much higher revenue per square foot, and
the facilities themselves are generally much smaller than a warehouse. The revenue from
leasing a solar system can appear relatively small, and therefore not worth the potential
problems associated with a rooftop lease. Depending on the contract terms, a long term
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rooftop lease can reduce the property owner’s flexibility in reconfiguring the site. Office
space owners are also concerned about potential disruptions to tenants during installation
of the solar system, something that is less of a problem with other types of facilities.
3. Remote solar projects can be located where there is more sun.
Palo Alto receives excellent amounts of solar energy, but other parts of California receive
even more. This can make a significant difference in the price of solar energy because the
developer can generate more energy from every panel they install.
Cost of Solar Installations in Palo Alto
Staff has estimated the cost of installing solar in Palo Alto based on discussio ns with developers,
property owners, other utilities, and using data from existing systems installed in Palo Alto and
throughout the Bay Area. The prices below assume that the projects will be financed by a 3 rd
party developer leasing a rooftop, or by a customer or facility owner willing to commit capital
to the project. They do not assume any debt financing. While larger systems can achieve
certain economies of scale on a per unit (kW) basis, the cost of installing small commercial solar
systems (<30 kW) and residential systems is substantially higher than the cost of installing the
larger systems that have been evaluated for the existing Palo Alto CLEAN program.
0.00
0.05
0.10
0.15
0.20
0.25
0.30
0.35
0.40
2013 2014 2015 2016
$/
k
W
h
Cost of solar in Palo Alto
Residential
Small Commercial
Large Commercial
RPS-eligible
Avoided Cost
Brown Power
Avoided Cost
Alternatives Considered
In developing its recommendation, staff considered several other alternatives for the future of
Palo Alto CLEAN. The first two alternatives listed below are priced to attract rapid participation
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by efficient 3rd party developers. The prices would be high enough to provide an attractive
return to a facility owner who invests in an efficient, low-priced solar system, and would also be
enough to enable a 3rd party developer to earn a moderate return while paying a moderate
lease rate for a Palo Alto rooftop. These program alternatives increase the chance of rapid
uptake in the program by setting a price that is attractive to those facility owners willing to
commit capital to build their own solar systems, but also provides enough of a return to enable
3rd party developers to lease rooftops on facilities whose owners are not willing to commit
capital.
The third alternative is the staff recommendation, which relies on efficient systems financed
partially by property owners and partially using debt financing. The fourth and fifth alternatives
minimize CPAU’s cost and eventual ratepayer impact, but are expected to result in little or no
program uptake.
The five alternatives are described below:
1) Program that accommodates 3rd party developers, with prices differentiated by
system size: Adopt a CLEAN program with different prices for residents, small
commercial property owners, and large commercial property owners. The program
would include separate capacity allocations for large systems, small systems, and
residential systems, and the price would be set to reflect th e different costs of
development for each type of system (32.4 ¢/kWh for residents, 28.1 ¢/kWh for small
commercial customers less than 35 kW in size, and 18.8 ¢/kWh for large commercial
customers for a 20-year contract).
2) Program that accommodates 3rd party developers, with a single price: Adopt a CLEAN
program intended to promote participation primarily by large commercial property
owners. The program would be open to all property owners, but it would be priced so
that only larger systems or aggregations of smaller systems would be economically
feasible (18.8 ¢/kWh for a 20-year contract).
3) Current Program (Staff Recommendation): Extend the current program at the same
rate (14 ¢/kWh for a 20-year contract).
4) Cost-neutral Program: Extend Palo Alto CLEAN, but price it at the cost of buying
renewable energy and transporting it to Palo Alto (11.6 ¢/kWh for a 20 -year contract).
5) No Program: Eliminate Palo Alto CLEAN.
City of Palo Alto Page 8
Staff believes that Program Alternatives 1 and 2 would be rapidly subscribed, but would cost
substantially more than the other alternatives. Program Alternative 3, the staff
recommendation, may take some time to generate results, but has a very small cost and
eventual rate impact compared to adding other types of renewable generation to the supp ly
portfolio. Program Alternative 4 does not increase utility costs, but staff believes the price
would not be adequate to generate any response.
The costs of the five program alternatives are summarized in Table 1 below, and are compared
to the CPAU avoided cost of energy. The annual budgets below are calculated based on a
4 MW program, but they vary linearly, so doubling the program size would double the budgets
and rate impacts below, and halving it would halve the budgets and rate impacts.
TABLE 1: Annual Cost of Program Alternatives
Program
Alternative Description
Energy Cost
(₵/kWh)
Annual Excess Cost*
$ and % increase in utility costs
1 Accommodates 3rd party
development, price varies
based on system size
25.0** $874,000 (0.7%)
2 Accommodates 3rd party
development, single price
18.8 $483,000 (0.4%)
3 Extend the current
program at the current
price
14.0 $158,000 (0.1%)
4 Extend the program,
reprice at avoided cost
11.6 N/A
5 Eliminate the program
N/A N/A
Renewable
Avoided Cost
Buying renewable energy
outside Palo Alto
11.6 N/A
Non-renewable
Avoided Cost
Buying non-renewable
energy outside Palo Alto
9.7 N/A
* This figure represents the cost of each program alternative compared to the cost of buying renewable energy
outside of Palo Alto.
** Average energy cost for this program alternative. Detailed costs: $324/MWh for the residential portion,
$281/MWh for the small commercial portion (35 kW or less) and $188 for the large commercial portion (>35 kw).
City of Palo Alto Page 9
To give some perspective on the costs for each program alternative, staff has prepared Table 2,
below, which shows what would happen if the annual costs of each program alternative were
allocated to customers on a per-kWh basis. These costs are calculated for a 4 MW program, but
it is possible to vary the program size. The costs vary linearly, so doubling the program size
would double the costs below, and halving it would halve the costs.
TABLE 2: Program Costs Compared to Customer Bills
Customer Type /
Monthly
Consumption
# of
Customers
Current
Average
Monthly Bill
Monthly Program Costs by Alternative*:
1 2 3 4 5
Residential Customers:
Summer (365 kWh) 25,678 $37 $0.33 $0.18 $0.06 $0 $0
Winter (453 kWh) 25,678 $48 $0.41 $0.23 $0.07 $0 $0
Commercial Customers:
0-1,000 kWh 1,844 $45 $0.30 $0.17 $0.06 $0 $0
1,001-8,000 kWh 1,481 $427 $3 $2 $1 $0 $0
8,001-100,000 kWh 606 $3,198 $27 $15 $4 $0 $0
> 100,000 kWh 101 $48,893 $405 $224 $74 $0 $0
*If allocated on a per-kWh basis.
Resource Impact
In addition to the energy costs described above, the staff recommendation will require staff
time associated with marketing and project review. The project review can be absorbed with
existing staff over the life of the program, and costs will be recovered through project review
fees. The additional marketing will require less than 0.25 FTE of staff time, and may involve an
additional budget for marketing materials, which would be requested through the annual
budget process. The marketing work will be absorbed by existing staff, bu t will decrease time
spent on other account management and efficiency program delivery.
Commission Review and Recommendation
On October 3, 2012, the UAC reviewed the staff proposal and on a 5-1 vote (with Commissioner
Waldfogel voting no) recommended that Council approve the staff recommendation with a
review of the program after one year. Several commissioners expressed their support for
renewable energy within Palo Alto, but were concerned about allowing the CLEAN price to
deviate too far from the City’s avoided cost. Commissioners expressed some concern about
City of Palo Alto Page 10
devoting staff resources to marketing the program instead of marketing other successful
programs, such as the PV Partners or energy efficiency programs. One commissioner supported
raising the program’s price to encourage more rapid participation. The draft minutes from the
UAC’s October 3, 2012 meeting are provided in Attachment C.
Policy Implications
The staff recommendation implements Long-term Electric Acquisition Plan (LEAP) Strategy #4,
Local Generation, which states “promote and facilitate the deployment of cost-effective local
resources.” The program will facilitate the deployment of local resources, but the
recommended price, 14 ¢/kWh, will only support the most efficient local solar pro jects. It also
implements Climate Protection Plan Chapter 3 (Utilities), Goal 3, “Expand use of renewable
energy installed or purchased directly by customers.” The program also implements
Comprehensive Plan Goal N-9, “A clean, efficient, competitively-priced energy supply that
makes use of cost-effective renewable resources” and Policy N-48, “Encourage the appropriate
use of alternative energy technologies.”
Environmental Review
The adoption of this resolution does not constitute a project under the California
Environmental Quality Act, California Public Resources Code section 21080, subdivision (b)(8).
Attachments:
Attachment A: Resolution Approving Amendments to Palo Alto CLEAN (PDF)
Attachment B: Revised Palo Alto CLEAN program rules (PDF)
Attachment C: Draft Excerpt of October 3, 2012 UAC Meeting Minutes (PDF)
*NOT YET APPROVED*
120925 DM 6051788
Resolution No. _________
Resolution of the Council of the City of Palo Alto Approving the
Continuation of The Palo Alto Clean Local Energy Accessible Now (CLEAN)
Program
R E C I T A L S
A. On March 5, 2012, the City approved the Palo Alto Clean Local Energy Accessible
Now Program, a CLEAN program (or feed-in tariff). Under the CLEAN Program, participants who
build a new solar generating system in Palo Alto may obtain a long -term, fixed-price contract
with the City to sell the energy from the system to the City’s electric utility.
B. The first program year of Palo Alto CLEAN commenced on April 2, 2012 and
terminates on the earlier of: 1) the date the City receives applications for contracts for 4 MW of
solar capacity, or 2) December 31, 2012. The City Council has not granted authority to staff to
enter in to contracts after December 31, 2012.
C. There have been no applications for the program to-date, but the City wants to
continue the program past December 31, 2012 .
The Council of the City of Palo Alto (“City”) RESOLVES:
SECTION 1. Revised Program Eligibility Requirements for Palo Alto CLEAN are
adopted as shown in Exhibit A.
SECTION 2. The Council hereby authorizes the City Manager or his designee to sign
contracts for the output of one or more solar energy generating facilities meeting the Program
Eligibility Requirements described in Section 1. The total CLEAN Program cost commitment
made by the City during the life of the Program shall not exceed $23,600,000.
SECTION 3. The Council finds that the City of Palo Alto Utilities’ (CPAU’s) purchase of
energy from local renewable sources provides additional local benefits to CPAU when
compared to energy purchased outside Palo Alto, which in turn become benefits to CPAU
ratepayers and the local community. These benefits include a reduction in CPAU’s costs and
energy losses associated with energy transmission and distribution, and a reduction in CPAU’s
capacity requirements. When the City purchases energy from local sources, a portion of the
City’s electric expenditures remain within the community, which provides revenue for local
economic development. Locating generation near load centers can also reduce the need for
new transmission lines, thus reducing the environmental impacts of the electric system and
improving reliability in transmission-constrained regions like the Greater Bay Area. The Council
therefore finds that continued implementation of the Palo Alto CLEAN Program is a reasonable
cost of providing electric service to CPAU’s electric customers.
*NOT YET APPROVED*
120925 DM 6051788
SECTION 4. The Council finds that the adoption of this resolution does not constitute
a project under the California Environmental Quality Act, California Public Resources Code
section 21080, subdivision (b)(8).
INTRODUCED AND PASSED:
AYES:
NOES:
ABSENT:
ABSTENTIONS:
ATTEST:
___________________________ _______________________
City Clerk Mayor
APPROVED AS TO FORM: APPROVED:
___________________________ _______________________
Senior Deputy City Attorney City Manager
___________________________
Director of Utilities
___________________________
Director of Administrative Services
PALO ALTO CLEAN (CLEAN LOCAL ENERGY ACCESSIBLE NOW PROGRAM )
PROGRAM ELIGIBILITY RULES AND REQUIREMENTS PROGRAM YEAR 2012
Effective January 1, 2013
A. PARTICIPATION ELIGIBILITY REQUIREMENT:
The Palo Alto Clean Local Energy Accessible Now Program (the “CLEAN Program”) , Program
Year 2012, is open to participation by any Eligible Renewable Energy Resource, as defined in
Section D.45, with a total generation capacity of at least 100 kilowatts (kW)..
B. TERRITORIALITY REQUIREMENT:
In order to be eligible to participate in the CLEAN Program during Program Year 2012, an Eligible
Renewable Energy Resource must be located in and generating electricity from within the utility
service area of the City of Palo Alto.
C. PRICES FOR CERTIFIED RENEWABLE POWER:
The following purchase prices (“Program Prices”) shall apply to the electricity produced by an
Eligible Renewable Energy Resource participating in the Program starting in Program Year 2012,
except as provided in Sections D.5 D.3 and D.6.
Solar generation facilities:
Contract Term Price
10 years 12.360 ¢ / kWh
15 years 13.216 ¢ / kWh
20 years 14.003 ¢ / kWh
D. ADDITIONAL RULES AND REQUIREMENTS:
1. The owner of the Eligible Renewable Energy Resource shall enter into a Eligible Renewable
Energy Resource Power Purchase Agreement, Eligible Renewable Energy Resource (“PPA”)
with the City of Palo Alto.
2. The last Eligible Renewable Energy Resource that is eligible for participation in the CLEAN
Program during Program Year 2012 will be the Eligible Renewable Energy Resource that first
causes the total capacity of Eligible Renewable Energy Resources receiving payments under
the Program to exceed four (4) MW (the “Program Capacity”).
3. An application for participation in the CLEAN Program to sell output to the City (the
“Application”) may be submitted at any time. Applications will be considered in the order
received. during the month. Any number of PPAs may be awarded at the end of each
month. If the City can accept all Applications submitted without exceeding the Program
Capacity, then all Applications will be accepted at the applicable Program Price(s). If, in any
month, the City cannot accept all Applications submitted during that month without
exceeding the Program Capacity, then the PPAs will be awarded in the following order of
precedence:
PALO ALTO CLEAN (CLEAN LOCAL ENERGY ACCESSIBLE NOW PROGRAM )
PROGRAM ELIGIBILITY RULES AND REQUIREMENTS PROGRAM YEAR 2012
Effective January 1, 2013
. The City will provide notification to all applicants that apply in the current month
that there is insufficient capacity to accept all Applications. All applicants that apply
for participation in the current month will be afforded two (2) weeks from the
notification date to submit bid prices at which electricity from its proposed resource
will be sold to the City. The bid price must be less than the price for the applicable
term described in Section C, or the City will reject or will be deemed to have
rejected the bid price.
. The City will award one or more PPAs based upon the proposed bid prices. The first
award will be made to the applicant offering the lowest bid price and any
subsequent award(s) will be made to the next higher prices, until the Program
Capacity has been attained.
. Nothing in this ‘bid price’ process will affect the status of applica tions accepted in
previous months.
8. In order for an Eligible Renewable Energy Resource to be eligible for participation in the
CLEAN Program during Program Year 2012, the City must receive an Application on or
before December 31, 2012 or, if that day does not fall on a regular business day of the City,
on the business day immediately preceding December 31, 2012.
9.4. For the purposes of Program Year 2012, an Eligible Renewable Energy Resource means an
electric generating facility that: (a) is defined and qualifies as an “eligible renewable energy
resource” under California Public Utilities Code Section 399.12(e) and California Public
Resources Code Section 25471, respectively, as amended; (b) uses a solar fuel source; and
(c) meets the territoriality requirement set forth in Section B.
10.5. The California Energy Commission’s (“CEC”) certification of the Eligible Renewable Energy
Resource shall be required within six (6) months of the commercial operation date of the
electric generating facility; the facility’s owner shall provide written notice of the CEC’s
certification to the City within ten (10) business days. If the City takes delivery of the
facility’s electricity prior to the CEC’s certification, then, as the facility’s electricity cannot be
considered in fulfillment of the City’s RPS requirements, the price that the City will pay for
the facility’s electricity (the “Pre-Certification Price”) will be set at 65% of the applicable
Contract Price. Upon the CEC’s certification of the facility, the City will pay the applicable
Contract Price for the facility’s electricity delivered on and after the date of the CEC’s
certification. The City will “true-up”, as appropriate, the difference between the Contract
Price and the Pre-Certification Price for any electricity received and paid for by the City,
effective as of the date of certification of the Resource.
11.6. If an Eligible Renewable Energy Resource is authorized to participate in the CLEAN
Program, then that Resource shall not be entitled to receive any rebate or other incentive
from the City’s Photovoltaic (PV) Partners Program, Power from Local Ultra -Clean
Generation Incentive (PLUG-In) Program, or other similar programs funded by the City’s
ratepayers. To the extent any rebate or incentive is paid to the owner of the Resource, that
rebate or incentive shall be disgorged and refunded to the City if the Eligible Renewable
Energy Resource continues to participate in the CLEAN Program. If a rebate or an incentive
has been paid to the Eligible Renewable Energy Resource, then that Resource shall be
PALO ALTO CLEAN (CLEAN LOCAL ENERGY ACCESSIBLE NOW PROGRAM )
PROGRAM ELIGIBILITY RULES AND REQUIREMENTS PROGRAM YEAR 2012
Effective January 1, 2013
ineligible to participate in the CLEAN Program.
12.7. All electricity generated by the Eligible Renewable Energy Resource shall be delivered only
to the City. No portion of the electricity may be used to offset any load of the generating
facility (other than incidental loads associated with operating the generating facility).
13.8. A metering and administration fee of $34.73/month will be charged to each Eligible
Renewable Energy Resource that participates in the CLEAN Program during Program Year
2012. . See Utilities Rate Schedule E-15 (Electric Service Connection Fees).
Excerpted Draft Minutes of the October 3, 2012 UAC Meeting
ITEM 1: ACTION: UAC Recommendation that Council Adopt a Resolution Approving the
Continuation of the Palo Alto Clean Local Energy Accessible Now (CLEAN) Program
Public Comment:
Craig Lewis, representing the CLEAN Coalition, stated that the Palo Alto CLEAN has had no
takers so far, but that the program could be tweaked to be successful. The CLEAN Coalition had
hoped when the program started that property owners rather than develo pers would develop
and own projects, eliminating the need for a lease payment. He said the price offered seems to
have been too low and developers and that property owners were not attracted by the rate of
return from a project in Palo Alto. He believed property owners would be more interested in
leasing their rooftops to a third party developer. He stated that the lease payment to building
owners translates to a 3 cent/kilowatt-hour (₵/kWh) increase in price so that a price of
17 ₵/kWh or higher would be required to get local solar projects. He recommended
implementing a Volumetric Price Adjustment (VPA) whereby non-participation in the program
over some period of time (e.g. a month) would result in an automatic increase in the price until
participants were attracted.
Resource Planner Jon Abendschein provided a summary of the written report. He stated that
the City has supported local solar photovoltaic (PV) system installations since 1999 and the PV
Partners program has resulted in the City being one of the top utilities nationwide for PV
system installations. Abendschein stated that, despite a large amount of interest, the CLEAN
program has not had any participants, primarily because the PV Partners is a more cost -
effective option for most facilities and the returns for CLEAN program are insufficient.
Abendschein explained the staff recommendation is to extend the program at the current 14
₵/kWh price, eliminate the 100 kW minimum size, and ramp up efforts to market the PV
Partners program. Since the program was evaluated last year, and the price was set at 14
₵/kWh, the City's projection of the avoided cost has fallen to 11.6 ₵/kWh so that additional cost
to ratepayers is $158,000 per year.
Abendschein explained that the alternatives to the reco mmendation were considered and
included increasing the price, lowering the price, or eliminating the program. Increasing the
price would increase the cost to ratepayers, while lowering the price would not result in any
participation. He also stated that staff had examined other types of renewable energy sources,
but did not find any other energy sources aside from solar that were viable in Palo Alto aside
from City-owned sources that could be developed without a CLEAN program.
Commissioner Melton said that originally the program had been priced at the City's avoided
cost, but now the price was 20% higher than the avoided cost. He asked what the City’s pricing
policy was, and at what price would the cost of the program be too high compared to the City’s
avoided cost. He did not want the program to entirely lose its relationship to avoided costs.
Director Valerie Fong stated that the City Council had been comfortable with a small premium
over avoided cost when the program was adopted, but had not provide d specific policy
direction on the maximum acceptable premium.
Commissioner Eglash asked how many PV systems had been installed in Palo Alto since the
CLEAN program had been adopted. Abendschein stated that there had been from 25 -50
systems installed in residences, but he did not have the exact numbers. Commissioner Eglash
said that many people were continuing to install solar even without Palo Alto CLEAN. He said
the goal was not to have a feed -in tariff (FIT) simply to have a FIT. It was to stimulate solar
development. He said the PV Partners program was economically more attractive and that
solar was being installed at a healthy rate even without Palo Alto CLEAN. That implied that Palo
Alto CLEAN was obsolete and unnecessary. He said the cost of solar was falling substantially,
and 3rd party developers were offering excellent prices. He was against raising the price, but he
was happy leaving the program operating as it was if it did not cost much to maintain it.
Commissioner Waldfogel asked what the equivalent cost of the PV Partners program was.
Abendschein said the avoided cost was the same, but if PV Partners were translated into a FIT
price it would be equivalent to 20 -24 ¢/kWh. PV Partners was a State mandated program,
however. Commissioner Waldfogel asked whether the size of the PV Partners program was
also a State mandate. Abendschein said it was.
Vice Chair Foster asked who paid for the PV Partners program. Director Fong stated the City
did. Vice Chair Foster asked whether it was better to have people participating in PA CLEAN or
PV Partners, since PV Partners was more expensive. Director Fong stated that PA CLEAN
participation would not relieve the City of its SB1 obligation, which the PV Partners program
fulfilled. Abendschein added that even if customers chose to participate in Palo Alto CLEAN,
the PV Partners capacity would still be available. Vice Chair Foster asked how much the
Brannon Solar project factored into the avoided cost calculation. Abendschein said it was a
small part of the calculation. Vice Chair Foster asked whether the staff recommended program
would allow people to fund solar on each other’s roofs if they chose to. Abendschein said the
funding source was not important as long as they sold the energy to the City.
Vice Mayor Scharff asked what it would cost to continue the program. Abendschein said the
staff time involved in maintaining the program without marketing it was minimal, but that the
staff proposal had involved some staff time for marketing which would be absorbed by existing
staff. Utility Marketing Services Manager Joyce Kinnear said that Key Account Representatives,
who market the City’s programs, including energy efficiency, would spend time on marketing
Palo Alto CLEAN, which would replace some of the time they spent marketing other programs
like energy efficiency.
Commissioner Foster stated that the program is an innovative program. The City should be
doing it and would like to see an increase in the price to get more participation. He wa s not
sensing much support for that proposal, so he would support the staff recommendation. He
would be opposed to eliminating the program.
Chair Cook thanked the CLEAN Coalition for support, but would not want to move much further
away from the avoided cost. He would support the staff recommendation, but would want to
review it again at some point in time, rather than have the program continue indefinitely.
Commissioner Melton remarked that the goal is to increase the amount of renewable power
generated within city limits, so he supported continuing the program despite the small increase
in price.
ACTION:
Vice Chair Foster made a motion to support staff's recommendation. Melton seconded the
motion.
Commissioner Eglash offered a friendly amendment to review the program in one year. Vice
Chair Foster and Commissioner Melton accepted the amendment.
Commissioner Waldfogel asked if the failure of the program could be attributed to a marketing
shortcoming. Abendschein said it was a matter of expanding the marketing to the specific
customers who the program would work for. Commissioner Waldfogel stated that he believed
that anyone who was eligible for the program had already heard about the program and had
determined it was not worthwhile. He was uncomfortable continuing to spend money to
market the program.
Vice Chair Foster said that some level of marketing should exist as not all have heard of the
program and it is being expanded to more customers.
The motion passed by a vote of 5-1 with Commissioner Waldfogel voting no.