HomeMy WebLinkAboutStaff Report 1403City of Palo Alto (ID # 1403)
City Council Staff Report
Report Type: Consent Calendar Meeting Date: 3/7/2011
March 07, 2011 Page 1 of 4
(ID # 1403)
Title: Utility Rule 29 Changes
Subject: Adoption of a Resolution Amending Utility Rule and Regulation 29 (Net
Energy Metering Service and Interconnection)
From:City Manager
Lead Department: Utilities
RECOMMENDATION
Staff recommends that the City Council adopt a resolution amending Utility Rule and Regulation
29 as attached. The amended rule, if approved, would become effective March 1, 2011
EXECUTIVE SUMMARY
Assembly Bill 920 (AB 920) (2009) modified the Public Utilities Code’s terms and conditions for
Net Energy Metering (PUC Section 2827). Staff identified revisions to the billing system to
implement AB920-related changes as they are currently described in Utility Rule and Regulation
29. During the Council’s review of the required changes on December 6, 2010, and with the
understanding of the minimal customer benefits involved (estimated to be $51 annually for
each of the current 42 customers, or $2,154 in total) and potentially significant costs (estimated
over $300,000 for a fully automated billing solution), the Council directed staff to limit
implementation costs to $10,000 or 100 hours of staff time, whichever occurs first. The
proposed revisions to Utility Rule and Regulation 29 achieve this objective by continuing the
current practice of billing customers monthly and allowing customers to carry forward bill
credits valued at the retail rate. This avoids the need for the expensive reconfiguration of the
billing system. Staff will make manual adjustments for customers who do not want to carry
forward their bill credits at the end of the year.
BACKGROUND
AB 920 modified the Public Utilities Code’s terms and conditions for Net Energy Metering (PUC
Section 2827). AB 920 requires electric utilities to compensate customers with a solar
photovoltaic system or a wind turbine, who generate electricity in excess of their use for their
net excess generation in a 12-month period.
In December 2010, the City Council established a Net Surplus Electricity Compensation Rate
Schedule (E-NSE-1), and revised Utility Rule and Regulation (Rule) 29 governing Net Energy
Metering Service and Interconnection for qualifying customer-generators (CMR 425:10). At the
same time, the Council directed staff to limit implementation costs to not exceed $10,000 or
March 07, 2011 Page 2 of 4
(ID # 1403)
100 hours of staff time, whichever first occurs.
DISCUSSION
While it is feasible to implement all of the requirements to comply with AB 920 through a
comprehensive and fully automated billing solution, the external SAP consultant estimated its
cost to be $327,000. This cost is clearly not justified for the small number of customers
affected and the small dollar value of the total amount of net generation citywide. Staff has
identified a simplified solution that leaves most existing billing procedures in place.As staff
estimates the number of eligible customers and applicable compensation amounts to be small,
the proposed approach is expected to have no negative resource impact. The impact to Net
Energy Metering customers is also expected to be minimal. The elements of the solution
include the following:
1.Annual vs Monthly Billing
California laws and regulations pertaining to Net Energy Metering require CPAU to bill
residential and small commercial customers annually and provide monthly information
regarding their net consumption and charges owed. The law also states that utilities shall
permit customers to pay monthly for net energy consumed. Currently, CPAU bills its Net
Energy Metering Customers monthly, and provides information regarding their credits, if any, in
a separate letter to the customers. The reason is that the CPAU billing system is currently not
configured to show monthly credits as part of the bills issued. The implementation of annual
billing will require considerable staff time and resources that are not now supported by the
limited budget. Therefore staff recommends continuing with the current monthly billing
approach for all Net Energy Metering customers. Staff also proposes to continue with issuing
monthly statements to provide customers with information regarding cumulative bill credits.
2.Annual Settlement
California law requires annual settlements for each customer, but currently CPAU does not
perform annual settlement. Instead, CPAU carries forward customer bill credits indefinitely or
until customers use up such credits. While bills will continue to be issued monthly, settlement
of any net generation will be conducted annually starting January 2011. This will be done by
adding certain information into the billing system for Net Energy Metering customers. CPAU
will then manually make the necessary adjustments to correct for monthly billing and calculate
the credit for the small subset of net surplus generator customers,who have billing credits that
remain at the end of the customer’s annual cycle and who have elected the compensation
option.
3.Compensation of Net Surplus Energy
Starting January 1, 2011, and in compliance with AB 920, Net Energy Metering customers, who
have generated more electricity than they have consumed, have the option of being
compensated for annual net surplus electricity at the new E-NSE-1 rate, or electing to carry
forward excess kWh into the new settlement period to offset future electric charges.
March 07, 2011 Page 3 of 4
(ID # 1403)
While implementing the monetary compensation option is feasible and relatively
straightforward, carrying forward negative kWh values from one settlement period into the
next is complex and requires significant staff time for configuration and testing. Staff proposes
to monetize the kWh to be carried forward as a dollar value and offer it as a bill credit for
eligible customers. All Net Energy Metering customers choosing the carry forward option will
retain the dollar value of their bill credits towards future electric kWh charges. Customers who
chose compensation (cash out) will be compensated at the published E-NSE-1 rate. The first
option (carry forward) is currently more favorable for Net Energy Metering customers as it
values kWh credits at retail rates instead of the E-NSE-1 rate.
The resource impact of this proposal is small. For the twelve-month period ending June 2010,
there were 409 Net Energy Metering customers and only 42 of these had bill credits totaling
combined net surplus electricity of 36,871 kWh. The value of the 36,871 kWh at the E-NSE-1
rate of $0.05841 per kWh is $2,154. The valuation of the same net surplus electricity at the
average retail rate of $0.116 per kWh amounts to $4,277. This represents a gross resource
impact of $2,123 if all customers choose to carry forward the credit instead of the cash-out
option. This increased annual cost to CPAU of $2,123 is more than compensated for the
elimination of the requirement for an expensive billing solution compensated by the
elimination of the more costly implementation requirements.
Staff plans to evaluate the level of program participation and the value of carry forward credits
annually. If and when the resource impact for the proposed option reaches a cross-over point
between value offered to program participants versus implementation costs saved for non-
participants, staff will propose additional revisions to Rule 29.
Proposed changes to Rule 29 were not taken to the Finance Committee since the overall
changes due to AB 920 had already been reviewed by the Finance Committee before being
approved by the City Council in December 2010. Furthermore, the implementation of the net
surplus compensation must become effective with customer bills issued in March. This
additional change to Rule 29 is in response to the Council direction to limit implementation
costs to $10,000 of hours of staff time.
RESOURCE IMPACT
No material negative resource impact is expected due to the proposed changes to Rule 29.
POLICY IMPLICATIONS
This recommendation does not represent a change to current City policies.
ENVIRONMENTAL REVIEW
Adoption of this resolution does not meet the California Environmental Quality Act’s definition
of a project, pursuant to California Public Resources Code Section 21065. Therefore, no
environmental assessment is required.
March 07, 2011 Page 4 of 4
(ID # 1403)
Attachments:
·Attachment A: Resolution for Rule and Regulation 29 (DOC)
·Attachment B: Utility Rule and Regulation 29 (DOC)
Prepared By:Ipek Connolly, Sr. Resource Planner
Department Head:Valerie Fong, Director
City Manager Approval: James Keene, City Manager
ATTACHMENT A
Not Yet Approved
110125 jb 0073496
Resolution No. _________
Resolution of the Council of the City of Palo Alto Amending
Utility Rule and Regulation 29 (Net Energy Metering Service
and Interconnection) Governing Electric Service
The Council of the City of Palo Alto does hereby RESOLVE as follows:
SECTION 1.Pursuant to Section 12.20.010 of the Palo Alto Municipal Code, Rule
and Regulation 29 (Net Energy Metering Service and Interconnection) is hereby amended to read
as set forth in the amended Rule and Regulation 29, attached hereto and incorporated herein by
reference. The foregoing Rule and Regulation, as amended, shall become effective March 8,
2011.
SECTION 2.The Council finds that the adoption of this resolution does not meet the
definition of a project under California Public Resources Code Section 21065.Thus,no
environmental review is required.
INTRODUCED AND PASSED:
AYES:
NOES:
ABSENT:
ABSTENTIONS:
ATTEST:
______________________________________________________
City Clerk Mayor
APPROVED AS TO FORM:APPROVED:
______________________________________________________
Acting Deputy City Attorney City Manager
___________________________
Director of Utilities
___________________________
Director of Administrative
Services
ATTACHMENT B
NET ENERGY METERING SERVICE AND INTERCONNECTION
RULE AND REGULATION 29
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 0231-08-2011
Sheet No. 1
A.APPLICABILITY
1.This Rule and Regulation 29 is applicable to any customer-generator of CPAU who signs the
Net Energy Metering and Interconnection Agreement. A customer-generator includes:
(1) an “eligible customer-generator,”as that term is defined in Section 331(h) of
the California Public Utilities Code to refer to a residential or small
commercial Customer,and,
(2) a customer-generator who is other than a residential or small commercial
Customer, as defined,of CPAU, which includes a medium commercial and a
large commercial (industrial)Customer, who uses a solar or wind turbine
electrical Generating Facility,or a hybrid system of both.
The facility must be located on the customer-generator’s owned, leased or rented Premises,
must have a capacity of not more than one (1)megawatt (or 1,000 Kilowatts),must be
Interconnected and operated in parallel with CPAU’s Electric utility Distribution System, and
must be intended primarily to offset part or all of the customer-generator’s own Electric
Service requirements.
2.The customer-generator will be required to sign a Net Energy Metering and Interconnection
Agreement (NEMIA) or an agreement containing substantially the terms and conditions of
the referenced NEMIA and agree to be subject to applicable Utility Rates and Charges and
Utility Rules and Regulations in order to be eligible for Net Energy Metering Service
provided by CPAU.CPAU will make available all necessary forms and contracts for Net
Energy Metering Service for download from the Internet.
3.CPAU shall process a request for the establishment of Net Energy Metering and
Interconnection from the customer-generator within the time period not exceeding that for
Customers requesting new Electric Service. Such time period will not exceed thirty (30)
days from the date of (1) receipt of a completed Application form for Net Energy Metering
Service and Interconnection from the customer-generator, (2) Electric inspection clearance
from CPAU,and (3) building inspection clearance from the City of Palo Alto Building
Inspection Division.If CPAU is unable to process the request within the thirty-day period or
other applicable period, then CPAU shall notify the customer-generator of the reason for its
inability to process the request and the expected completion date.
ATTACHMENT B
NET ENERGY METERING SERVICE AND INTERCONNECTION
RULE AND REGULATION 29
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 0231-08-2011
Sheet No. 2
B.TERRITORY:
Within the jurisdictional boundaries of the City of Palo Alto.
C.SPECIAL CONDITIONS:
1.Net Energy Metering
Net Energy Metering means measuring the difference between the electricity supplied
through CPAU’s Electric utility Distribution System and the electricity generated by the
customer-generator’s facility and delivered to CPAU’s Electric utility Distribution System
over a specified twelve-month period.
2.Metering Equipment
Net Energy Metering shall be accomplished by using a single Meter capable of registering
the flow of electricity in two different directions. If the customer-generator’s existing Meter
is not capable of measuring the flow of electricity in two directions, then the customer-
generator shall be responsible for all expenses involved in purchasing and installing a Meter
that is able to measure electricity flow in two directions. In lieu of one Meter, an additional
Meter to monitor the flow of electricity in each direction may be installed with the consent of
the customer-generator, at the expense of CPAU. The additional Meter shall be used onlyto
provide the information necessary to accurately bill or credit the customer-generator and/or to
collect solar or wind Electric generating system performance information for research
purposes.
3.Billing for Net Energy Metering
a.At the end of each twelve-month period following the date of Interconnection of the
facility, or for a Customer with a date of Interconnection of the facility commencing
prior to February 1, 2010, the day after CPAU’s receipt of the Customer’s net surplus
electricity election form,and at each annual settlement anniversary date thereafter,
ATTACHMENT B
NET ENERGY METERING SERVICE AND INTERCONNECTION
RULE AND REGULATION 29
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 0231-08-2011
Sheet No. 3
CPAU will determine whether the customer-generator is a net electricity consumer or
a net surplus customer-generator, as such terms are defined in California Public
Utilities Code sections 2827(h)(2) and 2827(h)(3) during that period. CPAU will bill
the customer-generator for the electricity used during that twelve-month period,
whether the customer-generator is considered a net electricity consumer or a net
surplus customer-generator.
b.At the end of the twelve-month period, where the electricity supplied by CPAU
during that period exceeds the electricity generated by the customer-generator’s
facility during that same period, the customer-generator is a net electricity consumer
during that period, and the customer-generator will owe compensation to CPAU.
The compensation shall be calculated according to the terms and conditions of the
NEMIA or other applicable contract referred to in Section A above and/or to the
applicable utility rates and Charges for baseline quantity of electricity, to which class
of utility Customers the customer-generator would be assigned. The net balance of
money owed by the net electricity consumer to CPAU will be carried forward as a
monetary value until the end of the twelve-month period in the case of a residential or
small commercial Customer, or the residential or small commercial Customer may
elect to pay the balance due at the end of the month immediately following the
twelve-month period. If the customer-generator is a medium commercial or large
commercial (industrial) Customer, then payment of any net balance due shall be
made on a monthly basis.
c.At the end of the twelve-month period, where the electricity supplied by the
customer-generator’s facility during that period exceeds the electricity supplied by
CPAU during that period, the customer-generator is a net surplus customer-generator
during that period. Upon the City’s receipt of the customer-generator’s affirmative
election, CPAU either will provide net surplus electricitycompensation, as such term
is defined in California Public Utilities Code section 2827(b)(8), in accordance with
Electric Utility Rate Schedule E-NSE-1, for any net surplus electricity generated
during the prior twelve-month period, or will allow bill credits due to the net surplus
electricity to be applied as a credit for electricity (expressed in Kilowatt-hours)
related charges subsequently supplied by CPAU to the customer-generator. If the
customer-generator fails to make an affirmative election to receive Service pursuant
ATTACHMENT B
NET ENERGY METERING SERVICE AND INTERCONNECTION
RULE AND REGULATION 29
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 0231-08-2011
Sheet No. 4
to net surplus electricity compensation, then CPAU shall retain any excess electricity
(expressed in Kilowatt-hours) generated during the prior twelve-month period, and it
shall not be obligated to pay net surplus electricity compensation nor shall it be
obligated to allow the application of net surplus electricity to be used as a credit for
Energy subsequently supplied by CPAU.
d.CPAU will allow a Customer to change the election option once each settlement
period provided that the Customer provides notice to CPAU one month prior to
the beginning of new settlement period.
e.CPAU shall provide the customer-generator with net electricity consumption
information with each monthly bill; that information shall include either the current
monetary balance owed to CPAU or the current amount of excess electricity
produced since the last twelve-month period.
f.A Residential or Small Commercial Customer may elect to pay the electricity Charge
(measured in Kilowatt-hours) portion of the billing statement each month, or at the
annual settlement. For a Residential or Small Commercial Customer who does not
elect billing at the annual settlement or medium commercial or large commercial
(industrial) Customer, electricityCharges are due and payable per applicable monthly
billing schedules. For the customers electing billing at the annual settlement, tThe
customer-generator’s bill payment will not be considered delinquent, unless the
customer-generator does not pay a final billing statement within twenty (20) days of
the date of issuance of that final billing statement.
g.For Residential Customers electing single billing for the twelve-month settlement
period, for each monthly period, the net balance of moneys owed to the electric
service provider for net consumption of electricity or credits owed to the customer-
generator for net generation of electricity shall be carried forward until the end of
each twelve-month period. Any excess kilowatt-hours generated during the billing
cycle shall be carried over to the following billing period, calculated according to the
procedures set forth in this section, and appear as a credit on the customer-generator's
account, until the end of the annual period when paragraph (3) of subdivision (b)
shall apply.
ATTACHMENT B
NET ENERGY METERING SERVICE AND INTERCONNECTION
RULE AND REGULATION 29
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 0231-08-2011
Sheet No. 5
h.For all customer-generators on monthly billing, and for each monthly period, the net
balance of moneys owed to the electric service provider for net consumption of
electricity shall be paid in accordance with the electric service provider's normal
billing cycle, except that if the residential and small commercial customer-generator
is a net electricity producer over a normal billing cycle,any excess kilowatt-hours
generated during the billing cycle shall be carried over to the following billing period,
calculated according to the procedures set forth in this section, and appear as a credit
on the customer-generator's account, until the end of the annual period when
paragraph (3) of subdivision (b) shall apply.
h.If an electric service provider providing net metering to a residential or small
commercial customer-generator ceases providing that electrical service to that
customer during any twelve-month period,and the customer-generator enters into a
new net metering contract or tariff with a new electric service provider, the twelve-
month period,with respect to that new electric service provider, shall commence on
the date on which the new electric service provider first supplies electric service to
the customer-generator.
i.If the customer-generator terminates the contractual relationship with CPAU, then
CPAU shall reconcile the customer-generator’s consumption and production of
electricity during any part of the twelve-month period following the last annual
settlement and reconciliation.If the electricity supplied by the customer-generator’s
facility during that period exceeds the electricity supplied by CPAU during that
period, the customer-generator will be deemed a net surplus customer-generator
during that period, and compensation will be provided in accordance with Electric
Utility Rate Schedule E-NSE-1.If the electricity supplied by CPAU during that
period exceeds the electricity generated by the customer-generator’s facility during
that same period, the customer-generator is a net electricity consumer during that
period, and the customer-generator will owe compensation to CPAU based upon the
applicable Electric Rate Schedule.
4.Safety Standards
ATTACHMENT B
NET ENERGY METERING SERVICE AND INTERCONNECTION
RULE AND REGULATION 29
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 0231-08-2011
Sheet No. 6
The facility will meet all applicable federal, state and local safety and performance standards,
including those established by the National Electrical Code, the Institute of Electrical and
Electronic Engineers, and accredited testing laboratories such as Underwriters Laboratories
and, as applicable, the rules of the California Public Utilities Commission regarding safety
and reliability. The customer-generator whose facility meets those standards and rules will
not be required to install additional controls, perform or pay for additional tests, or purchase
additional liability insurance.
5.Interconnection Standards (Design)
a. Customer-Generator will conform to the applicable National Electric Code (NEC)
Standards [NEC 690] and applicable building codes.
b.Customer-Generator will have a dedicated circuit from the inverter to the Service
panel with a circuit breaker or fuse [NEC 690-64(b)(1)].
c. Customer-Generator's overcurrent device at the Service panel will be marked to
indicate solar power source [NEC 690-64(b)(4)].
d.Customer-Generator's inverter will establish the following minimum specifications
for Parallel Operation with CPAU’s Electric utility Distribution System.
e.Customer-Generator will install a visible break, lockable AC disconnect switch in the
dedicated circuit to the inverter. This switch will be located where it is easily
accessible by CPAU personnel and will be equipped with a CPAU padlock [CPAU
Rule and Regulation 27].
f.Customer-Generator’s inverter will be UL 1741-aprpoved and have the following
specifications for Parallel Operation with CPAU’s Electric utility Distribution
System:
1.Inverter output will automatically disconnect from CPAU’s utility source
upon the loss of CPAU’s utility voltage and will not be reconnected until at
least five (5) minutes after normal utility voltage and frequency have been
restored [UL 1741].
2.Inverter will automatically disconnect from CPAU’s utility source within 120
ATTACHMENT B
NET ENERGY METERING SERVICE AND INTERCONNECTION
RULE AND REGULATION 29
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 0231-08-2011
Sheet No. 7
cycles (2 seconds)if CPAU’s utility voltage isles than 106 volts or greater
than 132 volts on a 120-volt base [UL 1741].
3.Inverter will automatically disconnect from CPAU’s utility source within 10
cycles (0.17 seconds) if CPAU’s utility frequency fluctuations is less than
59.3 hertz or greater than 60.5 hertz [UL 1741] cycle.
4.Inverter output will comply with IEEE 519 standards for harmonic
distortion [CPAU Rule and Regulation 27].