HomeMy WebLinkAboutStaff Report 1641City of Palo Alto (ID # 1641)
Finance Committee Staff Report
Report Type:Meeting Date: 6/7/2011
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Summary Title: Renewable Feed-in Tariff Policies and Guidelines
Title: Approval of Policies and Guidelines for a Renewable Energy Feed-in Tariff
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 the proposed Renewable Energy Feed-in-Tariff Policies
and Guidelines (Attachment A).
Executive Summary
A Feed-in-Tariff (FIT) is a purchasing mechanism that enables owners of small local renewable
generators (primarily rooftop solar panels) to sell power to the electric utility for a fixed price.
The electric utility is in turn able to include the energy in its supply portfolio and count it
towards its Renewable Portfolio Standard (RPS). Staff recently completed an initial evaluation
of renewable FITs as a method of purchasing renewable power and is now proceeding to design
a program. The attached policies and design guidelines reflect staff’s proposed approach to FIT
program development. If the policies and design guidelines are approved, staff would return to
City Council for approval of the detailed program later this year with the goal of launching the
program in early 2012.
Background
On March 7, 2011, Council unanimously approved the Long-term Electric Acquisition Plan
(LEAP) Objectives, Strategies and Implementation Plan (Staff Report 1317). LEAP Strategy #3
(RPS) and Strategy #4 (Local Generation) require the evaluation of the use of FITs to meet the
City of Palo Alto (City)’s RPS goal of supplying 33% of its power from renewable sources by 2015
and to encourage the development of local ultra-clean generation. Earlier this year staff
evaluated the use of FITs in Palo Alto and held study sessions with the UAC. Based on that
evaluation staff proceeded with the development of the proposed FIT Policies and Guidelines
(Attachment A), which were reviewed by the UAC on April 6, 2011.
Discussion
The City has an RPS goal to supply 33% of its power from renewable sources by 2015 while not
exceeding a 0.5 ¢/kWh impact on rates. Power from currently committed renewable resources
is expected to meet approximately 30.8% of the City’s annual electric energy needs in 2015
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leaving a gap of approximately 23,000 MWh/year, or 2.2% of load, to meet the 33% RPS goal by
2015. Part of this gap could be filled with power procured through a renewable FIT program.
The renewable FIT program that staff is designing will be “value-based”, meaning that it is
based on the value of the energy to the City. The alternative is a “cost-based” FIT, which is
based on the cost to build and operate the generator and is designed to guarantee a rate of
return to the developer even if it means setting the rate higher than the value of the energy to
the utility. Unlike a cost-based FIT, a value-based FIT will not increase the City’s cost of
renewable power over other power purchasing methods because it is based on the market
value of the power.
Given current market prices, if the remainder of the City’s RPS goal were achieved using only
local renewable sources purchased through the FIT program, staff believes the total cost of the
City’s renewable power supply would have less than a 0.5 ¢/kWh impact on rates, the goal
included in the LEAP. It is worth noting, though, that a FIT program will have higher contract
and program administration costs than the City’s traditional purchasing methods because it
involves many small contracts rather than fewer larger ones.
Under a FIT program, the City will offer a fixed long-term rate and standard power purchase
agreement (PPA) to any developer of an eligible generator in Palo Alto. Eligible technologies
will initially include solar, wind, and biogas fueled generators. If developers’ projects fit the
program guidelines, they would be able to sign up for the standard contract and rate unless the
program is already fully subscribed. For example, if the City offered a program with the
following terms: a fixed rate of 15 cents per kilowatt-hour (¢/kWh) for 20 years, any solar
developer willing to build a project in Palo Alto by the deadline, follow the program rules, and
agree to the standard contract terms could apply for the program and sign a 20-year PPA to sell
power at 15 ¢/kWh so long as there was still capacity remaining in the program.
The proposed Renewable FIT Policies and Guidelines (Attachment A) will be the basis for the
program. Below are some of the key features of the Polices and Guidelines:
1.The FIT will be value based.
2.A standard non-negotiable contract will be used.
3.Fixed rates will be available for solar, wind, and biogas-fueled generators.
4.Rates will take into account the value of the project to the utility, including the
renewable attributes, avoided transmission and distribution costs, local capacity value,
and the time of day the technology typically generates electricity.
5.The contracts will require the transfer of all energy, green attributes, and capacity
attributes (if applicable) to the utility.
The FIT program differs from the Request for Proposal (RFP) process, the method the City has
used to-date to purchase renewable power. In an RFP process several developers offer
projects, then the utility chooses the developers with the lowest priced feasible projects, and
negotiates PPAs with each one. An RFP process has worked well for obtaining contracts from
larger projects, but the costs and uncertainty associated with preparing a bid are too high for
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small local developers. A FIT program will reduce costs and provide local renewable project
developers certainty because of the fixed long-term rate, the standard contract, and the fact
that it is open to any developer rather than only those who are selected through an RFP
process.
In addition to enabling smaller developers to supply power to the City, a FIT program can
deliver benefits to other stakeholders as well, including:
·Benefits to the utility, such as the fact that renewable energy is generated locally, meaning
lower transmission costs than for remote renewable resources. Also, local generation can
help maintain regional (Bay Area) electric grid stability, which can result in financial benefits
to the utility
·Benefits to the site owner, including additional revenue from power sales or roof rental. A
FIT can also provide a way for owners of multi-unit commercial rental properties to take
advantage of distributed generation. Under traditional incentive programs like the City’s
Photovoltaic (PV) Partners program, the solar projects are typically built behind the
customer meter, offsetting their consumption. This benefits the utility customer rather
than the building owner, meaning there is less incentive for the building owner to install
solar panels.
·Benefits to the community, such as the potential for money spent on renewable power to
return to the community. The community can also take pride in generating renewable
power locally.
Timeline
Upon Council approval of the renewable FIT Policies and Guidelines, staff will proceed with
program design and bring a proposal to Council in December 2011. The program will include
fixed rates, the standard contract, program rules (such as minimum system size and deadlines
for project progress), the amount of capacity to be procured, and any other necessary changes
to the City of Palo Alto Utilities (CPAU) rules and regulations, such as interconnection
agreements or metering requirements. Staff’s objective is to obtain Council approval in time to
launch the program in early 2012.
Commission Review and Recommendation
Staff held two study sessions related to FITs with the UAC, one on February 2, 2011 and the
second on March 2, 2011. At these meetings the UAC supported the adoption of a FIT for local
renewable generators as long as it was based on the value of the energy to the utility and not
on the cost of generation. The proposed Renewable FIT Policies and Guidelines are aligned
with the UAC’s preference.
On April 6, 2011 the UAC reviewed the proposed policies and design guidelines for a value-
based FIT and unanimously recommended that the Council approve them. The minutes of that
meeting are provided as Attachment B.
Resource Impact
Aside from the staff time associated with designing and launching the program, there wil be
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some additional ongoing cost associated with program administration and interconnection and
permitting of new solar projects. The costs will depend significantly on the number of projects
that participate in the program, and may range from a negligible staff impact to 2/3 of an Full-
Time Equivalent or more. Most of these costs are related to permitting and interconnection,
meaning the costs would be recovered by the City’s existing permit fees. At this time staff does
not anticipate a need for additional permanent staffing, but will return with a more in-depth
projection of costs and staff time associated with the program when returning with the detailed
program design this fall. Any necessary additional resources would be requested via a Budget
Amendment Ordinance or through the Budget Process.
Policy Implications
The proposed Renewable FIT Policies and Guidelines help meet the Council-approved objectives
under LEAP Strategy #3 (Renewable Portfolio Standard, or RPS) and LEAP Strategy #4 (Local
Generation) and support the Council-approved Energy Risk Management Policies, and
Comprehensive Plan Goal N-9 (a clean, efficient, competitively-priced energy supply that makes
use of cost-effective renewable resources).
Enviromental Review
Approval of the proposed Renewable FIT Policies and Guidelines does not meet the definition
of a project pursuant to Public Resources Code Section 21065, thus no California Environmental
Quality Act review is required.
Attachments:
·Attachment A: Proposed Renewable FIT Policies and Design Guidelines (PDF)
·Attachment B: Excerpted Draft UAC Minutes of April 6, 2011 (PDF)
Prepared By:Jon Abendschein, Resource Planner
Department Head:Valerie Fong, Director
City Manager Approval: James Keene, City Manager
City of Palo Alto Utilities (CPAU)
Proposed Renewable Energy Feed-In-Tariff (Renewable FIT) Program Policies and
Guidelines
POLICIES
1. The Renewable FIT program’s objective is to maximize fulfillment of the City of Palo
Alto (City)’s Renewable Portfolio Standard (RPS) from local renewable sources.
2. Enrollment will be capped at the amount of energy projected to be required to fulfill the
City’s RPS.
3. Eligible resources will include those that are deemed renewable by the California Energy
Commission (CEC) and that can be included in meeting RPS goals including solar
photovoltaic (PV) systems, wind, and biogas-fueled generators.
4. Eligible resources are to be located in the City and connected to the distribution system
on CPAU’s side of customer meters.
5. The Renewable FIT rate, set as a fixed-price in cents per kilowatt-hour (kWh) for a
twenty-year term, will be based on CPAU’s avoided energy and capacity cost (i.e., value-
based) and may vary by load shape for each renewable resource type.
6. The agreement between CPAU and program participants will be a non-negotiable,
twenty-year standard contract available to all eligible resources.
7. Program participants will be responsible for direct costs associated with the project (such
as interconnection and metering).
8. Projects with a Renewable FIT will not be eligible for a net metering tariff or incentives
under the PV Partners Program, the Power from Local Ultra-clean Generation Incentive
(PLUG-In) Program, or any other CPAU-funded incentive program.
9. City Council must approve the Renewable FIT rates, standard contracts and updates.
PROGRAM DESIGN GUIDELINES
1. The methodology for calculating avoided cost should include all of the following that
apply to the technology in question:
a. The value of renewable energy (including the value of avoided carbon);
b. Local capacity value related to the applicable characteristics of the technology;
c. Avoided transmission charges, transmission losses, and ISO charges;
d. Avoided distribution losses; and
e. Any other avoided costs attributable to local renewable generation
2. A standard contract will be established and published. The term will be 20 years.
3. A program cap will be established.
4. Maximum and minimum limits on individual project sizes may be used to limit the
number of projects or the risk associated with the operation of any single project. These
may be differentiated by technology type.
5. Updates to rates, contract terms, or program size should occur at regular scheduled
intervals or should involve substantial advance notice to project developers.
6. Metering requirements will be designed to meet any applicable California Independent
System Operator (CAISO), Northern California Power Agency (NCPA), and City
operational requirements.
7. Interconnection rules will be established or modified to ensure FIT projects meet all City,
NCPA, and CAISO operational requirements. Interconnection rules may be modified on
a schedule independent of the FIT update schedule.
8. The FIT program will be designed similarly to FIT programs in other utility service areas
where desirable, reasonable and feasible.
ATTACHMENT B
EXCERPTED MINUTES OF UTILITIES ADVISORY COMMISSION
MEETING – APRIL 6, 2011
ITEM 1: ACTION: Proposed Policies and Guidelines for Renewable Energy Feed-In-Tariffs
Utilities Resource Planner Jon Abendschein provided a presentation summarizing the key points
in the development and approval process of a Renewable Feed-in-Tariff (FIT) program in Palo
Alto to meet the Long-term Electric Acquisition Plan (LEAP) Objectives for Renewable
Portfolio Standard (RPS) and Local Generation and requested that the UAC recommend Council
approve the Proposed Policies and Guidelines for Renewable Energy Feed-In-Tariffs.
During his presentation, Abendschein identified key policy and guidelines which would be used
to guide the development of the Renewable FIT program, including:
Objective of the Renewable FIT program is to meet the City’s RPS of 33% by 2015.
Initial eligible technologies would be solar photovoltaic (PV), wind, and biogas-fueled
generators.
A FIT rate based on the City’s avoided (value-based) cost and fixed for 20-years.
A standard, non-negotiable, Power Purchase Agreement (PPA).
Abendschein also touched on several program design elements and details that staff is currently
working on with other City departments and Utilities divisions related to program size and limits,
development of power purchase agreements, fees and FIT rates, and program administration.
Abendschein laid out the next steps including seeking Finance Committee and Council approval
of the proposed policies and guidelines in June 2011 and July 2011, respectively. Upon Council
approval of the policies and guidelines and development of the program details, staff will return
to the UAC, Finance Committee and Council in the fall of 2011 for approval of the Renewable
FIT Program including the PPA and FIT rate along with a request for delegation of authority to
the City Manager to execute FIT contracts.
Commissioner Melton asked why staff was pursuing a FIT for biogas-fuel generation and what
opportunities exist. Abendschein explained that biogas-fueled generation is a CEC approved
RPS technology and that it is essentially a fuel-cell that burns natural gas that has been injected
into the gas system at a different location and nominated to the specific fuel-cell generator.
Abendschein mentioned that there has been some interest in this technology in Palo Alto, but that
it was not clear whether it would be economic in the near term.
Commissioner Foster asked staff not to limit the program to the RPS of 33% by 2015, but rather
use the ½ cent premium as the cap. He asked for clarification on the list of avoided costs in the
proposed FIT policies. Abendschein clarified that the items listed were the ones staff expected to
use in developing the feed-in tariff, but that future policy changes could result in additional items
being added to the list. Additionally, Commissioner Foster asked if staff believed 4 MW of FITs
could be achieved per year and why staff was limiting the FIT technologies to PV, biogas-fueled
generators and wind. Abendschein explained that 4 MW is an optimistic projection for Palo
Alto. With regards to technology to include within the program, Abendschein explained that
staff is trying to keep the program simple in the first year of the program.
Commissioner Keller asked why staff was recommending that program be limited to a 20-year
PPA. Abendschein responded that staff will look at what other utilities are doing during the
design phase and may recommend alternative durations when staff returns for approval of the
program. Utilities Director Fong emphasized that staff is trying to keep the program simple in
the beginning and can expand features as we gain experience.
Commissioner Cook clarified that he works in the solar industry for a manufacturer of larger-
scale PV systems with the smallest size being 20 MW and therefore did not feel that there was
any conflict of interest. He also asked why staff was considering a 25% phase-in per year of the
program cap and why staff would develop different FIT rates by technology. Abendschein
explained that staff has not developed a recommendation yet for the total program cap or the
amount of capacity released each year, but merely cited 25% as an example. Abendschein
mentioned that different technologies might have different FIT rates because of the different
value each technology provides as a result of varying generation profiles. For example, PV
generation generally coincides with higher market price conditions, whereas biogas-fueled
generation is a base-load resource generating in all market price conditions. Commissioner Cook
asked whether staff was talking to other municipalities about their FITs. Abendschein said that
they were.
Chair Waldfogel suggested staff work closely with the Building Department to ensure they
understand the Renewable FIT program including how it differs from the City’s current PV
Partners program. Abendschein mentioned that staff has reached out to key staff within the
Building Department to develop a program design team. Commissioner Waldfogel asked
whether system upgrades would be necessary and who would bear the cost. Abendschein said
staff would be working with the Utilities Engineering Division to assess the need for upgrades
and define who would bear the costs.
ACTION:
Commissioner Melton motioned to recommend Council approve the proposed Renewable FIT
policies and guidelines. Commissioner Cook seconded the motion. The motion carried
unanimously (6-0) with Commissioner Eglash absent.