HomeMy WebLinkAboutStaff Report 6449
City of Palo Alto (ID # 6449)
City Council Staff Report
Report Type: Consent Calendar Meeting Date: 1/11/2016
City of Palo Alto Page 1
Summary Title: Local Solar Plan and PV Partners Update
Title: Finance Committee Recommendation to Continue the PV Partners
Program Until the State Legislative Requirements Set Forth in the California
Million Solar Roof Bill Have Been Fulfilled
From: City Manager
Lead Department: Utilities
Recommendation
Staff, the Utilities Advisory Commission (UAC), and the Finance Committee recommend that the
City Council continue the PV Partners program for rebates for customer-sited solar photovoltaic
(PV) systems until the state legislative requirements set forth in California Million Solar Roofs
Bill (SB1) have been fulfilled.
Executive Summary
On April 22, 2014, Council adopted the Local Solar Plan, which establishes the goal of meeting
4% of the City’s energy needs from local solar by 2023 and outlines a set of diverse strategies to
achieve it within a set of guiding objectives. The Local Solar Plan provides a holistic framework
incorporating all market segments and short- and long-term approaches. The plan further seeks
to do so in a cost-effective manner. Prior programs, incentives, and policies involving solar
installed in the City are integrated into the Local Solar Plan strategies, and new programmatic
areas are identified for staff research and development.
The City has long supported local PV and the Local Solar Plan demonstrates the City’s continued
commitment to encourage local PV installations. The PV Partners program was the City’s first
program to encourage local PV as it was established in 1999 to provide rebates for customer-
sited solar PV systems for both residential and commercial customers. In 2006, California
adopted the Million Solar Roofs Bill (Senate Bill 1 or SB1), and funding for PV Partners was
increased by $13 million to meet the City’s legislative obligations. All residential rebate funds
were completely reserved as of August 2014 and limited funds currently remain available for
commercial customers. Staff recommends continuing the program only until all legislative
requirements have been fulfilled and not expanding residential PV rebate funds for four
primary reasons: 1) the goals of SB1 to facilitate statewide deployment of 3,000 megawatts
(MW) of solar and create a self-sustaining solar market have already been achieved, 2)
City of Palo Alto Page 2
alternate solar procurement models such as a group-buy program model have resulted in lower
system prices for customers than systems installed with PV Partners rebates, 3) the
administrative costs of the rebate program for both City staff and solar installers are substantial
compared to alternate solar procurement models, and 4) re-opening rebates to residential
customer would result in disruptive market dynamics and messaging.
Instead of expanding residential rebates for customer-sited photovoltaics, staff will continue to
encourage local solar PV installations through the initiatives identified in the Local Solar Plan.
Specifically, staff will focus its efforts to launch a community solar program that would allow
anyone to participate in the solar movement, and to launch a solar donation program to help
local schools and non-profits install solar systems.
Background
The report provided to the Finance Committee for its December 1, 2015 meeting (Staff Report
6213) provides an update on the state of solar installed in Palo Alto and a detailed status of all
Local Solar Plan implementation efforts to date, including the status of three program initiatives
(a community solar program, a solar group-buy program, and a solar donation program) and
current efforts towards implementing net energy metering (NEM) incentives. The report
(provided as Attachment 1) includes a strategy-by-strategy update of all implementation efforts
that have been completed to date and that are planned for the near term.
Discussion
As of August 2014, all residential rebate funds for solar PV systems through the PV Partners
program were reserved with limited funds remaining for commercial customers. On March 17,
2015, the Finance Committee requested that staff return to the Committee for a discussion
about the options for continuing PV Partners rebate funds for residential use—either by adding
new funds for rebates or by shifting the remaining rebate funds not yet reserved by commercial
customers to residential customers. Members of the Committee questioned whether additional
rebates for residents might yield more solar deployment than funds directed to solar
developers through the Palo Alto CLEAN program.
Staff recommends retiring PV Partners after the City’s legislative requirements set by SB1 have
been achieved, and not shifting funds from the commercial customer class to the residential
customer class for four primary reasons, which are summarized below
1. SB1 goals will have been met;
2. The objective of lowering the cost of solar can be achieved in other ways;
3. PV Partners Program administrative costs are high; and
4. Making rebate funds available again to residential customers will result in disruptive
market dynamics.
The reasons and the alternatives are discussed in more detail in the report provided for the
Finance Committee’s December 1, 2015 meeting (Attachment 1).
City of Palo Alto Page 3
Committee Review
The UAC reviewed staff’s recommendation at its October 7, 2015, meeting and voted
unanimously to support staff’s recommendation. The minutes to the UAC meeting are provided
as Attachment 2.
The Finance Committee reviewed the recommendation at its December 1, 2015, meeting.
Noting that residents have continued to install solar PV without rebates, one Committee
member asked if the program could be stopped now with the remaining funds devoted to
another program, such as electrification. Staff advised that all program funds must be spent to
comply with the SB1 mandate. Another Committee member asked if the successful
discount/group buy program (Peninsula SunShares) that lowered costs could be repeated. Staff
replied that it is currently focusing on designing a community solar program and a solar
donation program, but that perhaps after the federal tax incentives expire, a new group buy
program could be developed. After a number of clarifying questions, the Finance Committee
expressed support for the recommendation and voted unanimously (4-0) to recommend
Council approve the recommendation. Action minutes from the December 1, 2015, Finance
Committee meeting are provided as Attachment 3.
Resource Impact
There is no change to budgets, planned expenditures or staff resources as a result of staff’s
recommendation to discontinue the PV Partners program once solar legislative mandates have
been met. Administering the PV Partners program requires dedicated staff resources through
at least 2020 to disperse all remaining rebate funds1. Once all program funding has been
reserved by customers and no more new applications are being processed, the ongoing staff
resource impact is anticipated to be 0.02 FTE to process performance-based incentive (PBI)
payments that are paid out over a five-year time frame. After all program funding has been
reserved, available staff resources will be reallocated to other solar program initiatives. If,
however, Council desires to add new rebates for residential solar PV, there would be a budget
and rate impact for the Electric Fund.
Policy Impact
The recommendation to continue the PV Partners program only until solar legislative mandates
have been met does not conflict with any City policy. The Local Solar Plan supports the City’s
environmental sustainability goals, including those set out in the Council-approved 2011
Utilities Strategic Plan and the City’s Sustainability and Climate Protection Plan. Fulfilling our
SB1 legislative mandates through PV Partners will help promote solar development and is
consistent with the Carbon Neutral Plan, the Local Solar Plan, and State and local efforts to
promote distributed solar projects.
1 For PV Partners reservations that are already approved, the last estimated performance-based incentive (PBI)
payment date is 2020. However, if staff receives an application for all or a portion of the remaining rebate funds
as a part of a new construction project, then the project may require PBI payments through 2022.
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Environmental Impact
Discontinuing the PV Partners program once solar legislative mandates have been met does not
meet the California Environmental Quality Act’s (CEQA) definition of “project” under California
Public Resources Code Sec. 21065, thus no environmental review is required.
Attachments:
Attachment A: Finance Committee Staff Report 6213 Local Solar Plan and PV Partners
Program Update (PDF)
Attachment B: 12-1-2015 FCM Minutes Excerpt Number 3 (DOC)
City of Palo Alto (ID # 6213)
Finance Committee Staff Report
Report Type: Action Items Meeting Date: 12/1/2015
City of Palo Alto Page 1
Council Priority: Environmental Sustainability
Summary Title: Local Solar Plan and PV Partners Program Update
Title: Utilities Advisory Commission Recommendation to Continue the PV
Partners Program Until the State Legislative Requirements Set Forth in the
California Million Solar Roof Bill Have Been Fulfilled
From: City Manager
Lead Department: Utilities
Recommendation
Staff and the Utilities Advisory Commission (UAC) recommend that the Finance Committee
recommend that the City Council continue the PV Partners program for rebates for customer-
sited solar photovoltaic (PV) systems until the state legislative requirements set forth in
California Million Solar Roofs Bill (SB1) have been fulfilled.
Executive Summary
On April 22, 2014, Council adopted the Local Solar Plan, which establishes the goal of meeting
4% of the City’s energy needs from local solar by 2023 and outlines a set of diverse strategies to
achieve it within a set of guiding objectives. The Local Solar Plan provides a holistic framework
incorporating all market segments and short- and long-term approaches. The plan further seeks
to do so in a cost-effective manner. Prior programs, incentives, and policies involving solar
installed in the City are integrated into the Local Solar Plan strategies, and new programmatic
areas are identified for staff research and development.
This report provides an update on the state of solar installed in Palo Alto and a detailed status
of all Local Solar Plan implementation efforts to date, including the status of three program
initiatives (a community solar program, a solar group-buy program, and a solar donation
program) and current efforts towards implementing net energy metering (NEM) incentives.
Preliminary results from a solar potential analysis confirm that the overarching Local Solar Plan
goal of meeting 4% of the City’s electricity needs is achievable with current programs (PV
Partners, Palo Alto CLEAN program, and NEM), continued falling solar system prices, and the
planned community solar and solar donation programs. The City’s progress toward meeting the
ATTACHMENT 1
City of Palo Alto Page 2
Local Solar Plan goal will be re-evaluated and communicated on an ongoing basis as current and
future programs are brought forward for UAC, Finance Committee, and Council review.
The City has long supported local PV and the Local Solar Plan demonstrates the City’s continued
commitment to encourage local PV installations. The PV Partners program was the City’s first
program to encourage local PV as it was established in 1999 to provide rebates for customer-
sited solar PV systems for both residential and commercial customers. In 2006, California
adopted the Million Solar Roofs Bill (Senate Bill 1 or SB1), and funding for PV Partners was
increased by $13 million to meet the City’s legislative obligations. All residential rebate funds
were completely reserved as of August 2014 and limited funds currently remain available for
commercial customers. Staff recommends continuing the program only until all legislative
requirements have been fulfilled and not expanding residential PV rebate funds for four
primary reasons: 1) the goals of SB1 to facilitate statewide deployment of 3,000 megawatts
(MW) of solar and create a self-sustaining solar market have already been achieved, 2)
alternate solar procurement models such as a group-buy program model have resulted in lower
system prices for customers than systems installed with PV Partners rebates, 3) the
administrative costs of the rebate program for both City staff and solar installers are substantial
compared to alternate solar procurement models, and 4) re-opening rebates to residential
customer would result in disruptive market dynamics and messaging.
Instead of expanding residential rebates for customer-sited photovoltaics, staff will continue
the initiatives identified in the Local Solar Plan to serve previously under-served residential and
non-residential customers. Specifically, staff will focus its efforts to launch a community solar
program that would allow anyone to participate in the solar movement, and to launch a solar
donation program to help local schools and non-profits install solar systems.
Background
The City has been a leader in local solar development starting in 1980 when it launched a solar
hot water heating program. California State law (Assembly Bill 1470) established a requirement
in 2007 for all natural gas utilities to offer rebates for solar water heating systems. In 2008, the
City of Palo Alto Utilities (CPAU) launched the Solar Water Heating (SWH) Program which
provides rebates to customers who install qualifying solar water heating systems that offset
energy used by an existing water heater or boiler for domestic water heating uses. The State’s
goal is to install 200,000 solar water heating systems by 2017, and CPAU’s proportionate share
is approximately 530 systems. The City’s 2007 Climate Protection Plan established a goal of
achieving 1,000 systems by 2020. As of August 1, 2015, $281,370 in rebates have been issued
under the program for a total of 58 systems. The slow uptake is due in part to the poor
customer economics. The program is expected to continue through 2017 with incentive levels
decreasing over the program lifetime.
In 1999, the City launched its first solar PV system rebate program called PV Partners to
encourage residents and businesses to install solar PV systems. In 2006, California adopted SB1,
the “Million Solar Roofs” bill, which requires that all load serving entities such as CPAU provide
City of Palo Alto Page 3
incentives in the form of rebates to meet the goal of installing 3,000 megawatts (MW) of solar
PV systems in California by 2017. The City’s proportionate share of the statewide goal is 6.5
MW by 2017. To meet the SB1 requirements, the CPAU increased the PV Partners Program
budget to $13 million over ten years, with proportions of the funding allocated across four
customer classes: residential, small and medium commercial, large commercial and non-
profit/public sector.
Table 1 provides a summary of the solar PV installations through the PV Partners program
through August 1, 2015:
Table 1: PV Partners Program Summary
PV Partners Program Capacity (MW)
Installed Between
1999 and 2006
(Prior to SB1)
Installed
Under SB1 as
of 8/1/15
Pending Projects/
Reserved
Capacity
Unreserved
Capacity
Total PV
Partners
Program
Residential 0.62 1.89 0.05 0 2.56
Commercial 0.31 3.76 0.52 0.91 5.50
TOTAL 0.93 5.65 0.57 0.91 8.06
As of August 1, 2015, 6.7 MW of solar PV has been installed1 on 785 customer sites and an
additional 0.57 MW of new solar PV installations at 14 customer sites have confirmed PV
Partners rebates and are pending completion. All residential rebate funds were reserved as of
August 2014. Currently, $1.1 million in funds remain unreserved for commercial solar PV
systems. In the unlikely event that any of the PV Partners funds remain unreserved at the end
of 2017, marking the end of the 10-year SB1 program, the funds will return to the Electric Fund.
In 2012, the City launched the Palo Alto Clean Local Energy Access Now (CLEAN) program (Staff
Report 2548, Resolution 9235), a feed-in tariff program. Through Palo Alto CLEAN, building
owners may lease their roof tops to solar developers, or develop solar themselves, and sell the
energy and renewable attributes to the City under a standard Power Purchase Agreement (PPA)
at a fixed rate over a specified term. The current Palo Alto CLEAN PPA price for solar PV systems
is $0.165 per kilowatt-hour (kWh) for a 20- or 25-year contract term for up to a maximum of 3
MW total of capacity. On May 27, 2015 (Staff Report 5756), Council opened the program to
eligible non-solar generation technologies under a separate 3 MW cap at a rate of $0.093/kWh
or $0.094/kWh price for a 20-year, or 25-year PPA, respectively. There have been no
applications for the Palo Alto CLEAN program to date.
On April 22, 2014, the City Council adopted the Local Solar Plan (Attachment A, Staff Report
4608, Resolution 9402), which set the overarching goal of meeting 4% of the City’s total energy
needs from local solar by 2023 and unified the City’s approach toward local solar and described
a set of diverse strategies for meeting the set goal. The Local Solar Plan provides a holistic
1 This total includes the 0.93 MW installed under PV Partners prior to SB1, the 5.65 MW installed after SB1 and the
systems that have been installed after PV Partners rebates for residential customers were no longer available.
City of Palo Alto Page 4
framework and incorporates all market segments and short- and long-term approaches. The
plan further seeks to do so in a cost-effective manner that does not create a burden on non-
solar customers. Prior programs, incentives, and policies involving solar installed in the City—
including specifically PV Partners, NEM, and CLEAN—are integrated into the Local Solar Plan
strategies, and new programmatic areas are identified for staff research and development. The
strategies range from supporting research and development partnerships supporting solar
innovation to establishing programs for underserved market segments, such as residents in
multifamily homes and renters.
Discussion
Status of Local Solar Plan Implementation Efforts
A strategy-by-strategy update of all implementation efforts that have been completed to date
and that are planned for the near term is provided as Attachment B. Detail about program
development, the status of net energy metering, and the future of PV Partners is included
below.
Updated Local Solar Penetration, Forecast, and Goal
Figure 1 shows cumulative solar PV installations in Palo Alto from 1999 through August 13,
2015. An estimated 785 systems and 6.7 MW of capacity are currently installed representing
over 1% of the City’s annual energy needs.
Figure 1: Cumulative Solar PV in kW CEC-AC2 Installed in Palo Alto through August 13, 2015
2 The California Energy Commission Alternating Current, or CEC-AC, rating is the product of the number of PV
panels, the Practical Test Conditions (PTC) rating per panel, and the inverter efficiency.
City of Palo Alto Page 5
Solar Potential Assessment
As a part of the Local Solar Plan, staff is completing a detailed GIS-based (geographic
information system) solar potential assessment for Palo Alto. The analysis takes into account an
assortment of factors affecting solar deployment, including:
Latitude/longitude of Palo Alto
Typical meteorological conditions
Land-use constraints
Orientation and slope of rooftops
Shading from surrounding trees and buildings
Industry average solar system performance
Forecast of solar system costs
Federal, state, local financial incentives
Assumption for expected financial return
Federal, state, local policies and regulations
Assumption for local adoption rate
Renters versus owner-occupied households
Table 2 shows updated values for all installed, planned and forecasted solar PV. The
overarching Local Solar Plan goal is that solar PV provide 4% of the City’s 2013 load, which
translates to about 23 MW of installed local solar PV capacity. After accounting for 8 MW from
the PV Partners program, 3 MW through the Palo Alto CLEAN program and 2 MW for new
community solar and solar donation programs that are under development, almost 10 MW of
additional solar capacity is required to meet the Local Solar Plan’s 2023 goal. Staff believes that
this is feasible given existing incentives and realistic forecasts for falling solar system prices.
The solar potential analysis supports the conclusion that the City can meet the 23 MW goal
without expanding rebates or net energy metering incentives.
Table 2: Updated Installed, Planned, and Forecast Solar PV and Local Solar Plan Goal
Program Status as of August 2015 Capacity
(MW)
Energy
(MWh/yr)
% of City’s
Energy Use
PV Partners Program (Installed and Remaining Capacity) 8.0 13,600 1.4%
CLEAN Program, Planned Capacity for Solar PV 3.0 5,100 0.5%
Non-Rebated Solar Installed to Date 0.3 510 0.05%
Anticipated Capacity for Community Solar and Solar
Donation Programs
2.0 3,400 0.4%
Additional Solar PV to Meet Local Solar Plan Goal 9.7 16,500 1.7%
Solar Penetration Goal in 2023 23.0 39,100 4.0%
It is important to emphasize that the City is much less certain to achieve the Local Solar Plan
goal without successfully deploying 3 MW through the CLEAN program and 2 MW through the
future community solar and solar donation programs.
City of Palo Alto Page 6
Program Development Update
Three programs were identified in the Local Solar Plan as having potential to spur solar
adoption and broaden participation: 1) community solar program; 2) a solar group-buy
program; and 3) a solar donation program.
1. Community Solar Program: Community solar programs (aka shared solar) typically enable an
electric utility’s customers to buy or lease solar panels in a centralized solar PV array and
receive regular credits for electric output via their utility bills. Community solar programs
are growing rapidly across the U.S. because they enable residents and businesses to
experience and derive the benefits from cost-effective local solar deployment, even if they
are unable to install solar at their own premises, for example because of shading,
ownership, structural or financial reasons.
Staff attempted to seek a partner to implement a turnkey community solar program and
issued a request for proposal (RFP) in July 2014 from a program administrator/solar
developer. The turnkey proposal did not materialize and staff terminated the RFP. More
information was provided to the UAC in July and to Council in August 2015 (Staff Report
5971).
Staff is currently evaluating other methods to provide community solar for Palo Alto, which
include utilizing municipal facilities to host community solar. In July 2015, an inter-
departmental committee was formed to develop a work plan for installing solar on City
facilities and, in the near term, identify a municipal site to host the solar system for the
community solar program. The committee is currently completing a comprehensive
database that combines site information for all municipal facilities with other solar-relevant
data, such as rooftop technical potential, on-site electricity consumption, and building lease
and use constraints. Upon completing the database, staff will retain the services of a solar
procurement specialist and adopt a work plan for installing solar on all viable facilities. Staff
expects to finalize the community solar site selection and begin the solar PV system
procurement process by Fall 2015.
2. Solar Group-Buy Program: Solar Group-Buy programs (aka group-discount or bulk buy) have
historically been successful in driving down system costs by aggregating purchasing power
and simplifying the process of solar adoption across a community. The City was fortunately
able to participate in Peninsula SunShares, a large, regional group-buy effort led by the City
of Foster City. An informational report about the program was provided to the UAC in
October 2014 and to City Council in November 2014 (Staff Report 5144). Peninsula
SunShares launched on April 31, 2015, and was open to all residents in the nine Bay Area
counties who registered by August 10. The entire program is expected to result in over 800
kW in new solar installations across the Bay Area. Palo Alto led the region in number of
enrollments with an estimated 28% of total participation. 54 Palo Alto residents signed
contracts to install 236 kilowatts (kW) of solar systems. Given the success of the program,
staff plans to seek opportunities to join future regional group-buy efforts.
City of Palo Alto Page 7
3. Solar Donation Program: In a solar donation program, participants would contribute funds
towards building solar PV systems on schools and other non-profit facilities. The projects
could be funded in a variety of ways, including via donations from participants through
monthly contributions (e.g., $5 to $10 per month) through their utility bills. This program is
estimated to take the least amount of staff time to develop. Research and development of
the program is planned for Winter 2015/2016 followed by review by the UAC and approvals
by the Finance Committee and Council leading to a program launch in Spring 2017.
Table 3 is a tentative timeline for the review, approval and launch for the three programs.
Table 3: Tentative Review and Approval Timeline for Major Programs
Program
Development
UAC
Review
Fin. Comm.
Review
Council
Review
Program
Launch
1. Group-Buy Program
(Complete)
Summer 2014 Oct 2014 N/A Nov 2014 April 2015
2. Community Solar
Program
May 2014 –
Present
Spring
2016
Spring
2016
Summer
2016
Winter
2016/2017
3. Solar Donation
Program
Winter
2015/2016
Summer
2016
Summer
2016
Fall
2016
Spring
2017
Net Energy Metering
In 1996, California state law required all electric load serving utilities to offer net energy
metering (NEM) to eligible customers on a first-come, first-served basis up to a maximum cap
based on the utility’s aggregate customer peak demand. NEM is a special billing arrangement
that provides a bill credit to customers with eligible solar PV or other net metered systems
based on the full retail rate for the electricity that their system generates. Palo Alto’s NEM cap
is set at 5% of the City’s 2006 peak electric demand or 9.5 MW. Current installations total 6.7
MW, representing 3.5% of the utility’s aggregate customer peak demand. Staff estimates that
the City will meet the 9.5 MW NEM cap by the end of 2016. To date, all local solar installations
utilize NEM and all net energy metered systems are solar PV3.
Staff plans to seek Council approval of the NEM cap to memorialize the calculation
methodology and clarify any ambiguity related to Palo Alto’s NEM cap. Additionally, as the City
approaches its NEM cap, staff will begin reporting progress towards meeting the cap in order to
further support market certainty and inform customer decision-making.
After the cap has been reached, customer-sited systems will be subject to a different set of
terms and conditions, referred to as the NEM successor program. Staff is preparing proposed
3 In principal, customers may install a variety of distributed energy technologies on-site that would be eligible for
NEM, including, for example, geothermal electric, fuel cell, wind, biomass, and anaerobic digestion technologies. In
practice, staff expects the vast majority—if not all—of on-site generation and NEM participation to be solar PV.
City of Palo Alto Page 8
design guidelines for the NEM successor program in Palo Alto to supplement the electric cost of
service analysis (COSA) guidelines approved by Council on September 15, 2015 (Staff Report
6061). Staff plans to further clarify terms and conditions for existing NEM participants (aka
“grandfathering” provisions) and a NEM successor program for UAC, Finance Committee and
Council consideration by early 2016.
Recommendation Regarding the PV Partners Program
As of August 2014, all residential rebate funds for solar PV systems through the PV Partners
program were reserved. Limited funds remain available for commercial customers. On March
17, 2015, the Finance Committee requested that staff return to the Committee for a discussion
about the options for continuing PV Partners rebate funds for residential use—either by adding
new funds for rebates or by shifting the remaining rebate funds not yet reserved by commercial
customers to residential customers. Members of the Committee questioned whether additional
rebates for residents might yield more solar deployment than funds directed to solar
developers through the Palo Alto CLEAN program.
Staff recommends retiring PV Partners after the City’s legislative requirements set by SB1 have
been achieved, and not shifting funds from the commercial customer class to the residential
customer class for four primary reasons.
1. SB1 Goals Will Have Been Met
The explicit goal of SB1 is to aid the deployment of 3,000 MW of solar PV across the state by
the end of 2018. In Palo Alto, staff expects all PV Partners rebate funds to be fully reserved by
the end of the 10-year program, so that the City will meet its contribution toward the statewide
goal. Additionally, the implicit goal of SB1 is to create a self-sustaining solar market, a goal that
was reinforced through a program design that ratcheted down incentive levels with increased
deployment so as to encourage solar installers to continually seek cost-reductions. Even though
the SB1 rebates through Pacific Gas & Electric (PG&E) and other investor owned utilities (IOUs)
have been nearly completely reserved4, solar deployment has continued such that California as
a whole has already exceeded the statewide SB1 deployment target of 3,000 MW5. In Palo
Alto’s service territory, residential installations have not slowed down absent rebates. All data
support that the implicit goal to create a self-sustaining solar market has already been
achieved.
2. The Objective of Lowering the Cost of Solar Can be Achieved in Other Ways
Alternative solar adoption models can result in lower overall systems costs and at a
substantially reduced cost to electric utility ratepayers compared to continuing the PV Partners
rebate program. Specifically, group-buy programs that aggregate the purchasing power of many
households across an organization or region have achieved substantial reductions in system
costs by lowering the customer acquisition costs for solar developers and facilitating economies
4 As of August 19, 2015, less than 1 MW worth of rebate funds remain for all IOUs combined. (http://csi-
trigger.com/) PG&E ceased accepting applications for residential rebates in Fall 2013.
5 As of August 19, 2015, solar deployment in California is 3,216 MW (http://www.gosolarcalifornia.org/).
City of Palo Alto Page 9
of scale. The system price offered through the Peninsula SunShares group-buy program for the
most basic installation was $3.50/Watt-Direct Current (DC) (approx. $4.40/Watt CEC-AC) for a 3
to 9 kilowatt system for a cash purchase (i.e. not including any financing option). Prices for
similar-sized customer-owned systems that applied for a PV Partners rebate in the last two
years were $4.70/Watt-DC (approx. $5.90/Watt CEC-AC) prior to receiving the rebate, and
$4.02/Watt-DC (approx. $5.00/Watt CEC-AC) after receiving the rebate. Therefore, a solar
system purchased through the Peninsula SunShares program was over 10% cheaper than the
post-rebate solar system cost through the PV Partners program and 25% cheaper than the pre-
rebate solar system cost. Figure 2 shows the historical average annual system cost of solar PV
installed through the PV Partners program. The base price for the Peninsula SunShares program
is included for comparison.
Figure 2: Average System Cost Installed through PV Partners
3. PV Partners Administrative Costs are High
Finally, the rebate and administrative costs of the PV Partners program are high, including the
administrative costs borne both by the City and by solar installers that are completing the
paperwork on behalf of utility customers. The California Energy Commission (CEC) set onerous
requirements for the implementation of SB1. Staff estimates that each residential rebate
application requires about 3 hours total of administrative work by City staff and solar installers,
in addition to a $50 per application cost for rebate processing software. The administrative
costs combined with the rebate value is over $2 per Watt-DC averaged over the program’s
history, which are costs paid for by all electric utility ratepayers. By comparison, staff estimated
City of Palo Alto Page 10
the administrative costs of a solar group-buy program for residential systems to be less than
$0.07 per Watt-DC.
Of course, a new residential solar PV rebate program could avoid the onerous requirements set
by the CEC for SB1 eligibility, but it’s still instructive to realize the administrative cost advantage
that a group-buy program offers. However, shifting the remaining rebate funds not yet
reserved by commercial customers to residential customers under PV Partners would not avoid
the CEC requirements.
4. Making Rebate Funds Available Again to Residential Customers Will Result in Disruptive
Market Dynamics
Residential rebate funds have been fully reserved for over 13 months. Making rebate funds
available again to residential customers will result in disruptive market dynamics and confusing
messaging to customers. Furthermore, it may have the unintended consequence of alienating
the dozens of households who have already installed systems without receiving rebates.
Alternatives for PV Partners
Alternatives to staff’s recommendation to retire the PV Partners program after solar legislative
mandates have been met include: 1) transferring the remaining PV Partners rebate funds not
yet reserved by commercial customers to residential customers; 2) adding new rebate funds for
residential customers from Electric Fund ratepayers; and 3) adding new rebate funds for
residential customers from the City’s General Fund.
Staff does not recommend any of the alternatives. The rate of residential installations has not
slowed since rebates for residential customers were fully reserved, indicating that rebates are
not required for customer adoption. A program providing rebates would therefore very likely
result in a high proportion of “free-ridership”, a hallmark of an ineffective incentive program
design.
Commission Review
The UAC reviewed staff’s recommendation at its October 7, 2015, meeting. Commissioners
were supportive of the staff proposal after asking a variety of clarifying questions. For instance,
commissioners asked whether the City could meet the Local Solar Plan goal after the PV
Partners program is retired, whether the changing federal incentive levels would affect staff’s
projection of solar PV deployment, and whether behavior was considered in the forecasted
solar potential.
Ultimately, the UAC supported staff’s recommendation and voted unanimously (7-0 with
Commissioners Ballantine, Cook, Danaher, Eglash, Foster, Hall and Schwartz voting yes) to
recommend that Council discontinue the PV Partners program after all legislative requirements
set forth in SB1 are fulfilled. Draft excerpted notes from the UAC’s October 7, 2015, meeting
are provided as Attachment C.
City of Palo Alto Page 11
Next Steps
Table 4 is a tentative timeline of all activities planned in the near future for the continued
implementation of the Local Solar Plan.
Table 4: Tentative Timeline for Near-term Implementation of the Local Solar Plan
Time
Period
Description
Fall 2015
Develop a strategy for solar on municipal facilities
Complete implementation of AB 2188 (Development Center)
Clarification of NEM cap calculation methodology to Council
Design guidelines for the NEM successor program to the UAC, Finance
Committee, Council
Incorporate solar perspective throughout the electric COSA process
Winter
2015/2016
Begin reporting progress toward the NEM cap in Utilities Quarterly Update
and on CPAU solar website: http://www.cityofpaloalto.org/solar
Complete study of distribution system impacts of high penetrations of solar
PV and EV
Incorporate solar perspective throughout the electric COSA process (cont.)
NEM successor program and grandfathering provisions to the UAC, Finance
Committee, Council
Continuation of community solar program research and development
Begin solar donation program research and development
Spring 2016 Community solar program design to the UAC, Finance Committee, Council
Resource Impact
There is no change to budgets, planned expenditures or staff resources as a result of staff’s
recommendation to discontinue the PV Partners program once solar legislative mandates have
been met. Administering the PV Partners program requires dedicated staff resources through
at least 2020 to disperse all remaining rebate funds6. Once all program funding has been
reserved by customers and no more new applications are being processed, the ongoing staff
resource impact is anticipated to be 0.02 FTE to process performance-based incentive (PBI)
payments that are paid out over a five year time frame. After all program funding has been
reserved, available staff resources will be reallocated to other solar program initiatives. If,
however, Council desires to add new rebates for residential solar PV, there would be a budget
and rate impact for the Electric Fund.
Policy Impact
The recommendation to discontinue the PV Partners program once solar legislative mandates
have been met does not conflict with any City policy. The Local Solar Plan supports the City’s
6 For PV Partners reservations that are already approved, the last estimated performance-based incentive (PBI)
payment date is 2020. However, if staff receives an application for all or a portion of the remaining rebate funds
as a part of a new construction project, then the project may require PBI payments through 2022.
City of Palo Alto Page 12
environmental sustainability goals, including those set out in the Council-approved 2011
Utilities Strategic Plan and the City’s Sustainability and Climate Protection Plan. Fulfilling our
SB1 legislative mandates through PV Partners will help promote solar development and is
consistent with the Carbon Neutral Plan, the Local Solar Plan, and State and local efforts to
promote distributed solar projects.
Environmental Impact
Discontinuing the PV Partners program once solar legislative mandates have been met does not
meet the California Environmental Quality Act’s (CEQA) definition of “project” under California
Public Resources Code Sec. 21065, thus no environmental review is required.
Attachments:
Attachment A: Adopted Local Solar Plan (PDF)
Attachment B: Summary of Local Solar Plan Implementation Efforts (PDF)
Attachment A
A-1
Exhibit A to Resolution No 9402
Adopted by City Council on April 21, 2014
City of Palo Alto Utilities – Local Solar Plan
Goal
To increase the installation of local solar photovoltaic facilities to provide 4 percent of the City’s
total energy needs by 2023.
Objectives
1. Facilitate the development of local, safe and cost-effective solar in Palo Alto to meet the
diverse needs of the community
2. Reduce the cost of installing solar in Palo Alto and become a leader in promoting renewable
distributed generation through solar installations
3. Understand the community’s solar potential and diverse needs and develop solar programs
accordingly
4. Remove internal obstacles to minimize cost and achieve greater solar potential
5. Promote solar installations in a cost effective and safe manner
6. Leverage industry resources to the extent possible
7. Deploy industry best practices
Strategies
1. Remove internal system and institutional barriers which increase “soft” costs and may
impede adoption of solar in Palo Alto
a. Work with the Development Center, Planning and Utilities to identify further
improvements to streamline the solar permitting process.
b. Promote advancements in the City’s permitting process to community and solar
developers.
2. Develop proper policies, incentives, price signals and rates to encourage solar installation
a. Solar Policy and Rate Design – explore rate structures that balance cost of service
with the City’s policy to promote the development of new solar systems in Palo Alto.
i. When evaluating new solar policies, evaluate the impact, if any, on non-solar
ratepayers.
b. City of Palo Alto Utilities (CPAU) Billing System – explore modifications to the billing
system and/or evaluate:
i. Incorporating net metering information on the monthly bills
ii. Virtual net metering to allow the sharing of net metering bill credits across
accounts
c. CPAU Incentives – assess providing rebates or other incentives after the SB1
mandated expenditures are exhausted, the Federal Investment Tax Credit has been
reduced from 30% to 10% and the net-metering cap has been met, to continue to
encourage local solar installations.
Attachment A
A-2
d. Leverage available resources for solar policy and program development
i. Participate in the Federal Department of Energy’s American Solar
Transformation Initiative to receive free services including development of a
customized solar road map
ii. Request assistance from existing membership in Solar Electric Power
Association and ESource
iii. Consider partnering with regional cities, counties and the State of California
in developing solar programs
e. Advocate at a local, regional and state level for effective rules, regulations and
legislation to promote cost effective and fair solar development
i. Coordinate with other municipal utilities through the Northern California
Power Agency (NCPA) and the California Municipal Utilities Association
(CMUA) on state legislation related to solar
3. Assess technical and market potential of solar in Palo Alto
a. Review commercial and residential sites to determine solar technical potential
b. Determine cost drivers for installing solar in Palo Alto
c. Utilize other industry studies to develop a feasible and marketable potential
d. Develop a database of solar potential
e. Assess the impacts of PV on CPAU’s distribution system
4. Implement policies and programs to increase solar system installations on CPAU customer
sites with good solar access
a. Continue to promote the PV Partners program to achieve the 6.5 MW of installation
by 2017, per CA SB1
b. Continue to promote the Palo Alto CLEAN (feed-in-tariff) program and revamp the
marketing of Palo Alto CLEAN to facilitate the coordination of potential sites with
developers and property owners/managers to achieve some level of participation
i. Annually re-assess the avoided cost of local renewable energy and
recommend adjustments to the CLEAN offer price and contract terms, as
appropriate
ii. Investigate developers’ concerns with Palo Alto CLEAN program rules
iii. Continue to educate commercial property owners about the CLEAN program
c. Evaluate solar project financing options
i. Coordinate with the California FIRST Property Assessed Clean Energy (PACE)
program which allows solar system owners to borrow funds for the PV
installation and pay it back on their property tax bills over a term equal to
the expected system life (20 years).
ii. Partner with local lenders to offer solar financing1
1 See an example of such a program from New Jersey’s Public Service Enterprise Group her:
http://www.pseg.com/home/save/solar/index.jsp
Attachment A
A-3
5. Facilitate and/or develop new programs to encourage new participants to develop local
solar installations.
a. Develop a solar donation program for community members to donate to public
sector and non-profit organizations which may benefit from solar, but can’t afford
the investment on their own.
i. Work with PAUSD and other non-profits to identify sites. Potential
installation sites include public sector and non-profit locations which are
ineligible to receive federal tax subsidies.
ii. Evaluate alternative mechanisms to provide donations to sustain the
program, including:
(1) Reformulating the suspended PaloAltoGreen electric program as a
mechanism to provide ongoing donations;
(2) Developing a bill donation mechanism to raise funds; or
(3) Developing on-line or crowd-funded sources to raise ongoing funds.
b. Develop a community solar share program for the benefit of community members
that do not have good solar access but have the desire to invest in local solar.
i. Evaluate program design options that allow CPAU customers to invest in a
share of a new larger-scale solar PV installations located in Palo Alto
ii. Evaluate options for providing value back to customer investors, including:
(1) Evaluate CPAU’s ability to provide monthly payments (in $) on the
customer’s Utilities bill
(2) Evaluate CPAU’s ability to offer “virtual net metering” so that energy
produced (in kWh) from a solar system could be reflected on customers’
Utilities bills. [Note that the billing system challenges may be substantial
for this option.]
(3) Evaluate providing payments to customers via a third-party administrator
separate from the Utilities bill.
iii. Evaluate outsourcing the administration of the community solar program to
provide the following:
(1) Develop the community solar program
(2) Perform program marketing
(3) Identify installation sites
(4) Manage the solar installation contract
(5) Own, operate and maintain the PV installation (or contract with a third-
party)
c. Investigate group-discount solar PV program options to allow/facilitate Palo Alto
residents to pool their buying power to secure significant discounts, making
installing solar on their home simple and more affordable.
i. Leverage existing group-discount programs offered to regional residents and
company employees.
6. Maximize solar installations on City-owned facilities
a. Assist Public Works in evaluating leasing City-owned facilities with low electric
consumption (elevated garages and surface parking lots) to a solar developer who
Attachment A
A-4
could install solar PV systems and would be compensated under the Palo Alto CLEAN
program.
b. Assist Public Works in investigating installing net-metered solar on City-owned sites
to reduce the City’s annual electric costs (and benefit the General fund).
7. Educate the community on the benefits of solar through information and demonstration
projects
a. Develop solar demonstration projects on City and public facilities
b. Promote the benefits of PV systems together with fuel switching (replacing end-of-
life gas appliances with electric appliances or replacing a gasoline vehicle with an
electric vehicle or a plug-in hybrid vehicle) strategies to reduce greenhouse gas
emissions.
c. Investigate developing a “one-stop-shop” model (e.g., Wave-one).
d. Develop "how to go solar" promotional materials which allows customers to
evaluate several solar options.
e. Develop direct marketing for small commercial/business customers.
f. Develop a database of solar projects installed throughout the community as “case
studies” and promote them through CPAU’s web site.
g. Promote new innovative solar technologies using the CPAU Emerging technology
Program
i. Thermoelectric paint
ii. PV & batteries
iii. Building-integrated PV (BIPV)
iv. White roofs
v. Microgrids
vi. Solar shingles
vii. Solar thermal
Attachment B: Summary of Local Solar Plan Implementation Efforts
1
Strategy-By-Strategy Update of Local Solar Plan Implementation Efforts
Strategy Achievements to Date Ongoing/Future Plans
Strategy 1: Remove
internal system and
institutional barriers
which increase “soft”
costs and may
impede adoption of
solar in Palo Alto
Pre-dating the Local Solar Plan, Development
Services implemented a streamlined
permitting process for residential solar PV
systems. Palo Alto received the 2014 Best
Solar Collaboration Award for the improved
permitting process.
Staff is publicizing the streamlined solar permitting process on an
ongoing basis.
Staff plans to continue streamlining of permitting, inspection, and
interconnection processes as necessary to comply with the
recently enacted AB2188 which mandates a standardized
procedure for solar permitting across the state. (Fall 2015)
Strategy 2: Develop
proper policies,
incentives, price
signals and rates to
encourage solar
installation
As described in detail in this report, staff
evaluated increasing the funding for PV
Partners beyond compliance obligations and
recommend not expanding the program after
all legislative mandates have been met.
Staff is currently incorporating local solar considerations in the
electric rate analysis discussions. (Ongoing)
Staff will bring forward a clarification for the methodology used to
calculate the City’s NEM cap for Council adoption (Fall 2015)
Staff members from multiple departments are coordinating to
integrate and improve the permitting, inspection, and
interconnection processes to ensure the City has visibility of all
systems being installed within Palo Alto and to accurately and
electronically track progress towards the NEM cap. (Fall 2015)
Staff seeks regular technical and non-technical assistance from the
Solar Electric Power Association, E Source, and the U.S.
Department of Energy funded American Solar Transformation
Initiative. (Ongoing)
The City coordinates with the Northern California Power Agency
(NCPA) and the California Municipal Utilities Association (CMUA)
on an ongoing basis on effective rules, regulations, and legislation
to promote cost-effective and fair solar development. (Ongoing)
Solar considerations are being incorporated in the ongoing
discussions for adopting new billing and customer information
Attachment B: Summary of Local Solar Plan Implementation Efforts
2
Strategy-By-Strategy Update of Local Solar Plan Implementation Efforts
Strategy Achievements to Date Ongoing/Future Plans
systems.
Staff plan to research and evaluate a NEM successor program,
which will be coordinated with the electric rate discussion and
analysis. Guidelines for the NEM successor program design will be
brought to the UAC, Finance Committee, Council in Fall 2015, and
a program will be brought for review by Spring 2016.
A clear path to securing a host site is critical to successfully launch
a community solar program. Staff is in the process of selecting a
municipal site to host the solar system, which could facilitate the
process of launching the program and enhance associated
education and outreach efforts.
Strategy 3: Assess
technical and market
potential of solar in
Palo Alto
Completed a GIS-based solar technical
potential assessment for rooftops and
published a map of the potential online for
interested community members1 (Summer
2014)
Staff is broadening the solar technical potential assessment to
incorporate surface parking. (Fall 2015)
Staff is completing the economic and market potential assessment
and documentation. Preliminary results of the potential
assessment are incorporated in the memo. (Fall 2015)
Staff plan to coordinate with the Planning Department on the
impact of current zoning rules for carport installations
Staff plan to conduct a study of distribution system impacts from
high penetrations of solar and EV (FY16)
Strategy 4:
Implement policies
and programs to
increase solar system
As described in detail in the full report, Palo
Alto’s PV Partners program providing rebates
for customer-cited solar systems has spurred
over 6.5 MW of local solar PV adoption to
Staff is currently evaluating joining the HERO program, which
would give residents another PACE financing option
1 https://cityofpaloalto.org/solarmap
Attachment B: Summary of Local Solar Plan Implementation Efforts
3
Strategy-By-Strategy Update of Local Solar Plan Implementation Efforts
Strategy Achievements to Date Ongoing/Future Plans
installations on CPAU
customer sites with
good solar access
date. All residential rebate funds have been
reserved and commercial rebate funds are
nearly depleted. Staff recommends that the
program not be expanded once all legislative
obligations have been fulfilled.
The Palo Alto Clean Local Energy Accessible
Now (CLEAN) program is a feed-in tariff
program for renewable generation facilities
sited within Palo Alto. To date, the program
has not generated a project. However, staff
continues to market the program.
Furthermore, after a recent solar developer
survey, the feedback provided led staff to
propose the recommendation to offer a 25-
year power purchase agreement (PPA)
option, instead of only the 20-year PPA.
Council subsequently approved this change.
The City is currently a member of California
FIRST, which give residents a Property
Assessed Clean Energy (PACE) financing
option to pay for on-site renewable energy
installations through their property tax bill
Strategy 5: Facilitate
and/or develop new
programs to
encourage new
participants to
Palo Alto joined a regional solar group-buy
program called Peninsula SunShares. The
solar system prices resulting from the
Aggregating the purchasing power of the
community resulted in solar system prices
Staff plans to begin the research and development of a solar
donation program (Winter 2015/2016)
Staff provides ongoing support to PAUSD and the Sustainable
School Committee in their efforts to evaluate the costs and
Attachment B: Summary of Local Solar Plan Implementation Efforts
4
Strategy-By-Strategy Update of Local Solar Plan Implementation Efforts
Strategy Achievements to Date Ongoing/Future Plans
develop local solar
installations
approximately 15-25% below current market
prices across all nine Bay Area counties.
Registration for the program ran from April
through August 2015. Palo Alto households
made up approximately 40% of the total
program participation.
benefits of solar PV installations on school facilities (ongoing)
Staff provided an informational report to the UAC in July 2015
regarding the status of the community solar program
development efforts. At present, staff is selecting a municipal site
to host the community solar facility. Staff will return to the UAC
with a proposed program design in Spring 2016.
Strategy 6: Maximize
solar installations on
City-owned facilities
Public Works released an RFP in May 2014 to
lease the top levels of five downtown City
multi-level parking structures for solar PV
facilities applying through the Palo Alto
CLEAN feed-in tariff program. Currently, staff
and the selected developer are negotiating a
site lease for the installations.
A committee was formed to inventory all municipal facilities and
their suitability for solar PV and to develop a work plan for
installing solar on viable sites. (Fall 2015)
Strategy 7: Educate
the community on
the benefits of solar
through information
and demonstration
projects
Pre-dating the Local Solar Plan, in 2008 Public
Works and Utilities installed solar
demonstration projects at the Municipal
Service Center, Baylands Interpretive Center,
and Cubberley Community Center.
Staff hosts workshops on a variety of topics,
including customer-sited solar energy. The
last solar energy workshop was April 25,
2015, and was coordinated with the program
administrator for the solar group-buy
program Peninsula SunShares.
Staff routinely evaluates innovative solar technologies through the
Program for Emerging Technologies (PET). Through PET, a 6-
month pilot project was launched in partnership with Petra
Systems to evaluate and demonstrate distributed solar PV on
street light poles. The pilot project concluded in May, and staff is
in the process of completing an evaluation report.
Staff is evaluating issuing an RFP for customer-facing tools to aid
in solar decision-making (Fall 2015)
FINANCE COMMITTEE
DRAFT ACTION
Page 1 of 1
Special Meeting
Tuesday, December 1, 2015
Chairperson Schmid called the meeting to order at 6:13 P.M. in the
Community Meeting Room, 250 Hamilton Avenue, Palo Alto, California.
Present: Filseth, Kniss, Scharff, Schmid (Chair)
Absent:
Oral Communications
None.
Agenda Items
2. Utilities Advisory Commission Recommendation to Continue the PV
Partners Program Until the State Legislative Requirements Set Forth in
the California Million Solar Roof Bill Have Been Fulfilled.
MOTION: Council Member Scharff moved, seconded by Council Member
Kniss to recommend the City Council continue the Photovoltaic (PV) Partners
Program for rebates for customer-sited solar photovoltaic systems until the
State Legislative requirements set forth in California Million Solar Roofs Bill
(SB1) have been fulfilled.
MOTION PASSED: 4-0
ADJOURNMENT: Meeting adjourned at 8:12 P.M.