Plant-wide Solar Feasibility Study Report No. 1346 Project No. 104054 July 2009 Metropolitan Water District of Southern California Plant-wide Solar Feasibility Study Report No. 1346 Project No. 104054 July 2009 Prepared by: MWH Americas, Inc. 626 Wilshire Blvd., Suite 850 Los Angeles, California 90017 (213) 316-7000 TABLE OF CONTENTS Section 1 Executive Summary................................................................................................... 1-1 Section 2 Introduction and Objective ...................................................................................... 2-1 Program Introduction ............................................................................................................. 2-1 Purpose and Necessity of the Program .................................................................................. 2-2 Drivers and Constraints.......................................................................................................... 2-5 Section 3 Laws, Rules and Regulations .................................................................................... 3-1 Existing Regulatory Framework ............................................................................................ 3-1 Relevant State Solar Programs............................................................................................... 3-2 Metropolitan Local Electric Jurisdictions’ Solar Programs ................................................... 3-8 Summary .............................................................................................................................. 3-10 Section 4 Project and Solar Industry Background ................................................................. 4-1 Facility Descriptions .............................................................................................................. 4-1 Electrical Demand: Historical and Projected ......................................................................... 4-1 Options for Selling Solar Distributed Generation to an Interconnected Utility in California 4-2 Market Issues: Evaluation of Solar Industry .......................................................................... 4-5 Section 5 Solar Sizing Analysis ................................................................................................. 5-1 Data Analysis ......................................................................................................................... 5-1 Solar System Sizes ................................................................................................................. 5-4 Aspects to Solar Implementation ........................................................................................... 5-5 Section 6 Future Potential Solar Facility Locations ............................................................... 6-1 Foothill Power Plant .............................................................................................................. 6-1 Etiwanda Power Plant ............................................................................................................ 6-2 Diamond Valley Lake – Wadsworth Pumping & Power Plant.............................................. 6-2 Lake Mathews Power Plant ................................................................................................... 6-6 Eagle Valley Property ............................................................................................................ 6-6 Arrow Highway Property ....................................................................................................... 6-9 Section 7 Recommendations.................................................................................................... 7-11 Treatment Plant Solar Facility size ...................................................................................... 7-11 Staging, Timing and Delivery Method ................................................................................ 7-13 Roadmap to Achieve Practical Implementation of Metropolitan Strategic Power Plan ...... 7-15 MWH TOC-i Plant-wide Solar Feasibility Study APPENDICES Appendix A - Sizing Calculations Appendix B – Solar Sizing and Sensitivity Analysis LIST OF TABLES Table 1-1 Recommended Solar Sizes .......................................................................................... 1-3 Table 4-1 Expected Energy Consumption with Ozonation ......................................................... 4-2 Table 5-1 Calculated Optimal Solar Sizing for Behind-the-Meter Generation ........................... 5-5 Table 7-1 Calculated Supply-Demand Sizes for Behind-the-Meter Generation ....................... 7-12 Table 7-2 Recommended Solar Facility Size............................................................................. 7-12 Table B- 1 Available 15-minute Electrical Demand Data by Facility ............................................ 5 Table B- 2 Calculated Optimal Solar Sizing for Behind-the-Meter Generation .......................... 21 LIST OF FIGURES Figure 5-1 Daily Energy Demand and Solar Generation ............................................................ 5-3 Figure 6-1 Foothill Power Plant Solar Facility ............................................................................ 6-3 Figure 6-2 Etiwanda Power Plant Solar Facility.......................................................................... 6-4 Figure 6-3 Diamond Valley Lake: Wadsworth Pumping & Power Plant Solar Facility ............. 6-5 Figure 6-4 Lake Mathews Solar Facility ..................................................................................... 6-7 Figure 6-5 Eagle Valley Solar Facility ........................................................................................ 6-8 Figure 6-6 Arrow Highway Solar Facility ................................................................................. 6-10 Figure B- 1 Daily Energy Demand and Solar Generation .............................................................. 2 Figure B- 2 Daily Fluctuations in Grid Demand ............................................................................ 3 Figure B- 3 Metropolitan Plant Electrical Demand, kWh .............................................................. 4 Figure B- 4 Metropolitan Treatment Plant Monthly Flow, MGD equivalent................................. 5 Figure B- 5 Normalized Monthly Electrical Demand – Jensen ...................................................... 6 Figure B- 6 Normalized Monthly Electrical Demand - Weymouth ............................................... 7 Figure B- 7 Normalized Monthly Electrical Demand - Skinner ..................................................... 8 Figure B- 8 Normalized Monthly Electrical Demand - Mills ......................................................... 9 Figure B- 9 Expected Electricity Rates Under Different Escalation Scenarios ............................ 11 Figure B- 10 Sensitivity of Solar Size and Net Present Cost of Capital Purchase by Grid Rate Escalator........................................................................................................................................ 13 Figure B- 11 Sensitivity of Solar Size and Net Present Cost of PPA by Grid Rate Escalator ..... 14 Figure B- 12 Equivalent Lines for PPA Initial Rates and Escalators ........................................... 15 Figure B- 13 Sensitivity of Solar Size and Net Present Cost of PPA by Initial Rate ................... 16 Figure B- 14 Sensitivity of Solar Size and Net Present Cost of Capital Purchase to Plant Energy Demand ......................................................................................................................................... 17 Figure B- 15 Sensitivity of Solar Size and Net Present Cost of PPA by Plant Energy Demand .. 18 MWH TOC-ii Plant-wide Solar Feasibility Study Figure B- 16 Per Unit Treated Flow Energy Consumption - Jensen ............................................ 19 Figure B- 17 Per Unit Treated Flow Energy Consumptions - Mills ............................................. 20 Figure B- 18 Net Present Cost of Capital Purchase vs. PPA Over Time..................................... 22 Figure B- 19 Net Present Cost of Capital Purchase vs. PPA Over Time with Different Grid Escalation ...................................................................................................................................... 23 MWH TOC-iii Plant-wide Solar Feasibility Study SECTION 1 EXECUTIVE SUMMARY The Metropolitan Water District of Southern California (Metropolitan) has developed a Strategic Power Plan (SPP) to implement its energy goals. These goals include developing projects that will provide power at its water treatment plants and at the retail facilities at a rate of 50% in 2014 and 100% by 2020, with 100% carbon reduction by 2030. There are many drivers that influenced the development of the SPP and its goals, although the primary drivers are regulatory and financially related. The Global Warming Solutions Act of 2006, popularly known as AB 32, requires that by 2020 California’s greenhouse gas (GHG) emissions be reduced to 1990 levels. Metropolitan may be required to take actions that will contribute to the legislated reduction. Even if legislation does not directly impact Metropolitan’s operations, it likely will cause energy prices to rapidly increase. Since the treatment and distribution of water is a highly energy dependent process, energy price increases could dramatically affect the cost of water Metropolitan provides to its 26 member agencies. Price volatility also affects Metropolitan’s annual operating budget. A steady supply and cost of electricity can increase system reliability as well as assist in the development of water supply initiatives. In addition to factors that directly impact its operations, Metropolitan seeks to lead through example on sustainability issues. To meet the immediate goals of the SPP, Metropolitan has conducted this Plant-wide Solar Feasibility Study (Study) in conjunction with a Preliminary Design Report for the implementation or expansion of solar facilities at its five water treatment plants. Regulations Governing Solar Facility Implementation Given current regulations, there are several methods of implementing solar. These include net metering, feed-in-tariffs, energy storage, and behind-the-meter generation. Net metering is considered the most optimal implementation scenario as any energy produced in excess of demand is fed back to the electric grid as a credit. The strategy can only be utilized for up to one megawatt (MW) per facility due to regulatory constraints. Feed-in-tariff rates are currently not high enough to justify selling solar renewable energy to electricity providers, especially considering that ownership of the Renewable Energy Credit (REC) is transferred with the sale of energy. Energy storage is currently not cost effective for medium scale operations of solar facilities in the United States. Behind-the-meter generation involves on-site solar generation that supplies electricity directly into the facility to which it is connected. With behind-the-meter generation, any energy that is in excess of demand is lost. Given these constraints, it is recommended to optimize net metering options and use behind-the-meter generation to meet daytime electricity demands. Financing Options There are two main options for financing solar systems: 1) capital purchase of the system, and 2) entering into a Power Purchase Agreement (PPA) with a third party. If Metropolitan were to purchase the system, it would receive all rebates, tax breaks or other incentives and would be MWH 1-1 Plant-wide Solar Feasibility Study responsible for maintenance and end of life disposal of the solar system. Under a PPA, Metropolitan would enter an agreement with a third party, which would be responsible for purchase, operation and maintaining the system, and end of life disposal. In this case the third party would receive any applicable rebates and tax incentives. In a PPA, Metropolitan would pay for all of the energy produced by the solar system at an agreed upon contractual rate, which could be flat or escalated. The RECs from the solar electricity produced could be negotiated to be retained by Metropolitan. To offset the capital expenditure of a solar system, there are several rebates and tax incentives available. Each of the three electric utilities serving Metropolitan load at retail has developed its own solar incentive program. Although they differ in detail, they generally limit the size of the solar facility eligible for rebate to 1 MW per facility. Under federal tax laws, private entities that purchase solar systems are allowed to accelerate the depreciation of the solar system, thereby greatly reducing their tax burden. This tax incentive is not available to Metropolitan under a direct purchase scenario, but is available to the financing party under a PPA system, which can make a PPA more financially attractive to Metropolitan, especially over the 20 year period of a typical PPA contract. In general, PPAs are preferred for short term horizons while a capital purchase is preferred for long term horizons. Unfortunately, not all electric utilities serving Metropolitan load permit PPAs. Feasibility Study Scope The focus of this Study is to determine the optimum solar facility size at Metropolitan’s five water treatment plants (WTPs) for behind-the-meter generation, under a capital purchase and a PPA, if applicable. It is recommended to add 1 MW of net metering at all WTPs because the nighttime electricity consumption at each WTP is greater than the production from a 1 MW solar facility. Thus study will also briefly investigate the available space for solar facilities at other Metropolitan properties which may be potentially suited for solar facilities. These properties could be utilized at a later date if regulatory conditions change to have more attractive net metering or feed-in-tariff terms. There are many factors to consider when sizing a solar facility, including: • variability in energy demand on a daily and seasonal basis • variability in solar energy production on a daily and seasonal basis • expected cost of grid electricity over time • rate of degradation of solar energy production • cost to install/maintain/dispose of solar system • cost to finance a capital purchase • rebate programs and incentives • PPA rate structure • cost of money These factors were accounted for in this study to perform a net present cost analysis of both financing options over a 40 year period. The optimal size of a solar facility is when solar energy production closely matches the electricity consumption of the facility it is serving. If the solar system is too large, energy may be wasted. If the solar system is too small, there is a lost MWH 1-2 Plant-wide Solar Feasibility Study opportunity to offset grid electricity demand. However, solar production and electricity demand will fluctuate based on temperature, time of year, and changes in facility operations, therefore it is impossible to always match solar production with electricity consumption. The best one can do is to utilize average and projected solar production and electricity consumption to estimate the optimal solar facility size that will minimize the net present cost of the system. Sensitivity analysis was conducted to determine how the optimal solar size changed if the assumptions were altered. This analysis showed that three factors had the greatest influence on the solar size. These factors were 1) the expected escalation in the retail rate of electricity over time, 2) the length of the analysis period, and 3) the PPA electricity rate. The sensitivity analysis consistently showed that the net present cost of the solar system increased significantly when the solar system was larger than the optimal size; whereas, the net present cost of the solar system reduced slightly if the system was smaller than the optimal size. Therefore, it is better to slightly undersize a solar facility than to oversize the facility, when compared to the optimal solar size. Recommendations The recommended solar facility size at each plant is presented in Table 1-1. The size is based on the optimal size for each facility and all constraints discussed in this report as well as land constraints discussed in the Preliminary Design Report. The optimal size varies slightly for a PPA or a capital purchase of the system. All of the water treatment plants are suited for solar facilities, except for the Diemer plant. The Yorba Linda Hydroelectric Plant, which is located onsite at the Diemer plant, is currently planned for upgrades that would provide all of the energy demand for the Diemer plant; thereby negating the need for a solar facility. Table 1-1 Recommended Solar Sizes Treatment Plant Total Solar Installation (MW) Capital Purchase/PPA Jensen* 1.5 Weymouth* 2 Skinner 3.2/3 Mills 2/1.9 Diemer 0 Total 8.7/8.4 *The size is space constrained. Total solar installation size based on 8acres/MW The two types of project financing allow three scenarios for solar facility bidding: 1) Solicit bids for capital purchase 2) Solicit proposals for power purchase agreements 3) Simultaneously solicit both a capital purchase bid and proposals for a PPA, with the option to choose either. MWH 1-3 Plant-wide Solar Feasibility Study The solar bid should be structured such that bidders have the option to propose on individual solar facilities at each water treatment plant, or to submit a single bid for all the water treatment plants. A single bid for all plants may allow for economy-of-scale pricing that could result in a savings to Metropolitan. However, there is one exception for the Jensen plant (served by the Los Angeles Department of Water and Power). The Los Angeles Department of Water and Power does not currently allow PPA agreements. They do allow for a third-party purchase of solar systems as long as the payments to the third-party are structured in a lease format. Thus, only a capital purchase or lease agreement can be utilized for implementing solar at the Jensen Plant. Use of a PPA at the Mills WTP is subject to Riverside Public Utilities approval. Of the three bidding scenarios, it is recommended to utilize the capital purchase option for several reasons. First, over the projected life of the project (40 yrs), the economic benefit of the capital purchase significantly outweighs the PPA because after the system has paid for itself, it continues to produce significant quantities of electricity that is essentially free to Metropolitan and at little cost. This is possible because solar facilities require little operations and maintenance expense and solar panels are warranted for 25 years with an expected lifetime of 40 or more years. A capital purchase is also a safe investment to protect against future dramatic energy increases and price volatility. In comparison, significant uncertainty exists regarding the end of a PPA contract. While Metropolitan has the option to purchase the system at “fair market value,” no clear definition of fair market value has yet emerged. There is speculation that fair market value could be interpreted to mean the value of the energy it produces, which would represent a significant amount of money if retail electricity rates are high. In addition, under a PPA, Metropolitan would be relying on outside financers and it is unclear what would happen if the PPA investors folded or dissolved. The availability of rebates and tax incentives provide favorable financing options for the implementation of solar facilities. These rebates and incentives will diminish as the number of installed solar systems increases. Therefore, Metropolitan should consider the implementation of solar facilities at the water treatment plants to take advantage of the current incentives, which are currently about 40% of the total cost via the California Solar Initiative. Solar installations at other available Metropolitan properties should also be evaluated to take advantage of the current incentives, and contribute to the overall goals of Metropolitan’s Strategic Power Plan. MWH 1-4 Plant-wide Solar Feasibility Study SECTION 2 INTRODUCTION AND OBJECTIVE The purpose of this Plant-wide Solar Feasibility Study (Study) is to provide a detailed technical and financial assessment of the issues facing the Metropolitan Water District of Southern California (Metropolitan) as it implements the solar program component of its Strategic Power Plan (SPP). The specific focus of this study is to assess and provide recommendations for the staged implementation of solar power production at Metropolitan’s five water treatment plants (WTPs): Joseph P. Jensen, F.E. Weymouth, Robert A. Skinner, Robert B. Diemer, and Henry J. Mills WTPs. The broader issues of financial, regulatory, and technical constraints and drivers concerning the implementation of renewable energy were also evaluated. These issues are structured into a preliminary planning framework. The goal is to provide a recommendation to guide and direct Metropolitan’s future energy management efforts related to the SPP. PROGRAM INTRODUCTION This study is the culmination of several months of master planning efforts by Metropolitan staff and consultants to develop a realistic, attainable, and cost effective expansion plan of solar power facilities at Metropolitan’s five water treatment plants. The results of this Study shall support the preliminary design phase of project implementation. This study is a high-level analysis of the feasibility of implementing solar power within Metropolitan’s service area, specifically at the WTPs, but also at satellite locations that could become feasible locations for solar/renewable energy generation, if current laws and regulations are changed to allow expanded net metering or feed-in tariffs. Specific topics covered in this Study include: • • • • • • Detailed financial analyses at each WTP Project delivery methods and purchasing mechanisms Existing and proposed laws and regulations related to implementation of renewable energy Sizing analyses and recommendations for solar facilities at each WTP Recommendations for programmatic oversight of the solar initiative as related to Metropolitan’s Strategic Power Plan Recommendations for continued oversight of laws and regulations as they evolve and change over the coming years The Preliminary Design Report (PDR) that will follow this study, will analyze specific aspects to implementing solar facilities at the five water treatment plants. Specific topics covered in the PDR will include: • • • • MWH Site layouts and future plans Conduit runs with points of connection Electrical single-line diagrams Other appurtenant information relevant to CEQA documentation and final design 2-1 Plant-wide Solar Feasibility Study In general, the implementation of solar generation facilities at Metropolitan’s water treatment plants is feasible and practical for three main reasons: 1) Each WTP has a high base load electrical consumptions 2) The electrical consumption at three of five WTPs will increase in the future when ozone disinfection is ultimately implemented at all the WTPs 3) Each WTP has land available on which solar facilities may be constructed. In addition, Metropolitan is interested is developing solar facilities in order to invest in the expansion of its renewable energy portfolio. The expansion may assist in demonstrating compliance with future renewable portfolio standards under which Metropolitan may be regulated; see Section 3 (Laws, Rules, & Regulations) for further discussion. Irrespective of future regulations, development of additional renewable energy facilities will demonstrate the commitment by Metropolitan to reduce its carbon footprint and reliance on greenhouse-gas producing energy. Moreover, implementation of renewable energy facilities will assist in hedging against future price increases and volatility in the retail electricity market. PURPOSE AND NECESSITY OF THE PROGRAM The mission of the Metropolitan Water District of Southern California is to provide its service area with adequate and reliable supplies of high-quality water to meet present and future needs in an environmentally and economically responsible way. As a leader in the water and utility industry, Metropolitan has made great strides in developing water conservation strategies that have substantially reduced per capita retail demand throughout its five-county service area. The conveyance, treatment, and distribution of water is a highly energy dependent process. As such, Metropolitan – as a steward of the public and in conjunction with its mission – has goals and aspirations to show leadership in the areas of sustainability as well as and energy conservation. The 2008/09 General Manager’s Business Plan outlines several strategic priorities, including sustainability. In particular, the Business Plan states: Metropolitan is faced with many challenges to ensure the long-term viability and sustainability of Southern California’s water supply serving over 18 million people. The challenges include the potential impacts of changing climate, increased urbanization, endangered species, increased environmental regulation and litigation, increasing competition for water, and population pressures. Metropolitan is committed to addressing these issues and ensuring long-term, high quality water supply in a manner that promotes our commitment to sustainability and reduces our environmental footprint. The Business Case for implementing solar renewable energy facilities fits well within the General Manager’s initiatives to commit to sustainability and the reduction of Metropolitan’s carbon footprint. Additionally, sustainability and environmental footprint concepts related to the Business Plan have been outlined at and through various forums over the past several years, including Metropolitan Board retreats, Board policies, and Board actions on projects to develop renewable energy facilities. As such, implementation and expansion of solar renewable energy facilities as described in this Study are directly related to these Board initiatives and actions, as MWH 2-2 Plant-wide Solar Feasibility Study described below. The Board’s retreats, actions, and policies form the basis for the purpose of the solar program and its necessity in the context of the SPP. April 2007 Board of Directors Retreat The 2007 Annual Board of Director’s Retreat highlighted several strategic priorities to assess, plan and implement in the coming years by Metropolitan. Included in the 2007 retreat, in light of California’s Global Warming Solutions Act of 20061, was the Board’s call for a reduction in Metropolitan’s carbon footprint and mitigation against risks associated with future carbon-related fees and regulations. Key energy issues identified and targeted for action by the Board during the April 2007 Retreat included: 1) price volatility 2) system reliability 3) environmental stewardship 4) energy independence 5) cost 6) implementation risk, including technical complexity and feasibility. Strategic Power Plan, 2008-09 During the 2008-09 fiscal year (FY) a variety of energy-related briefings on the SPP were given to Metropolitan’s Board. The presentations provided approval of updated Energy Policy Principals, information regarding Metropolitan’s activities related to the next Hoover power contract in 2017, and historical energy consumption and cost data for Metropolitan’s distribution system, the Colorado River Aqueduct (CRA) and the State Water Project (SWP). Over the course of several Board informational reports and presentations, a series of proposed SPP Policy Goals were identified. These SPP Policy Goals were brought to Metropolitan’s Board in July 2009 for adoption. If approved, the following actions will be implemented by Metropolitan: Immediate Actions (by FY 2010/11): • Expedite renewable energy at Metropolitan’s WTPs o Negotiate agreements to achieve 100 percent renewable hydroelectric power use at the Diemer plant. o Achieve 25 percent renewable power use to meet summer on-peak energy consumption at the Skinner plant ($10 million – Board approved project). o Complete design for a 1 MW solar facility to meet on-peak energy use at the Weymouth plant ($1 million – request Board approval September 2009). 1 The Global Warming Solutions Act of 2006 requires that by 2020 the state's greenhouse gas emissions be reduced to 1990 levels, a roughly 25% reduction under business as usual estimates. MWH 2-3 Plant-wide Solar Feasibility Study o Develop Request for Proposals (RFP)/Request for Bids (RFB) for approximately an additional 9 MW of solar project development at the treatment plants and execute implementation contracts. • Expedite renewable energy and energy efficiency projects at Union Station Headquarters o Establish partnerships with the Metropolitan Transit Authority (MTA), AMTRAK, and the Los Angeles Department of Water and Power (LADWP) to install solar facilities at Metropolitan’s headquarters and near-by MTA and Union Station train sites. • Expedite renewable energy along the Colorado River Aqueduct. o Establish partnerships for development of renewable energy projects located in the desert to meet CRA supplemental power requirements. Short-term Goal (by 2014): • Implement renewable energy programs to achieve a 50 percent carbon reduction in Metropolitan’s distribution system (for retail energy facilities, including WTPs, pumping facilities, and Union Station Headquarters) via renewable energy projects including solar and small hydroelectric facilities. • Establish partnership(s) with the Southern California Public Power Authority (SCPPA) and/or power developers to invest in renewable energy supplies that will achieve energy independence at Metropolitan’s CRA pumping plants in a phased and cost-effective manner. • Evaluate the potential for partnerships and for developing large-scale renewable energy projects that could meet a portion of the regional power needs, including that of Metropolitan, its member agencies, and future desalination facilities. Determine what potential changes to Metropolitan’s Act, if any, would be needed to implement this goal. • Work with the Department of Water Resources and State Water Contractors on State Water Project energy and carbon management issues. Intermediate Goal (by 2020): • Achieve 100 percent carbon reduction at all of Metropolitan’s distribution facilities (for retail energy facilities, including treatment plants, pumping facilities, and Union Station Headquarters) and a 50 percent carbon reduction from non-hydroelectric energy use on the CRA (wholesale energy facilities). Long-term Goal (by 2030): • Achieve 100 percent carbon reduction at all of Metropolitan’s distribution facilities (for retail energy facilities including treatment plants, pumping facilities, and Union Station Headquarters) and a 100 percent carbon reduction from non-hydroelectric energy use on the CRA (wholesale energy facilities). MWH 2-4 Plant-wide Solar Feasibility Study Skinner & Weymouth Solar Power Generation Facilities The Skinner Solar Power Generation Facility is Metropolitan’s first venture into large-scale solar power generation facilities. The project was implemented utilizing Metropolitan’s traditional capital project delivery method of design-bid-build. The project was planned, designed, and constructed over a two-year period, with preliminary design funding secured in June 2007, final design in November 2007, and the awarding of a construction contract in July 2008. Completed in April 2009, the project is projected to generate over 2.3 million kilowatt-hours (kWhs) annually of clean, renewable energy. An initial capital investment of nearly $10 million was required for the project, with an expected return on investment (ROI) of approximately eight years. The ROI is based on reductions in retail energy consumption at the current bundled retail rate of $0.12/kWh (escalated at 3% annually), as well as rebates Metropolitan will receive from Southern California Edison. Solar energy decreases the amount of retail energy that is purchased at retail electricity rates. Metropolitan expects to receive over $5 million in rebates based on actual solar power generation applied to Metropolitan’s reserved rebate structure of $0.46/kWh over the first five years of operation, as part of the California Solar Initiative (CSI). Metropolitan further demonstrated its commitment to expanding its solar renewable energy portfolio with approval of preliminary design of the 1 MW Weymouth Solar Power Generation Facility, in May 2008. Since that time, Metropolitan staff have completed the preliminary design and has assessed the project under environmental guidelines. Solar Program Relationship to the Strategic Power Plan In conjunction with the SPP, staff also initiated studies at the remaining WTPs, which form the basis of this Study. Implementation of solar facilities identified herein would reduce Metropolitan’s retail-level carbon footprint by approximately 20%. Conversion of the Yorba Linda Power Plant to meet all of the Diemer plant’s electrical needs would further reduce Metropolitan’s retail-level carbon footprint by an additional 10%. It should be noted that in order to meet the goals of the SPP, large-scale solar power generation facilities must meet three main objectives: 1. Implementation of the facilities must have a sound financial and business case to Metropolitan, with a reasonable return on investment 2. The facilities must have the ability to offset a large portion of the retail electricity demand at each installed location, in order to hedge against substantially large future retail rate increases 3. Metropolitan must retain 100% of the renewable energy credits (RECs) generated by each facility. DRIVERS AND CONSTRAINTS The California Energy Commission has estimated that approximately 5% of all electricity used in the state of California is for the treatment and transport of water; while water related energy MWH 2-5 Plant-wide Solar Feasibility Study use comprises 20% of the State’s electricity2. The SPP is Metropolitan’s response to action as an environmental steward to reduce the consumption of fossil fuels. Supported by its traditional core business of providing water and now with a new plan to generate renewable energy, Metropolitan is taking an active role at the water/energy nexus to reduce power demands and associated green house gas emissions attributed to the water industry. This new focus on energy provides opportunities and efficiencies as well as challenges. A focus on energy has the potential to drive down operating costs significantly over the long-term. However, the financial and technical challenges relevant to large-scale implementation of renewable energy creates an atypical set of drivers, compared to those normally association with water industry projects and initiatives. These drivers include: • • • • Regulatory Environment Drivers o Assembly Bill (AB) 32 regulations o Interconnection policy for power providers o Other state and federal regulations Solar Industry Drivers o Financing and market outlook Financial Drivers o Hedge against retail electricity rate increases o Market volatility o Purchasing mechanisms (e.g. PPA, capital purchase, etc.) Technical Drivers o Space constraints This Study analyzes these drivers and constraints as they relate to the implementation of the first phase of Metropolitan’s Strategic Power Plan. Major activities currently underway include 1) operation of the recently constructed Skinner 1 MW solar project, 2) conversion of the SCE hydroelectric contract at the Diemer plant in 2010/11, and 3) implementation of the recommendations included in this report for solar installations at Metropolitan’s water treatment plants between 2010-2014. 2 California Energy Commission. California’s Water – Energy Relationship Final Staff Report. 2005. MWH 2-6 Plant-wide Solar Feasibility Study SECTION 3 LAWS, RULES AND REGULATIONS EXISTING REGULATORY FRAMEWORK Jurisdictional Issues An analysis of the allowances and constraints to the existing regulatory framework is critical to the analysis of available solar resources and the successful implementation of Metropolitan’s solar program. Under California’s regulatory scheme, the energy industry is divided into retail and wholesale energy markets. Wholesale energy is generation that is sold in bulk for resale, while retail energy is sold in smaller quantities to end-use customers. Wholesale energy sales by privately owned entities such as investor-owned utilities (IOUs) and independent power producers are subject to regulation by the Federal Energy Regulatory Commission (FERC). Energy from Metropolitan’s small hydrogenation facilities is sold at wholesale to local electric utilities. Additionally, as Metropolitan is a quasi-municipal corporation, Metropolitan is not a “public utility” as defined in Section 201 of the Federal Power Act. Thus, Metropolitan is exempt from direct FERC regulation, although FERC does have some oversight of Metropolitan because of its wholesale generation and transmission ownership (e.g., electric reliability standards). The sale of retail energy by IOUs is regulated at the state level by the California Public Utility Commission (CPUC). There are three primary IOUs or “electric corporations” in California: Pacific, Gas & Electric (PG&E), Southern California Edison (SCE), and San Diego Gas & Electric (SDG&E). Publicly-owned utilities are referred to as “municipal utilities” and also as local publicly owned electric utilities (LPOEUs). LPOUEs providing retail service are largely self-regulated by their respective governing boards, with limited oversight by the CEC. Although Metropolitan appears to meet the statutory definition of an LPOEU, it is largely exempt from CEC oversight because it does not server retail end use customers. Metropolitan’s Authority to Develop Solar Power Metropolitan was created by an act of the California Legislature and is a limited–purpose municipal corporation, created primarily to convey, treat, and deliver water to its member agencies on a wholesale basis. However, the Legislature has authorized Metropolitan to generate power for its water supply purposes. Expressly, Metropolitan was created for “the purpose of developing, storing, and distributing water for domestic and municipal purposes and may provide, generate, and deliver electric power within or without the state for the purpose of MWH 3-1 Plant-wide Solar Feasibility Study developing, storing, and distributing water for such district.”3 Thus, Metropolitan has authority to develop solar power for use at its facilities, including its water treatment plants as addressed in this study. Additionally, a reasonable interpretation of Metropolitan’s organic authority allows for the development of solar power at off-site facilities for use to offset electrical costs at Metropolitan facilities as permitted under existing law. Metropolitan hopes to maximize the benefits of existing solar programs to reduce its use of greenhouse gas emitting electricity resources. RELEVANT STATE SOLAR PROGRAMS Other than federal grant and tax credit programs that subsidize the cost of solar projects, the federal government is typically uninvolved in smaller-scale solar generation. This study focuses on the applicable state solar programs overseen primarily by the CPUC for IOUs, and the CEC for LPOEUs, as discussed in more detail below. California Solar Initiative (CSI) In 2007, the state launched the Go Solar California campaign, established by the Legislature through the enactment of Senate Bill (SB) 1. Today, the Go Solar California campaign has a goal to create 3,000 MW of new, solar-produced electricity by 2016, with a statewide budget of $3.3 billion over 10 years. The California Solar Initiative (CSI) was developed by the CPUC for the IOUs. CSI provides cash incentives for each kilowatt-hour of customer-generated solar energy for the first five years and the rate per unit of electricity varies by organizational class with different levels for residential, commercial, and government/non-profit. The CSI program is also a tiered incentive program where early solar purchasers receive a larger rebate rate. Currently, the CSI program for SCE is at the fifth tier where the rebate for government/non-profit agencies is $0.32/kWh and the rebate for commercial agencies is $0.22/kWh. The generation incentives are funded through a surcharge on IOU customer bills. The CSI program allows non-residential solar systems up to 5 MWs, but only provides incentives for the first 1 MW of capacity. Incentive payments are calculated for solar energy systems that exceed 1 MW in size by prorating the energy output based on the ratio of 1 MW to the size of the site. Thus, if a customer installed a 5 MW system, the customer would receive incentive payments for 1/5 of the output of the system. As an alternative, the customer may, at its election and cost, separately meter a 1 MW element of a larger system. Under CSI, customers must execute an interconnection agreement with the host utility. Receipt of CSI incentives does not require transfer or sale of the RECs to the host utility; instead, they are held by the customer-owner of the solar facility and may be sold by the customer regardless of receipt of CSI incentives. Each local utility has developed and implemented its own program to meet the mandates of SB 1 3 See MWD Act §§ 25, 139. Section 139 states: “A district may acquire, construct, operate, and maintain any and all works, facilities, improvements, and property to provide, generate, and deliver electric power within or without the state necessary or convenient to carry out the objects or purposes of the district.” Section 25 states Metropolitan purposes, as set forth above, limiting Metropolitan’s rights to generate and sell power to Metropolitan’s water conveyance purposes. MWH 3-2 Plant-wide Solar Feasibility Study and each LPOEU’s solar program is self-regulated, with limited CEC oversight. Metropolitan has water treatment plants within the service areas of SCE, the Los Angeles Department of Water and Power (LADWP) and Riverside Public Utilities (RPU), each of which has their own solar programs, discussed in more detail below. Renewable Portfolio Standard Program (RPS) California’s Renewable Portfolio Standard Program (RPS Program) is a further major commitment to renewable energy. As of 2002, existing law directed the CPUC to require the IOUs to reserve or set aside a specific portion of future generating capacity for renewable resources. In 2002, legislation was enacted to require utilities to increase procurement of electricity from renewable energy sources by at least one percent per year, which was set to meet a target of 20% renewable energy by 2017. The program was accelerated in 2006 under Senate Bill 107 that required IOUs and other CPUC-regulated entities, but not the municipal or locally owned utilities, to increase procurement from eligible renewable energy resources by at least 1% of their retail sales annually, until they reach 20% by 2010. In November 2008, the Governor issued Executive Order S-14-08 increasing the target for all electric utilities (including LPOEUs) to 33% by 2020. Several legislative proposals are currently pending to codify the Governor’s increased RPS mandates, and some form of these requirements is expected to be enacted this year. Of significance, the current RPS Program only applies to retail suppliers who deliver energy to end-use customers, specifically, “entit[ies] engaged in the retail sale of electricity to end-use customers located within the state.” RPS standards are calculated as a portion of total annual retail load. Since Metropolitan serves no retail end-use customers, it is not subject to the current RPS Program. Under the current RPS Program, IOUs are subject to an RPS mandate, enforced via the CPUC, requiring IOUs to acquire certain percentages of renewable energy resources by certain dates, specifically setting targets of 20 percent of total retail sales being met with renewable energy resources by 2010. Existing law defines what qualifies as “renewable energy resources” for IOUs and the CPUC determines the amount of generation that counts toward meeting the RPS standard. Among other things, only small hydroelectric generation facilities having a maximum generation capacity of 30 MW are considered a renewable energy resource. This limit prevents facilities, like Metropolitan’s plant at Diamond Valley Lake and others that can generate over 30 MW per year, from counting as a renewable energy resource for purposes of meeting the current RPS. Publicly owned utilities that sell to retail customers are also required to develop RPS programs, although they retain considerable discretion in determining what qualifies as a renewable energy resource and when they will achieve their RPS target because LPOEUs are self-regulated. For example, many LPOEUs have included energy from hydroelectric power resources that exceed the 30 MW limit in reporting their RPS results. The CEC has very limited jurisdiction over the LPOEUs self-regulated RPS programs, limited primarily to review and reporting functions. MWH 3-3 Plant-wide Solar Feasibility Study Pending legislation proposes to mandate the RPS 33% by 2020 goal on LPOEUs, but only as to retail sellers. Because Metropolitan and DWR (and SWP) are not retail sellers, the current and proposed RPS mandates do not apply to them. Also, as a state agency, DWR is not an LPOEU and is expressly exempt from RPS laws so the RPS standards in existing law and pending legislation do not apply to SWP. AB-32 In 2006, the Legislature enacted Assembly Bill (AB) 32, the Global Warming Solutions Act, which set a goal to reduce greenhouse gas (GHG) emissions in California by 25 percent by 2020. It directed the California Air Resources Board (CARB) to begin developing discrete early actions to reduce GHG while also preparing a scoping plan to identify how best to reach the 2020 limit. The reduction measures to meet the 2020 target are to be adopted by the start of 2011, and to be in effect and enforceable by 2012. Assembly Bill 32 includes a number of specific requirements of relevance to Metropolitan: • CARB shall prepare and approve a scoping plan for achieving the maximum technologically feasible and cost-effective reductions in GHG emissions from sources or categories of sources of GHGs by 2020. The scoping plan, approved by the CARB Board December 12, 2008, provides the outline for actions to reduce GHGs in California. The approved scoping plan indicates how these emission reductions will be achieved from significant GHG sources via regulations, market mechanisms and other actions. The scoping plan identifies increasing the RPS standards to 33% by 2020, the development of a carbon cap and trade program, and a public good charge on water as potential mechanisms to achieve GHG reductions. • Identify the statewide level of GHG emissions in 1990 to serve as the emissions limit to be achieved by 2020. In December 2007, the Board approved the 2020 emission limit of 427 million metric tons of carbon dioxide equivalent (MMTCO2E) of GHGs. • Adopt a regulation requiring the mandatory reporting of GHG emissions. In December 2007, the Board adopted a regulation requiring the largest industrial sources to report and to verify their GHG emissions. The reporting regulation serves as a solid foundation to determine GHG emissions and track future changes in emission levels. • Identify and adopt regulations for discrete early actions that could be enforceable on or before January 1, 2010. The Board identified nine discrete early action measures including regulations affecting landfills, motor vehicle fuels, refrigerants in cars, tire pressure, port operations and other sources in 2007 that included ship electrification at ports and reduction of high global warming potential gases in consumer products. Regulatory development for the remaining measures is ongoing. Currently, except for reporting requirements associated with its Colorado River Aqueduct load, Metropolitan is not directly affected by proposed regulatory mandates or requirements. Hence, any carbon reduction actions that Metropolitan enacts are on a purely voluntary basis. However, MWH 3-4 Plant-wide Solar Feasibility Study it is possible that future regulatory changes could affect Metropolitan directly. Also, the proposed public goods charge on water would indirectly impact Metropolitan’s ability to increase water rates, adding to the overall cost of water conveyance statewide. Thus, Metropolitan, like all other retail customers, will share in the costs of electric utility implementation of AB 32. Finally, state regulators are beginning to coordinate AB 32 and RPS efforts, intertwining the mandates and goals of both programs. For these reasons, Metropolitan is carefully monitoring AB 32 and recognizes the potential for future impacts. The SPP policy goals provide for a means to mitigate this risk, as well as Metropolitan’s exposure to future carbon related fees. While no federal plan for GHG reduction currently exists, bills have been introduced that would establish a cap and trade market and limit GHG emissions. It is likely that federal legislation on GHG reduction or limits will be enacted within the next two sessions of Congress. Such legislation could pre-empt AB 32. Sale of Excess Renewable Generation The three programs that allow utility customers to sell excess renewable generation are netmetering, feed-in-tariff (FIT), and virtual net metering. Net-metering allows customers to receive a retail level credit (in kWhs), for excess power placed on the grid. However, if the customer generates more than he/she consumes over the course of a year, the credit is eliminated and the customer is not paid for that excess generation. A FIT allows customers to sell their generation to the utility at a fixed wholesale rate which is less than the retail rate paid by the utility customers. Both net-metering and FIT programs apply the credit or sale to the location at which the customer is generating the renewable energy. Virtual net metering permits a customer to credit generation in excess of its energy use at one location against its energy uses at another location within the same utility’s jurisdiction. This is particularly helpful for public agencies or commercial customers with multiple locations within a single utility jurisdiction. Net Metering – SB 656 & AB 58 Net metering is an electricity policy for consumers who own (generally small) renewable energy facilities, such as wind, solar power or home fuel cells. “Net”, is used in the sense of meaning “what remains after deductions” — in this case, the deduction of any energy outflows from metered energy inflows. Under net metering, a system owner receives retail credit (in kWhs), for whatever generation is in excess of its energy consumption. However, under California netmetering law, if you generate more electricity than you use over a 12-month period (which starts upon beginning of net metering agreement), you will not make any money or get any credit for it, in effect you give away your extra energy if you do not use it. To remedy these losses, renewable energy advocates are working to enact FITs as a complement to net-metering and to incentivize additional renewable production. In addition, the CPUC regulations provide that the customer maintains ownership of all of the renewable energy credits generated by the system, including the credited energy. California’s initial net metering law was significantly expanded in 2001, with enactment of Assembly Bill 58, and now allows retail customers to install renewable energy facilities sized up to 1 MW. AB 58 is applicable to all IOUs and LPOEUs except LADWP, which it expressly MWH 3-5 Plant-wide Solar Feasibility Study exempts.4 Since January 2001, utility customers have installed 596 net metered projects totaling 25.1 MW. California’s net metering law, codified in California Public Utilities Code Section 2827, currently caps the utilities’ obligations to allow net metering facilities to an amount equal to two and a half percent of the utility’s total aggregate peak demand. There are pending legislative efforts to increase this cap. Section 2827 exempts net metering customer-generators from “standby rates,” which are monthly charges based on costs the utility incurs for installing and maintaining distribution infrastructure to serve the customer’s load when the customer’s generating system is not operating. Section 2827 also exempts customer generators from any additional demand, interconnection, or other charges not paid by a customer without net metering. While exempt from the state net metering program, DWP has developed its own net metering program which allows credits to accumulate until the termination of service, at which point they are given to the utility without compensation. Feed-In-Tariffs – AB 1969 & SB 380 A feed-in tariff is an incentive structure to encourage the adoption of renewable energy through government legislation that requires electricity utilities to buy wholesale renewable electricity at established rates set by the government. The California Feed-In Tariff Program (FIT Program) was developed to provide further incentives for development of smaller wholesale renewable energy facilities in California. Unlike net metering, where system owner receives a credit in kWhs for the generation that is in excess of a customer’s needs, under a FIT the energy placed onto the grid is sold to the utility at wholesale rates. There are two options when selling electricity under a FIT: all energy or excess energy. Under the all energy option, the system owner sells the total production of the system to the utility at wholesale rates and purchases all of its electrical demand at retail rates. Under the excess energy option, generation onsite is first used to meet system demand and excess electricity is sold to the utility at wholesale rates. In either option, the utility receives the renewable energy credits for the electricity it purchases and can count that electricity toward its RPS. In addition, feed-in-tariffs cannot be used in conjunction with the CPUC’s California Solar Initiative (CSI), Self-Generation Incentive Program (SGIP), the Renewable Portfolio Standard (RPS) program, net metering programs, or any other ratepayer funded generation incentive program. Initially, under AB 1969, enacted in 2006, FITs were limited to installation of renewable generation at publicly owned water and wastewater treatment facilities located in IOU service territories. However, the FIT Program was expanded in 2008 with the passage of SB 380, 4 California Public Utilities Code § 2827(b)(3) exempts LADWP by definition: “Electric distribution utility or cooperative” means an electrical corporation, a local publicly owned electric utility, or an electrical cooperative, or any other entity, except an electric service provider, that offers electrical service. This section shall not apply to a local publicly owned electric utility that serves more than 750,000 customers and that also conveys water to its customers. MWH 3-6 Plant-wide Solar Feasibility Study making FITs available for all wholesale renewable generation facilities up to 1.5 MW, and until 500 MW of generation is installed5. The CPUC is currently engaged in rulemaking to expand the FIT to larger renewable facilities. The FIT Program only applies to CPUC-regulated jurisdictions. Metropolitan may be able to benefit from the FIT Program for solar facilities within SCE’s service area, although it is unclear whether the FIT rate is sufficiently high to warrant its use. However, there has been recent controversy over CPUC’s authority to implement FITs. SCE recently argued that the development of FITs establishes wholesale electric rates which are solely within FERC’s jurisdiction and therefore outside of the CPUC’s ability to regulate. It is not clear how this debate will be resolved, but Metropolitan will continue to monitor the proceedings at the CPUC. Virtual Net Metering – AB 2466 Under California’s “virtual net metering” program, a local government customer6, receives a credit for generation in excess of a customer’s energy use at one location, which is applied to its energy use at another location. This program applies only to CPUC-regulated utilities, primarily the IOUs and not the LPOEUs. With the passage of AB 2466 in 2008, codified in California Public Utility Code Section 2830, the Legislature authorizes a local government entity to install a renewable generating facility up to 1 MW on land it owns or controls, and to apply as a credit any generation in excess of its energy use at that location to its use at another location. The amount of the credit is based on the generation component of the customer’s rate schedule and not on the full retail rate. At the end of every 12-month period, any generation in excess of consumption is given to the utility without charge. Similar to the net-metering program, the customer owns all RECs for the amount of energy credited and the electric corporation is not allowed to count the energy toward its RPS requirements. Unfortunately, this program is limited to 1 MW. In addition, it is not clear whether Metropolitan will be able to use virtual net metering or not. First, it is unlikely that Metropolitan would have excess generation from a facility limited to 1 MW that could be credited against its energy use at another site. Second, Section 2830(b)(7) of the California Public Utility Code requires that the “local government does not sell electricity exported to the electrical grid to a third party.” Read literally, this could prevent Metropolitan from benefiting from the program because of its sales of hydroelectric power from its small conduit generating facilities to third parties. However, it appears that the intent of the law was simply to ensure that the renewable energy facility receiving the credit be used for the local governments own use, and not that no other resources could be sold. If Metropolitan wishes to pursue this option, it should request an advisory opinion from SCE regarding its eligibility for this recently initiated program. SCE’s program implies that 5 SCE and PG&E may permit facilities up to 1.5 MW; SDG&E may permit facilities up to 1 MW “Local government” is defined broadly as “a city, county, whether general law or chartered, city and county, special district, school district, political subdivision, or other local public agency, if authorized by law to generate electricity, but shall not mean the state, any agency or department of the state, or joint powers authority.” Cal. Public Util. Code § 2830(a)(5). Metropolitan qualifies as a political subdivision and a local public agency under this definition 6 MWH 3-7 Plant-wide Solar Feasibility Study it cannot be used in combination with its net metering program, so Metropolitan may choose to use net metering instead if this anomalous issue is not readily resolved. METROPOLITAN LOCAL ELECTRIC JURISDICTIONS’ SOLAR PROGRAMS Metropolitan’s solar program is initially focused on the development of solar facilities at its five water treatment plants: Joseph P. Jensen, F.E. Weymouth, Robert A. Skinner, Robert B. Diemer, and Henry J. Mills WTPs. The Jensen plant is located in Los Angeles County and receives retail electric service from the Los Angeles Department of Water and Power (LADWP). The Mills plant is located in and receives retail electric service from the Riverside Public Utilities. The remaining three plants—Weymouth (located in Los Angeles County), Skinner (located in Riverside County), and Diemer (located in Orange County)—are within Southern California Edison’s service area. In addition to plants, small generation projects may be developed at the Metropolitan headquarters building located in Los Angeles County in LADWP’s service area. Future studies will also analyze the feasibility of solar along the Colorado River Aqueduct, largely in Riverside County. In order to better assess the first phase of the solar program, development at Metropolitan water treatment plants, a closer analysis of the available programs in the service areas of SCE, RPU, and LADWP is required. Southern California Edison SCE is an investor-owned utility (IOU) regulated by the CPUC. Metropolitan’s Weymouth, Skinner, and Diemer WTPs lie in SCE’s service area, and could benefit from its well-developed solar initiative programs. These primarily include CSI and net-metering. Under CSI, Metropolitan is able to obtain incentives for the development of solar facilities, which are discussed in detail above and applied in the WTP case studies throughout this study. Under the net-metering program, Metropolitan could net meter energy produced from a solar facility up to 1 MW in size. It is less clear whether Metropolitan may benefit from SCE’s feedin-tariff or virtual net metering programs. The feed-in-tariff program would allow Metropolitan to sell energy from a solar facility, up to 1.5 MW, to SCE. However, this tariff has been controversial. Metropolitan is monitoring the CPUC proceedings in the hopes of benefiting from it in the future. As noted above, it is unclear whether Metropolitan may benefit from the virtual net metering tariff because of its sales to third-parties, but Metropolitan should seek an opinion from SCE regarding this issue because it isn’t clear the program was intended to preclude application to Metropolitan. However, Metropolitan will have to opt for either net-metering or virtual net metering at each of its facilities, and may choose to go with the latter to avoid any controversy. Riverside Public Utility RPU is the subdivision of the City of Riverside, and provider of local utility service to the city’s approximately 312,000 residents. Metropolitan’s Mills plant lies within RPU’s service area and its solar programs would be subject to RPU approval. RPU is a LPOEU and has limited solar initiative programs, but it is not prohibited from developing new or customer-specific programs. MWH 3-8 Plant-wide Solar Feasibility Study RPU’s lone program is the Non-Residential Photovoltaic (PV) System rebate program, under which it implements the SB 1 and net-metering mandates. Under this program, RPU provides financial incentives to business customers who purchase and install solar energy systems. The program offers a $3.00 per watt rebate not to exceed 50% of the project cost up to an incentive cap of $50,000 per flat rate customer. The incentive cap for demand customers is $200,000 and the incentive cap for large industrial time-of-use customers is $500,000. The goal is to provide a rebate to five non-residential customers per fiscal year for installing qualified PV systems. RPU customer generators are eligible if they have solar facilities with a capacity of not more than 1 MW that are located on the customer’s premises, are interconnected and operating in parallel with the RPU’s transmission and distribution facilities, and are intended primarily to offset part or all of the customer’s own electrical requirements on the premises. Applicants must execute (1) a Net Energy Metering (NEM) Agreement with the City of Riverside Public Utilities prior to final connection to the grid and before any incentive can be paid and (2) if requested by RPU, an agreement for receipt of incentive funds. In addition to allowing Metropolitan to construct and operate its own solar system, RPU’s rebate program appears to allow third-party ownership via a power purchase agreement. However, Metropolitan should negotiate this issue with RPU to confirm that third-party ownership arrangements are allowed, in addition to any alternative arrangements. For future solar facilities at its Mills plant, Metropolitan could apply for this program or negotiate with RPU to develop a site-specific project. Given the limitations of the current program, Metropolitan should consider working with RPU to develop a more generous incentive, if possible. Los Angeles Department of Water and Power LADWP is the largest municipal utility in the nation. Metropolitan’s Jensen plant, Union Station headquarters building, and Soto Street maintenance facility are located in LADWP’s service area. In compliance with SB 1, LADWP has implemented its Solar Photovoltaic Incentive Program (Incentive Program) that provides an incentive payment to LADWP customers that purchase and install their own solar power PV systems. LADWP’s has set aside $313 million to fund its incentive program. Under its program, LADWP provides incentive payments for solar facilities up to 1 MW per billing meter, per fiscal year, although actual system size may be larger based on historic annual usage. Subject to the availability of funding, LADWP may allow up to 2 MWs of funding subject to a reduced incentive payment. In no case will LADWP provide an incentive of more than 50% of commercial systems of the gross installed system cost, regardless of system size or incentive level. Any energy generated by the solar power system must be either utilized on site by the customer or credited back to LADWP in accordance with the city’s net metering ordinance as it is exempt from the state net-metering requirements as discussed above. Energy cannot be sold to any other entities. MWH 3-9 Plant-wide Solar Feasibility Study To receive an incentive payment from LADWP, customers must apply for and receive a written, confirmed reservation number issued by the Solar Energy Group. LADWP incentive payments are based on the estimated performance of the solar system. An annual kilowatt hour output is estimated and a formula is applied to give the customer a one-time payment for 20 years of solar production. Details of the incentive payment formula are available in LADWP’s Incentive Program guidelines (at http://www.ladwp.com/ladwp/cms/ladwp009742.pdf). Customers may elect to have ownership of the Renewable Energy Credits (RECs), but incentives are proportionally reduced based on this ownership. LADWP’s rebate program currently prohibits third-party ownership via a power purchase agreement. However, LADWP does allow third-party ownership through leasing and other agreements that are not based on payments for energy production.7 PPAs and leasing agreements typically provide similar results. Metropolitan’s Los Angeles facilities--Jensen plant, headquarters building, and Soto Street maintenance facility--are eligible for DWP’s Incentive Program, including its net-metering provisions. SUMMARY In summary, Metropolitan may benefit from several statewide solar initiatives. SCE, RPU, and LADWP all provide incentive payments and net-metering benefits. However, most net-metering programs are limited to 1 MW at this time. SCE also provides a FIT for up to 1.5 MW facilities, although the future of this program is in question as discussed above. There are numerous legislative and regulatory proposals to increase the statewide solar programs, including proposals to increase the statewide CSI caps and net-metering and FIT allowances. Metropolitan will continue to monitor these programs and work with public utility interest groups, including the California Municipal Utility Association, to promote the development of more beneficial state and local solar incentives. Metropolitan will also continue to monitor parallel renewable energy and GHG initiative as the federal level in coordination with the American Public Power Association. 7 For example, LADWP recently allowed the Metropolitan Transit Authority (MTA) to install a rooftop solar facility within its service area where Bank of America owns the solar facility and sells it to MTA over time via a long-term lease, like an installment sale. MTA financed the construction via municipal bonds, paid annually. This arrangement is referred to as a tax exempt leaseback project or TELP. Metropolitan is assessing whether TELPs would be beneficial to it. MWH 3-10 Plant-wide Solar Feasibility Study SECTION 4 PROJECT AND SOLAR INDUSTRY BACKGROUND As the regional water wholesaler for Southern California, Metropolitan’s five water treatment plants are designed to have relatively consistent treatment operations throughout the day and week. Metropolitan does not supply water directly to customers; water is supplied to 26 member agencies. As such, the WTPs are not required to meet the rapidly changing water demand typical of a municipal facility with customer connections. For instance, the treatment approach does not have to address the fluctuating distribution system service pressures, fire flow demands, flushing flow requirements, and similar requirements typical of a municipal utility. Instead, the treatment approach is designed to ensure most efficient treatment operations considering seasonal variation in water source, water supply, and water demand. Metropolitan’s treatment plant operations vary, and as a result, the energy demands are not constant and exhibit considerable diurnal (daily), weekly, and seasonal variations. As part of this study, treatment volume and energy consumption patterns of the treatment facilities were utilized to determine the optimal size of solar power generation at each facility. As solar power production also exhibits both diurnal and seasonal variations, facility sizing needs to be optimized to minimize the cost of lost energy. FACILITY DESCRIPTIONS There are five water treatment plants owned and operated by Metropolitan: Joseph P. Jensen, F.E. Weymouth, Robert A. Skinner, Robert B. Diemer, and Henry J. Mills. These treatment plants are located in Los Angeles, Riverside, and Orange Counties. All five treatment plants employ conventional treatment, which consists of primary disinfection, coagulations, flocculation, sedimentation, filtration, and post-disinfection. Metropolitan is currently upgrading the primary disinfection process at all plants from chlorination to ozonation. Ozone facilities are being phased in over several years and have already been built at the Henry J. Mills plant and the Joseph P. Jensen plant. Ozone facilities will be completed at the Robert A. Skinner plant in 2009 and construction at the remaining two plants will be completed by approximately 2013. Conversion of the treatment plants to utilize ozone disinfection is expected to increase retail energy consumption by up to 100 percent at each plant. The increased energy demand provides incentive for Metropolitan to pursue solar energy facilities at each WTP to reduce the on-peak retail electricity consumption at the plants. ELECTRICAL DEMAND: HISTORICAL AND PROJECTED Electrical demand from the five water treatment plants was 43 million kWh in 2008 and will increase in the future due to the addition of ozone disinfection facilities at all the WTPs. Data from the Mills and Jensen WTPs shows that when ozonation came online, energy use due to the ozone was approximately 50 percent of the total energy consumption of the plant. Therefore, based on the experiences at the Mills and Jensen plants, energy use at the other three plants can be expected to double as ozone is brought online. A summary of the expected energy MWH 4-1 Plant-wide Solar Feasibility Study use post ozone can be found in Table 4-1. Table 4-1 Expected Energy Consumption with Ozonation Water Treatment Plant Energy Consumption PreOzone, 2008 (kWh) Equivalent average demand, kW Energy Consumption Post-Ozone (kWh) Equivalent average demand, kW Joseph P. Jensen Ozone already online - 16,721,000(actual) 1,909 Henry J. Mills Ozone already online - 6,261,000 (actual) 715 F.E. Weymouth 10,703,788 1,222 21,407,576 (projected 2,444 Robert A. Skinner 10,481,529 1,197 20,963,058 (projected) 2,393 Robert B. Diemer 5,049,691 576 10,099,382 (projected) 1,153 OPTIONS FOR SELLING SOLAR DISTRIBUTED GENERATION TO AN INTERCONNECTED UTILITY IN CALIFORNIA Metropolitan’s short-term goal of the SPP is to achieve 50% carbon reduction at all distribution facilities, including all five WTPs. To help achieve this goal there are several renewable energy options. Implementation of 9 MW of solar generation facilities described herein would reduce Metropolitan’s projected retail-level carbon footprint by approximately 20%. The planned conversion of the Yorba Linda Power Plant to meet all of the Diemer plant’s electrical needs would further reduce Metropolitan’s retail-level carbon footprint by an additional 10%. Moving forward with these solar power generation projects at this time, along with identification of additional greenhouse gas reduction measures and projects under the SPP Implementation Plan, would allow Metropolitan to meet the near-term SPP goal of a 50% carbon footprint reduction by 2014. Distributed Generation Distributed generation (DG) generally refers to energy that is generated and used on-site. In contrast, grid energy is generated at centralized power plants and distributed to consumers. Entities engaged in distributed generation are often connected to the power grid to supply energy when demand is greater than production. However, grid-connected distributed generation raises significant technical concerns such as regional grid stability and capacity. Specifically, DG can induce voltage sags and swells, harmonics and flicker due to non-centralized control of the DG power production and export. Thus export of distributed generation to the grid is strictly regulated. To avoid technical issues associated with connecting to the grid, distributed generation can also be isolated from the grid. In 2005, the California Energy Commission (CEC) report “Distributed Generation Interconnection Monitoring: The FOCUS-II Project” included a two-year study evaluating the effects of isolated distributed generation on the California utility grid. Their MWH 4-2 Plant-wide Solar Feasibility Study results indicated that “power quality at the DG systems was generally better than that of the benchmark surveys.” They found that there were no events of the DG impacting the distribution system. This study would indicate the general stability of distributed generation power sources. While the 9 MW of solar will not offset 100 percent of the electrical demand of the WTPs, during peak solar-production the energy generated by the solar system may be in excess of energy demand. There are four implementation scenarios to account for energy produced in excess of demand: behind-the-meter generation, net metering, feed-in-tariffs, and energy storage. The second and third scenarios involve the export of excess electricity to the grid while the first and fourth scenarios involve the system being isolated from the grid. Behind-the-Meter Generation Behind-the-meter generation refers to distributed generation that is not connected to the grid and electricity generated in excess of demand is lost. Behind-the-meter generation can be used to offset purchases of grid electricity and can be financially optimized by timing the peak energy production to coincide with peak price and demand periods. However, since excess electricity is lost, utilizing behind-the-meter generation requires careful selection of system size to minimize those energy losses. The implementation of behind-the-meter generation will require a permitting process, tight electrical controls, and likely negotiation of standby charges. Behind-the-meter generation can be combined with net energy metering to increase the effective size of the solar power installation, but will require two independent sets of onsite electrical controls and metering in order to comply with regulatory requirements. Net Energy Metering Net energy metering (NEM) generically refers to the concept where distributed generation, in excess of demand, is fed back into the grid and the energy generator receives a credit (in kWh) for the electricity. This results in a form of electricity grid storage. In periods where the energy demand is greater than the energy production the credit is reduced, and thus the generator is metered for the “net” energy consumption. Net energy metering is generally only allowable in states that have established an applicable energy policy, due to having to push the utilities to overcome the same technical issues that confront grid-connection distributed generation systems. In California, net metering systems are limited to a capacity of 1 MW. For additional information regarding net metering regulation, please see Section 3. Feed-in Tariffs A feed-in tariff is an incentive structure to encourage the adoption of renewable energy through government legislation that requires electricity utilities to buy renewable electricity at rates set by the government. In California, the feed-in-tariff program is capped at 1.5 MW of renewable energy generation per site and the electric utility will purchase either the total or the excess energy generated by the system at wholesale rates. Renewable energy credits will be transferred to the utility for the amount of electricity they purchase and that electricity will count towards the utilities RPS. Current feed-in tariff rate structures are sufficiently low that interconnection using a feed-in tariff at this time is not feasible, especially when feed-in-tariffs cannot be used in conjunction with the CPUC’s California Solar Initiative (CSI), Self-Generation Incentive Program (SGIP), net metering programs, or any other ratepayer funded generation incentive program. Thus it is not optimal to implement a feed-in-tariff solar system in place of a behind- MWH 4-3 Plant-wide Solar Feasibility Study the-meter generation facility that can receive rebates and other incentives. Should a feed-in-tariff system be implemented it should be noted that for carbon reduction goals, the feed-in-tariff may only be applied to excess energy so the customer can retain the renewable energy credits for the renewable energy it uses. The rules associated with this program are currently under revision which may result in an increased value for energy sold via this program. For additional information regarding feed-intariff regulation, please see Section 3. Onsite Storage Onsite energy storage utilizes a technology, such as batteries, to store electricity so that it can be used at a later time. In the case of solar generation, electricity produced during the day could be stored onsite and used during the night. With an appropriately sized system, this could provide 100 percent of the electricity demand. There are several technologies that can be used to store electricity, though only batteries would be appropriate for applications in the range of a few mega-watts. There are more than half a dozen different type of batteries that show varying degrees of promise including: Polysulfide Bromide Flow Batteries, Vanadium Redox Flow Batteries (VRB), Zinc Bromine Flow Batteries, Sodium Sulfur Batteries (NaS), Lithium Ion Batteries, Traditional Lead-Acid Batteries, and Metal-Air Batteries. Of these batteries, VRB and NaS batteries show the most promise. These technologies, however, have only started to be utilized at a commercial level. Installations of VRB batteries have occurred in California, Florida, and Utah; however the projects were not seen as successful. Installations of NaS batteries have mostly occurred and been successful in Japan where conditions are significantly different than in the United States. Though some installations have been done in the United States, these installations have occurred in the past few years and are too recent to determine the success of the project. Both VRB and NaS batteries are expensive, costing thousands of dollars per kW. Due to this price, these technologies are currently best suited to projects were storage is needed and few if any alternatives exist. Given the state and cost of energy storage technology and the cost of retail grid electricity in California, it is currently economically infeasible to use energy storage to meet net zero grid electricity use. Storing renewable energy, however, could be an option in the future if conditions change or if the priority of other goals, such as net zero grid electricity use, significantly increases. Combined Program Approach The economic return on energy storage is currently negative under current regulatory and financial conditions. Currently, feed-in-tariffs cannot be cost effectively utilized to achieve net zero grid use because the generating agency will lose the right to the renewable power (in the form of a REC) when the electricity is sold to the electricity utility, ratepayer funded generation incentive programs are not available to feed-in-tariff systems, and tariff prices are not presently cost competitive. MWH 4-4 Plant-wide Solar Feasibility Study All of the proposed solar projects at the WTPs are to be designed to offset on-peak electricity consumption. The most robust methodology of generating more energy than the 1 MW net metering is to combine the various programs. First, behind-the-meter generation is used to supply the base load of the WTP and second, net metering is applied to the energy above the base load. A solar system should be optimized to minimize wasting energy to ground but will typically require some level of wasting (1 to 5% on low demand days). MARKET ISSUES: EVALUATION OF SOLAR INDUSTRY In an emerging market, it is difficult to predict the benefits of being an early adopter of a technology or waiting for a better price. It is commonly discussed in the industry that solar energy will reach retail electric rate (aka, grid) parity between 2012 and 2015. Solar market forecasts predict that the cost of electricity from solar systems will decline during this period from its present $0.25/kWh to about $0.10/kWh. Solar panel manufacturing prices are in steady decline and thin film panels are or will be at a $1.00/watt cost very soon (down from $4$6/watt). Manufacturing systems are constantly reducing the time and energy required to produce the panels and contractor competitiveness is slowly gaining ground. Furthermore, funding mechanisms for these systems paired with federal and state incentives is in its infancy. Analyzing the solar industry is a shell game of assumptions. On a macro level, the need for renewable energy is spurred by the threat of oncoming climate change. It is safe to say that there is a cost for dealing with climate change that will affect all aspects of all construction projects and business as usual activities. There is currently no price of carbon incorporated into either Metropolitan’s projects or the manufacturing industry. Incentive programs are steadily declining in the State as PV equipment prices decline resulting in a net stagnant price to install a system in the State. If calculated out with current CSI rebates (provided by SCE), over the life of a project, the system will generate power at a cost of about $0.12/kWh which is nearly at the same retail parity level of 2015. Though equipment price may decline from a raw manufacturing perspective, the new price of doing business in a carbon constrained world will increase. It can be perceived now that in order to win market share, key solar integrators are buying projects with little or negative profit in order to beat the pack of competitors which many of whom are offering nearly identical technologies. One can also safely assume that during this growth period, there will be price instability for several years that can be to the advantage of Metropolitan. In the end, and as presented in this document, it is cost effective for Metropolitan to move forward with solar installations now. Though it is uncertain that installing solar system in 20092010 will be the absolute lowest price point over the next 5-10 years, solar is still a sound investment and will result in medium and long term operations cost savings. MWH 4-5 Plant-wide Solar Feasibility Study SECTION 5 SOLAR SIZING ANALYSIS DATA ANALYSIS Although there are several methods of implementing solar, there are two preferred methods that are recommended given the current regulatory conditions: net metering and behind-the-meter generation. Net metering is the preferred solar installation scenario as solar energy produced in excess of demand can be credited against later use. This reduces the amount of solar that is wasted, or not used, depending on the electricity demand and the solar production. Net metering opens the option for net zero emissions if solar production is greater than energy consumption over a twelve month period. However, net metering is currently only available for facilities up to 1 MW. Since the energy demand at each of the five proposed solar sites is greater than the annual production from a 1 MW facility, over-sizing a net metering facility is not a concern. It is recommended to utilize behind-the-meter generation to serve the minimum standard load at each plant facility. In addition, it is recommended to install 1 MW of net metering. During peak hours behind-the-meter generation will meet most of the retail electricity (aka grid) demand and the excess electricity produced by the 1 MW of net metering will generate electricity credits. These credits offset electricity consumption during the evening/night time periods when solar electricity cannot be produced. Solar sizing for behind-the-meter generation is dependent on the following factors: 1. Variation in electrical energy demand over the day (diurnal variation) and year (seasonal variation) - Daily variation can occur because of various operational requirements, while seasonal variation occurs due to variation in water supply, water demand and temperature. 2. Variation in solar electrical energy production over the day (diurnal variation) and year (seasonal variation) - Diurnal variation occurs because of weather events and the rotation of the earth on its axis while seasonal variation occurs because of climate and rotation of earth around the sun changing the angle of solar incidence. 3. Efficiency of panels – Higher efficiency panels will result in a smaller solar facility size 4. Energy demand per unit volume of water treated – Variation occurs because of changing energy demand for treatment and disinfection, thus even if treated water volume falls, the total energy demand might increase. 5. Total water volume treated – After accounting for energy demand per unit volume, energy consumption will vary with total delivered water volume. 6. Land area available – Land can be a limiting factor because solar generation must occur onsite. 7. Financing option (power purchase agreement (PPA) versus capital purchase) – Applicable tax and revenue benefits vary according to the purchasing entity. 8. Future retail electricity prices – Potential greenhouse gas legislation and other factors MWH 5-1 Plant-wide Solar Feasibility Study may cause energy prices to increase more rapidly than historical averages. 9. PPA contract terms – Net present value will be determined by base cost and escalation rate. 10. Cost to install solar – Affects capital purchase directly through purchase price and power purchase agreements indirectly as the terms of the agreement will reflect the purchase price. 11. Capital purchase rebates – Will directly offset a capital purchase and indirectly influence PPA terms. 12. Tax incentives – Reduces net cost of solar installation for PPAs only, since tax incentives are not available to Metropolitan. The first step in sizing a solar facility for behind-the-meter generation, whether a capital purchase or financed through a PPA, is to account for the daily and seasonal electricity demand patterns. Figure 5-1 shows representative daily variation of grid energy demand pre and post solar in addition to solar power generated and lost. Wasted energy is the difference between solar production and grid demand. MWH 5-2 Plant-wide Solar Feasibility Study MWH kWh 0 2,000 4,000 6,000 8,000 10,000 12,000 Figure 5-1 Daily Energy Demand and Solar Generation 15 Minute Data 5-3 12:00 AM 1:00 AM 2:00 AM 3:00 AM 4:00 AM 5:00 AM 6:00 AM 7:00 AM 8:00 AM 9:00 AM 10:00 AM 11:00 AM 12:00 PM 1:00 PM 2:00 PM 3:00 PM 4:00 PM 5:00 PM 6:00 PM 7:00 PM 8:00 PM 9:00 PM 10:00 PM 11:00 PM Plant-wide Solar Feasibility Study Typical Solar Power Generation Typical Wasted electricity Typical Grid electricity, w/solar Typical Grid electricity, pre‐solar To account for daily and annual variation in energy demand, 15-minute energy demand data (provided by Metropolitan) was analyzed for several years at all WTPs; however a specific “base” year was chosen to conduct the sizing analysis. This was done to capture the hourly, daily, and seasonal variation that would be lost if the 15 minute data was averaged over several years. The smoother distribution of energy demand in an averaged year would result in a closer matching to the solar production than would actually be realized. The base year was chosen with regards to monthly and annual historical trends in energy usage and flow, plant upgrades, and other factors that may influence electrical demand. The 15-minute data from the base year was then analyzed and compared to the distribution of solar production. Solar production was given in hourly averages by month and was based on the Solar Advisor Model for single axis tracking silicon panels. The silicon panels in this model typically produced 2-2.4 million kWh per MW per year in Southern California. In addition, a derate factor of 0.77 was assumed. The derate factor accounts for losses from conversion from DC to AC power. Through comparing the distributions of energy demand and generation, a distribution of annual solar production and solar consumed by MW capacity was obtained. The MW capacity was varied, and the resulting solar power production and solar power consumption was assessed. Many of the factors that influence the sizing decision vary over time. Thus, to fully optimize the system, the distribution of solar production and consumption was utilized in net present cost analysis for both capital purchase and PPA financing. This type of analysis looks at the net present cost of implementing solar under each financing scenario in comparison to doing nothing and used a set of assumptions for costs and avoided costs. The calculations were set up so that the basic parameters could be varied, resulting in automatic recalculation of the costs. Once the set of assumptions was determined, the MW capacity was varied and the optimal size was determined when the net present cost was minimized. A negative net present cost represents net present savings of implementing solar in comparison to doing nothing. Specific assumptions pertaining to the net present cost analysis are detailed below. Since different solar technologies generate different quantities of kWhs per installed MW, the optimal size can also be viewed as an optimal generation level in terms of kWhs. The optimal size and the net present cost of a system are significantly impacted by the values chosen for the assumptions made in order to size the system and sensitivity analysis was conducted to determine the impact that the various assumptions had in the final size of the system. A more detailed description of the sizing and sensitivity analysis can be found in Appendix B. SOLAR SYSTEM SIZES Given all of the assumptions and sensitivities described above, the optimal size for solar facilities, including net metering, by plant, can be found in Table 5-1. The optimal size can also be viewed from an electrical production standpoint, thus the annual production from the optimal size is included in Table 5-1. Higher efficiency panels will produce more kWh per MW, and so the associated size to meet the plant’s demand will be smaller. MWH 5-4 Plant-wide Solar Feasibility Study Additional supporting calculations can be found in Appendix A. At the optimal size on behindthe-meter generation production facilities, the annual quantity of solar produced is slightly larger than the annual quantity of solar energy consumed. This is because during peak solar production, solar production is greater than the solar consumption which results in excess energy discharging to ground. Discharging 1% to 5% under these extreme supply/demand conditions of energy is optimal under both financing options because the benefit of the additional capacity in terms of additional solar production. Use in non-peak hours outweighs the additional cost associated with the loss in system efficiency, up to a certain point. This sizing analysis is based on supply and demand matching only. Comparison of the calculated optimal level of power generation and facility space constraints will be evaluated in the Preliminary Design Report. Table 5-1 Calculated Optimal Solar Sizing for Behind-the-Meter Generation Capital Purchase Treatment Plant Solar Size (MW) Initial Annual Production (kWh) PPA Solar Size (MW) Initial Annual Production (kWh) Jensen 2.2 4,400,000 2.0 4,000,000 Weymouth 2.1 4,200,000 1.8 3,600,000 Skinner 3.2 6,400,000 3.0 6,000,000 Mills 1.0 2,000,000 0.9 1,800,000 Diemer 1.0 2,000,000 0.9 1,800,000 9.5 19,000,000 8.6 17,200,000 Total Note: *The Diemer plant will not require solar electricity because the Yorba Linda Hydroelectric Plant will satisfy the WTPs electric demand. ASPECTS TO SOLAR IMPLEMENTATION Solar installations are a significant financial undertaking. In addition, a host of regulatory restrictions, incentive programs, and other issues also affect the decision on how much or whether to install solar facilities at a particular location. Financing remains one of the largest components related to solar installations due to a host of different tax incentives, rebate programs, grant options, and financing options that are applied differently for commercial, residential or municipal installations. In addition there are potential revenue streams that could be available in the future, pending greenhouse gas regulations. Other considerations in the installation of a solar facility include technical and operational issues. While solar systems generally have low maintenance requirements, the inverters need to be replaced every decade. In addition, special consideration needs to be given in selecting the size and location of the inverters to minimize the losses associated in long runs of cable. Interconnection issues with the grid must be assessed if net metering is allowed. Also, some rebate programs require metering by a third party representative. These and other related issues significantly impact the decision to install MWH 5-5 Plant-wide Solar Feasibility Study solar. Financial Aspects There are three parts to implementing a solar energy system, whether through a capital purchase or a PPA: direct cost of purchasing the solar panels and related accessories, tax incentives and rebates, and the value of the energy derived from the system. There are several tax incentives and rebates available for the implementation of renewable energy systems, both at the federal and state level. These incentives are designed to offset the capital purchase of the solar system and are not identical for private and public entities. In some cases, incentives that exist for private entities do not exist for public ones. Some of the incentive programs designed to offset a portion of the capital cost are described below. In the case of a capital purchase, financial analysis looks directly at the cost of purchase, the available incentive programs, and the value of energy derived from the system. In the case of a PPA, the financiers analyze these factors and determine a rate and rate escalator for the electricity produced from the facility that they would be willing to accept. The value of energy derived from the system includes a comparison to grid prices, renewable energy credits, and potential greenhouse gas emission credits. PPA contracts can be written so that renewable energy and potential greenhouse gas emission credits reside with the entity purchasing the solar electricity. Metropolitan Financials Metropolitan does not currently have the available standing capital to make an outright purchase on the order of tens of millions of dollars or more. To make a purchase of this magnitude, Metropolitan typically issues municipal bonds for the amount of the intended purchase. The issuance of bonds allows Metropolitan to finance large purchases over a 30 year period. Bonds issued by a municipal entity are afforded certain advantages. One advantage is that the interest earned from municipal bonds is generally tax exempt at the federal and state level, which allows the interest rate on the bonds to be smaller than those offered by private companies. The current interest rate on bonds issued by Metropolitan is 4.2%. California Solar Initiative and SB 1 The California Solar Initiative (CSI) is a program through the California Public Utilities Commission that provides financial incentives for solar energy systems. The financial incentives are specified for IOUs while LPOEUs can set their own terms that comply with the mandates in SB-1. In general, “CSI rebates” refer to the IOU rebate program while the LPOEUs programs are considered to be “other” rebate programs. Regardless of the program, rebates are only available for systems up to 1 MW,. For additional information regarding the rebates available under the California Solar Initiative and SB 1, see Section 3. Revenue Potential revenue streams depend on the entity purchasing the solar system. Additional revenue streams may be available in the near future in the form of greenhouse gas emission reduction credits, pending future legislation. For a system financed through a PPA, the available revenue streams are assessed by the financiers and the agency is only responsible for paying a contract rate for the electricity produced by the system. Depending on the terms of the contract, the agency may also own the renewable energy redits (REC) produced by the system. Under a MWH 5-6 Plant-wide Solar Feasibility Study capital purchase some of the rebate programs may provide a revenue stream for a portion of the life of the solar system, the RECs are owned by the owner of the solar facility. In either financing option, the use of solar electricity reduces the electricity demand from the grid, resulting in avoided costs. Renewable Energy Credits Renewable Energy Credits (REC) provide a method for commoditizing renewable energy despite the fact that all electricity becomes indistinguishable once it becomes part of the grid. A REC represents verification that a unit of electricity was generated from a renewable source and the owner of a REC can claim that they used renewable energy in the amount of the REC. RECs can also be purchased for a specific type of renewable power such as wind or solar. If a producer of renewable energy would like to produce and sell RECs they must hire an organization to certify the REC and give it a unique ID number to avoid double counting. Organizations that perform REC certification include: Green-e, Environmental Resources Trust’s EcoPower Program, and the Climate Neutral Network. While these organizations are attempting to standardize the certification process and have a national database, large scale regulation of the REC market is lacking. The money spent on a REC is the value individuals place on the renewable power the REC represents. RECs are only tradable within the United States and may also be called Green Tags or Tradable Renewable Certificates (TRCs). While this type of credit does not directly enhance the amount of renewable power on the grid, it does provide an additional subsidy to producers of renewable energy. Also, it should be noted that due to the fact that RECs are sold in units of energy, they can only be used to offset electricity related emissions. Prices for RECs fluctuate wildly both over time and between companies. According to the US Department of Energy prices for National Retail REC products ranged from $5 to $56 per MWh in 2008. Price volatility for RECs is due to many factors. These include: volatile demand and lack of large scale regulations and standards. In addition, the price varies depending on the quantity of RECs being purchased. In 2006, the Bonneville Environmental Foundation sold a 1 MW REC for $20 in retail, while the same credit could go for $5-10 for significant commercial orders (per phone conversation). While selling the RECs generated from the solar facilities would generate additional income, it is recommended that Metropolitan retain ownership of the RECs. By retaining ownership of the RECs, Metropolitan retains the right to claim use of the renewable energy which will reduce Metropolitan’s carbon footprint and help meet the goals of the SPP. Greenhouse Gas Emission Offset Credits While the United States government does not currently regulate greenhouse gas emissions, there is a greenhouse gas cap and trade program within the United States for those organizations who wish to participate. The program is run by the Chicago Climate Exchange (CCX). While entry into the exchange is voluntary, membership involves signing a legally binding contract to meet the emission reduction targets set by the CCX, which is currently one percent per year. To assess whether they have met the reduction targets, members must employ the National MWH 5-7 Plant-wide Solar Feasibility Study Association of Securities Dealers (NASD) for independent third party verification for their greenhouse gas inventory. Both member conduction inventories and NASD verification relies on the inventory rules set forth by the CCX. If members have reduced their emissions below the target, a Carbon Financial Instrument (CFI) is created and can be sold to a member agency who has not met their emission target. Members can also generate CFIs through qualifying offset projects. A CFI represents 100 metric tons of CO2 equivalence and its price is relatively stable at about $2 per CFI. Tax Advantages While rebate programs are in place for municipal agencies, tax advantages currently only exist for entities or individuals that pay taxes. Tax advantages available for private agencies include accelerated depreciation, which significantly reduces the tax burden for private agencies in the years following the purchase of solar panels. Technical Aspects Solar technology has been in existence for more than 30 years and is a well developed technology. The use of silicon is the most traditional and one of the highest efficiency materials in these cells. New materials such as thin film technology are also on the rise, which use materials such as Copper indium diselenide (CIS), Copper indium galium selenide (CIGS) and Cadmium telluride (CdTe). Technically all these systems are feasible for a solar farm installation at Metropolitan, though the primary driver for selection is financial. Panels are a major cost component but mounting systems, inverters, switching/breaker design and conduit runs are all components that need to be optimized. Site evaluation is the most important part of a solar system design. Grading that obstructs the sun from hitting the proposed system will drastically reduce the system performance. Ideal sites should be flat, with un-shaded southern exposure. Grade angles to the south are preferred and in the case of large systems, these flat areas should be continuous in order to minimize conduit runs and tracking equipment if used. Care should be taken when developing a site to ensure that shading impacts and grading costs are minimized. Operational Aspects Solar photo-voltaic (PV) generation systems require very little operations and maintenance. Once the system is calibrated and commissioned, it requires no operator intervention. The system operating full scale installations of solar PV generation systems varies by location but this section will discuss the most likely systems to be installed at Metropolitan facilities. In a PPA program, there is no operation and maintenance work required in the traditional sense. A third party monitor and its contractor partner will have a relationship where regular monitoring will analyze data on a daily basis, at minimum, to look for any anomalies. In the event that a field visit is required, field staff will be dispatched to visit the site and make any necessary physical repairs. This occurs at no direct or separate charge to Metropolitan. Though on site data and system I/O points can be fed into the plant SCADA system, this is not required because the system will be maintained for Metropolitan. The benefit of this to Metropolitan is that there is no staff time required to run the system which frees staff up to deal with other issues at the plant. MWH 5-8 Plant-wide Solar Feasibility Study Maintenance at a solar site however, is very minimal; with the exception of occasional panel cleaning (which research suggests may not be required) and replacing the inverters every 10 years, there is no regular maintenance required. In the event that Metropolitan purchases the solar system directly, the duty of operation and maintenance is dependent on several conditions. For net metered facilities, a third party monitor is required to operate and maintain the system for the first 5 years. After this period the owner, unless they opt to contract out the operations for an extended period, will operate the equipment. Any solar system O&M would be the full responsibility of Metropolitan though again, the option to outsource operations still exists but is not required. MWH 5-9 Plant-wide Solar Feasibility Study SECTION 6 FUTURE POTENTIAL SOLAR FACILITY LOCATIONS This Study’s main purpose was to identify and recommend solar generation facilities within Metropolitan’s water treatment plant boundaries. However, additional known Metropolitan properties exist within the geographic boundaries of Metropolitan’s distribution area that could become ideal locations for solar renewable energy in the future, should existing laws and regulations change to allow export of renewable power into the regional utilities power grid. The most logical and amenable Metropolitan facilities for future solar facilities were evaluated on a cursory-level. These facilities include existing power plants and other sites where there is existing electrical demand, infrastructure, available land and close proximity to power lines. At a minimum, up to 70 MW of additional solar power generation facilities could be implemented at the six locations identified below. Although these facilities are not feasible locations at this time, as there are not any substantial loads or demands at these sites that would allow behind-the-meter generation or net metering; these future facilities could become feasible with the expansion of net metering laws, feed-in tariffs, or future electrical power wheeling initiatives. 1. 2. 3. 4. 5. 6. Foothill Power Plant Etiwanda Power Plant Diamond Valley Lake – Wadsworth Pumping and Power Plant Lake Mathews Power Plant Eagle Valley Property Arrow Highway Property FOOTHILL POWER PLANT Hydroelectric power plants were constructed at several locations within Metropolitan’s distribution system to generate electricity and to control the pressure within the system. The power plants are of three general types: (1) Reaction Turbine, (2) Impulse Turbine, and (3) Pump/Generator. Metropolitan embarked on a hydroelectric power plant retrofit program in the late 1970's through the mid-1980's, in part to take advantage of federal energy incentives for alternative energy sources resulting from the energy crisis during the 1970's and to help offset the cost of pumping. The Foothill Power Plant is one of these facilities. Constructed in 1967 and located at the base of Castaic Lake’s main dam, the power plant sells wholesale power to Southern California Edison. In 2005 the power plant generated over 65 million kWhs, as water was drawn from Castaic Lake to meet demands in Metropolitan’s service area through the Foothill Feeder pipeline. As can be seen in Figure 6-1, the Foothill Power Plant has a large contiguous area of open land that is vital to the construction of a solar power generation facility. In addition, as there are existing connections to SCE’s distribution system, the infrastructure required to connect to the regional grid exists and MWH 6-1 Plant-wide Solar Feasibility Study only minor upgrades would be required to implement a solar generation facility. A 1 MW facility could ultimately be constructed at the Foothill Power Plant, should laws and regulations change. The existing plant demand does not warrant construction at this time however; plant demands in 2007 were slightly over 225,000 kWhs, while a 1 MW solar generation facility would generate close to or more than 2 million kWhs. This future facility would become feasible with the adoption of financially attractive feed-in-tariffs or electrical power wheeling to allow energy generated at this site to offset Metropolitan’s total electrical load. ETIWANDA POWER PLANT Constructed in the early 1990’s and located in Rancho Cucamonga, the power plant sells wholesale power to Southern California Edison. In 2005 the power plant generated over 95 million kWhs, as water was fed through the Etiwanda Power Plant to the Lower Feeder Pipeline, to break head and reduce pressure on the Rialto Pipeline. As can be seen in Figure 6-2, the Etiwanda Power Plant also has a large contiguous area of open land that is vital to the construction of a solar power generation facility. This land was recently used for storage of the Inland Feeder’s tunnel lining system, and with completion of that project, has become available for other land planning purposes. In addition, as there are existing connections to SCE’s distribution system, the infrastructure required to connect to the regional grid exists and only minor upgrades would be required to implement a solar generation facility. A 1 MW facility could ultimately be constructed at the Etiwanda Power Plant, should laws and regulations change. The existing plant demand does not warrant construction at this time however; plant demands in 2007 were slightly over 225,000 kWhs, while a 1 MW solar generation facility would generate close to or more than 2 million kWhs. This future facility would become feasible with the adoption of financially attractive feed-in-tariffs or electrical power wheeling to allow energy generated at this site to offset Metropolitan’s total electrical load. DIAMOND VALLEY LAKE – WADSWORTH PUMPING & POWER PLANT The Wadsworth Pumping & Power Plant was constructed in the late 1990’s with implementation of Diamond Valley Lake (DVL). Located at the west dam of Diamond Valley Lake, water can be pumped into DVL from the San Diego Canal, although with recent implementation of the Inland Feeder Project, water will flow via gravity into the lake under abundant water supplies and normal operating conditions. In 2005 the power plant generated over 11 million kWhs. When Diamond Valley Lake is at higher water elevations, the power plant will generate power as water is drawn from the lake to meet demands in Metropolitan’s service area through the San Diego Canal and connecting distribution system pipelines. As can be seen in Figure 6-3 below, the Wadsworth Pumping & Power Plant has three large MWH 6-2 Plant-wide Solar Feasibility Study contiguous areas of open land that would be vital to the construction of a large-scale solar power generation facility. In addition, as there are existing connections to SCE’s distribution system, the infrastructure required to connect to the regional grid exists and only minor upgrades would be required to implement a solar generation facility. Nearly 30 MWs of solar generation facilities could ultimately be constructed at the Wadsworth Pumping & Power Plant, should laws and regulations change. Diamond Valley Lake has six separate electrical meters in and around the large reservoir, although in 2005 the total usage was less than 1 million kWhs. A 30 MW solar generation facility would generate close to or more than 60 million kWhs. This future facility would become feasible with the adoption of financially attractive feed-in-tariffs, increased net metering laws, or electrical power wheeling to allow energy generated at this site to offset Metropolitan’s total electrical load. Figure 6-1 Foothill Power Plant Solar Facility MWH 6-3 Plant-wide Solar Feasibility Study Figure 6-2 Etiwanda Power Plant Solar Facility MWH 6-4 Plant-wide Solar Feasibility Study Figure 6-3 Diamond Valley Lake: Wadsworth Pumping & Power Plant Solar Facility MWH 6-5 Plant-wide Solar Feasibility Study LAKE MATHEWS POWER PLANT The Lake Mathews Power Plant was constructed in the late 1960’s. Located northwest of the main dam at Lake Mathews, water flows from the lake through the power plant to meet demands in Metropolitan’s service area through the Upper Feeder Pipeline and connecting distribution system pipelines. In 2005 the power plant generated over 21 million kWhs. As can be seen in Figure 6-4, Lake Mathews has a large contiguous area of open land approximately ½-mile east of the power plant that could accommodate construction of a large-scale solar power generation facility. In addition, as there are existing connections to SCE’s distribution system, the infrastructure required to connect to the regional grid exists and only minor upgrades would be required to implement a solar generation facility. Nearly 4 MWs of solar generation facilities could ultimately be constructed at Lake Mathews, should laws and regulations change. Lake Mathews has one electrical meter and in 2005 the total usage was less than 1.25 million kWhs. A 4 MW solar generation facility would generate close to or more than 8 million kWhs. This future facility would become feasible with the adoption of financially attractive feed-in-tariffs, increased net metering laws, or electrical power wheeling to allow energy generated at this site to offset Metropolitan’s total electrical load. EAGLE VALLEY PROPERTY Located at the eastern most boundary of the city of Corona, the Eagle Valley property was purchased by Metropolitan in December 1993 from Shea Homes, Inc. for approximately $12,000,000. The 1,096-acre site was originally proposed as a 3,204 dwelling unit master planned community; as such a Specific Plan was adopted by the City of Corona in the late 1980’s to accommodate this planned community. The land was purchased for the future Central Pool Augmentation (CPA) Project, specifically for a 500 MGD treatment plant west of Lake Mathews. The land is currently vacant and recent studies by Metropolitan indicate that the CPA treatment plant is not needed until 2049. Although there are existing connections to SCE’s distribution system, it is unclear as to whether the infrastructure required to connect to the regional grid is substantially adequate, or would require major upgrades. Nonetheless, Eagle Valley is a very suitable site for solar power generation facilities, as it has the large contiguous area of open space needed as can be seen in Figure 6-5. Also favorable is the fact that the property is within a hidden valley that potentially negates aesthetic risks of a large solar facility. In addition, as there are existing connections to SCE’s distribution system, the infrastructure required to connect to the regional grid exists and only minor upgrades would be required to implement a solar generation facility. Approximately 36 MWs of solar generation facilities could ultimately be constructed at Eagle Valley, should laws and regulations change. No electrical load or consumption currently exists in this area. A 36 MW solar generation facility would generate close to or more than 72 million MWH 6-6 Plant-wide Solar Feasibility Study kWhs. This future facility would become feasible with the adoption of financially attractive feed-in-tariffs, increased net metering laws, or electrical power wheeling to allow energy generated at this site to offset Metropolitan’s total electrical load. Figure 6-4 Lake Mathews Solar Facility MWH 6-7 Plant-wide Solar Feasibility Study Figure 6-5 Eagle Valley Solar Facility MWH 6-8 Plant-wide Solar Feasibility Study ARROW HIGHWAY PROPERTY The Arrow Highway property is a separate parcel of Metropolitan-owned land, approximately 0.5 miles south of the Weymouth WTP, just north of Brackett Field County Airport. It is within the extents of the City of La Verne, but close to the eastern edge of the City of San Dimas. It is bordered by Puddingstone Drive to the south and by the southern terminus of Wheeler Avenue. The site is surrounded by light industrial-use to the north and east, as well as the channelized Live Oak Wash to the east, a city-owned open space field to the west of Metropolitan’s property limits, and Brackett Field County Airport to the south. The site is approximately 22 acres in size, though 8 acres would be available for solar, and is currently an ungraded, open dirt area with gently rolling topography. If it is determined that Metropolitan can participate in virtual net metering, this site would be ideal for solar as it has the large contiguous area of open space needed as can be seen in Figure 6-6 and is located near the Weymouth WTP, which will have a large electrical demand when ozone disinfection is implemented at the WTP. However, light grading and appropriate facilities to connect to the grid would be necessary, and residents may be highly sensitive to visual appearance, since the area is near a popular passive and active recreation area of Puddingstone Reservoir. If virtual net metering is not possible, this site could become feasible in the future with the adoption of financially attractive feed-in-tariffs, increased net metering laws, or electrical power wheeling to allow energy generated at this site to offset Metropolitan’s total electrical load. MWH 6-9 Plant-wide Solar Feasibility Study Figure 6-6 Arrow Highway Solar Facility MWH 6-10 Plant-wide Solar Feasibility Study SECTION 7 RECOMMENDATIONS TREATMENT PLANT SOLAR FACILITY SIZE Optimal Size There are two aspects to the recommended size of a solar facility: net metering and behind-themeter generation. The optimal size of a solar facility at each plant will be discussed based on the current 1 MW limit on net metering per WTP. Other regulatory restrictions and land constraint issues will be discussed later in this section. Net metering is the preferred method of implementing solar energy because any energy produced in excess of demand is fed back to the grid and the agency gets a credit for that quantity of electricity. During time periods in which on-site energy demand is greater than energy produced, there is no credit. However, when on-site energy demand is less than the energy generated, the excess energy is banked as a credit to be applied against future energy consumption. There are two drawbacks to current net metering regulations: 1) it is limited to 1 MW net metering per facility, and 2) the credit is reset to zero at the end of a 12 month period and the retail customer receives no compensation for any unused energy credits. Despite these restrictions, it is still the preferred method of implementing solar energy. The energy demand at each plant during periods in which no solar is produced is greater than the electricity produced by 1 MW of solar, thus it is recommended to install 1 MW of solar at each plant pending regulatory restrictions and land constraints. This recommendation is identical regardless of the financing method. Once net metering capabilities have reached the 1 MW limit, it is recommended to implement behind-the-meter solar generation in addition to the net metering. Under a behind-the-meter generation scenario, energy that is produced and not immediately consumed on-site is lost. Due to losing excess solar, it is important to not oversize a system, accounting for both daily and seasonal variation in both solar energy production and energy demand. Since it is recommended to implement 1 MW of net metering at each facility, sizing was done for behind-the-meter generation. The optimal size was determined by adding 1 MW for net metering to the optimal size for behind-the-meter generation. The optimal behind-the-meter generation size for financing through a capital purchase or a PPA was analyzed utilizing a number of assumptions. The assumptions that were made were conservative assumptions based on industry information and historical averages. Detailed discussion of the methodology for sizing a behind-the-meter generation facility can be found in Appendix B. The optimal size of a behind-the-meter generation solar facility under both PPA and capital purchase financing scenarios can be found in Table 7-1. MWH 7-11 Plant-wide Solar Feasibility Study Table 7-1 Calculated Supply-Demand Sizes for Behind-the-Meter Generation Capital Purchase PPA Solar Size (MW) Initial Annual Production (kWh) Solar Size (MW) Initial Annual Production (kWh) Jensen 2.2 4,400,000 2 4,000,000 Weymouth 2.1 4,200,000 1.8 3,600,000 Skinner 3.2 6,400,000 3 6,000,000 Mills 1 2,000,000 0.9 1,800,000 Diemer 1 2,000,000 0.9 1,800,000 9.5 19,000,000 8.6 17,200,000 Water Treatment Plant Total Limitations There are three limitations relative to the implementation of solar at the WTPs. These include: 1) electric demand, 2) regulatory restrictions, and 3) land availability. Electric demand applies to the Diemer WTP only. Planned upgrades at the Yorba Linda Hydroelectric Power Plant, which is located on the Diemer WTP property, will allow for the entire Diemer plant electrical load to be supplied from the Yorba Linda Hydroelectric Power Plant. These upgrades include an upgrade to the Francis turbine and connecting the power plant directly to the treatment plant load. The supply from this generation facility exceeds the plant demand and will result in a continued revenue stream for Metropolitan and an energy neutral plant. It is expected that even with the implementation of ozone disinfection at the Diemer WTP, the facility will be a net exporter of energy. The electricity produced by the Yorba Linda Hydroelectric Power Plant is significantly cheaper than electricity purchased from SCE or electricity produced from solar and is also considered renewable energy. Therefore, it is not recommended to install a solar facility at the Diemer WTP. The second limitation is regulatory restrictions on net metering. Regulatory restrictions exist for future net metering facilities at the Skinner WTP because a 1 MW net metering solar facility has already been installed in 2009 and current regulations limit net metering to 1 MW per meter connection. Thus, all additional solar facilities at Skinner must be behind-the-meter generation. Jensen, Weymouth and Mills are available for a 1 MW net metering facility, which are added to the totals in Table 7-1 to achieve the total optimal size. The third limitation is land availability at each plant. This final parameter is evaluated in the PDR. The final recommendations, including restrictions due to land availability, for solar facility size can be found in Table 7-2. Table 7-2 Recommended Solar Facility Size MWH 7-12 Plant-wide Solar Feasibility Study Net Metering Capital Purchase Treatment Plant Total Solar Installation (MW) Behind-the-Meter Generation PPA Solar Size (MW) Solar Size (MW) Jensen 1.0 0.5 4,400,000 0.5 4,000,000 1.5 Weymouth 1.0 1.0 4,200,000 1.0 3,600,000 2.0 0 3.2 6,400,000 3.0 6,000,000 3.2/3.0 1.0 1.0 2,000,000 0.9 1,800,000 2.0/1.9 0 0 3.0 5.7 Skinner Mills Diemer Total Initial Annual Production (kwh) 0 17,000,000 Solar Size (MW) 0 5.4 Initial Annual Production (kwh) 0 15,400,000 Capital Purchase/PPA 0 8.7/8.4 PROJECT TIMING AND DELIVERY METHOD Project Timing Significant rebates and tax incentives are currently available that make solar projects economically attractive. The current California Solar Initiative rebate ($0.37/kWh) produces a rebate of approximately 40% of the total cost of a solar system. This produces favorable payback periods and PPA terms, which make solar financially feasible. These rebates diminish over time, as more solar is installed; therefore, it is recommended for Metropolitan to implement solar facilities at the water treatment plants as soon as possible. Although solar equipment prices could decrease in the future, it is subject to market and economic conditions. The future solar market is unknown, whereas the current rebates and tax incentives are known; therefore, it is recommended for solar to be implemented now because these projects are economically feasible with a favorable return-on-investment. The 1 MW Skinner Solar Power Generation Facility was successfully commissioned in June 2009. This project was executed as a capital purchase project under a design-bid-build delivery method. CSI rebates are projected to pay for approximately 50% of the total project, which produces a payback period in the range of 6 to 8 years. The project was designed to be expanded with additional solar equipment. With the pending startup of ozone disinfection at the Skinner plant in Fall 2009, the electrical demand at Skinner will increase up to 100%. Therefore, solar facility expansion at the Skinner plant should be implemented as soon as possible to offset the plant’s high electrical demand. The Weymouth WTP is currently undergoing design for a major Electrical Upgrades Project, which will also add electrical infrastructure improvements to install solar power generation equipment at the Weymouth WTP. Solar can be easily and quickly implemented at the Weymouth plant, and is therefore recommended to proceed as soon as possible with the installation of solar facilities. The Weymouth plant is eligible for CSI rebates. The environmental review process for both the Skinner and Weymouth solar facilities has been completed and is therefore cleared to proceed. MWH 7-13 Plant-wide Solar Feasibility Study The Jensen and Mills WTPs are also suitable for solar facilities. Environmental documentation has not started for solar facilities for these plants. It is recommended to begin the environmental review process to clear the way for solar facilities. Engagement with the LADWP and Riverside Public Utilities for Jensen and Mills, respectively, is also recommended to discuss potential contract terms, rebates, and incentives for solar facilities. Based on past experience with the Skinner Solar project, it is estimated that the design and construction of one or more solar projects at the WTPs can be completed in approximately 17 to 20 months. This time period would meet current CSI regulations for rebates. Project Delivery Method There are two main types of project delivery methods currently available to Metropolitan for construction of its multi site solar farms. The first is a capital purchase and the second is a power purchase agreement (PPA). There are federal tax rebates that a PPA provider can utilize, which are not available to Metropolitan, which can make a PPA attractive under certain conditions, especially short term horizons. Capital purchase of a system is attractive because it would not be subject to a third party agreement and Metropolitan would retain full control of the assets. The project delivery method that is commonly used in the solar industry is design-build. With design-build, a solar integrator or solar contractor will design and build a solar system based on performance specifications provided by the owner. This delivery method often produces lower costs, innovation and creativity that could be hampered by a detailed design-bid-build project delivery method. In design-build, the owner has less control over the design because it is the responsibility of the design-build company to produce a design which meets the performance specifications. Metropolitan currently does not have the statutory authority to execute design-build projects. There is pending legislation that could allow for Metropolitan to execute design-build projects for renewable energy projects. It is recommended that Metropolitan support such legislation in order to increase the project delivery options to execute future renewable energy projects. The two currently available project delivery methods allow three scenarios for solar facility bidding: 1) Solicit bids for capital purchase 2) Solicit proposals for power purchase agreements 3) Simultaneously solicit both a capital purchase bid and proposals for a PPA, with the option to choose either. Under all scenarios, bidding would be for the installation of the solar facilities and any necessary grading and bidders would have all available space on which to optimize their systems. In addition, all bids will require that resulting solar production be within a range acceptable to Metropolitan. This range would be based on the solar production from the optimal sizes determined in this study. MWH 7-14 Plant-wide Solar Feasibility Study In a capital purchase only bidding scenario, Metropolitan would produce a set of bid documents. These documents would be put out to bid under standard bidding procedures. There are two elements to the ultimate capital cost of a project: the cost to install and the rebates associated with the system. Since the rebates are given per kWh of energy produced by the system, more efficient panels will result in a larger rebate. These systems, however, have a higher cost to install. To fully account for the capital cost of the project after rebate, the bids would be evaluated on a best value basis. In a PPA only bidding scenario, Metropolitan would issue a request for proposal for PPA contract terms. The request would specify common contract terms such as the length of the PPA contract and an acceptable minimum guaranteed annual production. The proposals would be evaluated based on the PPA terms given the specified length and minimum acceptable annual production from the system. In a scenario in which a capital bid and PPA contract documents are requested, all capital bids would be compared to each other and all PPA contract documents would be compared to each other. In the request for proposal/bid documents, Metropolitan would include the spreadsheet used to calculate the net present cost of the systems on equal terms over a 40 year period. Metropolitan would retain the right to select the preferred delivery method. This methodology helps to put both methods on an even playing field to the long term benefit of Metropolitan. As previously discussed, however, it is recommended that Metropolitan proceed with a capital bid process for the installation of solar facilities at Metropolitan’s water treatment plants for several reasons. First, over the life of the project (40 yrs), the economic benefit of the capital purchase significantly outweighs the PPA because after the system has paid for itself, it continues to produce significant quantities of electricity that is essentially free to Metropolitan. This is possible because solar facilities require little operations and maintenance expense and solar panels are warranted for 25 years with an expected lifetime of 40 or more years. A capital purchase is also a safe investment to protect against future dramatic energy increases and price volatility. In comparison, significant uncertainty exists regarding the end of a PPA contract. While Metropolitan has the option to purchase the system at “fair market value,” the definition of fair market value is not defined. It is speculated that fair market value could be interpreted to mean the value of the energy it produces, which would represent a significant amount of money. In addition under a PPA, Metropolitan would be relying on outside financers and it is unclear what would happen if the PPA investors folded. Also, the Los Angeles Department of Water and Power does not currently allow PPA agreements. While they do allow third-party purchase agreements with lease payments, addition of this financing option for Jensen would require extra documentation and guidance in the bid documents. ROADMAP TO ACHIEVE PRACTICAL IMPLEMENTATION OF METROPOLITAN STRATEGIC POWER PLAN Metropolitan’s Strategic Power Plan (SPP) is the backbone structure on which expansion of renewable energy resource development will occur at Metropolitan. This planning process will have many branches with the underlying goal of cost effectively attaining carbon neutral goals on a realistic schedule. This will require navigation through issues in and out of Metropolitan’s MWH 7-15 Plant-wide Solar Feasibility Study direct decision making authority. Many of the constraints such as net metering laws and grid interconnections are not under the direct control of Metropolitan and will require careful investigation and effort to help shape metering laws on a state and eventually federal level. Technology review and selection is also a key factor in moving forward. A variety of options including the most likely selectable technologies such as PV solar, solar thermal and wind based electricity generation are real options for Metropolitan with opportunities and challenges to both. Siting, funding, environmental clearance, generation tie ins, connections to the grid, facility sizing, funding and preliminary design are all key issues that will have to be investigated once a feasibility analysis has been created to flush out the optimal technologies. As Metropolitan marches towards the future, real and present drivers exist towards a carbon neutral operation for all major utility providers. As a provider of the foundation of life and society, which is dependent on electricity to function, there is a direct tie between water and a sustainable energy supply. Metropolitan’s Board has also expressed a corresponding desire to lower its carbon footprint. The next steps after the feasibility report would be a preliminary design report. Determination of this approach would be presented in the feasibility study. In this manner Metropolitan can demonstrate to the public and its rate payers that it has reviewed an extensive array of energy options and those actions to move forward are being done to optimize financial, environmental and social benefits of each project. With these major pieces in mind, there is a need to plan for the future and a few major steps and recommendations have been developed. There are a wide variety of options to attaining a carbon neutral goal. In order to flush out the major steps in achieving this, a SPP implementation plan is recommended. From this jump off point, a detailed energy efficiency estimate would first be performed. Shortly thereafter, a renewable energy feasibility study of the following major items would be performed: 1. Review all Metropolitan owned property 2. Evaluate energy efficiency opportunities 3. Evaluate wind, solar PV, solar thermal, geothermal, wave/tidal/run of river resources throughout Metropolitan’s existing property holdings 4. Evaluate energy distribution issues, options and opportunities 5. Evaluate wholesale PPA purchase or development of utility scale power supply 6. Evaluate a network of small renewable energy power generation 7. Evaluate partnerships, special leasing or land purchases required to site new technologies 8. Conceptual cost to benefit analysis of new programs. 9. Develop an implementation priority schedule of the proposed feasible technologies. It is also recommended that Metropolitan create and maintain a focused effort of institutional involvement to engage and guide external factors relevant to the Metropolitan energy program. External factors have significant potential impact on the implementation of the Metropolitan energy program. Specific regulatory requirements, such as greenhouse gas reductions and water quality-related treatment requirements are clearly an important driver for the program. Other MWH 7-16 Plant-wide Solar Feasibility Study primary external factors are the cost of grid energy, conversion efficiency of the solar cell, and component costs of the solar production system. Each of these other factors is also, in turn, strongly influenced by policy and regulation. The significant impact of external factors that are primarily driven by public policy, and not material availability or technological advancement, suggests that Metropolitan should take initiative to guide the relevant local, state, and federal policy development to enhance the implementation of effective and meaningful renewable energy programs. Institutional involvement would include efforts such as corporate sponsorship, regional policy initiatives, personnel membership and engagement, and internal and external information exchange forums. It is recommended that Metropolitan begin to identify and support critical policy initiatives that are necessary for efficient implementation of renewable energy programs. These policy initiatives might include components of local, state, and federal programs. These policy initiatives will range from refining existing policy to defining entire new programs or sectors of involvement. Because of the magnitude and impact of the Metropolitan operations, it is important for Metropolitan to be involved in framing these issues as they are developed, instead of taking a reactionary approach and trying to manage under poorly defined regulatory language. Policy initiatives will likely also require collaboration among agencies and organizations and Metropolitan leadership will significantly enhance the effectiveness of the policy initiatives due to their broad member agency structure. MWH 7-17 Plant-wide Solar Feasibility Study