We have just learned that Burbank Water and Power (BWP) - which had suspended its solar rebates back in April 2011 - is introducing what might be the most bizarre rebate procedure ever - a rebate lottery! Here is the text of the announcement in its entirety from the BWP website:
Direction for how the program will accept new applications effective July 1, 2012 will be provided by the Burbank City Council on June 26. Staff is proposing the following:
Additional details will be posted on this web site in early July 2012. If you have additional questions please contact the program manager at email@example.com
- Retain the current policy of dividing the remaining non-Performance Based Incentive (PBI) budget amount evenly between residential and small commercial solar installations. This is projected to provide approximately $60,000 in incentives for each customer category.
- Lottery applications would be accepted from July 1 through September 1, 2012.
- On September 4, 2012, BWP would use a lottery system to provide an order of rebate consideration for both residential and commercial (including Not-for-Profit organizations)solar applications. Priority will be given to business accounts that fall under a not-for-profit designation.
- Applicants will be notified in early September of their lottery number and application status. ”Winners” will be provided one month to meet all previously defined system application requirements through BWP’s online PowerClerk system, including, but not limited to, a signed contract, meter service confirmation, and City permit application approval.
- Rebates would open at Step 6: $1.28/watt for residential installations and $0.97/watt for commercial installations.
If this announcement is to be taken at face value, this means that they will be setting up a two-month lottery for the chance to be one of maybe 12 residential projects to get a rebate and only one fo 2-4 small commercial projects. Seriously? All this Sturm und Drang for a grand total of 16 rebates? With no way for a BWP customer to know in advance whether they will be one of the lucky “winners"?
We sent an email to the address above asking for some clarification, but as of this publication we have not received a reply. If you think this “lottery” is as silly as we do, please send an email to firstname.lastname@example.org - maybe they will be more willing to respond to you!
Say what you will about the California Public Utilities Commission (CPUC), but their recent rulings have been strongly in support of the solar industry and on May 24, they did it again. In a unanimous decision, the CPUC voted to increase the cap on net metering, overriding protests from some utilities and misguided “consumer” advocates.
At issue was the manner by which the statutory cap on net metered installations was to be computed. Under existing state law, California utilities are obligated to accept net metering connections from solar power customers until the installed capacity of the utility’s solar customers equals 5% of the “aggregate customer peak demand." The problem before the Commission was how to define the denominator: does aggregate customer peak demand mean the peak demand that the utility as a whole had seen (as the utilities argued) or was it the sum of the peak demand for each of the utility’s customers?
That turns out to be a very significant difference and the CPUC came down on the side of the solar industry. As a result, the total amount of net metered capacity under the law will now be computed to be 5.2 GW compared to just 2.4 GW under the utility’s interpretation!
Unfortunately, the Commission didn’t stop there. Part of the argument from the utilities was the claim - echoed by TURN - that net metering amounts to a “silent subsidy” from the general rate payer to more affluent customers who can afford solar. In their ruling, the Commission authorized a study to investigate that claim and to quantify the cost-benefits of net metering to the larger rate paying community. Wrote the Commission:
The goal of the study will be to provide the Commission and all interested parties, including the Legislature, with a better understanding of who benefits, and who bears the economic burden, if any, of the NEM program. The report should quantify the costs and benefits of NEM to participants and non-participants and should further disaggregate the results by utility, customer class, and household income groups within the residential class. The study should also seek to gather and present data on the income distribution of residential NEM participants. In order to assess the costs and benefits at various levels of NEM implementation, the above analyses should be conducted using multiple NEM penetration scenarios, including at minimum, the capacity needed to reach the solar photovoltaic (PV) goals of the CSI and the estimated NEM capacity under the five percent cap as defined in this decision. The results of such a study then can be used by the Commission to set future policy for the NEM program, with full awareness of the economic impacts of any policy choices on all classes of ratepayers.
Once the study is complete, the Commission is to promulgate new regulations regarding net metering based on that analysis. All of this is to happen by the end of 2014 - but if new rules aren’t in place by then, net metering will be suspended until such time as they are! Again quoting from the Commission:
We anticipate this temporary suspension in the NEM program, effective January 1, 2015, will remain in place pending the issuance of new rules at the conclusion of a rulemaking proceeding we will commence once the study described above is completed. Of course, if the study can be completed and the new rules are issued prior to December 31, 2014, then the suspension of the program in 2015 will not be necessary. But if the post-study rulemaking remains open and incomplete on January 1, 2015, then under the terms of today’s decision the program will be suspended thereafter, and the utilities will not accept any new NEM applications, until the new rules are issued and take effect.
At the risk of sounding cynical, this sure feels like an opportunity for the utilities to game the system and drag out the rule making if they cannot get the deal that they want. This process will bear close observation!
As an aside, there was one odd detail buried in the decision - the numerator in that 5% computation is supposed to be the installed solar capacity. However, the value used is “CEC-AC Watts” which is computed as the PTC rating of the solar panels used, multiplied by the total number of solar panels, multiplied by the efficiency of the inverter(s) used. So for example, an installation of 20 LG 250 Watt solar panels driving 20 Enphase M215 micro-inverters would have a Nameplate power rating of 20 x 250 =5,000 Watts. The PTC rating of the LG 250, however, is 225.2 Watts and the Enphase M215 is 96% efficient, meaning that the CEC-AC rating would be:
20 x 225.2 x 96% = 4,323.84 Watts
But here’s the curiousity - rebates aren’t paid based on CEC-AC Watts - they are paid on the CSI rating. The CSI rating takes the CEC-AC rating and modifies it based on the actual characteristics of the site - shading, attachment method, azimuth and tilt. This is certainly reasonable as all four of those factors combine to have a significant impact on the energy yield of the system - and that is what an EPBB rebate is supposed to be incentivizing. So why doesn’t the net metering cap use the sum of the CSI ratings as its numerator? And if it did, how big of a difference would it be?
We decided to find out. We took the most recent CSI data set (dated May 30, 2012) and created a pivot table that would report by year and for each of the three investor-owned utilities ("IOUs") subject to CSI, the sum of the CEC-AC and CSI ratings and then give us the ratio. Here are our results combining all three IOUs in each year (in kWs):
These are very interesting numbers - the difference between the CEC-AC rating versus the system-specific-corrections-adjusted, CSI Ratings is very small. Now why is that? The simple answer is that you can actually score higher than 100% when you go from CEC-AC to CSI. How can that be? And how often does that actually happen?
To probe a little deeper we decided to just look at systems installed in SCE territory. Here’s what we found:
Indeed, over the total lifetime of the CSI project, systems installed in SCE territory have averaged 101.7%!
(The numbers drop off in San Diego Gas & Electric to ~98% whereas in PG&E territory the average drops to 96%.)
Still, as a solar installer, we had to admit that these numbers were troubling - we’ve done lots of rebate calculations since 2007 and we really don’t recall seeing design factor scores greater than 100%. An hour of experimentation with the online rebate calculator confirmed that experience - we could get configurations to equal 100%, but not exceed it. So what was the source of these results?
Then it hit us - we were calculating based on EPBB rebates - which makes sense because that is where the CSI rating is reported. However, larger solar systems receive PBI rebates - payments made based on actual performance over five years. What would happen if we distinguished PBI from EPBB rebated systems - would that explain our difference? Indeed it would - check this out:
How about that? From 2006 to 2009, neither rebate method averaged over 100%. But starting in 2010, PBI rebates consistently averaged over 100%, even while EPBB averages remained largely unchanged.
So why the difference? In July of 2009, the rebate calculator was changed. (You can find links to both the current and the old calculator on the CSI website.) It appears that the real difference in how the two calculators work is for PBI rebates - where it allows the design factor to exceed 100%. More importantly, the new calculator takes into account single or dual axis tracking configurations for PBI rebated arrays. Scanning the data, we discovered a site that actually has a recorded design factor of 148%! This is a 1MW system and you can see how a substantial number of comparably sized installations using single or dual axis tracking would really skew the results.
So now we understand where the numbers came from, but we are still somewhat troubled by our results. Are any of these utility-scale systems operating under net metering rules? That seems highly unlikely. And assuming that is the case, shouldn’t they be excluded from the net metering cap computation? In which case, using the CSI rating would add an extra 5% to that numerator, and that would be a good thing! Any CPUC Commissioners or other insiders who might care to educate us further, please do so in the comments.
There aren’t a lot of publicly traded solar companies out there - most of the companies in the solar sector are relatively small operations. However, two companies in the public sphere are subject to lots of buzz and the contrast between them is intriguing. We are talking about Enphase Energy (which went public at the end of March) and SolarCity (whose long anticipated IPO is scheduled for… sometime soon?).
Enphase had its IPO on March 30, with shares priced at $6.00, and the IPO raised total gross proceeds of $61.9 million. As of the market’s opening today, Enphase (ENPH) was trading at $8.33/share. On May 10 the newly public company published its first quarterly earnings report with some strong numbers. Total net revenues grew 136% from the first quarter of last year, going from $18.1 to $42.6 million. Units sold in the quarter more than doubled from 123,000 last year to 292,000 this year, and gross margin increased from 14.7% to 21.8%.
As impressive as those revenue and growth figures are, they have yet to translate into a profit for the company, with the quarterly loss increasing to $10.2 million, up from $9.3 million last year. That loss worked out to $-5.38/share. Nevertheless, that loss was significantly less than the consensus prediction of the four analysts covering the company (by $3/share), and the stock is presently rated as a “strong buy” by two and a “buy” by the other two.
The keys for Enphase will be to continue growing market share (even in the face of growing - if dubious - micro-inverter competition from string/central inverter players like SMA), continue to innovate and keep costs down. It will be intersting to see how they build on this strong start in the coming years. (Full disclosure - I do not own any Enphase stock.)
Which brings us to SolarCity which announced on April 30 that it had filed a “draft” registration statement with the SEC on April 26. While normally a filing with the SEC is a matter of public record, under recent changes in the law, companies with less than a billion dollars in annual revenue can file draft registration statements with the SEC, revise the document based on the agency’s feedback, and only make the filing public once it is actually approved by the SEC. This is particularly interesting given that it had been reported that SolarCity had delayed its filing while working out “accounting issues” related to its business model of leasing solar power systems. (As one pundit put it, “Apparently not all lease accounting is the same.") Also still outstanding, apparently, is the issue of Sunpower’s lawsuit for theft of trade secrets against SolarCity.
The purpose of the pre-IPO disclosures to the public is to allow potential investors to get a look at how the company is actually doing - revenues, profits (or losses), costs, salaries, etc. This is of particular interest in conjunction with SolarCity given its unusual business model that has lead to questions about its practices being raised from a number of quarters (including this blog). Unfortunately, SolarCity has opted - as is its right under the law - to keep that information secret, at least for now.
Assuming that at some point SolarCity actually has to put its cards on the table, we will follow-up on this story.
Readers of this blog will know all about the 52.3kW solar project that Run on Sun just recently completed installing at Pasadena’s renowned Westridge School for Girls. Now that project has become the cover story in the Annual “Green Issue” of Pasadena Weekly.
Titled, “Solar Flair: New solar installation at Westridge School brings environmental lessons to life,” the piece features interviews with Westridge’s Head of School, Elizabeth McGregor, Facilities Manager Brian Williams, and three students who are part of the school’s environmental group known as the Green Guerrillas. The story reveals the school’s deep commitment to sustainability in everything from solar power to drought tolerant plants.
This first of what we hope will be many solar projects at Westridge really highlights the value of these projects for all schools, especially those in the Pasadena Water and Power service territory. Good rebates and a solar company that really understands your goals makes a solar power system installed by Run on Sun a “no-brainer.”
In Part 1 of this series about Installing Solar at Westridge School, we looked at the process of putting our materials together for the rebate application. With the rebate safely reserved, it was time to turn to pulling the permits for the job. A solar project of this size involves two separate permits - building and electrical - but four points of inspection - fire, electrical, building, and utility. We had already provided the utility, PWP, with the materials they needed but now we needed to load up for the permit center.
The permit process addresses an entirely different need than does the rebate application. The permit process is intended to guarantee that the proposed system, as designed, satifsfies all applicable codes and standards. In theory, once you have successfully pulled the permit, the inspection process should simply be a matter of showing the inspector that you built the system as it was approved when you pulled the permit.
This project presented one signficant challenge - the actual attachment of the system supports to the roof. While the roof looked conventional enough, that was not a wooden truss underneath those shingles. To the contrary, our roof was built from a 20 gauge “Type B” steel deck with two layers of 5/8″ plywood, followed by 3″ of solid foam insulation, followed by 3/4″ of plywood to which the roofing materials themselves - membrane, felt and shingles - were attached. So the question arose: what would be a sufficient way to attach our standoffs to this roof to provide the requisite resistance to wind loads - the effect of which had recently been demonstrated in Pasadena in such a disastrous fashion?
To help answer that question we turned to the structural engineer (SE) who had originally done the load calcuations for our building. Could we use a “FastFoot” and simply put multiple screws into the wooden decking materials? Surely with enough screws - the FastFoot will allow for up to eight - we could reach the required pull-out resistance. Unfortunately, that wouldn’t work since the engineer could not guarantee the manner by which the plywood materials were secured to the underlying steel deck. In other words, while we could be sure that our array would remain attached to the plywood, we couldn’t be sure that the plywood would remain attached to the building! Images of Wizard of Oz roofs flying through the air filled my mind - clearly we would need another way!
The engineer suggested that we could use carriage bolts that ran all the way through the steel roof and were bolted together on the back side. Certainly such an approach would guarantee that our array and the roofing materials stayed connected, and indeed, you would have to separate the steel deck from the steel framework of the building for that method to fail. Unfortunately, that wouldn’t work either since there was no way to access the back side of the roof in order to complete the connection.
There was one other approach - a company by the name of Triangle Fasteners sells some very strong, very long, self-tapping screws (called “Concealor screws“) that could drill their way into the steel deck and provide us with the required pull-out resistance. The bad news - our distributors only sold screws up to 7″ long - and that would not be long enough to guarantee that our screws made it through the decking. A call to the manufacturer revealed that in fact, they did make 8″ screws, they even made 9″ screws! Excellent! We now had a solution that our SE could bless. It was time to go pull our permits.
Anyone who has ever pulled a permit knows the combination of emotions that you encounter upon entering the building: fear that something you haven’t considered will suddenly become A Really Big Deal, loathing for the interminable waiting, and of course, the pain of paying for it all. Dentists’ waiting rooms tend to be cheerier places.
Pasadena’s permit center is certainly better than most: it is a comfortable old building across the street from the beautiful City Hall. They have a clever scheduling system that routes you among the different windows: Building and Safety, Zoning, Historical Preservation (very big in Pasadena but not a factor for solar projects), Fire, Permit Processing and, last but certainly not least, the Cashier. A solar project applicant must navigate their paperwork through every one of those windows before exiting with your Grail - a stamped set of plans and a bright Yellow permit folder where inspection sign-offs will be recorded.
First stop - Building and Safety.
The building and safety folks are responsible for reviewing your plans for conformity with state and local codes and standards - a really important task. First, however, you have to speak with someone who knows what you are showing them and on our first trip to the permit center, no such person could be found! The gentleman behind the B&S desk was very polite, and you could tell that it pained him to inform us that after our thirty minute wait, he couldn’t help us. Moreover, none of the people who “understood solar” were available - we would have to come back tomorrow.
Tomorrow dawned cloudy but we were determined to press forward. This time our 35 minute wait was rewarded with an appearance before someone who was prepared to pass judgment on our plans! We walked him through each of our sixteen 24″ x 36″ pages, explaining as we went exactly what we were doing and where the answers to his questions could be found.
All seemed fine, but then he started throwing us some curves.
Our SE had done his calculations for a basic wind speed of 85 mph - the same wind speed we had always used for load calculations in Pasadena.
“No,” said the man behind the desk, “You have to use 100 mph.”
“Really? Since when?”
“Since the windstorm in Pasadena at the end of November,” we were told. (Never mind that the wind speed never reached 85 mph in Pasadena, let along 100 mph, during that terrible event.)
“Really? Where was that published?”
“It wasn’t,” he conceded, but simply told us that we needed to revise our calculations for 100 mph or he wouldn’t approve them. That meant another iteration with our SE and another trip back to the permit center.
Now the good news here is that we were certain that our system would easily handle 100 mph winds (or 120 mph, for that matter) so this change in policy did not pose a danger to the project going forward. But changing the basic wind speed for an area from 85 to 100 mph is something of a big deal and will add to the expense of many projects that need permitting. Shouldn’t there be a more public process before such a change is implemented?
The other curve sent our way was really just odd.
We did a detailed drawing showing our attachment method as it penetrated the various layers of roofing materials and made contact with the steel deck beneath. We drew that straight up on the page and included multiple elevations in our sixteen pages that showed the pitch of the roof and indicated that the array was installed on top of our attachment method, parallel to the roof.
“Not good enough,” we were told.
“Why? What’s missing?”
“You need to show the attachment at the slope of the roof.”
“Really? We show you the slope of the roof, we gave you the detail of how the attachment connects to the roof and we told you that the array is parallel to the roof. How is that not sufficient?”
“You need to add a drawing that shows the array attachment and which reflects the slope of the roof.”
“Really? So what you want is for me to rotate the image of our attachment 13° to reflect how it will be pitched on the roof?”
Sigh. Ok, back to the drawing board (or more accurately, the computer screen).
Fortunately, our SE was able to redo his calculations in short order. And not surprisingly, it was also pretty easy to take our attachment image and rotate it. We printed up the revised plans and headed back to the permit center.
Surprise - there was yet another person behind the counter this time. Whereas his predecessor seemed to be actively looking for little things to complain about, this fellow could not have been more helpful. He looked at our revised load calculations - veryifying that they had been done for 100 mph and that the SE had concluded that all was well - and then proceeded to stamp our plans. (I had pointed out our added, rotated drawing, but it was clear that he wasn’t interested in that at all.) After he stamped our plans, he then took them himself to the zoning and historical preservation desks and secured those sign-offs as well! Wow! He saved us an hour of waiting in those queues and he seemed genuinely helpful and concerned. What a pleasant contrast! We were well on our way with just one real substantive hurdle remaining - the Fire department.
The California State Fire Marshall developed a set of guidelines that provide guidance as to how fire departments should permit and inspect solar installations. The guidelines call for space to be set aside for pathways around the array and for venting of smoke in case of a fire. The guidelines call for different restrictions based on the size and shape of the roof and whether it is a residential or commercial building.
(While the document from the Fire Marshall is labeled “guidelines", most localities seem to treat it as gospel. Even more curious, the guidelines clearly say that they are just that, guidelines that do not have the force of law until a local jurisdiction passes an ordinance adopting the guidelines as regulations. We have yet to see such an ordinance.)
Our building plan included a three-foot set aside around both sides of the array and from the ridge, and was augmented by automatic smoke ventillation devices already built into the roof. But that was not sufficient - the fire official wanted us to provide a four-foot clearance on all three sides. Yet another trip to the computer.
We returned with our revised drawing, showing four feet of clearance as requested. But now there was another concern - the same fire official now wanted us to open a walkway in the middle of the array. (We already had access paths for potential maintenance, but they were not wide enough to be considered a walkway.) No matter that our roof was not at all like the flat roof with parapet shown in the guidelines, we still needed to provide a walkway. There was only one way to do that - take out a column of panels. Together we X-ed out seven panels and thereby created a walkway. The fire official was now satisfied - she signed off on our plans.
And just like that, we were done. Well, not quite - there was still the little matter of paying for all this. Here we made out surprisingly well. Unlike some cities that gouge solar applicants (and you know who you are!), Pasadena’s fees were quite reasonable. Total cost for our now 52.25kW solar project? $732. Sadly, we know of residential projects one tenth that size in other cities where the permit fees have exceeded $1,000! (But that’s a story for another day.)
Altogether, it took us four separate trips to the permit center, three plan revisions, and a little over $900 in expenses to secure our permit.
Now all we needed to do was get the materials to the job site on time, and complete the installation in the two week window that we had to mesh with the School’s schedule. The real work was about to begin…
«climate change» «commercial solar» cpuc «enphase energy» «feed-in tariff» fit gwp «jim jenal» ladwp «net metering» pg&e pwp «run on sun» sce seia «solar power» «solar rebates» solarcity usc «westridge school for girls»