UPDATE - We heard back from BWP - details at the end of the post…
The wizards at Burbank Water and Power have announced their solar rebate program will resume, but only for the lucky few who happen to be facing West. Here’s our take.
Having a stable, predictable solar rebate program is the key to making a solar program successful. Municipal utilities like Pasadena Water & Power, and investor-owned utilities (like SCE) participating in the California Solar Initiative, have had great success with their programs.
Then there are other munis, like Burbank Water & Power (BWP), that just can’t seem to get it right. BWP, like its similarly misguided neighbor, Glendale Water & Power, has had an on-again, off-again rebate program that baffles all who attempt to make use of it. Now, for a brief moment, BWP’s solar rebate program is on-again, sort of. During the month of August, potential Burbank solar customers are allowed to submit rebate applications (submission deadline is August 29 at 5:00 p.m.) for a lottery to be held on September 8th. The lucky 60 residential and 15 small commercial (<30 kW) customers who make the grade (no details on how the auction will actually be conducted have been released) will be advised of their good fortune by September 12th. Rebate amounts are $0.96/CEC AC Watt for residential and $0.73 for small commercial.
But wait, there’s more.
For the first time in our experience, a utility is limiting rebates for solar systems to only those which face in a generally westerly direction. In fact, systems facing true south are completely ineligible for rebates (as shown in the image to the left), even though such systems are the most productive!
BWP is essentially precluding the overwhelming majority of building owners from even having a chance at a rebate in their lottery system.
This continues a trend we have seen with other muni utilities (GWP we are talking about you) where solar programs are designed to be unsuccessful. It will be interesting to see if we can extract any data from BWP about the results of their lottery.
BWP’s Stated Rationale for Restricting System Azimuth
But why the restriction in the first place?
According to BWP, it is to insure that the power produced comes closest to overlapping with BWP’s peak afternoon demand from 4-7 p.m. Thus to qualify, systems have to be oriented between 200 and 270 degrees and have a minimum tilt of 5 degrees.
That seemed pretty arbitrary to us.
While we could understand a utility wanting to limit providing rate payer money to systems that yield the maximum benefit to those rate payers, there is certainly nothing magical about a limit of 200-270 degrees. In fact, somewhere around 270 should be the sweet spot for afternoon production, with a fall-off on either side. So why cutoff systems beyond 270 degrees?
We decided to run some models using NREL’s PVWATTS tool. We assumed a 10 kW system at a 10 degree pitch (a common residential roof pitch) and accepted the other defaults for the model. We then calculated the hour-by-hour output for systems with azimuths ranging from 200 to 330 degrees. Here are the results for the critical hours from 4 to 7 p.m.
All of the azimuth angles in the green box are acceptable to BWP, whereas all of the azimuth values in the red box are deemed unacceptable for a rebate from BWP.
But here’s the thing… see that green horizontal line? That represents the 4-7 p.m. output for our hypothetical array with an approved azimuth of 200 degrees. Yet five out of six azimuth values modeled here that are rejected by BWP, actually produce more power during the critical period than does our approved system at 200 degrees!
So what exactly is going on here? BWP’s asserted rationale does not hold up to scrutiny. Which begs the question, why, really, is BWP so seriously limiting who can participate in their lottery? It certainly is not justified by their desire to maximize 4-7 p.m. production. If that were truly the case, they should include azimuth angles all the way to 320 degrees. They would get more timely power production while opening their rebate lottery to many more potential customers.
How about it, BWP, what is going on here?
If you are a potential BWP customer who falls outside of the “accepted” azimuth band, you might want to contact the Solar Support program managers:
John Joyce: firstname.lastname@example.org or
Alfred Antoun: email@example.com
If you get a response, please add it to the comments.
UPDATE - We heard back from John Joyce, Solar Support Program Manager at BWP, about the outcome of the lottery process. According to Mr. Joyce:
105 lottery entries have been submitted and the budget is sufficient to allow each of these applicants to participate, therefore no lottery will be held.
We have a further inquiry in to Mr. Joyce to see if there is still budget left over to allow more applications going forward. We will update this again if we hear back.
Last week LADWP responded to its critics by announcing major changes in how its solar program works. In a widely distributed press release, LADWP said its actions were “aimed at reducing delays, streamlining the program, and increasing transparency." Or in other words, providing participants with some hope that one of the most difficult jurisdictions in which to install solar might finally have a chance to live up to its potential. Here’s our take.
There can be no doubt that LADWP is in serious need of improving how its solar program works. Indeed, earlier this month we wrote a piece about Why “Soft Costs” are so Hard (particularly in LADWP territory) and in January we wrote in LA: Where Good News goes to Die, how the LA Department of Building and Safety insisted upon adding their own, entirely redundant, testing regime on new solar products, thereby delaying their introduction in the City, even though those products were UL listed and approved for use everywhere else in the State of California by the California Energy Commission.
At the time we appealed to LA’s new major to fix this:
We suspect that the Garcetti Administration could make this go away tomorrow—so why don’t they? Given the Mayor’s claim to green cred, why not call a meeting with appropriate stakeholders: installers (including small installers), manufacturers, and department heads and lets cut through this unnecessary nonsense and make it easier to install rooftop solar in the biggest city in the biggest solar market in the country. It’s about time.
Now we have no idea whether anyone at LA City Hall reads this blog, and we are certainly not the only folks who have been speaking out about the problems in LA, but last week’s announcement does appear to have picked up on these themes. Here’s how LADWP’s new General Manager framed the issue:
“We recognize that our solar customers have become frustrated with longer than normal response times and the challenges of navigating through the application, review, inspection and rebate processes to receive the incentives and turn on their solar systems,” said LADWP General Manager Marcie Edwards. “We want to make it easier for customers to go solar so they can benefit from the city’s abundant sunshine by controlling a portion of their electricity costs, while helping to green the grid.”
To which we say, bravo, but the devil is in the details.
So what exactly is LADWP promising to do? Quite a bit, apparently, including (from the press release):
- Doubling the number of staff to expedite processing applications and issuing rebate checks.
- Hiring new staff members on a permanent basis to improve response times to hotline calls
- Streamlining the lease application review process
These are all good steps, but if folks who are brought in to review applications don’t understand what they are reviewing, then simply having more bodies will not improve the process. Maybe DWP could bring some actual installers into the training process. Why not pay them to sit down with your new hires and go over the materials being submitted via PowerClerk so that there could be a better understanding of what those materials mean? I’m guessing you could get some volunteers to assist with this process, for a price, and that would improve things for everyone.
In any event, to help increase the transparency of these efforts, DWP is also creating what they are calling “two Mayor’s Dashboards to keep customers informed of the progress and improvements” to the program. These dashboards are to be updated weekly—here is a portion of the dashboard as of March 24:
This shows that the delay in getting a rebate reservation reviewed is presently two months or 56 days—which would in and of itself be a significant improvement on the 78 days we recently endured. By the end of April, DWP is hoping to shave another week off of that and by the end of May to have cut it all the way down to just three weeks, which would bring DWP in line with its neighbors in SCE territory.
Unfortunately for those unhappy customers awaiting a rebate, your delays will get worse before they get better, with payments taking a full quarter of a year by the end of April. Ouch.
The announcement was not confined to just improvements at LADWP, apparently Building and Safety is also getting into the act. Again, from the press release:
Concurrently with efforts being made at LADWP, the solar permitting process at the Department of Building and Safety is being streamlined and simplified, with the vast majority of residential permits soon to be available online and additional training of field inspectors to deliver consistent and timely customer service.
These efforts are expected to save solar installers – and their customers – hundreds of dollars on solar PV systems by reducing trips to DBS for simple permits and ensuring that inspection issues are dealt with promptly. As this streamlining process moves forward, DBS will work with industry stakeholders to continuously deal with the introduction of new technologies in this rapidly evolving sector.
Heavens, be still my heart! Who knows, perhaps someday soon we will be able to skip the whole, “LA has to test everything itself just because it can,” phase and be allowed to deploy best-in-class technology as those products become available on the CEC list—just like we now can in every other jurisdiction. (Along those lines we have heard that the Enphase M250 has been approved and that the final certification should issue shortly. Finally.)
All and all, these are very encouraging noises coming from the City of Angels, and we can only hope at this stage that positive changes will match the promising rhetoric. We will be waiting to see… watch this space.
The folks running the CSI rebate program over at SCE (alas, dear Bruce, we barely knew ye) announced yesterday the imposition of a wait list for all residential solar rebates. In an email received at 1:53 p.m. on March 17th with the subject line, “CSI Waitlist Notification", we were informed as follows:
Dear CSI Solar Community:
Update on CSI Program Status
The remaining funds in SCE’s California Solar Initiative (CSI) Residential Incentive Program continue to be reserved at a higher than usual pace. Although California Solar Statistics shows just over a million dollars in Remaining Funds, the presence of “Remaining Funds” for a given Program does not mean that all those funds are available as incentives for available projects. Consequently, SCE will be establishing a wait list sooner than anticipated in an effort to ensure there is no oversubscription of the remaining funds. The Waitlist will become effective end of day on Monday March 17, 2014.
All new residential applications received after 7:00pm PST on Monday, March 17, 2014 will be placed onto the Wait List. SCE will continuously monitor the remaining incentive funds and review the highest waitlisted application as funding becomes available. Applications that do not have all required and correct documentation will be suspended and given 14 days to submit the requested information. If the documentation is not submitted correctly within the suspension period, the application will be cancelled and removed from the waitlist. All suspension timelines will be strictly enforced. Additionally, wait list projects may still have an opportunity to receive an incentive if previously reserved projects are cancelled out of the CSI Program. Please note waitlist projects will be reserved in the order received and are not guaranteed an incentive.
SCE has recently requested permission from the California Public Utilities Commission (CPUC) to shift some nonresidential incentive funds into the residential incentive budget. If approved by the CPUC, SCE will be able to allocate more megawatts and therefore more incentive dollars for CSI residential projects.
If you have any questions please call the CSI Helpline at (866)584-7436.
CSI Program Administrator
Southern California Edison
Who waits until mere hours before a deadline to announce the deadline? Why not simply announce it after the fact and be done with the drama?
So what does this mean? It means that as of now, residential CSI rebates in SCE territory are no longer guaranteed. Of course, at 20¢/Watt they were nearly gone for a while now, but this makes it official. Presumably non-residential rebates are still available, but it sounds like SCE will ask the CPUC for permission to tap that piggy bank and shift some or all of those funds to the residential program.
If you are a commercial, or more significantly, non-profit entity considering going solar, you better act quickly before those moneys disappear as well.
Everyone in the solar industry is focused on soft costs—that is all the extra expenses that are rolled into the cost of installing a solar power system. Since prices for solar modules have dropped to below a dollar/Watt, the percentage of an overall system price consumed by soft costs continues to increase. But soft costs are really hard to reduce and we just had a painful example to help drive that point home.
One of the most pernicious of the soft costs are those associated with getting approvals from the Authorities Having Jurisdiction (AHJs) over the project. That includes both the utility that must approve any rebate application and interconnection agreement, as well as the local building and safety department which must issue the permit and inspect the project. The requirements for approving a solar power system vary considerably from jurisdiction to jurisdiction and that lack of standardization—combined with just plain arbitrariness that runs rampant in some places—means long, pointless delays in moving projects forward.
We are working on a medium-sized residential project in Los Angeles. If we were doing this in Pasadena, it would be installed by now, but as everyone knows, LA isn’t Pasadena. We submitted the requested materials for reserving the rebate on this project on December 3 of last year and then sat back while we waited to hear from them. Weeks went by without a peep—while we reassured our client that we would update them as soon as we heard something.
Then, finally, we did. On February 19th, seventy-eight days after we submitted the application, we got an email telling us that the application was “incomplete” and that:
If you fail to submit the requested documentation by the above date your incentive application will be subject to cancellation without further notice.
(It really was in red type.) How long did they give us to respond? Two weeks. In other words, we get less than one fifth of the time that LADWP took to, in its sole discretion, identify “deficiencies", to cure those deficiencies.
If that wasn’t bad enough, LADWP adds insult to injury by sending a copy of the “deficiency” email to the client! Pity the poor client—they have picked a contractor, signed a bunch of paperwork, and made a down payment, all months ago with nothing to show for it, and then they get an email that suggests for all the world that their contractor has botched things and their project is about to go south! How helpful.
So now the contractor has to spend time reassuring the client that despite the dire tone of the email, everything will be ok. Then you spend more time addressing the “deficiencies” that have caused all the ruckus in the first place.
I won’t bore you with the entire litany of nonsense that we were asked to cure, but my favorite one was this: when you submit information about the system online, you are supposed to show the cost of modules, the cost of the inverter(s) and the balance of system (BoS) costs. You are also required to submit a copy of your contract for the sale. This we did. But they complained that the contract price and the system price entered online did not agree. Now here’s the thing, once you submit the rebate application to LADWP you can no longer see those details, so the contractor has no way to know where this “error” came from. So, with no other options, you tell them that the contract is the controlling document as to the system cost so they should use that.
Instead, they send out yet another email, this time with the scary heading: “FINAL NOTICE” (yes, all in caps) with the following declaration:
The Los Angeles Department of Water and Power (LADWP) has received your Solar Incentive Program application, and it is still incomplete.
And yes, they send a copy of this email to your client as well.
Now if they had actually read the contract they would have understood that the discrepancy is due to the rebate amount itself. Online, the total cost reflects the price before rebate. But because we front the rebate for our client, the contract price is net of the rebate amount. (The contract itself spells that all out, of course, but then LADWP would have to actually read the contract.) We thought about explaining this before coming to our senses and realizing that was a lost cause. Instead, we created a letter requesting that they modify the online data to reduce the BoS amount by the rebate, and uploaded that to their system. Voila, just like that, they reserved the rebate.
By my count, it took eight emails to get this resolved.
Just about everything about this interaction is wrong. The delay in the initial contact is wrong. The tone of the email sent out is wrong. The absurd disparity between the timing LADWP allows itself versus that to the contractor is wrong. And the lack of understanding of what they are reviewing is infuriatingly wrong. It builds in delays and costs to deal with those delays. It is what makes soft costs so damn hard.
It needs to change.
Solar rebates are fleeting in many locations—now you see them, now you don’t. Case in point, Burbank Water and Power (as is the case with its cousin in Glendale) is notorious for offering, and then taking away solar rebates. We monitor BWP’s website for new developments, and we have now learned that they will be holding a lottery for possible rebate funds next July. No additional details were made available; presumably they will be posted sometime in June.
Given that development, we decided to update our overall rebate status. Here is how things stand generally in the Run on Sun service area as of this date:
|Utility||EPBB ($/Watt)||PBI (¢/kWh)|
|(Click to see website)||Residential||Commercial||Non-Profit||Residential||Commercial||Non-Profit|
|Anaheim||Unavailable until June, 2014||Unavailable until June, 2014|
|Azusa||Wait List||Wait List|
|Burbank (BWP)||Lottery in July, 2014||Lottery in July, 2014 (30 kW or less)|
|Glendale (GWP)||Unavailable until 7/1/2014||Unavailable until 7/1/2014|
|Los Angeles (LADWP)||$0.40||$0.70||$1.45||Not used|
|SoCal Edison (SCE)||$0.20||$0.25||$0.90||2.5¢||3.2¢||11.4¢|
Here are a couple of very important qualifications to what appears in that table:
This is a moving target; watch this space.