Five Topics of Public Comments We Can Make to Achieve Local Renewable Energy Generation at the End of the Edison Grid in Ventura and South Santa Barbara County

The following series of comments are from The Clean Coalition telling the CA Public Utilities Commission exactly how to speed up resiliency with clean local energy generation that we deserve.

1. Goleta Load Pocket and a Resilience Feed-In Tariff (FIT)
2. Net Energy Metering–why a Feed-In Tariff accelerates development of resilience and Direct Relief in the Goleta Load Pocket
3. FIT vs Auctions for Acceleration of Renewable Energy Projects
4. Streamlined Interconnections for Ramping Up Rooftop and Parking Lot Solar and Community Microgrids
5. Reform Transmission Access Charges to Remove Unfair Market Distortion (the big hidden rip-off by SoCal Edison)

Part One: Goleta Load Pocket and a Resilience Feed-In Tariff (FIT)

The Clean Coalition believes that it is of the utmost importance to transition the electrical grid towards a sustainable and renewable future.  With the knowledge that as the number of wildfires in California has been increasing, so has the damage that they are causing, the first step that must be taken is to better outfit our critical facilities. These critical facilities should not have to split resources between actually fighting disasters or providing services and ensuring that there is enough energy to sustain rescue and recovery.  Most fire departments across the state only have enough diesel fuel for between two days and two weeks.  Considering that the firetrucks rely on diesel and the fuel is needed to pump water, there is enough demand, without also having to use diesel on backup generators.

I want to take a moment to focus on the situation in the Goleta Load Pocket, which is in Santa Barbara County.  The Goleta Load Pocket encompasses the cities of Goleta, Santa Barbara (including Montecito), and Carpinteria, an area of approximately 70 miles across the coast from Lake Casitas on one end, to Point Conception on the other end.  It is an area that is both highly transmission vulnerable and disaster-prone and is in need of 200 megawatts (MW) of solar and 400 megawatt-hours (MWh) of energy storage to achieve renewables-driven backup power in the case of a complete transmission outage.

The vast majority of solar siting opportunities in the GLP exist on rooftops, parking lots, and parking structures.  Small residential projects with the help of net energy metering are important steps to creating a more resilient grid, but larger scale projects on built environments will be key to generating the necessary renewable energy.   Because of a lack of unused space, a Feed-in Tariff (FIT) will be the most effective way to build renewable energy and storage within the confines of a large urban area like the Goleta Load Pocket.

Orange and yellow areas represent optimal sites for solar and storage in the Goleta Load Pocket — only a portion of what can be developed locally.

Part 2: Net Energy Metering Does Not Work for the Rooftop and Parking Lot Solar Projects We Need (Why a FIT is a resilient solution)

On a large scale like the Goleta Load Pocket, a Feed-In Tariff is the most resilient solution to the issue of energy procurement.  A cost-effective FIT is a standardized, long-term, guaranteed contract that allows smaller local renewable energy projects to sell power to the local utility or other load-serving entity.  A FIT simplifies the process for all commercial properties to participate in energy generation,

The renewable energy generated under the FIT is sold to the utility at the FIT rate and then the utility sells it at the common retail price.  A FIT using Market Responsive Pricing allows prices to adjust based on market response, ensuring that energy contracts are always set at the best market price. Moreover, through adders, a FIT can be tailored to drive the deployment of projects that have certain characteristics, such as location, size, or ability to dispatch power on-call using energy storage.

In the Goleta Load Pocket, for example, the non-profit Direct Relief needed a microgrid to ensure that their Goleta facility never loses electricity. Direct Relief is one of the largest disaster recovery and supply non-profits in the world and its headquarters has far more rooftop and parking lot solar siting opportunity than its existing 320 kW solar project utilizes. Net Energy Metering (NEM) and more general behind-the-meter (BTM) constraints, limit Direct Relief to 320 kW of solar even though its built-environments can support almost four times that amount of solar.

A Resilience Feed-in-Tariff targeted at critical community facilities would allow for the entire Direct Relief site to be used for Wholesale Distributed Generation of renewable energy, much of which could be directly distributed back to the utility under the FIT rate.

Part 3: FIT vs Auctions

Auctions and similar competitive solicitations result in a highly inefficient market due to exorbitant bidding costs and extreme failure rates.

The average minimum cost of producing an auction bid is over $150,000, which overwhelms commercial-scale projects that generally have total turnkey installed costs of less than $500,000. They also have 97% failure rates, combined with exorbitant bidding costs, and are a recipe for bankruptcy. Competitive solicitations for project developers raise the costs of doing business for all developers — and result in higher prices for consumers.

While losing bids tie up prime siting options and flood interconnection queues.  Winning bids include unrealistically low offers based on speculative future pricing rather than firm current pricing, resulting in projects that may never be built.

Across California RPS solicitations, fewer than 1 in 10 project bids were actually developed, which resulted in high administrative costs for the program and exorbitant risk/cost for renewable energy project development.

On the other hand, the standardized contracts and prices of Feed-in-Tariffs can be approved in a single decision. Not only does the Feed-in-Tariff approach nearly eliminate speculative projects, but it also drives down renewable energy development costs.

Part 4: Streamline Interconnection

A FIT uses wholesale interconnection, so the Load Serving Entity and Independent System Operator (ISO) have visibility and control of power produced by DG systems.

Giving Wholesale Distributed Generation (WDG) the same advantageous streamlined treatment as net energy metered (NEM) projects would make it equally fast and predictable. Currently, WDG interconnections are significantly more risky, costly, time-consuming, and expensive.

In the ideal world, FIT projects will be built immediately and proven to deliver power within 12 to 18 months.  The largest part of this time will be spent connecting the property to the grid and getting through the interconnection queue.  With the current auction system, the project needs to apply for the interconnection queue with each developer, as opposed to only one time under the FIT system when the best option is chosen.  Moreover, streamlined interconnection will make it easier for aggregate generation of energy for contiguous properties or sites with split meters.   This includes an obligation for utilities to offer cost certainty for prices estimates relating to interconnection.

With the CPUC Rule 21, about the future of grid connection, it is essential to consider upgrading the grid interconnections; inverters need to be upgraded to be able to communicate over the internet and eventually to use advanced functions, like sending data.

Example of new Interconnection Capacity Analysis (ICA) maps, showing color-coded existing capacity and detailed information for the specific identified point, as well as circuit load profiles, at the Paul Sweet substation in the Santa Cruz, CA area.

Part 5: Reform Transmission Access Charges

Transmission Access Charges (TAC) in California are assessed inconsistently and unfairly, creating a massive market distortion. In Permission To Operate (PTO) utility service territories, California ratepayers pay the same charge for “using” the transmission system whether or not the energy they use travels across that system. The TAC market distortion has these hidden costs:

• Californians could pay up to $60 billion extra over the next 20 years
• 3 cents per kWh is being stolen from clean local energy projects — 50% of their total cost — making them look more expensive than they really are
• Fewer dollars are available for the resilience that Community Microgrids bring our communities

A possible reform could be to Charge for electricity transmission based on actual use of the transmission grid. This method is already being used successfully by California’s municipal utilities.

We have the rare opportunity to look the five California Public Utilities Commissioners in their eyes and tell them we need more transparency, more accountability and greater speed getting off of fossil fuels. We are the public that they are supposed to be protecting instead of the for-profit utilities. Please read these topics and show up at the Oxnard City Council Chamber 305 West 3rd St. and help let these regulators know we are watching.

1. Climate Emergency Goal Net Zero Emissions by Earliest Possible Date

350 Ventura County Climate Hub joins Sierra Club California in declaring that the world faces an existential Climate Emergency requiring a state goal of net zero emissions by the earliest possible date. I am asking others who believe we are in a Climate Emergency to please stand.  We declare the climate situation threatens natural habitats, biodiversity and human populations and economies.

We therefore urge you to accelerate comprehensive, immediate, and sustained action to achieve net zero emissions in all California jurisdictions by the earliest possible date to help limit global warming to no more than 1.5 °C, toward a safe and stable climate while working in partnership with disadvantaged communities to achieve essential environmental justice goals.

Is it responsible for us to shout FIRE! in a crowded PUC meeting?

The house is on fire. We believe your new Integrated Resource Plan and all agencies of state and local government can do much more to remove barriers and stop protecting the profits of Investor Owned Utilities to the detriment of the public. Update your priorities, commitments and procedures as quickly as possible to achieve net zero emissions by the earliest possible date.

2. Distributed Energy Generation (DER), Resilience, and Cost-Effectiveness

 We in the Moorpark Subarea have been fighting your preconceived theories about what we need for many years. We appreciate that storage and DR is replacing the Puente boondoggle, but the truth is that our advocates told you in 2012 that Edison did not give a chance to anything but Puente. You dismissed us. We fought you for four years. We are unhappy about wasted time. To add insult to injury CAISO approved Edison’s 4^th transmission line from Santa Clarita to Moorpark substation despite the flaws in the cost comparison that did not include operation and maintenance. The 4^th line is more expensive in the long run and less resilient than DERs. You may say, ‘To assure reliability we require cost-effectiveness.’  If you include true costs, investments in renewable DERs will always be more cost-effective.

It is time that you start properly allocating the true costs. Who pays when utilities help wreck the climate, make children sick and cause fires? It is time to let communities decide what is cost-effective and who will pay for what. It’s not just ratepayers who benefit from protection against climate change, fire and bad air! Our CCA can do the best resource plan for our area.

3. Clean Power Alliance can do a reliable Integrated Resource Plan for energy reliability. We do not want a Central Buyer.

When we say we can do our own Integrate Resource Plan, we are saying we can make the best decisions about true costs and who should pay them. We can also plan our contracts to assure reliable energy supply. We do not want a state central buyer. A central buyer will block efficient development of renewable energy, because it will be influenced if not completely captured by Sempra Gas Company who we do not trust, whose negligence and unaccountability at Aliso Canyon is infamous.

We trust Clean Power Alliance to plan our integrated resources, because the board members and all related institutions of our CCA share our values and are transparent. Stop forcing us to fight against top-down controls and barriers to progress that protect the profiteering and polluting utilities who do not have our interests at heart.  Please work with us as we work for reliability, resilience, and rapid deployment of local generation to achieve net zero energy at the earliest possible date.

4. Agenda Item 24 Proposed Decision on Cost Effectiveness Testing (R14-10-003) re: True Social Costs of Carbon and Health Impacts/Costs Must Be Analyzed in All CPUC Proceedings

We welcome cost-effectiveness tests that incorporate the true costs of greenhouse gas emissions causing the climate crisis and the health impact of toxic air pollutants.

We ask you to improve this decision to more accurately incorporate the value of clean local energy or DERs as critical tools for meeting California’s policy goals — clean renewable energy, reliability, and reasonable rates.

Specifically,

• The Societal Cost Test should include well-documented methane leakage in the gas generating system, which results in substantial climate damage.
• Please use the Societal Cost Test in all proceedings relevant to DER’s starting when the decision is effective. You should not wait until the IRP evaluation is concluded in late 2021. California law has required that you include the health costs of fossil fuel generation since 1990. Only the Societal Cost Test includes these health costs.
• Please update the Avoided Cost Calculator this year to incorporate the substantial avoided cost of long distance transmission due to clean local energy resources. In 2017 $2.6 billion of long distance transmission projects were canceled due to energy efficiency and residential rooftop solar.

4. Necessity to electrify buildings ASAP, no more natural gas

Talking points:

• The impacts of climate change are at our doorstep, and we must move quickly and thoughtfully to achieve the state’s ambitious and needed climate goals of carbon neutrality by 2045
• The CEC’s recent Energy Report identifies buildings as a major roadblock to achieving our climate goals, and calls on state agencies to adopt policies to support electrification of gas end uses.
• As the CEC identified, the PUC has a major role in transitioning our homes and buildings to operate safely and reliable at zero-emissions. Policies like rebates, rate reform, and pilots will go a long way to help ratepayers transition off gas.
• However, we are concerned to hear from C4BES today, and to see their materials here. C4BES is a gas industry front group that ‘s putting CA at risk of slowing down our transition to zero-emissions technologies like heat pumps as well as trucks and buses.
• C4BES advances a position that is not grounded in facts. C4BES, like SoCalGas, claims we don’t need to electrify buildings or transportation but that qw can instead rely on biomethane and power-to-gas and other far off and costly fossil-gas replacements. This simply is not the case. California’s supply of biomethane could at most replace 10% of gas use. Power-to-gas is a costly reach technology that could turn a clean source of energy like solar into a highly potent GHG (methane) that leaks from the gas system.
• To achieve our climate and air quality goals, and to protect our communities from the safety risks of the gas system, I urge you to move forward with policies like incentives, rate reform, and pilots to speed deployment of zero-emission technologies, and to say no to investing more in expanding the gas system which will soon be a costly stranded asset.

Check the tweet from the gas company front group “Californians for Balanced Energy Solutions”  (C4BES) that are recruiting people who think cooking with gas is fine even though it is helping cook the planet and renewable energy will do the job and needs to be expedited.

Sunday, March 10

Doors Open 2:30 pm for mixing and meandering at Community Roots Garden on the church grounds

Program 3:00 – 6:00 pm

North Oxnard Methodist Church

1801 Joliet Place [near Gonzales and Galatin]

Oxnard, CA 93030

John Dennis Liu in his short film “Forest Keep Dryland Working”

The Community Roots Garden organizer is going to give us a tour of the garden at the church starting around 2:30 and we hope Jason and a friend will play some music, so come early!

John D. Liu is touring California to inspire us with his vision for large-scale ecosystem restoration to release the potential of nature and people. He chronicled China’s journey to revitalize the immense Loess Plateau. For the past ten years Liu has worked with colleagues identifying and documenting approaches to restore damaged and destroyed ecosystems around the world.

Liu is a Chinese-American environmental filmmaker and ecological field researcher. His documentaries have aired on CBS, National Geographic, and BBC.His award-winning Hope in a Changing Climate explores the true potential of ecosystem restoration.

He will be on his way from Paradise, CA, future site of the first Ecosystem Restoration Camp in California, and from the site for the first camp in Mexico. He will receive the Eco-Hero Award at the Lobero Theater in Santa Barbara on March 17, 6:30 pm. Buy tickets here – from $12, $24 and $100.

Contact: Ron Whitehurst, [email protected], cell 805-746-5368
To learn more about Liu’s work see www.ecosystemrestorationcamps.org

A coalition of climate organizations met with staff of Representative Julia Brownley asking for support for the Green New Deal Resolution

On Thurs., Feb 7, a group of 14 people from 350 Ventura County Climate Hub and other environmental groups met with staff at Congresswoman Julia Brownley’s Oxnard office in the Oxnard Transportation Center. We were there to voice our support for the Green New Deal as part of a nationwide action by 350.com to pressure Congress.

Brownley’s staff person, Ashley Orozco, invited comments from all attendees on their reasons for supporting the Green New Deal, and took notes to give to the representative.

Margot Davis requested a townhall meeting in Oxnard or Ventura on the Climate Crisis, and also suggested that Rep. Brownley write a letter to her voters about her position on the GND.

At the meeting, we learned that Rep. Brownley has been named to the Select Committee on the Climate Emergency that same day. This makes our work even more important. Staying in contact with the congresswoman, and reminding her of the importance of the climate crisis to her constituents will be vital during her term.

A note for those interested in visiting the Oxnard office: it’s necessary to set an appointment as the Oxnard office doesn’t have regular staff. Staff came in from her other office to meet with us.

Last week 350 Conejo & San Fernando Valley group visited Rep. Brownley’s Newbury Park office.

Here’s how to contact Rep. Brownley’s California offices to set up appointments:  Phone: (805) 379-1779

Alan Weiner (blue 350 shirt) leads the visit to Rep Brownley’s Newbury Park office to deliver thousands of petitions asking for cosponsorship of GND resolution.

In a media release, Congresswoman Julia Brownley (D-CA) released the following statement:

“This Committee’s work could mean the difference between a safe and healthy future for our
children and grandchildren and one where our planet, our economy, and our security are under
unrelenting and catastrophic threat. As a long-time champion for protecting our environment,
supporting investments in clean, renewable, and sustainable energy, and preventing anti-
environmental policies, I am honored to be appointed to this important Committee and will be
laser-focused on addressing climate change before it is too late.”

We need to hold her to that.

Rep. Brownley’s local offices:

Thousand Oaks, CA Office     
223 E. Thousand Oaks Blvd., Suite 220
Thousand Oaks, CA 91360  

Oxnard, CA Office
201 East Fourth Street, Suite 209B  (2nd floor of the Oxnard Transportation Center)
Oxnard, CA 93030

On Tuesday, December 11, the Ventura County Board of Supervisors adopted a resolution calling upon Congress to “expeditiously enact a revenue neutral carbon tax to combat global warming”, and supporting legislation that contains no immunity or exemptions for fossil fuel producers. Supervisors Long and Foy voted against the resolution.

The county becomes the first in Southern California to support the Citizen’s Climate Lobby (CCL) proposal for a federal Carbon Fee and Dividend Program. Fourteen other counties in Northern California, Colorado, Georgia, New Mexico, New York, Utah, and Wisconsin as well as over 100 cities.

As  lead sponsor of the resolution, Supervisor Steve Bennett spoke about how it builds on the momentum of the county’s progress toward local green energy and towards a strong Climate Action Plan. In a slide presentation he clarified features of CCL’s policy proposal:

• It is the opposite of a ‘command and control’ program. It does not ‘force’ changes. It is a ‘market-based mechanism’ that works to correct a distorted price throughout the economy because fossil fuels are subsidized by taxpayer dollars and do not pay for the pollution they cause.
• It is more favorable to low-income people than most other carbon pricing plans.
• It raises prices steadily on whatever depends on fossil fuels, but it is inherently flexible in that it returns all revenue to households so everyone can invest in the best adjustments for them.
• It provides a long-range window for forecasting and planning for small businesses as well as unleashing American technology innovation and ingenuity.
• It stimulates the economy with an increase in GDP, creates more jobs, improves air quality, and reduces health care costs.
• The French carbon tax that the people are protesting does not distribute the revenues to the people like CCL’s plan does.
• Carbon pricing failed to get public support in France because it became a financial burden on households.
• The way to prevent that is to return all the revenue to people, and that’s what a revenue neutral carbon tax policy does. The French made an unfair carbon tax design.
• Fairness to low-income people is a feature of CCL’s policy.

Supervisor Bennett showed polling data that 68 per cent of people in Ventura County want to see a carbon tax on fossil fuel companies. Supervisor John Zaragoza brought to the Board’s attention that HR 7173 was recently introduced in the US House of Representatives by a group of Republicans and Democrats. Entitled the Energy Innovation and Carbon Dividend Act, it would return a climate dividend payment to the pockets of all Americans.

Supervisor Linda Parks asked that the resolution include that any legislation to put a price on carbon should not exempt current federal Clean Power Plan regulations or give immunity for the damages caused by the burning of fossil fuels. She did not want to appear to be supporting a carbon tax proposal advocated by fossil fuel companies that includes exemptions and permanent immunity. Supervisor Bennett answered the concerns expressed by Supervisor Kelly Long about double taxation and conflict with state policies in that this policy would improve and not conflict with state carbon pricing policies.

In public comment Dr. Richard Elsley, leader of the Conejo Valley Chapter of Citizens’ Climate Lobby clarified that actually 97.5% of scientists agree that climate change is real and caused by human activity. Kimberly Rivers, Executive Director of Citizens for Responsible Oil and Gas commented that while Western States Petroleum advocates a sustainable energy future that appears to mean that they want to sustain pollution of the atmosphere by fossil fuels.

Jan Dietrick, Ventura CCL Chapter Leader asked 15 supporters to stand, saying there are over 500 CCL members throughout the county. She said those interested in learning more about CCL can go to www.citizensclimatelobby.org and that organizations and community leaders who want to endorse the Energy Innovation and Carbon Dividend Act, can do so at www.energyinnovation.org.