December 12, 2011

Dear Mayor, LA City Council and DWP Board of Commissioners,

We have better options for powering our city than out-of-state, dirty coal plants. Clean, renewable energy is possible, generated right in our neighborhoods. Through the CLEAN LA Solar Program, businesses and homeowners can get paid back for the energy they produce from their rooftop solar panels. This policy is known as a feed-in-tariff (FiT), and is one of the best mechanisms to help cities switch to clean, solar energy.

A broad coalition of businesses, environmental groups, public health groups, and community organizations are calling for the Los Angeles Department of Water and Power (LADWP) to adopt the CLEAN LA Solar Program. According to research conducted by the Los Angeles Business Council, in partnership with UCLA, USC and energy experts, the economic benefit of the CLEAN LA Solar Program will be tremendous. The impact will include an estimated 16,000 jobs between now and 2020 and $2 billion in private investment across the city.

California has set a goal of generating 33% of its energy from renewable sources by 2020. Unfortunately, the LADWP has one of the weakest solar track records among major California utilities, generating only 1/6 as much solar power per customer as the leading utility in the state.

The CLEAN LA Solar Program can help change that, and bring clean, affordable solar power to our city. Please support a 75 MW solar FiT program beginning in 2012, with completion by the end of 2014, and fulfill the Mayor's vision of 150 MW of solar FiT by 2020.

A private-sector FiT program is critical to leverage private investment in solar power, generate plentiful jobs, and achieve sustainable energy goals established by state law. I support LA's bright solar future.

Sincerely,

[See attached list of people who sent letters supporting the CLEAN LA Solar Program]

fu!lname Rev. Dr. Robert Shore-Goss

Eric Anthony Rachel Deblinger Julian Carmona

Rachele Huennekens Joy Cernac Kent Minault

Reverend Joseph Shore-Goss

Kara Middleton Megan More Rev. Frank Elliott

Elinor Brandt

Dennis Tran Marilyn Roebuck L.E. Payne Jeannene Graham Randal Cummings Heather Herndon Jen Neib!ing Naoto Shimada Jennifer Sagastume Perry Rosensweig

Frank Faye Alex Reed Will Wright Drew Shula Reverend Dr. Neil Thomas Gary Russell Christian Campisi

Brent Schoradt Matthew Nesburn

Stanley Haye

David Murphy Darrell Clarke

Tiffany Duong Jacklyn Springer paul prejza Jorge Madrid Debra Gerod

Andrea Kusina Riley Mcintire Julie

zip comments

CA

91601 As Pastor of MCC in the VaHey Church in North Hollywood, it took 17 months and public embarassment of the LADWP officials at the city hearing on rate hikes to get action to get our church connected to the grid. \n\!11 and my congregation support the initiative for the LADWP adopt the Clean LA Solar Program.

90046 90036 91411 94115 90049 91423 With an aggressive commitment to renewables and efficiency, we can transform our energy

consumption and give a future to our children. 91352 The LADWP has done every thing to make solar very inconvienlant. This needs to,change and Ia

should put solarbon all new city construction and any city building it can

91040 get us off of Coal plants now. Go Solar on every city/county building in the city. Be pro-active. 90069 !t\'s time to stop the police brutality and the prison industrial complex and start leading the · world by building a world that works for \'Everyone\" Fossil Fuels are dead and they are ki!Jing

all of us! 90042 91331 91411 91606 91343 91345 90024 90032 92618 81833 92886 Dear Mr. Mayor, LA City Council, and DWP Commissioners:\n\nA los Angeles feed-in tariff will

do so much to lower unemployment figures and increase tax revenues within the City of los Angeles. A feed-in tariff will establish los Angeles as a true leader in the business of stimulating

green energy. This is truly a winning solution for everyone in the los Angeles metro area and I

urge you to pass the measure.\n\nPerry Rosensweig 92614 90034 The research is complete, the options have been weighed. Now is the time to \"just do it.\"

90010 90403 90027

90254 FiT is the proven way to speed-up the adoption of solar and renewable energy.let\'s make LA a leader in solar energy adoption!

91604 90272 93555 DonYt screw up the Owens Valley with huge solar panel fields. You have already done enough

damage. 31035 90025 90071 Renewable Energy is the hope for the future of our city, state, country, and world.

90016 90031 90041 This should be considered to be \"low hanging fruit\"- something very easy for the City to do

that will reap significant enery, economic, and political benefits.

90042 This is a win-win deal! 31049

James Brennan

Andree Denninger Michael Gordon

Kathryn Porter

Angelle Gullett Timothy Hane Isabella Cassini sheila b

Robert Melero Allison Thomas

Mirabal Auer Eric Clarke Jaime Bae Jacklyn Benavente

Elvia Aldaco

Ana Castillo angela brooks

Richard Prantis Ruth Rieman

Melvin leon Moody Jr lorena Avila francis del Iavecchia

Shadrach Pilip-Florea Eric Haas Michael Gonzales

dina Jim Stewart Hannah Linkenhoker James Finlay

Raymond Esha_ghian Anika Berhang Carrie Norton

Ca

90066 Please implement a 75 MW solar FiT program beginning in 2012, with completion by the end of 2014 ~¥and 150 MW of solar FiT by 2020. Please include a community solar bill credit allowing DWP ratepayers to invest in FIT solar arrays and offset their electric bill with the power that is generated.

90813 Please help us to save the extraordinary and irreplaceable Mojave Desert from industrial~scale

solar projects! 93534 Rooftop solar is much better than destroying our desert ecosystems by covering large areas of

land with solar panels. Costly, ugly transmission lines which also damage the environment are not needed.

916D2 9D027

90026 90D2S

We need at least 25 to 30 cents/kWh, with no caps on system size, and no system caps! let\'s get serious about dean energy now, and follow the proven solution of generous FITs being used a1! over the world! No more killing wilderness for energy!

91342 I believe that we shoudl do something to help our Earth be better than it is now. We are damaging our home and when its gone we wont have it anymore.

91325 Global warming has increased drastically due to the pollution which is produced by many of the coal mines used in today\'s society.! believe that as leaders within the los Angeles County, we all share the responsibility of taking care of Earth in order for humanity to continue existing. Without the help of the LA City Council Members, not many opportunities are given to civilians whether it be in public heath or jobs.CLEAN LA Solar Program can really Create a difference in this world, benefiting the citizens in the United States and Earth. Council Members I believe that you are th·e first to initiate a change which can not only bring success for humanity but <i!so for each individual who takes part in making a difference.

91316 90043 I have been involved in putting solar on multi-family affordable housing projects since 1999. We

need a better program than the \'net-metering\' we have now which does not incentive anyone to put more solar on their building than they can use. Put more solar on those bigger flat rooftops! We are not a privately held company, the LADWP is US!!!

9D026 92284 Dear Mayor,\nPlease set an example for the rest of the SoCal communities to follow. Your

neighbors in the Mojave Desert need you to lead and know that you can.\n\nSincere!y,\nRuth 9134S 914D2 9D291 9D03S Just Do it. 9D010 90013 1 am a resident and business owner in the City of Los Angeles and we need to adopt a viable

rooftop solar program for this City. We are behind the times incorporating this technology into our energy future. A small program will leave us in virtually the same place. We need to start thinking big.

90041 We need this now!!!!! make it affordable to all. 9DDD6 REDUCING GLOBAL WARMING EMISSIONS FROM LA IS IN YOUR HANDS! DO IT!!! 9DD36 90291 I am a commercial real estate appraiser with Wells Fargo Bank and just reviewed a beta version

of a very effective tool for property owners, buyers and sellers to determine the additional market resale value of a solar PV system. I mention this because solar PV has nearly reached financial viability and any effort to support it will help many people reduce our dependence on out of state dirty coal power. Solar is the right economic choice for clean long term power security !!

9DD1D

9DD26

Ray Bishop Ray Bishop

Tad ChuckS. Mirjahangir Janet Gagnon

dennis atkinson Elizabeth Crawford Boris von Bormann elsa rodriguez Dafyl Gale sheree levin lisa doell

Dan Thomsen

Usa Lewenberg Lisa Lewenberg

Ryan Matulka Owen Bailey Ronald Mu!ick Kent Minault

Russel! Horning Mark Bramhall Stan Evenson

Greg Johanson

Diane Ekker LESLIE EKKER Amanda Millett

Teri Bond Asi Kaufman

Ray Chavez Jacqueline Keller Mircal!a Wozniak Stuart Cooley

Phil Yaney

Joseph Held Cynthia Phakos

Cash Sutton Daynard Tullis Craig Lewis

cwrdf cwrdf

91303 92672 Go green.\nReduce Co2 Emissions

91367 When LADWP does solar, it should ALL be rooftop and within the L.A. basin. We have plenty of rooftop space (residential, commercial and industrial) to fulfill our needs. We do not need to exchange a huge coal monster for a huge solar mirror monster in our desert or a neighboring state.

90010 91436

91204 90024 90230 90291 90036 I am only for this initiative if a comprehensive energy audit is required for solar is installed with

at least a 20% reduction in the buHdings usage before solar can be installed

90045 91316 91301 Do what is right for the people who pay your salary. 91423 The jobs benefit here is really important. With these new jobs, every business owner in town

will benefit. Too many angetenos are walking around with no money in their pockets. Let\'s make our own stimulus.

90039 90034 90230 91361 LADWP has failed to produce meanful solar production results over a de.cade and has over

$100MN dollars in unused Public Benift Funds. It is time for the.City Counicil to take apporiate actions and move LA into the 21st Century. As a recent ga!loup Pol! states over 91% of the public wants Solar energy they have paid for it (1.85% surcharge for Over ten years) Where is the political will to follow through with the Public demands and hard earned money.\nl repesent over lOMW of working PV systems in the loacal area over a 20 year period without any downside to the community, Only reliability and over production by 10~15% per year what happens when they announce PV lasts 50 years plus and this is the counicel that could not act

90230 90041 Please support the expansion and use of solar energy in los Angeles. This is a great economic

and social opportunity and I would like to see or city take national leadership in this area.

\n\nThanks, \nAmanda Millett 90232 91604 This is the foundation for green economy, based on renewable energy!\nWe demand it now,

we demand the right to make electricity by ourselves and give/ sell it to anyone we want, TODAY

90019 90064 94104 90066 The City of Los Angeles needs to direct its Department of Water and Power to establish, IN

ADDITION TO existing solar promotional programs, a saleable feed~in tariff for the currently disenfranchised citizens and ratepayers who would gladly adopt solar if there were an avenue of choice. Cities should be exceeding investor~owned utilities in renewable adoption rates.

90209 Solar works.! have it installed and send power back to the grid every day. Lets free our selves from polluting sources and help our city become an example for others to follow.

90067 90028 I am an architect and look forward to installing solar on apartment buildings south of downtown

LA> 91710 90291

George ·M Coladonato Bob Tregih..is

charles fancher Amanda Dave Donaldson Marc Strassman Courtney Linton Scott Kanas Courtney linton Balduin Hesse Yo ram Shily Yo ram Shily sandy henriks

Kristina Davtyan AI Rosen Jamil Barrie David Olsen ZHIQIN SHEN Robert Lizarraga Andrew Read

Randy Nichols Matthew Moses ross butcher

Viki Goto Vaughan Davies James Hankla J. Gonzalez Samaria Chavez Mike Whatley

Tor Valenza

Maggie Wineburgh-Freed

Robert Siebert Denise Knight Anders H-A Joanne Kravetz Aaron Wdowin John Lansden Tara Kelly John Zinner Julie Kirkenslager

CA

92071 89509 lt\'s the smart thing to do. And you can help show myopic states like Nevada that there\'s a

better and cheaper way to do renewables.

Make solar happen in sunny LA! 91791 Specify the equipment installed must have a high US content to keep jobs in the US. 91607 We need a FIT for Los Angeles.

31026 90291 90291 90210

91303 We have to move on .... move off coal and on to solar (cleaner) power ..... the way of now and

90049 90043 93001 90034 91731

especially the future .... we must work together for the betterment of all. .... go from dirty black coal to clean white solar power .... and we all benefit ... thanks

92821 Please approve this action. it will create jobs stimulate the economy and generate new interest in our environment\n

90292 90068 90803 I want sOlar

90015 90071 90803 Include LA COUNTY Officials in this effort! 90017 We need to get Solar going in LA! 91491 92806 SunPower supports the implementation of a FiT program primarily due to our customers\'

desires to secure a return on an otherwise non-productive portion of their asset (i.e., roof) and to demonstrate their environmental leadership by helping the City reduce emissions and reduce its dependence on out-of-state electricity imports.

92866 93004 94606 90024

A solar FiT is critical to growing my solar PR business, not to mention helping the entire city to breath cleaner air. Please support this program. We have so many empty solar roofs in Los

Angeles, and we could create so many new jobs.

We have put solar panels on our home, and have gotten 4 of our friends/neighbors to do so as well. lt\'s the way to go- let\'s use the sun!

93036 lt\'s the future!

92121

92806

~'!if"''''" "-!ABC Los Angcle~ CU:Ml

Business Council

CLEAN LA COALITION

American Institute of Architects- LA

American Lung Association*Californla

Beverly Hills/Greater LA Association of Realtors

Building Owners and Managers Association

CaiSEIA

California Apartment Association~LA

California Interfaith Power & Light

Center for Sustainable Energy

Clean Economy Network

Communities for a Better Environment

Environment California

Enterprise Community Partners

Faith 2 Green

Global Green USA

Greater LA African American Chamber of

Commerce

Latin Business Association

LA Area Chamber of Commerce

LA Housing

LA Family Housing

LA Conservation Corps

San Fernando Valley Green Team

Sierra Club

Silver Lake Neighborhood Council

Southwest Regional Council of CarpenterS

Tree People

Union Roofing Contractors Assn.

US Green Building Councii~LA

Wilshire Center Business Improvement District

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FAQS and Questions: LA City ~rn~~Vt e (;; Council File No I j-ltem No. .±, \,

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In 2008, Mayor Antonio Villaraigosa called for 150MW of Solar Feed-in Tariff to be implemented in the city as part of a large 1GW Solar Program. The LADWP included 150MW of Solar FiT in their 2010 Integrated ResourcesPian.

In 2009, CA State Senator Gloria Negrete-Mcleod introduced SB 32 creating at state-wide feed-in tariff program (750MW state-wide; 75MW allocated to LADWP). Its goal was simple: establish a feed-in tariff (FiT) to spur the development of rooftop solar power in our state. The bill called on the MOUs and IOUs to create FIT programs that possessed the following attributes: fixed-price at a reasonable rate, simple application, low inter-connection fees and guaranteed access to the grid. On April12, 2011, City Council Energy and Environment Chairwoman Jan Perry introduced a motion asking LADWP to report to council on the implementation of a 75MW pilot program that is compliant with SB 32. The LADWP has conducted more than 4 summer workshops on the implementation of a 75MW FIT program and to the dismay of workshop stakeholders, returned with a 6MW Solar Demonstration Program that employs competitive bidding style price discovery process which do not meet the FIT program requirements set forth in SB 32. Members ofthe City Council introduced a motion in late August 2011, requesting the City Attorney to report to Council on the DWP FIT guidelines for the 6MW demonstration program and whether the use of competitive bidding to set the tariff and to select the program participants is consistent with the FIT program requirements set forth in SB 32. On November 2, 2011, in conjunction with the City Attorney, the LADWP has determined that the Board of Water and Power Commissioners (Board) has the discretion to approve a FiT Demonstration Program with a competitive model to set a price for the standard tariff that would be consistent with the requirements

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set forth in SB32. In addition, the City Attorney report declares that the use of a competitive process to determine the price offered in a standard tariff generally appear not to be inconsistent with SB 32. The City Council recommended that the LADWP return to the Energy and Environment Committee with a determined time line for the FIT among other things in 30 days (mid-December)

Challenges with proposed LADWP Solar Demonstration Program: Below are the challenges associated with the current LADWP Solar Demonstration proposal and entire FIT strategy:

• At this time, LADWP's proposed solar demonstration program as it stands is NOT a feed-in tariff but instead a competitive price discovery program that can best be described as a reverse-auction mechanism. A reverse-auction mechanism is neither compliant with the intent of SB 32 nor likely to generate the kind of program that will be most beneficial to the city. It is well documented that successful FiT programs have price certainty, easy application process, low interconnection fees and must provide fair rate of return. If an auction process were allowed to occur, LADWP customers, both large and small scale, will not be able to complete with large-scale solar developers who will underbid the program.

• Another major obstacle to customer participation in the sola program is a complex application process. The solar demonstration program application that presented at the latest stakeholder meeting is a byzantine process that will preclude LADWP customers from participating in the program. Attached are two 30+page applications for this program.

• The LADWP states that this program will have high administrative overhead because it will be a retail energy program. Unlike the SIP program (which is an energy program that DWP pays a retail price to participants), the FIT will allow participants to enter into power purchase agreement (PPA) agreements with the utility as an energy provider. Because of this, the LADWP should consider the FIT as part of their wholesale energy procurement program. Ultimately, costs will be evenly distributed throughout the renewable energy procurement sector thus reducing high administrative overhead.

• The SIP (Solar Incentive Program) is set to go offline in 2014. A well designed and well vetted FIT as intended by SB 32 should be established to bridge the gap between programs so the solar industry in LA will continue to thrive. 7SMW of FIT should be effectuated entirely by 2014 with half of the MW available in 2012-2013 and the other half in 2013-2014. Further, the department should return to the City Council E2 committee quarterly to report on the progress of the program.

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1'••<>'-'i'·:,,:,,,,,,,:n ~ ~ 1 '""'1!"~'·'· As it stands the LADWP has budgeted more than $100 million dollars for a utility built solar program in the 2011 budget. Most of this work will be done out of the LA basin thus seeing economic development being generated outside of the city. A private sector solar program deserves parity with any public sector utility programs because a private sector program can leverage private investment, generate good paying jobs and it allows LADWP customers to use the 30% federal tax credit.

• As it stands the 6MW Solar Demonstration Program will be divided between 1MW for smaller projects and SMW for larger projects. Of the 1MW allocation, 850Kw will in LA-basin and 150kW will be in Owens Valley. A Solar FIT program should be exclusively for LA Basin residents only.

Solutions for the proposed LADWP Solar Demonstration Program:

We have identified challenges with the LADWP proposed solar demonstration program above. Below are the specific solutions that will align the LADWP with the intent of SB 32 and ensure that all Angelenos benefit from a Solar Feed-in Tariff program:

1) Recommend that the LADWP set a fixed price, which includes utility and locational value adders at the outset of the program. Adders are additional incentives for energy delivered during peak times and for delaying the utility's need to invest in distribution system upgrades at a given location.·

2) Ensure a simple application process (current application is over 60 pages long compared with 7page application from GRU and 1 page application from SMUD)

3) Ensure the FIT program does not have high administrative costs. Must ensure that the FIT is part of the power purchase program

4) Ensure that the entire 6MW Solar Demonstration Program and 75MW be allocated entirely in the City of Los Angeles and fully comply with the state mandated SB 32

5) 75MW FIT must be fully implemented by 2014.

General Questions for the LADWP

1. Background: When the LADWP announced that they would be introducing a 75MW FIT program as mandated by SB 32, the environmental and business community expressed excitement and support. As you know, the intent of this legislation is to incentivize local businesses to play a part in distributed generation in urban centers. Further, the FIT is an opportunity for your customers to help mitigate rising energy costs. However, it seems that business and community support has diminished following 4 FIT stakeholder hearings

because the 6MW Solar Demonstration Program is a far cry from the intent of the SB 32 legislation and the application process is much too complicated. As an advocate for small business in Los Angeles, we need a program that is customer friendly can be easily financed and has a simple application. At this time, LADWP's proposed solar demonstration program as it stands is NOT a feed-in tariff but instead a competitive price discovery program that can best be described as a reverse-auction mechanism. A reverse-auction mechanism will not generate interest from small businesses and non-profits. As you know, many studies of successful FiT programs have found that price certainty and a fair rate of return are essential.

a) Question: How will your customers--commercial and multifamily building owners, business owners, etc.- be able to compete with large scale solar developers who can underbid the price in order to gain market share in LA? How do we ensure that this program will be available for your small and mid-scale LADWP customers who are not professional solar developers? A fixed price gives developers, owners and operators much needed financial certainty when participating in the program. UCLA recommends a FIT incentive between .14-.17 cents per kWh.

2. Background and comment: The proposed Solar FIT program does not determine · a timeline or benchmarks for 75MW FIT program. We need to ensure that any FIT program moving forward is fully implemented by 2014 (perhaps, 30MW by 2012-2013 and 45MW by 2013-2014 with quarterly reporting to ensure that the program is being implemented correctly}.

3. Background: As it stands the 6MW Solar Demonstration Program will be divided between 1MW for smaller projects and SMW for larger projects. Of the lMW allocation, 850Kw will in LA-basin and lSOkW will be in Owens Valley.

a. Question: Why would you allocate a portion of the FIT to be completed in the Owens valley? This program is intended to be an in basin solar program for City of LA customers and needs to be restricted to small businesses and non-profits in the City of LA.

4. Background: Any solar policy moving forward needs to echo the goals outlined in the ordinance and ensure that any application process is simple, straight forward and short. As it stands the application process proposed for the 6MW Demonstration Program is long, complicated and will discourage participation by LADWP customers. Further, it appears that the application is modeled after the unsuccessful Southern California Edison CREST program which is not applicable

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to LA customers. Both SMUD (Sacramento utility) and GRU (Gainesville utility) have very short applications and require minimal staff to administer their FIT programs. (see the attached 1 page applications from GRU). LADWP needs to streamline their application process for the solar demonstration program.

a. Comments/Question: We need to ensure that the application for any Solar FIT Program and the 75MW FIT is no more than 10 pages at best. I propose that the LADWP reconfigure the current application and return to E2 with a revised application no longer than 10 pages.

5. Background: We need the LADWP to identify locations in the city which in cent program participants to develop in certain areas with high solar potential and low income areas. At this time, we have training programs that are churning out trained solar installers in areas of high solar potential. However there is no policy in place to put them to work.

a. Question: Why hasn't LADWP identified locations in the city that could handle additional load and service areas of high solar potential? I move that LADWP create a map which identifies locations in the city with high solar potential and low income areas and add locational value benefit that can be added to the to the determined tariff which reflect a program participants desire to develop in said area.

6. Background: The LADWP is spending upwards of $100 million dollars in this year's budget on two out of basin solar projects. Further, they plan on spending approximately $3 million on an Owen's Valley Solar Project. Yet municipal programs cannot leverage the federal tax credit which provides 30% tax credit on private solar projects.

a. Question: Explain to me why we are developing such a small demonstration program when the key federal tax credits are due to run out in 2016. As a proponent for business attraction and retention in LA, this is a missed opportunity on our part, not to capitalize on these tax credits that would help bring more private investment and job creation to LA.

7. Background: The SIP program at LADWP was created by SB 1, the California Solar Initiative. The SIP program is a customer program which operates on the retail side of the meter which necessitated a large administration budget. As a result, it is not considered part of the department's overall renewable energy procurement strategy. At this time, the LADWP is planning on administering the FIT program, demo and 75MW, as a new retail program. This is problematic because it will significantly raise the administrative costs of the program through new administrative costs and training. At this time, other FITs across the country

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such as those operated at SMUD and at GRU, are all programs which are considered part ofthe utility's overall renewable energy procurement strategy. Moreover, neither of those programs cost the utility more in administrative overhead costs.ln order to decrease the cost of this program, the 75MW program, should operate on the wholesale side of the meter as the solar energy generated from a FIT will be included in the renewable energy procurement strategy. (FYI-Ron Nichols was open to the idea of moving the FIT to a wholesale program)

a. Question: How will the LADWP deliver a cost effective Solar FiT program with low administrative costs and a simple application process?

www.nrdc.org

Date: __ l~ -(1·-\ (

Submitted in_£ E Committee

Council File No:

Item No. J \ -QI / ') -5 1 8 \J... . " f:\!"J"I! AL RESOURCES DEFENSE COUNCIL

Deputy· I~ I /'- ' ______ <.,......c "If' '\.Q ~~

April 7, 2011

Mary Leslie, President Los Angeles Business Council

Dear Ms. Leslie,

On Behalf of the Natural Resources Defense Council, I would like to add our support for a Solar Feed in Tariff (FIT) program for the City of Los Angeles. We agree that a FIT program along the lines promoted by LABC/UCLA would effectively promote renewable energy, create jobs and reduce greenhouse gas emissions in Los Angeles. This program can play a key role in getting the City's economy back on track and promote rapid development of a local renewable energy industry by utilizing Los Angeles' natural solar potentiaL

The CLEAN LA program has already attracted the strong support of organizations representing business, labor, the environment and numerous communities from around the city. We find the proposal attractive because it closely tracks the criteria we consider crucial for an effective Feed in Tariff for development of clean distributed energy.

NRDC advocates for a range of policies designed to dramatically increase the deployment of renewables and meet our climate challenge. These policies include an economy wide carbon cap and trade system, target-based renewable portfolio standards, production- and investment-based financial incentives, and utility revenue decoupling. Renewable distributed generation deployment presents specific challenges that require additional policy solutions. A Feed in Tariff, such as that promoted by LABC/UCLA can play an integral role in the promotion of distributed generation, if properly designed.

However, a poorly implemented FIT can cause significant rate impacts without establishing a sustainable market and the complexity of designing such a policy should not be underestimated.

Key Components for NRDC Snpport of a FIT:

FITs are not a substitute for competitive resource procurement of renewable energy by electric utilities. Instead, FITs and other incentive mechanisms, are intended to provide additional supp01t for emerging technologies to overcome existing barriers to deployment under traditional competitive procurement, incentivize smaller distributed wholesale generation that can face administrative and transaction cost barriers to participation in competitive procurement, attract private sector capital, and drive down costs· in· the! eng-run.

111 Sutter Street 201h Floor San Francisco, CA 94104 TEL415875·6100 FAX415875·6161

NEW YORK · WASHINGTON, DC · LOS ANGELES· CHICAGO · BEIJING

www.nrdc.org

As we outline in the points below, there are several vital elements of a well-designed FIT. We are pleased to see the consistency of tbe LABC/UCLA proposal with these principles and hope that any FIT adopted by LADWP will meet these requirements as well. NRDC would support an LADWP FIT that incorporates the following key components:

" Restrictions on Project Size: FITs should be available for small wholesale distributed generation systems, no larger than several megawatts

-7 Small wholesale generating systems can have significant environmental and system benefits by being built with no or low land impacts and without need for additional transmission. However, these projects also face higher transaction costs, have difficulty finding cost-competitive financing, and thus have a harder time effectively bidding in to competitive utility renewable energy procurement programs. On the other hand, larger commercial projects should be able to access capital at lower costs and achieve enough scale benefits to compete effectively in competitive resource solicitations. Additionally, allowing larger projects to take advantage of FITs could undermine the advantages of a complementary competitive renewable procurement policy.

-7 Projects that can be sized to the demand of the building can be funded through programs for smaller scale renewables and are often not a good match for wholesale mechanisms like Feed in Tariffs.

• Tariff Rate-Setting to Limit Rate Impact and Reflect the True Value of Distributed Generation: FITs should be launched with a reasonable starting value ancf payment duration, account for existing deployment incentives, and ensure payment rates decrease dynamically over time for new project contracts. FIT rates should also be designed to be cost-effective, paying for value of clean distributed generation to the grid and society and the value of increased cost reductions through accelerated deployment.

-7 The primary driver of success and cost-effectiveness with a FIT mechanism is the setting of an appropriate starting rate of payment that drives, but does not over-compensate developers. At first, payments should be differentiated based upon technology type, project size and utility system resource quality. A mandated reduction of tatiff rates, perhaps based on achieving installed capacity goals, encourages learning and promotes market competitiveness.

-7 However, calculating FIT rates based solely on cost of generation and tbe . need . .to ensure a.stable proje.ct rNQrn ulth11ately obscures the value of

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distributed generation and does not ensure a cost-effective policy. When recalibrating FIT rates and applicability in order to reflect early cost reductions and increased market penetration, the goal should be to match quantifiable avoided utility system costs and long-term environmental and economic benefits gained from the clean distributed generation. The rate should monetize avoided utility system costs, reduced transmission needs, avoided emissions benefits, reduced grid congestion, reduced land use bnrden benefits, and any additional value appropriately reflected in a long­term, total resource cost calculation.

e Regular Evaluation and Flexibility: Program evaluation should occur regularly and balance the need to ensure investor and industry certainty with the need to ensure that the FIT is cost-effective.

-7 Recurring evaluations of price and other program attributes can determine if FITs are leading to an overheated market, which can be expensive and lead to investment volatility, and lead to booms and busts in the supply and servicing industries. Program evaluation should also include performance assurances that use regional balancing authority measurement and verification standards. The ability to change FIT guidelines is an important driver of the policy's cost-effectiveness and can also improve integration practices.

e Capacity Cap: In order to minimize cost concerns, a reasonable limit should be placed on the amount of resources that can be procured under the FIT.

-7 Given the expensive history of select FIT programs, a reasonable program size cap should be in place to limit the risk of runaway growth that can impact the full ratebase and ultimately lead to integration challenges for utilities. However, this cap should still provide a substantial opportunity for distributed renewable resources. If this limit is reached, the FIT should continue after consideration of continued need and acceptable rate impact to make the FIT available for additional resources.

• Performance assurances. In order to ensure value for utility customers, regular perfonnance assurances (though none additional to those required by the balancing authority) should be an essential component of the program.

o Informed Distributed Generation Siting: Sufficiently precise and transparent distribution system analyses to identify specific grid locations that would benefit from new clean distributed generation ought to precede and then strongly inform FIT rate design and capacity limits.

-7 While not specific to a FIT, the physical positioning of new distributed generation on the grid is an important factor in detennining locational benefits such as reduced congestion, avoided systems losses, deferred T&D investments and lowered emissions of environmental pollutants. Renewable distributed generation may also add unique societal and environmental

--·-··-··-··· -----·-- ----· .. -·--·--·-·· -------.. benefi1ts that hinge upon other locationa!factors and customer~profiles.;

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Distribution system analyses should be conducted to inform the development of a FIT mechanism that helps grid planners rapidly deploy systems that will most enhance glid reliability, reduce grid congestion and reduce transmission and distribution investment.

We appreciate look forward to working with you to develop an effective distributed renewable energy program in Los Angeles!

Many thanks,

Noah Long Energy Program Attorney Natural Resources Defense Council Ill Sutter St. 20th Floor San Francisco, CA 94104-4540

CC: Lorraine Paskett, LADWP

; For one calculation method, see Plwtovoltaics Value Analysis, Contreras et. al., NREUNavigant, 2008: hltp://www! .ecre.enemy.l!oV/i;o[ar/pdM4230J.gdf

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SOUTHWEST REGIONAL COUNCIL OF CARPENTERS Representing Carpenters in Southern California, Nevada, Arizona, Utah, New Mexico and Colorado

Hal Jensen President

Representing Local Unions in Southern California, Nevada, Arizona, Utah, New Mexico and Colorado

55 Denver

150 Camarillo 184 Salt Lake City

209 Sylmar

244 Denver

408 Phoenix 409 Los Angeles

440L Santa Ana

510 Denver 515 Denver 547 San Diego

630 Long Beach 721 Whittier 743 Bakersfield

803 Orange

897 Bullhead City

944 Ontario

971 Reno 1245 Las Cruces

1319 Albuquerque !353 Santa Fe 1498 Provo

1506 Los Angeles

1507 Salt Lake City

1553 Hawthorne

1607 Ontario

1780 Las Vegas

1800 Arroyo Grande 1827 Las Vegas 1977 Las Vegas

2007 Orange

2093 Phoenix 2361 Orange

2375 Wilmington

2834 Denver

Mike McCarron, Executive Secretary-Treasurer

Jim Flores Marc Furman Sr. Admin. Assistant Sr. Admin. Assistant

Councilmember Jan Perry, Chair Energy & Environment Committee City Hall 200 N. Spring St. Los Angeles, CA 90012

Dear Councilmember Perry:

Randy Thornhill Dir. of Special Projects

November 17, 2010

On behalf of the Southwest Regional Council of Carpenters, I am writing to express our support for the Los Angeles Business Council's CLEAN UP LA 600 MW Solar Feed-in Tariff (Fit) program. This Program will create a vibrant solar market to put people back to work, reduce polll.!tion and generate much needed revenl.!e. It will demonstrate to the rest of the nation that the City of Los Angeles is a leader in transitioning from fossil fuels to renewable clean energy.

The CLEAN UP LA Program offers many benefits, including the possibility of powering over 137,000 households with clean energy ar1d generating more than $2 billion in private investment over 10 years while producing an estimated 18,000 higb wage jobs including many for our members in construction. Our industry has been hit harder than any other segment of the economy with unemployment running at 40% during this recession. Implementation of this Program offers the City an immediate way to promote renewable energy and help move us out of this economic downturn.

Our organization continues to spend tens of millions of dollars in state-of-the-art training facilities and specialized courses to respond to the needs of the growing green economy including solar power installation. We firmly believe that if the City is to achieve its goal of encouraging development of a strong renewable energy industry, this Program and others must not be hamstrung by requirements for specialty contractor licenses that would artificially restrict the participation of all qualified and capable contractors and employees.

. 533 S .. EremontAve.,IOth Fl. 50 !North bamb-Bivd, · Las Vegas. NV 89 l 10

1702) 531-1800

· l !50Termina1Way Reno. Nevada 89502

(775) 323-1409 Fax (775) 323-6561

Los Angeles, CA 90071 (213) 385-1457

Fax: (213) 385-3759 4547 W. McDowell Rd. 8149 S. Welby Park Dr. Phoenix. AZ 85035 West Jordan, UT 84088 ( 602) 272-2700 (801) 280-0292 Fax (602) 272-1928 Fax: (801) 280-0370

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{303) 355-8774

Again, we urge the City to adopt and implement the CLEAN UP LA 600 Solar Feed-In Tariff program immediately.

YoJZ/Pkk-Mike McCarron Executive Secretary-Treasurer

Cc: Councilmember Cardenas Councilmembet Alarcon Councilmember Koretz Councilmember Krekorian

GLAAACC

Greater Los /.l,ngeles African American Chamber of Cornrnerce 501(C) 6

Board Members Gene Hale. Chairman Clarence A. Daniels, Jr., Vice Chair Angela Gibson. President Bellve Dixon, Vice President rviidlelle Smith-B8flard, Secn:lary Kimbe1·1y Cafter, Pal1iamentarian Lemuel Daniels, Treasurer

Directors t:":io!J 81ctke Sonya Dukes Charles J. Fronklin Douglas L. Hall Chatles A. Harmon '.Ah11!er Hill. Jr. Kerman Maddox Patricia IVieans Ci1fistine Simmons Derek C. Srnilh Mone\la Stephens I.Za1·int Zaman

October 13, 2010

Los Angeles Business Council 2029 Centuty Park East, Suite .1240 Los Angeles, CA 90067

Dear Los Angeles Business Council,

I would like to extend the Greater Los Angeles African An1erican Chamber of Commerce's (GLAAACC) support to the Los Angeles Business Council/UCLA's proposed 600 MW Feed-in Tariff (FiT) program for the City of Los Angeles. We agree that the LABC/UCLA proposed program is the best step our city can take right now to promote renewable energy in Los Angeles. Given the current economic and environmental climate, where people are losing jobs, manufacturers are leaving the region, and greenhouse gas emissions need to be reduced, this program can play a key role in getting the City's economy back on track by putting people to work utilizing our City's own solar potential.

The LABC/UCLA Solar FiT program has already attracted the strong support of organizations representing business, labor, the environn1ent and numerous communities from around the city. GLAAACC is pleased to join this extensive coalition of suppOtters because we believe the program offers great economic and environmental benefits for Los Angeles and its residents. These benefits include:

• Creation of 11,000 high-wage green jobs in the City • Attraction of clean-tech industries to the region by demonstrating political

commitment to creating a green City • Guaranteed cost saving opportunities and long-term retums for energy

consumers by moving away from coal usage, which is a significant liability to the City because of its escalating cost, legal risks, regulatory uncertainty, and public health effects

• State and federal tax credits to fund up to 40% of solar panel installation costs • Use of a FiT program to reach AB 32 renewable energy goals • Cost saving opportunities for multi-family affordable housing developments

GLAAACC suppOtts the LABC/UCLA 600 MW FiT for the City of Los Angeles as a means of driving our economy, creating jobs, and cleaning up our environment.

Sincerely,

Gene Hale Chaimmn, GLAAACC

The San Fernando Valley Green Team 5121 Van Nuys Blvd., Suite 200

October 22, 2010

Los Angeles Business Council 2029 Century Park East, Suite 1240 Los Angeles, CA 90067

Sherman Oaks, CA 91403

Re: LABC/UCLA 600 MW Feed-in Tariff Proposal

Dear Los Angeles Business Council,

I would like to extend The San Fernando Valley Green Team's support to the Los Angeles Business Council/UCLA's proposed 600 MW Feed-in Tariff (FiT) program for the City of Los Angeles. We agree that the LABC/UCLA proposed program is the best step our city and region can take right now to promote renewable energy in Los Angeles. We also believe that this program will play a key role in expanding solar business opportunities within the City and helping the local economy.

The LABC/UCLA Solar FiT program has already attracted the strong support of organizations representing business, labor, the environment and numerous communities from around the city. We are pleased to join this extensive coalition of supporters because we believe the program offers great economic and environmental benefits for Los Angeles and its residents. These benefits include:

• Creation of 11,000 high-wage green jobs in the City, • Attraction of clean-tech industries to the region by demonstrating political commitment to

creating a green City, • State and federal tax credits to fund up to 40% of solar panel installation costs, • Contributions of the FiT program to reach AB 32 renewable energy goals, • Cost saving opportunities for multi-family affordable housing developments, and • Significant Economic Development opportunities in the San Fernando Valley given the

massive amounts of commercial and industrial rooftop space available for solar generation potential.

The San Fernando Valley Green Team supports the LABC/UCLA 600 MW FiT for the City of Los Angeles as a means of driving our economy, creating jobs, and cleaning up our environment.

Sincerely,

'' ~: :.

Carolyn Casavan, P.E. Co-Chair THE SAN FERNANDO VALLEY GREEN TEAM

VGT ~FIT Endorsement Letter.10.2010.doc 1