Tuesday, May 31, 2011

LADWP vs Edison: Same part of the world but worlds apart

Introduction:

Since 2005 the solar industry has grown over 500%. This has been an exponential growth fueled by the high cost of energy in both dollars and environmental pollution caused by conventional methods of generating electricity. The LADWP solar rebate program has been very popular. Many systems have been installed as the solar industry and the consumer have adopted the new technologies. LADWP has done the best that they can to incorporate the emergence of solar energy into their infrastructure.

Many of LADWP employees involved with solar have been with the department for twenty to thirty years and the requirements for cogeneration were written in the 1970’s. It has been difficult for the department to adapt. Within the solar department there have been many staff changes, many interdepartmental procedural changes and many changes to the paperwork process. LADWP has not had the financial resources to hire staff to run their solar program. People have retired and been furloughed, overtime has been disallowed and staff has been reassigned. One woman said point blank, “I am not qualified for my job since the man that was doing it before me was an engineer, but I am doing the best I can.”

The staff means well at LADWP, they are handicapped by the outdated requirements and procedures. At one point there were three site visits and five departments involved with each solar installation. Given the acceleration of the solar industry it has been very difficult for LADWP to keep up.

Given that there is still interdepartmental confusion at LADWP concerning solar and they are quite under staffed we don’t believe LADWP will be able to keep up with the goals of Governor Jerry Brown to aggressively add solar capacity to the state of California. Local solar power makes economic and environmental sense since local power prevents a 10% line loss when power is transmitted from out of state and prevents coal form being burned. It is ironic that when you Google “success LADWP solar” what comes up is articles on how the solar program has been suspended.

For some reason at LADWP there is a lack of understanding or a lack of acceptance when it comes to UL 1741 and the design of modern inverters.

1. All modern inverters meet and exceed the requirements of UL 1741. This prevents and inverter from going on line in the event of a power outage. Solar Forward has installed over 500 inverters and observes the following:

a. We have witnessed the LADWP grid at 277 volts (high) and two of our SMA inverters went off line until the grid returned to normal levels.

b. We have witnessed the Edison grid at 205 volts (low) and our inverter went off line until the grid returned to a normal level.

c. We have witnessed a 120 volt leg that fell to 107 volts due to a client having a short in a lamp and our inverter went off line.

d. We have tried to “trick” our inverters on line with a generator and they would not come on line.

e. We have a client that had two TV’s, a computer and a SMA inverter receive damage after a huge voltage spike in the LADWP grid.

f. We have had a total of seven inverters fail. All have failed OFF, unable to feed the grid.

We concluded that modern inverters are not a risk to a lineman or any electrical worker.

We make the following observations of the Edison and PG&E Solar Programs:

1. Edison and PG&E have had safe and efficient solar program.

2. There have been no untimely terminations of their solar programs for any period of time.

3. All paperwork with Edison and PG&E is handled in a timely manner and solar contractors may submit and observe the process on–line. A rebate reservation takes an average of two weeks.

4. Building and Safety inspectors have verified the integrity of solar installations. About 12% of solar systems are inspected by a third party on a random basis – no injuries have resulted from an improperly inspected or improperly installed solar systems.

5. All PG&E and Edison solar installations have been interconnected and turned on after passing building and safety inspection within 48 hours.

6. All modern inverters meet and exceed the requirements of UL 1741. This prevents and inverter from going on line in the event of a power outage. Solar Forward has installed over 500 inverters and observes the following:

a. We have witnessed the LADWP grid at 277 volts (high) and two of our SMA inverters went off line until the grid returned to normal levels.

b. We have witnessed the Edison grid at 205 volts (low) and our inverter went off line until the grid returned to a normal level.

c. We have witnessed a 120 volt leg that fell to 107 volts due to a client having a short in a lamp and our inverter went off line.

d. We have tried to “trick” our inverters on line with a generator and they would not come on line.

e. We have a client that had two TV’s, a computer and a SMA inverter receive damage after a huge voltage spike in the LADWP grid.

f. We have had a total of seven inverters fail. All have failed OFF, unable to feed the grid.

7. Edison does not require an open blade AC disconnect unless the solar system is over 10 Kw. No additional performance meter is needed.

8. Staff at Edison and PG&E have been trained and in sufficient numbers to run the solar program. There are a total of two departments to work with for systems under 10 Kw. These two departments talk to each other. There are three departments for systems over 10 Kw. There are currently few problems with paperwork.

We make the following observations of the LADWP program:

1. LADWP has had a safe but unstable solar program.

2. The LADWP solar program has been put on hold without warning at least three times over three years. This has caused the solar contractor and the consumer to try and adapt to a market place that as been turned on and off. The rules for the program have changes many times without warning. Rebates were delayed for up to a year without notice. Currently it is impossible to process paperwork with LADWP for the installation of a solar system in the city of Los Angeles.

3. All rebate paperwork is submitted through the mail to LADWP. There is no method to track the paperwork other than making a phone call or sending an email. Most email requests for status are not returned. A typical rebate reservation takes six to ten weeks.

4. LADWP requires their own personal to inspect every solar system. LADWP has not had a consistent staff of trained inspectors. All LADWP solar inspectors have been reassigned as of May of this year. Inspections are scheduled six to ten weeks after passing building and safety inspections.

5. All LADWP solar installations take six to ten weeks to be interconnected. After building and safety inspection the solar system is off until the meter is replaced by an LADWP inspector. This costs the consumer an average of $50 per week, burning 250 pounds of coal a week for an average total of one ton of coal being burned while waiting for inspection.

6. LADWP has consistently ignored the safety value of UL 1741 and has sent safety notices to their clients telling them LADWP employees could be injured by their solar system. LADWP solar requirements were written in the 1970’s and have not been updated to reflect the technology that has been available for the past five years.

7. LADWP requires an open blade AC disconnect and an old fashioned analog meter for all solar systems. For systems over 10 Kw LADWP requires an open blade disconnect with a window and a commercial grade electrical panel with test sockets. This adds $3000 to the cost of a 10 Kw system. No other utility in the country requires an open blade disconnect.

8. The LADWP solar program has been consistently under staffed and they have consistently put untrained personal in jobs that they are not qualified for. There are three departments for systems under 10 Kw. They do not work seamlessly. For systems over 10 kw there are more than five departments. Paperwork is consistently lost for months at a time.

Sunday, May 8, 2011

LADWP is Broken

To the Editor:

The solar industry in Los Angles, operating within the LADWP service area, has been put on ice for four to five months.  The LADWP has shut down the ability to sell and install a Solar Electric System for the third time in five years.  Permits from building and safety are still available, but due to the dysfunctional conditions at LADWP  (extremely understaffed, department infighting and operating under rules that were designed for technology in the 1970’s) it has become impossible to install a solar electric system in the largest municipal utility in the United States servicing over four Million residents.
 
Without any warning on midnight April 8, 2011 LADWP shut down 70% of our business by refusing to process any solar rebate paperwork.   April 11, 2011 LADWP sent letters to all customers installing a solar electric system threatening financial penalties and legal action if they turn on their solar system with out first receiving a LADWP solar inspection.   The following week LADWP reassigned most of their solar inspectors to other jobs, thereby bringing the inspection process to a virtual halt.  
 
            The LADWP solar incentive program had a staff of three up until December 2010, when one person retired. This leaves two people to process all the paper work for solar installations, man the office and answer the phone.  Processing paper work for each project requires carefully examination to check all the calculations and confirm all the components selected for the solar system are acceptable to LADWP.  After this is complete (which takes by one estimate takes about two hours) a “rebate reservation” of the system can be scheduled. This process takes six to ten weeks.  After the reservation is issued, the solar system can be installed.  Once installed, LADWP needs to have a copy of the final inspection from Building and Safety.  Then after another four to ten weeks of processing paperwork an inspection of the system can be scheduled with an LADWP solar inspector.  Then after two to four weeks an inspector will show up.  In the case of one of our clients, Mr.Reinstein, was given an estimate that it would take 3-4 weeks for the DWP to come out and inspect his system so that it could be turned on. Mr. Reinstein, like all customers are given strict instructions that they are not allowed to “turn on” their solar systems before the solar inspection or they will be in violation of LADWP rules. Mr. Reinstein waited four months.  This means his solar system, which was already inspected and approved by LA Building and Safety, remained turned off and was not producing energy.   All because the LADWP requires they send out their own inspector to look at the system.   In the mean time, as his solar system sat dormant on his roof, four tons of coal was burned to produce the electricity that Mr. Reinstein was consuming.
 
So Cal Edison allows the solar system to be turned on immediately after passing Building and Safety inspection.  So Cal Edison has outsourced the inspection responsibility because it is more economical and efficient in terms of quality control and speed.   They randomly inspect 15% of the solar systems installed.
 
LADWP needs restructuring or to outsource the solar program. Current policies are a bureaucratic nightmare and their commitment to accommodating renewable energy on a local level is only PR rhetoric.  Several solar contractors have offered to pay for an additional staffer at the DWP just to speed up the paperwork, but the response was to actually decrease staffing instead.   
 
Secondly, there is the basic issue that LADWP is disorganized and inefficient.  Skip Farber (another Solar Forward client) had the following to say after dealing with the DWP on his solar project.
 
 “I found the LADWP people to be smart and courteous with a genuine desire to serve the customer.  That being said, as an experienced business person I can make the following assumptions and observations: The Solar Program is not organized or empowered to manage the internal LADWP cross-over of departments. Inefficiencies and coordination issues were obvious in several areas.  A specific example was the installation of the proper meter….we had three such changes to meters before getting the proper meter.  This was both expensive for LADWP and us.  It also resulted in billing mistakes which required time on both (LADWP/us) our parts to sort out. It seems that LADWP has several “silos” that operate somewhat or completely independently.  The Solar Group needs to access or function across these groups but does not have control or authority to manage projects centrally.  This leads to the kind of inefficiency described above.”
 
Similar to Mr. Reinstein, Mr. Farber not only had to wait an extraordinary amount of time for his paperwork to be processed and his system to be inspected by DWP’s own people—while his system was sitting dormant—but he also received a lower rebate check amount with no justification or notification of the change.  This was due to DWP staff making mistakes.  After six months of futile efforts, there is still no response from LADWP to over thirty phone calls and emails.  Now, the manager and all of the solar inspectors have been reassigned.
            
The policy of LADWP sending out their own inspector to re-inspect a solar system for safety purposes is an insult to LA Building and Safety.  The claim is solar electric systems on the grid could cause harm to electricians working on electrical lines nearby.  UL 1741 is the required standard with modern inverters – they turn off when the grid is down.   There is no justifiable safety hazard. So Cal Edison, PG&E and all of Europe have faith in today’s technology and don’t even require an old fashion open blade AC disconnect switch that LADWP requires let alone redundant inspectons.
            
We want to work with the DWP to resolve this issue. It is not our goal to sit on the sideline and play the blame game. We have made several requests for meetings with LADWP to discuss the issues and work together - all have been denied.  It is in all of our interests to see this process become streamlined, for the environment, our health and for the economy. Many solar contractors working in LA have had to lay people off.  This has now become a legal issue of “Restraint of Trade” since LADWP is not allowing us to operate our business.  Realistically,  Solar Forward will not be able to install a new solar electric system for five months. 
 
In order to achieve Governor Brown’s goal of producing 33% clean energy by 2020, something needs to change. Our aging infrastructure with a centralized energy design is inefficient.  Close to 10% of the coal-generated energy is lost traveling hundreds of miles across interstate lines, through transformers and local distribution.  Residential and commercial solar electric systems supply energy locally, to their own house or business.  If your not home or the business is closed on the weekend, the energy is consumed locally in the neighborhood.  
 
If the city of Los Angeles is truly serious about clean energy, then this issue needs to be made a priority. The American Lung Association calls Los Angeles the second dirtiest and most dangerous city in terms of air pollution and respiratory problems. They also released information recently conveying that particle pollution from power plants kills approximately 13,000 people a year.  About 50% of the LADWP’s electricity comes from coal-powered plants.
 
Solar power is clean, safe, local energy.   LADWP has proven that it is not a team player in enabling the residents and businesses in Los Angeles effectively install green energy on a local level.   The solar program needs to in the hands of a third party.