MEETING NOTICE AND AGENDA

REGIONAL ENERGY WORKING GROUP The Regional Energy Working Group may take action on any item appearing on this agenda.

Thursday, November 17, 2011 11:30 a.m. to 1 p.m.

SANDAG, Board Room 401 B Street, Suite 800 San Diego, CA 92101-4231

Staff Contact: Susan Freedman (619) 699-7387 [email protected]

AGENDA HIGHLIGHTS

• ENERGY AND CLIMATE MEASURES IN THE 2050 REGIONAL TRANSPORTATION PLAN AND SUSTAINABLE COMMUNITIES STRATEGY

• SAN DIEGO GAS & ELECTRIC’S GENERAL RATE CASE: POTENTIAL IMPACTS TO SOLAR CUSTOMERS

SANDAG offices are accessible by public transit. Phone 511 or see www.511sd.com for route information. Secure bicycle parking is available in the building garage off Fourth Avenue.

In compliance with the Americans with Disabilities Act (ADA), SANDAG will accommodate persons who require assistance in order to participate in SANDAG meetings. If such assistance is required, please contact SANDAG at (619) 699-1900 at least 72 hours in advance of the meeting.

To request this document or related reports in an alternative format, please call (619) 699-1900, (619) 699-1904 (TTY), or fax (619) 699-1905. REGIONAL ENERGY WORKING GROUP Thursday, November 17, 2011

ITEM # RECOMMENDATION

1. WELCOME AND INTRODUCTIONS

+2. APPROVAL OF MEETING SUMMARY APPROVE

The Regional Energy Working Group (EWG) is asked to approve the September 22, 2011, meeting summary. 3. PUBLIC COMMENTS/MEMBER COMMENTS

Members of the public shall have the opportunity to address the EWG on any issue within the jurisdiction of SANDAG that is not on this agenda. Anyone desiring to speak shall reserve time by completing a “Request to Speak” form and giving it to the EWG coordinator prior to speaking. Public speakers should notify the EWG coordinator if they have a handout for distribution to working group members. Public speakers are limited to three minutes or less per person. EWG members also may provide information and announcements under this agenda item.

REPORTS

+4. ENERGY AND CLIMATE MEASURES IN THE 2050 REGIONAL INFORMATION TRANSPORTATION PLAN AND SUSTAINABLE COMMUNITIES STRATEGY

On October 28, 2011, the SANDAG Board of Directors adopted the 2050 Regional Transportation Plan and its Sustainable Communities Strategy. Staff will present an overview of the proposed measures that fall within the scope of the Energy Working Group and that help implement the Regional Energy Strategy. +5. SAN DIEGO GAS & ELECTRIC’S GENERAL RATE CASE: POTENTIAL DISCUSSION IMPACTS TO SOLAR CUSTOMERS

As part of its General Rate Case, the San Diego Gas & Electric (SDG&E) is proposing changes to customer rates including the addition of a network use charge. The proposed changes will have cost implications for existing and future solar customers. A. Staff will provide a brief overview of how solar is addressed in the Regional Energy Strategy. B. J. C. Thomas, SDG&E, will present an overview of SDG&E's filing and proposed rate changes for solar. C. Andrew McAllister, California Center for Sustainable Energy, will present information on potential impacts to residential, school, and public agency customers using solar.

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6. SCHEDULING AGENDA ITEMS FOR FUTURE MEETINGS

Members of the EWG are invited to suggest topics for future meetings. The next EWG meeting will occur one week earlier than usual on Thursday, December 15, 2011, from 11:30 a.m. - 1:00 p.m.

+ next to an agenda item indicates an attachment

3 San Diego Association of Governments

REGIONAL ENERGY WORKING GROUP

November 17, 2011 AGENDA ITEM NO.: 2

Action Requested: APPROVE

SEPTEMBER 22, 2011, MEETING SUMMARY File Number 3200300

ITEM #1: WELCOME AND INTRODUCTIONS

Chair Carrie Downey, City of Coronado, called the meeting to order at 11:39 a.m. Chair Downey announced that Kayla Race would be the second alternate from Environmental Health Coalition.

ITEM #2: JUNE 23, 2011, MEETING SUMMARY

Don Mosier, City of Del Mar, motioned to approve the meeting summary from June 23, 2011, and Mike Evans, San Diego Regional Chamber of Commerce, seconded the motion. The motion carried without opposition.

ITEM #3: PUBLIC COMMENTS/MEMBER COMMENTS

No public comments.

ITEM #4: U.S. DOE PLUG-IN EV PLANNING GRANT

Chair Downey reviewed the status of the grant opportunities from the U.S. Department of Energy (DOE) and California Energy Commission (CEC) to promote regional planning for plug-in electric vehicle (PEV) charging stations. The California Center for Sustainable Energy (CCSE) received an awarded for this grant as the lead entity for a one year project starting in 2012.

ITEM #5: STATE LEGISLATIVE STATUS REPORT

Chair Downey noted that information on Energy Working Group (EWG) relevant bills was included in the agenda and that the special session of the California State Legislature ended on Friday, September 9, 2011. Governor Brown’s last day to take action is Sunday, October 9, 2011.

ITEM #6: ENERGIA SIERRA JUAREZ WIND PROJECT

Scott Crider, Director of External Affairs for Sempra Energy, and Lisa Briggs, Sempra Generation, presented an overview of the Sempra Generation Energia Sierra Juarez Wind Project. Ms. Briggs provided background on the organizational structure of Sempra Energy, which consists of five companies including San Diego Gas and Electric (SDG&E) and Sempra Generation.

4 Sempra Generation has been developing the Energia Sierra Juarez Wind Project since 2007 and is nearing the end of the permitting stage for its Phase 1. Phase 1 would comprise 52 wind turbines and provide 156 megawatts (MW) of capacity. The wind turbines will be located in La Rumorosa, Mexico, and the project would extend into San Diego and Imperial Counties, connecting to the existing Southwest Powerlink at SDG&E’s planned East County Substation in Jacumba, California. The closest wind turbine to the US border would be 10 miles southeast of Jacumba. Future project phases could supply 1,000 MW of additional wind capacity.

Pending permit approvals, construction on Phase 1 would begin in 2012 and end in 2013. SDG&E underwent a competitive bid process and was awarded the Phase 1 contract with Sempra Generation. The Power Purchase Agreement (PPA) is pending approval from a California Public Utilities Commission (CPUC) appointed independent evaluator since SDG&E is an affiliate company to Sempra Generation.

The project must receive three permit approvals: a U.S. DOE Presidential Permit allowing for a cross-border power line, a Major Use Permit from the County of San Diego Major (for 0.5 miles of power line and 3 transmission towers in the U.S.), and a permit from SEMARNAT for the project in Mexico. The CPUC and Bureau of Land Management are jointly evaluating the Environmental Impact Report and Environmental Impact Statement (EIR/EIS). A Final EIR/EIS is scheduled for completion by November 2011, and a decision on the Presidential Permit is expected by December 2011. Once the final EIR/EIS is completed and approved by the CPUC, the project will go before the San Diego County Board of Supervisors for final approval.

Ms. Briggs noted that the Energia Sierra Juarez project will help SDG&E and California increase the use of renewable resources and bring both closer to meeting the 33 percent renewable energy mandate and GHG reduction goals. It will provide renewable power to the San Diego region and create 300 construction and operations jobs on both sides of the border, which includes 50-70 temporary jobs to build the power line on the U.S. side.

Mr. Crider added that there are several wind projects already built, or being developed in California, and that this project area represents the last untapped, major wind resource in the Southwest.

Chair Downey asked if there are other PPAs pending for future project phases and who else will be receiving energy from this project. Mr. Crider responded that Phase 1 is solely for the pending PPA with SDG&E. Sempra Generation has been marketing future phases to utilities in the southwest and Mexico.

Kurt Kammerer, KJK&A, asked if all the wind resources in the Boulevard area had been developed, and if Sempra Generation planned to be the developer of the remaining Energia Sierra Juarez project phases.

Mr. Crider stated that in the Boulevard area on the U.S. side of the border, several projects are in various stages of the permitting process. Additionally, there is a limit to the number of wind projects in that area given the need to avoid sensitive resources. For the additional 1000 MW capacity of future Energia Sierra Juarez project phases, Sempra Generation would be the developer and already has control of the lands through lease arrangements.

5 Chair Downey requested that SDG&E update the EWG on future project developments once the PPA is approved for this project.

ITEM #7: UPDATE ON REGIONAL ELECTRIC VEHICLE (EV) ACTIVITIES

CCSE Regional Electric Vehicle Update

Mike Ferry, CCSE, gave an update of regional electric vehicle (EV) activities. He stated that the San Diego region was leading the nation with more EVs on the road on a per capita basis. Mr. Ferry added that the work done to date should be leveraged and publicized.

As of September 21, 2011, there were 700 PEVs on the road, compared to a couple dozen earlier this year. By next year, he expects that 2,000 PEVs will be on San Diego roads. Of the 700 current vehicles, 571 were Nissan LEAFs. Ownership was geographically widespread and 32 percent also owned solar photovoltaic (PV) systems. In addition to the LEAF owners, the region has 101 Chevrolet VOLT owners and a handful of Tesla Roadster and Smart Electric Drive (ED) owners.

Pamela Bensoussan, representing the South County Economic Development Council, asked if the VOLT owners also owned PV systems. Mr. Ferry stated that currently CCSE had this data only for Nissan LEAF owners.

Mr. Ferry reviewed the importance of EVs for the region including the cost of gasoline, air quality, public health, and the need to reduce greenhouse gas (GHG) emissions from transportation. State policies have helped drive EV deployment in California, including AB 32 (Global Warming Solutions Act of 2006), SB 375 (regional GHG targets), AB 1493 (vehicle efficiency standards), the Low Carbon Fuel Standard (promoting alternative fuels) and the AB 118 Alternative Fuel/Technology Program.

Mr. Ferry discussed the California Clean Vehicle Rebate Project (CVRP), funded through the California Air Resource Board and CEC, which CCSE administers. The CVRP has provided rebates to purchasers of EVs. This rebate program is annually funded through 2015 and has increased from annual funds of $3.7 million in fiscal year (FY) 2009-2010, up to $20 million for FY 2011-2012. CCSE has processed 1,980 rebate checks and has a wait list of 1,501 applicants, 597 of which reside in the San Diego region.

While the Tesla Roadster, Nissan LEAF, and Chevrolet VOLT are currently available, more EVs will be released within the next year. Additionally, a pilot Car2Go program in San Diego will start at the end of 2011. This is the first EV car share program in the nation and first EV car share fleet of this size in the world. There will be 300 public-access share EVs available that will operate within a 33 square mile radius in the Downtown, Uptown, Midtown, Old Town, Point Loma, Ocean Beach, Pacific Beach, and Mission Valley areas. It is an on-demand, point-to-point, pay-as-you-drive, all inclusive program.

San Diego regional PEV infrastructure planning has been occurring through the DOE and CEC funded EV Project ($100 million in match funds nationwide from DOE and $8 million in CEC funds for California to Ecotality). Within San Diego, Ecotality’s goal has been to install 1000 residential Level 2 (220 volt) chargers for Nissan LEAF & Chevrolet VOLT owners, 1000 publicly accessible Level 2 chargers, and 30 DC fast chargers (480 volt). To date 580 residential and 23 public chargers have been installed with an additional 25 public stations under construction and 75 under contract.

6 Organizations interested in hosting a charging site can contact the Clean Fuels Coalition or EV Project before the end of this year to capitalize on the available funding.

Aside from the EV Project, the region is expected to receive funding from DOE and CEC to continue regional PEV planning. Through the DOE, CCSE should receive $100,000 for the California PEV Readiness Project, a one year planning grant that will start in 2012. Through the CEC, SANDAG should receive $200,000 to form a local PEV working group and prepare a regional plan for continued EV deployment.

Mr. Evans asked if natural gas fueled vehicles would be more efficient than EVs, since EVs are fueled by electricity generated from predominantly natural gas plants.

Mr. Ferry responded that CCSE had researched this issue, accounting for the losses from transmission, the types of electricity supply and methods of generation. He explained that when an EV is plugged in, it adds marginal load to generation which comes from natural gas. The argument can be made that EVs are then natural gas powered vehicles due to natural gas being burned at power plants to generate the electricity when plugged in. However, power plant efficiencies range from 20 to 55 percent. The primary factor in determining if a natural gas vehicle is more efficient than an EV is the time of day that the charging takes place. If during peak-hours in the summer, when the grid is over loaded, the marginal generation is probably going to come from a natural gas peaker plant with lower efficiencies. If charging can be pushed to off-peak periods, then the efficiency is on the side of EVs over natural gas vehicles. There are timing studies being conducted on residential charging behaviors in order to distinguish the best methods to encourage off-peak charging. Currently 90 percent of EV owners are charging during off-peak periods.

Other comments, questions, and discussion were as follows:

• Chair Downey asked what home owners who have PV systems can do if they charge at night when their systems are not generating electricity. Ms. Bensoussan added that it is counter intuitive that all charging stations are designed to function during peak-hours, and solutions on how to rectify this issue should be considered. Mr. Ferry responded that it is not known yet how public access infrastructure will be utilized, but the infrastructure being built in the San Diego region is part of a study funded by the DOE to answer these questions. There are several theories about public access for EVs based on modeling, but we are now learning what pricing signals should be set to discourage peak charging. • Mr. Mosier commented that the City of Del Mar has experienced difficulties in getting charging stations installed as the Ecotality leasing and contracting process has been slow. Mr. Ferry stated that this has been a common issue due to one Ecotality legal representative being available for contracting for the nation, but he would pass the concern along to managers at Ecotality. Mr. Mosier added that there also is uncertainty for cities as to what to do with the chargers after the two year lease arrangement. • Joel Pointon, SDG&E clarified that there are two deadlines for the EV Project, December 31, 2011, to have chargers installed, and April 30, 2013, for Ecotality to release study results on charging behavior. After April 30, 2013, Ecotality lease arrangements will end, and with the exception of DC fast chargers, property owners will gain ownership of chargers that they had installed. They also can have Ecotality remove the charger at no cost to the property owner.

7 • Chair Downey asked about the appropriate parties for seeking rebates on chargers and vehicles. Mr. Ferry clarified that the discounted price for EV chargers and their installation was through the EV Project, while the Clean Vehicle Rebate Project provided rebates for electric vehicles.

SDG&E Clean Transportation Program

Next, Joel Pointon, SDG&E, provided an overview of the SDG&E Clean Transportation Program. The program’s goal is to support the growth of electric transportation while ensuring its safe, reliable and efficient integration with the grid. The program seeks to make EV technology and infrastructure widespread and convenient, pricing attractive for charging off-peak, utility system integration efficient and smart, and to support education for market development.

Mr. Pointon explained some utility issues and activities related to EV deployment. SDG&E has entered into “notification agreements” with Nissan and GM in order to learn EV purchaser locations. There is no requirement to notify utilities about EV purchases, so purchasers have the ability to refuse releasing information about their location. This can present a critical problem for SDG&E by limiting its ability to ensure that localized distribution systems are adequate where EVs are likely to be charged. Through the notification agreements, SDG&E’s distribution improvements have kept pace in areas with EV chargers. Currently, SDG&E has received 95 to 97 percent notification from utility customers who have purchased EVs. Since utility notification is voluntary, SDG&E has become aware of at least 101 Chevrolet VOLTS purchased in the region, but opted out of notification (as of September 18, 2011).

With regard to additional EVs coming to the San Diego market, SDG&E has received notifications from several manufacturers that San Diego will be an early release market for their EVs: Mitsubishi “I”, CODA EV, Ford Focus EV, Honda Fit EV, BMW ActiveE, and Smart ED. Mr. Pointon also noted that the CODA EV will be the first EV in California to be able to charge at 6.6 kW, which will cut charging time in half. More vehicles will be available in the future with this faster charging rate, which will have more significant impacts on SDG&E distribution system.

The CPUC has required SDG&E to prepare a State of California Notification Report by December 2011, with recommendations on how the state can comprehensively accomplish a utility notification system for all PEV manufacturers coming into the market. Additionally, the CPUC has prohibited investor owned utilities from owning or installing EV supply equipment at this time.

The CPUC also gave SDG&E authorization to conduct a pricing study within the EV Project to test three experimental rates that could influence what time of day EV owners charge their vehicles. Three different price points were set for on- and off-peak charging to test whether the cost of EV charging influences when people recharge. The study rates are randomly assigned to Nissan LEAF owners who voluntarily enroll in the program. The Chevrolet VOLT will be included in the study soon. Thus far, 80 percent of EV Project participants have voluntarily enrolled in the pricing study.

Locally, Mr. Pointon has been holding monthly workshops on EV charging issues for multi-unit dwellings to understand and resolve challenges that are unique to apartment buildings, attached buildings, condos and mobile homes. SDG&E has been heading a project for the Electric Drive Transportation Association at www.GoElectricDrive.com, a virtual EV showroom. The utility also is developing a catalog of all available EVs to be categorized along with their specifications for

8 nationwide use to help support the directive from the CPUC to remain neutral in the EV marketplace.

Mr. Pointon also mentioned that he serves on committees at the Electric Power Research Institute and a standards committee for the Society of Automotive Engineers, which determines the US standards for Level 2 and DC Fast Charge connections. Mr. Pointon expects that the committee will approve a US standard for all DC fast chargers in the first quarter of 2012. Additional SDG&E EV efforts have included a Workplace Charging Workshop, connecting 180 customers to Ecotality for the EV Project, entering into a site Agreement at their Energy Innovation Center in Kearny Mesa as an EV charger host site, giving over 200 presentations at community and industry events, and growing the size of the SDG&E company EV fleet.

Ms. Freedman gave recognition to Mr. Pointon for the integral role he has been playing in the success of regional EV efforts for many years. Due to his diligence, Nissan had approached Mr. Pointon several years ago about bringing the LEAF to the San Diego region as a first market, and Mr. Pointon brought this issue to SANDAG and other regional stakeholders.

Mr. Evans asked if SDG&E had cost estimates of the required distribution system upgrades to support the future EV fleet in the region and if the scope of the upgrades was standardized. Mr. Pointon responded that SDG&E is conducting PEV impact studies to try to identify required costs and impacts of EVs on the distribution system. Additionally, an innovative smart transformer project is being developed in which the transformer itself could communicate and give updates on what the load levels are in localized areas. So far, there have been minimal impacts to load, with only one transformer upgrade made in one neighborhood. That instance was for an area that was already built out and that had already experienced increased load from other major appliances.

Mo Lahsaiezadeh, City of Oceanside, asked whether manufacturers were developing replaceable batteries for EVs. Mr. Pointon responded that there is research being conducted by groups in Israel, Denmark & Hawaii on battery replacement options.

Chair Downey requested that Mr. Pointon’s contact information be distributed:

Joel Pointon, SDG&E, Electric Transportation Program Manager, 8306 Century Park Court, CP42K San Diego, CA 92123, [email protected]

ITEM #8: ENERGY ROADMAP PROGRAM PROGRESS REPORT

Susan Freedman, SANDAG, introduced the new SDG&E local government partnership representative, Josh Brock. Ms. Freedman then provided an update on the Energy Roadmap program.

As of September 2011, the program had conducted preliminary assessments at 95 municipal sites, documented in “Energy Report Cards,” and conducted 42 more comprehensive energy assessments at a subset of municipal sites. Each identified energy use over one-year, associated costs and GHGs, and potential energy- and/or cost-saving opportunities. The findings were presented to each city’s facilities or public works department and next steps identified to implement projects. Ms. Freedman stated that, if implemented, the potential savings identified thus far included:

9 - $361,000 in annual bill savings from switching utility rates - $310,000 in annual savings from energy efficiency upgrades - 2.1 million Megawatt-hours (MWh) of electricity savings annually - 706 metric tons CO2E (greenhouse gases) annually

She continued that after energy assessments were completed at a jurisdiction, a customized Energy Roadmap report would be prepared. The Roadmap would serve as a user-friendly energy management plan that summarized the project findings and offered recommendations that could assist a jurisdiction with implementing energy-saving measures. The Roadmaps were divided into two sections and have eight chapters as follows.

Saving Energy in Local Government Operations: (1) Save Energy in City Buildings and Facilities, (2) Demonstrate Emerging Energy Technologies, (3) Green the City Vehicle Fleet, (4) Develop Employee Knowledge of Energy Efficiency, and (5) Promote Commuter Benefits to City Employees.

Saving Energy in the Community: (6) Leverage Planning and Development Authority, (7) Market Energy Programs to Local Residents, Schools, and Businesses, and (8) Support Green Jobs and Workforce Training.

The Energy Roadmaps are intended to compliment, not compete with, any existing efforts by cities. After Roadmap reports are completed, SANDAG is able to continue working with each city through the life of the grant. Currently the program runs through December 31, 2012, but the CPUC has stated its desire to continue the energy efficiency programs (including this one) through 2013.

Ms. Freedman invited Mo Lahsaiezadeh, City of Oceanside staff, to share his experiences on the Roadmap process over the past six months. Mr. Lahsaiezadeh commented that this has been a great partnership and experience. He thanked Ms. Freedman and the Roadmap team.

Chair Downey encouraged other cities to continue to share any additional information and lessons learned with the EWG in the future.

ITEM #9: ADJOURNMENT AND SCHEDULING AGENDA ITEMS FOR FUTURE MEETINGS

Chair Downey adjourned the meeting at 1:01 p.m. The next scheduled meeting is on October 27, 2011, from 11:30 a.m. to 1:00 p.m.

10 ENERGY WORKING GROUP MEETING ATTENDANCE September 22, 2011

MEMBER / REPRESENTATION JURISDICTION / ORGANIZATION NAME ATTENDING ALTERNATE

City of Coronado Hon. Carrie Downey, Chair Member YES South County Subregion City of Chula Vista Hon. Pamela Bensoussan Alternate NO

North County Coastal City of Del Mar Hon. Don Mosier Member YES Subregion City of Solana Beach Hon. Lesa Heebner Alternate NO

North County Inland City of Escondido Hon. Ed Gallo Member NO Subregion Vacant Vacant Alternate -

City of Santee Hon. Rob McNelis Member NO East County Subregion Vacant Vacant Alternate -

Hon. Sherri Lightner Member NO City of San Diego Subregion City of San Diego Hon. David Alvarez Alternate NO

County of San Diego Peter Livingston Member YES County of San Diego Subregion Vacant Alternate -

Metropolitan Transit System (MTS) Sharon Cooney Member NO Public Transit Operators North County Transit District (NCTD) Vacant Alternate -

Paul Manasjan Member YES

San Diego County Regional Airport Authority Brett Caldwell Alternate YES

Other Public Agencies Ed Gowens Alternate NO

Michelle White Member YES Unified Port of San Diego Cody Hooven Alternate NO

San Diego State University Dr. Heather Honea Member NO Universities University of California, San Diego Dave Weil Alternate YES

Matt Burkhart Member YES Energy Utility San Diego Gas & Electric Claudia Valenzuela Alternate NO

Andrew McAllister Member NO Energy Non-Profit California Center for Sustainable Energy Irene M. Stillings Alternate NO

San Diego Clean Fuels Coalition Greg Newhouse Member NO Transportation Fuels Vacant Vacant Alternate -

Energy Academics and Energy Policy Initiatives Center, Scott Anders, Vice Chair Member YES Research University of San Diego School of Law Nilmini Silva-Send Alternate NO

Laura Hunter Member NO Environmental Health Coalition Nicole Capretz Alternate NO Environment/Social Justice Bill Powers Member NO Sierra Club Carolyn Chase Alternate NO

Mike Evans Member YES

Business San Diego Regional Chamber of Commerce Mike Nagy Alternate YES

Carmen Sandoval Alternate NO

North County Economic Development Council David Lloyd Member NO Economic Development South County Economic Development Council Pamela Bensoussan Alternate YES

11 OTHER ATTENDEES: Josh Brock, SDG&E Brisha Cordella, SDG&E Elvira Felix, Consulate Coral of Mexico Mike Ferry, CCSE Michael Gervais Kurt Kammerer, KJK&A Dan King, City of Solana Beach Mo Lahsaiezadeh, City of Oceanside Elaine Lukey, City of Carlsbad Jim McCollum, Solar Turbines Joel Pointon, SDG&E Kayla Race, Environmental Health Coalition Lianna Rios, SDG&E Susan Freedman, SANDAG Katie Levy, SANDAG

12 San Diego Association of Governments REGIONAL ENERGY WORKING GROUP

November 17, 2011 AGENDA ITEM NO.: 4

Action Requested: INFORMATION

ENERGY AND CLIMATE MEASURES IN THE 2050 REGIONAL File Number 3200300 TRANSPORTATION PLAN AND SUSTAINABLE COMMUNITIES STRATEGY

Introduction

On Friday, October 28, 2011, the SANDAG Board of Directors adopted the 2050 Regional Transportation Plan (2050 RTP), a balanced vision for the evolution of our region’s transportation system over the next 40 years. Along with the 2050 RTP, the Board adopted the Sustainable Communities Strategy (SCS). The SCS details how the region will reduce greenhouse gas (GHG) emissions to state-mandated levels over time. The inclusion of the SCS is required by Senate Bill 375, and the San Diego region is the first in California to produce a regional transportation plan with an SCS.

The SCS is Chapter 3 of the SANDAG 2050 RTP, “Forging a Path Toward More Sustainable Living: A Sustainable Communities Strategy.” Of the 31 Actions identified to implement the SCS, the 13 listed in Attachment 1 correspond to efforts undertaken by the Regional Energy Working Group (EWG). These actions were part of the Regional Energy Strategy (2009), Climate Action Strategy (2010), and/or Regional Alternative Fuels, Vehicles, and Infrastructure Report (2009).

To view the adopted 2050 RTP, SCS, Environmental Impact Report, public comment record, and other relevant documents, visit the SANDAG Web site at www.sandag.org/2050rtp.

Discussion

The 2050 Plan

The 2050 RTP lays out a plan for investing an estimated $214 billion in local, state, and federal transportation funds expected to come into the region over the next 40 years. The largest proportion of the funds will go toward transit, which will receive 36 percent of the funds in the first 10 years, with 34 percent going to highway improvements (largely for the addition of high occupancy vehicle lanes to existing freeway corridors), and 21 percent to local roads and streets. The percentage dedicated to transit will grow each decade, up to 44 percent from 2021 to 2030, 47 percent in the third decade, and 57 percent in the last decade of the plan.

The 2050 RTP and SCS seek to guide the San Diego region toward a more sustainable future by integrating land use, housing, and transportation planning to create communities that are more sustainable, walkable, transit-oriented, and compact. Planning for future patterns of density, how people get around, and how land is used is really driven by one goal: creating great places to live,

13

work, and play. The path toward living more sustainably is: focus housing and job growth in urbanized areas where there are existing and planned transportation infrastructure, protect sensitive habitat and open space, invest in a transportation network that provides residents and workers with transportation options that reduce GHG emissions, and implement the Plan through incentives and collaboration.

Public Outreach

SANDAG implemented a comprehensive public outreach and involvement program to support the development of the 2050 RTP and SCS. The Public Involvement Plan (PIP) outlined specific activities for communicating with the public throughout the development of the RTP and SCS. To engage low-income and minority communities early in the planning process, SANDAG established a mini- grant program to focus on their concerns in a timely and meaningful way, and to provide resources so community collaboratives could reach out to their constituents throughout the process. The goals, strategies, and tactics outlined in the PIP have built awareness of the regional transportation planning process, and identified opportunities for stakeholders to shape our region’s future.

Energy and Climate Planning Background

The EWG developed the policy measures that became the most recent Regional Energy Strategy (2009) and the first Climate Action Strategy (2010). These strategies, along with a regional assessment of alternative fuel and infrastructure needs, served as foundations for preparation of the SCS. With assistance from the California Energy Commission, Energy Policy Initiatives Center, California Center for Sustainable Energy, and San Diego Gas & Electric; the EWG built consensus around these policy measures. These documents are available from the EWG staff contact and from the SANDAG Web site at www.sandag.org/energy.

Attachment: 1. List of Energy and Climate Actions to Implement the Sustainable Communities Strategy

Key Staff Contact: Susan Freedman, (619) 699-7387, [email protected]

14 Attachment 1

List of Energy and Climate Actions to Implement the Sustainable Communities Strategy

Actions Responsible Party

Regional Comprehensive Plan (RCP) Update 3. Refine indicators that are used to monitor progress toward SANDAG the implementation of the RCP so they include additional measures that address sustainability, greenhouse gas reductions and public health considerations. 6. Expand the smart growth strategy in the RCP to include SANDAG and local climate change principles that emphasize petroleum Jurisdictions reduction, energy efficiency, water efficiency, and renewable energy. Smart Growth Tools and Model Enhancements 7. Provide additional guidance on SB 375 CEQA streamlining SANDAG and local provisions. jurisdictions 11. Consider greenhouse gas reductions/climate change SANDAG and local principles in the evaluation criteria for existing grant jurisdictions programs, such as the Smart Growth Incentive Program. 12. Continue to make enhancements to travel demand models to SANDAG improve GHG and VMT estimates. Energy/Climate Change 19. Implement the Regional Energy Strategy and the Climate SANDAG and local Action Strategy, in coordination with state and local jurisdictions jurisdiction efforts. 20. Support the increased use of clean, alternative fuels in SANDAG and local SANDAG and local jurisdiction-owned vehicle fleets, and the jurisdictions vehicle and equipment fleets of contractors and funding recipients, such as the vehicle fleet for the SANDAG Vanpool Program or for local jurisdiction waste haulers. 21. Support planning and infrastructure development for SANDAG and local alternative fueling stations and plug-in electric vehicle (EV) jurisdictions chargers. 22. Develop or facilitate a regional approach to long-term SANDAG and local planning for alternative fuel infrastructure that includes the jurisdictions continued development of public-private strategic alliances. 23. Monitor research and independent assessments of the impact SANDAG that increasing the use of clean, alternative fuels would have on gas tax revenues. 24. Integrate alternative fuel considerations into the SANDAG, MTS, and development of the regional transportation network by, for NCTD example, integrating infrastructure for electric vehicle charging into regional park-and-ride lots and transit stations. 25. Work with San Diego Gas & Electric and other stakeholders to SANDAG and local mitigate the potential impacts of electric vehicles on the jurisdictions electric grid. 26. To the extent possible, address climate adaptation issues in SANDAG, Caltrans, and the design of new projects, and when improvements are local jurisdictions made to existing infrastructure.

15 San Diego Association of Governments REGIONAL ENERGY WORKING GROUP

November 17, 2011 AGENDA ITEM NO.: 5

Action Requested: DISCUSSION

SAN DIEGO GAS & ELECTRIC’S GENERAL RATE CASE: File Number 3200300 POTENTIAL IMPACTS TO SOLAR CUSTOMERS

Introduction

On October 3, 2011, San Diego Gas & Electric (SDG&E) filed Phase 2 of its General Rate Case (GRC) with the California Public Utilities Commission (CPUC). A GRC is typically performed every three years and provides the CPUC the opportunity to examine a utility’s operations and costs and to establish an approved revenue requirement. SDG&E’s Phase 2 addresses the allocation of charges, and includes the introduction of a “network use charge.” SDG&E’s GRC Phase 2 Application (A. 11- 10-002) is available online at www.sdge.com/regulatory/A11-10-002.shtml. It consists of 11 chapters. Chapter 1 provides a policy overview and chapter 2 provides details about the proposed network use charge.

Discussion

This agenda item will include three presentations. Staff will provide a brief overview of the SANDAG Regional Energy Strategy relative to its solar and renewable energy components. J.C. Thomas, SDG&E, will present information about SDG&E’s filing including the network use charge. Third, Andrew McAllister, California Center for Sustainable Energy (CCSE), will present information on potential rate impacts to residences, schools, and public agencies that have solar panels.

The renewable energy and distributed energy sections of the Regional Energy Strategy are provided as Attachment 1. Information sheets from SDG&E and CCSE are provided as Attachments 2 and 3.

Attachments: 1. Renewable Energy and Distributed Generation Goals from the Regional Energy Strategy 2. SDG&E Information Sheet: Building a Foundation for a Sustainable Energy Future: SDG&E’s Proposal Designed to Expand Access to Renewable Energy for Customers 3. California Center for Sustainable Energy Information Sheet: SDG&E Proposes New Rates for Solar Customers

Key Staff Contact: Susan Freedman, (619) 699-7387, [email protected]

16 Attachment 1

Renewable Energy and Distributed Generation Goals from the Regional Energy Strategy

Section 5. Regional Energy Strategy Goals Renewable Energy Goal Support the development of 5.2 Renewable Energy renewable energy resources to meet or exceed a 33 percent Introduction renewable portfolio standard (RPS) by 2020 and a 45 percent After energy efficiency and demand response, the state’s RPS by 2030. preferred loading order calls for meeting electricity needs and reducing GHG emissions with renewable resources, including onsite power systems such as photovoltaic solar panels and utility-scale electricity projects that convert solar and wind resources into electricity.

This section discusses the need to increase utility scale renewable energy projects and the potential challenges that arise, such as impacts to sensitive environmental resources and landscapes. Renewable onsite power systems, and clean, nonrenewable onsite power systems are addressed in Section 3 – Distributed Generation.

In general, renewable energy resources include:

• Wind (produced in windy locations usually at wind farms to generate electricity), • Solar (systems powered by the sun to provide heat or generate electricity including photovoltaics, concentrated solar power, and solar thermal), • Geothermal (systems using thermal energy from beneath the earth’s surface to provide heat and generate electricity), • Biogas (captured from landfills and sewage at wastewater treatment plants), • Biomass (technologies that burn primarily paper, wood, tree trimming and other similar “green” waste as fuel), • Hydro power (flowing water that drives a turbine to generate electricity), and • Offshore wave power (built along shorelines, systems extract energy in breaking waves).

The advantages of utility scale renewable energy can include lower greenhouse gas emissions, energy price stability, and ability to bring large amounts of power online quickly. Many renewables resources such as wind and geothermal are cost-competitive with fossil fuel energy sources and can be carried on existing transmission infrastructure. Renewables can also displace the need for fossil fuel-powered generation.

A mixture of utility scale renewable resources can support a stable and reliable electricity grid. Resources like biomass, geothermal, and small-scale hydroelectric generation can provide baseload power. Some renewables such as solar thermal technologies have the potential to store energy for an extended period and provide power generation into evening hours (i.e., after the sun goes down). Some renewable technologies like solar thermal may also be able to operate in a hybrid mode as typical

Excerpts from SANDAG Regional Energy Strategy 17 natural gas or biomass-fired power plant with characteristics similar to a baseload power plant. Other renewable resources are intermittent such as wind or solar. The integration of large amounts of intermittent generation into the electricity system will require grid improvements to accommodate variation in power availability and improve grid reliability such as improved communications technology, automated demand response, and other modern technologies that would be possible with a smart grid (see Section 6 for further discussion).

Key state policies related to renewable energy production include:

• Senate Bill 1078 (Sher, Chapter 516, Statutes of 2002), which establishes California’s Renewables Portfolio Standard (RPS) requiring retail sellers of electricity to procure 20 percent of retail sales from renewable energy by 2017. • Energy Action Plans I (2003) and II (2005), which recommended accelerating the RPS deadline to 20 percent by 2010, and recommended a further goal of 33 percent renewables by 2020, respectively. • Senate Bill 107 (Simitian, Chapter 464, Statutes of 2006), which accelerated the 20 percent target to 2010 and authorizes a system of tradable renewable energy credits (RECs). • Executive Order S-06-06 (2006), which established a biomass target for 20 percent within the RPS goals for 2010 and 2020. • Executive Order S-14-08 (2008), which established accelerated RPS targets (33 percent by 2020) as recommended in Energy Action Plan II. The order also called for the formation of the Renewable Energy Action Team, comprised of the Energy Commission, Department of Fish and Game, Bureau of Land Management, and U.S. Fish and Wildlife Service. Through the team, the Energy Commission and the Department of Fish and Game are to prepare a plan for renewable development in sensitive desert habitat. • Executive Order S-21-09 (2009), which directs the ARB to work with the CPUC, the California Independent System Operator (ISO), and the Energy Commission to adopt regulations increasing California’s RPS to 33 percent by 2020. ARB must adopt these regulations by July 31, 2010.

Key state policies related to renewable energy and transmission infrastructure include:

• Senate Bill 1565 (Bowen, Chapter 692, Statutes of 2004) addresses the need for an official state role in transmission planning with the passage of this bill. SB 1565 directed the Energy Commission to develop a Strategic Transmission Investment Plan (Strategic Plan), which identifies and recommends actions to stimulate transmission investments to ensure reliability, relieve congestion, and meet future growth in load and generation, including renewable resources, energy efficiency, and other demand reduction measures. • Senate Bill 1059 (Escutia and Morrow, Chapter 638, Statutes of 2006), which continued to develop an integrated, statewide approach to electric transmission planning and permitting to address the state’s critical energy and environmental policy goals. This bill provided a bridge between the transmission planning process and the permitting process by designating

Excerpts from SANDAG Regional Energy Strategy 18 transmission corridor zones on state and private lands available for future high-voltage electricity transmission projects, consistent with the state’s electricity needs identified in the IEPRs and Strategic Transmission Investment Plans.

Many state strategies and programs have been implemented to increase renewable energy generation consistent with these policies, including Energy Commission’s Renewable Energy Program, the RPS Program jointly administered by the Energy Commission and CPUC, the Renewable Energy Transmission Initiative, the Desert Renewable Energy Conservation Plan, feed-in tariffs for renewable generators, the Bioenergy Action Plan, and multiple RD&D activities.

5.2.1 Renewable Energy Credits

A system of tradable RECs could facilitate goals for increasing the amount of renewable energy. The REC is a certificate representing the environmental benefit of a given unit of renewable energy production. RECs could reward generators of renewable resources by allowing them to earn revenue from the environmental benefit of their renewable energy systems, and could provide purchasers of RECs like utilities with increased flexibility to meet legal mandates such as the RPS. The CPUC may authorize the use of RECs for RPS compliance, but has not done so as of this writing.

5.2.2 Renewable Energy in the San Diego Region

The renewable energy targets developed for the 2003 Regional Energy Strategy were considered aggressive at the time. Since then, state laws and policies have called for more aggressive targets. As discussed above, Executive Order S-21-09 requires multiple state agencies to collaborate and adopt regulations to increase the state RPS to 33 percent by 2020. The RES reflects these changes to be consistent with state policy direction by setting an increased target of 45 percent, which represents a little more than one percent supply increase each year between 2020 and 2030 (roughly consistent with the annual one percent increase required by state policy through 2020). The state does not currently set policy for the RPS beyond 2020.

Table RE-1: Renewable Energy Targets for San Diego County

Targets 2010 2020 2030 RES Targets from 2003 strategy 15% 25% 40 % RES Targets for 2009 strategy (% of sales) 20% 33% 45 %

Renewable Energy and Electricity Prices

The CPUC, Energy Commission, and other agencies are conducting financial analyses to learn the cost and benefit impacts of meeting the 33 percent renewable energy target by 2020. Initial CPUC analysis shows that electricity costs will increase in 2020, regardless of renewable resource requirements. As

Excerpts from SANDAG Regional Energy Strategy 19 shown in Table RE-2, the preliminary analysis indicates that the cost of producing statewide electricity with a 20 percent RPS in 2020 is comparable to the cost of generating the same amount of electricity with all natural gas. Achieving a 33 percent RPS by 2020, is estimated to cost approximately 7 percent more than using all natural gas generation sources.

Table RE-2: Electricity Costs in 2020 under Renewable Portfolio Standard and Natural Gas Scenarios 20% RPS 33% RPS All-Natural Gas 2008 Reference Case Reference Case Scenario in 2020 in 2020 in 2020 Total Statewide Electricity $36.8 billion $49.2 billion $50.6 billion $54.2 billion Expenditures Average Statewide $0.132 per kWh $0.154 per kWh $0.158 per kWh $0.169 per kWh Electricity Cost Source: CPUC/E3, June 2009

The all-natural gas scenario may grow more costly with passage of federal climate change laws. A greater demand for natural gas may occur in places reliant on coal. The added competition could raise prices (for example, San Diego natural gas prices are impacted by price spikes in the eastern United States) and reduce available supply. If this scenario occurs, increasing renewable energy supply may help insulate the region from higher-priced finite natural gas resources. Historical average electricity prices by customer class are shown in Table RE-3. However, natural gas prices have been volatile in recent history, and price forecasts have been highly inaccurate. See Section 7. Natural Gas Power Plants, for more discussion of natural gas prices. Renewable energy is expected to provide more price stability than more volatile natural gas.

Table RE-3: Historical Average Electricity Prices by Customer Class (in cents per kilowatt-hour) Residential Commercial Industrial Year SDG&E CA SDG&E CA SDG&E CA 1990 10.7 10.4 9.6 10.6 6.6 7.7

2000 14.1 11.5 14.5 11.5 12.0 7.9

2007 15.7 12.5 17.4 15.3 13.5 10.9 2008 15.5 12.7 16.9 15.5 12.7 11.1 Source: Energy Almanac, Energy Commission, 2009

Potential Impacts of Renewable Energy

Renewable energy can provide environmental benefits to the region by improving air and water quality and reducing GHG emissions. Adding large amounts of renewables can also present challenges. Conflicts

Excerpts from SANDAG Regional Energy Strategy 20 could arise between the broader goal of reducing GHG emissions and the specific environmental impacts of additional renewable infrastructure such as power lines to access renewable resources or renewable energy projects that could impact sensitive habitats or communities. While residents are generally supportive of renewable energy and its environmental benefits, many citizens are concerned about renewable energy projects and transmission lines because of their potential for environmental and aesthetic impacts. For example, proposed solar projects located in the California desert may impact sensitive species habitat or may require large amounts of water, while transmission lines could adversely affect sensitive environmental resources or pristine landscapes. Some desert solar technologies such as photovoltaic and dish-Stirling use little water (for cleaning only) while cooling towers could be used for solar thermal power plants to significantly reduce water use. The impacts of solar projects to the landscape can also vary significantly from major grading activity to little-to-no disturbance to the landscape. Wind projects use only a small percentage of the project site for turbines and service roads, leaving most of the site available for compatible uses.

State Initiatives are already underway to facilitate the early identification and resolution or to avoid land use and environmental constraints to promote timely development of renewable generation resources and associated transmission lines.

Even with the 45% renewables goal for 2030, dispatchable power (most likely natural gas power plants) will provide much of the power supply to the grid. This dispatchable power along with utility scale renewables to the extent they are equipped with energy storage or hybrid operating characteristics will provide stability and reliability to balance power supplied from renewables that are variable in nature, such as wind and solar. Additionally, there may be need for energy storage and other technologies to provide the kinds of services that electricity and transmission systems need to operate reliably. Although new natural gas plants are more efficient and cleaner burning than older gas plants, some of the efficiency and emission benefits may be lost if such plants are frequently ramped up and down to firm up variable renewables. Many factors will influence the mixture of renewables, fossil fuels and other sources providing power to the grid including weather conditions, load characteristics, geographic dispersion of renewables, implementation of smart grid technologies, the extent to which plug-in electric vehicles can feed power to the grid, and others.

5.2.3 Renewable Energy Transmission Initiative (RETI)

To help address potentially significant land use and environmental concerns, the state created the Renewable Energy Transmission Initiative (RETI), a statewide initiative to help identify the transmission projects needed to accommodate state renewable energy goals, support future energy policy, and facilitate transmission corridor designation and transmission and generation siting and permitting. The RETI process, which is open and collaborative so all interested parties can participate, is supervised by a coordinating committee comprised of the Energy Commission, CPUC, California ISO, and publicly owned utilities. In addition to identifying transmission corridors for renewable resources, RETI assesses all competitive renewable energy zones (CREZ) in California, and sometimes zones in neighboring states,

Excerpts from SANDAG Regional Energy Strategy 21 that can provide significant electricity to California by 2020. In addition, the federal Department of the Interior and the State of California entered into an agreement to encourage the development of environmentally-appropriate renewable energy on federal lands in the state. Major provisions of the agreement include developing a strategy to identify areas suitable and acceptable for renewable energy development, including renewable energy zones, based on criteria such as renewable energy development potential and wildlife and conservation criteria.

RETI has identified and prioritized preferred renewable resource development areas and associated transmission line links to deliver renewable power to load centers. The RETI Phase 2A Report prioritizes transmission projects to interconnect renewables that are identified as in the state’s best interests. It also forms the basis for a draft method for identifying which of the RETI line segments should be considered for corridor designation in the Energy Commission’s corridor designation process.

In addition, to help address potential impacts of new renewable power plants and related transmission lines, the Energy Commission and California Department of Fish and Game are implementing Governor Schwarzenegger’s Executive Order S-14-08, which establishes a process to conserve natural resources while expediting the permitting of renewable energy power plants and transmission lines. The primary objectives are to identify and establish areas for potential renewable energy development and conservation areas in the Colorado and Mojave deserts to help reduce the time and uncertainty associated with licensing new renewable projects on state and federal lands.

The criteria used in this process or the RETI process to balance the objectives of renewable energy development and environmental conservation could be used to guide regional decision-making in situations where these objectives may coincide in the San Diego region.

5.2.4 Barriers to Renewable Energy Development

In order to reach the renewable energy targets, certain permitting barriers must be addressed. Renewable generation facilities must receive a site permit in order to construct a project. The California Energy Commission is responsible for approving permits for thermal power plants 50 megawatts and greater. All other projects must receive a county or city permit. Projects on federal land also must receive permits from the appropriate federal agencies, usually the Bureau of Land Management or the United States Forest Service. Most renewable facilities in California require permits from federal and state agencies since renewable resources often are located on lands within federal and state jurisdiction. In recent years, permitting entities have been inundated with applications for new renewable energy facilities, causing project delays. Governor’s Executive Order S-14-08, discussed previously, seeks to remove permitting barriers to renewable energy projects. The Energy Commission and Department of Fish and Game also adopted a one-stop permitting process to streamline the process, which has generally reduced application times by half.

Excerpts from SANDAG Regional Energy Strategy 22 Many renewable electrical generation facilities need to be located near the site where geothermal, wind, and solar resources are available, and therefore need new transmission lines to connect to existing transmission infrastructure. New transmission lines often require lengthy permitting processes and, as discussed above, can have the potential to result in significant adverse impacts to conservation areas and landscapes. These factors may impede the development of renewable resources. Potential adverse impacts will need to be weighed against positive impacts such as lower GHG emissions, price stability, and improved air quality.

Connecting to the electricity grid to supply clean power to resource load centers like the San Diego region is generally cost prohibitive for a single renewable energy project. Since multiple renewable projects are often located within a renewable resource area, California ISO is developing a framework for multiple projects within a transmission constrained renewable resource area to share the costs of connecting to the grid. The magnitude and scale of infrastructure necessary for California to meet the 33 percent target for 2020 has never before been planned, permitted, procured, developed, and integrated in such a short time horizon. The CPUC identified several measures that must be implemented in the near term if achieving a 33 percent RPS by 2020 is to be a top priority, including:

• Planning now for adequate transmission and generation capacity to meet long-term needs for increased generation from renewable energy sources. • Procuring electricity from resources that are not dependent on new transmission such as distributed solar photovoltaics. • Concentrating renewable development in pre-permitted land that could be set aside for a renewable energy park.

5.2.5 Recommended Actions to Support Renewable Energy

SANDAG, local governments, or other regional entities can undertake the following actions to support the development of renewable energy. In some cases, active collaboration among multiple jurisdictions will be needed to implement the recommended actions. The following recommended actions will contribute to other energy goals, and likewise be enhanced by recommended actions identified in other topic areas, as described below.

Recommended Actions to Promote Renewable Energy SANDAG, Local Governments, Recommended Action or other Regional Entities Identify potential locations in the region that could accommodate utility-scale renewable RE-1 energy infrastructure. RE-2 Explore options to pre-permit zones of appropriate land for renewable energy development. Identify existing barriers to siting large-scale renewable energy installations (e.g., renewable RE-3 energy parks) in the San Diego region.

Excerpts from SANDAG Regional Energy Strategy 23 Support cost-effective transmission access and related infrastructure that will help the region RE-4 meet or exceed requirements for procuring electricity from renewable resources while protecting environmental and other resources. Monitor the Renewable Energy Transmission Initiative (RETI) and related state efforts and RE-5 consider its recommendations in future regional planning.

5.3 Distributed Generation Distributed Generation Goal Introduction Increase the total amount of clean distributed generation After energy efficiency and demand response, increased (renewable and non-renewable) use of renewables and distributed generation systems is to reduce peak demand and the preferred strategy for meeting the state’s GHG diversify electricity resources in the San Diego region. reduction goals while satisfying demand for energy. Distributed energy systems are complementary to traditional electric power systems, and include small- scale power generation technologies such as photovoltaics, small wind turbines, and cogeneration systems located close to where energy is being used. The advantages of distributed energy systems include increased grid reliability, energy price stability, and reduced GHG emissions. The following state policies encourage the use of distributed generation systems:

• Assembly Bill 1969 (Yee, Chapter 731, Statutes of 2006) authorized feed-in tariffs for small renewable generators of less than 1 MW at public water and wastewater treatment facilities. In July 2007, the CPUC (D. 07-07-027) implemented AB 1969 and expanded the feed-in tariffs to 1.5 MW and included non-water customers in the PG&E and SCE territories (SDG&E territory was included by later legislation). The power sold to the utilities under feed-in tariffs can be applied towards the state’s RPS targets. • Assembly Bill 2466 (Laird) Government Renewable Energy Producers, which authorizes a city, county (whether general law or chartered), special district, school district, political subdivision, or other local public agency, if authorized by law to generate electricity to receive a bill of credit to a designated benefiting account for electricity exported to the electric grid by an eligible renewable generating facility. Additionally, the bill requires the CA Public Utilities Commission to adopt a rate tariff for the benefiting account. • Assembly Bill 811 (Levine) Public Financing Districts For Energy Improvements, which authorizes a legislative body of any city to determine that it would be in the public interest to designate an area within which authorized city officials and free and willing property owners may enter into contractual assessments to finance the installation of distributed generation renewable energy sources or energy efficiency improvements that are permanently fixed to real property, as specified. The bill would require the resolution of intention to include the kinds of distributed generation renewable energy sources or energy efficiency improvements that may be financed as well as a statement specifying that it is in the public interest to finance those distributed generation renewable energy sources or energy efficiency improvements.

Excerpts from SANDAG Regional Energy Strategy 24 • Assembly Bill 920 (Huffman) Credit For Net Surplus Electricity From Solar And Wind Distributed Generation, which among other things would: require the ratemaking authority of an electric utility to adopt, by January 1, 2011, a net surplus electricity compensation valuation to compensate a net surplus customer-generator, for the value of net surplus electricity generated by an eligible customer-generator and delivered to the grid that is in excess of the amount of electricity that is delivered from the grid to the eligible customer-generator; require the electric utility to offer a standard contract or tariff to eligible customer-generators that includes compensation for the value of net surplus electricity; require the electric utility, upon an affirmative election by the eligible customer-generator to receive service pursuant to this contract or tariff, to either: (1) provide net surplus electricity compensation for any net surplus electricity generated in the 12-month period, or (2) allow the eligible customer-generator to apply the net surplus electricity as a credit for kilowatt-hours subsequently supplied by the electric utility to the surplus customer-generator; provide that upon adoption of the net surplus electricity compensation rate and the eligible customer-generator electing to receive net surplus electricity compensation, any renewable energy credit, for net surplus electricity belongs to the electric utility purchasing the electricity and that net surplus electricity counts toward the electric utility's renewables portfolio standard purchasing requirements. • Senate Bill 412 (Kehoe) Self-Generation Incentive Program: Inclusion Of Non-Solar Technologies, which would require the CPUC to require the collection of funding for the self-generation incentive program for non-solar distributed generation resources through December 31, 2011; require that combined heat and power units meet certain efficiency and emissions requirements, including the greenhouse gases emission performance standard, to receive incentives; require the PUC to ensure that distributed generation resources are made available in the program for all ratepayers; prohibit recovery of the costs of the program from ratepayers that participate in the California Alternative Rates for Energy (CARE) program; delete the authorization for the PUC, in administering the program, to include other ultra-clean and low- emission distributed generation technologies; and, delete the current requirement that the CA Energy Commission, by November 1, 2008, and in consultation with the PUC and CA Air Resources Board, to evaluate the costs and benefits of providing ratepayer subsidies for renewable and fossil fuel ultra-clean and low-emission distributed generation. • Senate Bill 380 (Kehoe, Chapter 544, Statutes of 2008) codified CPUC’s expanded feed-in tariff to include all RPS-eligible generators 1.5 MW and below. The program cap was also expanded from 250 MW to 500 MW. SB 380 expanded the program to include all investor-owned utilities including SDG&E. • Assembly Bill 1613 (Blakeslee, Chapter 713, Statutes of 2007), also known as the Waste Heat and Carbon Emissions Reduction Act, was designed to encourage the development of new combined heat and power (CHP) systems in California with a generating capacity of up to 20 MW, resulting in more efficient use of natural gas and reduced GHG emissions. The bill requires the CPUC and the Energy Commission to establish policies and procedures for the purchase of electricity from eligible CHP systems.

Excerpts from SANDAG Regional Energy Strategy 25 • The California ARB Climate Change Scoping Plan set a target of 4,000 MW of CHP that would displace 30,000 gigawatt hours of electric energy from other power generation resources with the overall goal of reducing GHG emissions by 6.7 million metric tons of CO2 equivalent. • Senate Bill 1 (Murray, Chapter 132, Statutes of 2006) enacted the Governor’s “Million Solar Roofs” program with the overall goal of installing 3,000 MW of solar PV systems.

To implement SB 1, the state officially launched Go Solar California in 2007 to bring customer awareness to the CPUC California Solar Initiative (CSI) and the Energy Commission New Solar Homes Partnership (NSHP), and solar incentive programs offered by publicly-owned utilities beginning in 2008. The CSI offers rebates to existing homes and non-residential energy customers installing solar systems in IOU service territories. As of June 2009, 226 MW of new solar systems were installed as a result of the program. When fully implemented in 2016, the CSI program is expected to provide incentives for about 165 MW of photovoltaics in the San Diego region.

The NSHP offers incentives for home builders to construct solar homes. The goals of the program are to achieve 400 MW of installed solar capacity by the end of 2016, create a self-sustaining solar market without the need for government incentives, and foster sufficient market penetration in the new residential market so that 50 percent or more of new housing built by 2016 and thereafter will include solar systems. However, with the recent extreme downturn in new home construction, program activity has been slow and is likely to remain so until if and when the economy recovers. The NSHP does not allocate available funding on a regional basis, so it is not possible to project the amount of photovoltaics that will be installed in the region as a result of the program.

Another customer-side strategy is the Self-Generation Incentive Program, which is administered by the CPUC and implemented through the IOUs and provides rebates for customers who install wind turbines and fuel cells. SB 412 (Statutes of 2009) revises this program to provide incentives for certain non- renewable distributed generation systems. The program originally included microturbines, small gas turbines, wind turbines, solar photovoltaics, fuel cells, and internal combustion engines, but as of January 1, 2008, only fuel cells and wind energy technologies are eligible. As of December 2008, the IOUs have paid more than $600 million in rebates for more than 1,200 projects totaling more than 337 MW of generating capacity. The Energy Commission administers a similar program also limited to wind turbines and fuel cells, the Emerging Renewables Program.

5.3.1 Feed-in Tariff

The feed-in tariff is intended to help contribute to the state RPS and encourage customers to install renewable energy systems to help meet the state RPS goals. Some smaller renewable energy systems are able to be counted toward the RPS due to the state feed-in-tariff. Feed-in tariffs are fixed, long-term prices for energy. The law initially supported deployment of renewable resources on publicly owned water and wastewater treatment facilities.

Excerpts from SANDAG Regional Energy Strategy 26 The California feed-in tariff was amended by Senate Bill 32 (Statutes of 2009), and must be implemented through regulations to be developed by the CPUC. SB 32 allows eligible customer-generators in the residential, commercial, and industrial sectors to enter into 10-, 15-, or 20-year standard contracts with their utilities to sell electricity produced by small renewable energy systems, up to 3 megawatts (MW), at time-differentiated market-based prices determined by the CPUC’s market price referent (MPR), which is an administratively determined rate based on the cost of natural gas generated electricity. Eligible technologies include solar thermal and photovoltaic, landfill gas, wind, small hydroelectric, among others.

Time-of-use adjustments will be applied by each utility and will reflect the increased value of the electricity to the utility during peak periods and its lesser value during off-peak periods. Power produced during peak demand times earns the highest rate. Power purchased under the feed-in tariff counts toward the utility’s RPS obligations, and renewable energy credits (RECs) (discussed below) transfer to the utility under a feed-in tariff contract. The tariff is available until installed generation equals 750 MW, a portion for which each utility is responsible. Any customer-generator who sells power to the utility under this tariff may not participate in other state incentive programs.

5.3.2 Net Metering

Net metering is another strategy to help increase customer-side distributed generation technologies, particularly PV. Customers who install an on-site renewable energy system can apply for net metering, a special billing arrangement with the utility for electric customers who generate their own electricity. Net metering allows for the flow of electricity both to and from the customer – typically through a single, bi-directional meter. When a customer’s generation exceeds the customer’s use, electricity flows back to the grid and offsets electricity consumed at a different time. In effect, the customer uses excess generation to offset electricity that the customer otherwise would have to purchase at the utility’s full retail rate. Unlike the feed-in tariff, net metering does not involve long-term agreements or prevent the customer from taking advantage of incentives prohibited under the feed-in tariff. The customer’s electric meter tracks electricity generated by the renewable system versus electricity consumed, with the customer paying only for the net amount taken from the grid over a 12-month period.

California’s net-metering law requires investor-owned utilities like SDG&E to offer net metering to all customers for solar, wind, biogas-electric, and fuel cell systems up to 1 MW. Net excess generation (NEG) is carried forward to a customer’s next bill. Previous law granted NEG remaining at the end of each 12-month period accrue to the customer’s utility. Assembly Bill 920 (Statutes of 2009) now gives customers the option of rolling over remaining NEG from month-to-month indefinitely or receiving financial compensation from the utility for their remaining NEG. Customers not electing either option will have their NEG granted to the utility at the end of the 12 month period without any compensation. The renewable energy credits (RECs) associated with the electricity produced and used on-site remain with the customer-generator. If, however, the customer chooses to receive financial compensation for

Excerpts from SANDAG Regional Energy Strategy 27 the NEG remaining after a 12-month period, the utility will be granted the RECs associated with just the surplus they purchase. The utility can take credit for the surplus purchased under the RPS.

5.3.3 Interconnection Policies

Interconnection policies can be a barrier to increased use of distributed generation (further defined below). California applies a standard practice for interconnecting distributed generation systems to the electric grid (Rule 21). Non-standardized interconnection rules create uncertainty and risk for customers interested in using distributed generation technologies and can make this option cost prohibitive. Rule 21 specifies standard interconnection, operating, and metering requirements for specified distributed generation generators.

5.3.4 Distributed Generation in the San Diego Region

For purposes of this strategy, clean distributed generation is small-scale power generation technologies located close to the load being served, capable of lowering costs, improving reliability, reducing emissions and expanding energy options. Combining energy efficiency measures with distributed generation is the best way to reduce a customer’s energy demand, thereby properly sizing the distributed system and generally saving the customer the costs of a larger system.

Table DG-1 presents quantified goals for distributed generation technology penetration through 2030 building on several California mandates and recommendations. These market projections were developed for SANDAG by the California Center for Sustainable Energy.

Table DG-1: Distributed Generation Targets for 2030 Technology 2008 Level 2030 Base Targets 2030 Stretch Targets Biogas/Biomass 26 MW 27 MW 31 MW Solar photovoltaics 49 MW 844 MW 970 MW Combined heat and power 341 MW 398 MW 458 MW Other (hydro & steam) 11 MW 11 MW 11 MW Total Distributed Generation 427 MW 1,278 MW 1,590 MW in the Region Proportion of Regional Peak Demand Targets from 2003 Strategy 12% (2010) 30% 30% Targets for 2009 Strategy 9% (actual) 21% 24% Source: California Center for Sustainable Energy, 2009

5.3.5 Solar Photovoltaic Systems

Using the Energy Commission Distributed Generation Roadmap, CCSE projects that the amount of solar photovoltaics could increase from 49 MW in 2008 to a base target of 844 MW in 2030. With additional measures, the region could achieve a stretch target of 970 MW. In the San Diego region, solar PV

Excerpts from SANDAG Regional Energy Strategy 28 systems have the greatest growth potential among DG technologies. Several regional resources are available that help enable residents to install solar. The City of San Diego partnered with the California Center for Sustainable Energy (CCSE) to develop an interactive solar mapping tool. The Solar Map identifies solar systems installed in the region and can help a resident determine their own rooftop's viability for solar panels.

Moreover, CCSE manages the California Solar Initiative incentive program for the region and hosts an annual Solar Energy Week including a Solar Homes Tour and Commercial Solar Sites Tour. In the 2009 Environment California report, California’s Solar Cities, the City of San Diego was ranked the number one solar city in California, with the most solar roofs and the highest solar capacity kilowatts installed.

5.3.6 Combined Heat and Power Systems

Using the Energy Commission Distributed Generation Roadmap, CCSE projects that the amount of combined heat and power (CHP) (also known as cogeneration) could increase from 341 MW in 2008 to a base target of 398 MW in 2030. With additional measures, the region could achieve a stretch target of 458 MW. CHP efficiently converts natural gas to energy by recycling otherwise wasted heat and reusing it for additional electricity or heating and cooling. These systems also can operate on renewable fuels such as biogas. Technologies typically used on a CHP configuration include microturbines, internal combustion engines and fuel cells.

CHP can provide a variety of benefits to end users. Customers that need greater reliability than what the electric grid can supply can use CHP systems. Biotech firms, data centers, telecommunications, and industrial processes are some of the business types that cannot afford power interruptions. CHP can provide premium power onsite, offering end users a higher level of reliability than the electric grid. CHP is often used in industrial processes that take advantage of the electricity and heat. The relatively small amount of industry and manufacturing in the region limits the potential applications for CHP systems.

5.3.7 Distributed Generation System Costs

Although the lifecycle costs of distributed generation systems make them a good choice for many end users, the upfront capital costs can be a barrier to their increased penetration. California offers many financial incentives (e.g. the California Solar Initiative, New Solar Homes Program, and Self Generation Incentive Program) to help defray the costs for new and existing buildings. Some local governments and large businesses use third party energy providers that can cover the upfront cost of a system through a long-term contract with the jurisdiction.

Since there are a variety of distributed generation systems, customers are able to choose the technology that best serves their needs. Distributed generation also benefits the utility by reducing peak demand on the electric grid and benefits businesses by reducing costs associated with peak demand charges. In power constrained areas where outages are common, distributed generation can serve to provide reliable power.

Excerpts from SANDAG Regional Energy Strategy 29 Advanced energy storage (AES) is a distributed energy system that is expected to perform an integral role in future increased use of renewable energy and in improving grid reliability. AES is a technology that converts electricity into another form of energy, stores it, and then converts it back into electricity at another time. By storing energy that can be used or dispatched at a time when it is more useful to the overall electric grid, AES can help make electricity from intermittent resources such as solar and wind more usable to the electricity system. Similarly, AES also can reduce peak demand and save money by storing electricity for use when grid-based electricity is most expensive (e.g., during periods of peak demand).

5.3.8 Recommended Actions to Support Distributed Generation

SANDAG, local governments, or other regional entities can undertake the following actions to encourage an increase in clean distributed generation. In some cases, active collaboration among multiple jurisdictions will be needed to implement the recommended actions. The following recommended actions will contribute to other energy goals, and likewise be enhanced by recommended actions identified in other topic areas, as described below.

Recommended Actions to Support Distributed Generation Local Governments Recommended Action Revise, or support revision of, local zoning policies, homeowner association codes, and other codes DG-1 to remove hindrances and promote installation of PV or other distributed renewable energy systems (e.g., require or provide incentives for new construction to pre-wire for PV installation). Explore opportunities and applications for local governments to demonstrate and deploy advanced DG-2 energy storage with distributed generation technologies. SANDAG, Local Governments, or other Recommended Action Regional Entities Combine energy assessments and energy efficiency improvements with installation of distributed DG-3 energy generation systems to reduce system costs and maximize energy savings. Establish financing programs (using public or private sources) that residents and businesses can DG-4 access to install distributed energy systems such as PV and combined heat and power systems as well as conduct energy assessments and make energy efficiency retrofits to existing buildings. Continue to monitor and support a feed-in-tariff or other policies that will facilitate increased, cost- DG-5 effective installation of small-scale renewable energy systems like solar photovoltaics. Identify local barriers to DG installations and provide supportable and applicable solutions across DG-6 jurisdictions to reduce confusion for builders, contractors, and officials, about technologies, costs and benefits. DG-7 Conduct analysis of potential applications for CHP systems in the region (e.g., industrial, hotel, etc.). Promote the use of high efficiency distributed generation technologies like combined heat and DG-8 power. Encourage local home builders to participate in the New Solar Homes Partnership to install solar DG-9 photovoltaics on new homes in the region.

Excerpts from SANDAG Regional Energy Strategy 30 Attachment 2

Building a Foundation for a Sustainable Energy Future SDG&E’s Proposal Designed to Expand Access to Renewable Energy for Customers

Background On Oct. 3, 2011, San Diego Gas & Electric (SDG&E) filed its General Rate Case (GRC) Phase 2 with the California Public Utilities Commission. The GRC Phase 2 is a proposal that sets the way electric rates are applied to all customers, including residential, commercial, and industrial. In a separate application, to be filed later in October of this year, SDG&E will propose a new community solar program called “Share the Sun,” which will enable all customers to access solar power from projects located within SDG&E’s service territory. SDG&E’s proposals are designed to help build a foundation for a sustainable and clean energy future.

These proposals are designed to promote fairness, ensure a smooth transition toward a sustainable energy future, and to help achieve low carbon policy goals outlined by the State of California. Due to the increased usage of new technology (such as solar panels, plug-in vehicles and fuel cells), customers are changing the way they use electricity infrastructure. To fully realize the promise of these technologies, SDG&E has proposed new rate designs to accommodate and promote these opportunities and choices for customers.

Customer benefits 1. Increased fairness, accuracy and energy conservation, ensuring that all customers pay their fair share of energy costs. 2. Enhanced choices and control over their energy use. 3. Improved access to solar power, through the Share the Sun Program, allowing customers to receive up to 100 percent of their energy from renewable power.

Collaborative discussion Stakeholder feedback is an essential part of this proposal, as SDG&E intends to make this effort a collaborative process from start to finish. The initial outreach to stakeholders included representatives of senior groups, affordable housing advocates, environmental organizations, taxpayer groups, minority groups, civic and business leaders, renewable energy companies and associations, state and local governments and consumer advocates. SDG&E will continue to work closely with customers, stakeholders, community-based organizations and employees to ensure customers not only are prepared for this change, but also have the necessary tools and information to make informed energy choices.

31 Changing the rate design A number of changes in the current rate structure are proposed to ensure fairness and greater transparency. They’re designed so customers “get what they pay for, and pay for what they get.” Today, most residential customers pay a “bundled” rate for electricity. These proposed changes do not increase the overall amount of revenue collected; they simply show more clearly what customers are paying for:

• Replace the minimum bill charge of Current Proposed Basic Service Fee $5.10 per month with a $3 Basic Service Fee. The basic service fee is not an additional charge. The cost will be Network covered by reducing Tier 1 rates. This Electricity Use Charge Usage (distribution basic fee covers such things as SDG&E’s (includes transmission, infrastructure) some distribution round-the-clock Customer Call Center, and energy) electric troubleshooters, and monthly billing services. Public Purpose Programs • Establish a Network Use Charge to recover the cost of distribution Residential Tiered Residential Tiered infrastructure. All customers Rate Structure Rate Structure would see this charge applied as a Tier 4 monthly average of their “demand” $0.31 on SDG&E’s system, which reflects 600 kWh Tier 3 $0.26 not how much electricity they Tier 3 $0.29 use, but how and when they use 400 kWh 400 kWh it. It would also apply to customers Tier 2 Tier 2 sending electricity to the grid $0.16 $0.11 and redelivered at a later time. 300 kWh 300 kWh The network use charge will be Tier 1 Tier 1 $0.14 $0.08 established by reducing the tiered rates to offset bill impacts for Illustrative purposes only residential customers.

• Promote super off-peak use of electricity by providing an optional exemption to the Network Use Charge for electric vehicles when charging at night between midnight and 5am.

• Simplify the rate structure by reducing the number of tiers from four to three, by combining Tiers 3 and 4 into a single tier.

Next steps The proposed changes would be phased in over the next couple of years to ensure a smooth transition and avoid major bill impacts:

Dec. 2012 Approval of proposed changes in rate design (GRC Phase 2) 2013 Basic Service Fee implemented Educate customers about billing changes 2014 50% of the Network Use Charge introduced 2015 100% of the Network Use Charge in effect 32 Attachment 3

SDG&E Proposes New Rates for Solar Customers San Diego Gas & Electric ( SDG&E) has filed their 2012 General Rate Case, which upon approval by the California Public Utilities Commission ( CPUC), will determine its rates and tariffs for 2012-2015. This is a regular and regulated process that all investor-owned utilities in California must do every three to four years to, as the San Diego Union Tribune states, “make their case for how much money they need to operate safely and reliably, while still earning a profit for shareholders.” The rate case is divided into phases and is currently in hearings for phase one, which addresses proposed increases in pricing. You can find out more about the proposed increases from the Division of Ratepayer Advocates at the CPUC and from local news sources, including the U-T article quoted above. Phase two of the rate case addresses allocation of charges (as opposed to increases addressed in phase one) and was filed October 2, 2011 with responses due November 2, 2011.You can find related documents here. Though they’re not defined as rate increases, the changes SDG&E propose could have significant impacts for their solar customers, and could set a precedent for solar customers in other locales if they are approved. The most notable of these is a “network use charge” SDG&E is proposing for all customers. $347 Annual Increase for What is the network use charge? $800 Typical Solar Home Utility electricity bill charges are derived from $700 two rate categories: energy consumption and $347 $600 Added Costs of distribution. Proposed Rate Currently, people who generate solar power are $500 Design billed on the cost of energy they draw from SDG&E $400 and credited the value of the solar energy they put back into the grid. Generally, solar customers $300 $371 meet their electricity demand first with the power they generate through their solar systems. When $200 Today’s they make more electricity than they need, they Annual Cost put it into the grid and receive credit on their bill. $100 When they need more electricity than their system generates or the sun is down, they draw it from the $0 grid like everyone else. With the proposed network use charge, solar customers would not only be Residential Solar Customer Profile charged for the energy they use from the grid, they • Applicable utility rate is SDG&E’s DR tariff would additionally be charged for the energy they • New rate structure in full effect by 2015. Chart shows 2015 impacts. put on the grid for others to use. • Average solar home where 10,300 kWh consumed annually • 4 kW-AC solar photovoltaic system offsets 75% of annual kWh consumption

What is the potential impact of the network use charge? • Solar homeowners who generate enough energy to cover the majority of their household consumption could see their SDG&E bills increase by between $10 and $40 per month. • The proposed residential increase may not seem like much, but it could be enough to significantly reduce the value proposition for future solar buyers and could stifle San Diego’s burgeoning solar marketplace, harming small businesses and the local jobs they have created. • When residents install solar, it means more clean energy available close to where people are using it, reducing the need for utilities to source energy elsewhere and to carry it long distances. Charging customers to put solar into the grid undervalues the clean energy investments made by San Diego’s innovative homeowners, business leaders and civic institutions who have responded to calls for state leadership to embrace solar.

33 8690 Balboa Ave., Suite 100 San Diego, CA 92123 www.energycenter.org (866) SDENERGY (733-6374) Hours: 8 a.m. - 5 p.m., Monday–Friday • Although SDG&E has made some adjustments to the charge for schools, our $122,400 Increase for Water District initial analysis indicates the greatest impact O setting >90% of Energy with Solar will likely be on municipalities, public $200,000 agencies and local businesses that have $180,000 invested in solar. For example, a water district $160,000 that is offsetting over 90 percent of its utility $122,400 bill with solar energy production will see $140,000 Added Costs of their current annual costs increase by over $120,000 $120,000, or over 300 percent. Proposed Rate $100,000 Design in 2014 What else in this new rate case concerns CCSE? $80,000 $60,000 Although SDG&E has allowed schools an exemption to the network use charge, their $40,000 $50,600 Today’s proposed rates would still hurt the 109 San Diego $20,000 Annual Cost County schools that have already invested in solar $0 projects, raising total annual energy costs at those facilities by an additional $1 million to $3 million. Local Government Customer Profile • Applicable utility rate is SDG&E’s DG-R tariff What is CCSE doing to assess the proposed new • New rate structure in full effect by 2014. Chart shows 2014 impacts. charges? • 1,050,000 annual kWh consumed and MAX annual demand of 750 kW • 500 kW-AC solar photovoltaic system offsets 93% of annual kWh consumption 1. CCSE has asked SDG&E to share with us and other local solar stakeholders the data they have on solar generation, use patterns and utility cost impacts. $8,100 Annual Increase for Typical Elementary School 2. CCSE is collaborating with the local solar $20,000 industry, municipalities and others to continue to analyze potential impacts of the new rate $18,000 $8,100 structure on existing solar users, the future of the $16,000 Added Costs of solar industry and the state’s ability to achieve Proposed Rate stated goals for renewable energy generation and $14,000 Design energy efficiency. $12,000 3. CCSE will work with local stakeholders to $10,000 $10,904 share our concern over these proposed rate hikes $8,000 with the CPUC and continue to support policies that help the state meet its goals for reduced $6,000 Today’s Annual Cost fossil fuel dependence, fewer greenhouse gas $4,000 emissions and cleaner air quality. $2,000 Rate cases take months to move through the public process. A decision on this phase is not $0 expected until August and would not be in effect until January 2013. We will continue to monitor Elementary Solar Customer Profile the discussion and update our website as we learn • Applicable utility rate is SDG&E’s DG-R tariff more. In the meantime, we seek your comments • New rate structure in full effect by 2014. Chart shows 2014 impacts. • 170,000 annual kWh consumed and MAX annual demand of 163 kW on this proposed network use charge, and • 61 kW-AC solar photovoltaic system offsets 90% of annual kWh consumption encourage you to share your ideas for how SDG&E might rethink their approach to solar in this and future rate planning.

34 8690 Balboa Ave., Suite 100 San Diego, CA 92123 www.energycenter.org (866) SDENERGY (733-6374) Hours: 8 a.m. - 5 p.m., Monday–Friday