PLATFORM: RENEWABLE POWER TO THE PEOPLE

A DEMAND FOR CHANGE IN OUR DAMAGING RENEWABLE-ENERGY TRAJECTORY

September 2011

Whereas,

We must take rapid, effective, innovative action to change the ways we generate and use energy;

Renewable energy is  ubiquitous, offering  a new model of energy generation that is local, democratic and freefrom the abuses of a centralized monopoly;

The US government’s current renewable-energy policy pushes industrial solar development onto public lands;

This industrial development is proposed for hundreds of thousands, possibly millions, of acres of our public lands—much of that acreage consisting of intact ecosystems which provide habitat for rare (and even endangered)plants and animals, sequester carbon, and offer the chance for ecosystem adaptation to climate change;

The utility-scale solar generating plants now proposed, most with footprints of thousands of acres, wouldtransform these ecologically-rich, multiple-use lands to single use industrial facilities, in effect privatizing vastareas of public lands;

Once developed, those lands cannot be returned to their previous state after the life of a project–conversion istotal and permanent, even though most such projects will generate power for only 30-50 years;

The thousands of miles of new transmission infrastructure necessary to carry power from remote desert solarelectric generating plants to urban demand centers drastically   inflates the cost of renewable energy, whileimposing its own serious environmental impacts;

The federal government has provided billions of taxpayer dollars in grants and loan guarantees for remoteindustrial-scale solar development to many of the same corporations that have dominated the Fossil Fuel Eraand helped hasten the recession;

The Environmental Protection Agency's “Re-Powering America’s Lands” program has identified 15 millionacres of degraded or contaminated land potentially suitable for renewable energy development, completelynegating any need to use undeveloped land, and;

Distributed generation—point-of-use energy generation on rooftops, in parking lots and highway medians, andthroughout the built environment—is a cost-effective, efficient, clean, and democratic strategy that would servecommunities, ratepayers, and taxpayers  with far less environmental impact than industrial-scale solar power onintact ecosystems, while making our electrical power grid far less prone to catastrophic failure;

Therefore, we demand:

That the Federal government abandon its current path of industrialization and destruction of our public lands;

That any large-scale solar installations be restricted to degraded, contaminated, or already-developed lands,including those identified by the EPA;

That government facilitate a massive deployment of point-of-use solar power, creating clean energy, adding tohome values, and creating millions of local jobs;

That no new large, long-distance electrical transmission projects be approved to serve remote solar projects until distributed power generation is maximized;

That the Federal Housing Finance Agency immediately lift the freeze on property assessed clean energy (PACE)loans, which encourage home energy retrofits and generate employment;

That federal funding and other incentives be made available to help states establish and expand Feed in Tariffs(FITs) and net metering, and that Congress work to establish FITs and net metering at a national scale.

Efficiency and Distributed Renewable Generation as the Centerpiece of Energy Policy

Solar Done Right March 2019

Download the PDF below:

Introduction

With state Renewable Portfolio Standards (RPSs) set to increase, conserving our public lands while increasing Distributed Energy Resources—such as rooftop solar systems, parking lot shade structure photovoltaic systems, local distributed battery storage, smart microgrids, and other advanced local renewable energy systems in the built environment becomes ever more important. 

Solar Done Right is a think-tank about distributed renewable energy policy, that includes engineers, solar advocates, rooftop-solar generators, attorneys, and conservation biologists. 

It is a widely held misconception that point-of use distributed solar generation such as rooftop solar (DG) is too expensive, too slow to implement, or otherwise inadequate to meet the current renewable energy needs of our country and that remote concentrating solar power (CSP) plants should be the solar centerpiece of any renewable energy policy.  Indeed, the California Energy Commission has said in its Staff Assessments of various projects[1] that, although such projects will cause substantial and unmitigatable harm to huge swaths of our remaining intact desert landscapes, all the rules normally restricting such immense harm should be overridden because of the urgency of greenhouse gas (GHG) reductions and meeting California’s RPS.

Setting aside the entirely unproven premise that CSP power plants and their new transmission will result in substantial net cradle-to-grave GHG emission reductions when compared to the alternatives (existing natural gas or in-city photovoltaics), with the right policies in place, our ecosystems, our ratepayers and our taxpayers could be spared the significant costs of an industrial CSP build-out across our precious open spaces, while enjoying the substantial environmental, economic and security benefits of a clean energy future by focusing on increasing efficiency and clean energy production within our built environment and leaving our open spaces intact.  In fact, there is no compelling reason to build any CSP in our deserts or arid grasslands, and dozens of reasons not to.

[1]  See, e.g., Staff’s Opening Brief, Introduction. Bright Source’s CSP plant at Ivanpah::

http://www.energy.ca.gov/sitingcases/ivanpah/documents/index.html

In light of ongoing oil spills in the Gulf of Mexico, off the California Coast, and along pipelines in the midcontinent, we must be particularly wary of projects that sacrifice healthy, functioning ecosystems for energy production when there are cheaper, cleaner, safer and more reliable alternatives, and in light of the twin goals of improving the economy and improving the environment, we should be particularly interested in solutions which promote the economic well-being of the American people and small businesses, not just large energy corporations.  Although there is much along these lines to be said about remote large-scale PV installations and Industrial Wind developments, and myriad wonderful specifics relating to passive heating/cooling, efficiency and conservation upgrades, this short document deals primarily with the choice between remote Concentrating Solar Power (CSP) and local Photovoltaic Power (rooftop and smaller in-city installations).

Please consider the following 3 points:

1.      Local, distributed solar PV (both polycrystalline and thin-film) is at least as efficient and productive, faster to get online, and less expensive than remote central station CSP or PV plants when all relevant costs, including new transmission and line losses, are taken into consideration.

Residential Rooftop Solar, the Democratically Owned Solution:    The neighborhood residential rooftop solar consolidator 1 Block Off the Grid (1BOG)[1] reported the following actual installed costs for 2009:

            - San Diego locations at $5.29/Wdc[2]

            - Denver locations at $6.10/Wdc.

            - San Antonio locations at $4.80 W/dc

            - Coachella Valley locations at $5.49/Wdc

            - North NJ locations at $5.45/Wdc

            - Pricing noted above does not include any tax credits, cash rebates, or other incentives that may be or become available, but even without them, these prices are in the same range as the capital cost estimate for dry-cooled solar thermal in the RETI analysis in Footnote 2, and prices continue to drop.

[1] http://1bog.org/1bog-cities/ each city has a pricing tab.

[2] See: http://solarsandiego.1bog.org/san-diego-solar-panel-cost/

These costs are based on documented installed cost of group-purchase 4 kW poly silicon residential PV systems, San Diego, 2009, and translates into a cost of approximately $6,000/kWac

Comparison of net energy output:   “Higher solar insolation,” meaning higher solar radiant energy, is the stock reason for siting CSP projects in locations like the Mojave Desert. Yet transmission losses largely negate higher insolation and higher capacity factors of solar projects in Mojave Desert locations compared to the slightly lower solar insolation in urban centers like Los Angeles, Riverside, and San Diego.  On average, the difference in solar insolation between the Mojave and Southern California urban centers is approximately 10%.[1] Transmission losses average 7.5% (average) to 14% (peak) in California. This means there is no significant difference in the net electric power delivered to customers from CSP plants in remote Mojave Desert locations and rooftop PV installations in Riverside or Los Angeles (for projects with the same rated capacity).[2]

Transmission costs:  The CSP costs above do not factor-in the very substantial costs of new transmission infrastructure for getting solar-generated energy from remote rural and Federal land locations to urban demand centers-costs that will be borne by ratepayers and that will generate substantial guaranteed profits for investor-owned utilities, currently running at ~$24 million/mile in California[3].  Peak summertime power demand drives utility infrastructure construction, both new generation and transmission. Remote generation and transmission are both built at capacities large enough to meet “peak” demands, which means substantial over-building of each for the handful of hours each summer that the system peaks are hit. This results in underutilized - but profitable - utility infrastructure resources[4].  Local solutions like rooftop or parking lot solar PV that shave “peak load” will result in major infrastructure savings if procurement of new conventional generation or transmission is avoided.

Big Solar Subsidies further Distort the Market: Big Solar currently enjoys a number of direct and indirect subsidies including 30% Federal cash grants; Federal loan guarantees, which are essentially guaranteed federal loans; guaranteed returns on investment via PPAs; use of public lands and resources; waivers of millions of dollars in application fees; and externalization of costs onto local communities and ecosystems (such as depleting scarce local water resources, removing land from other productive uses which would create jobs and local benefits, lost recreational and viewshed values, etc.).  If these resources were dedicated instead to efficiency upgrades and local solar power, the cost of each would decrease dramatically and the speed of uptake would increase equally dramatically.

Local Solar is much faster than Big Solar:  Permits for residential solar need only take weeks, not years.  Germany installed over 714 MW of mostly rooftop solar power in the first quarter of 2010 alone[5], and each quarter installs more than the prior quarter, despite declining tariffs. 

[1] http://www.nrel.gov/csp/maps.html

[2] The Design, Construction, and Operation of Long-Distance High-Voltage Electricity Transmission Technologies

Environmental Science Division, Argonne National Laboratory, Technical Memorandum ANL/EVS/TM/08-4

[3] See KPBS story dated January 28, 2010:

http://www.kpbs.org/news/2010/jan/28/1-billion-may-be-needed-for-lines-tied-sunrise-po/

[4] See: Distributed Renewable Energy Operating Impacts and Valuation Study, Prepared for: Arizona Public Service, January 2009: www.aps.com/_files/solarRenewable/DistRenEnOpImpactsStudy.pdf

[5] http://guntherportfolio.com/2010/07/german-2010-photovoltaic-installs-climb-to-714-7-megawatts-through-march/

Permits for larger, in-city solar projects take only months, as does construction.[1] Transmission and Big Solar permits and construction take roughly 5-10 years when done correctly[2], and the current fast-tracking short-changes the environment and public participation.  If anyone is serious about reducing GHG emissions and increasing employment, local, not remote solar, is the only solution that makes sense.

The Duck Curve: The solar build-out on California and Nevada public lands has been successful since 2010. Thousands of acres of public lands desert ecosystems have been developed into power plants, with several thousand megawatts of utility-scale energy fed into the national grid.

[1] http://gigaom.com/cleantech/sce-starts-second-rooftop-solar-installation-awaits-puc-decision/

[2] see Table 5 and Table 7: http://docs.cpuc.ca.gov/efile/RULINGS/119573.pdf

But with any new, experimental push for future energy supplies, this comes with costs and a learning curve. So much utility-scale solar projects have been placed on line that the grid has become overloaded.[1] Utility-scale solar projects reduce demand during peak hours. But as people go home and use home electricity, the sun is setting and the solar projects cannot meet this late-day demand. To meet this late afternoon-evening demand, California and Nevada must quickly ramp-up energy generation with peaker natural gas power plants—which are basically jet engines attached to the grid. Flip a switch to fire up the natural gas burner and you generate megawatts of electricity to help balance this evening grid imbalance. 

But there could be a better way, using Distributed Renewable Energy Resources.  

[1] https://www.caiso.com/Documents/FlexibleResourcesHelpRenewables_FastFacts.pdf

The grid in California and Nevada is now imbalanced with too much peak renewable energy generation (when the sun is shining), and not enough dispatchable power or energy storage that can reduce the imbalance. 

Therefore, the California Independent System Operator is forced to “curtail” or shut down utility-scale solar projects in order to stop the peak day flood of solar energy that is causing this grid instability.

Before any more utility-scale solar and wind projects are added to the grid in California and Nevada, we need to assess how many megawatts are being curtailed daily--desert solar project built but then shut off to reduce this imbalance and negative pricing. 

Distributed Energy Resources---including rooftop solar systems plus advanced lithium-ion battery storage, net-positive energy building design, energy efficiency, and energy conservation, can greatly help this grid imbalance. Storing excess solar energy during the day in rooftop solar systems plus batteries, and feeding this excess into electric vehicles during the night can potentially revolutionize renewable energy grid problems using local models. 

Requested Action: We ask that a moratorium on Big Solar and electric transmission permits on all public lands other than Superfund Sites and Brownfields be implemented while the much cleaner, faster, and more affordable alternative of local, point of use solutions within the built environment is fully brought online, preferably via the proven policies set forth below.  Subsidies and policies favoring local solutions should be considerably higher and more aggressive than those favoring Big Solar and transmission, to reflect their greater value to communities, ecosystems and climate change.

2.      The harm that will be done to hundreds of thousands if not millions of acres of intact desert and plains ecosystems by Big Solar is substantial, irreversible and unnecessary, and could in fact result in an acceleration of catastrophic climate change by steeply increasing GHG emissions in the short term; whereas efficiency and DG will be more effective at reducing GHG emissions in the short and long term, while preserving the public’s open spaces and healthy ecosystems.

Desert Ecosystems may sequester substantial amounts of CO2:  Researchers at the University of Nevada Las Vegas have been monitoring carbon uptake in Mojave Desert ecosystems for the past 7 years and have consistently found substantial uptake, processing and sequestration of carbon, rivaling or exceeding that of some forested or grassland ecosystems.[1]  Likewise, wetland and grassland ecosystems, such as those that occur in the San Luis Valley, CO (currently targeted for industrial solar development) are well-known for their ability to uptake and store C02[2].  More study is needed, but the possibility should not be ignored.

Transmission infrastructure emits enormous amounts of SF6: Sulfur Hexafluoride (SF6) is the most harmful and potent greenhouse gas (GHG) known to man:[3] One pound of SF6 has the same global warming impact of 11 tons of CO2.[4]  It is 23,900 times as harmful as CO2, has a half-life of 3,200 years, and nothing sequesters it[5]. EPA Administrator Lisa Jackson listed SF6 as one of six GHGs most critical to be regulated by the EPA.[6] Its global concentration has increased 7% each year from 1980 to 1999 (more recent statistics are not available). Eighty percent of the SF6 in the atmosphere derives directly from electrical transmission infrastructure[7].

Big Solar creates substantial emissions: Manufacturing, transportation, construction transmission and operation emissions of Big Solar are enormous. For one example, the cement industry is the second largest CO2-emitting industry, after power generation, producing about 5% of global man-made CO emissions.[8] Steel is considered another extremely high emitter, especially steel produced in China in inefficient plants powered by coal[9].  For example, during the 4 years of construction of the Ivanpah solar project 17,779 metric tons CO2 equivalent will be released.[10]

Big Solar will not reduce coal burning or foreign oil consumption: Due to its intermittency and the current state of energy storage, grid-tied solar power (large and small) can currently only replace load-responsive natural gas, and hydropower, not coal, which is not load-responsive or oil, which is rarely used in electricity production.  Natural gas emissions are roughly 50% of those produced by coal, and hydro has no emissions.  Local solar also has no emissions, so any comparisons between CSP and the power it will ostensibly displace need to be made to local solar, hydro and natural gas, not to coal or oil emissions. 

There is only a “reduction of GHGs” if the offset power is not used: Currently, there is no requirement that any fossil fuel plants be closed or their capacity reduced to ensure any actual offset of existing fossil fuel power generation by new CSP power, which means it is very likely that Big Solar will simply increase the amount of power in the grid, rather than result in any legitimate reductions in emissions.  This, in turn, means it will not halt or slow Climate Change at all, but rather will accelerate Climate Change, albeit possibly marginally less quickly than adding coal power would, because it is adding power and emissions to the grid.  Most climate scientists agree that any increase in GHG emissions could be catastrophic[11] and that dramatic decreases are required, so this result will not meet any of the stated climate policy goals.

The EPA has set forth it’s requirements for accounting GHG emission reductions which can be used as a guideline[12]:

“…GHG emission reductions from offset projects [must] meet four key accounting principles—they must be real, additional, permanent, and verifiable.”

Requested Actions: We ask that the GAO immediately undertake a comprehensive, cradle-to-grave analysis of the total emissions caused by Big Solar/CSP (including the loss of effective CO2 sequestration in the project areas and surrounding areas which will be impacted by erosion, flash flooding, blowing sand, etc.) and compare them to the total emissions caused by producing an equivalent amount of intermittent power from local solar, hydro and natural gas.  The EPA’s accounting requirements must be met for any permit to be issued.

In the interim, no federal or state agencies can be allowed to use “GHG reductions” as a reason to override the environmental protections of NEPA, CEQA or otherwise, nor should Big Solar qualify as “clean energy” for purposes of subsidies, loans, preferential treatment, RPS calculations, fast-tracking, project permitting or otherwise.  

All “fast-tracking” of Big Solar projects must be immediately halted, as the permits being pushed through are neither legally, economically or environmentally defensible, and we cannot allow politics to trump the science-based policy we were promised by this administration.

As part of every Big Solar application, applicants should be required to provide proof of binding agreements which will completely and permanently reduce or eliminate an equivalent output of fossil fuel combustion at an existing power plant.  As a practical matter, every PPA could easily include a provision designating which power plant would be slowed down and/or shut down as a result of the PPA.

The EPA should ban all use of SF6, including that used in transmission infrastructure, and policies steering away from unreliable, expensive and unneeded transmission should be implemented immediately in favor of local, ratepayer-controlled smart grids, efficiency upgrades and local solar.

3.      A policy promoting distributed generation, supported through expanded net metering, Property Assessed Clean Energy (PACE) loan financing, and feed in tariffs would be far more effective at meeting the goals of citizens, the non-utility business sector, and elected officials than Big Solar, which only benefits Big Energy companies like Chevron, BP, and Goldman Sachs.

Feed in Tariffs (FITs) are proven to work quickly, cheaply, and reliably:  Germany installed over 714 MW of PV in the first quarter of 2010, 80% of which is rooftop systems under 100kW, and which is more PV than was installed in the entire first half of 2009[13].  Even as their tariffs reduce, they continue increasing the amount of PV installed, thanks to their well-considered FIT.  A recent study done by the Los Angeles Business Council and UCLA indicates that 3,300MW of rooftop solar is currently “economically available” for an FIT (over 15% of Los Angeles’ total power load) and an FIT program would create over 11,000 local jobs.  [14] Modest feed in tariffs would also cost ratepayers very little.  The UCLA study noted above projects an average monthly impact of only $0.48 for households and $9.37 for business and industry for the first 10 years of a very conservative 600 MW program, and after that a net savings to all ratepayers, based on historical and projected price increases in natural gas (the market referent fuel)[15].  Germany’s numerous rooftop installations, supported by generous feed in tariffs have also had minimal impact on non-generating ratepayers,[16] while providing unprecedented gains in clean energy generation and reasonable return on investment for generating ratepayers. 

PACE loans make local efficiency and PV improvements possible: PACE style loans (see, e.g., AB811 in CA) that allow ratepayers to amortize the costs of rooftop solar across 20 years and repay along with property tax payments have proven very popular where they have been offered to date. There is no cost to taxpayers or other ratepayers.  Unfortunately, Freddie Mac and Fannie Mae (FM) have taken a counterproductive view of these loans and have suggested that because property tax assessments take the first lien on the applicable property, these loans will pose a threat to the supremacy of mortgages held by these agencies[17].  Although California and other jurisdictions are demanding that FM treat these funds like any other property tax assessments[18], FM’s position has resulted in a collapse in current and imminent PACE loan funding, which may be disastrous for our economy (many PACE programs were funded by ARRA) and for our energy future.

Expansion of Net Metering programs would help in the interim: Firstly, all states which insist on maintaining an RPS/RES to meet “clean energy goals” should account for all net metered clean electricity (and off-grid power) as “power,” for purposes of meeting RPS/RES goals, not as “demand reduction,” as is currently done.  By refusing to count clean, democratically-owned solar power as solar power, such programs create a completely artificial exigency for large, central-station power plants which are otherwise not needed.

Caps on individual system sizes and on the amount of power the utilities must accept from rooftops must be removed, and compensation at a level providing return on investment for ratepayer generators must be paid fairly (based on cost, not on market referents) for all power that is produced and not consumed by ratepayer generators. 

Community benefits are substantial: Aside from the obvious improvements in property values and the enormous number of well-paid local jobs resulting from widespread efficiency upgrades and local solar supported by feed in tariffs/well-considered net metering, when “green energy premiums” for clean energy are paid to our neighbors rather than to giant corporations, the economic benefits inure to Main Street, stimulating local spending, jobs creation, debt reductions and other tangible economic benefits.  In contrast Big Energy profits are taken out of the region and result in a net reduction in local economic stimulus through higher electric bills.  The risks of power outages, spikes in power bills, water waste, climate change, urban “heat islands” and pricing and supply manipulations by utilities are all also greatly reduced in a decentralized, democratized energy grid, where the electric car becomes clean and affordable as well.

Requested Actions: Fannie Mae Freddie Mac and FHFA must immediately stand down from their crippling position on PACE loans[19], which should be classed similarly to local bond issues (which also take first lien as part of a property tax assessment) and not as “loans” for purposes of seniority of lien.  Substantial additional federal funding for PACE loans should be made available immediately to stimulate job creation, decrease energy consumption and emissions, and bolster sagging property values to keep families in their homes and meet stated societal and political goals, and ongoing PACE funding should be made available to continue our nation down the path to sustainability.

Feed in Tariffs similar to Germany’s need to be implemented on a national scale immediately, so that ratepayer-generators receive return on investment for doing the right thing (in contrast to the abject failure of “cost avoidance” style FITs like California tried[20]).  Failed policies like RPS/RES should be discarded in favor of proven successes like FITs.

Net Metering should also be standardized, expanded and improved.  Understandably, states will want to administer their own programs, but there should be some Federal Minimum Standards established to ensure that the stated national priorities are being met.  Firstly, all states which insist on maintaining an RPS/RES to meet “clean energy goals” must account for all net metered electricity (and off-grid power) as “solar power,” not as “demand reduction.”  Further, all caps on system sizes and caps on utility interconnections should be eliminated; and fair payments to ratepayer-generators (based on fixed return on investment, just like utilities are paid) for power that is produced and not consumed must be paid on a monthly basis.

Any RPS should have at least a 33% carve-out requiring net-energy metering and other rooftop solar or distributed energy resources to be part of a state portfolio.

Conclusion

Fundamental changes to power generation and consumption will need to be considered in order to avoid unacceptable land use impacts. The old utility model should be reconsidered. Moving towards net-positive energy building design systems[21] can help conserve high-value public lands, while more efficiently reaching renewable energy goals in the future. Net-positive approaches emphasize how buildings work collectively within networks, and how homes with rooftop solar systems add value to the grid. Crucial for the future are integration of life cycle analysis of clean technologies, energy efficiency, energy conservation, increasing on-site renewable energy, and building smart-grids with bi-direction flow of energy from generators to local transmission networks.

Thank you for considering the information we have presented, and the solutions we have proposed.  Obviously in such a compact document, much was left to more detailed reports. Please contact us with questions or requests.

[1] http://www.unlv.edu/Climate_Change_Research/Projects/pub_abstracts/2005-Jasoni-GCB.pdf

[2] http://pubs.usgs.gov/pp/1745/

[3] http://www.epa.gov/highgwp/scientific.html

[4] http://www.epa.gov/electricpower-sf6/basic.html

[5] http://www.epa.gov/electricpower-sf6/basic.html

[6] http://www.foxnews.com/politics/2009/04/17/epa-takes-step-regulating-pollution-linked-climate-change/

[7] http://www.epa.gov/electricpower-sf6/basic.html

[8] http://www.bgs.ac.uk/education/carboncapture/Anthropogenic.html

[9] http://www.worldsteel.org/?action=storypages&id=226 and http://www.npr.org/templates/transcript/transcript.php?storyId=10172700

[10] Final Staff Assessment/Draft Environmental Impact Statement at p. 6.1-64 [Greenhouse gas table 2].

[11] http://www.350.org/understanding-350; see also http://co2now.org/

[12] see “Project Methodologies” at http://www.epa.gov/climatechange/emissions/index.html

[13] http://guntherportfolio.com/2010/07/german-2010-photovoltaic-installs-climb-to-714-7-megawatts-through-march/

[14] See p. 39, “Bringing Solar Energy to Los Angeles:  An Assessment of the Feasibility and Impacts of an In-basin Solar Feed-in Tariff Program”:

http://www.labusinesscouncil.org/online_documents/2010/Consolidated-Document-070810.pdf

[15] ibid, p. 12

[16] As of 2008, increases were approximately 1 Euro ($1.30)/month:

http://www.nytimes.com/2008/05/16/business/worldbusiness/16solar.html?_r=3&scp=1&sq=Solar+Valley+Overcast

[17] http://www.npr.org/templates/story/story.php?storyId=128700648

[18] http://green.blogs.nytimes.com/2010/07/14/fannie-and-freddie-are-sued-in-california/

[19] http://www.ab811.org/

[20] http://www.renewableenergyworld.com/rea/news/article/2010/02/nrel-feed-in-tariffs-legal-in-us-when-certain-conditions-met

[21] For instance, see
https://www.tandfonline.com/doi/full/10.1080/09613218.2015.961046

But the utilities fight back, and in 2023 NEM in California is gutted.

In Nevada a similar fight took place to save rooftop solar policies. Basin and Range Watch participated in these protests at the Public Utilities Commission building in Las Vegas.

2012 (most of this is still applicable in 2023)

1. Bulldozing the land to build massive solar projects may have local impacts on the desert, but won’t it ultimately save the rest of the world from global warming?

Big Solar and Wind facilities will require so much land to meet our energy demands that we will ultimately lose many of the places and wildlife we want to protect from global warming. In California alone, energy companies have submitted applications to destroy over 1,000 square miles of public land--mostly pristine wild lands--for solar and wind projects, according to the Bureau of Land Management. Those projects would supply less than 25% of California's energy needs, but they would industrialize many of the remaining valleys and hillsides in the state. If we apply this math to meet even more of our energy needs in every state, we lose many more thousands of square miles to industrialization.

2. Given the urgency of climate change, isn’t rooftop solar deployment too slow?

Distributed generation installations increase rapidly with the right policies. Over half of Germany’s 53,000 megawatts of clean energy are generated by smaller installations owned by individuals, and that number is growing rapidly. In just December 2011 alone, Germany installed nearly 3,000 megawatts of solar panels. In Australia, over 500,000 homes have rooftop solar thanks to a successful feed-in-tariff program. The United States has been slow to institute the right mix of policies to match the pace of other countries, but California has already reached 1,000 megawatts of rooftop solar, enough to power 750,000 homes.

Citations

Germany solar:

http://energyselfreliantstates.org/content/american-and-germany-getting-theirrenewable-

energy-just-desserts

http://www.bloomberg.com/news/2012-01-06/germany-s-solar-surge-leaves-biggestmarket-

steady-in-2011.html

Australia: http://www.smh.com.au/environment/energy-smart/solar-panel-users-climbthrough-

roof-20111205-1ofjx.html

California:http://www.mercurynews.com/business/ci_19292783

3. Aren’t deserts too inhospitable to support much life, and besides, how can

solar panels hurt the desert?

While many people believe that deserts are inhospitable places that support very little

life, nothing could be further from the truth. According to the Center for Biological

Diversity, our diverse North American deserts support many thousands of species and

hundreds of diverse ecosystems that are threatened by global warming second only to

the Arctic.

Industrial solar development impacts 100% of the project site that can be as large as 10

square miles. Before construction can begin, the entire area is graded flat by bulldozers

and scraper-graders to place the posts that will hold the PV panels or mirrors. The

disturbance of carbon-sequestering desert soils creates blowing sand, erosion and

flooding problems. Animals such as desert tortoises, burrowing owls, and kit foxes must

be relocated off the site. Disease can be introduced or spread and an estimated 50% of

tortoises moved from their homes will perish from this process. Chain-link fences are

placed around the entire plant excluding larger animals and interrupting normal

migration patterns in large areas.

4. Won't the tortoises like the shade of the solar panels?

No, desert tortoises find shade under desert shrubs and in burrows, which are

destroyed by large-scale solar projects. Tortoises are permanently relocated from the

solar site. Because of the difficulty of finding small juveniles and eggs, hundreds more

are crushed and killed by construction vehicles. Up to 50% of the relocated tortoises

will perish from this process.

5. What about preserving valuable agricultural land from solar and wind

development?

There is no need to pave productive agricultural land over with solar panels when land

can be used for food production. There are plenty of degraded and contaminated lands

unfit for agriculture identified by the Environmental Protection Agency (EPA), as well as

rooftops and parking lot space in cities.

6. Don’t we need all kinds of renewable energy production in order to combat

climate change?

Some people think we can have both DG and remote industrial solar development, but

the evidence suggests otherwise. Allocation of limited transmission capacity and

financial and technical resources creates a path dependency on remote, corporateowned

industrial solar that primarily benefits utility investors, while depriving local

communities of the opportunity to develop and benefit from their own renewable

resources beyond a handful of unskilled jobs.

See: “Centralized v. Decentralized Clean Energy – We May Have to Choose, by John

Farrell, http://energyselfreliantstates.org/content/centralized-v-decentralized-clean3

energy-we-may-have-choose

7. Don't desert panels produce a lot more power than panels in shadier areas?

No, they are less efficient in hot desert summer temperatures, and more efficient in

cooler coastal areas. Also power is lost over long-distance transmission lines – as

much as 10-12%. When these losses are factored in, remote installations produce

essentially no more power than the equivalent-sized photovoltaic solar installation in

most of the local (load) areas consuming the power. Transmission infrastructure is

inherently vulnerable to weather, natural disasters, cyber hacking/terrorism and human

error, while local micro-grids are ideal to accommodate local solar generation at peak

times without ever accessing transmission infrastructure.

8. Wouldn't the large-scale solar projects bring a lot of jobs to the community?

Solar power plants can be controlled remotely and only a few highly skilled people are

needed to manage several plants. Once the 1-2 year construction process is over, very

few jobs result. Construction workers are usually hired by building contractors who

bring their own skilled labor force with them from urban areas or out of state. Depending

on the technology, permanent jobs during operation of a typical solar plant may only

amount to 5 to 30.

In contrast, installing solar panels on rooftops in communities where the power is

needed produces local long-term jobs. Rooftop solar also improves property values,

and if feed-in-tariffs are in place, improves prosperity for the community. Further,

remote public land that is squandered on industrial solar or wind applications cannot be

used for local investment in projects like manufacturing facilities that would create many

more long-term jobs.

9. Why should NIMBY's get to stall our best chance to combat global warming?

We should all be concerned about our own backyard, and get to know it. The principle

of "Think Globally, Act Locally" is a sound one. People will conserve and protect what

they are most familiar with, i.e., the wild ands and neighborhoods around them. If every

community installed rooftop solar, conserved energy, and cared for their nearby

ecosystems, we would achieve much towards reducing greenhouse gas emissions.

10. What is the difference between Net Metering and Feed-in-Tariffs?

Net-metering is when a ratepayers utility company gives a credit against a customers

energy bill for energy they generate from rooftop solar, or other onsite renewable

energy generation. A feed-in tariff (FIT) is a policy that requires the utility to purchase

power generated from onsite renewable resources, including residential and commercial

rooftops. Net-metering rates are based on the cost the utility avoids by not having to

build additional generation. In the US, this is usually just a fraction of the real value of

renewable energy. If well designed, a FIT will cover the full cost of installment plus

provide a small profit to the owner/generator for energy generated above its own needs.

Thus FIT’s are a far more effective policy incentive for people to put solar on their

rooftops than net-metering.

11. What is PACE?

A Property Assessed Clean Energy (PACE) bond provides upfront financing to

residential and commercial property owners who wish to implement energy efficiency

measures and install small (usually up to 1 MW) renewable energy systems. The funds

are repaid through an annual assessment (usually 20 years) on their property tax bill. If

the property owner later sells, the assessment stays with the property. PACE bonds

can be issued by state, county or municipal financing districts or finance companies and

the proceeds can be typically used to retrofit both commercial and residential

properties. PACE is not a tax but rather a voluntary program where only those property

owners who opt into the program are affected. Learn more about PACE at:

http://pacenow.org/blog/

Solar Done Right criteria for identifying “disturbed” lands

January 2011 by Kevin Emmerich

All too often, wind and solar applicants attempt to classify the sites that they choose to develop their massive proposals on are referred to as disturbed land. These classifications are often misleading as they refer to an occasional tire track or litter. If these lands are disturbed based on a tire track, than  Yosemite National Park and Great Smokey Mountains National Park easily fall into the disturbed category due to their high volume of visitation. Litter and illegal off road tracks can be found in both parks. The BLM often adopts the energy company’s spin that these lands are disturbed.

We have developed our own “Disturbed Lands Criteria” that we would like to see the Department of the Interior adopt.

We have broken these down in the following four categories: 

1. Number 1 being the most pristine ecosystems and inappropriate for development. 

2. Number 2 being old or unusable agricultural fields. While these are disturbed, they have a recovery potential. 

3. Number 3 being geologically altered landscapes such as strip mines and associated cyanide leach ponds for gold mining. Both number two and three will create transmission sighting issues on pristine lands.  

4. Number 4 being the built environment, the most appropriate for development of renewable energy.

Introduction

The U.S. could avoid the elevated economic and environmental costs of remote utility-scale solar power development, and greatly expand the direct involvement of individuals and communities in renewable power generation, with a policy that favors distributed PV. Priority development of solar PV and solar hot water heaters within our built environment (cities and towns), combined with high value energy efficiency measures, could meet much of U.S. clean energy and greenhouse gas emission reduction targets.

This paper highlights the cost and environmental advantages of distributed PV, on rooftop and smaller in-city installations, over remote utility-scale solar power. In light of the recent and ongoing tragedy in the Gulf, we should be wary of energy projects – conventional or renewable – that can permanently alter healthy, functioning ecosystems when there are cheaper, cleaner, safer, and more reliable alternatives. In the case of solar power, the U.S. can accomplish the dual goals of improving the economy and improving the environment by prioritizing the deployment of distributed PV.

I. When all costs are factored in—including new transmission infrastructure and line losses—local, distributed solar PV (both polycrystalline and thin-film) is comparable in efficiency, faster to bring online, and less expensive than remote utility-scale solar thermal power or remote utility-scale PV plants.

Residential rooftop solar, the democratically owned solution: Residential solar PV is much more cost-effective now than most policy makers realize. For example, the residential rooftop solar consolidator 1 Block Off the Grid (1BOG)  reported the following actual installed costs in Watts direct current (Wdc), prior to any rebates, tax credits, or other incentives, for 2009:

These 1BOG prices, specifically the 4 kW residential PV systems sold in the San Antonio area at $6.00/Wac, already approach the capital cost estimate for a 200 MW dry-cooled solar thermal of approximately $5.50/Wac (see Table 1). In addition, solar PV prices are projected to drop at a much faster rate than solar thermal prices over time. Both the California Energy Commission and the Department of Energy project that solar PV prices will drop by half between 2010 and 2020, while solar thermal prices are projected to decline much more gradually. 

Comparison of net energy output: “Higher solar insolation,” meaning higher solar radiant energy, is the most common reason put forth for siting remote utility-scale solar projects in locations like the Mojave Desert. Yet transmission losses largely negate higher insolation and higher capacity factors of solar projects in Mojave Desert locations compared to the slightly lower solar insolation in urban centers like Los Angeles, Riverside, and San Diego.  Transmission losses average 7.5% (average) to 14% (peak) in California.  The difference in solar insolation between the Mojave and Southern California urban centers is approximately 10%, in the same range as expected transmission losses associated with remote solar projects.  This means there is no substantial difference in the net electric power delivered to customers from remote utility-scale solar plants in remote Mojave Desert locations and rooftop PV installations in Riverside or Los Angeles (for projects with the same rated capacity). 

Transmission costs

New transmission infrastructure needed to carry solar-generated energy from remote locations to urban demand centers entails substantial costs. These costs are borne by ratepayers, with actual costs for new California transmission lines currently running at ~$11 to ~$24 million/mile. 

A power delivery strategy that concentrates on large generation and transmission projects to meet load leads to substantial over-building, as projects are often justified on aggressive load growth projections that indicate new electricity supply will be necessary 5-10 years in the future.  This approach is highly profitable for investor-owned utilities (IOU), which are guaranteed a healthy rate of return for “steel in the ground” infrastructure projects like transmission and generation. Local installations such as rooftop or parking lot solar PV reduce peak load at the source of demand and thereby reduce or eliminate the need for additional conventional generation and transmission infrastructure. It is no surprise given how IOUs make money that these utilities are generally opposed to expanded development of local solar power.

Subsidies and externalized costs

Large-scale remote solar projects are preferred by Southwestern IOUs over local solar primarily because of the revenue that such projects can generate indirectly in the form of new IOU-owned transmission capacity. These large-scale remote solar projects enjoy a number of direct and indirect subsidies that are too seldom taken into account. These include federal cash grants and loan guarantees; exclusive use of public lands and resources designated for multiple use; waivers of millions of dollars in state application fees; and externalization of costs onto local communities and ecosystems.

Timeframes

Large-scale remote solar projects and related transmission lines take many years to complete.  In contrast, distributed PV can be brought online quickly.  Germany, using a simple and effective feed-in tariff (FIT) contract structure to spur cost-effective development of distributed PV, installed nearly 4,000 MW of distributed PV in 2009 and may install as much as 6,000 MW in 2010. 

Needed action

The Solar Done Right Coalition requests that permitting of all remote utility-scale solar projects and associated transmission projects be suspended on public lands, with the exception of proposed projects on Superfund sites or brownfield sites. Concurrently, solar energy subsidies and policies should be redirected to advance point-of-use solar solutions in the built environment to reflect the greater value of local solar to communities, ecosystems, the economy, and the climate crisis.

II. Large, remote solar projects could permanently reduce natural uptake of carbon by the desert environment cleared for development. In contrast, increased efficiency and distributed solar PV will reduce carbon emissions without this tradeoff.

Desert ecosystems may sequester substantial amounts of CO2: Researchers at the University of Nevada Las Vegas have been monitoring carbon uptake in Mojave Desert ecosystems for the past seven years and have consistently found substantial uptake, processing and sequestration of carbon.  Likewise, wetland and grassland ecosystems, such as those found in Colorado’s San Luis Valley (targeted for industrial solar development), are well-known for their ability to uptake and store CO2.  More study is needed to determine how much carbon uptake will be lost when thousands of acres of natural desert cover are converted to scraped earth and covered with solar collectors. To the extent that the lost carbon uptake is substantial, it undercuts the greenhouse gas reduction justification for building the solar facility at that location.

Transmission infrastructure emits greenhouse gas SF6: Sulfur hexafluoride (SF6) is the most potent greenhouse gas evaluated by the Intergovernmental Panel on Climate Change,  and eighty percent of the SF6 in the atmosphere derives directly from electrical transmission infrastructure.  With an atmospheric life of 3,200 years, one pound of SF6 has the same global warming impact of 11 tons of CO2 and nothing sequesters it.  The Environmental Protection Agency has identified SF6 as one of six emissions most critically in need of regulation.  With policies favoring transmission, the U.S. may contribute to a surge in unnecessary SF6 emissions.

Remote utility-scale solar construction and operation creates substantial emissions: Emissions from the manufacturing, transportation, construction, transmission, and operations associated with remote utility-scale solar are substantial.

For example, over 4 years of construction, the 370 MW Ivanpah solar project in California will release 17,779 metric tons of CO2-equivalent emissions, with additional operating emissions of 27,444 metric tons of CO2.  During the construction of the 250 MW Blythe solar project, 103,900 metric tons of CO2-equivalent emissions will be released. The project will cause a loss in carbon uptake of about 8,806 metric tons of CO2 per year due to vegetation removal, plus 14,789 metric tons of CO2-equivalent for operations. Decommissioning is expected to emit nearly as much again as construction.  These projects are not benign with regard to environmental impacts.

Emissions are reduced only if the offset power is not used: The EPA has set forth its requirements for accounting for emission reductions which can be used as a guideline :

“… emission reductions from offset projects [must] meet four key accounting principles—they must be real, additional, permanent, and verifiable.”

Needed actions

The Solar Done Right Coalition requests that the GAO immediately undertake a comprehensive, cradle-to-grave analysis of the total emissions related to all aspects of remote utility-scale solar development and associated transmission, and compare these to the total emissions derived from producing an equivalent amount of intermittent power from local PV, hydro and high-efficiency natural gas. The EPA’s accounting requirements should apply to all remote utility-scale solar projects proposed. The solar developers and utilities buying the power should be required to demonstrate that the EPA accounting requirements will be met before a construction permit can be issued. Calculations should be based on actual outputs in verifiable kWh, rather than rated capacities.

Pending completion of the GAO study, neither federal funding, including loan guarantees and investment cash grants, nor construction permits should be issued to projects for which the National Environmental Policy Act (NEPA) or other relevant federal environmental laws have been wholly or partially overridden on the basis of presumed reduction benefits from these remote utility-scale solar projects.

“Fast-tracking” of remote utility-scale solar projects, based on the untested presumption of overwhelming reduction benefit, should be immediately halted.

The EPA should study the phase-out of SF6.

The 2005 Energy Policy Act should be amended to (a) site the mandated 10,000 MW of clean energy production described in the Act on federal buildings and federal properties within the built environment rather than on public lands; and (b) repeal the National Interest Electric Transmission Corridors provisions.

III. Distributed generation, supported through Feed-in Tariffs (FITs), Property Assessed Clean Energy (PACE) loan financing, and expanded net metering would be more effective than remote utility-scale solar in creating renewable energy and addressing the climate crisis.

FITs are proven to work quickly, economically, and reliably: FITs provide a simple contract mechanism for individual homeowners and business owners to profitably install as much solar PV as their buildings/properties will allow, maximizing the potential of rooftops, parking areas, and brownfields in urban and suburban environments. Germany installed over 714 MW of solar PV in the three months of 2010, 80 percent of which is rooftop systems under 100 kW. This is more PV than was installed in that country during the first half of 2009.  Even as its solar PV tariffs shrink, Germany continues to increase the amount of PV installed. The reason for this is the rapid decline in the cost of PV systems. As stated earlier, DOE currently projects that the cost of solar PV systems will drop by half between 2010 and 2020.  The steadily declining German tariff for solar PV reflects this market reality. 

A recent study done by the Los Angeles Business Council and UCLA indicates that 3,300 MW of rooftop solar is currently “economically available” for German-style FITs for Los Angeles. The study indicates that the FITs program would create over 11,000 local jobs.  Modest feed-in tariffs would also cost ratepayers very little. The UCLA study projects an average monthly additional cost of only $0.48 per month for households and $9.37 per month for business and industry for the first 10 years of the proposed 600 MW FITs program. Based on historical and projected price increases in natural gas and the rapidly declining cost of solar PV, after 10 years a net savings to all ratepayers is projected. 

Germany’s numerous rooftop installations, supported by generous feed-in tariffs, have had minimal impact on non-generating ratepayers,  while providing unprecedented gains in clean energy generation and jobs creation while providing a reasonable return on investment for PV system owners.

PACE loans make local efficiency and PV improvements possible: PACE (Property Assessed Clean Energy) loans that allow ratepayers to amortize the costs of rooftop solar and efficiency upgrades over 20 years and repay them along with property tax payments have proven very popular where offered. There is no cost to taxpayers or other ratepayers, and virtually no risk to lenders or borrowers. Unfortunately, Freddie Mac and Fannie Mae (FM) have suggested that because property tax assessments take the first lien on the applicable property, PACE loans will pose a threat to the supremacy of mortgages held by these agencies.  Although California and other jurisdictions are demanding that FM treat these funds like any other property tax assessments,  FM’s current position has resulted in a collapse in PACE loan funding.

Expansion of net metering programs would help in the interim:  All states that establish or maintain RPS to meet clean energy goals should account for all net metered clean electricity and off-grid power as eligible power for meeting RPS goals, not simply as “demand reduction” as is currently done. By failing to count clean, net metered solar power as renewable power, such programs create an artificial preference for large, central-station power plants. 

Community benefits of local focus are substantial: In addition to improvements in property values and the creation of well-paid local jobs from efficiency upgrades and local solar PV, the local focus provides “green energy premiums” to communities, rather than merely profiting large corporations. This stimulates a cycle of local spending, local jobs creation, debt reductions, and other tangible economic benefits. 

Needed actions:  Fannie Mae, Freddie Mac, and FHFA must immediately reverse their positions on PACE loans.  These loans should be classified similarly to local bond issues (which also take first lien as part of a property tax assessment) and not as “loans” for purposes of seniority of lien.  Substantial additional federal funding for PACE loans should be made available to stimulate job creation, decrease energy consumption and emissions, and bolster sagging property values to keep families in their homes. PACE is a very strong tool with which to meet stated societal, economic, environmental and political goals, and ongoing PACE funding should be made available immediately to lead our nation down the path to sustainability.

FITs similar to Germany’s should be implemented nationwide, with fair tariffs and simple contract requirements, so that system owners receive return on investment for doing the right thing. Amendments to the Public Utility Regulatory Policies Act could be made to ensure that fair market value, based on cost of generation, and access to the grid are afforded to all Americans willing to invest in this nation’s renewable energy infrastructure.

Policies like the California RPS, which has largely been a failure to date, should be discarded in favor of well-crafted FITs.

Net metering should also be standardized, expanded and improved as an interim step until fully functional FITs are in place. Understandably, states will want to administer their own programs, but there should be some Federal minimum standards established to ensure that national objectives for greenhouse gas reduction are being met. 

Conclusion

This is an overview document. More detail is available in the reference documents, reports such as the study recently prepared by the Sierra Club of California on the economic benefits of local solar power compared to remote utility-scale solar power, as well as materials and updates which will be periodically made available on our website 

Federal Asks

-TAX CREDITS/CASH GRANTS: 

            1.         The current 30% tax credit should be available to small producers as a cash grant, just like big producers;

            2.         Much more money should be made available to subsidize local projects and finance projects, including for low-income people, just like the many billions in loan guarantees (which are actually loans) to Big Solar.  Citizens and small businesses should receive Federal financial support in a ratio of 3:1 compared to Big Solar because of the enormous downstream effects (jobs, local incomes, home improvements, civic participation, energy conservation, etc.);

-PACE LOANS: Property Assessed Clean Energy program

            1.         Fannie Mae and Freddie Mac have bought Billions of Dollars in loans that they KNEW to be garbage, and are now trying to close the door after the horse left the barn.  Allowing municipal lenders first lien is the least of their problems, and they need to allow the fledgling PACE program to proceed IMMEDIATELY.

            2.         These loans cannot help but SUBSTANTIALLY IMPROVE the value of the property the improvement is being made on, often in excess of the cost of the actual project.  These are not cash-out re-fis to go on vacation - the improvement MUST stay on the property, and the Appraisal Institute shows a $20 increase in property value for every $1/year reduction in energy bills.

            3.         There is no risk to Fannie or Freddie and they need to stop interfering with our only chance for clean energy that won’t destroy our wilderness.

-BLM PROCESS:

            1.         We need an absolute moratorium on all solar projects sited on Federal Land until the Programmatic Environmental Impact Statement (showing cumulative harm from the thousands of applications pending) is complete and ratified (after public comment).

            2.         The Fast-Tracking process virtually guarantees serious violations of NEPA, which we are already seeing in permitting processes (example, the CEC admitting that there are very serious unmitigatable harms from Ivanpah, but since there is some vague, unproven reduction in GHGs, they will override NEPA and CEQA).  This is unacceptable

            3          Every applicant should be required to show a SPECIFIC source of offset power which will be shut down because their power plant is built, along with a detailed, peer-reviewed study proving the NET GHG reductions from that offset (net of Transmission/SF6; construction emissions; manufacturing emissions; lost GHG sequestration; etc.).  If the applicant cannot prove a very substantial ACTUAL reduction (plant is closing, GHGs will be lower than if we left the plant running), their application must fail.

            4.         The pricing scheme (ROW plus production payment) is inadequate to stanch the ongoing externalization of costs by Industry onto our wild places.  The US has an ignominious history of allowing miners, energy extractors, developers and other for-profit enterprises to ruin, poison, despoil and otherwise eliminate public lands for all other uses by their owners - the taxpayers.  This is unacceptable.  There are plenty of Brownfields and Superfund sites available for remediation and development of Big Solar and until those are completely full (and our built environment is completely developed with as many efficiency upgrades and local power production facilities as are possible), NO open space should be sacrificed to for-profit enterprises.

State Asks

- FEED IN TARIFFS:  

            1.         We need a system of legitimate FITs that provide a reasonable ROI for home and business owners installing systems under 20 MW - Big Solar can continue to negotiate for PPAs as they have been (no FITs for them).

-REVISIONS TO NET METERING: 

            1.         ALL solar power produced in the state and fed into the state grid needs to be accounted as “solar power” for purposes of the RPS calculation, whether the compensation is an offset on a bill or a check.  It is completely disingenuous to pretend it is “demand reduction,” when it is “renewable energy.”

            2.         NO system size caps for anyone.  If people want to oversize and have an optimal site, then by all means, we need to encourage them.  A FAIR payment for excess power (produced and not used onsite) in the 50 cents/kWh range should be paid on a monthly basis.  We cannot pretend in speeches to support solar power then crush it where people are trying to build it with NO environmental harm, and with democratic ownership.

            3.         NO limitations on the amount of projects that can be grid-tied.  Utilities are propagating a mythology that more than 2.5 or 5% of power being produced on-site will “disrupt” their grid operations, but it’s not true.  Most engineers agree that we could easily fulfill 30% on rooftops without any grid overloads or problems, even more as we shift to “smart grid” technology (which needs to be designed with point of use power production in mind).

-PACE LOANS/AB811

            1.         We appreciate the lawsuit filed by Atty General Brown, and we need a lot of follow-through from the state to make sure that ARRA funds are fairly distributed to residents for these efficiency upgrades and rooftop solar opportunities. 

            2.         If you must divert ARRA funds, we need them to go to these same recipients, not to any Big Solar companies or other recipients.