thinking

I have a bill draft request for improvements to the Solar Generations incentives program and would like your input.

The resulting concept document will be considered for drafting by the Legislative Counsel Bureau into a bill to be considered this session by the Nevada Legislature.

Will every concept make it to drafting? No, but I've spoken to enough of you one on one and heard your perspectives on how to make the program better that I believe this experiment in collaborative bill drafting could yield some interesting results.

Thank you Assemblyman Bolozien for providing a new format , and forum for discussion. I would like to state a few facts already established in Nevada. It is important that we maintain all standards for contractors that are currently in place. Nevada State Contractors Law is there to protect the public. PV systems are highly technical and should be installed by companies that have the correct licenses, training, certifications , insurances and bonding capacity. There are currently many outlets for training of a workforce that are not paid for by the ratepayers in any way. While Renewable Energy is important, it should not need to circumvent laws on contracting or public finance to be successful. We should strive to maintain the INTEGRITY of the Industry, rather than compromise for convenience.

Thanks,

Robert
First of all, I would like to thank Assemblyman Bobzien for creating a forum for discussion regarding this important solar program. Below are my recommendations are as follows:

1. Notify Respective Contractor of their Customers Approval: While homeowners are able to submit an application online, these applications are usually submitted by contractors who have more knowledge about the process and procedures. In fact, customers overwhelmingly prefer for their contractor to submit their application for them. Customers give their contractor their power bill and contact information to submit the application on their behalf. Because the customer has already given the contractor their information, they assume and expect the contractor will be notified when the application has been approved. Customers are very often confused when they dont receive a call from their contractor when they are approved, because their contractor was the one who entered the application. This confusion can be avoided simply by notifying respective contractors of their customers' approvals.

2.Increase Capacity Caps relative to current market demand and interest (subject to evaluation by legislature every two years with recommendations from the Task Force and the PUCN.)

-Residential 5,000 Kilowatts (CEC)

-Schools 2,000 Kilowatts (CEC)

-Public Buildings 1,000 Kilowatts (CEC)

3.Lock the Incentive Levels (subject to evaluation by the legislature every 2 years with recommendations from the Task Force and the PUCN.)

-Residential - $2.00 / watt (CEC)

-Schools - $4.00 / watt (CEC)

-Public Buildings - $4.00 / watt (CEC)

4.First Come First Serve Rolling Applications

I like the idea that others have posted that customers can apply immediately for the rebate. This streamlines the process for both customer and contractor. In my experience working with customers, it would help customers immensely in completing a solar power system project if they could, at anytime, initially expressing interest and receive their rebate in a timely fashion.
Assemblyman Bobzien. Thank you for this innovative and important new way to communicate with our State Legislative process. I was part of the early editions of Solar Generations during my tenure as the Director of Energy Efficiency and Conservation for Nevada Power and Sierra Pacific Power (now NV Energy) from 2001 through mid 2006. And having spent time on the Nevada State Task Force for Renewable Energy and Energy conservation., we struggled with balancing market forces with customer expectations and needs. I remind the group that in early 2003 after Las Vegas Solar Electric went out of business, the State had zero qualified electrical contractors doing solar work. We needed the early versions of Solar Generations to build contractor capabilites as well as customer interest and action. I submit that Solar Generations has been very successful in accomplishing this.

I have a suggestion. In my experience, now going on 35 years in the energy field, one underlying fact has not changed. Consumers want immediate satisfaction from their purchases. As has been stated a couple of times, SolarGenerations and the imbedded process precludes that.

My suggestion is, go big, set your yearly targets to something just beyond, the expected market for the new solar residential and commercial installations. Set your rebates at the value to achieve this penetration and get out of the way. In a stretch of good market transformation, allow the utility to recover all rebates paid for under qualifed installed projects. Reduce paperwork and process review.

And most importantly think about the end use customer in developing your new process. It is ok for SolarGenerations to sunset. We simply needed it in 2002, 2003 and 2004 to get this market moving. I think it has.

Step 1- develop detailed market study- what is the potential MW of customer installed solar based on a couple of rebate values.

Step 2- set your yearly targets just beyond that market threshold

Step 3- allow the hosting utility to recover 100% of the rebates and continue to allow installed capacity to count towards the RPS requirements- this will be small dollars compared to their expected investment in natural gas power plants and utility sized renewable energy projects and associated transmission lines

Step 4- Qualify contractors, set basic standards for inverters, pv panels and expected yearly maintenance or production-- for long term value, we need continued long term production.

Step 5- Get out of the way of the market forces working well.

Thank you for the opportunity to comment

Robert Balzar

8997 Opus Drive

Las Vegas, Nevada, 89117
I would like to thank Assemblyman Bobzien for creating this forum. This is such a cool way for us to communicate our ideas.

I believe the intent of the original legislation had many objectives.

-To create a sustainable renewable energy (RE) industry in the state. By doing so you would have a group of Nevada companies hiring Nevada labor wich in turn creates jobs and increases the tax base through sales tax, employee head tax and siting of business operations in Nevada creating potential property taxes.

-To systematically lower the cost through the devolopement of that industry.

-To create awarenes and exposure of RE.

-To produce renewable energy in the state for the state.

That being said, I think there are a few things that would make this succesful program even better.

-Capacity is tied up by potential participants that are not building. Create a methodology to remove non performing applicants.

-Eliminate any application period.

-Increase capacity.

-Give Task Force the ability to move capacity and individual limit as it sees fit.

-The Task Force should have the ability and responsibility to make best effort to ensure that any applicants are in compliance with existing NRS before application is accepted and/ or approved. This would help protect the rate payer, encourage safe installations and foster an environment were businesses would operate on a more level playing field.

-Fix the level of rebate at its projected level of $4 a watt for schools and public buildings and $2 a watt for private. This would make program years appear seamless and help to create a constant rolling application period.

-The Task Force should have the ability to modify policies and procedures if it is not in conflict with PUCN or legislature.

-Mandate access to status of application from applicant.

These are a few ideas from someone who has dealt with every aspect of this program as a customer and a contractor. I look forward to any suggestions or comments from the other participants.

Thanks,

hris

SolarGenerations Recommended Program Improvements

- Objective:

Increase the percentage of SolarGenerations rebate allocations.

- Assumptions and Facts:

- Categories and Current Capacity Caps.

Residential and Small Commercial - 1000 KW

Public Buildings - 760 KW

Schools - 2000 KW

- Current Incentive Level

Residential / Small Commercial $2.30 / watt

- Up to 5KW (CEC Rated) residential. PY6

- Up to 30KW (CEC Rated) small business. PY6

- Declines $.20 / yr for next 4 years (end of program)

Schools $4.60 / watt

- Up to 50 KW (CEC Rated) PY6.

"unless the Commission determines that approval of a solar energy system with a greater generating capacity is more practical for a

particular school property." (NRS 701B.260)

- Declines $.40 / yr for next 4 years (end of program)

Public Buildings $4.60 / watt

- Up to 30 KW (CEC Rated). PY6

- Declines $.40 / yr for next 4 years (end of program)

- Schedule

- Program Year; July 1st June 30th.

- Application Opportunities are once per year and fill up in less than 1 hour, 1st Come 1st Serve.

- Current Timeline (from customer interest to SolarGenerations Approval)

- Minimum 6 months

- Maximum 20 months

- Current Customer Participation (Applications)

- PY1 - .632 MW

- PY2 - 1.4 MW

- PY3 - 4.8 MW

- PY4 - 7.6MW

- PY5 - 10 MW

- PY6 - 9.3 MW

- Contractor Training

- Approval Notification

- Customer Qualification

- 3rd party Ownership

- Discussion of Findings and Analysis:

The SolarGenerations Program is a major contributing factor to the development of Solar PV Power Systems for homeowners in Nevada. Few if any residential / small business projects are constructed without the SolarGenerations rebate. The SolarGenerations program is contractor driven, meaning that the program relies heavily on contractor participation, education, and communication to potential participants. There is a tremendous amount of interest in the program, as demonstrated by the quantity of applications in recent years. Homeowners are able to submit an application online, although these applications are usually submitted by contractors who have more knowledge about the process and procedures. Recently the program has filled up in less than 1 hour of opening the application opportunities. This can put tremendous amount of pressure on contractors to submit applications for an entire year of business opportunities in less than 1 hour time. Currently the wait time from customer interest to getting a SolarGenerations approval letter is 6 -20 months. During this time prices on many Solar PV System components could go up or down, adjusting the Solar PV Power System cost up or down 5%-15%. There is no current motivation for a contractor to deliver a firm proposal until the customer has received the SolarGenerations approval letter. This is because the customer is not likely to build a Solar PV Power System until they receive a SolarGenerations rebate approval letter, and prices are subject to change before notice of a SolarGenerations rebate approval.

The SolarGenerations program is held hostage by customer action. Under current policies customers can tie-up rebate allocations for up to 12 months without a commitment to building the project. The SolarGenerations team has made progress in this area by motivating customers to meet milestones or forfeit their rebate.

Another major concern of the SolarGenerations program is the inability to develop projects in the School and Public Building Category. Both categories have a rebate level twice that of residential and small business but have not installed nearly the capacity of the residential / small business category.

- Conclusion:

Currently some customers wait as much as 20 months under current program policies. An Open Rolling On-Line application process would maintain the first come, first serve approach and likely result in full allocation of all residential / small business rebates at each level quicker than the current once a year application process.

The SolarGenerations program will benefit from Contractors actively qualifying customers before submitting an application. By successfully qualifying the customer, there is a greater chance the project will be built. This will also eliminate customers from reserving allotment allocation with little or no intention to build. Contractors need to be motivated for this to happen. With an Open Rolling On-Line application process contractors would be more likely to qualify the customer before submitting an application. At the beginning of this strategy the wait times would be long, but as projects are developed or withdrawn wait times are expected to be reduced.

Solar PV Power System projects for schools are not going to be developed without a larger contribution to installation cost. There have been few School projects developed over the first 5 years of the program, and incentive levels are scheduled to decline in the coming years. It is not likely that the declining incentive level will result in development of more projects.



- Recommendations:

- Continue the first come first serve approach with an Open Rolling On-line application process.

- Increase the Solar Program Capacity Caps to be more in line with current market demand / interest. This should be evaluated by the Legislature every two years with recommendations from the Task Force and the PUCN.

- Residential 5,000 KW (CEC Rated)

- Schools 2,000 KW (CEC Rated)

- Public Buildings 1,000 KW (CEC Rated)

- Eliminate the customer perceived connection between program year applications and program year allotments.

- Lock the Incentive Level; this should be evaluated by the Legislature every two years with recommendations from the Task Force and the

PUCN.

- Residential - $2.00 / watt (CEC Rated)

- Schools - $4.00 / watt (CEC Rated)

- Public Buildings - $4.00 / watt (CEC Rated)

- Modify individual project caps

- Residential 5KW (CEC Rated)

- Small Business 30KW (CEC Rated)

- Public Building 50KW (CEC Rated)

- Schools 100 KW (CEC Rated)

- Allow customers to apply for a second rebate after first project has been complete.

- Notify contractors, as well as customers, of approval when contractors submit the application. This is a contractor driven program where contractors are often the point of contact for the customer in the development of the solar project. Notifying the contractor listed on the application will give contractors, who have invested in developing the project, a better chance to complete the project.

- Implement New SolarGenerations Milestones, from notice of approval.

- Residential / Small Business - 60 days (secure contract for installation), 180 days (complete installation).

- Schools / Public Buildings 180 days (secure contract for installation), 540 days (complete installation).

- Conduct annual SolarGenerations contractor seminars in both Reno and Las Vegas. The goal of these seminars should be to educate contractors on the processes and procedures of the SolarGenerations program to include but not limited to Renewable Generations Applications, Permitting, Net-Metering, and Utility Codes. The goal should not be to train contractors on installation of Solar PV Power Systems, there are currently training programs in both northern and southern Nevada along with manufacturer product specific training that address this concern.

- Investigate modifying the school category. Schools have been unsuccessful in developing projects with the current strategy. One

recommendation would be to provide a grant to schools that would cover nearly all of the installation cost for a Solar PV Power System.

- Contracts for Schools and Public Building should be subject to current NRS regulations.

- NRS 332 Purchasing: Local Governments.

- NRS 333 Purchasing: State

- NRS 338 Public Works

- NRS 618 Occupational Safety and Health

- NRS 701B Renewable Energy Programs.

- Develop a Qualified Contractor Standard and maintain an active SolarGenerations contractor list for customers to contact.

- Current State of Nevada C-2 contractor license.

- Current Nevada OSHA PV Installers license.

- Current N.A.B.C.E.P. Certification

- Completed SolarGenerations Policies and Procedures Contractor Training.

- Investigate how 3rd party ownership will be allowed to participate. Should contractors who are leasing equipment to homeowners based on KWhr production qualify for the SolarGenerations rebate? Often times the a 3rd party owner will have more than 500 employees, and therefore are not qualified applicants for the program. It is assumed that a 3rd party owner would pursue owning and operating more than one Solar PV Power System each program year. Why should a 3rd party owner have the ability to get more than one application and / or rebate per year when homeowners and small business that would own and operate the Solar PV Power System themselves would only qualify for one application and / or rebate per year.

I would like to take this opportunity to thank Assemblyman Bobzien, for allowing me the chance to share my suggestions for increasing the percentage of SolarGenerations Rebate allocations. This program has the opportunity to be a significant economic driver for the State of Nevada.

Bo Balzar