SOLAR TODAY - July/August 2011

a call for

Comprehensive Planning

40 July/August 2011 SOLAR TODAY solartoday.org As the demand for renewable energy grows and more states are adopting or expanding their renewable port- folio standards (RPS), the types and size of projects are becoming more diverse. In particular, more developers are demonstrating an interest in smaller wholesale PV projects up to 20 megawatts (MW). In certain cases, projects at this scale offer environmental, grid and pricing benefits that may make them more attractive than larger utility-scale projects and smaller rooftop installations.

In response to this burgeoning interest, states have begun to implement programs to require utilities to procure power from projects of this size. California has established programs to develop nearly 3,000 MW during the next few years for projects up to 20 MW. Arizona has launched a program comprising 75 MW from projects between 2 and 15 M W, Hawaii’s feed-in tariff is designed for projects up to 5 MW, and Colorado has developed a carve-out in its RPS targeting distributed-generation projects up to 30 MW. Some of these programs operate on aggressive timeframes.

Proponents of distributed-generation projects in the up-to-20-MW range highlight that these systems have the potential to be sited closer to the load they will serve, can more easily interconnect directly to the distribution grid and may obviate some of the transmission-line upgrades necessitated by larger projects. In addition, they can offer significantly reduced environmental harm when compared to so-called utility-scale projects of 500 MW or more per site. They also are more likely to reuse degraded sites, including low-value, previously disturbed farmland, brownfields with soil contamination and remediated landfills.

The reality, however, is that projects near-
ing 20 MW still require a significant amount of
land — project sites are generally in the 150-acre
range. They are subject to the same environmen-
tal regulations and other permitting require-
ments that apply to much bigger projects. Fur-
thermore, they are not always proposed on sites
that make it possible for their purported benefits
to be realized. Thus, in order to meet the ambi-
tious procurement goals that states are setting
for distributed generation, it is important that
we fully consider and plan for the implications
of permitting these projects. Using California
as an example, this article identifies proposed
approaches to help ensure the permitting pro-
cess goes smoothly for developers and the com-
munities where the projects are sited.

in that region. While some of the work done by the DRECP can help to inform the process for siting distributed resources, the plans will apply only to projects on federal lands.

Distributed-generation projects are outside the jurisdiction of the CEC and are less likely to be sited on public lands. Thus, the lead agency for environmental review is normally the city or county where the project is located. There are advantages to local reviews, but certain agencies may not be prepared to process the quantity of applications that they are likely to receive during the coming year. They also do not act as “ one-stop shops” for permitting, so projects have to seek permits from the various other state and federal agencies involved.

In order to avoid extensive public controver-sies, to ensure siting of solar facilities in environmentally and culturally responsible locations and to promote efficient processing of solar applications, cities and counties in California and elsewhere will benefit from initiating a broader planning process. Comprehensive planning can identify the appropriate locations for renewable energy, the procedures that will apply for reviewing permit applications and the relevant fees. It also will invite public participation, so that the community can feel comfortable with the projects that result.

coordinating the Permitting Process

One key difference between the major utility-scale projects that have been sited to date and the distributed-generation projects discussed herein is the way the permitting process is coordinated. A centralized decision-making body often has been responsible for coordinating the review of traditional power plants and larger utility-scale projects. For example, for thermal projects larger than 50 M W in California, the California Energy Commission (CEC) conducts the environmental review process, and it has statutory authority to handle all aspects of permitting, including local, state and even some federal permits.

For projects on public lands, the Bureau of Land Management acts as the lead agency for federal environmental review. State and local permits still need to be obtained, but there has been a concerted effort to coordinate the review process thanks to state and federal directives related to renewable energy goals. For example, California has been working with the federal government on a Desert Renewable Energy Conservation Plan (DRECP) that seeks to “provide binding, long-term endangered species permit assurances and facilitate renewable energy project review and approval processes.” (See drecp. org/about/ index.html.) The DRECP has coordinated the various state and federal permitting agencies to develop a coherent set of best practices and policies that can be applied to projects

applying advance Planning
in Key areas

The following sections discuss some of the entitlement processes where comprehensive planning might be particularly useful.

Distributed-generation projects up to 20 megawatts can have great environmental, grid and pricing advantages over utility-scale projects. however, these projects still require a significant amount of land. They are subject to the same permitting requirements that apply to bigger projects.