Utility raids CEC rebate funds for 5 MW solar project [RE-wrenches]

[mlafferty at universalenergies.com]

FIRST AMMENDMENT DISCLAIMER:  THE ORIGINAL TEXT, CONTENT, INTENT,
"INTELLECTUAL PROPERTY RIGHTS", AND RESPONSIBILITY THEREFORE ARE HEREBY
RESERVED AND ACCEPTED BY MYSELF PERSONALLY, WITH PREJUDICE.... 

(Bottom line: What follows is from me, by me, and in no way is intended
to be construed as related to, on behalf of, or in affiliation with any
organization or group I may or may not be associated with.... Just me...
Nothing more...)

All:

First of all, I was one of a bunch of us at the CPUC hearing last
Thursday.  About a dozen of us spoke on the record in opposition to this
piece of BS.  I've spent many hours since (as have a couple others we
know), digging in the mud for the facts and relationships "beneath the
surface"... I'm not done with the issue yet, but will withold my
"comments" regarding the "to-date" findings for a future time... Please
understand the complexities and sensitivities involved here!
(Personally, I can't wait to scream from the rooftops!  Biting my tongue
is something I've had to learn, but still don't like to do!)

The "project" in question is not technically being "installed" by a
utility.  Nor is it purported to be "owned" by them.  It is a
"green-power" purchase contract... At least that's the way it's being
touted and "sold"... The premise is that the entity/entities involved
will develop and maintain the facility while selling the power to SCE.
Much appears to be amiss with this "project", but the "tracks" appear to
be fairly well covered and not "on the surface" so far.  Preliminary
2-Cents.

Some suspected and perhaps related "fallout" is being witnessed today in
SCE's territory by at least of couple of Wrenches that I've heard from.
My suspicion is that this is directly tied to and timed to coincide with
the CPUC's vote last week.

Throw it out there, guys!  Did I correctly hear that SCE is notifying PV
Contractors that "Your systems will be locked out for non-compliance
with our new 'policy'?"  Hmmmm?  Is that the new policy that says, "SCE
must receive a copy of a signed-off final building permit within 30 days
of your application."????  

Let me get this right... 

You can't be approved for CEC Buydown Reservation funds until you've got
an approved Interconnection Agreement form from the Utility (Right or
Wrong????)

The time period from Utility Application Submittal to "I've received the
Agreement", assuming everything is "correct" on the application, is like
at least two weeks (Right or Wrong????)

The time period from Interconnection Agreement Receipt to CEC
Reservation Confirmation Receipt is currently running in excess of 4
months (Right or Wrong????)

Any "reasonable person" (A valid and long-standing legal standard, by
the way... Don't forget that for the future!  We may need to refer to
it!) would not apply for a building permit until after receiving the CEC
Reservation Confirmation (Right or Wrong????)

A "reasonable person" would not order the equipment until after
receiving the CEC Reservation Confirmation (Right or Wrong????)

Building permits are taking anywhere from 15 minutes to 6 or 8 weeks to
be issued (Right or Wrong????)

Equipment lead-times vary.... For the sake of "being fair", let's assume
this is only a "one-day" part of the process.... Fair enough?

Legally, work cannot begin until the building permit is issued (Right or
Wrong????)

Installation takes from, oh, let's say they are all "slam-dunks" and are
done in just one day....

Inspection scheduling and actually having it done.... Let's even assume
it happened on the day of installation.... Just to keep it in "benefit
of the doubt" status for SCE.... Fair enough?

OK.  The fastest reasonable time to expect being able to transmit a copy
of the signed off building permit to SCE is, oh, let's say you fax it to
them when you get home on the night of installation/inspection (this is
AFTER the SCE personnel are in bed....) so it is waiting for them when
they get to the office in the morning.

Are you seeing a pattern here?

Best-Case turn around, Application to Final Inspection, is like 4
Months, 3 Weeks.... Give or take about two months... All this math is
giving me a headache... 

OK.  Back to the "5 MW" thingy....

We've all smelled dead rats before... This one's alive!  Still a bad
smell!

Safety related question for the next round of CA NABCEP Certification
Exams (Tongue in cheek here!):

What is the best form of personnel protection from the hazard(s)
associated with dealing with live rats in the process of getting a
Grid-Connected PV System installed in California?

A.  Gloves
B.  Safety Footwear
C.  Eye Protection
D.  Full Body Condom
E.  Winning Lotto Ticket

(Correct answer is: E.  Winning Lotto Ticket. The benefits of Full Body
Condoms are unsubstantiated at this time!)

How in the heck is California going to meet the campaign promise of the
new Governor to have 50% of new homes built in California after 2005
include PV if the existing funds for that market segment are depleted
and there is no backup or replacement funding in place?

I believe, at least so far, that the basis for the secretive (On the
surface it also appears to be illegal!!!!!) nature of the "procurement"
process surrounding this "project" is multi-fold.... One of the most
insidious suspicions of mine is that the "powers that be" figured that
the best way to get the "Solar PV Flea Off Our Asses" was to go after
the CEC Emerging Renewables funds because, at the time the "project" was
being "dreamed up", the Self-Gen monies were expected to sunset at the
end of 2003 so they would have that "flea" terminated without effort.
Better to just "backdoor" some type of strongarm robbery a couple of
streets over (at the CEC).... And, perhaps, just pull off some "help out
your family and friends while you're at it" action.... What a way to
retire!

CPUC, CEC, DWR, SCE, IOU, CPA, State Helps Injurious Treason Agency,
UNS, TEP, ETC, FERC, IBEW, BS-R-US, DMV (How did they get involved in
this????  Just a joke, by the way.... I was sooooo hoping at least 1/2
of my tripled vehicle license fee would go directly to the CEC buydown
program.....)

I suggest that the Governor have a REAL broom-sweeping party with those
appointed officials that are charged with the duty of protecting the
Public Interest at the regulated utility level....  The CPUC
Commissioners...  (He didn't personally appoint them... You can thank
the former resident of the Governor's chair for that... They are still
his responsibility now!  Be sure you let him know that!

I further contend that, pay attention here, all persons at any level
involved with this entire "project" (public or private) that are found
to be complicit with any action(s) found to be unethical, in conflict of
interest, injurious to the public good, collusive, non-transparent,
negligent to the public trust..... Basically anything I personally would
find to be "not right".... Be prosecuted with a vengeance, yes, a
retributory vengeance, and brought to trial for their actions and
participation.

Furthermore, once found guilty of crimes against the public, penalties
and remuneration damages be awarded and collected from said individuals
and their
estates/trusts/spouses/offspring/friends/cronies/pets/neighbors/real-est
ate agents/bankers/insurance agents/doctors/attorneys/kindergarten
teachers/parents/school-bus drivers/prison-guards' union at large/former
governor Davis/.... Well, I hope you get the point here... The monies
should be directly and unequivocably placed in trust to effect the
deployment of viable, DISTRIBUTED, renewable electric generation...

While it may be "believed" that the "project" will be defeated at the
CEC, don't hold your breath.  Just because it is in excess of the 30KW
ceiling, doesn't mean that the squirrels won't somehow find a way to
turn it into a nut they can chew on for a while.  Even if it is
ultimately defeated, it has the potential to "hold-up" ALL disbursement
activity over there on 9th St. once it is pushed over there for
"consideration".... As if activity has even been observed in the last 5
months!.... When will there be true accountability at the agency level
in government?

Where will it end?  Will it ever end?  Not until more than a few "public
executions" are performed and "the fear of God and Cooperation" are
instilled in all of the parties, I'm sure!  (Don't think you get a free
pass just because you're "in Solar" if that ever happens!)

Best advice if you're doing on-grid stuff in California.... Mind your
P's and Q's...  Right now especially.  The "forces that be" are
desperate and have a LOT more money, bankrupt or not, than we do!  FACT!
We are and continue to be met at every front with obstruction and
wrongful, ever-changing "rules" and "application" of them.  It is time
that we adopt the opposition's tactics... Offensive instead of
defensive... Bluff when necessary... Keep your "Aces up your
sleeves".... Beat them with a stick when they don't accept your
"carrots"!  Just be sure to have that stick handy!

Fight like hell and take the time to keep us all posted in as close to
real-time as you can!  More ammo needed!  The "line" isn't straight and
it isn't continuous.  It is hard to follow and/or put together.  The
"Money-Trail" is smelled by several, but not conclusively proven yet.  I
believe we need to be and appear to be in solidarity... Less
fractured... More cohesive... "Bigger than we have been so far"....

We need facts!  Real-World Experiences... E-Mails, Faxes, Etc.  All of
them!  No matter how seemingly insignificant... "Little" things often
turn out to be more significant than one would expect on the surface
when put into context and fully researched and divulged!  How do you
think those "I can't believe they voted that way" verdicts are
reached???

Mere "gripes and complaints" without backup documentation don't further
the cause.  Somebody has to consolidate the "stories" out there... Real
proof...  Without it, "they" will continue to run right over us... 

There isn't really a central "repository" to collect, conslidate and
convey the message that I know of.  I know I don't have tons of time and
resources to do this personally, but will volunteer to accept and
maintain anything you guys are willing to send over.  If you have any
"don't let my name out" or whatever kinds of things like that, just
write/type it at the front.  If you choose to do so, anything you
forward to me personally will be held in the strictest of
confidentiality possible, if that helps.  

I guess I look at it like, if we are serious about survival and
sustainability then we need to realize that we need to be proactive and
not just whine about stuff so we each need to contribute where we can to
get there 'cause we sure as heck ain't there yet!   (I'm not writing a
book on the topic or anything like that...At least not for a couple more
years.... After I win that Lotto!)  

We must get started... If not now, when?  After it's too late?  

Meanwhile....

Play the Lotto!  Play the Lotto!  PLAY THE LOTTO!

Matt Lafferty
Universal Energies Institute
mlafferty at universalenergies.com
(916) 422-9772
(916) 628-7694 Cell
(916) 914-2247 Fax
www.universalenergies.com

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