California Climate Solutions achieving environmental goals + creating business opportunities

A New Solar Landscape

Improving County-Level Landscape Planning for Utility-Scale Solar PV Facilities

California is committed to achieving a greenhouse gas-free electricity grid by 2045. This landmark goal will require the deployment of a significant amount of new renewable energy facilities in the state in coming decades. In particular, the state will likely need to incorporate thousands of megawatts of new solar photovoltaic (solar PV) generation capacity into its electrical grid. The increase in solar PV generation will entail large, new facilities to be located throughout California, bringing both benefits and potential attendant conflicts over their location. County governments, which have primary land use authority over many of these decisions, along with the cities located within their boundaries, will need tools to ensure that community and environmental interests are protected while renewable energy goals are achieved. Landscape-level planning, which identifies priority mitigation and conservation areas in advance of impacts to preserve larger areas of higher habitat quality and connectivity, may be essential to the exercise of that authority in a manner that supports state priorities and environmental conservation.

California may need to add up to 100,000 acres of new solar facilities by 2030 to meet its climate targets.  SB 100 (de Leon, 2018) requires 60% renewable electricity by 2030, compared to the approximately 35% renewable energy produced in 2018. Utility-scale solar PV, which has become increasingly cheap in recent years–even out-competing traditional fossil fuels in certain areas–is already the state’s top renewable source and will be the most economical way to achieve these goals.

Up to 13 million acres of land in California may be compatible with utility-scale solar PV facilities. These lands have the right topography, are proximate to transmission lines, and are not located in environmentally protected areas. They are also often located in minimally developed or rural areas that are high in ecosystem and natural habitat value.

Local governments determine where and whether a solar PV project can be sited, but state and federal agencies, community groups, solar developers, transmission planners, and California Environmental Quality Act lawsuits all play a role in the process. Landscape-level planning, properly implemented, can help coordinate across the various interests.

Policy Needs

Policy Solutions

Increasing Local Buy-In to New Solar Projects

Build Planning Processes that Integrate Stakeholder Concerns and Deliver Benefits

State and Local Leaders

Help communities define a sufficient quantity of local land needed for solar facilities in order to meet the state’s climate goals.

By clarifying how many acres of solar coverage will be necessary statewide to meet the RPS, California Energy Commission leaders could demonstrate how relatively minimal total land coverage might be for local governments under even the most aggressive scenarios. And by helping communities translate this analysis into county-by-county estimates of land needed for development shown in clearly drawn examples, state and county officials could potentially reduce uncertainty and public opposition to further  development.

State and Industry Leaders

Assist local governments in educating their constituents about the value of optimal solar PV deployment through the provision of data and maps.

State data and analytical tools can help county landscape-level planners develop maps and talking points showing constituents different regions and landscapes and the percentage of  renewable energy that could potentially come from each area, as well as the relative environmental value of more distributed versus utility-scale deployment. Local leaders could discuss options for repowering existing sites, in order to convey how much more power is needed to achieve renewables goals and how communities can contribute. The California Energy Commission, California Department of Conservation, and California Department of Fish and Wildlife could all assist in this effort.

Industry Leaders

Identify, craft and publicize the community benefits that can accompany solar facilities, including priority and direct benefits for environmental justice communities.

Many counties and localities require developers to enter into community benefit agreements or packages that require delivery of certain minimum benefits (e.g., local employment requirements and job training) as a part of the approval process. For example, Riverside County requires developers of facilities larger than 20 megawatts to pay $150 per acre per year for each acre developed, with 25% of all fees collected going to benefit local communities; Imperial County set  voluntary guidelines of $150-200 per acre in community benefit charges for infrastructure improvement and quality of life enhancements

Local Governments

Raise sales tax revenue from new projects.

Increased revenue could ensure that local communities benefit from new solar developments and are able to link those benefits to specific projects. One strategy to ensure appropriate revenue from new developments is the use of sales taxes on solar hardware to generate revenue for community benefits.

Solar Developers

Ensure that project benefits flow first to communities most immediately affected by development.

Communities that neighbor development sites or lie along major transportation routes are most likely to experience the impacts of increased activity and exploratory and preparatory work and may be most likely to present early opposition to a proposal. Developers can work with counties and the affected local communities to explore how to improve directing mitigation and structuring benefits up front to assist those communities that are directly affected.

State and Industry Leaders

Assist local governments by providing job training funds for high school and college students and vocational training for solar installation and maintenance training programs.

The state could encourage local governments to include a similar local labor requirement for utility-scale projects or require developers to host job fairs to ensure local access to project work. State leaders could also create a solar job training program in community colleges or the California State University system, to incorporate project management and similar roles into the training apparatus.

Government and Industry Leaders

Identify appropriate parties to communicate accurate, locally appropriate messages and counter misinformation.

State leaders could prepare a compendium of common false arguments, together with sample best responses and supporting science, providing planners with a “playbook” to combat misinformation, similar to the website that the Governor’s Office of Planning and Research has prepared to fight inaccurate objections to climate change science. Such a resource could assist communities in distinguishing misinformation and increase understanding of project benefits.

Solar Developers

Conduct communication training and guidance for officials responsible for interfacing with the public on solar PV projects.

In often highly charged contexts, tensions between community character, environmental, and revenue interests can render community outreach nearly impossible task, with local governments pressed to demonstrate that they are adequately representing constituent interests while also seeking to solicit investment. Communications training for employees and staff responsible for interfacing with community members during the planning process could address this challenge.

Government and Industry Leaders

Clarify the harm of not taking action by quantifying short-term risks and benefits.

Reduced production of fossil fuel-generated electricity can provide immediate and direct benefits to local communities by reducing the risk of asthma and other negative health effects. Planners and project developers could emphasize, when proposing new projects, that addition of new solar facilities can reduce utilization of older natural gas plants, improving human health by removing harmful pollutants from the air.

State Leaders

Encourage development of local landscape-level plans by linking them to incentives like expedited review under the California Environmental Quality Act.

Since every utility-scale solar project involves permits and approvals from multiple governments and subsidiary agencies, and the use and transformation of significant quantities of land, CEQA review is a central component of any solar project planning process. Local jurisdictions that prepare comprehensive, solar development-inclusive programmatic EIRs when developing and approving general plans may allow individual projects to “tier” off the findings of the programmatic EIR. The Governor’s Office of Planning and Research, which oversees state CEQA implementation, could promote the benefits of tiered review as a means to incentivize solar landscape plan development.

State Leaders

Create a work group to assess options for reform of the current tax assessment process for solar PV and associated energy storage, including the tax exemption and tax reassessment process.

Assembly Bill 1451 (Leno, 2008) created a property tax exemption for a range of solar energy systems, including newly constructed solar PV projects. However, battery storage for solar PV is not exempt under the law. Some energy storage proponents argue that the AB 1451 exemption should extend to storage assets built on-site at solar PV facilities.

Improving Coordination among Utilities, Regulators and Land-Use and Grid Planners

Create Forums for Cross-Agency Interaction and Comprehensive Planning

County Planners

Identify government representatives at all levels (e.g., state, city, and local) to include in the planning process.

The state’s 35 regional Air Pollution Control Districts and Air Quality Management Districts, which hold the statutory mandate to manage compliance with federal and state air quality, are generally required to include city officials (such as city council members) in their management structures, which helps to ensure consensus decision-making and reduce conflict and costly delays. County planners could use the districts’ involvement of city governments as a model for improved coordination in solar planning processes.

State Legislators

Encourage and help fund local general plan elements on climate action or renewable energy.

In 2011, Assembly Bill X1-13 (V. Manuel Perez, Chapter 10, Statutes of 2011) authorized the Energy Commission to award up to $7 million in grants for certain counties to develop rules and policies that facilitate the development of eligible renewable energy resources, associated transmission facilities, and the processing of permits. The state legislature could provide more funding for counties to develop these elements, which could be a vehicle for landscape-level planning to identify the quantity and optimal locations for these facilities and coordinate additional processes.

County Planners

Prepare solar-focused permitting guidebooks.

Butte County has prepared such a guidebook in the form of its Utility-Scale Solar Guide. The guide includes key information on development and design, local and federal permitting processes, community benefits and outreach, and future innovations to consider, with process diagrams, maps and links to additional resources and key regulators’ websites. County officials around the state could facilitate streamlined permitting processes and increased public acceptance by preparing similar guidebooks.

County Leaders

Form and use existing councils of governments to coordinate planning.

Councils of governments and similar planning entities offer a regional venue for management of key public assets, providing representation of all member communities and consideration of long-term development needs and trends. Many councils of governments are already involved in small-scale energy planning via the administration of Property Assessed Clean Energy programs, such as the Western Riverside Council of Governments’ CaliforniaFirst, HERO and SAMAS programs which have facilitated access to energy efficiency and solar panel installations for millions of residential and commercial customers.

Transmission Planners

Better incorporate county-level land-use planning objectives.

The California Independent System Operator, which manages the majority of the state’s electrical grid, conducts an annual Transmission Planning Process, which includes coordination with the California Energy Commission and the California Public Utilities Commission to accurately assess system-wide electricity supply and demand and renewable energy  requirements. By explicitly adding location and land-use considerations to the core group of factors analyzed in the transmission planning process, CAISO leaders could ensure that plans developed at the local level are adequately reflected in state priorities.

California Department of Fish and Wildlife

Improve coordination of endangered species permitting and data-sharing with federal and local governments.

The state legislature could provide the Department of Fish and Wildlife with funding for increased staff capacity to coordinate with other state and federal agencies, and/or to invest in more data monitoring and analysis to increase understanding of the impacts of solar PV on key species across all levels of government and provide better recommendations for mitigation measures. The Energy Development Companion Plan, a component of the California State Wildlife Action Plan that identifies key goals for planning, collaboration, and communication around energy development planning and wildlife conservation, is a model for the increased coordination that the Department of Fish and Wildlife could promote with increased resources.

Overcoming the Mismatch Between Ideal Lands, Viable Economics, and Transmission Infrastructure

Align Transmission Planning with Solar Needs

State and Local Leaders

Increase support for transmission infrastructure located in areas appropriate for solar development.

Transmission development typically relies on committed generation projects and utility power purchase agreements, and yet it is typically planned and financed in decade-long timescales, while generation development is shorter. Transmission projects can also implicate significant environmental review and land-use concerns, as they are often placed on undeveloped land. The Renewable Energy Transmission Initiative was an effort to coalesce state transmission, environmental and renewable energy expertise in support of optimal transmission siting. In order to further this work, the state legislature could direct dedicated funding or incentives to support the proposed projects identified in the initiative report as having the potential to address key system restraints in solar-optimal counties. Alternatively, the legislature could consider authorizing new state bond issuances to fund appropriate transmission projects.

California Independent System Operator

"Right-size” transmission proposals and planning timelines and improve internal processes.

The CAISO transmission planning process is generally designed to integrate known future generation projects into the broader grid. Transmission planning typically operates on 10-year time horizons, as a means to account for projections in supply and demand and population distribution. However, the state’s long-term renewable energy goals require planning on longer timelines. And even when a discrete new solar development is not identified,transmission projects could be planned with capacity for expansion to accommodate future solar power in areas where long-term energy forecasts and state plans indicate it will necessarily be located.

Solar Developers

Increase onsite battery storage at solar PV facilities to help reduce the need for transmission upgrades.

On-site storage can serve as a buffer between capacity and production by easing peak demands on substations and transmission lines, rather than feeding all electricity produced immediately into the grid (which can place stress on existing grid resources during midday solar energy generation peak periods). This in turn can reduce the need for new transmission capacity. As storage technology becomes more efficient and affordable (and if on-site storage is granted the same tax treatment as solar PV generation, as discussed earlier), solar developers could include more of it in their projects in order to decrease demands placed on the existing grid and the need for new grid infrastructure.

County Leaders

Employ standard-based identification of suitable lands as an alternative or in addition to mapping lands for solar PV development.

Local authorities actively seek to identify sites that are
appropriately sized, located near necessary infrastructure, and not subject to land use restrictions or conflicts. However, by publicly sharing those sites explicitly or via mapping in order to attract development, these authorities can communicate market signals to land speculators and competing developers, which may raise land prices and decrease solar development prospects. One possible resolution is a hybrid system such as that employed by San Bernardino County, which supplements standards with listing of priority site types, to incorporate a rule-based approach into the inherently discretionary process of applying narrative standards.

State Leaders

Accelerate permitting processes and incentives for brownfield sites.

Brownfields can be ideally situated for utility-scale solar developments: they are often located near electrical infrastructure and other major electricity consuming facilities; they consist of relatively large, flat spaces; and solar facility installation, with its limited human maintenance and operation, represents a minimum of health risk compared to residential or other commercial uses. The state legislature could amend the California Land Reuse and Revitalization Act to reduce site investigation and remediation requirements for solar facilities, or the California Department of Toxic Substances Control, which administers the voluntary cleanup program under the Act, could fast-track approval of solar sites.

County Planners

Implement interim use plans or shorten general plan update timelines to facilitate solar PV development.

County general plans are long-term documents, as required by state law, typically operating on a 20-year horizon, presenting challenges for solar developments, which are a less mature use category than many of the traditional categories such as housing, business, industrial, or open space, and which may face longer and more uncertain planning processes due to regulatory, financing and energy market complexity. Counties could adopt interim plans in order to provide more frequent opportunities for review and revision, ensuring maximum accommodation for solar developments.

State Leaders

Explore options to increase the use of general mitigation fund banking under the California Environmental Quality Act.

Where a project is anticipated to have significant environmental impacts, appropriate mitigation measures can be difficult to design and costly to implement, and their sufficiency can be a focal point of CEQA litigation. Allowing developers to “bank” mitigation funds in advance, by determining the dollar value of the anticipated project impacts and paying that amount into a statewide or countywide fund devoted to large-scale, pre-planned mitigation projects that create an equivalent amount of public and ecosystem benefit, can relieve developers of the difficulty of identifying appropriate mitigation projects in advance, while potentially limiting the fragmented nature of some project-by-project mitigation measures. The existing Conservation and Mitigation Banking Program and Regional Conservation Investment Strategies Program are viable models for this purpose.

Governor's Office of Planning and Research

Compile and distribute a best practices solar PV planning compendium for local governments.

The Office of Planning and Research already operates the Best Practices Pilot Program, “a suite of programs and partnerships that produce replicable case studies of best practices being adopted and implemented at the local and regional level around the state” including climate action plans, high speed rail plans, and general plan updates. Preparing an equivalent resource for solar development planning could allow counties to improve their practices and increase helpful planning process uniformity around the state.

Increasing Access to Reliable and Relevant Data

Facilitate Data-Sharing and Identify Trusted Third Parties

Government, Industry, and Community Leaders

Engage in joint fact-finding to identify consensus data addressing the most contentious topics.

Local governments and developers could collectively identify the top 10 to 20 most commonly raised community issues; state energy and environmental agency staff could work with them to develop an agreed set of science-based responses that are accessible to the general public; and community leaders could then review the responses and provide feedback on content and presentation. The result would be an invaluable, statewide resource containing a trusted and broadly endorsed set of baseline data. One example of a similar resource that could serve as a model for such a joint
fact-finding enterprise is the Governor’s Office of Planning and Research’s “CA@50 Million” website.

State and County Leaders

Collaborate to create a consolidated, statewide zoning and planning data resource.

All county-level solar planning occurs in the context of local general plans and zoning ordinances. While all general plans and zoning ordinances include the same basics, they can differ significantly between jurisdictions with respect to not only the different rules for various uses and development areas, but also the underlying concepts and definitions that outline these rules. These variations can slow developers’ plans and increase legal costs. By working with county planners, councils of governments, and metropolitan planning organizations, state leaders at the Governor’s Office of Planning and Research or the California Energy Commission could develop a statewide zoning and planning data resource that consolidates the disparate local information in a readily viewable and comparable format—a “one-stop shop” to determine appropriate development sites based on permitted uses, present and future planning priorities, and solar optimality.

County Planners

Conduct scenario planning to align solar development with related considerations.

By engaging in scenario planning for solar development, county planners could evaluate the different ways in which increasing solar generation might interact with factors such as anti-sprawl initiatives, water demand, and new transportation infrastructure. For a potential model of scenario planning, counties could look to the scenario analysis that metropolitan planning organizations have undertaken as part of the process of identifying regional greenhouse gas emission target recommendations under SB 375.

Governor's Office of Planning and Research

Serve as a neutral, trusted keeper and distributor of key data in coordination with other state agencies.

Planners and developers alike seek a neutral, state-level authority to compile and publicize trusted and relevant data for all stakeholders. Such a resource could level the
informational playing field and increase trust both between governments and industry, and between community members and those proposing developments. The Governor’s Office of Planning and Research, as the state’s environmental and land use planning agency and with its extensive background in data preparation and analysis, could be the ideal entity to serve as this neutral, trusted purveyor of key solar development-related information.

Many communities still see development as a threat to community character. You won’t get everyone to agree, but if you make people know their concerns have been heard—provide helpful data, provide financial assurances that enforcement will be sufficient—you can earn community buy-in.

Renee Robin, Allen Matkins