Energy Issues



Position on LADWP's LA 100 Study

There is an issue before the LADWP that could affect its ability to compete with other Power Providers.

The City Council has instructed the Department of Water and Power to prepare a Strategic Long Term Resources Plan that achieves 100% carbon-free energy by 2035, in a way that is equitable and has minimal adverse impact on ratepayers.   (carbon free: A zero-carbon city runs entirely on renewable energy, it has no carbon footprint.)  While this instruction does not require the Department to adopt the plan, it is a clear indication of the wishes of the City Council.

The Water & Power Associates Board is advocating for a Carbon Neutral by 2045 plan.  (carbon neutral: A state of net-zero carbon dioxide emissions.)  This can be achieved by balancing emissions of carbon dioxide with its removal (often through carbon offsetting) or by eliminating emissions from society.  This is the policy established by the California legislature that covers all power entities in California.

The Board of the Water & Power Associates, has developed the following position paper expressing concerns over this proposal and recommending that LADWP adopt a more prudent, yet still very aggressive policy, that while fraught with unknowns and risks, join California in striving to achieve carbon-neutrality by year 2045.


Water & Power Associates, Inc.
Concerns regarding CARBON-FREE 2035
and recommendation for CARBON-NEUTRAL 2045


On March 9, 2022, The Los Angeles City Council instructed the Department of Water and Power to prepare a Strategic Long Term Resources Plan that achieves 100% carbon-free energy by 2035, in a way that is equitable and has minimal adverse impact on ratepayers.   While this does not require the Department to adopt the plan, it is a clear indication of the wishes of the City Council.

Implementing this requirement would be extremely expensive and the costs to LADWP customers would be unsustainable.  This is unacceptable.

A more prudent challenge, yet still very aggressive and fraught with unknowns and risks, is to join California in striving to achieve carbon-neutrality by year 2045. 

This has many advantages:

•          Since renewable generation is so capital intensive, being able to partner with like-minded entities on projects should be a very high priority. This would allow us to add to our clean generation assets and lower front-end costs, helping us to maintain rate parity.

•          Getting carbonless generation to our customers involves the western States. This generation will most likely be in remote locations, requiring upgrades to the western States grid, especially to CA load centers. This will require close coordination with CAISO and implementation of their 20-year Transmission Plan. This will also be very expensive, partnering being vitally important. We must also add to that cost the substantial expense of upgrading our L.A. basin transmission to reliably accommodate local renewable generation, which is an expense LADWP must shoulder alone.

•          And don’t forget the third element of our power system—the Distribution System. This often neglected, less glamourous, but absolutely vital part is in serious need of attention and upgrading.

•          Strategizing to a carbon-neutral 2045 would give us opportunities to cooperate and coordinate with like-minded, affected entities.  The City Council motion for carbon-free power by 2035, being essentially 10 years ahead of everyone else, most likely wouldn’t allow this to happen.

•          A carbon-neutral 2045 would allow time for research and innovation to develop new technologies, for these technologies to evolve pilot projects, be designed to scale, and built and operational by the 2045 goal. This would relieve LADWP from intense pressure to do this essentially on our own by 2035.

•          LADWP has a long, successful history of partnering with other entities to our benefit. Examples are Hoover Dam, the Pacific DC Intertie, and the Intermountain Power Project.


September 1, 2022



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Ratepayer Impacts of LA100 Proposel




Position on LADWP's LA 100 Study

LADWP has recently published the Final Report of its LA 100 Study which is a feasibility study performed by the National Renewable Energy Lab to assess four possible pathways for LADWP to become a 100% renewable energy provider. Water and Power Associates, Inc. (WPA) has reviewed the Report in detail and offers City Leaders the following recommendations.

WPA conditionally supports the early achievement date of 2035, not withstanding the increased costs and unproven technology, because of the urgency of the situation and proposed governmental mandates.   This support is conditioned upon the establishment of metrics to measure the necessary progress towards the goal along with a commitment to revise the goal if the metrics are not being met.

The Study finds that the earlier the 100% target is reached, the more expensive the transition becomes. For example, if the 100% target is reached by 2035, the cost will be 50% higher than the least expensive 2045 pathway because the hydrogen fuel technology and its supporting infrastructure that replaces natural gas may not be fully mature by 2035. Also, prices for solar and battery storage are projected to continue to fall between 2035 and 2045 resulting in a cost savings if the target year is deferred.  Furthermore, a 2035 target contradicts the LA 100’s environmental justice goal by negatively and disproportionately affecting low-income communities because of the higher cost of energy that will result.

Regardless of the pathway considered, the Study finds reaching about 90% of the energy consumption can be feasibly and reliably met by developing more geothermal, wind, solar, and energy storage sources both internal and external to the LA Basin. WPA recommends aggressively pursuing these renewable sources. There is a finite number of sites suitable for development that are reasonably close to connection points in LADWP’s transmission system, so the sooner the sites are developed, the better. Transmission costs will increase, if the only remaining sites are distant from existing LADWP transmission facilities. Although costs of solar and battery energy storage will almost certainly decrease over time, this cost reduction will likely be offset by increased transmission costs unless LADWP acts quickly.

The Study finds the “final 10%” of annual energy must be met by in-basin hydrogen-based generation, which will require repowering some of the existing natural gas facilities with technology which is not fully proved.   This 10% plugs the reliability gaps that renewables cannot fill during times when, for example, winter rains impact and reduce local and external solar or brush fires take out transmission lines.  WPA supports the long-term goal of fueling these turbines with hydrogen, but strongly recommends maintaining existing gas-fired generation in the LA Basin as long as necessary to successfully transition to hydrogen. LADWP’s local gas-fired generation is one of the main reasons LADWP has maintained its reliability while other areas of the state experienced blackouts.

The Study finds that in order to maintain the current level of reliability, critical upgrades must be made to the existing LADWP transmission system. WPA supports these upgrades and therein lies another reason for keeping local gas-fired generation available as long as possible. Transmission lines must be removed from service to be upgraded, a process that can take several months to complete. The absence of these lines weakens the local transmission system and exposes customers to reduced reliability unless local gas-fired generators remain available.

WPA believes the strategy outlined above will create a new renewable energy system with an acceptable cost, will first tackle the problems involving the longest lead-times such as renewable siting and permitting, and will maintain the high reliability on which LADWP customers have come to depend.

Yours truly,

Gerald A. Gewe
President,  Water and Power Associates


The above letter was sent to:

Mayor Garcetti
All LA City Council Members
ALL the LADWP Commissioners
Valley Industry & Commerce Association
LA Chamber of Commerce
Building Industry Association of Southern California
Martin Adams - General Manager of LADWP


May 15, 2021


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Ensure Grid Reliability During the Transition to a Clean Energy Future


       The Water and Power Associates supports the City’s goal of a 100% clean energy supply, and we believe the plan put forth by LADWP management is critical to maintaining reliable electric service during the challenging transition period ahead. The Water and Power Associates, a 501(c)4 non-profit corporation, was established in 1971 to inform and educate its members, public officials and the general public on critical water and energy issues affecting the citizens of Los Angeles, Southern California and the State of California.  Our members have decades of experience and understand the complexity of the electric grid, physical assets and operational practices which ensure service to residents and businesses day in and day out, regardless of most foreseeable contingencies.

          Customers expect an endless supply of electric energy at their homes or businesses, whenever they turn on a switch, start an air conditioner, or plug in an electric vehicle.  And utilities have an obligation to serve, and must build, operate, maintain or procure all the wires, equipment, and generation needed to serve demand.  All of these assets require large capital investments, have long lead times to implement, and often face various degrees of opposition.  Few people are aware that when California experiences several days of state-wide prolonged heat, referred to as heat storms by grid operators, that on such days the wind rarely blows, yet power demand reaches peak levels.

          State mandated “Once-Through Cooling” regulations necessitate the replacement of existing coastal generation units.  After numerous studies by experts in the field, staff recommended building new, lower-emitting natural gas fueled generation in the southern areas of the LADWP service area.  Some environmental advocates, with a singular focus on implementing renewable power, have opposed this approach.  The studies, however, found this to be the only feasible option for maintaining electric reliability.  Other options, such as building additional High Voltage transmission which would take decades, are not feasible and do not address the need for local generation for grid stability and voltage support.  Battery storage is not feasible due to space requirements for the capacity needed, is not cost effective today, and has its own environmental impacts, such as hazardous waste disposal.  Natural gas generation will provide the required flexibility to start or stop in order to coordinate with the variable output of wind and solar resources, and eliminate the possibility of energy brownouts with adverse impacts on the safety and wellbeing of LADWP’s customers.  Also keep in mind that natural gas generation may be able to bridge to hydrogen fuel as technology and delivery systems develop over time.

           The transition to Clean Energy is complex and will take time.  Staff has performed the necessary planning studies and processes involving myriad stakeholders.  The Associates urge you to consider the information that has been assembled with the careful evaluation of options and support the LADWP staff recommendation.


February 10, 2019


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Position Letter on Solar Feed in Tariff (FiT)


The Los Angeles Board of Water and Power Commissioners
111 N. Hope Street
Los Angeles, California 90012


Re:  Board of Water and Power Commissioners Action regarding Solar Feed in Tariffs



It is the understanding of the Water and Power Associates that the duty of the Rate Payer Advocate is to provide independent analysis to the Board on its actions that will, among other things, affect rates.

It is the Associates further understanding that Mr. Fred Pickel, the Rate Payer Advocate, has recommended to the Board of Commissioners that it delay the pricing guidelines for LADWP’s Solar Feed in Tariff (FiT) program until there is a more adequate understanding of its impacts on the citizens of the City and the Department of Water and Power.

However, the Board, at its June 20, 2013 meeting, elected to set aside the Rate Payer Advocate’s recommendation on the FiT program , despite what appears to be strong evidence that the costs are not consistent with ( i.e. significantly higher than) other FiT programs in California.  

The Associates are not privy to all the facts or discussions that led to the  Board’s decision but believe that decision may well  have long-term consequences on the increasing cost of electricity for the City’s ratepayers, its residents and businesses.

In light of other significant costs that will compel the Department's Power System to seek increases  to the electric rates over the next few years, we believe that before the ratepayers are asked to pay the bill they deserve to have full disclosure of the benefits and costs of the FiT program.

Accordingly, we recommend that your Board, as public policy and prior to the award of any contracts under the FiT program, be thoroughly briefed by Department management on the issues raised by the Rate Payer Advocate.




Edward A. Schlotman, President 

Water and Power Associates, Inc.


Cc: Fred Pickel                                                
DWP GM                                                       
Sr. Assist GM, Power
City Council

July 1, 2013


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Position on Once-Through Cooling


Click HERE for W&PA's position on State Lands Commission Proposed Rule on Once-Through Cooling