Welcome to the
Run on Sun Monthly Newsletter
In this Issue: |
March, 2010
Volume: 1 Issue: 3
The Solar Bill of Rights - Rights 7 and 8The last two of the eight Rights in the Solar Bill of Rights once again focus on the rights of consumers. Here is number Seven: 7. Americans have the right to buy solar electricity from their utility. As utilities operate under Renewable Portfolio Standards they are required to purchase increasing amounts of renewable energy. Utility customers should be allowed to purchase the renewable energy of their choosing, thereby voting with their dollars for the energy source that they prefer. Some utilities, such as Pasadena Water & Power, have a "Green Energy" option that allows customers to purchase some or all of their electricity from renewables, but it does not allow them to choose solar specifically (and right now PWP's "green power" offering appears to be solely wind power). By allowing consumers a choice, utilities would receive a premium for providing solar energy which can then be used to fund incentives for adding solar, thereby increasing the supply. It would also let consumers proclaim their desire to avoid using coal-fired electricity. Keeping the best and most important Right for last, SEIA's Solar Bill of Rights concludes with Right # 8: 8. Americans have the right, and should expect, the highest ethical treatment from the solar industry. Beyond a shadow of a doubt, this is the most important Solar Right of all if we are to build an industry that is respected and trusted by consumers throughout this country. This should almost go without saying - and yet, saying it, and living it, is extremely important. As we have seen time and again, there are many solar installers out there who care way more about making a sale than they do about building a reliable system that will meet the customer's needs for the next 25 years. (As you can see here.) But what does ethical treatment really mean? We think there are some very important elements that together constitute this Right, including:
These are reasonable requests for consumers (and America in general) to make of the solar industry. As professionals in a rapidly expanding field, we need to hold ourselves to the highest standards, and hold others in our field accountable when they do not measure up. Otherwise, all of us will be diminished by the acts of the fly-by-night artists and scammers -- and the entire nation will suffer. |
Americans have
the
Right,
and should expect,
the highest
ethical
treatment
from
the Solar Industry...
AB 920 Notices Raise QuestionsAs expected, AB 920 Notices started to arrive in customer mailboxes this week. Unfortunately, the notices from Pasadena Water and Power and Southern California Edison raised as many questions as they answered. We will start with the Notice from PWP and turn to SCE's below. PWP's AB 920 NoticePWP's Notice mailing consists of a letter to the customer, a form for the customer to fill out and return, and a set of "Frequently Asked Questions." The Notice letter gives some background on the law, informs the customer that there is no deadline for submitting the form, but then points out that: You will not receive any compensation for net surplus electricity generated prior to PWP's receipt of your election form. Frankly, this is just silly. Since the election form only provides two options - Yes I want to get paid or No I don't - is there really any mystery what customers want here? Why should the customer lose one month (or more) of credit while the utility waits to receive an "election" form the outcome of which is a foregone conclusion? Unfortunately, that is the way the legislature (in its infinite wisdom) wrote the law. Thus, the lesson for customers is clear - get your forms in TODAY! PWP goes on to advise customers that the compensation rate is "currently under review by PWP" and that the City Council will conduct a public hearing on the compensation rate sometime this year. While PWP encourages customers to "attend or submit comments" on the proposed rate structure, apparently they intend to leave it to the customers to monitor the city's website to determine when that hearing will be held. Why? Clearly PWP will have that information and they are requesting contact emails on their AB 920 forms. So why isn't PWP promising to notify customers in advance of the hearing so that they can more readily participate? Question # 1 for our friends at PWP. What will that compensation structure look like? PWP is not disclosing anything about its current thinking in this Notice. However, the statute does provide some guidance: The net surplus electricity compensation valuation shall be established so as to provide the net surplus customer-generator just and reasonable compensation for the value of net surplus electricity, while leaving other ratepayers unaffected. The ratemaking authority shall determine whether the compensation will include, where appropriate justification exists, either or both of the following components:(i) The value of the electricity itself.(ii) The value of the renewable attributes of the electricity.AB 920 - codified at PUC § 2827 (h)(4)(A). This means that the statute leaves it to the discretion of PWP and the Pasadena City Council to determine what "just and fair compensation" shall mean, and whether it will include the value of the RECs that PWP is receiving. All the more reason for customers to be involved in this process! The AB 920 "Net Surplus Electricity Compensation Request Form" is reasonably straight-forward. If the customer elects Option A to receive compensation under the to be determined compensation structure, they also assign to PWP any associated renewable energy credits that PWP can then use to meet its compliance obligations under the state's renewable portfolio standard. This is in accordance with AB 920 itself, and since such credit would be of little value to residential customers, this seems like a fair trade-off. However, as noted above, the value of those credits should be considered when the compensation rate is established. Curiously, the Option B choice - "I prefer not to receive compensation for net surplus electricity" - says nothing about PWP's obligation to carry the credit forward. In the words of the statute, option B is to choose to "allow the eligible customer-generator to apply the net surplus electricity as a credit for kilowatt hours subsequently supplied by the electric utility to the surplus customer-generator." Presumably, an election of Option B does not transfer any RECs to the utility. For customers with very large systems, there may be some benefit in taking this election. The most puzzling document in the Notice mailing has got to be the list of Frequently Asked Questions. While the majority of this document is not surprising, the last question and answer is startling: Q. Can I increase the size of my solar PV system to generate more Net Surplus Electricity? A. No. Eligible systems must be designed to meet no more than 100% of a customer's historical electric use. Really? To the best of our knowledge, there is nothing in AB 920 that imposes such a limitation. While PWP may elect to cap rebate payments to systems sized at 100% of prior usage, that has nothing to do with compensation requirements to a surplus energy producer under AB 920. As we understand the law, a customer under an existing net metering agreement who opts for Option A under AB 920, could expand their system so as to increase their surplus energy production and PWP would be obligated to pay them for that additional energy production. We would hasten to add that this is almost certainly not a cost-effective thing to do as the compensation rate will almost certainly be too low to provide a meaningful rate of return on the added investment. But that is not at all the same thing as saying that the system must not exceed 100% of the historical usage. Yet another question for PWP! SCE's AB 920 NoticeAs to SCE's Notice, our concerns include: 1) While the law calls for the customer to opt-in to the program, SCE is doing that for you, unless you opt out. But they are not doing so immediately; rather, they are waiting until your annual "relevant period" (i.e., the anniversary of you becoming a solar customer) expires before doing so. Why would they approach the program this way? SCE doesn't explain their reasoning; however, since customers who participate provide the renewable energy credits to SCE, this may be a way for SCE to count the customer's production toward their renewable energy portfolio requirements now but not pay until later! 2) The form allows for an opt-out choice - however, contrary to AB 920, the form does not make clear that the customer is entitled to roll their surplus energy credits over into the next "relevant period." We will be asking the SCE folks for clarification on this point. 3) The form also allows customers to reset their "relevant period" and begin accumulating credits toward a future payment now. While the form asserts that if you do this "any surplus energy remaining under your current relevant period is forfeited," it appears that will be the case whenever the transition to the AB 920 accounting procedure is adopted. So what should you do? If you are currently carrying a very large surplus and your historic usage suggests that you will be reducing that over the next months, it probably makes sense to wait. (You need not wait, however, for SCE's chosen time to switch - you may make that election at any time this year.) On the other hand, if your surplus now is small, it almost certainly will be to your benefit to submit the form now and start accumulating credits that will result in an actual payment. If you have questions about what to do, you may contact us for help or call SCE's customer service (we would love to hear how that goes!) Here are the phone numbers: SCE Residential Solar Customers: 866-701-7868 |
AB 811 UpdateLA County continues to make progress toward implementing their AB 811/PACE program. The latest bi-monthly implementation report to the Board of Supervisors is here. Some highlights from the report, after the break. Some key milestones ahead, according to the report:
The County reports having met with the following Cities and Council of Governments (COGs) as part of its outreach efforts:
Grant support for AB 811 - the County has sought some $26 million in grant funding from the California Energy Commission. The County is also seeking some $30 million out of a statewide pool of some $75 million being sought from the federal government as an EECBG (Energy Efficiency and Conservation Block Grant). We will report on the status of those awards - and their impact on the program - as soon as we learn more. |