07/22/20

  02:36:00 am, by Jim Jenal - Founder & CEO   , 407 words  
Categories: All About Solar Power, Solar Tax Incentives

How do you spell Relief: S O L A R!

United States Capitol buildingAs Congress tries to come to consensus on another stimulus package, we are focused on something that could help rebuild the economy in a greener way.  Here’s our take, and a call to action!

Congress is now back in session, and task number one is to come up with a new round of stimulus spending to try and get the economy moving again, amidst the chaos of the worst pandemic in a century.  This is a big crisis, and it calls for big and bold solutions.

Our friends over at Solar Rights Alliance are good at thinking up big ideas, and they are johnny-on-the-spot now.  Here are a couple of key concepts that should be included in the next stimulus bill:

  • Extend the federal solar tax credit - presently the federal solar investment tax credit (ITC) is set to step down from 26% to 22% at the end of this year, and expire altogether after 2022.  The ITC should be extended at the prior 30% rate through 2025.  This is vitally important as utility-sponsored rebates have disappeared in many areas, leaving the ITC as the primary economic incentive.

  • Turn the ITC into a direct cash payment for at least the next twelve months.  While tax credits are great, if you aren’t working, you can’t use a tax credit.  Direct cash payments upon completion of the project would help close the liquidity gap that would otherwise keep projects from going forward.

These two simple steps would help restart the solar industry, resulting in thousands of good paying, can’t-be-outsourced jobs for workers across this country.  Moreover, home and business owners would lower their energy costs, leaving them with more money in their pocket to spend in their communities.  And on top of all that, we would be helping to green the grid, lowering greenhouse gas emissions - a necessary step in the battle to reverse climate change.

Sounds pretty good, right?  Damn straight!  But in this time of crisis, silent approval isn’t enough - action is required!

Fortunately we can make that action really easy.  Just click on that big, Take Action! button below and you will be redirected to a website where you can send an email to your U.S. Senators and Representative, urging them to take action to grow solar and jobs in the next stimulus.  It takes all of one minute to do it, but the benefit could be felt for years.  So what are you waiting for?  Mash that button now!

 TAKE ACTION!
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07/16/20

  07:11:00 am, by Jim Jenal - Founder & CEO   , 1119 words  
Categories: Net Metering

FERC Ruling: Win for Net Metering, for Now!

We have been writing about a petition before the Federal Energy Regulatory Commission (FERC) filed by a shadowy organization calling itself the New England Ratepayers Association (NERA) seeking to gut net metering throughout the United States.  (See my prior posts here and here.)

Well we just learned of the ruling issued yesterday by the FERC, and while it is being widely touted as a big win for net metering, the reality of the decision is far less comforting than the victorious proclamations suggest.  Here’s our take…

Net Metering Survives…

The bottom line of the 3-0 Order Dismissing Petition for Declaratory Order is that NERA’s petition was dismissed by the FERC, with all three Commissioners in agreement.  But this was no full-throated defense of net metering, or even an assertion that the FERC has no business regulating how utilities deal with their rooftop solar customers.  After going back over the petition in painful detail, the order identifies the responding parties, and the arguments advanced in support and opposition to the petition.

One of the more interesting points raised in opposition challenged NERA’s refusal to disclose its members, who pay annual dues in the range of $5,000 to $20,000, which makes them a very special class of ratepayers!  Certainly not an organization of regular Janes, paying their electric bill. 

Noted commenter Public Citizen:

NERA does not disclose its constituent members or the interests it represents; therefore, NERA has not demonstrated that it will be subject to harm based on the outcome of the Petition or that it has an identifiable interest in the proceedings.

And the Pennsylvania Public Utility Commission asserted that

[T]he net metering regulatory scheme is already well established and the Petition fails to identify a specific state net metering scheme that is at issue, even though the Commission requires a concrete case or controversy with limited exceptions… [and the]  Commission’s net metering precedent is sound and there is no controversy or uncertainty to resolve.

That, of course, is a jurisdictional argument – nothing new had occurred to warrant the petition, and the case law that they relied upon was a decade old!  And that is how the Commission decided to resolve this non-dispute:

Declaratory orders to terminate a controversy or remove uncertainty are discretionary.  We find that the issues presented in the Petition do not warrant a generic statement from the Commission at this time. Therefore, we exercise our discretion to decline to address the issues set forth in the Petition, and, accordingly, we dismiss the Petition.

The manner in which the Commission addresses a petition for declaratory order depends on the “specific facts and circumstances” presented to the Commission. NERA in its Petition makes general assertions that Net Energy Metering policies adopted by various states improperly intrude on the Commission’s authority under the FPA and PURPA. NERA states that “it is in the public interest for the Commission to address this Petition promptly so that the pricing of [Net Energy Metering] sales becomes settled and affected parties can make appropriate decisions.” NERA further states that the Petition “focuses on the more common form of [Net Energy Metering] described above, as that was the subject of the Commission’s prior rulings…” The Petition, however, does not identify a specific controversy or harm that the Commission should address in a declaratory order to terminate a controversy or to remove uncertainty… For this separate reason as well, we decline to issue the requested order. 

If you were hoping for a clear signal of support for the concept of net metering, you won’t find it here!

…For Now

To the contrary, what you find in the two concurrences filed with the order is cause for alarm.  Commissioner McNamee noted:

[T]he Commission’s Order is not a decision on whether the Commission lacks jurisdiction over the energy sales made through net metering; nor is it a decision on the merits of the issues raised by and contained in the Petition. I also note, that as a general proposition, I think it is best to decide important legal and jurisdictional questions, like the ones raised in in the Petition, when applying the law to a specific set of facts, such as in a Section 206 complaint, or through a rulemaking proceeding.

That is what you call a roadmap for future filings.  Either repackage your petition as a Section 206 complaint, or bring it up in the next appropriate rulemaking.  But just a petition to end net metering out of the blue was a bridge too far. 

However, McNamee’s view may not matter as his term ended last month, so he will likely go back to his law practice “primarily representing electric and natural gas utilities before state public utility commissions."  Surprise, surprise.

The second concurrence, from Commissioner Danly (whose term does not expire until 2023!) is even more troubling.  He wrote:

The petition for a declaratory order filed by New England Ratepayers Association (NERA) raises difficult legal questions regarding the regulatory treatment of facilities (like rooftop solar) used by retail customers primarily, but not exclusively, to serve their own electricity requirements. These questions not only include the rate treatment for excess generation but, more importantly, the boundary between federal and state jurisdiction to address such rate treatment.

I have yet to reach any conclusion regarding either rate treatment or jurisdictional boundaries, but I am certain that these are questions of profound importance and the Commission will eventually have to address them.

I am concerned that dismissing the petition on procedural grounds may well result in a patchwork quilt of conflicting decisions if the questions raised in the petition are instead presented to federal district courts across the country. While the federal courts are more than capable of adjudicating preemption claims, they are not steeped in the history of the Federal Power Act nor in matters of national energy policy. Confusion, delay and inconsistent rules—some of which will apply to individual states or parts of states—will be the inevitable result.

Nevermind that the Commission has addressed the jurisdictional question before and determined that it lacked jurisdiction over state-operated net metering programs.  And is net metering really a “matter of national energy policy"?  Whether a PWP customer gets full retail value for the energy they sell back to the grid has zero impact on the ratepayers of New England, except, of course, to the extent it reduces the value of their stock holdings in the oil and gas industry.  But that’s really none of FERC’s concern.

So, bottom line, we live to fight another day, and that’s a good thing.  But net metering continues to be under attack, and this order provides no shelter from that coming storm.

Want to do something?  Join CALSSA (or your state’s solar/storage association) or the Solar Rights Alliance - they need your support to fight back.

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06/29/20

  07:47:00 am, by Jim Jenal - Founder & CEO   , 404 words  
Categories: Residential Solar, Net Metering

Update on Net Metering Attack at the FERC

Back in April we wrote about an attempt to eliminate Net Energy Metering - the primary economic benefit for rooftop solar - by way of a misleading petition filed with the Federal Energy Regulatory Commission (FERC). Here’s an update (h/t Utility Dive)…

The petition was filed by an entity called the New England Ratepayers Association (NERA) and if successful, would potentially affect net metering in the 45 states where it presently exists in one form or another.  The FERC regulates interstate electricity markets, and NERA portrayed net metering as a “wholesale sale” of energy, essentially subjecting rooftop solar systems as if they were utility power plants.  From NERA’s FAQ about the petition:

[N]et metering is having an unfair and harmful impact on ratepayers, especially low-and middle-income families. Given this problem, NERA has chosen to challenge net metering at the body which has the proper jurisdiction over wholesale electricity transactions.

Under FERC rules, the public had until June 15 to comment on the petition, and NERA found support from some usual suspects including the Heartland Institute (famous for its climate change denialism), the coal company Murray Energy (hilariously ridiculed by John Oliver a few years ago), the Competitive Enterprise Institute, Americans for Tax Reform (say what?), and Citizens Against Government Waste. 

Curiously, although several utility companies - including PG&E - had suggested that they would comment, none of them did.

In opposition was a very long and bipartisan group of people ranging from solar companies (well duh) and solar trade associations, to local state energy regulators.  For example, the National Association of Regulatory Utilities Commissioners (which includes the California Public Utilities Commission amongst its members) said in its comments:

The [FERC]… has for nearly 20 years acknowledged states’ authority and held that net metering does not involve wholesale sales subject to its jurisdiction… Relying on that settled law, states and utilities have developed and implemented net metering programs, and millions of Americans have made long-term investments in solar panels and other distributed generation for their homes and businesses.

Exactly!

Interestingly, Public Citizen dug up some IRS filings for NERA - which self-describes as "a non-profit organization focused on promoting sound public policy that protects utility customers, both families and businesses, and lowers the cost of regulated services” - that cast doubt on that claim.  According to the IRS filings, NERA consists of 15 members (identities not disclosed), ten of whom pay $20,000 in annual dues and five that pay $5,000.  Not exactly a grassroots organization!

Watch this space!

05/19/20

  01:57:00 am, by Jim Jenal - Founder & CEO   , 424 words  
Categories: Solar Economics, SCE

SCE Hikes Rates 6%

Talk about tone deaf - just as folks are stuck at home, sheltering in place, SCE jacked its rates roughly 6% across the board, because, you know, folks can so much more easily afford a rate hike while people are losing their jobs!  Here’s our (can you say outraged) take…

As of April 13, with little to no fanfare, SCE’s latest rate increase went into effect.  While different rates vary by somewhat different amounts, the overall average of 6.7% is expected to provide SCE with an additional $478 million dollars in revenue.  How nice.

The rate increase is not new; it is part of the CPUC-approved General Rate Case that was adopted in 2018 and covers rates for three years.  Nevertheless, at a time when other utilities, like PWP, are working hard to support their customers during a disastrous financial time, SCE’s willingness to press ahead with the rate increase is baffling, at best.

Using our regular proposal tool - Energy Toolbase - we decided to look at the results for three actual clients: a small usage client, a medium or really typical client, and then a very large usage client to see how the percentages played out.  Here are our results:

SCE rate increase

SCE’s Rate Increase - Click for Larger

The small user, with a total annual usage of 6,093 kWh (16.7 kWh/day) still has an annual bill on the tiered, Domestic rate plan of $1,267 and will experience a 6.24% increase or an extra $79 out of pocket.  Our medium user consumes nearly twice as much annual energy, 11,814 kWh (32.4 kWh/day), but because of the higher costs in the upper tiers of the Domestic rate plan, their bill is more than double.  After the 6.24% increase, the medium user is spending an extra $166.  Our large user - and this is not our largest residential client! - consumes 32,488 kWh (89.0 kWh/day), and has a bill to match, roughly four-times that of the medium user due to essentially living in the top tier of the rate structure.  After a 6.26% increase, they will be spending an extra $633!

We also looked at the same users switched over to a Time-of-Use rate (here, the 4-9 p.m. peak rate structure) and ran the numbers again.  One thing that leaps right out at you is that very large users will do much better on a TOU rate generally since otherwise almost all of their usage is billed in the top tier.  The percentage rate increases under the TOU rate are slightly smaller, with the small user paying an extra  $76, the medium user $160, and the large user $507.

Not exactly the sort of relief that ratepayers need at this time of unprecedented uncertainty.

05/12/20

  06:41:00 am, by Jim Jenal - Founder & CEO   , 949 words  
Categories: All About Solar Power, Residential Solar, Energy Storage

New Rule in SCE Territory Makes Solar + Storage More Valuable

We just learned from our friends at Energy Toolbase that Southern California Edison has just changed a rule about how solar PV systems with Energy Storage can operate, and the result - amazingly enough - results in greater savings for our clients!  Imagine that?!?  Here’s our take…

It used to be in SCE territory that when you added a storage system to your PV array, you could not export energy from the storage system to the grid and receive net metering credit.  That meant that when the storage system was discharging, it could not exceed what the home’s loads were demanding.  If your usage in the evening was low, or say you were out of town, your fully charged battery could not discharge at all - a poor utilization of that expensive storage system.

But now SCE - along with the other IOU’s, PG&E and SDG&E - have changed their rules to allow storage systems to discharge back to the grid and receive full net metering credit for that energy, as long as the storage system is solely charged by the PV array.  When you combine that rule change with electricity rates that favor storage, such as SCE’s TOU-D-Prime rate, the change in the rule can account for significant savings.

To get a handle on how big a change this will be, we went back to the data that we have for a client who we will be installing a small PV array and a 10 kWh Ensemble storage system soon.  (All of our data analysis and visualizations you see here were done using Energy Toolbase, simply the best presentation tool on the market.)

Solar PV & Storage - No Net Metering Discharge

Our client with the small, 4.6 kW, PV system and 10 kWh Ensemble storage system has a system payback of 11.4 years.  (Larger systems would have a faster payback.)  For this analysis, we imported his SCE interval usage data (provided by UtilityAPI) into Energy Toolbase.  ET then takes the performance output from the PV system, the charge and discharge parameters of the storage system, and overlays that on the existing usage - doing that calculation over every fifteen minute interval for a year.

The graph below shows one day, July 8th, as a representative sample.  Let’s break this down:

Solar PV + Storage - no net metering discharge

There’s a lot going on in this image (click on it for a larger version).  The dark gray is the historical usage demand based on the SCE data.  The value is shown at the top as “Current Demand” and at the moment we have focused on - July 8 at 4:15 p.m. - the historical demand was 1.94 kW. 

The green curve shows the modeled PV array output, using the specific parameters for this site - azimuth, tilt, shading, historical weather, specific equipment being used - as determined by NREL’s PVWatts tool (version 5).  Right now it is at 1.17 kW. 

The red line shows the percentage state of charge for the storage system, at this moment it is 83%.  Net Demand is what is being imported (positive number) or exported (negative number) to the grid.  Finally, Battery Power is how much power is being pulled from the storage system which at this moment is 1.94 kW.  At the bottom is the cost parameters for this rate schedule.  Under the pre-solar Domestic rate (which is a tiered rate) the cost of energy is 18.7 cents/kWh, whereas under the new rate structure it is more than twice that at 38.3 cents during the peak, 4-9 p.m. period.

 So… earlier in the day, as the output from the PV increases, and energy charges are cheap, the solar charges the battery for use later when the rates are high. As we cross over into the peak rate period at 4:00, the storage system begins to discharge and its output is exactly the same as the demand, meaning that all of the power from the PV system can be exported to the grid. 

But note that the battery power is only 1.94 kW, even though its continuous peak output is roughly twice that, 3.84 kW.  Under the old rules though, the storage system cannot output more than that, since it is barred from exporting to the grid.  As a result, when the peak rate period ends at 9:00 p.m. the storage system shuts off, even though it is still partially charged (nearly 40% capacity remains in this example).

That’s leaving money on the table!

Solar PV & Storage - Net Metering Discharge Allowed

Consider the same day, only now we can export the full output of the storage system as desired to maximize our time-of-use arbitrage.

Solar PV + Storage - no net metering discharge

Everything is essentially the same until we get to 4:00 p.m. and then things get very different!  Look at the difference in the output from the battery system, it is now putting out it’s maximum sustained power of 3.84 kW, resulting in more than 3 kW being exported during the peak price period

More importantly from an arbitrage perspective, the storage system is completely cycled.  Meaning that we have gotten full utilization from our storage system investment.  

What does that mean overall economically?  Payback is reduced from 11.4 to 10.7 years, a 6.1% improvement.  Gee, thanks, SCE!

So why are they doing this?  Simple: grid support. Having storage systems maximizing their output during the peak demand period (remember the Duck Curve?) helps the utility to manage its load, and reduce the need for expensive peaker capacity. Everybody benefits: our client (with faster payback), the utility (with better grid load management), and even non-solar/storage rate payers (as they don’t have to pay for that additional production capacity.  Win, win, win!

Of course, these economic benefits don’t really apply to a tiered rate structure, such as is used for residential rates in PWP territory.  But if you are in SCE territory, adding smart storage, like the Enphase Ensemble system, just became a lot more lucrative.

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Jim Jenal is the Founder & CEO of Run on Sun, Pasadena's premier installer and integrator of top-of-the-line solar power installations.
Run on Sun also offers solar consulting services, working with consumers, utilities, and municipalities to help them make solar power affordable and reliable.

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