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Sustainable Energy Advantage, LLC
New England
Renewable Energy
Solar ‘Eyes & Ears’ Digest #48
December 30, 2014
Terms & Conditions
Eyes & Ears Service is provided to the Subscriber for the Subscriber’s internal use only, and may be
distributed to employees, officers and directors of Subscriber or Authorized Affiliate who have been made
aware of the Limitations on Use under the Subscription Agreement. Subscriber agrees not to distribute
materials received under the Eyes & Ears Service, whether by written, oral or electronic means, to any
other person, including consultants engaged by Subscriber, except with specific written permission from
SEA or as required by applicable law, regulatory proceeding or exchange rule. Subscriber is subject to
additional terms and conditions stated in the Subscription Agreement.
New England Renewable Energy ‘Eyes & Ears’ Digest Sustainable Energy Advantage, LLC Digest #48 – Tuesday, December 30, 2014
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Top Stories in this Update… Other Featured Topics…
Massachusetts Net Metering and Solar Task Force Initiates Study Process Pursuant to Chapter 251; Will Receive Comments from Public on January 6
Massachusetts DOER Will Not Grant Weather Related Extensions for Managed Growth
Massachusetts: National Grid Selects 16 MW of Solar Projects under Solar Program Phase II
Massachusetts: SunEdison Announces Solar PPAs, Totaling 39.5 MW of Capacity, with 16 Public Housing Authorities
Connecticut: District Court Rules Allco has No Standing to Challenge DEEP Decision under PA 13-303 Section 6, and that Section 6 Procurement is not Invalid under FPA
Connecticut DEEP Finally Issues 2014 Draft IRP and Seeks Comments; Proposes not to Phase-Down Biomass and LFG REC Values for the Next Three Years; Procurement Plans Also Discussed
Connecticut Light & Power and United Illuminating Company Provide Update on Year 3 LREC/ZREC RFP
Connecticut Governor Malloy to Expand Residential Solar Investment Program by Ten Times
Rhode Island OER and DG Board Continues Discussion on Ceiling Prices, MW Allocation and Tariff Development for 2015 REG
Maine PUC Issues Second Maine Value of Solar Methodology Draft after Reviewing Stakeholder Comments; PUC Requests Data from T&D Utilities in Value of Solar Proceeding
Vermont PSD Issues Report to Legislature Considering Adoption of Mandatory RPS
New Hampshire Sustainable Energy Association, Policy Advocates and Legislators to Introduce Solar Bill in 2015 Session
ISO-NE Issues Final 2014 Regional System Plan
ISO-NE and NEPOOL MC Continue to Discuss Evolving Proposals on Zonal Sloped Demand Curves
SunEdison and TerraForm Power Acquire First Wind for $2.4 Billion
MASSACHUSETTS
Net Metering and Solar Task Force Initiates Study Process Pursuant to Chapter 251; Will Receive Comments from Public on January 6
o First Net Metering Task Force Meeting Focuses on Realigning Framework with Legislation, Finalizing Consulting Scope
New England Renewable Energy ‘Eyes & Ears’ Digest Sustainable Energy Advantage, LLC Digest #48 – Tuesday, December 30, 2014
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o Net Metering and Solar Task Force Holds 2nd Meeting to Review Study Work Plan; DPU Projects When Net Metering Caps will be Filled
o Net Metering and Solar Task Force to Receive Public Comments at January 6, 2015 3rd Meeting
DOER Releases 2013 RPS & APS Annual Compliance Report
DPU Adopts Emergency Regulations to Implement Net Metering Cap Increase
DOER Announces SREC-I and SREC-II Load Exemptions
DOER Will Not Grant Weather Related Extensions for Managed Growth
DOER Conducts Stakeholder Process for Thermal APS Rulemaking
IOUs Seek Approval to Reduce Capacity of Bingham Wind Farm in Section 83A PPA
Energy Undersecretary Sylvia to Join BlueWave Capital
DPU Submits Information Requests to Utilities in DG Interconnection Group Study Proceeding
WMECO Files 2014 Annual Solar Compliance Filing
DPU Approves Unitil's Proposed 2015 Net-Metering Recovery Surcharge Rates
DPU Issues Grid Modernization Business Case Filing Requirement
DPU Adopts Basic Service Time-Varying Rates Policy Framework; Denies Three Parties' Petitions for Reconsideration
DOER Publishes Comments on Final Design of Residential Solar Loan Program
NECEC, SEBANE, SEIA and Vote Solar Form Mass Solar Coalition to Work with Legislature on Solar and Net Metering Issues
Paragon Holdings Petitions to Transfer ACA Reservation Fee from Initial Reservation to Updated Reservation
DPU Grants Syncarpha's Petition for Limited Exception from Single Parcel Requirement for Net Metering Qualification
MassCEC Selects Mass Energy for Solar Connect Non-Profit Group RFP; Issues RFPs for Solar Connect Outreach Consultant and Solar Installers
MassCEC Announces Selected Communities for 2015 Solarize Mass; Seeks Proposals from Solar Installers
National Grid Selects 16 MW of Solar Projects under Solar Program Phase II
SunEdison Announces Solar PPAs, Totaling 39.5 MW of Capacity, with 16 Public Housing Authorities
Appellate Tax Board Publishes Decision Finding Some Virtually Net-Metered Systems Should Receive Property Tax Exemption
New England Renewable Energy ‘Eyes & Ears’ Digest Sustainable Energy Advantage, LLC Digest #48 – Tuesday, December 30, 2014
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Dennis-Yarmouth School District Signs Power Purchasing Agreement for 3-MW of Solar Projects
Altus Power Signs Long-Term Purchasing Agreement with Belchertown for NM Credits Generated from Company's Solar Projects
Clean Energy Collective to Build Community Solar Project in Adams
NSTAR Issues RFP Seeking Certificates for Meeting MA RPS and APS Compliance Obligation
WMECO Issues RFB to Purchase and Sell MA SRECs
DOER Hosts Webinar on Solar PV Safety and Permitting Training
Environmental Massachusetts Issues Report on Solar Growth
NSTAR Hosts Interconnection and Net Metering Seminar
CONNECTICUT:
District Court Rules Allco has No Standing to Challenge DEEP Decision under PA 13-303 Section 6, and that Section 6 Procurement is not Invalid under FPA
DEEP Finally Issues 2014 Draft IRP and Seeks Comments; Proposes not to Phase-Down Biomass and LFG REC Values for the Next Three Years; Procurement Plans Also Discussed
PURA Issues Final Virtual Net Metering Decision Removing Virtual Netting Protocol
EDCs Provide Status Updates Regarding Year 3 LREC/ZREC Procurement, Limited Reopening of RFP and Small ZREC Tariff
o CL&P and UI Provide Update on Year 3 LREC/ZREC RFP
o CL&P Files Supplements to Interim Procurement Plan for Year 3 LREC/ZREC Solicitation; Delays Submission of Individual LREC/ZREC Bid Report due to Reopening of Year 3 RFP
o CL&P Motions PURA to Allow Both EDCs' Small ZREC Tariff to Launch on the Same Date; to Hold Year 3 Small ZREC Program Webinar for Applicants with UI
CL&P and UI Issue RFI to Seek Stakeholder Input on Improving LREC/ZREC Program
Governor Malloy to Expand Residential Solar Investment Program by Ten Times
PURA Issues Decision on CL&P Rate Case: Proposed Increase Fixed Monthly Service Fee to Residential Customers is Adjusted Downward
Renewable Industry Stakeholders Discuss Electricity Rate Design in Response to CL&P's Fixed Charge Hike
PURA Considers Definition of Class III Sources Under PA 13-303; Denies Petition to Include All Demand-Side Management Projects in Class III in Final Decision
Connecticut Green Bank and EnergySage Announce Partnership to Support CT's
New England Renewable Energy ‘Eyes & Ears’ Digest Sustainable Energy Advantage, LLC Digest #48 – Tuesday, December 30, 2014
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Residential Solar Initiatives
Connecticut Green Bank Holds Webinars on Residential Solar Incentive Program, Approves New Incentive Levels including a Blended Rate for Oversized Systems
Solarize CT Reaches 14 MW PV Installation
CSC Grants UI's Petition for Declaratory Ruling in Bridgeport Solar/Fuel-Cell Project Proceeding
PURA Requests Comments on Submetering for On-Site Generation
CT Green Bank to Host Webinar on Solar Customer Segmentation
RHODE ISLAND:
OER and DG Board Continues Discussion on Ceiling Prices, MW Allocation and Tariff Development for 2015 REG
o DG Board Approves Final Recommendations Regarding Ceiling Prices for 2015 REG
o DG Board Approves OER's Recommended MW Allocation Plan
o National Grid Submits Tariff Proposal for 2015 REG to PUC
o Wind Energy Development Files Motion to Intervene in National Grid REG Tariff Proposal
PUC Makes Partial Ruling on Interconnection Dispute between WED and National Grid
Patriot Renewables Seeks RI RES Qualification for Saddleback Ridge Wind Project
Commerce Corp. Issues REF Grants to Six Solar Projects
MAINE:
PUC Issues Second Maine Value of Solar Methodology Draft after Reviewing Stakeholder Comments; PUC Requests Data from T&D Utilities in Value of Solar Proceeding
VERMONT:
PSD Issues Report to Legislature Considering Adoption of Mandatory RPS
PSB Continues Investigation on Avoided Cost Caps for SPEED 2014 Standard Offer Program
o Stakeholders Submit Comments on SPEED Standard Offer Program Avoided Cost Caps Developed by Working Group
o Farm Methane Working Group Develops Cost Models for 2015 SPEED Avoided Costs Price Caps
o REV and PSD File Avoided-Cost Price Cap Proposals for Non-Farm Anaerobic Digestion; PSB Requests Comment on New Non-Farm Anaerobic Digestion
New England Renewable Energy ‘Eyes & Ears’ Digest Sustainable Energy Advantage, LLC Digest #48 – Tuesday, December 30, 2014
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Category
GMP Sponsors Program to help Non-Profits Develop Solar Facilities
Winhall Citizens Voice Concern Regarding Proposed Solar Project
New Haven Selectboard Votes Against Two Solar Projects
Bennington Residents Concerned Solar Project May Affect Well Water, Tourism
NEW HAMPSHIRE:
NHSEA, Policy Advocates and Legislators to Introduce Solar Bill in 2015 Session
PUC Staff Recommends Incentive and Requirement Changes to C&I Solar Rebate Program; Invites Stakeholder Comments
OLS Comments on PUC's Final Proposed Group Net Metering Rules
PUC Gives Updates on Energy Programs and FERC Decision Related to Demand Response and RTO at October 16 EESE Board Meeting; December 19 Meeting Cancelled
OEP Holds Second Stakeholder Session on Reducing Costs Related to Residential Permitting and Zoning for Solar Under Rooftop Solar Challenge
PSNH Issues RFP for RECs to Satisfy RPS Obligation
Town of Milton Moves Forward with Solar Garden
Derry Seeks Proposals for Land-Lease to Install Solar Systems at Town's Landfill
ISO NEW ENGLAND, REGIONAL AND NATIONAL DEVELOPMENTS:
ISO-NE Issues Final 2014 Regional System Plan
NEPOOL MC and PC Approve ORTP Exemption for Distributed RE Technologies
NESCOE Proposes ICR Calculation Reflecting Solar DG Forecast and Pay-for-Performance Rules
Distributed Generation Forecast Working Group December Meeting Addresses State DG Policies, Economic Drivers of PV, and Utility PV Penetration Data
VRWG Cancels December 4 Meeting Due to Schedule Conflicts
NY PSC Increases Utility Net Metering Caps from 3% to 6%; To Study Value of Distributed Generation
LIPA Selects 122 MW of Solar Projects under Long-Term Contract RFP; Deepwater ONE Proposal Not Selected
U.S. International Trade Commission Increases Anti-Dumping Duties on Solar Modules from China and Taiwan
New England Renewable Energy ‘Eyes & Ears’ Digest Sustainable Energy Advantage, LLC Digest #48 – Tuesday, December 30, 2014
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SunEdison and TerraForm Power Acquire First Wind for $2.4 Billion
2014 IREC/Vote Solar “Freeing the Grid” Report on Net Metering and Interconnection Best Practices Released
LBNL Issues Report on Solar Price Variability; Held Webinar on December 15
CESA to Host Webinar on Rate Design Approaches to DG Solar
MASSACHUSETTS Net Metering and Solar Task Force Initiates Study Process Pursuant to Chapter 251; Will Receive Comments from Public on January 6 (KEYWORDS: Net Metering, DG, Solar, RPS, Planning, Rates) New E&E Content As described in Digest 46, Chapter 251 (enacted in August 2014 pursuant to HB 4185), among a series of net-metering- and renewable-thermal- related provisions, orders the establishment of a Net Metering Task Force to review the "long-term viability of net metering in the commonwealth and develop recommendations on incentives and programs that will support the deployment of 1600 MW of solar generation facilities" in Massachusetts. It requires that the Task Force file any recommendations for legislative or regulatory reforms with the legislature, by no later than March 31, 2015. A detailed summary of Chapter 251 is available in Digest 46. Task Force members include:
The Task Force selected a consulting team consisting of Peregrine Energy Group (prime contractor), in conjunction with Sustainable Energy Advantage (serving as project manager), Meister Consultants Group, and La Capra Associates, as the Task Force's consultant to aid the review process. The consulting team has contracted with the Department of Energy Resources and reports to DOER, but is guided by the Task Force. The proposed study timeline (based on the consultants' December 15 presentation summarized below) is as follows:
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Here we provide a status update of the study process to date.
CONNECTICUT District Court Rules Allco has No Standing to Challenge DEEP Decision under PA 13-303 Section 6, and that Section 6 Procurement is not Invalid under FPA
(KEYWORDS: Institutional, Litigation, RPS, Utility Procurement, LT Contracts)
No Modifications/Last Updated: Flash 47.6
As reported in Digest 41, the Department of Energy and Environmental Protection (DEEP) selected EDP
Renewables North America LLC's 250 MW Number Nine Wind Farm and Helio Sage Energy LLC's 20
MW Fusion Solar Center for the Class I Renewable Energy Request for Proposals under Section 6 of
Public Act 13-303. In October 2013, Allco Renewable Energy filed a Petition for Reconsideration with
PURA, asking PURA to deny the Number Nine PPA. The petition was denied.
On December 18, 2013, Allco, following the precedent of court decisions in Maryland and New Jersey
pertaining to state violations under the Constitution’s Supremacy Clause (see Digest 42, 45, 46), filed a
lawsuit in U.S. District Court (Connecticut District) against DEEP Commissioner Daniel Esty (now Robert
Klee) for violations of the Federal Power Act (FPA), the Public Utility Regulatory Policies Act of 1978 and
the Federal Energy Regulatory Commissions' regulations. In its complaint, Allco argues that only FERC
may establish wholesale rates and regulate the wholesale market. Under FERC's regulations, utilities can
enter into contracts to purchase power from QFs at the utility's full avoided costs. The size of a QF is
capped at 80 MW. Hence, the 250 MW Number Nine project is not a QF. Filings and transcripts related to
the case are available online, through the Federal PACER website under docket number 3:13-cv-01874.
(See Digests 43 & 46 for a discussion of the proceedings).
On December 10, 2014 the District Court dismissed Allco's Lawsuit on two grounds, directly comparing
facts of the lawsuit to those present in the Maryland and New Jersey cases, mentioned above:
1. Allco Lacks Standing to Challenge DEEP's actions
The Court first determined that Allco lacked standing to challenge DEEP's actions. Specifically, the Court
found that the FPA does include disappointed bidders within the "zone of interest" of the statute and that
denial of a contract in a bidding process does not create sufficient injury under the FPA (foreclosing
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standing). The Court also found that Allco's injury, even if it were sufficient, is not redress-able by judicial
action, as there is no guarantee under the terms of Section 6 that Allco's project would have been
selected if Number Nine was not.
The Court also explicitly distinguished the current case from the matter at issue in the Maryland case PPL
Energyplus v. Solomon (discussed in Digests 42 and 46), stating that there the claimants, as existing
generators and utilities, had a concrete injury resulting from the depression of wholesale prices by state
action, which would "cost [them] millions of dollars," giving them standing under the FPA.
2. Connecticut's Section 6 Bidding Process is Not Preempted by the FPA
Even though the Court found that Allco did not have standing to pursue the claim (thus effectively
dismissing the lawsuit), the Court also discussed the substance of Allco's claim, finding that Section 6,
although it has an effect on wholesale rates, is not preempted by the FPA.
Specifically, the court determined that, because the price/rate was offered by the bidder (as opposed to
being set by DEEP), because DEEP had no ability to alter the price, and because any bidder could
decide to not go through with the proposal after being selected, that the Section 6 program was not
interfering with FERC jurisdiction over wholesale markets. Therefore, Section 6 is not an attempt to 'set'
or 'fix' wholesale prices, and is not preempted.
The court found the mechanism by which final prices are set dispositive, again distinguishing the current
case from PPL Energyplus v. Nazarian and PPL Energyplus v. Solomon. In those cases, the district court
stated that, because the mechanism used (bidders received a standard rate equal to difference between
revenue requirements and actual sales receipts) effectively set rates and was ordered by state law, that
these laws were preempted by the FPA and were invalid.
It is unknown if Allco will appeal the decision to the First Circuit.
RHODE ISLAND OER and DG Board Continues Discussion on Ceiling Prices, MW Allocation and Tariff Development for 2015 REG
(KEYWORDS: DG, Solar, Wind, Net Metering, Hydro, Anaerobic Digestion, Interconnection, LT
Contracts, Utility Procurement)
New E&E Content
The Rhode Island Office of Energy Resources and Distributed Generation Contracts Board held meetings
on September 22, October 20, November 10, 17, 20 and December 9 and 15, 2014 to discuss and
provide updates on the development of the 2015 Renewable Energy Growth program. The meetings
focused on three primary issues surrounding the 2015 REG Program:
Ceiling Prices
Capacity Allocation
Tariff Development
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Contributors: Bob Grace, Jason Gifford, Deborah Donovan, Tom Michelman, Po-Yu Yuen, Daniel von
Allmen, Andrew Kostrzewa, Nicole Hamilton, Will Bittinger and Kathryn Craddock
For More Information Please Contact:
Sustainable Energy Advantage, LLC
161 Worcester Road, Suite 503
Framingham, MA 01701
www.seadvantage.com
Bob Grace - [email protected] 508.665.5855
Jason Gifford - [email protected] 508.665.5856
Deborah Donovan – [email protected] 508.665.5859
SEA Solar Eyes & Ears Sample Flash Email
From: Bob Grace
Sent: Monday, January 19, 2015 11:38 AM
Subject: SEA Solar Eyes & Ears/Flash No. 48.3 Week Ending January 16, 2015
**Flash Update**
Dear Solar Eyes and Ears Subscribers: Flash 48.3-S Week Ending January 16, 2015
Time sensitive articles are identified with the following icon:
Contents
Massachusetts
MA Land Court Sides with Residents, Says 2.4-MW Hatfield Solar Violates Zoning Bylaw
Connecticut
PURA Approves UI and CL&P's Year 3 LREC/ZREC Final Procurement Plans
PURA Grants Amgraph One-Time Extension to LREC Contract Delivery Term Start Date; CL&P Motions
for Reconsideration of Ruling
PURA Solicits Comments on On-Site Submetering
Rhode Island
DG Board to Hold Meeting on January 20 to Provide Updates on Various Topics
OER Solicits Applications for Renewable Energy Projects at RI Schools
Maine
PUC Accepts Comments on Value of Solar Methodology Second Draft; CMP and Emera Maine File Load
and Solar Data
Vermont
Governor Shumlin Discusses Vermont RPS, Net Metering and Other Clean Energy and Environment Issues
in Inaugural Address
Utilities File Revised Net Metering Tariffs to Reflect Rate Changes Pursuant to Act 99; PSB to Initiate
Stakeholder Process in Preparation for 2016 Net Metering Rulemaking
Eyes & Ears Terms and Conditions Eyes & Ears Service is provided to the Subscriber for the Subscriber’s internal use only, and may be distributed to employees, officers and directors of Subscriber or Authorized Affiliate who have been made aware of the Limitations on Use under the Subscription Agreement. Subscriber agrees not to distribute materials received under the Eyes & Ears Service, whether by written, oral or electronic means, to any other person, including consultants engaged by Subscriber, except with specific written permission from SEA or as required by applicable law, regulatory proceeding or exchange rule. Subscriber is subject to additional terms and conditions stated in the Subscription Agreement.
Headlines Time sensitive articles are identified with the following icon:
Massachusetts
MA Land Court Sides with Residents, Says 2.4-MW Hatfield Solar Violates Zoning Bylaw
On January 2, 2015, the Massachusetts Land Court ruled that the Hatfield Zoning Board of Appeal erred in
denying a building permit appeal filed by residents against Hatfield Solar, LLC's 2.4-MW, 8,276-panel solar
project. Hatfield Solar LLC is a subsidiary of Citizens Enterprises Corp. In 2012, Hatfield Solar was granted a
building permit to install the project in a rural residential district in Hatfield. A group of 21 Hatfield residents
appealed the building permit to the ZBA. The residents argued that the town's local zoning bylaws limit
renewable or alternative energy development to industrial and light industrial use districts. However, the ZBA
denied the appeal and sided with Hatfield Solar, who asserted that the project was exempted from the local
zoning regulations pursuant to a state solar provision that prevents any local zoning or bylaws from
unreasonably regulating the installation of solar systems other than for public health, safety or welfare reasons.
As a result, the residents challenged the ZBA's ruling to the Land Court.
In her January 2 decision, Land Court Judge Judith Culter noted that the ZBA's interpretation of the state laws
was incorrect, noting that the referenced solar provision only prohibits unreasonable regulation of solar
development. She further noted that the responsibility of proving a local solar bylaw is unreasonable is borne by
the developer. Subsequently, she ruled that Hatfield's zoning bylaw clearly prohibits the siting of solar facilities
in a rural residential district and overturned the ZBA's decision. (Daily Hampshire Gazette)
It should be noted the solar project has been qualified as a SREC-II Managed Growth project for the 2014
capacity block allocation. The project currently has a commercial operation milestone of February 27, 2015
pursuant to its Assurance of Qualifications. Given delays caused by the legal challenges, it is almost impossible
for the project to meet its milestone at this juncture. It is unclear whether the company will appeal the Land
Court's decision and apply for an extension of the reservation period. If the project fails to come online before
ISO New England & Regional Developments
FERC Issues Order Accepting ISO-NE's Proposed ICR Values for FCA9; Directs ISO-NE to Consider DG
and Solar PV Forecasts in ICR Calculations for Future Auctions
LBNL Issues Report on Sales Premiums for PV Homes
its commercial operation deadline, it would free up 2.4 MW of space for other SREC-II Managed Growth
projects currently on the waiting list.
Connecticut
PURA Approves UI and CL&P's Year 3 LREC/ZREC Final Procurement Plans
United Illuminating Company and Connecticut Light & Power filed their Year 3 LREC/ZREC Final
Procurement Plans under Docket 11-12-06 on December 29 and 30, 2014 respectively:
CL&P:
Final Procurement Plan
Exhibit A - Procurement Plan for the Purchase of LRECs and ZRECs
Exhibit B - Individual Bids (Bids for Reopening RFP Only)
Exhibit D - Standard Contract
UI:
Final Procurement Plan
Exhibit A - Procurement Plan for the Purchase of LRECs and ZRECs
Exhibit B - Individual Bids (Bids for Reopening RFP Only)
Exhibit D - Standard Contract
The following tables summarize the prices for the Year 3 procurement:
*The Small ZREC Tariff rate = 110% * Weighted Average Bid Price of Accepted Bids for Medium ZREC
On January 15, the Public Utilities Regulatory Authority approved CL&P and UI's plans.
PURA Grants Amgraph One-Time Extension to LREC Contract Delivery Term Start Date;
CL&P Motions for Reconsideration of Ruling
On October 8, 2014, Amgraph Packaging, Inc. filed a motion with the Public Utilities Regulatory Authority to
amend the Delivery Term Start Date on its LREC contract with Connecticut Light & Power from October 1,
2014 to October 1, 2015. Amgraph asserted that the implementation of its fuel cell project was delayed due to
delays in CL&P's interconnection study review process. PURA granted a one-time extension per Amgraph's
motion on January 6, 2015. On January 8, CL&P filed a motion for reconsideration of the ruling and asking
PURA to determine that the Delivery Term Start Date cannot be extended. It asked that PURA uphold its
precedential determination, which ruled that the Delivery Term Start Date cannot be modified after an
agreement is executed, but the contracting distribution company can grant a 6-month extension of the
termination date. CL&P further explained that the interconnection application delays mentioned in Amgraph's
motion is not a fundamentally unique issue and does not warrant a departure from PURA's regulatory
precedence.
PURA Solicits Comments on On-Site Submetering
As last discussed in Digest 48, the Public Utilities Regulatory Authority requested comments from electric
distribution companies and docket participants regarding on-site submetering under Docket 13-01-26.
Specifically, PURA requested comments on the following topics:
1. Provide recommendations to modify the Electricity Submetering Application Form (Without Self-
Generation) (SE Form) to accommodate the submetering of electricity at facilities with self-generation
as required by the Act. The SE Form is located in the Interim Decision as Appendix C.
2. Describe any issues that applicants have experienced in filling out the application.
3. Discuss when submetering should start in facilities where tenants’ leases expire at different times.
4. Characterize what type of Class I and combined heat and power units will self-generators utilize.
5. Provide a formula to develop the tenants billing rate that have a self-generator.
6. Explain if a submetering customer in a self-generation environment faces monopoly pricing.
7. Describe any new customer protections that are needed for tenants in facilities that have a self-generator.
8. Describe the remedy for a submetering facility having a self-generator that does not meet, or in the
future fails to meet, the required performance standards.
9. Discuss any new metering requirements needed for tenants in a facility that has a self-generator.
Five parties submitted comments to PURA:
777 Main Street, LLC, a 285 unit sustainable residential development which recently installed a 400 kW
fuel cell.
CL&P and UI
MEPT Chapel Street LLC, a landlord that has installed on-site renewable generation.
Chandler LLC, a specialized boutique consultancy that offers Owner Representation and Project
Management for the planning, design and construction of building projects that are healthy and efficient
to operate.
Connecticut Fund for the Environment
Rhode Island
DG Board to Hold Meeting on January 20 to Provide Updates on Various Topics
The Rhode Island Distributed Generation Contract Board will hold a meeting on January 20, 2015 from
4 to 5:30 pm at the Department of Administration, Conference Room A. The meeting agenda includes:
Notification on the interconnection dispute between Wind Energy Development, LLC and National Grid
under Docket 4483;
Update on the 2015 Renewable Energy Growth Program;
National Grid presentation on the results of the 3rd enrollment of the 2014 DG Contract Program;
Cadmus presentation on solar quality assurance; and
2016 ceiling price services – reconciliation funding.
Summaries for the first three agenda items can be found in Flash Update 48.2. There will also be a public
comment opportunity at the end of the meeting.
OER Solicits Applications for Renewable Energy Projects at RI Schools
The Office of Energy Resources OER is accepting applications for Regional Greenhouse Gas Initiative (RGGI)
funding to develop renewable energy at K-12 schools throughout Rhode Island. This funding comes from the
2014 Plan for the Allocation and Distribution of RGGI Auction proceeds, which allocated $13 million for
renewable projects at schools through a competitive grant process. Eligible applications must contain an
education element as part of the project. The solicitation is a continuous recruitment through April 17, 2015.
More information on the solicitation can be found on OER's website.
Maine
PUC Accepts Comments on Value of Solar Methodology Second Draft; CMP and Emera
Maine File Load and Solar Data
As last discussed in Digest 48, the Maine Public Utilities Commission is conducting an investigation on the
value of distributed solar under Docket 2014-00171. On December 5, 2014, the PUC's consultants (a team led
by Clean Power Research that also includes Sustainable Energy Advantage, Pace Energy and Climate Center,
and Richard Perez) issued a second draft of the solar valuation methodology. The PUC accepted comments on
the draft, focusing on the following issues:
Calculation of Effective Load Carrying Capacity;
Proposed Calculation of Transmission and Distribution Benefits;
New Value Components for SO2 /sub> and NOx and the Calculation Methodology for SO2; and
Avoided Fuel Price Uncertainty.
Six parties filed comments with the PUC:
The Alliance for Solar Choice
Office of Public Advocates
Emera Maine
Natural Resources Council of Maine
Central Maine Power
Acadia Center
Additionally, CMP and Emera Maine filed data related to distribution losses, hourly load, and solar installation
pursuant to PUC's data request:
Emera Maine:
Bangor Daily Hydro - Net Metering Projects
Bangor Daily Hydro - Distribution Losses
Maine Public District - Net Metering P+rojects
Maine Public District - Distribution Losses
CMP:
2011 Hourly Load Data
2012 Hourly Load Data
2013 Hourly Load Data
Average Cost of Capital and Distribution Losses
Net Metering Projects
Vermont
Governor Shumlin Discusses Vermont RPS, Net Metering and Other Clean Energy and
Environment Issues in Inaugural Address
Governor Shumlin gave his inaugural address on January 8, 2015. The address focused on clean energy and
environment, highlighting policy initiatives and goals the administration will target in the next four years. In his
speech, Governor Shumlin highlighted that Vermont's net metering program has been the main engine driving
the state's solar growth. He also discussed his administration's plan to implement a renewable portfolio standard
program. The RPS program will replace the state's existing SPEED program, which, he stated, "laid the
groundwork for where [the state is] today." The state now needs a strategy that can achieve its renewable energy
and greenhouse gas reduction goals. While the proposed program will share similar structure with RPS policies
in other states, he asserted that the Vermont program will be much broader, offering credits to thermal
efficiency services, electric vehicle technologies and potentially other clean energy initiatives. The Public
Service Department is currently working on a proposal. As discussed in Digest 48, the PSD will likely be
submitting a proposal to be considered for the 2015 legislative session. The state currently plans to have the
program in place in 2017. It is estimated that the RPS program will add 1,000 local jobs and bring "hundreds of
millions of dollars" in energy bill savings to Vermont ratepayers. One of the key motivator for this policy
decision is the ongoing Connecticut PURA proceeding exploring whether the Vermont Speed goals result in
double counting in violation of PA 13-303 Section 1, which would trigger rejection of RECs associated with
SPEED resources from use for CT Class I RPS compliance. (VT Digger)
Utilities File Revised Net Metering Tariffs to Reflect Rate Changes Pursuant to Act 99; PSB
to Initiate Stakeholder Process in Preparation for 2016 Net Metering Rulemaking
Act 99, enacted in 2014, made several changes to Vermont's net metering program, among which include
increasing the cumulative output capacity of net metering systems from 4% to 15% of the distribution
company’s peak demand during 1996 or the peak demand during the most recent full calendar year, whichever
is greater. It also adjusts the net metering rates such that solar net metering systems of 15 kW or less will
receive a net metering rate of 20¢/kWh, while other metering systems will receive a net metering rate of
19¢/kWh. A more detailed summary of Act 99 can be found in Digest 44. According to VT Digger, the states'
utilities have recently filed revised net metering tariffs to reflect the changes in Act 99. The tariff filings are not
yet available for public consumption. Since the changes are established by the legislature, it is expected that the
revised tariffs will be approved. Additionally, the PSB will begin working on redesigning the state's net
metering rules. On November 5, 2014, the PSB held a hearing to present findings from its recent net metering
study. A summary of the study can be found in Digest 48. As we understand, the Board is planning to issue a
procedural schedule for future hearings and workshops in late January. A formal rulemaking place is scheduled
to take place in 2016. It is anticipated that the final rules will be adopted in 2017. We will continue to follow
this topic and provide updates as information becomes available. Information on the rulemaking procedures will
be available on PSB's website.
ISO New England & Regional Developments
FERC Issues Order Accepting ISO-NE's Proposed ICR Values for FCA9; Directs ISO-NE to
Consider DG and Solar PV Forecasts in ICR Calculations for Future Auctions
In Digest 48, we reported that the Federal Energy Regulatory Commission was conducting an investigation on
ISO-NE's proposed Installed Capacity Requirement Value for the ninth Forward Capacity Auction (FCA 9)
under Docket ER 15-325-000. As discussed in Digests 47 and 48, several parties, including the New England
States Committee on Electricity and Conservation Law Foundation, have criticized ISO-NE for not
incorporating its distributed generation and solar PV forecasts in the calculation of the ICR values. The critics
asserted that, by omitting a material capacity of solar PV projects, including small net-metered installations and
MW-sized resources, coming online in the next three years, ISO-NE's method could potentially overestimate
the capacity needed for the future. On January 2, 2015, FERC issued an order accepting ISO-NE's proposed
ICR values for FCA 9, but also directed ISO-NE to consider incorporation of distributed generation and solar
PV in its ICR value calculation for FCA 10 and future auctions.
LBNL Issues Report on Sales Premiums for PV Homes
On January 13, 2015, the Lawrence Berkeley National Laboratory issued a report quantifying the sales
premiums for homes equipped with host-owned solar PV systems. The report examined home sales data in eight
states, including Massachusetts and New York, and concluded that homebuyers are willing to pay more for
properties with host-owned PV systems. The report observed a "green cachet" pattern, where buyers are willing
to pay a certain amount for having any size of PV systems on their homes and an incremental amount
depending on the size of the systems. Further, the report noted that PV premiums stay relatively constant
despite significant decline in PV gross costs over the study period. This study did not look at non-host-owned
PV homes, such as properties with leased PV systems. Regards, Bob Grace
Sustainable Energy Advantage, LLC 161 Worcester Road, Suite 503 Framingham, MA 01701
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Robert C. Grace – President and Managing Director Sustainable Energy Advantage, LLC Tel 508.665.5855 Fax 508.665.5858 Mobile 617.803.8900 [email protected] www.seadvantage.com **********************************************************