Defend Solar Energy in New York
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This is a statement on behalf the Long Island Solar Energy Industries Association (LISEIA) on the proposed January 1, 2018, implementation of VDER policy on Long Island.
We oppose VDER because in its current form it will negatively impact solar adoption at a time when we need to accelerate deployment. The New York solar community is supportive of migrating to a new more dynamic pricing system for solar and consumption, and we are ready to work with LIPA toward that end. However, VDER, as proposed, has many design flaws and therefore adoption should be postponed for the following specific reasons:
- It reduces the payback and decreases the ability to predict savings for all demand account non-residential customers. This means that solar will be much harder for small, medium and large businesses and non-profits looking to invest in reducing operating expenses.
- Calculating the exact solar compensation rate is highly complicated and varies based on 5 factors. Key to forecasting is accurately understanding 12 month hourly total kilowatt-hour (kWh) and kilowatt (kW) data for the site consumption. Then, estimates for annual hourly solar production must be compared to historical hourly consumption, in order to predict the net hourly kW and kWh export.
- The solar community was only recently shown partial information about the calculation methods and values proposed for several of the value stack components, including Capacity Value, Demand Reduction Value (DRV), Locational System Relief Value (LSRV) and Environmental Value. Even in the initial review, there are many concerns and disagreements about the methodology and valuations.
- The rest of New York State only recently adopted VDER. Early reports suggest that solar demand is weak as a result. We should wait to observe how VDER impacts the rest of the state.
- Dynamic pricing for solar should be instituted at the same time as dynamic pricing for consumption. California, a leading market for solar, modified net metering to net metering 2.0. This new program still connects solar value to the cost to consume energy, and it also requires a new solar customer to use a time of use rate account. This design principle is absolutely vital, and something that the rushed state-level policy left out. LIPA/PSEG recognizes the importance of this in the Utility 2.0 proposal.
To properly launch VDER the Long Island Solar community requests the following:
- Easy access to minimum 12-month hourly interval data. At this time, there is limited access, and 12-month data unavailable for many 281 and 285 accounts.
- The exact calculations and formulas used to determine VDER value stack of 5 input calculations be made publicly available to allow for thorough public review and commentary.
- Dynamic pricing for consumption be put in place at the same time as dynamic pricing for solar generation to maintain fair and accurate price signals.
- Public Reporting of total solar generation as a percentage of the Long Island Energy mix reported quarterly. Further, a reporting of how this relates to New York State goals.
Postpone Adoption, Collaborate To Improve
A clear and reasonable alternative would be to postpone adoption VDER for a minimum of 24 months. Postponing implementation would provide time for a thorough public comment period, observe how VDER impacts the rest of the state, and collaborate to achieve the right solution.
About net metering: Any excess solar power sent back to the grid results in a net metering credit. This credit is worth the same as a unit of electricity that a homeowner would otherwise purchase from the grid, which can be used at night or during winter when solar production levels are lower.
What’s being proposed: Value of Distributed Energy Resources or VDER creates a value stack of 6 categories that place a variable price on solar net hourly exports. The value of the excess energy credit will vary based on many different factors including: time of day, time of year, and the value of energy in the client’s specific location.
The Solar Potential
We firmly believe that solar can generate the majority of the energy supply, and, coupled with storage, electric vehicles, smart grid technologies and more, can deliver a 21st century energy system that results in stable prices, clean air, clean water, mitigate climate change, and create robust regional economic development from the fast-growing clean tech sector. We believe it’s therefore imperative to promote policies that lead to robust and sustained growth of distributed solar and storage.
Thank you for this opportunity to comment and appreciate your consideration of our recommendations.
The following organizations have signed on to the above letter:
Long Island Association
Vision Long Island
Citizens Campaign for the Environment
Sustainability Institute at Molloy College
Renewable Energy Long Island
Sisters of St. Joseph
All Our Energy
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