IUB Still Seeking Comments on Distributed Generation, Net Metering, & Innerconnection

Update: The current round of comments and replies in the Net Metering portion of this docket is closed. We will leave the explanatory section below for those interested, and provide updates and new guidance as the docket progresses.

On January 7, 2014, the Iowa Utilities Board (Board) issued an order commencing an inquiry docket into distributed generation (DG). DG includes the full spectrum of customer owned or third-party owned electrical generation systems. Solar photovoltaic (PV) are the most common and rapidly growing form of DG, and allow households, businesses, farms, and institutions to generate a portion of their own energy.

The IUB docket (officially known as NOI-2014-0001) is part of a nationwide push by large investor-owned electric utilities to add costs and regulatory and connection hurdles to DG in order to restrict its growth. The Board has been narrowing the investigation, and the most recent request for further comments is focused on net metering. The history document called the Gold Memo summarizes the case to this point and relevant issues, and the Solicitation Order provides a briefer background and the specific question list.

For a somewhat extensive review of the context, history, process, and issues involved in this docket, see our initial overview from 2014, or the other documents also linked in the left sidebar. The key is that WE ALL SUBMIT SOMETHING, REGARDLESS OF HOW TECHNICAL, or whether you feel qualified. If you pay electric bills you ARE qualified and DESERVE  to be heard. As this docket proceeds through mutliple rounds, it is natural that the larger numbers of early commenters lose interest or feel intimidated, and utilities are left as the principal participants with few other voices involved.

Important points for submitting comments in the current round:

1. You do not need to reply to every question or write extensively. If you have submitted comments in previous rounds, remind the Board of this. Say what you want to say and submit it.

2. Use your experience! It matters to hear WHY customers want to install solar/DG, why it is important the rules of the game enable maximum participation with minimum fees or obstruction to energy citizens and communities.

3. From economics to ethics, Iowa communities and energy customers want to participate in the energy world. Local ownership, investment, and participation matter, and the Board should act in the interest of all Iowan’s. DG is not fringe anymore, it is mainstreaming. Utilities do have a social compact with society but that does not extend to a 100% guarantee of forever profits for investors, that would be the ultimate bailout and moral hazard. Investors need to hold executives accountable to changing conditions in the energy world, while regulators need to act in the best interests of ratepayers, citizens, and communities.

4. Possible talking points (make then your own) regarding net metering:

  • Net metering may not be a perfect solution for all situations but it is an amazingly elegant, straightforward, and fair approach for the vast majority of utility/grid customers. If it ain’t broke, don’t fix it, and where customers have site options to install DG (rooftop or open space) net metering WORKS. There is no crisis in Iowa with “too much DG”, the Board should not allow utilities to impose extra costs on DG customer owners, and in fact should expand net metering to fairly cover all customers.
  • The utilities say solar customer-owners do not pay their fair share of the grid costs and shift infrastructure burdens to non-DG customers. This is untrue, because solar DG also contributes a great deal of value to the grid, including helping with peak demand, supporting voltage and frequency regulation, reducing new transmission needs, and of course providing significant customer investment into renewable energy.
  • Many customers however do NOT have suitable site options, or other challenges to “behind-the-meter” DG connection. This is why “community solar” with some form of “virtual net metering” is highly recommended: customers could “subscribe” or buy into a community project, be partial owners, and utility would apply their portion of generation against their monthly bill just as if the system were on their roof.
  • Third Party Power Purchase Agreements, or PPAs, are now legal in Iowa, yet utilities are refusing to allow net metering in PPA situations because the utility customer does not own the system. The Board should make it clear that PPA arrangements ARE eligible for net metering as is the case in other states, because the power being fed to the grid from the customer’s side of the meter is owned by the customer, and that is the consistent with the letter and spirit of net metering.
  • The Board should be very careful to not allow utilities to put up roadblocks or add costs to DG customers that are or will be perceived to be punitive, discriminatory, or otherwise in opposition to customer and community ownership. This will contribute to customer alienation and, as customer-owned storage becomes increasingly economically viable, growing grid defection/disconnection. Keeping net metering and ensuring it applies to everyone (including virtual net metering and net metering in PPA situations) will greatly contribute to healthy and collaborative grid evolution in Iowa, as opposed to the grid chaos and deterioration if customers (large and small) feel disenfranchised and unheard.

Click here to access the IUB electronic filing system to submit a comment

Click here for a step-by-step guide to submitting your comment

Energy District Testimony

Talking Points

Distributed Generation Case Studies, Resources and Articles

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