March 22, 2022
In reply, please refer to:
Docket No. 21-08-02
Motion No. 26
Brad Mondschein
Deputy Executive Director
Solar Connecticut, Inc.
P.O. Box 515
Higganum, CT 06441
Re: Docket No. 21-08-02 – Annual Residential Renewable Energy Tariff Program Review and Rate Setting
Dear Attorney Mondschein:
On February 26, 2022, the Connecticut Solar and Storage Association (ConnSSA) filed a motion (Motion No. 26) with the Public Utilities Regulatory Authority (Authority or PURA). Specifically, Motion No. 26 requests that the Authority, in light of a shortage of meter sockets, require The Connecticut Light and Power Company d/b/a Eversource Energy (Eversource) and The United Illuminating Company (UI; collectively, the electric distribution companies, or EDCs) to utilize production data from inverters with revenue grade metering capability to verify the production of solar facilities under the Residential Renewable Energy Solutions (RRES) program. While ConnSSA’s specific requested relief is denied at this time, the Authority provides further clarification and direction herein to address the current anticipated meter socket shortage and to further investigate the use of inverter data in future program years.
In response to Motion No. 26, the Authority stated that it would hold a Technical Meeting on March 14, 2022, on the issues raised in Motion No. 26 and issue a subsequent ruling. Motion Ruling No. 26 dated March 1, 2022. The March 14th Technical Meeting included presentations from ConnSSA, in conjunction with various stakeholders from the solar industry, as well as Eversource, UI, and the Connecticut Green Bank (CGB).
Program Administration
The Authority first reiterates its expectation for the administration of the RRES program. Pursuant to the Authority’s Decision dated February 10, 2021, in Docket No. 20-07-01, PURA Implementation of Section 3 of P.A. 19-35, Renewable Energy Tariffs and Procurement Plans (Residential Tariff Decision), the EDCs were directed to establish and administer the RRES program. Residential Tariff Program, p. 43. Additionally, the Residential Tariff Decision set forth several objectives to guide the Residential Tariff rate setting process, including a goal to deploy approximately 60 megawatts (MW) per year of residential solar. Id., p. 7. Furthermore, the Authority established objectives to guide the EDCs in their administration of the RRES program. Id. The Authority reiterated the RRES program objectives in the present docket. See, Docket No. 21-08-02, Annual Residential Renewable Energy Tariff Program Review and Rate Setting, Interim Decision dated October 6, 2021, pp. 2-3.
The Authority expects the EDCs as program administrators to take ownership of the RRES program and play an active role in achieving the program objectives. Although the Authority, with the help of various stakeholders including the EDCs, developed the RRES program and has the ability to adjust the program rules through its annual review dockets, the EDCs play a crucial role in ensuring that the program objectives are met and, thus, are expected to take a leadership role in developing solutions to confront challenges that endanger the timely realization of the program objectives. As ConnSSA stated at the Technical Meeting, “[s]omeone needs to be held accountable for the success of the program…[and] those accountable need to be looking for technological solutions [to the present issues].” Technical Meeting Tr. 3/14/22, p. 7.
The Authority is disheartened by the lack of meaningful solutions offered by the EDCs to the equipment shortage issue, particularly in light of the proposed solutions offered by the Connecticut Green Bank at the March 14th Technical Meeting. The Authority is perhaps more disappointed that the EDCs have not already implemented any of their proposed solutions. As the Program Administrator, it should not require a PURA Technical Meeting for the EDCs to put in place no cost, common sense measures that may help alleviate barriers to achieving the program objectives, i.e., meter socket shortages, which the EDCs acknowledged present a potential risk to deploying 60 MW under the RRES program in 2023. Id., pp. 77-81. Ultimately, the lack of proposed meaningful solutions paired with the generally underwhelming responses provided during the Technical Meeting do not comport with claims that the EDCs are committed to meeting the program objectives.1 Id. pp. 73-81.
Authority Analysis and Direction
Based on the information provided by the EDCs in response to Motion No. 26, the Authority finds that integrating data from inverters with revenue grade metering capability will not provide the immediate relief ConnSSA and the rest of the solar industry seek. See, UI Response to Motion No. 26, p. 2; Eversource Response to Motion No. 26, pp. 2-3. However, as indicated in the Residential Tariff Decision, the Authority is open to the use of inverter data in the RRES program, particularly to the extent the systems and processes from the Energy Storage Solutions program can be leveraged.2 See, Residential Tariff Decision, p. 19. Accordingly, the Authority sets forth the direction below to further investigate the potential use of inverter data in the RRES program and to provide short-term relief to the effects of the meter socket shortage.
First, the Authority directs the EDCs to develop a least cost plan to utilize inverter data in the RRES program, leveraging the distributed energy resource management systems (DERMS) and other systems from the Energy Storage Solutions and Non-Residential Renewable Energy Solutions Programs, as well as any planned or proposed systems in the EDCs’ Advanced Metering Infrastructure plans. The EDCs shall submit their respective plans in the upcoming RRES program Year 2 Review, Docket No. 22-08-02, when it is initiated, for the Authority’s consideration. ConnSSA’s request to use inverter data will be revisited at that time.
Moreover, at the Technical Meeting, the EDCs indicated that it may be able to expand the list of approved meter sockets to help alleviate supply constraints. Technical Meeting Tr. 3/14/22, pp. 72-74. Accordingly, the Authority directs the EDCs to work with stakeholders in the solar industry to develop an expanded list of approved meter sockets. The EDCs shall submit to the Authority as a compliance filing a list of approved meter sockets no later than Friday, April 1, 2022. Once the list is submitted, the solar industry may continue to propose new sockets for the EDCs’ consideration for use in the RRES program.
Additionally, the stakeholders at the Technical Meeting indicated that Durham was a supplier who sells meter sockets directly to the EDCs only. Id., pp. 74-76. The Authority directs the EDCs to contact Durham to determine the wait time to procure 1,000, 2,000, or 3,000 meter sockets, respectively, and file a record of its communication with Durham, including Durham’s subsequent response, and proposed next steps to procure meter sockets for resell to solar project developers, no later than Friday, April 8, 2022.
Further, on March 15, 2022, the Authority issued Interrogatory CAE-8, which directed the EDCs to provide, by month, the total number and kilowatts (kW) (AC) of applications received for the Residential Renewable Energy Solutions (RRES) program, the total number and kW (AC) of applications approved for the RRES program, and the total number and kW (AC) of systems that received permission to operate under the RRES program. The Authority hereby directs the EDCs to submit, as a compliance filing in the instant proceeding, an update to CAE-8 on or before the 15th of every month, through January 1, 2023 (i.e., the final filing will be made on December 15, 2022).
Last, on March 22, 2022, the Authority issued Interrogatories CAE-9 through CAE-11 to the Connecticut Green Bank to better understand their proposed interim solutions to a meter socket shortage in the absence of an immediate inverter data solution. The Authority will evaluate those responses and the compliance filings received on the 15th of every month to determine any next steps regarding any interim production data solutions. Any next steps will be identified through the instant proceeding.
The Authority commends the EDCs’ efforts through 2021 and into 2022 to operationalize the RRES program design and the proactive approach to problem solving and customer education and outreach taken by each company during that time. By all accounts, the transition to the new residential solar program through the beginning of the calendar year was one of the more seamless processes the solar industry has experience in any jurisdiction. The Authority is hopeful that the EDCs will bring that same proactive approach to solving the matters outlined herein and to administering the RRES program moving forward.
Sincerely,
PUBLIC UTILITIES REGULATORY AUTHORITY
Jeffrey R. Gaudiosi, Esq.
Executive Secretary
cc: Service List
1 For example, the EDC staff present at the March 14, 2022 Technical Meeting were unfamiliar with how inverter data from distributed energy resources is being used in the EDC-administered Energy Storage Solutions program, despite its relevance to the present matter and the EDCs’ analysis that it would take upwards of twelve months and $2.5 million to utilize inverter data in the RRES program. Technical Meeting Tr. 3/14/22, pp. 89-93.
2 The Authority notes that the use of inverter data may also help facilitate the wholesale market participation under FERC Order No. 2222 in future years.
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