Sierra Club Seeks Faster Expansion of Solar Energy in DC

The Sierra Club hereby provides comments regarding the Notice of Proposed Rulemaking to amend Chapter 9 (Net Energy Metering) of Title 15 of the District of Columbia Municipal Regulations as outlined in the DC Public Service Commission’s filing RM9-2020-03-M.

We applaud the Commission for raising the generation threshold for net metering facilities to 200 percent of the historical usage over the previous 12 months. The proposed change is an important contribution toward supporting the District’s commitment under the Renewable Portfolio Standard to produce 5 percent of DC’s electricity from locally-generated solar by 2032 and 10 percent by 2041.

The Sierra Club is disappointed the Commission is phasing these changes incrementally in steps of 20 percent per year over five years. This issue was first raised in 2018 in the relevant Commission working group, meaning the slow phase-in comes after a lengthy process to arrive at a relatively simple change in rulemaking.

The Sierra Club urges the Commission to allow net metering for 200 percent of the historical usage over the previous 12 months in two steps: a 120 percent threshold for 2020, as proposed in this rulemaking, a 150 percent threshold for 2021, and a 200 percent threshold for 2022. Our suggestion means reaching the final threshold two years earlier than the Commission’s proposal, putting DC much closer to achieving the 2032 and 2041 climate commitments the Commission is statutorily obligated to uphold. Our proposal accelerates the introduction of the desired threshold while still allowing for ample opportunity to review the experience and learn incrementally. The Commission should consider Maryland’s successful experience allowing a 200 percent threshold when determining whether to accelerate solar energy in DC. We believe a faster phase-in is consistent with the Clean Energy DC Omnibus Act of 2018, which mandates that the Commission uphold “the preservation of environmental quality, including effects on global climate change and the District’s public climate commitments.”

To meet DC’s climate commitments, the Commission must move quickly. A photovoltaic (PV) system installed before the full 200 percent of the historical usage threshold is allowed will likely remain undersized for the rest of its lifetime. A homeowner who installs a smaller system due to the slow phase-in will likely not upgrade the system later on when the threshold rises due to the fixed costs of installation, permitting and system design. The Commission’s proposed five-year phase-in, not completed until 2024, will stymie the District’s ability to meet its 2032 and 2041 solar commitments.

The Commission’s new climate mandate was not law for much of the time that the relevant working group on this issue met, nor were DC’s upgraded solar energy commitments. Thus, the Commission’s approach to raising the solar generation threshold should be updated. The Sierra Club urges the Commission to move boldly to expand solar energy in the District.