Community Solar Projects Should Not Face Additional Regulatory Hurdles

Brinda Westbrook-Sedgwick, Commission Secretary
Public Service Commission of the District of Columbia
1325 G Street, NW, Suite 800
Washington, DC 20005

VIA EMAIL

Re:  Notice of Proposed Ruling For Chapter 29 as Published on October 23, 2020

Dear Commission Secretary:

Thank you for the opportunity to provide comment on the Notice of Proposed Ruling (NOPR) published October 23, 2020 in the D.C. Register, which proposed amendments to Section 2902 of the Commission’s Renewable Energy Portfolio Standard (RPS) rules.

The Sierra Club supports prioritizing equity and inclusivity in the solar marketplace and allowing those across all incomes, both renters and homeowners, to be able to participate in the renewable energy sector.  Community solar projects offer this opportunity, and we support these projects as means to achieve this equity.

Toward that vision, the proposed NOPR as written would jeopardize – and potentially kill – a small community solar project located at an affordable housing community on the DC feeder that would serve at least 30 low-income residents with no-cost solar electricity, cutting their energy burden in half. The project is a collaboration between DC-based nonprofit Groundswell and the Montgomery County Green Bank.

This project has been in development for two years and has overcome many hurdles. Interconnection and permitting requirements have been completed and the project is poised to begin construction. Access to the DC SREC market, based on the project’s location immediately adjacent to the DC Feeder, is essential to meeting the project’s equity goals for low-income residents. The PSC’s July Notice of Proposed Rulemaking would have allowed the project to proceed, and the project developers were taken by surprise by the Second Notice of Proposed Rulemaking, which if finalized in its current form would prevent this beneficial project from coming to fruition.

The project is specifically designed to meet the values and policy priorities that DC and its neighbors in Maryland share related to community solar, equitably serving low- and moderate-income residents, and leveraging investments in clean energy to support inclusive prosperity. Furthermore, low- and moderate-income families have been disproportionately impacted by COVID, and relieving these families of electric utility payments will help them recover from the economic hardship of the pandemic.  

The Sierra Club supports this project. We urge the Public Service Commission to include a provision in its ruling that enables community solar projects that serve low- and moderate-income residents and that have achieved Authorization to Install (ATI) from Pepco by the time of the final rulemaking to be allowed to proceed under existing provisions. “Grandfathering” such LMI community solar projects will support the goals of equity, inclusivity, and access while also providing clarity for the future.

Sincerely,

Lara Levison
Chair, Clean Energy Committee
Sierra Club DC Chapter