More Public Engagement Needed on New Solar Rules

Comments on NOPR RM29-2021-01

Submitted via email to psc-commissionsecretary@dc.gov

The Sierra Club’s Washington, DC Chapter has over 3,000 members and 10,000 supporters in  all eight Wards of the District. The Sierra Club regularly participates in Public Service  Commission (PSC) working groups and formal cases to advance the District’s clean and  renewable energy goals. The Sierra Club is generally supportive of efforts to collect more precise data about energy production from renewable energy systems and acknowledges that  current rules can be refined to improve the accuracy of reporting the production of energy from  solar systems. Accurate reporting helps ensure that the District is on track to reach its  renewable energy goals and reduce greenhouse gas emissions from polluting fossil fuels.
 
The Sierra Club, however, opposes the Notice of Proposed Rulemaking (NOPR RM29-2021-01) because it does not sufficiently articulate the problem with existing energy performance  reporting, does not provide a robust rationale for why the proposed changes to the rules are  necessary, and does not present a cost effectiveness evaluation of the changes.

This NOPR has been advanced without stakeholder discussion; therefore, we request that the PSC grant an additional 90 days for the convening of a stakeholder process consisting of no fewer than two meetings and the generation of a workgroup report. Owners of affected energy  systems and organizations representing the renewable energy community need to be heard by  the regulators and require more time and opportunity to weigh in on this proposed rulemaking.

This process should provide stakeholders with:

1. Data on how many systems may be reporting inaccurately,
2. The costs of retroactively installing new monitoring equipment, and
3. The assurance that the solution will be proportionate to the problem and that the burden  of fixing the problem will not fall on homeowners unable to afford it.

The Sierra Club is concerned that the proposed changes to the Renewable Energy Portfolio  Standard (RPS) regulations would impose onerous requirements on the owners of existing  small-scale solar installations. The PSC's NOPR does not demonstrate that the PSC has  analyzed the incremental costs and benefits to different groups of solar adopters. Some solar  systems might deserve different treatment under the rules, including (1) systems that do not  have any means to report actual performance and (2) systems that do have performance  reporting equipment installed, and can begin to report immediately, but may not meet the ANSI  C-12.20 meter standard. While having more detailed data from these types of installations  would be useful, requiring the level of reporting identified in the NOPR from existing systems  may impose a significant financial burden on District homeowners who rely on Solar Renewable  Energy Credits (SRECs) to pay back the costs of installing their solar systems.  

Additionally, the reporting requirements of the proposed rule present a significant time  investment on the part of owners. The Sierra Club recommends that the PSC conduct a more  thorough assessment of whether the benefits of the NOPR will outweigh the costs, and then consider refinements to the proposed rule. The Sierra Club encourages the PSC to account for  the financial and logistical burdens that would be imposed on the owners of smaller-scale solar  installations. The Sierra Club views the NOPR as insufficiently informed and presenting a  possible obstruction toward the hastening of the District toward its clean energy commitments.