PUBLIC COMMENTS
SUBMITTED TO THE
LOUISIANA PUBLIC SERVICE COMMISSION
RE: PHASE II - NOTICE OF PROPOSED MODIFIED RULES AND REQUEST FOR COMMENT
DOCKET NO. R-33929
SUBMITTED BY: SIERRA CLUB DELTA CHAPTER
Julie Rosenzweig, Chapter Director
PO Box 52503
Lafayette, Louisiana 70505
JANUARY 26, 2018
1. INTRODUCTION
The Delta Chapter of the Sierra Club, which encompasses the entire state of Louisiana, is a non-profit corporation seeking to explore, enjoy and protect the wild and beautiful places of Louisiana; to practice and promote the responsible use of Louisiana’s ecosystem and resources; and to educate and enlist people to protect and restore the quality of the natural and human environment. Our 3,400 members live in, work in, and enjoy the natural world of Louisiana.
2. BACKGROUND
Net Energy Metering (NEM) allows residential energy consumers to get credit for the energy they produce on their property. If a homeowner has installed solar panels on the roof of his home, yet does not use all of the energy that the solar panels produce every month, net metering enables the homeowner to get credit for the excess energy from his energy provider.
Currently, Louisiana’s net metering rules allow for a homeowner to utilize all of the power their solar panels generate and then receive credit at a wholesale rate or “avoided cost” for any excess energy. The rules also include a grandfathering clause which locks in the rates, for the excess energy, for the life of the system. This means that if the homeowner installed solar panels with the understanding that they would receive a 1-for-1 kWh credit for each kWh excess their system produced, that 1-for-1 credit is locked in for the life of their solar panels.
4. CHANGES THAT WILL RESULT FROM APPROVAL OF NEW N.E.M. RULES
The Louisiana Public Service Commission (PSC) proposed changes to its NEM rules intended to have applicability to all small-scale Distributed Generation (DG) technology going forward, and the instant comments pertain to the request for public comments issued for these proposed NEM rules.
The proposed rules changes have the potential to eliminate net metering all together, opening the door for a “Buy all, Sell all” market, meaning that the homeowner would be forced to sell all of the energy his solar panels produce to his utility at avoided cost and then buy all of the energy his family uses at the standard retail rate. This would also apply to existing solar customers, as the proposal only includes a grandfathering clause for five years. So even though the homeowner made an investment based on a certain understanding, the new rules are poised to turn the tables on him to where his investment may not “pencil out.”
The proposed modified rules eliminate the 1-for-1 credit that people with solar panels get from their utility company for producing clean energy and delivering it to the grid. Without the credit, utilities can take the energy generated on private property, at below market value, and re-sell it for a profit. They can also charge additional fees, allowing costs to vary widely by utility, leaving customers and businesses with no statewide standard to rely on.
No economic justification for these changes have been provided despite multiple calls from experts requesting a cost-based analysis. The draft rules are out of step with national practices and ignore the increasingly important role of Distributed Energy Resources (DERs) in diversifying generation and strengthening reliability. Despite the stated purpose of the rules, they inhibit and do not encourage growth in distributed generation and solar adoption. These proposed changes could hurt small businesses owners and stifle job growth among solar installers.
5. REQUEST FOR PUBLIC SERVICE COMMISSION TO REJECT
PROPOSED MODIFIED N.E.M. RULES
For the foregoing reasons, the Sierra Club Delta Chapter requests that the Louisiana Public Service Commission reject the above-referenced proposed modified NEM rules. If changes to NEM must be made, the Delta Chapter requests that the PSC propose changes that are based on data derived from a new study using 2018 data, conducted by an independent consultant with no past ties to the fossil fuel industry or any energy utilities.