The following comments were submitted by the Vermont Sierra Club regarding the Department of Public Service (PSD) proposals concerning the biennial adjustment of net metering compensation rates. You can submit a comment as well by:
Using the Sierra Club's action alert page , or
Sending a personalized message via email to the Public Utilities Commission to puc.clerk@vermont.gov, and the subject line should include "Biennial update of the net-metering program (26-0291-INV)."
To: Vermont Public Utility Commission
Re: Comments on Case No. 26-0291-INV: In re: biennial update of the net-metering program
Objections to PSD Proposal #1: Rulemaking and Avoided Cost Transition
The proposal by the PSD to fundamentally revamp net metering by reducing the value of excess generation to the avoided cost of electricity supply (approximately 6 to 7 cents/kWh) represents a destabilizing shift in Vermont’s energy policy. By eliminating the blended rate increase, this proposal disproportionately harms community solar and off-site net metering customers for whom nearly all generation is classified as "excess." Furthermore, the absence of new adjustors fails to counteract the recent, abrupt termination of the 30% federal Investment Tax Credit (ITC). Relying solely on avoided cost metrics fails to reflect the true value of net metering to the grid and the environment. A full, open rulemaking in the current political climate is fraught with risk and likely to yield adverse outcomes for both current and future Vermonters seeking energy independence.
Analysis of PSD Proposal #2 and Economic Impacts
While the PSD’s second option, which would entail increasing the blended rate to 20.71 cents/kWh while further reducing the current adjuster to -6 cents/kWh, is comparatively less severe than a total transition to avoided cost net metering, it remains problematic. These proposed changes would undermine the financial stability of the 20,000 Vermonters currently participating in net metering. The resulting devaluation of bill credits would impose significant hardships on schools, municipalities, and non-profits, potentially increasing property taxes in school districts that rely on virtual net metering. These cuts also threaten high-quality jobs in the solar sector and make renewable adoption unaffordable for the average homeowner. At a time when Vermont must take decisive action to achieve its emissions reduction goals, these cuts send the wrong signal.
Regulatory Expectations and the Path Forward
Vermonters maintain a reasonable and settled expectation that the blended rate will be updated biennially in accordance with PUC Rule 5.100. Failure to adjust these rates upward to reflect current economic realities subverts this regulatory framework and penalizes thousands of citizens who made good-faith investments in renewable energy. While solar must eventually be paired with storage and supplemented by wind to ensure grid resilience, penalizing current solar adopters does not solve underlying equity concerns.
Instead of devaluing existing investments, the Commission should:
- Uphold the integrity of Rule 5.100 by updating bill credits as required by law.
- Increase compensation for new systems to bridge the gap created by the loss of the federal ITC.
- Shift the policy focus toward local resilience and distributed generation, which provide tangible benefits to Vermont’s grid and help the state achieve statutorily binding climate goals.
The Commission must reject any policy that threatens the financial viability of community solar arrays and instead foster an environment where affordable local renewable generation remains a cornerstone of Vermont’s energy future.
Thank you,
Robb Kidd
Chapter Director, Sierra Club Vermont Chapter