Board of Public Utilities Two Gateway Center Newark, NJ 07102
ENERGY
I/M/O The Electric Discount and Energy)
Competition Act of 1999 – Net Metering) ORDER ADOPTING
Standards ) INTERIM STANDARDS
Docket No. EX99030182
(Service List Attached)
BY THE BOARD:
The Electric Discount and Energy Competition Act (“EDECA”), N.J.S.A. 48:3-49 et seq. requires that the Board adopt standards for the implementation of net metering applicable to electric power suppliers and basic generation providers for wind and solar photovoltaic systems, as well as attendant safety and power quality standards for such systems. N.J.S.A. 48:3-87.
On June 24, 1999, the Board released for public review and comment, draft Interim Net Metering, Safety and Power Quality Standards for Wind and Solar Photovoltaic Systems (“draft Interim Standards”). At that time, the Board indicated that it would conduct a public hearing on the subject draft Interim Standards and accept written comments through July 19, 1999. A public hearing, chaired by Commissioner Frederick F. Butler, was held at the Board’s offices in Newark on July 15, 1999, and written comments have been received.
Addressing the Board at the public hearing were representatives of the Division of the Ratepayer Advocate (“RPA”); Hydro Quebec Energy Services U.S. (“HQ”); Natural Resources Defense Council (“NRDC”); GPU Energy (“GPU”); Public Service Electric & Gas Company (“PSE&G”); and Gabel Associates.
Parties filing written comments on the Draft Interim Renewable Portfolio Standards included the Ratepayer Advocate; Atlantic City Electric Company (d/b/a Conectiv Power Delivery and known as “Conectiv”); GPU; New Energy Ventures (“NEV”); PSE&G; Rockland Electric Co. (“RECO”); the New Jersey Department of Environmental Protection (“NJDEP”); American Wind Energy Association; Integrated Waste Services Association; Mid-Atlantic Power Supply Association (“MAPSA”); First Energy Trading Services Inc. (“FET”); HQ; Energy Photovoltaics Inc. (“EPV”); New Jersey Business Users (“NJBUS”); GeoSolar, Inc.; and the Mid-Atlantic Solar Energy Industries Association. The Environmental Defense Fund, Natural Resources Defense Council,
New Jersey Public Interest Research Group (“NJPIRG”), Pace Energy Project and Union of Concerned Scientists submitted joint comments on net metering.
The group consisting of the Environmental Defense Fund, NRDC, NJPIRG, Pace Energy Project and the Union of Concerned Scientists asked that the Board clarify allowable interconnection costs, restrictions regarding contracts and method for calculating net metering credits. They also wanted “non-discriminatory” rates redefined to assure that customer-generators have the same rates as a regular customer and recommended that the 100 Kw limit should be retained.
GeoSolar and EPV both commented that net metering should be redefined, a single meter should be allowed, the financial impact of net metering should reflect the peaking nature of photovoltaic (PV) power and interconnection charges should be capped.
Mid-Atlantic Solar Energy Industries Association wanted net metering redefined and a single meter allowed. It also suggested that the financial impact of net metering should include the value of distributed generation to the system and for PVs, the peaking value and that a simplified application form should be developed and application fees capped at no more than $100.
The NJDEP felt that the Board should have the option of authorizing installations higher than the100 Kw limit, at its discretion, and that penalties should be imposed on a utility if it is not properly implementing the program.
GPU believes a size limit of 10 Kw should be sufficient to cover the needs of residential and small commercial customers. GPU suggests that to make units larger than 10 Kw eligible for net metering would provide larger customers with an inappropriate subsidy. GPU also proposed that the Board allow the utility to use a second meter, if it wants. This would provide more accurate data indicating the actual financial impact on the utility as well as the environmental benefits to the State.
PSE&G recommended a 10 Kw limit on net metering installations, and suggested that a unit of 100 Kw improperly connected to its distribution system could pose safety concerns. PSE&G also believes that if the 100 Kw limit is retained then utilities should be able to require additional liability insurance of customer-generators. PSE&G states that the financial impact, both on energy suppliers and distribution utilities, as well as lost revenues, should be included when determining the $2,000,000 threshold for program reevaluation.
The RPA indicates that standard contracts should be developed and reviewed by the Board and the RPA and that the net metering standards should clearly define how the supplier calculates the avoided wholesale cost of energy.
DISCUSSION
The Board has carefully reviewed all of the comments received, both oral and written, and changes have been made to the original draft standards in response to the various comments. In addition to routine clarifications and refinements to definitions, the major issue raised in the comments relates to the proposed 100 Kw size limitation of a unit and related utility distribution system interconnection requirements.
Since the Board, as part of the Comprehensive Resource Analysis process, has already received applications for photovoltaic customer-generator facilities larger than 10 Kw, the Board is satisfied that the higher, 100 Kw limit originally proposed is consistent with the EDECA requirement (N.J.S.A. 48:3-87) that net metering be available for residential and small commercial customers.
However, the Board is also concerned about the PSE&G suggestion that units above 10 KW, improperly connected to its distribution system could pose safety concerns. On March 27, 2001, Board Staff convened a meeting of interested parties, consisting of electric utilities, the RPA and renewable contractors and organizations, to further discuss the size limitations and interconnection requirements. At that meeting, the parties indicated that the Institute of Electrical and Electronics Engineers (IEEE) had developed interconnection standards for customer sited photovoltaic facilities. This standard, IEEE Recommended Practice for Utility Interface of Photovoltaic Systems, IEEE 929-2000, establishes uniform standards for facilities up to 10 Kw. IEEE 929-2000 also may be used as an interconnection guide for facilities from 10 Kw to 100 Kw, with adjustments, which would be specific to each distribution system.
Consequently, the Board has modified the draft Interim Standards to reflect that, for units up to 10 Kw, and except for areas served by network systems, IEEE Standard 929-2000 would apply. The Board believes that for units from 10-100 Kw and for areas served by network systems, further discussion is required, and therefore DIRECTS Staff to continue to meet with the parties and develop interconnection recommendations, within 120 days of the date of this Order, for future approval by the Board. While final interconnection standards are being developed, and in order not to delay customers interested in pursuing wind or photovoltaic installations, the Board DIRECTS that customer-generators comply with utility interconnection requirements. The Boards FURTHER DIRECTS the electric utilities to make compliance filings, including interconnection requirements for 10-100 Kw systems, within 30 days of the date of this Order.
In addition to the foregoing, the Board believes that the intent of EDECA is to encourage customers to explore renewable generation for their own energy needs, while not turning customers into net generators. Therefore, the Board has modified the Interim Standards to reflect that the 100Kw size maximum be conditioned upon the unit not exceeding the current peak electric needs of the customer-generator’s own residential or small commercial facility.
With the foregoing conditions, the Board ADOPTS the attached Interim Net Metering Standards so that the requirements for access to the electric distribution system for wind and solar photovoltaic customer-generators will be fair, consistent and known, and so that wind and solar photovoltaic customer-generators will be fairly compensated for the energy that they may provide to the electric distribution system.
These Interim Standards shall go into effect immediately upon filing with the Office of Administrative Law and will remain in effect for no longer than 18 months, until final rules are promulgated by the Board, as permitted by EDECA. During that period, the Board will gain experience with the solar photovoltaic and wind power industries and interconnection procedures so that final rules can be proposed.
DATED: BOARD OF PUBLIC UTILITIES
BY:
CAROL J. MURPHY
ACTING PRESIDENT
FREDERICK F. BUTLER
COMMISSIONER
ATTEST:
FRANCES L. SMITH
SECRETARY
Docket No. EX99030182
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