Help Stop APS from taxing solar

MikeSus

We Need Your Support To Stop The APS Solar Tax
We Need You November 13


On November 13, we will find out if APS managed to convince the Arizona Corporation Commission to tax the sun. At 9a.m. at the Commission offices at 1200 West Washington Street commissioners will hold a hearing to decide if APS’ tax on solar energy should be approved.

We need your support at this meeting. Pleased attend if possible. Let the Commission know you stand for solar choice.

APS, through shady third-party groups has flooded the airways with messages attacking solar customers. So much money was spent that the Arizona Republic investigated. APS was forced to admit it was funding the messages.

APS’ shady behavior should not be rewarded. Their call to tax solar energy should be rejected.

Its passage will effectively end private rooftop solar as we know it. More importantly if this measure passes, APS will cement its position as a monopoly and the sun will set on energy choice. Approval of the APS plan amounts to a $2 billion dollar subsidy for the utility monopoly.

Please attend this critical meeting and send a message to state regulators.

When: Wednesday November 13, 9a.m.
Where: Arizona Corporation Commission Offices 1200 West Washington Street, Phoenix
Why: To prevent APS from taxing the sun

If you can’t make the meeting you can still support solar choice by emailing the members of the Arizona Corporation Commission.

Please consider expressing your support for net metering by emailing the Arizona Corporation commission.

Please indicate you are referencing docket number

E-01345A-12-0290

The following email addresses go directly to the commissioners. The last one goes to the utilities division

Pierce-web@azcc.gov
Burns-web@azcc.gov
Stump-web@azcc.gov

BitterSmith-web@azcc.gov
RBurns-web@azcc.gov
mailmaster@cc.state.az.us

solar_dave

Re: Help Stop APS from taxing solar

Thanks for this Mike.

SolInvictus

Re: Help Stop APS from taxing solar

APS is trying to apply a flat fee to grid-tied residential PV systems or alter net-metering to reduce the price per kilowatt hour that they pay for the PV electricity. The price reduction applies to all electricity generated whether or not it is surplus. The rule change does not apply to current owners of grid-tied PV systems for 20 years. Some background information:

Arizona Mulls Solar 'Tax', Sustainable Business News, 8/1/2013

Solar Industry Takes on Crony Capitalism in Arizona, The Christian Post, Rachel Alexander, November 4, 2013

With the extreme hostility Arizona Public Service Company is showing for photovoltaic systems and the success it is presently having with the Arizona Corporation Commission, it might be best to abandon this monopoly altogether by going off-grid.

MikeSus

Re: Help Stop APS from taxing solar

SolInvictus wrote: »

APS is trying to apply a flat fee to grid-tied residential PV systems or alter net-metering to reduce the price per kilowatt hour that they pay for the PV electricity. The price reduction applies to all electricity generated whether or not it is surplus. The rule change does not apply to current owners of grid-tied PV systems for 20 years. Some background information:

Arizona Mulls Solar 'Tax', Sustainable Business News, 8/1/2013

Solar Industry Takes on Crony Capitalism in Arizona, The Christian Post, Rachel Alexander, November 4, 2013

With the extreme hostility Arizona Public Service Company is showing for photovoltaic systems and the success it is presently having with the Arizona Corporation Commission, it might be best to abandon this monopoly altogether by going off-grid.

Don't throw the towel in yet. Get folks to email, doesn't matter if you are in the state or not. I can guarantee if APS succeeds your power company is next.

SolInvictus

Re: Help Stop APS from taxing solar

Is this good text for an email?

Please deny Arizona Public Service Company's Request to Reallocate Production Based Incentive Funding, docket number E-01345A-12-0290, scheduled to be considered in the Regular Agenda during the open meeting on November 13 and 14, 2013. Passage of APS's request would suppress the deployment of renewable energy in the areas serviced by APS and cement APS's status as a monopoly while profiting excessively from those who, despite being underpaid for their electricity generation, deploy grid-tired renewable energy systems.

Notice of Open Meeting of The Arizona Corporation Commission on Nov. 13 and 14, 2013

10. Arizona Public Service Company (E-01345A-13-0248 ) - Application for Approval of Net Metering Cost Shift Solution.
***Note, the Commission intends to hear public comment on Item No. 10 on November 13, 2013 and each commenter will be limited to 3 minutes.***

11. Arizona Public Service Company (E-01345A-13-0140) - Application for Approval of its 2014 Renewable Energy Standard Implementation Plan for Reset of its Renewable Energy Adjustor.

There are two docket numbers. The agenda suggests E-01345A-13-0248 is the one we do not want them to approve.

eDOCKET describes E-01345A-13-0248 as

Filed Date: 7/12/2013
In the matter of the application of Arizona Public Service Company for approval of net metering cost shift solution.

and E-01345A-12-0290 as

Filed date: 6/29/2012
In the matter of the application of Arizona Public Service Company for approval of its 2013 renewable energy standard implementation for reset of renewable energy adjustor.

Per Procedural Order dated 02/15/2013 docket #s E-01345A-10-0394, E-01345A-12-0290, E-01933A-12-0296 and E-04204A-12-0297 are consolidated

Per procedural order dated 09/28/2012 docket #'s E-01345A-10-0394 and E-01345A-12-0290 are consolidated

solarix

Re: Help Stop APS from taxing solar

Not to dissuade anyone from putting in their 2 cents, but we have it on good authority from a solar customer who is personal friends with one of the commissioners that they are going to postpone this decision for 2 years until they do a full-blown rate hearing with APS. The net-metering issue has become too hot (thanks to all your interest) for them to handle at this time. The issue is not going away though. Keep those comments coming as Utilities nationwide know they have to change their business model due to affordable solar and haven't figured out how to do it yet without hurting their pocketbooks.

solar_dave

Re: Help Stop APS from taxing solar

Well they already slipped through the change to EPR 6 rate plan to lower the true up payback from ~$0.065 to $0.0289. They are not done so lets keep tabs on these less than solar friendly corporations.

MikeSus

Re: Help Stop APS from taxing solar

solarix wrote: »

Not to dissuade anyone from putting in their 2 cents, but we have it on good authority from a solar customer who is personal friends with one of the commissioners that they are going to postpone this decision for 2 years until they do a full-blown rate hearing with APS. The net-metering issue has become too hot (thanks to all your interest) for them to handle at this time. The issue is not going away though. Keep those comments coming as Utilities nationwide know they have to change their business model due to affordable solar and haven't figured out how to do it yet without hurting their pocketbooks.

That is good to hear, but I don't trust ACC to necessarily do the right thing.

solar_dave

Re: Help Stop APS from taxing solar

Spending by Arizona Public Service Co. and solar groups in a fight over net metering may be getting a review from the Arizona Corporation Commission.

Commissioner Bob Burns has asked APS, the state’s largest utility, as well as Tucson Electric Power Co., Unisource Energy and other electric companies to submit information into any potential involvement in bringing in third-party groups to lobby on the net metering issue.

In his letter to other commissioners, Burns also requested information from the solar companies.

His major concern is that utilities are using money from ratepayers to fund ads, and finding out whether the utilities will try to recover those funds through their next rate increase.

APS has said it has pushed money to two outside groups, 60 Plus and Prosper, that have been running ads attacking several solar industry companies.

The Arizona Solar Energy Industries Association last week called on the ACC to investigate spending by the utilities on the outside groups.

The ads were in response to a fight over how much solar customers are paid by APS for their excess power, a process known as net metering. APS officials spent six months meeting with solar companies in discussion of the process, saying they were shifting costs from solar customers to non-solar customers.

Solar companies that are based in the state or have large operations here have mounted a counterattack with television ads of their own aimed at promoting the program and solar in general.

The ACC is set to discuss what to do with net metering, if anything, in November.

http://www.bizjournals.com/phoenix/blog/energy-inc/2013/10/corporation-commission-may-review-aps.html

Maybe they will, but I think the ACC is in the pocket of APS.

APS Proposal To Tax Solar Energy Gets Big “No” From Arizona Corporation Commission Staff



The staff at Arizona Corporation Commission has issued a memo advising Commissioners to reject both of APS’ proposals to kill competition by taxing solar savings.

According to their report:

“Staff recommends that the Commission not approve either of the NM cost-shift solutions proffered by APS in the instant application for the reasons discussed above. Instead, Staff recommends that no changes be made at this time, but instead, this issue be evaluated during APS’s next rate case.”

The staff report also said the APS proposals yield unwarranted increased revenue to APS without giving money back to the people.

ACC Staff’s report comes after a July 16 letter by Commissioner Gary Pierce to Staff requesting help in analyzing APS’ net metering proposals, primarily due to Staff’s “experience in analyzing costs and revenues related to rate cases.”

APS seeks to end net metering, a process by which rooftop solar customers are fairly compensated for excess electricity they send back to the grid.

The utility’s reaction to the report is stunning in that APS fails to mention its plan was outright rejected. Here is an excerpt from APS’ statement:

“We stand by our initial proposal and we look forward to working with the commissioners, staff and other stakeholders on
developing the right solution for our customers.”

APS has taken spin to a whole new level, a complete departure from reality.

About T.U.S.K
T.U.S.K (Tell Utilities Solar won’t be Killed) was formed to stand for energy choice and energy independence. T.U.S.K. Chairman Barry Goldwater Jr. said, “The Corporation Commission staff doesn’t buy APS’ false claims and let’s hope our Corporation Commissioners heed the expert advice of their staff.”

To learn more about T.U.S.K. visit www.dontkillsolar.com

T.U.S.K. believes that rooftop solar is similar to a charter school—it provides a competitive alternative to the monopoly. Monopoly utilities aren’t known for reducing costs or for driving business innovation, but the Arizona solar industry is. Solar companies have a track record of aggressive cost reduction in Arizona. The more people use rooftop solar, the less power they need to buy from the utilities. Energy independence for Arizonans means smaller profits for the utilities, so APS is doing everything it can to stop the spread of independent solar. Recently, APS has proposed a plan to tax rooftop solar out of existence.

http://cleantechnica.com/2013/10/03/aps-proposal-tax-solar-energy-gets-big-arizona-corporation-commission-staff/

I saw in another article that APS's corporation spent $3.7 million on the add campaign. Now why would APS spend all those dollars of the shareholders if it wasn't about their profit picture. I wonder what the SEC would say about this.

Ian S

Re: Help Stop APS from taxing solar

solarix wrote: »

Not to dissuade anyone from putting in their 2 cents, but we have it on good authority from a solar customer who is personal friends with one of the commissioners that they are going to postpone this decision for 2 years until they do a full-blown rate hearing with APS. The net-metering issue has become too hot (thanks to all your interest) for them to handle at this time. The issue is not going away though. Keep those comments coming as Utilities nationwide know they have to change their business model due to affordable solar and haven't figured out how to do it yet without hurting their pocketbooks.

This is good for now. I would still urge folks to contact the commissioners. I attended a meeting this summer where Susan Bitter Smith was the speaker and she gave some tips on contacting the commission. First and foremost, don't rant! That, understandably, turns them off. What they are interested in is how their decision may affect you as an individual and how you perceive it may affect the state, the environment, etc. Some points I think aren't getting much exposure are the following:

1. APS' plan for grandfathering screws those on a lease who might have to sell and move before their lease is up. The grandfathering should be allowed to pass on to the next owner just as the lease will.
2. APS seems to completely ignore the large investment folks make in solar either through purchase or leasing.
3. APS doesn't seem to mind sticking it to ratepayers to build their huge solar farms so why are they attacking the rooftop solar segment so strongly. The only reason I can see is that they don't get to control the rooftop solar like their solar farms. It's a control issue.
4. APS also ignores the effect of the year-end true-up changes. It's looking like I will have hundreds of kWh's of peak usage that APS sold to my neighbor months ago @ $0.25 reimbursed to me @ 0.029. Nice profit margin there!
5. Now we're seeing anti-solar ads by the Edison Institute a national group representing major utilities. Make no mistake, this battle is going nationwide.
6. Our excess solar production goes to our next-door neighbors thus not putting much if any strain on the grid unlike huge remote solar farms. APS should be encouraging more not less of the distributed approach.

ggunn

Re: Help Stop APS from taxing solar

Ian S wrote: »

This is good for now. I would still urge folks to contact the commissioners. I attended a meeting this summer where Susan Bitter Smith was the speaker and she gave some tips on contacting the commission. First and foremost, don't rant! That, understandably, turns them off.

This is good advice. Many people torpedo their own arguments by slipping into rants and hyperbole. Once you say something like "APS is taxing the sun!!!", which is a hyperbolic and ridiculous claim, you might as well sit down and shut up because the folks on the other side of the table are no longer listening.

MikeSus

Re: Help Stop APS from taxing solar

ggunn wrote: »

This is good advice. Many people torpedo their own arguments by slipping into rants and hyperbole. Once you say something like "APS is taxing the sun!!!", which is a hyperbolic and ridiculous claim, you might as well sit down and shut up because the folks on the other side of the table are no longer listening.

I was quoting an email that I received from TUSK. Should have stated source.

I do agree tho. One of the best arguments pro solar is the fact that APS is getting the energy for wholesale rates without any line loss. (my neighbor gets my excess and is 15 ft away)

Found a good explanation of why grid tie and net metering is a good idea.


"Grid-Tie energy economics: Here is why the (clear thinking) utilities love grid-tie. When you produce an excess 1 kW back into the grid, it really goes no farther back into the grid than the nearest 1kW load (your neighbor!). Now your power company still gets to charge your neighbor for the 1kw, but does not now have to generate 2kW worth of electricity at the generator to make up for the distribution losses. And in avoiding generating 2 kW of power, they save more than 4 kW energy equivalent in coal that they can save for later. Often times, the utility might have to pay 10 to 20 times the normal rate of electricity from peaking-plants to meet peak demand. Grid-tie solar in that case is worth 10 to 20 times its value!

You win, you pushed your meter backwards 1 kW
Your neighbor wins (he gets the 1 kW at standard rates)
The power company wins (they don't have to burn the 4kw of coal)
The power company also does not have to buy that 1kW at 10 to 20 times the cost from a neighbor utility"


Would love to see APS argue the math...

westbranch

Re: Help Stop APS from taxing solar

have a read of this article for some good points to use

http://www.smartplanet.com/blog/take/myth-busting-germanys-energy-transition/1275

BB.

Re: Help Stop APS from taxing solar

You want the math?

Typical (probably older) A/C unit that uses 1,000 kWH per month. They will run around 0.67 Power Factor. At this time, pretty much all GT Inverters are programmed to output 1.0 PF power.

1,000 kWH * 1/0.67 PF = 1,492 kVA per month
1,000 kWH power from GT tied.
1,492 kVA - 1,000 kWH provided by GT = 492 kVA to be supplied by utility

492 kWH energy per month from Utility Power Plants that they still have to provide even in the middle of a sunny Arizona Day--and the utilities don't get to charge for that power (kVA is not charged for residential billing--at this time).

Commercial customers (in our state, and probably most others) are having to pay for some form of "Reservation Charges" (15 minute peak load in the last year) and Power Factor Penalty (something like worst 15 minute PF in the last year in our region). And newer GT inverters can be programmed to output from -0.80 to +0.80 PF (no more solar array needed, but GT inverter+wiring have to be 1/0.80 heavier to handle non 1.0 PF power).

So, there is no free lunch here. The math (and economics) are complex.

While I would agree that the utility is trying to slant the discussion to favor their math--The solar RE companies are trying to slant the discussion their way too.

All I can say is try to keep both sides honest in the conversation. The economics (and technology) are changing much faster than the State PUS and various bureaucracies care capable of changing.

Just keep in mind what happened in California... We had "deregulation" (really just a wholesale change in utility regulation) in the 1990s that went "swimmingly" until it failed... Then we had rolling blackouts, utilities going bankrupt, and other utilities gaming the system for huge profits (and the Enron's of the world)--And ended up with a $25,000,000,000 40 year bond to pay for a two summers worth of (PUC approved peak rates/inter-tie charges) power before they fixed it.

I am no longer paying $0.40 per Mbyte or $30 per month for 1,200 BAUD dial-up Internet. I am paying $70 a month for 250 GByte of cable internet (not cheap these days either--But not $100,000 that 250 GByte of data would have cost me "in the olden days"). And the major "data companies" of the time are either gone or barely keeping their head above water (AOL, EarthLink, AT&T local phone loop, etc.). And we don't buy 8 mpg 3/4 ton pickups anymore (friend's son just bought one and is now trying to figure out what to do).

It is terrible--But the professional lobbyists on both sides are in a bidding war for the controlling the state regulators. When Solar RE was less than 1% of the installed generation capacity--We could afford to "ignore" the economics and system engineering issues... When it gets over ~10% of the installed generation base--It can no longer be ignored--But must be metered/controlled/charged/regulated/tariffed just like any generation source. The argument really is "how much is solar RE power worth socially compared to other sources of power". No engineer is going to be able to satisfactory answer that question in a political forum.

We are having the same discussions about the questions of hybrids/electric/and other highly fuel efficient/alternative (no road taxes) vehicles. If some people pay for that concrete/asphalt ribbon (the "Hummer" crowd) while others don't (the EV crowed)--Something going to give. Either the Hummers/Trucks/Large Vehicles will pay more (and shipping/commuting will become even more expensive for those people/companies), or you will see an alternative. Whether it is a flat $64-$100+ per year registration fee or installing a GPS in every car and charging road tax based on where you drive/time of day/day of week... Something is going to happen.

My fear is that any of the "modern" solutions are going to erode our privacy even more (anyone trust our GPS road tax data won't be used for writing tickets/NSA data hoovering/IRS/etc.?). And anyone that wants to kill the GPS vehicle billing system--Just a simple oscillator to generate a tiny amount of radio frequency hash at 1.2 GHZ will kill satellite navigation for anyone for miles around.

The Hunt for RFI: Unjamming a Coast Harbor

The regulations will have to change. There is nothing magic going on here. It is ugly and probably not going to get better anytime soon.

-Bill

MikeSus

Re: Help Stop APS from taxing solar

In your explanation because they generate it if its not needed solar should pay for it? Ummm no.

The excess kw that I create go directly to the nearest load, that would be my neighbor. And unless the electrons are pink (sic) they are charging the same fees etc that they would for electric generated by coal or nuclear.

That argument also assumes that we have exceeded demand and now they are generating waste. I thought in the current system they sell excess, is that no longer happening?

ggunn

Re: Help Stop APS from taxing solar

MikeSus wrote: »

The excess kw that I create go directly to the nearest load, that would be my neighbor.

Not quite. Once the energy passes out through your meter it becomes free range kWh's. It goes into the bucket with all the rest of the power that is available on demand to the utilities' customers, and just like with a bucket of water, once a drop goes into it the drop doesn't exist as a separate entity any more.

You are correct, of course, that energy is sold by the utility at whatever their going rate is, whether they got it from you or generated it themselves or bought it on the spot market, and whether it's to your neighbor or to someone across the state from you. But they bought energy from you and they are free to sell it for whatever they can get for it. You agreed to that selling price, whatever it is, when you signed the interconnect agreement.

SolInvictus

Re: Help Stop APS from taxing solar

Does anyone have a link to the text of APS's proposal?

I will not email the ACC commissioners without studying the document and verifying the docket number.

SolInvictus

Re: Help Stop APS from taxing solar

Here is a summary from ASU: APS’s Proposal to Change Net-Metering, Arizona State University, Energy Policy Innovation Council, Published October 2013

Solar rooftop owners participating in APS’s net-metering program receive credits on their next utility bill for excess electricity exported onto the grid at retail rates (typically, $0.13-$0.16/kWh after taxes). At the end of the year, APS compensates the rooftop solar owner for any remaining excess energy credits at the “avoided cost” rate, which usually only occurs with relatively large solar systems.

Since APS pays for the surplus PV electricity annually and collect revenue monthly, they are receiving an interest free loan for 11 months of the year. That is not fair.

Under the Net-metering Option, APS would retain the current net-metering rate structure, but would add a monthly demand charge of $50-$100 to the average net-metered customers’ bills. This “ECT-2 rate” is a demand-based rate that about 100,000 APS (about 10 percent) customers currently use. Customers in this rate are charged less per kWh for energy use but are assessed an additional charge based on their peak load usage, or peak demand.

Under the Bill Credit Option, APS would place residential customers with grid-tied solar rooftop installations on a regular rate plan and give them a credit toward their bill for power produced by their solar energy devices at an avoided cost rate based on the forward market at Palo Verde Nuclear Generating Station. This proposal effectively turns residential net-metered customers into wholesale producers of solar power that must sell all of their power to APS at about $0.04/kWh, around a 70 percent decrease from the current net-metering compensation.

solar_dave

Re: Help Stop APS from taxing solar

here are all the documents:
http://edocket.azcc.gov/Default.aspx?SEARCH=E-01345A-13-0248
And for the other APS item on the agenda:
http://edocket.azcc.gov/Default.aspx?SEARCH=E-01345A-13-0140

solar_dave

Re: Help Stop APS from taxing solar

here is one that is pretty complete:
http://images.edocket.azcc.gov/docketpdf/0000148646.pdf

SolInvictus

Re: Help Stop APS from taxing solar

I think I found it, docket number E-01345A-13-0248, docketed July 12, 2013

APS - Net Metering Cost Shift Solution - Testimony and Briefs, Arizona's Residential Utility Consumers Office (RUCO)

NorthGuy

Re: Help Stop APS from taxing solar

solar_dave wrote: »

here is one that is pretty complete:
http://images.edocket.azcc.gov/docketpdf/0000148646.pdf

I haven't read all the document, but it appears reasonable to me. They have their wires and they have a right to establish rules of the use and charge anyone who uses their wires. I don't see any reason why they should be abligated to buy power from their customers.

What puzzles me is that they solicit the government to grant them the rights, which in my mind, they already have. I understand that they're monopoly and the government may regulate how they sell electricity to people. But there's no reason for the government to dictate them how to buy thier electricity.

Ian S

Re: Help Stop APS from taxing solar

This is interesting. I just got a letter from APS today stating that they had changed their "grandfathering" proposal to permit transfer to a new owner for 20 years. Previously, grandfathering was lost upon the sale of the home. Heh-heh they must be sweating and are hoping to peel off existing solar homeowners from the opposition to their plans.

BB.

Re: Help Stop APS from taxing solar

The "social benefits" of Solar RE power (from distributed grid tied systems) is something that politicians, regulators, and utilities (screaming and kicking) have decided is worth ~$0.15-$-.30+ per kWH (with the whole "net metering/subsidizes for wind turbines/etc.) type of thing.

And the rest of the market power has a cost to the utility of -$0.02 to +$0.065 per kWH or so (all highly variable based on a whole bunch of issues)... But that is a heck of a lot less than the "social value" of RE power.

The network engineer can schedule/buy/dispatch power based on the needs of the network... The solar power comes in when the customer (and the sun) want to generate it. The "value" of RE power (excluding dams, co-generation, solar power with thermal storage for "off sun" generation, and other "dispatchable" large power generators) is very low to the person/group managing the utility. In California, large Hydro/Dams are not considered "Green Power".

So, in my case, the utility has to "buy" power from me at near $0.30 per kWH (I am on TOU/Seasonal billing, my "net metered" cost for week day summer afternoons) and sell it to my neighbor at ~$0.14 per kWH (flat rate billing which almost everyone around here has--GT Systems where "forced" by the state PUC to go on TOU billing--probably to soften up the rest of the user base to be pushed to TOU billing sometime in the dim future--was original plan for smart metering--power prices set with 23 hour notice was the original smart metering plan... my guess).

I do understand the reasoning for 20 year grandfathering of GT installations... Lots of people (and solar leasing companies) have made economic commitments/investments based on those rules. But to expect those exact same rules to continue for an every growing installed base is going to cause problems.

The utility "signed up" to be a regulated monopoly--So they sort of have to play the game. But, at times, people are going to play rough. It is a PR battle more than a technical/conservation based set of arguments.

-Bill

SolInvictus

Re: Help Stop APS from taxing solar

Here is another version of an email to the ACC commissioners critiquing APS's application. Now it is too long which means they will not read it.

Please deny Arizona Public Service Company's Net Metering Cost Shift Solution, docket number E-01345A-13-0248 submitted on July 12, 2013, scheduled to be considered in the Regular Agenda during the open meeting on November 13 and 14, 2013.

Alteration of net metering should not be considered during this early stage of building out renewable energy systems. Adoption of APS's proposals would work against the incentive programs currently in place for renewable energy and thus be contrary to public policy. Arizona offers property and sales tax exemptions and an income tax credit. The federal government offers a tax credit available to rooftop solar installations. Any consideration for altering NM should be postponed until APS acquires 15% of its energy for retail loads from renewable sources as per Arizona’s Renewable Energy Standard Tariff (REST). APS's application is premature.

Continuing to apply net metering unaltered to commercial and industrial customers (page 2, line 15) while arguing that NM for residential customers must be altered to pay for costs of the grid, is unfair. The result of APS's proposals would be to discourage residential distributed energy systems in favor of commercial, industrial and utility scale systems. It suggests APS's intention is to suppress residential renewable energy systems.

Direct cash incentives paid by utility companies should continue to be phased out as per REST compensating for the declining cost of photovoltaic panels. No alteration should be made because it is working as intended.

Figure 1 on page 5 labeled Typical Customer Usage shows an approximately 2 kW power consumption in the wee hours of the morning. My electric power consumption at such times of the night when I am asleep is about 20 W, one thousand times less than APS asserts is typical. I have a hard time believing that clocks, phantom loads, lights and refrigerators typically consume 2 kW at night. Perhaps APS's "Typical Customer Usage" includes more than homeowners, such as street lights, businesses and industry. Integrating the curve shows their typical customer is consuming about 73 kWh/day which is far in excess of the typical residential usage of about 30 kWh/day. I also wonder if this "Typical Customer Usage" is typical of homeowners with grid-tied photovoltaic systems who are more inclined to conserve power. Things can be done to reduce nighttime loads on the grid, such as using battery powered clocks, the switch on a power strip to turn off phantom loads, LED lighting and timers to force refrigerators to operate only during daylight. Perhaps APS should advocate educational programs to reduce wasted power instead of increasing rates to people who use less of their product.

On page 4, line 19, APS asserts a cost-shifting issue:

"And because Net Metering allows customers installing rooftop
solar to avoid paying for infrastructure they rely on and
services they use, these installations come at a cost to APS’s
remaining non-solar customers."

If cost-shifting is even occurring, the magnitude contributed by residential distributed energy systems is presently insignificant, limited to 5% as per REST. Again, APS's application is premature.

According to APS's figure 2 on page 6 the vast majority, 94%, of the residential photovoltaic electricity is consumed at the residence where it is generated placing no cost upon APS. From the chart, I estimate 6% is export energy. APS sells that export energy to a neighbor at full retail price incurring no cost to generate the electricity. The distribution cost is nothing more than one residential transformer, some aluminum cable and a power pole or two meaning APS profited well from that sale. In figure 4 on page 8, the typical system shown does not generate an annual surplus of electricity because the system is not sufficiently sized and because clouds reduce generation (the chart is for sunny day power generation). The customer with the grid-tied PV system would pay APS for the power he used from the grid at the full retail price (the green area labeled "APS provides power") and thus already pays for his use of the utility grid. In actuality residential distributed energy reduces the amount of electricity APS sells to customers, and APS is trying to spin this fact by falsely claiming cost-shifting.

APS's claim on page 9, line 24 that the cost-shifting amounts to $1,000 per year per rooftop solar system is contradicted by their own data. For 94% of the generated PV power the inverter is only using the grid to synchronize its output waveform. The inverter is not drawing the power that it outputs from the grid. On page 6, line 14, APS claims, "It permits them to avoid paying almost their entire electric bill." This is clearly false for the typical customer shown in Figure 2 because he is consuming considerably more power than he is generating. Figure 5 on page 8 shows the average residential rate at $.14 / kWh. If an average residential customer consumes 30 kWh/day, then his annual bill is $1,534. APS is arguing that 65% of the bill is cost-shifted when they provide only a small fraction of the net power to a house with a grid-tied PV system. On average, a residential grid-tied solar system reduces APS's revenue because the customer uses less of their electricity.

If APS really wanted to be fair, they would argue for a metering system that detects where the energy is generated and where it is used.

A. Electricity generated by the homeowner's PV system and used by the
homeowner would not be billed.
B. Electricity generated by the homeowner's PV system and sent to the grid
would be purchased by APS at some fixed rate ($.06 / kWh)
C. Electricity generated by APS and used by the homeowner would be billed at
the full retail rate.

Instead APS is trying to force people to pay them for the power they generate and consume in their own home.

The Net-Metering Option forces customers with residential solar systems to use the ECT-2 rate which incurs a monthly service fee between $50 and $100 or about $1,000 / year. This would be a massive rate hike to homeowners who reduce their use of APS's product by going solar which is not fair. People who use APS's product should pay for it while those who do not, should not.

The Bill Credit Option proposes to pay customers with rooftop solar at the market rate for electricity from Palo Verde Nuclear Power Plant, which would probably range between 3 and 4 cents per kWh. Solar power does not have the same costs as nuclear power. Nuclear Power is heavily subsidized by the federal government conducting research and development, the Price-Anderson Act which limits the liability in the event of a nuclear accident and the federal government having the burden of disposal of radioactive waste. The cost of a solar system includes all of its costs unlike nuclear. What will become of this market rate when Palo Verde NPP eventually shuts down? The value of solar power should be determined by its own unique characteristics. 3 or 4 cents / kWh is far below the cost and value of solar generated electricity. APS wants to charge the full retail rate for all the power the residence consumes even when it consumes the power from its own solar system.

Approving either option would discourage if not outright halt the installation of residential solar systems and allow APS to capture solar incentives for its own profit from the few who would install them. These are not the intentions of current public policy for renewable energy systems.

At Page 14, line 3, making the grandfathering clause not transferable to a new customer at the same premise would devalue residential solar systems placing an additional financial burden on the customer.

solar_dave

Re: Help Stop APS from taxing solar

Ian S wrote: »

This is interesting. I just got a letter from APS today stating that they had changed their "grandfathering" proposal to permit transfer to a new owner for 20 years. Previously, grandfathering was lost upon the sale of the home. Heh-heh they must be sweating and are hoping to peel off existing solar homeowners from the opposition to their plans.

Yep I got one of those letters too. I assume this go round they are not going to get what they ask for but I am willing to bet the next rate case from them will be a nasty read. I suspect my 9AM to 9PM TOU is on the chopping block since it is already frozen from new sign ups.

solarix

Re: Help Stop APS from taxing solar

Since when was "fairness" the deciding point? Net metering is of course an unfair inducement to help encourage the use of solar energy and has been a big factor in building a substantial solar industry. It is a good thing to help society transition to a better energy source that is clean and inexhaustible. Currently, utilities receive the unfair, monopolized benefit of not having to pay the environmental and health costs of burning coal (clearly a controversial topic) which according to a Harvard Medical school study is on the order of $1000/person/year. Society makes decisions as to how to best provide its needed resources like electric power. In the past, we incentivized burning dirty, unrenewable fuels and now we are transitioning to promoting clean, renewable sources. It is not about fairness.

MikeSus

Re: Help Stop APS from taxing solar

SolInvictus wrote: »

Here is a summary from ASU: APS’s Proposal to Change Net-Metering, Arizona State University, Energy Policy Innovation Council, Published October 2013


Since APS pays for the surplus PV electricity annually and collect revenue monthly, they are receiving an interest free loan for 11 months of the year. That is not fair.

The 13-15 is totally inaccurate. Its kWh to kWh credit and settled up at wholesale rates so in essence its an interest free loan til the end of the year.

MikeSus

Re: Help Stop APS from taxing solar

solarix wrote: »

Since when was "fairness" the deciding point? Net metering is of course an unfair inducement to help encourage the use of solar energy and has been a big factor in building a substantial solar industry. It is a good thing to help society transition to a better energy source that is clean and inexhaustible. Currently, utilities receive the unfair, monopolized benefit of not having to pay the environmental and health costs of burning coal (clearly a controversial topic) which according to a Harvard Medical school study is on the order of $1000/person/year. Society makes decisions as to how to best provide its needed resources like electric power. In the past, we incentivized burning dirty, unrenewable fuels and now we are transitioning to promoting clean, renewable sources. It is not about fairness.

Fairness keeps getting tossed about because APS has made a point in all their "hit pieces" and ads to emphasize that rooftop solar owners aren't paying their fair share. (hence the ice cream topping thief commercial)

MikeSus

Re: Help Stop APS from taxing solar

solar_dave wrote: »

Yep I got one of those letters too. I assume this go round they are not going to get what they ask for but I am willing to bet the next rate case from them will be a nasty read. I suspect my 9AM to 9PM TOU is on the chopping block since it is already frozen from new sign ups.

Really I think that 9-9 is hurting you more than helping. You need some off peak generation. I almost wonder if they will find a way to force solar to use a plan like yours as they are almost guaranteed off peak usage.

MikeSus

Re: Help Stop APS from taxing solar

BB. wrote: »

So, in my case, the utility has to "buy" power from me at near $0.30 per kWH (I am on TOU/Seasonal billing, my "net metered" cost for week day summer afternoons) and sell it to my neighbor at ~$0.14 per kWH

And APS is relying on folks that don't have a dog in this hunt to THINK its happening that way here. In fact, its not. IF you chose a credit on your bill monthly, its at or below wholesale ($0.02-$0.03) If you chose EPR6, you get a "credit" for each kWh peak, and off peak and at the end of the year you will get a cash credit of $0.02-$0.03 per kWh. They are playing a shell game by saying that solar is using the grid as a battery while not accounting for the free loan of kWh. Currently, if you generate more than you consume, you can offset all the fees. That seems reasonable as they are getting kWh that they have already sold, and do not have to pay for until they are either needed or settled up.