1. Rick Umoff, SEIA Sean Garren, Vote Solar
SEIA & Vote Solar – The DER Rider Value of DER & Interim Methodology NY PSC Case15-E-0751
Rick Umoff, SEIA
Sean Garren, Vote Solar
votesolar.org

2. The Solar Parties
The Solar Energy Industries Association (SEIA) is the national trade association representing installers, project developers, manufacturers, contractors, financiers and non-profits in the solar industry. SEIA works with its 1,000 member companies to champion the use of clean, affordable solar in America by expanding markets, removing market barriers, strengthening the industry and educating the public on the benefits of solar energy.
Vote Solar is a non-profit grassroots organization working to foster economic opportunity, promote energy independence and address climate change by making solar a mainstream energy resource across the United States. Over the past eight years, Vote Solar has been an active participant in many of New York’s solar policy and program decisions that have helped establish the state as a leading solar market.
September 18, 2018

3. Protect Customers’ Rights
Principles
Protect Customers’ Rights
Get the Value of Distributed Energy Resources Right
Keep it Simple, Gradual and Predictable
Protect Existing Customers
Be Transparent and Thorough
September 18, 2018

4. An Ongoing Transition
In order to balance the desire to move quickly with the need for the market to continue to grow, it is important that any changes to policy be made through a predictable and measured transition.
The interim distributed energy resources (DER) compensation mechanism should be developed in a manner that will establish a foundation for further reforms that can lead to increased granularity and the development of more & more accurate price signals.
The ultimate goal should be to develop a robust and diverse DER market as envisioned under Reforming the Energy Vision (REV).
Our proposal does this by setting a simple structure for valuation and compensation of DER and envisioning a transition over time for new customers to more granular and dynamic time based rates.
September 18, 2018

5. Structure
Customer’s energy usage from the grid is netted against excess energy exports to the grid, as in today’s net metering
Customer is charged for net monthly energy usage at retail rate or receives a credit for net monthly excess energy exported to the grid at the DER Rider rate
In months where there is a net excess, customer is credited at DER Rider rate & left over monetary credits roll over on customer’s bill to the next month
Electricity generated and used on-site is valued at retail rate
Over time, the netting period can transition from monthly to time-of-use, hourly and instantaneous as the customer education and rate design evolves
September 18, 2018

6. DER Rider Rate
DER Rider rate should reflect all categories of benefits provided by DER to the grid
Two components:
Levelized Fixed Value (life of project)
Variable Value
This is based on a projected generation profile for the DER and the existing market for these values
Additional value streams
Based on unique project attributes
Can be applied on a project or aggregated basis
September 18, 2018

7. Categories of Benefits
Variable Value
Levelized Fixed Value
Locational Marginal Price ▲
Wholesale Capacity Benefits
Market Based Ancillary Services
Demand Reduction Induced Price Effects (DRIPE)
Reduced Transmission Capacity Needs
Reduced Distribution Capacity Needs
Equipment Life Extension
Avoided Line Losses
Fuel Price Hedge
Reliability & Resiliency
Economic Development
Carbon Emissions
Criteria Air Pollutants
Water
Land
Conservation Voltage Reduction
Voltage and Power Quality
Siting in High-Value Locations
Peak-Demand Reduction (e.g. West-Facing Systems, Storage)
September 18, 2018

8. DER Rider Applicability
Solar Market Segment
Permanent Choice of Retail Rate NEM
Option to Choose DER Rider
DER Rider
Existing Systems
Mass Market: On-site Systems ≤ 250kW X
On-site Systems > 250kw
Community Distributed Generation (CDG) Systems
Remote Net Metered Systems
New Systems
Community DG Systems
RNM Systems
September 18, 2018

9. Community Distributed Generation
The Solar Parties support Staff’s recommended approach to CDG
New community distributed generation systems should be placed on the DER Rider rate to encourage deployment in high value locations
Further, CDG customers in the same service classification as mass market customers should receive equitable compensation for their generation.
The Commission should review the DER Rider once developed and, if necessary, adjust the compensation level for CDG customers to be the same as retail rate net metering for mass market on-site customers
This is especially important for low and moderate income customers who are likely to participate in CDG programs as a means of accessing the DER market
September 18, 2018

10. Grandfathering Critical to:
Avoid changing existing project economics drastically
Chilling the market due to regulatory uncertainty and increased risk
Undermine existing contracts
Grandfathering policy should be set as part of this proceeding or as quickly as possible
Our proposal would preserve existing rate classes and tariff structures of DER customers as regulatory reforms are implemented
September 18, 2018

11. Existing vs. New Customer
All existing systems should be grandfathered at retail rate net metering on their current tariff
The Solar Parties propose that “existing systems” be defined as solar projects that are currently interconnected or have paid for their CESIR up to six months after the Commission issues its order establishing the valuation of the DER Rider
All new systems for which the DER Rider is applicable should be placed on the DER Rider rate.
All solar customers, existing and new, should have the option to move to the DER Rider at any time.
September 18, 2018

12. Opting for DER Rider Existing Customers: New Mass Market Customers:
Grandfathered on retail rate net metering with the option to move to DER Rider permanently
New Mass Market Customers:
Option to move between retail rate net metering and DER Rider up to once per year in order to protect customers from unexpected economic impacts
New Customers In All Other Market Segments:
Can choose to use shadow billing for one year during which time they may revoke election
After one year of shadow billing election becomes permanent
September 18, 2018

13. Process – Phase One Initial Comments Technical Conference
Reply Comments
Staff Draft Framework: Staff issues draft proposal for interim framework based on comments
Proposal Includes:
Components of DER Rider rate
Identification of fixed vs. variable components
Statement regarding how often components will be set
Comment Period: Opportunity for parties to comment on Staff draft framework
Commission Approval of Staff Framework: Commission rules on Staff proposed framework of DER Rider, including components of DER Rider rate
September 18, 2018

14. Process – Phase Two
Staff Proposal of DER Rider Valuation: Proposal from Staff recommending valuations of each component within DER Rider rate
Discovery Phase: Opportunity for parties to engage in discovery in preparation for comment on Staff proposed DER Rider valuation
Comment Period on Staff Proposal: Comment period in which parties offer critique and propose modifications of Staff’s proposed DER Rider valuations
Commission Approval of Staff’s Proposed DER Rider: Staff submits proposed DER Rider to Commission for approval
September 18, 2018

15. Q & A
Future questions can be addressed to: Rick Umoff Regulatory Counsel and Director, State Affairs Solar Energy Industries Association (SEIA) Sean Garren Northeast Regional Manager Vote Solar
September 18, 2018