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Off Peak Rates in Massachusetts?

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The DPU ruled that they will not regulate EVSEs as they are selling a "charging service", and not "selling electricity" per se. I believe they left an exception for consumer protection in the case of utility owned EVSEs, but I'd have to read it again to be sure.

If I understand it right, EVSE owners can now set per kWh fees instead of flat rates.

By all means, please chime in on the technical conference if you have a mind to. I believe they're leaning towards separate meters for home EVSE, but that's what the conference is supposed to sort out. In some states, TOU rules seem very complex, I'm advocating for as much simplicity as possible.
 
Yes, I think it's a very good thing that EVSE stations won't be subject to utility regulation. Utilities have whole departments filled with accountants and lawyers to manage state regulators, and EVSE shouldn't be burdened with the same admin overhead. Besides, as a matter of policy, the reason that utilities are so tightly regulated is because there's no meaningful competition: if you live in Boston and want power, you have to buy from NStar. EVSE networks can compete on quality, convenience, and price, so there's no reason to regulate them.

Note that the tech conferences are very focused on how retail rates should be set to support EV integration. I've spoken at many such tech conferences (on different topics, not EVSE rates); the best approach is to prepare a written statement. You then read the statement into the record, handing a hard copy to the clerk to ensure that they've got it accurately. Keep it short so that there is time for people to ask you questions.

Some topics that could be addressed:
  • Is the two-tiered (on- and off-peak) time-of-use (TOU) rate, such as offered by NStar, good enough?
  • In the alternative, should there be more tiers (e.g. super off-peak from 11pm to 6am)?
  • Currently the Standard Offer power product procured by the utilities has no TOU aspect. Should future contracts obtain a different price for on- and off-peak power?
  • Instead of a TOU rate, should a true Real Time Price be adopted, with the utility passing through real-time wholesale prices as determined by ISO New England? If so, how would this fit with the Standard Offer procurement?
  • Should a separate meter be required? If so, who bears the cost of the meter? And how does the utility guarantee that all charging, and only charging, is billed on that meter?
  • Should utilities be encouraged to develop interruptible rates for EVSEs that would allow the utility to temporarily halt charging at a customer location? Such a program existed for many years for electric hot-water heaters.

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My former colleague Ahmad Faruqui, now at the Brattle Group, has done some excellent work on retail rate design. Here's a good presentation that summarizes a lot of the issues facing regulators:

http://www.brattle.com/system/publi...Faruqui_EEI_Webinar_Aug_2_2013.pdf?1378772103
 
Some state's TOU rates not only vary several times per day, but also seasonally, sometimes also mixing in baseline thresholds. Then there's the issue of folks with solar arrays on net metering. The email that attachment came in included a link to a solar net metering info page, so I'm sure that will be on the agenda.
 
Some state's TOU rates not only vary several times per day, but also seasonally, sometimes also mixing in baseline thresholds. Then there's the issue of folks with solar arrays on net metering. The email that attachment came in included a link to a solar net metering info page, so I'm sure that will be on the agenda.
I'd love to see them require municipal electric companies to do net metering and offer EV/TOU rates. My muni pays me wholesale for excess solar (it works like reverse TOU w/ net metering).

I'm actually incented to use as much during the day as possible and not feed the grid. It's the exact opposite of what they want.
 
Some topics that could be addressed:
  • Is the two-tiered (on- and off-peak) time-of-use (TOU) rate, such as offered by NStar, good enough?
  • In the alternative, should there be more tiers (e.g. super off-peak from 11pm to 6am)?
  • Currently the Standard Offer power product procured by the utilities has no TOU aspect. Should future contracts obtain a different price for on- and off-peak power?
  • Instead of a TOU rate, should a true Real Time Price be adopted, with the utility passing through real-time wholesale prices as determined by ISO New England? If so, how would this fit with the Standard Offer procurement?
  • Should a separate meter be required? If so, who bears the cost of the meter? And how does the utility guarantee that all charging, and only charging, is billed on that meter?
  • Should utilities be encouraged to develop interruptible rates for EVSEs that would allow the utility to temporarily halt charging at a customer location? Such a program existed for many years for electric hot-water heaters.

This is a valuable place to show up, and encourage EV solutions. Our rates are going up about 2.5-3 cents/kwh, on the supply charge (generation):
Massachusetts electric rates shoot up 37 percent - Massachusetts news - Boston.com


  • Consistent with the above, I think it is fair to ask at the hearing if the spread between off-peak and peak rates will grow, as a result of the huge price spikes seen on the wholesale winter markets, during the daytime. I believe the supply charge will simply rise by the same 2.5-3 cents/kwh, as all the features of MA TOU plans are priced away from the supply charge (counter-intuitive, but true). That's not fair, and does not reflect, at all, evening weighted consumption.
  • I'm not for separate meters, as the anecdotes in California suggest high meter install costs, and crazy cheap kwh EV rates were sometimes followed by increased kwh rates (after EV owners did the math). The current regulatory structure, that protects cheap electric energy, is better off without separate meters. I think drivers would ultimately see another form of revenue targeting, like they already do with reg fees, excise taxes, etc.

With land based wind and hydro expected to play a much bigger role, in MA, day prices will be at even greater spreads to night. My belief is if this is a normal function of the market, DPU should preserve it in as many pricing mechanisms as they can. Arbitraging cheap nights with the day, is where its at for the sake of both economics and the environment, and you don't see that very often!!!
 
@3mp_kwh: I agree that the energy pricing is the biggest issue. NStar's TOU rates seem pretty reasonable, but they cover only the "wires" costs. The Standard Offer energy price is layered on top, and there's no TOU aspect to that. It would _not_ be hard to conduct SO auctions that had off- and on-peak pricing, particularly if they used the industry standard definition of on- and off-peak (onpeak: 6am-11pm nonholiday weekdays, here in the east.).

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FWIW, were I to make comments, I wouldn't touch net metering. Net metering is a PV issue, not an EV issue. While many EV owners also install PV, I don't think there's a tight enough linkage between the two topics.
 
I think they'd like to require home EVSE to be sub-metered to qualify for TOU rates, to encourage off peak charging.

The Concord muni is doing this already, charging $300 for their required meter, install at your expense, with off peak rate at $0.05/kWh. I'm not clear on the relationship between the DPU and the various munis in MA, vs NStar and NGrid.

I have no doubt they'll try to tie in a "fuel tax" someday. We don't call it Taxachusetts for nothing. I'd prefer a road tad based on mileage and vehicle weight, but leave the gas tax in to fund environmental clean up, as a disincentive to gas use.
 
Regret that I couldn't alter today's schedule to be there. Maybe the next one. Sent my comments in by email. Will post any results of the conference that they send me. The 11/6 conference will focus more on EV rates. The agenda for today's also included direct load control, EV to Home and future EV to Grid possibilities, and how to pay for all that.
 
I went to today's hearing.
RE: How to incentivize EVs through MA's rate structure.
Represented: Nat Grid, NSTAR/Northeast Utilities and Chargepoint (among others).
Topics:
-Peak and Off-peak pricing, as in standard binary TOU rates
-Peak and Off-peak pricing, as in new TVR, or Time Value Rates

They didn't really get into commercial, destination, or highway charging. This was mostly a residential discussion, on how to get to 300,000EVs. The utilities want "AMI", or smart metering, which will enable more detailed time interval pricing. This is good to capture each hour of peak and off-peak rates. They also want demand charges. I didn't feel like the only EV, or environmental, person in the room, but did speak when it came to what I sensed was happening. The short of it seems to be their argument that TOU rates don't really work as well as AMI, and that, as they argued, the demand charges that AMI would enable could be structured to rebate back money to EV owners. To get it, the idea would be to restrict, say a Tesla (not their example) to 5kw rather than 10kw during the day. No talk of V2G, here, just what an EV owner would be owed for being willing to reduce their load during the day. -this is effectively a demand charge in reverse, or demand response.

Sorry if this is confusing, but what I worry is going on is a revenue adder to the utilities. On the one hand, smart meters can be an installation profit center. Like a cable box, there was talk of "$15/mo for the modem cost". There was talk of separate EV meters (liked by the DPU, who wants to artificially push cheaper EV rates). There's the hardware cost. Then, there's the prospect of demand charges, which gets into a Pandora's box.

As described above, the idea of having your Tesla pull 5kw, instead of 10kw during the day, is on the table as creating a "credit" to your account. Where AMI can sound scary, to EV and solar users, is in its ability to capture your peak kw use. This isn't kwh, mind you. It's your instantaneous load spikes, whether pulling or sending watts. Residential power pricing very rarely includes a "demand charge". That day may have to end, as the legitimate argument from the utility perspective goes something like this: Picture a home with, say, 200amp service, an 80amp twin charged Tesla and a 25kw solar system, all pushing watts around at peak sun (I dunno, call it 2PM). We think in terms of kw HOURS and things netting out, but there's a wire load component that can require additional equipment. It's a hot topic in U.S., right now, and clearly a target point of utilities. Net metering doesn't capture instantaneous wire load. It has other shortfalls I won't get into, which disadvantage the solar owner. The ones that disadvantage the utility are the portal through which this type of metering could become more common. You'd have a normal, cumulative kwh bill, but then a charge added on depending upon how close you got to your maximal 200amp service. What makes these charges scary is that they are typically layered on top of all of the kwh's billed. Example, a 10 cent kwh could see a 1.5 cent demand charge, if during one simple minute in an entire month, you were drawing 25kw. At a 40kw minute, they might add 3 cents across the whole bill, etc.

I hope this makes sense. Corrections welcome.

I was the guy who pushed Nat Grid on its policy of restricting residential TOU to its >2,500kwh per month customers, more or less arguing that was an exclusionary threshold. The utility was trying to make the case that TOU was unsuccessfully subscribed. C'mon guys, maybe there aren't that many, but with how hard it has become to simply read a utility bill, should we be surprised if buying nighttime electricity isn't as popular as, say, $2 gas after 9PM would be???
 
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Wow! Thanks for the update 3mp_kwh.
Maybe I'm just jumping onto a moving train (or feel like I am), but not sure I fully understand the pros/cons of each of these pricing format: Time of Use (TOU), AMI, or any others. I've been a NGrid customer for many years and haven't been told of any other options. Also, seeing that the TOU option requires >2,500kwh per month, I doubt there are any homes that fit the bill there. I probably am in the top 10% of users, and even then I'm probably around 1,500kwh per month avg for the year (i.e. about 18mWh/yr).
Maybe someone can help explain what these changes would mean to the common person(s):
1. Someone who has no EV, no PV
2. Someone who has EV and PV (I fall in this category)

Thank you all for the great information here. I'm really sick of the crazy electric rates and the rate fluctuations.
 
Thanks for the report, 3mp_kwh. Sounds like it was the typical utility hearing, with the drumbeat of "how can we earn higher profits?"

One thing that struck me as bizarre is the idea of charging extra ​for AMI. They're asserting that it's more expensive to use electronic meter reading than having someone drive around to ever household?

The idea of lowering your charges if you're willing to let them automatically ramp down the charge rate is a good one, IMO. There should be some caveats around that:
  1. The user can manually override (in which case he loses the discount)
  2. The action is only taken during system reliability issues, specifically when ISO New England invokes Operating Procedure 4, Action 3 or higher (which is when ISO triggers real-time demand response and real-time profiled response resources)

I'm really sick of the crazy electric rates and the rate fluctuations.
Me, too, but almost all the fluctuations you see on your bill have nothing to do with the utility. Throughout New England (except VT), your electric bill has two distinct pieces: an energy charge, and a wires charge.

  • You have the ability to buy your power from whomever is licensed to sell it, at whatever price structure. There are many suppliers who will guarantee you a fixed rate for, say, 24 months, which would be a good choice if you like price certainty. If you don't shop for power, then by default you are buying at the "Standard Offer" or "Default Service" rate. Periodically the utility holds a competitive auction to secure the Standard Offer power, at a fixed price for the relevant period. Either way, the power price reflects expected future wholesale power prices, which in turn reflect the expected cost of natural gas (plus, on really cold days, fuel oil). Because of inadequate gas pipeline capacity into New England, winter gas prices routinely pop, which makes power prices pop. All that gets put on your bill.
    • The only way to address this problem in the short run is to build another gas pipeline or a major transmission link to Canada. Northeast Utilities has proposed doing that latter, but New Hampshire residents are pushing back, hard.
  • The other side of the bill is the distribution charges. The utility uses these charges to cover its costs of owning and maintaining the grid infrastructure (and earn a regulated rate of return thereon). So, increasing the "rate base," i.e. the capital invested into the grid such as meters and transformers, lets the utility earn more money. (The utility's cost of capital is lower than its allowed rate of return.) Nonetheless, the level of these distribution charges doesn't change much from one year to the next.
 
Thanks for the report 3mp_kwh. I hope the DPU comes up with a reasonable policy. A $15/mon modem fee would negate a lot of the savings from TOU rates for a small user like me. With the LEAF, at most I average 10 kWh/day. I wouldn't want them to mess with my PV net metering either. That was part of the incentive to put up an array in the first place.
 
Wow! Thanks for the update 3mp_kwh.
Maybe I'm just jumping onto a moving train (or feel like I am), but not sure I fully understand the pros/cons of each of these pricing format: Time of Use (TOU), AMI, or any others. I've been a NGrid customer for many years and haven't been told of any other options. Also, seeing that the TOU option requires >2,500kwh per month, I doubt there are any homes that fit the bill there. I probably am in the top 10% of users, and even then I'm probably around 1,500kwh per month avg for the year (i.e. about 18mWh/yr).
Maybe someone can help explain what these changes would mean to the common person(s):
1. Someone who has no EV, no PV
2. Someone who has EV and PV (I fall in this category)
h
Thank you all for the great information here. I'm really sick of the crazy electric rates and the rate fluctuations.

Essentially, that TOU amount means you're heating your house with electricity and then to take advantage of it you'd need to be making heavy use of storage heating.
 
Yes, you can call me Big Maple

I got a very good deal for my system. It was installed about 22 months ago. I went with Solar City (Power Purchase Agreement - which means they own the equipment, insure it, repair it, and guarantee a particular yearly output, or they refund some money). I paid it all up front, so I didn't have the inflation calculation applied to the cost of the power. Their math showed me paying around 5 cents per kwh from the panels for 20 years. I don't get the SRECs, but my total expense was less than $5,000. They way I calculate it (which takes into account the benefit of how TOU is calculated), I have saved paying NSTAR about $2300 at this point. So, payback will be in less than 4 years. The low capital cost, 20 years of insurance, repair, and guarantee, and removal from uncertainty about the future pricing of SRECs, made the PPA the way to go for us. Also, because I don't own the panels, I get no rebates, incentives, or tax breaks (other than the 10-year property tax abatement on the improvement)

Note - I checked on getting some panels put on the garage about 6 months ago, and the price with 2 to 3 times what it was for the house. The economics are different in that case, and they would also have a longer payback if I couldn't do TOU at the same time. I'm not surprised about the higher prices, to be honest. I know the state rebate amounts have gone down with each new rebate/incentive program, and since this would be my second install at the same address, there may even be other exclusions.

For my mostly west facing 4 pitch roof, with an Edge Solar inverter system (hybrid, sort of like microinverter in that it finds the power point for each panel, and if a panel is shaded, it doesn't take down the whole string), my first year (Nov '12 through Oct '13) I produced 5.4Mwh from a 4.8Kwh system. So far this year (Nov'13 through Aug'14) I have produced 5.1Mwh. I do have some evening shading on the panels, and the first year I had a maple tree to the south that had some shading that I removed to build the garage, so this year will probably have a higher total output.

Hope that is helpful.

Hi Big Maple,

Thanks much for the detailed explanation of your experience with Solar City.

I just signed up my MetroWest home with Community Solar - a Solar Farm operator opening farms to the public (western mass - ok for Worcester county is one). You can sign up for as much capacity as you'd like and either pay monthly - or take advantage of an 8% discounted cash flow for 25 years - which is pretty much the life of the farm (and me).

My net cost was $18K for 8KW, which is much less than the $24K net after tax credits for an install. They start construction in April and claim it will take about 2 months to come online - hopefully in time for peak season. To justify a purchase, I would have to count on ToU benefits (which are not available with NGG - only NSTAR) - and count on some SREC benefits. With SRECs currently at $278 in the PRM, that would work - but with the capacity coming online, including this and other farms - that has to go down by at least half. A couple of local companies claimed that I'd get 92% with and east/west house, but this seem to defy physics - so I'd rather have my panels in perfect position on a farm and not risk issues with my roof (which already lost integrity once during an ice storm).

Least attractive was Solar City - they emailed with a '37% increase' fear memo - by 7 different reps - and not one followed up in a timely manner or returned calls. Then I looked back in my emails and found the exact same memo about the 37% increase a year ago. I would never do business with them.

Has anyone had experience with a Solar Farm or heard of Community Solar - they claim to have done the town of Princeton and Smith College - Robert, do you have an opinion on Solar Farms like this?

Thanks,

Jack

PS: Solar city now asks 15.6 per kwh - so you got a fantastic deal. Community Solar is asking a similar rate, as are a couple of others - so 5 cents is amazing.
 
PS: Solar city now asks 15.6 per kwh - so you got a fantastic deal. Community Solar is asking a similar rate, as are a couple of others - so 5 cents is amazing.

Hi Jack,

I wonder if rising electricity costs gives room for the solar PV companies to offer less attractive deals. Also, I have heard a lot of similar complaints about solar city - they don't follow through and their prices are not as competitive as they were. Hopefully it is because they are so busy they can't keep up - not because there is a local management problem or anything.

I still have a considerable energy production deficit over what I use, especially now that my wife is driving electric too. I have been considering adding more production. I had never heard of the solar farm idea, but it sounds intriguing. Let us know how things work out.
 
Thanks for the responses and the lesson.
@Robert.Boston - I think there is another way to limit the "winter pop" in prices... Go solar! :biggrin:
Then again, until we get the clear break-through in battery tech for a cost-effective energy storage option at home, we'll still need the power companies providing "back-up" (night and winter usage, etc.). So, guess that means I still have to be on their good side.

@Big Maple1 and Jack - I've had a roughly 7kW system (about 30 panels) on my home for about 3 years now. Been going up in energy usage with the addition of a decent sized pool 2 years ago (running pool pump throughout the summery) and the Tesla about 1 year ago. So, now I need to look for more space for additional panels!
In terms of a cost rate, I'm averaging about $0.09/kwh for the next 30 year period. (This doesn't even consider the SREC credits which I sell into the market.) I've talked to Solar City, Sungevity and SunRun (who installed the first system). The big difference is how these companies are doing their pricing. I had them both do a pricing for another house (no solar yet) and here is what I got:

Solar City: Final cost includes them taking all of the SREC credits and giving you a lump sum reduction in final figure, then you deal with the 30% from federal taxes. The final figures: $31,625 for 11.5kW system, after 30% fed credit and they take the SREC credits. This should give roughly 13gWh/year. So over 20yrs approx. 240gWh (including slight degradation over time). Therefore, $31,625 / 240,000kWh = $0.132/kWh avg for 20 years.
(On side note, they did respond rather quickly for me.)

Sungevity: You also have to do your own 30% fed taxes credit, but you also keep your SREC credits. The final figures: $20,600 for 8.75kW system, after 30% fed credit, and I get to keep/sell my SREC. This should give roughly 10gWh/year. So over 20yrs approx. 180gWh (including slight degradation over time). Therefore, $20,600 / 180,000kWh = $0.114/kWh avg for 20 years. AND I STILL KEEP/SELL MY SREC! Assuming avg of 9 SREC credits for the next 10 years only @ $200/credit = $18,000 = most of my expense... so real cost is closer to: $2,600 / 180,000kWh = $0.014/kWh.

I'm holding off on this until next year... getting my current house upgraded first.

Another benefit that you can get from all of these companies is referrals. If anyone is looking to knock off $500 from their install costs from Sungevity, let me know. (I also get some referral bonus as well.)
 
Me, too, but almost all the fluctuations you see on your bill have nothing to do with the utility. Throughout New England (except VT), your electric bill has two distinct pieces: an energy charge, and a wires charge.

  • You have the ability to buy your power from whomever is licensed to sell it, at whatever price structure. There are many suppliers who will guarantee you a fixed rate for, say, 24 months, which would be a good choice if you like price certainty. If you don't shop for power, then by default you are buying at the "Standard Offer" or "Default Service" rate. Periodically the utility holds a competitive auction to secure the Standard Offer power, at a fixed price for the relevant period. Either way, the power price reflects expected future wholesale power prices, which in turn reflect the expected cost of natural gas (plus, on really cold days, fuel oil). Because of inadequate gas pipeline capacity into New England, winter gas prices routinely pop, which makes power prices pop. All that gets put on your bill.
    • The only way to address this problem in the short run is to build another gas pipeline or a major transmission link to Canada. Northeast Utilities has proposed doing that latter, but New Hampshire residents are pushing back, hard.
  • The other side of the bill is the distribution charges. The utility uses these charges to cover its costs of owning and maintaining the grid infrastructure (and earn a regulated rate of return thereon). So, increasing the "rate base," i.e. the capital invested into the grid such as meters and transformers, lets the utility earn more money. (The utility's cost of capital is lower than its allowed rate of return.) Nonetheless, the level of these distribution charges doesn't change much from one year to the next.

Hi, @Robert.Boston,

Do your words above apply as well to municipal utilities, e.g., Wellesley?

I have been under the impression that, living where I do, my only choice is to buy power from the town's plant.

Thanks,
Alan