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Rebuttals to the 'Cost Shift' Argument...

nwdiver

Well-Known Member
Feb 17, 2013
8,113
10,575
United States
I'm fighting a very anti-DG rate case in NM. The local thugs are attempting to increase the fee for solar PV to $0.041/kWh produced. So if I were to charge my car perfectly... taking ~40kWh from the roof and directly into my car... NEVER using the grid... I would owe $1.64 for using MY solar. MY wires. MY panel. I totally agree that if I exported 40kWh and charged at night I should pay for using the grid.

A few rebuttals I've thought of...
- No credit for self-consumption or storage
If the premise is that DG owners are shifting the cost of their peak demand to non-DG owner then wouldn't it also be true that DG owners with higher grid demand are shifting cost more than DG and non-DG owners with lower grid demand? Someone with a 15kW on demand heater is shifting A LOT more cost... where's the fee for that? The calc assumes 53% availability of the DG asset. What if there's storage?​

- No credit given for the higher value of energy during day vs night
By their own TOU rider. Summer energy from 12-6 is ~4x more valuable than 'off-peak'. Solar is almost ALWAYS generating during those hours especially during the summer.
- Flawed calculations in determining the actual rate
In the testimony of their load forecaster Jannell Marks never once does she do a load calc for a DG customer. The rates for each class are determined by the peak load for that class. The peak load for a DG home is FAR more favorable to the grid than the peak for a non-DG home. Their using the load calc for non-DG customers to determine the rate offset for DG customers.​

Seriously looking for good ideas... I really want to kill this Rate this time around. It has utterly destroyed the economic viability of solar on one of the sunniest parts of the country :mad:
 

Attachments

  • Rate 59 & 67 Testimony.pdf
    2.3 MB · Views: 4
  • Jannell Marks (Load Forecast).PDF
    8 MB · Views: 3
  • 4th Rate 59.pdf
    356.3 KB · Views: 3

SageBrush

REJECT Fascism
May 7, 2015
12,393
15,333
New Mexico
Do you pay a fixed monthly charge ?
I would try and find its justification and hope to find evidence of double billing if this nega-kWh charge is passed.

My guess is that utility billing in your area fundamentally covers expenses and makes a profit from kWh consumption billing. They can yap about load but that is an excuse. Their problem is reduced consumption. But low consumption occurs with a variety of customers, not just PV owners. Unless they apply nega-kWh charges to every customer below a threshold, they are discriminating.
 

nwdiver

Well-Known Member
Feb 17, 2013
8,113
10,575
United States
Do you pay a fixed monthly charge ?
I would try and find its justification and hope to find evidence of double billing if this nega-kWh charge is passed.

My guess is that utility billing in your area fundamentally covers expenses and makes a profit from kWh consumption billing. They can yap about load but that is an excuse. Their problem is reduced consumption. But low consumption occurs with a variety of customers, not just PV owners. Unless they apply nega-kWh charges to every customer below a threshold, they are discriminating.

The majority of 'fixed costs' are embedded in the volumetric charge for residential customers. The fixed cost for each rate class is determined by their typical load profile. This is why a general service customer has a different volumetric rate than a residential customer. The standby rider tariff is intended to makeup for the lack of volumetric sales due to DG. The problem is that a DG customers typical load profile is no where near the same as a non-DG customer.
 

bak_phy

Member
Jun 15, 2016
451
271
New Jersey
It seems to me that the solution is to have everybody pay a fixed monthly fee if they want to be connected to the grid.
Although it may seem unfair to have to pay a potentially size-able fee when you might barely use the grid at all somebody has to pay for the wires that go to your house.
 
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nwdiver

Well-Known Member
Feb 17, 2013
8,113
10,575
United States
It seems to me that the solution is to have everybody pay a fixed monthly fee if they want to be connected to the grid.
Although it may seem unfair to have to pay a potentially size-able fee when you might barely use the grid at all somebody has to pay for the wires that go to your house.

It's not just 'unfair' it's detrimental. There needs to be a cost signal to customers to use the grid in a way that doesn't increase the need for transmission and generation upgrades.
 
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SageBrush

REJECT Fascism
May 7, 2015
12,393
15,333
New Mexico
It seems to me that the solution is to have everybody pay a fixed monthly fee if they want to be connected to the grid.
Although it may seem unfair to have to pay a potentially size-able fee when you might barely use the grid at all somebody has to pay for the wires that go to your house.
Yep -- that is the way my local co-op operates. I pay a $35 a month connection fee like everybody else, and the co-op does not care how much grid electricity I use or that I have PV. I end up paying $35 for ~ 150 kWh a month of grid supplied juice although my net use is less than zero.

NWDiver cannot tell the utility to change its archaic rate structure -- they will have to figure out for themselves that consumption and grid infrastructure should be billed out separately. In the meantime the best we can hope for is the utility is prevented from discriminating PV owners. That is my take on it anyway.

Good Luck, NWDiver! You are fighting for us all, and if you end up litigating against your PUC I'll support you with a contribution.
 

nwdiver

Well-Known Member
Feb 17, 2013
8,113
10,575
United States
Good Luck, NWDiver! You are fighting for us all, and if you end up litigating against your PUC I'll support you with a contribution.

THX. If you're not already a member I strongly encourage you to join Vote Solar. Not really sure what's more effective for donations. Vote Solar or Earth Justice. VS uses attorneys provided by Earth Justice. I donated $1k to Earth Justice last year.
 
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Electric700

Active Member
May 21, 2013
1,704
364
Florida, United States
Nwdiver, what was the previous rate?

If you are always generating greater than 100% of your energy usage needs monthly, I definitely think you should be eligible to be reimbursed for the additional energy generated over 100%. The calculation could be (kWh Used from Grid x Charge per kWh) + Flat Fee Grid Connection Charge - (kWh Produced by Solar or Wind Systems x Credit per kWh) = Monthly Credit or Amount Due.

So say you generate 1,200 kWh but only use 1,000 kWh that month, one possible calculation becomes: (0 kWh used from Grid x $0.08 per kWh) + $15 Grid Connection Fee - (200 kWh x $0.10 Credit per KWh) = $5 owed. So in this case, you need to pay $5.

Power companies have employees to pay and a complex infrastructure to maintain, so it's important to put everything into perspective. Remember too that you have solar panels and that in and of itself is a big step forward.

You can request they offer incentives to solar / wind power customers to encourage people to install more of those systems. One of the ways they can do this is with the rate. For instance, in the above calculation they could increase the generation credit to $0.10 per kWh, which would yield a check to you of $5 from the power company.

Your other ideas look good too. Just be professional in your request. There are likely others in a similar situation affected by the change in your state.
 

nwdiver

Well-Known Member
Feb 17, 2013
8,113
10,575
United States
Nwdiver, what was the previous rate?

If you are always generating greater than 100% of your energy usage needs monthly, I definitely think you should be eligible to be reimbursed for the additional energy generated over 100%. The calculation could be (kWh Used from Grid x Charge per kWh) + Flat Fee Grid Connection Charge - (kWh Produced by Solar or Wind Systems x Credit per kWh) = Monthly Credit or Amount Due.

So say you generate 1,200 kWh but only use 1,000 kWh that month, one possible calculation becomes: (0 kWh used from Grid x $0.08 per kWh) + $15 Grid Connection Fee - (200 kWh x $0.10 Credit per KWh) = $5 owed. So in this case, you need to pay $5.

The current rate is $0.036/kWh

Under the example you provided. Generating 1200kWh and consuming 1000kWh I would have a bill of ~$45 under the proposed rate increase.

Here's a snapshot of a bill from a current Rate 59 victim. They actually generated MORE than they used but STILL had a ~$36 bill. It's a negligible amount... but what I think is REALLY perverse about this is that they're essentially paying sales tax for electricity they generated!! Can you imagine paying a tax on food you grow in your garden?!

Screen Shot 2017-11-01 at 1.12.10 PM.png


IMO by far the biggest issue with this rate structure is that I would owe $45 whether I export/import 1000 or export/import 0. It's purely consumption based with no credit to self-consumption and storage. Shifting the fee to imports from usage would make it significantly better.
 
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