IV. Measurement Issues
D.05-05-011 stated that DG participation in the RPS program is hindered by the problem of measuring the electric production from DG facilities.28 In the July 12 ALJ Ruling, we sought comments on the following questions:
· How can the Commission measure DG output for purposes of RPS?
· Can meters be installed and if so, what type, and for what size systems?
· If meters are not reasonable for certain smaller systems, what method can be used to measure DG output for these systems?
· How can the Commission ensure that electrical generation consumed on the customer side of the meter is added to the utility's total retail sales?
The above issues would apply only if the output from renewable DG were to be used by the utilities to meet their RPS obligations. Given the approach adopted here to allow system owners to retain 100% of their RECs, utilities will not be counting the output of renewable DG in their RPS calculations at this time. Therefore, the above measurement issues are unnecessary to address at this time. If and when the Commission authorizes unbundled RECs to be applied toward the RPS, it may be necessary to revisit the metering requirements to ensure the number of RECs sold is an accurate reflection of renewable DG system output, consistent with the measurement requirements adopted for grid connected renewable facilities and the WREGIS tracking system.
28 See D.05-05-011, p. 6.
