Petition to Modify Metering and Monitoring Requirements
On March 5, 2007, the Joint Solar Parties,2 filed a petition for modification of D.06-08-028 seeking the following three changes to the decision:
1. Reduce meter accuracy requirements for EPBB customers to +/- 5% regardless of size;
2. Require all PBI systems to have meters accurate to within 2% of actual system output, and eliminate the metering and monitoring cost cap for customers participating in the PBI program; and
3. Eliminate the independent monitoring requirement but institute random sampling.
In today's decision, we will address the first two requests, and the third item will be resolved by later decision. Also, we note that on April 2, 2007, PV Powered filed a document styled as a petition for modification which was a reiteration of the Joint Parties' petition. We summarily deny PV Powered's petition as duplicative and focus our attention on the Joint Parties' petition.
The Joint Parties contend that these requirements result in unwarranted costs for owners who have received an incentive payment pursuant to the EPBB. In contrast to incentives received under the PBI, actual system generation is not used in calculating incentive payments under the EPBB. Accordingly, the +/- 2% metering accuracy requirement for systems over 10 kW, and the higher associated costs of these more accurate meters, is an unnecessary expense for all system owners participating in the EPBB program.
The Joint Parties state that actual meters range in cost between $1,800 and $2,700. Additional data and communication services raise prices to above $3,000. This pricing information was obtained from "discussions with metering experts," according to the petition and includes installation costs, taxes, ongoing maintenance, testing and calibration, as well as the cost of the customer-supplied socket. According to the Joint Parties, these costs were not included in the cost data the Commission relied upon in setting the metering requirements.3 The Joint Parties state that incremental gain in accuracy from +/- 5% to +/- 2% is too costly, and will not provide substantial benefits or measurable value to consumers. They contend that the requirement places negative cost impacts on purchasers of solar energy systems.
Responses to the petition were filed by Fat Spaniel Technologies, Inc., jointly with Energy Recommerce Inc. (FST),4 Southern California Edison Company, the Consumer Federation of America, and PVI Solutions, Inc. On the two issues to be addressed in this decision, the responses all opposed granting the requested modifications.
The Consumer Federation of California responded that the petition's price information, which is not properly documented, does not constitute new information sufficient for the petition process, per Commission rules. Southern California Edison did not support lowering the metering requirements, but favored an analysis of the benefits of +/-2% meters because a range of data and communication benefits may be useful to the program development, and mentioned that costly retrofits might result if the higher accuracy rating is later deemed necessary. FST raised the issue of installations with the less accurate meters being ineligible for Renewable Energy Credits.
The Joint Parties replied that meter accuracy requirements must reflect meter accuracy needs, and the smaller EPBB installations cannot meet the accuracy requirements without exceeding the cost cap. The Joint Parties stated that the cost estimates on which the Commission relied in D.06-08-028 have proven to be much less than actual cost data being presented to solar installation owners.
2 Pacific Gas and Electric Company, PV Now, California Solar Industries Association, jointly with Vote Solar Initiative, San Diego Regional Energy Office (now known as the California Center for Sustainable Energy), and SMA America.
3 Joint Petition for Modification of Decision No. 06-08-028 Regarding CSI Metering Requirements, p. 2.
4 The response was also supported by: Bridgeover, Inc., Connected Energy Corp., Draker Solar Design, LLC, DRI Energy Inc., Heliotronics, Inc., Independent Energy Solutions, Inc., Old Country Roofing, Solar Wave Energy, Inc., Solectria Renewables LLC, and Southern California Solar dba Solar Electric Systems.
