Discussion

The table below summarizes the changes to the metering requirements sought by the petitioners:

Table 2

Modified CSI Metering and Monitoring Rules⁵

Incentive Type	System Size	Minimum Meter Accuracy	Performance Communication and Reporting Requirement	Cost Cap
EPBB	< 10 kW	+/- 5%	Yes	1%
EPBB	10 kW to 30 kW	+/- 5%	Yes	1%
EPBB	30 kW and greater	+/- 5%	Yes	.5%
PBI	< 10 kW	+/- 2%	Yes	No Cost Cap
PBI	10 kW to 30 kW	+/- 2%	Yes	No Cost Cap
PBI	30 kW and greater	+/- 2%	Yes	No Cost Cap

We will grant Petitioners request and modify D.06-08-028, along with the appropriate sections of the CSI Program Handbook, to allow all installations participating in the EPBB incentive program to install meters that are accurate to within +/- 5% of actual system output. We note that the cost cap exemptions adopted in D.06-08-028 still apply to these systems,⁶ and that the cost of meeting the metering, communications and reporting requirements shall be less than 1% of total system costs of system up to 30 kW and less than .5% of total systems costs for larger systems. However, our expectation is that under the less stringent metering requirement adopted herein for systems receiving EPBB incentives, most systems will be able to meet the metering, communication and reporting requirements without exceeding their respective cost caps. We will also grant Petitioner's request that all systems taking incentives under the PBI be required to install meters that are accurate to within +/- 2% of actual system output. Finally, we will remove the cost cap on metering, reporting and communications for all PBI systems.

In adopting the original accuracy requirement in D.06-08-028, we found that a metering accuracy requirement of +/- 2% for systems greater than 10 KW in size "would not add a significant cost burden to CSI participants" and would increase owner knowledge of system performance and foster adequate system maintenance. Joint Petitioners have provided new information demonstrating that, at current pricing, the costs of meeting the metering, communications and reporting requirements for EPBB eligible systems of 10 kW⁷ or greater will, in most circumstances, equal or exceed the relevant cost cap.

Rather than wholly exempting these systems from metering, communications and reporting requirements, we believe it is reasonable to relax the metering accuracy requirement for all EPBB systems as requested by Petitioners. We anticipate that the lower cost burden associated with the less stringent metering requirement will allow systems to deploy the required metering, communications and reporting capabilities without exceeding their cost caps. In the context of the EPBB incentive program, because incentives are provided up-front as a lump-sum payment, and not on the basis of actual, metered output, we find the additional cost of meeting the +/- 2% metering standard cannot be reasonably justified. Furthermore, although the decision stated that the costs of metering, reporting, and communications should not exceed specified cost caps, we see little value in retaining metering requirements that, for almost all EPBB systems, seem likely to result in the cost caps being met or exceeded.

We, therefore, grant Petitioners request and require all systems taking incentives under the EPBB to have meters that are accurate to within +/- 5% of actual system output.⁸ We direct the metering subcommittee reporting to the Program Administrators, within six months of the date of this decision, to develop a plan to ensure the accuracy level of +/- 5% meters used to report output from systems receiving CSI incentives under the EPBB program. Independent certification of meter accuracy will advance our interests in obtaining reliable generation data with the lower-cost meters. We note that nothing in this decision changes the existing cost caps or communications and reporting requirements applicable to these systems.⁹

However, for systems participating in the CSI under the PBI, where incentive payments are made on the basis of actual kWhs generated, more accurate meters are needed both to ensure that ratepayer's provide incentives only for actual generated energy, and system owners receive an incentive that closely reflects their system's actual performance. We will, therefore, also grant Petitioner's request that all systems receiving PBI incentives have meters accurate to within +/-2% of actual system output, with no cost cap.

Much of the substance of the arguments made in the Petition to Modify and in Reply Comments revolved around incremental cost differences between different types of meters, levels of metering accuracy, and the cost of monitoring and reporting services. We believe that while the Joint Parties have demonstrated that certain metering requirements are cost prohibitive, there is still a great deal about this market that remains unclear. We therefore direct the CSI Program Administrators (PAs) to retain an independent third party to conduct a metering, monitoring and reporting market assessment. In coordination with the metering subcommittee and with direction from the Energy Division, the PA's will develop a research plan which will be conducted by this independent third party, and funded through CSI Program Administration funds. The results of this study will serve to inform future decision making with regards to metering accuracy, monitoring and reporting requirements, and system eligibility.

The changes proposed herein will apply to all open applications on the effective date of this decision. That is, any CSI application that has not received an incentive payment as of the effective date of this decision will be subject to the changes adopted in this decision.

In addition to their concerns regarding metering accuracy, Petioners also raised issues pertaining to the independence requirement for the provision of performance monitoring and reporting services (PMRS). This issue will be addressed by a separate decision.

⁵ Note that currently systems greater than 100 kW are required to participate in the CSI under the PBI, while systems less than 100 kW can participate under the EPBB. However any system may opt into the PBI.

⁶ In their reply comments, at p. 3, the Petitioners state that the CSI Handbook "allows EPBB customers with systems smaller than 20 kW to request exemption from the more expensive metering and PMRS costs" by "demonstrating [they] are unable to satisfy the +/- 2% metering requirements under the cap." This appears to suggest that systems 20 kW and larger are not able to seek an exemption from the metering requirements. It is unclear how this comports with what was adopted in D.06-08-028, which specifically established a cost cap for systems up to 30 kW of 1% and for systems larger than 30 kW a cost cap of .5%.

⁷ The current size threshold for requiring a meter accurate to within +/- 2% of actual system output, as provided in D.06-08-028.

⁸ The accuracy standard adopted in this decision is a minimum, not a maximum. System owners may elect to install more accurate meters at their discretion. For example, the +/- 5% metering standard may not be sufficient for purposes of certifying renewable energy certificates under the operating rules of the Western Renewable Energy Generation Information System (WREGIS). Prospective system owners may wish to install meters that satisfy the accuracy requirements of WREGIS to the extent they want the renewable energy produced by their systems to be recognized/certified by WREGIS.

⁹ For systems that exceed the cost cap, the Program Administrators shall use the CSI handbook process to develop alternative metering, communication, and reporting standards that will fulfill the basic objectives of the requirement while staying within the cost cap.