Reply Comments Regarding the JU Recommendations on Rate Design and CBC
March 16, 2020
In comments, the JU proposed several recommendations that will directly undermine the State’s policy goal to significantly increase distributed solar in the next several years. JU recommended no grandfathering of bridge rate options, imposition of demand based delivery rates, and an escalating CBC that would result in massive monthly fixed charges for solar customers. These recommendations would completely eliminate any incentive for a residential or commercial customer to install rooftop solar in New York.
The JU proposal to not allow grandfathering will present significant uncertainty for future customers and developers in New York. While any rate option is subject to change over time, the JU have consistently made clear their intention to implement rate options (high fixed charges and demand charges) that eliminate any customer interest in rooftop solar. Also, as we’ve shown in previous comments, eliminating grandfathering and increasing fixed charges to unreasonable levels will decimate the solar industry in New York, making it impossible for the State to meet its solar installation and climate goals.
The CEP have commented on the JU proposals to move to demand based rates for solar customers several times throughout this proceeding. This proposal is not cost based, will reduce customer incentives to reduce overall consumption or engage in utility energy efficiency programs, and will drastically reduce the number of rooftop solar installations. The CEP believe that time based rates, including time of use rates with critical peak pricing or variable peak pricing, achieve greater demand reductions and provide customers with better price signals than demand based rates.
Finally, the JU proposal to increase the CBC will impose an extremely high fixed charge on solar customers. Table 1 shows the potential fixed charges for a residential solar customer with a 6 kW facility under the JU proposal. As the table shows, the JU proposal would more than double the current fixed charges. For a residential customer in Central Hudson with a 6 kW system, the monthly fixed charge would be nearly $70 per month.
The JU also offer no justification for the proposal. The CBC as originally designed is intended to recover additional costs of public benefit programs. The JU proposal goes far beyond any public benefit programs. This proposal, especially when combined with other JU recommendations, would strongly discourage any investment in rooftop solar in New York and should be rejected by the Commission.