| December 12, 1997 Dennis Keschl, Administrative Director Re: Rulemaking on Qualifying Facility Rates, Terms, and Conditions in Restructured Electric Industry (Chapter 360); Docket # 97-794 before the Maine Public Utilities Commission I wish to thank you for the opportunity to comment on the present rulemaking notice for Qualifying Facilities and the regulations affecting net energy billing. My wife and I own a Qualifying Facility in Cape Porpoise...known to others as our home. We have a photovoltaic array of 4 kilowatts on the roof tied into the grid through an inverter. My contract with Central Maine Power Company began in December of 1994 and extends through December 31, 1999. To date, we've essentially broken even each year in terms of our electricity bills...some months we've bought extra power, other months we've sold excess power. We constructed our solar home in a manner that would tread as lightly as possible on the environment - we generate on an annual basis, all of our electricity with pv panels, generate most of our hot water needs using solar thermal panels, and cook with propane...about a clean as you can get. Through this power-swapping arrangement with CMP, we provide hi-quality, non-polluting electricity to the utility during our peak output periods. It is "Green" power in its truest sense...no pollution...no drawing down of limited resources. I wish to add my voice to that of Peter Talmage and Naoto Inoue, also of Cape Porpoise, in proposing a clean, efficient approach to net metering in the State of Maine. I will draw heavily from their written comments in this presentation. Maine has had net metering on the books for 10 years. The recently enacted restructuring legislation has put that at risk. Fortunately, the PUC's enlightened approach to this new legislation is a reassurance that the state's goals of encouraging the use of renewable and indigenous sources of energy and diversifying the source of electricity in the State of Maine will be preserved and, hopefully, enhanced. The statue also calls for support of locally available sources - our home certainly fulfills that mandate in part. The PUC has an rare opportunity to re-write the currently applicable regulations in a simplified, streamlined manner...an opportunity to lead in this coming era of competitive energy sales. The PUC has asked for comments on two net metering options. The Talmage/Inoue written response addresses both. I'll pass over that to emphasize what we believe to be a cleaner, less burdensome approach to net metering...for the regulators in the state, the Qualified Facilities and, yes, even for the utilities. I would like to outline our view of net metering. It does not add complexity to the current system, it eliminates it. I suggest that the PUC take a "do away with" approach. Do away with the complexities, the unwarranted costs and the regressive approaches of utilities that currently confuse the net metering landscape. First, do away with two meters for net metering customers. A single bi-directional meter is already required or allowed in 16 of the 20 states currently offering net metering. A single meter will turn backwards when the QF is producing more power that it is consuming and forward when additional power is needed. The difference will be accurately measured. This should not be in dispute, regardless of CMP's claims. The New England states that currently allow for single metering are New Hampshire, Massachusetts, Connecticut, Rhode Island and Maine. While we're on that list, the practice in the field is much different. Three years ago Central Maine Power placed two meters on my house in Cape Porpoise, earlier this month they installed two meters on the Talmage facility, and even as I speak a two meter installation is on tap for the Inoue facility. Only Arizona requires two meters. Two meters cost more to install, require more juggling of figures at billing time and generally add complexity to what should be a straight forward process. Second, do away with complex billing procedures. Allow excess generation in any billing period to be credited or rolled over to the following month, thus eliminating the need for the purchase of this excess energy by a utility or competitive provider. This crediting would continue until the end of the calendar year. Any remaining excess would be granted back to the power provider without compensation to the customer. Any underage would of course be purchased by the customer. How is it that we would be willing to "give away" our excess production at the end of the year? Have we lost our minds, you ask, or are we simply naive about the value of our power? Hopefully, neither. Quite simply, as home power producers, we are attempting to satisfy our own electrical needs with renewable energy...we are not in the business of trying to make money on whatever excess power we produce. Are other states taking this approach? Yes. California, Maryland, Nevada, New York and Rhode Island either require or allow this annualization of the net billing calculation. Third, do away with the utilities' perception that under the new restructuring law they are not required to enter into net metering contracts with QFs of 100kW or smaller. We have already seen how CMP intended to act under the new legislation...to deny new net metering contracts to Peter Talmage and Naoto Inoue. If new power providers coming into the state take an approach similar to CMP's, small power production in Maine will be a thing of the past. This result is diametrically opposed to good public policy and in opposition to the stated goals of encouraging renewable power production in the state. Fourth, do away with power company imposed interconnection requirements, fees and facilities charges. The PUC should establish a standard hookup form which endorses the installation, interconnection and operation standards set for solar installations by the National Fire Protection Association and the Institute of Electrical and Electronic Engineers. Those standards require compliance with the National Electrical Code and the use UL listed components. Ideally, interconnecting a solar electric system or a wind turbine to the grid should be no more complicated than obtaining new electricity service. Have others states stepped in to established these standards? Yes. New net metering laws recently enacted in Maryland, Nevada and New York include such standards. The PUC should establish the standards that all utilities would have to follow, otherwise, QFs would be subjected to varying standards depending on what company was providing their power. In conclusion, I suggest that the PUC has a rare opportunity to do away with complexity, confusion and outdated policies. Our state motto is Dirigo..."I direct." What better opportunity could come your way that to help direct this nation toward the new century of electricity restructuring with a sensible and straight forward net metering policy. Thank you. William Lord |