On March 9, 2021, the Utah Public Service Commission will consider a new request by Rocky Mountain Power to further lower the solar export credit rate rooftop solar owners receive for the solar they export to the grid.
It’s been barely four months since Utah’s Public Service Commission (PSC) ruled to lower the compensation for exported rooftop solar energy down to less than 6 cents per kilowatt-hour (kWh) from 9 cents per kWh, a devastating blow for Utah’s solar industry. “This ruling was a hard blow for Utah’s solar jobs, and for every Utahn that still wants to go solar. We’re still trying to figure out how and if the solar industry will be able to stay afloat in Utah,” says Doug Shipley, President of Intermountain Wind and Solar.
In newly filed testimony, Rocky Mountain Power is asking the PSC to revisit a key element of the Export Credit Rate calculation – the capacity contribution. Rocky Mountain Power is proposing a unique, one-of-a-kind methodology for calculating this value, that if approved would take the Solar Export Credit Rate down even further to 3.569 cents per kWh in summer and 3.239 cents per kWh in the winter.
The proposal comes out of left field for other interveners in the Solar Export Credit case. “Rocky Mountain Power is trying to re-litigate an issue that has been extensively considered for over a year. The Public Service Commission already considered Rocky Mountain Power’s proposal during the proceeding late last year and denied it. Re-submitting their proposal, essentially unchanged, after the formal proceeding has ended is disingenuous,” states Kate Bowman, Utah Clean Energy’s renewable energy program manager.
Utah Clean Energy opposed Rocky Mountain Power’s proposal in filed testimony on February 22. A few of our arguments include:
- Rocky Mountain Power is simply trying to re-litigate an issue that has been extensively considered through pre-filed testimony and during the hearing. RMP already advanced their capacity contribution proposal through rebuttal testimony, filed in July 2020, and at the hearing, during which the PSC heard oral arguments and cross examination of witnesses and extensive public comments over the course of six days. The PSC had ample opportunity to consider RMP’s proposal and did not approve it.
- RMP failed to introduce this issue in their Petition for Rehearing, when they had the opportunity to do so. Several parties, including UCE, Vote Solar and Vivint Solar, and RMP, filed Petitions for Review or Rehearing following the Commission’s Order in October. RMP could have chosen to raise the issue of capacity contribution in their own Appeal, but did not. Instead, RMP re-introduced their proposal in response to an appeal filed by Vote Solar and Vivint Solar. Vote Solar and Vivint Solar’s appeal addressed several issues, but it did not address the capacity contribution. Confusingly, Rocky Mountain Power states that the Commission’s decision on the Export Credit Rate was overall reasonable and should not be changed, however if the Commission chooses to re-hear any of the issues raised by Vote Solar and Vivint Solar, then it should also re-hear the separate and unrelated issue of capacity contribution.
- RMP’s new capacity contribution proposal is a unique and first-of-its-kind methodology that is not standard practice for utilities and is not, as far as we are aware, in use anywhere else. RMP’s method penalizes rooftop solar for generation from utility-scale solar farms that occurs during the same hours, without consideration of the broader interaction between solar resources, customer load, and other types of generation and energy resources. RMP has not provided evidence that their capacity contribution proposal is more accurate than other, more commonly used and tested, methodologies.
Utah Clean Energy has asked the Public Service Commission to affirm their previous decision and reject Rocky Mountain Power’s proposal to lower the capacity value of rooftop solar energy, which would further injure Utah’s solar industry and put rooftop solar even further out of reach for families and businesses in the state. A hearing will take place on March 9th, 2021.
On a separate note, Vote Solar has appealed the Public Service Commission’s October order to the Utah Supreme Court. This case is proceeding as Appellate Case No. 20210041-SC.