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Wednesday, May 13, 2015

RENEW Wisconsin submits public comments regarding Northern States Power Company's pilot solar garden program

Vernon Electric Cooperative's
Community Solar Project in Westby, WI
 Xcel Energy's Wisconsin affiliate, Northern States Power Company (NSPW), is seeking approval to launch a pilot solar garden program. This is the first formal proposal from a Wisconsin investor owned utility to offer solar subscriptions to its customers. Under the program, Xcel Energy would purchase up to three megawatts (3,000 kilowatts) of electricity from local community solar arrays in the company's service area in western and northern Wisconsin. Customers would in turn subscribe for capacity to meet their desired solar energy needs up to their annual usage and receive a monthly credit for their subscription. If approved as is, the monthly credit would be 7.4 cents per kWh for residential customers and 6.9 cents per kWh for business customers. NSPW will set the subscription price based on the results of its solicitation.

Update: On a 3-0 vote, the Public Service Commission approved Xcel's pilot program as proposed. Check our website for details about the program's rollout. 

RENEW submitted the comments below prior to the commission's deliberation of NSPW's solar garden proposal:

 
 222 S. Hamilton, Madison, WI 53703

May 13, 2015

Ms. Sandra Paske
Public Service Commission of Wisconsin
610 N. Whitney Way
Madison, WI  53707-7854

RE:    Application of Northern States Power Company, a Wisconsin corporation, for Approval to Implement a Community Solar Garden Pilot Program (Docket No. 4220-TE-101)

Dear Ms. Paske:

On behalf of RENEW Wisconsin, I would like to submit these brief comments on the above-mentioned application filed by Northern States Power Company (NSPW) on April 27, 2015.  Our comments are as follows.

Items we support:

  • According to a study from the National Renewable Energy Laboratory, about 75% of residential rooftop area is not suitable for installing solar panels, either because the roof is shaded or is not oriented properly, or because the customer doesn’t own their home or building.  We commend NSPW for offering a pilot program to begin exploring how to meet the solar energy interests of such customers.
  • This pilot program, if approved, will be useful in exploring how “community solar gardens” can be effectively designed and operated in Wisconsin by regulated electric providers.
  • We commend NSPW for deciding to acquire solar capacity through a competitive request for proposal process. This will ensure all parties that NSPW will acquire the projects’ output at a competitive, market-based cost.
  • As proposed, this program would operate outside of NSPW’s rate base, like its voluntary green pricing program.  The proposed bill credit has been set to compensate customers based on NSPW’s costs.  Customers should instead be compensated based on what their investment in solar is actually worth. Robust empirical studies have been conducted in multiple states which conclude that there are additional financial benefits of solar over the lifetime of the project. A more complete analysis of these benefits should be conducted, with NSPW and stakeholders, to improve the bill credit level.
  • We commend NSPW on offering a program that enables the participants to directly contribute to increased renewable generation capacity.  New participants in some utility green pricing programs do not necessarily lead to additional renewable energy capacity; that would not be the case here.
  • We believe success of this pilot, if approved, will be determined initially by two factors:  (1) interest from solar developers under the proposed parameters, and (2) customer interest, which will be driven by the perceived value of the offer based on the final subscription price and bill credit level. Both of these factors would be enhanced if NSPW works with stakeholders to improve the formula for calculating bill credits, as suggested above.

Thank you for the opportunity to provide these comments.

Sincerely,



Tyler Huebner
Executive Director

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