Differences about Solar Net Metering Policy Refutation of JEA Assertions

JEA: Changes “creating need to realign our solar strategies and policies” ¡  Technologies

Falling costs, Better packages ¡ Markets

Expanding customer-sited generation ¡  Regulations

Including EPA Clean Power Plan ¡ Customer interests

Renewable energy options

Timing, Direction, Full-scope Analysis NOT complete NOT transparent NOT inclusive

JEA: Customers want choice; needs a Clean energy strategy; levels the Playing field; reduce Costs; needs Sales and Revenue stability

¡  Net Metering is one current choice; “Green pricing” options would be another, such as JEA’s proposed voluntary SolarSmart Program. More Efficiency?

¡  JEA’s Clean Energy Strategy has not been articulated; Analysis not explained publicized.

¡  Level playing field (Evaluate the basis for leveling).

¡  Reduce customer Costs by improving system utilization analysis incomplete

¡  Sales growth and Revenue stability? Net metering capacity at 0.1% — far from destabilizing.

JEA’s 2015 10-year system plan sales growth forecast: 0.49% annual average.

JEA: Current level of net metering subsidy is small, but expected to grow ¡  What customer-sited solar generation growth profile is anticipated?

Not yet detailed by JEA. 10-times local growth in customer-sited PV net metering over next few years, customer solar feed: maybe 1% of JEA total sales (2014 JEA total energy sales to customers: 12,224,128 MWh).

¡  No JEA solar PV customers have received end-of-year payments for excess generation in 2014 or 2015. In 2015, solar net-metering customers did receive monthly credits in aggregate of $127,726, for delivery of 1.169 million kWh (1169 MWh) to JEA (0.0096% of JEA sales).

¡  Those same customers purchased 6.533 million kWh (6533 MWH; 2015), 5.6 times more power purchased than credited. Those 448 residential solar customers in 2015 bought per household about 1200 kWh per month—basically the same as the average JEA household customer—at the same rates and charges. Substantially, they paid for their share of JEA capacity overhead and energy, plus fuel charges—as well as fees and taxes.

¡  There’s no material subsidy.

JEA: Engaged Stakeholders Throughout the Community ¡  Several groups were consulted. What kind of dialog took place?

What support and objections were heard? How many people per group; who really do they represent? How much preparation was possible? Sierra Club representatives were not informed before its periodic meeting with JEA of the prospect of solar changes.

¡  Generally, objections have been: too much change, too early, too fast. JEA’s proposal would create disincentives for customer-sited solar. Which stakeholders are welcoming the change? What factors are they considering? How informed are they?

¡  To help address this oversight, we organized this forum—and we encouraged JEA to reach-out more widely to the community and to open its anticipated board workshop in April to the community.

¡  Commonly in Jacksonville, public participation is fostered by / required of government agencies, respecting transportation, city planning, security, major investments or environmental issues. Why is JEA not reaching out widely to inform and engage its customers in 2-way dialog. There are many benefits to be had by such outreach—and continuing.

JEA: Groups consulted without evident, substantial local interests: SEPA & CEA ¡  How are these groups representative of our

community’s solar power interests ¡  Solar Electric Power Association (SEPA) is known

to be influenced by a number of prominent utilities that have come out in favor of changing net metering.

¡  Solar Electric Industries Assn. (SEIA; several local/Florida members) engaged with utilities on issues, pushes back against proposals deemed damaging to the solar industry.

¡ Consumer Energy Alliance—ties to fossil fuel industries. Local membership?

JEA: Growing solar resources 38 MW in 2016 and proposing new value-added products.

¡ 50 MW utility solar will be 1.4% of total JEA generation capacity (Goal for 2012 was 7.5% Renewable Energy per JEA-Sierra Club Community Commitment)

¡ 2015 customer-sited solar PV amounts to 3.7 MW of capacity, equivalent mid-day to about 0.1% of total JEA capacity

¡ Much of this customer-sited solar capacity serves on-site load at peak times, bringing peak-demand shaving benefits to community’s JEA system.

JEA: Pays for excess [feed-in] electricity at JEA’s “cost to acquire solar energy” ¡ Would pay net metering @ $0.075/kWh

for 2016 (to be updated annually). Grave uncertainty for customer-sited solar PV owners.

¡ This PPA-based cost is not reflective of the full range of values to our community afforded by solar power generation as a capacity complement.

¡ [others speaking on the value of solar]

JEA: Proposal in middle of net-metering rates offered by 2 Florida utilities groups ¡  A poor reference—comparing small utilities to the biggest

JEA: Proposed new text Net Metering Policy “. . . to provide support to emerging renewable energy technologies that could someday provide clean, cost effective electric power. As these technologies mature, JEA will adjust its level of support through the implementation of rates that equitably apportion costs based on the cost to serve these Net Metering customers.”

¡  Emerging? Solar is among the fastest growing renewable energy investments in America’s utility sector. Someday? Next to wind turbines, Solar, today and tomorrow, is the cleanest, cost-effective source of electric power. It’s burgeoning in several states, many with much less solar potential than northeast Florida.

¡  Equitably apportion costs? JEA has not taken into account in its economic analysis the full range of net values solar power brings to the community today and will tomorrow. Its analysis was referenced to a “market” basis that failed to include many factors important for our community. How about equitably apportioning benefits?

JEA: Current Net Metering Customers will not be affected, as long as you“ ‏own your home.”

¡  On the contrary, the asset value could well be diminished for solar PV systems owned by a current JEA net metering customer if the proposed Change of Ownership policy is implemented:

“Ownership change of a renewable generation system will result in that system being exclusively governed by the Net Metering Policy in effect at the time of ownership change.”

¡  Net meter customers should be protected for the standard life of their system investment, upon which their financial expectations and commitments were based at time of interconnection agreement with JEA. Performance guarantees for solar systems are typically 20-25 years.

JEA’s current policy of retail-rate Net Metering works; it’s simple, easy to implement, and offers a fair price for distributed generation. JEA Net Metering change as proposed would make it uneconomic for almost anyone to go solar, while offering no corresponding benefits to other customers. Not now: Too soon; Too much; Too fast