California, you will soon be deciding an interesting debate
about who, if anyone, should be collecting data about the state’s distributed
generation installations. Under the
California Solar Initiative (CSI), information about all of the systems that
took advantage of the CSI incentives has been collected and published on the California
Solar Statistics website. One would
think that such transparency that allows an agency and other interested parties
to track the success of a program funded with public money would be a
no-brainer. Apparently, it isn’t.
California Public Utilities Commission, you will soon be
issuing a final ruling on minimum reporting requirements that, with the phase
out of the CSI, would now fall to the utilities. This was reported recently in Solar Industry Magazine available here. According
to the article, unsurprisingly, certain large developers and the utilities
oppose these eminently reasonable reporting requirements citing such specious
arguments as the cost of providing this data ($7 to $22 on systems costing tens
or hundreds of thousands of dollars).
For years, California and CSI you got this right. As noted in Solar Industry Magazine “The
information is supposed to let manufacturers, contractors and investors know
which equipment is being installed and where, provide academics and journalists
with industry information, and help utilities understand more about their
distributed generation fleet.” This debate brings to mind a
similar one that existed in Colorado back in 2006 concerning the collection of
information on that state’s solar incentive program.
At that time, a
Colorado PUC staffer was assigned to assess a utility application to implement
a forward-looking tariff that would fund the nascent solar incentive program
under Colorado’s new Renewable Energy Standard (RES). That new tariff came to be known as the
Renewable Energy Standard Adjustment (RESA) and it now collects a bit over $50
million a year in customer money from that one utility and a lesser amount from
a second, smaller utility (the fact that the utilities have been allowed to be
the administrators of those accounts raises other concerns but that is a
different discussion). At the time, the
requested tariff of 1% of customer billings was projected to raise approximately $20
million per year. The PUC staffer was
charged with recommending to the Commission whether the tariff should be
allowed to go into effect unopposed or should be suspended and set for hearing.
Ever the dutiful
public servant, and having not inconsiderable experience in major industrial project management in the private sector,
this staff member requested from the utility a pro forma budget indicating how
the funds were to be spent. He was told
there was none. The rest of the
conversation was brief:
PUC Staff: Then why are you asking for $20 million?
Utility: Because we can.
The tariff was
suspended and set for hearing initiating Colorado PUC docket 06S-016E.
Through
subsequent negotiations, the initial RESA tariff would be set at 0.6% of
customer bills on the condition that the utility provide the PUC with a monthly
report from its database that included much the same data that CSI has been
collecting. That too took a strange
twist. That conversation went something
like this:
PUC Staff: We’re interested in tracking the growth of
the program and how the incentives will contribute to the development of the
solar industry in Colorado. So, we would
like a monthly report from the solar registration database.
Utility: What database? We’re not going to have any database.
PUC Staff: Well,
how are customers and installers going to apply for the rebates?
Utility: They’ll submit an application with all of
the interconnection data and rebate information on it. But, there won’t be a database.
PUC Staff: Really?
Utility: If you want that information, we’ll send you
paper copies of all of the applications each month and you can create your own
database.
PUC Staff: Oh,
well. OK.
And so for the next 6 months the utility dutifully submitted
seven copies (as required by PUC rules for all paper submittals) of all of the solar
rebate applications which an intern working for the staffer gleefully compiled
into a database of system level data using Microsoft Excel. That is, until the utility representative’s
successor came back to the PUC staffer and said:
Utility: Look, we’re
really tired of copying all of these applications and hauling them over every
month. How about we just send you a copy
of the database on CD each month?
PUC Staff: You mean the database that you don’t have?
Utility: Yeah, that
one.
And so, the PUC staffer ultimately used this data to report
to the public on the success of the solar rebate program, where the incentive
payments were going county by county, how system costs were falling, the level
of economic activity generated by the program, and many other statistics that
the public and policy makers would (or should) want to know about how hundreds of
millions of dollars in support for the renewable program was being spent.
The first publicly issued report of this data showing four
years’ worth of data on solar installations in the state was welcomed by many
and was especially of interest to the installer community. Curiously, the report was not welcomed by
certain PUC bureaucrats and the utilities who together sought to quash the report
because they felt that it reflected negatively on their administration of the
solar program. It didn’t but the report
did contain some policy recommendations to manage the program more effectively
in the public interest. The agency even
went so far as to deny an open records act request by the industry trade
association seeking a copy of the report.
Ultimately, the report became the focus of a Whistleblower
complaint and was released by a state personnel department administrative law judge who soundly
rejected agency and utility arguments for a protective order that would bar
disclosure of the information contained in the report. Sadly, by the time all of this had occurred,
much of the information contained in the report had become stale. Today, the
arguments in many states are no longer over solar subsidies per se, but whether
net metering and distributed generation itself provides a subsidy that
disadvantages a utility and the general body of ratepayers.
The end of this story is that docket 06S-016E is still open
and utilities still contribute monthly reports of their collections and
expenditures of RESA funds. However,
neither the utilities nor the agency appear interested in a comprehensive
analysis of the systems installed using those funds and the policy implications
thereof.
The moral of this story for you California is that you’ve been doing the right thing in the collection and
publication of this system level data all along and should continue to do so to
foster transparency in the administration of programs in the public interest.