Inside the Guts of Maine Solar Policy: The Gross Metering Timeline
On Monday, October 29, Insource Renewables filed a motion with the Maine Public Utilities Commission (PUC) related to the costs of the state’s new gross metering provisions. In this filing, Insource Renewables requested that the PUC order Central Maine Power and Emera Maine to exempt medium and large electricity consumers who install solar from the gross metering requirements due to excessive costs that are shifted onto other ratepayers. Insource also requested that the Commission order a detailed accounting from the utilities to effectively assess the costs and benefits of the changes to Maine’s net energy billing (NEB) program that were announced on March 1, 2017 and went into effect on March 17, 2018.
This filing details costs associated with the program that are significantly higher than were anticipated by the Commission during previous regulatory and legislative proceedings.
Maine’s discussion surrounding solar policy has delved into very complex issues that have been difficult for the public to understand and have at times been covered incompletely by the press. Since filings to the PUC are very formal in nature and the technical details are complex, we are publishing this blog post in an effort to create a summary timeline of key events detailed in the filing that is more accessible to the layperson. With the complexities related to this issue, it is our hope that this summary will help simplify the matter and inform the statewide decision on this topic.
Below are key events related to the implementation of Maine’s gross metering requirements for new solar installations.
March 1, 2017 – PUC Issues Order Adopting Gross Metering
The Maine Public Utilities Commission issues Order Adopting Rule and Statement of Factual and Policy Basis in Docket 2016-00222 that revises the Chapter 313 rules related to net energy billing (NEB). The revised rules define “nettable energy,” which requires the installation of additional “gross meters” to measure the total energy generated by all NEB facilities installed after December 31, 2017. The rule retains language that prohibits the utilities from charging the NEB customer “for the cost of the additional meters or other necessary equipment.” This provision has been in the rules pertaining to NEB since they were originally adopted.
June 16, 2017 – Public Advocate Issues Memo with Initial Utility Estimates for Gross Meter Installations
As part of the legislative hearings related to LD 1504, which sought to override specific revisions to the Chapter 313 rules made by the Commission, the Office of the Public Advocate issues an analysis of the costs and benefits of the nettable energy provisions of the revised Chapter 313 rules in a memo submitted to the Energy, Utilities, and Technology (EUT) Committee of the Maine State Legislature. In this document, the Public Advocate includes the estimate of cost for installing the additional meters or other necessary equipment provided by Central Maine Power (CMP) and Emera Maine (Emera) in the legislative proceeding. This estimate is $500.
June 19, 2017 – PUC Responds to Public Advocate’s Memo Using Same Meter Cost Assumption
In response to the aforementioned memo from the Office of the Public Advocate, the Commission submits a document entitled Public Utilities Commission Information Regarding LD 1504, An Act to Modernize Rates for Small-scale Distributed Generation to the EUT Committee. In this document, the Commission confirms its assumptions for evaluating the cost effectiveness of the revised Chapter 313 rules. Their assumptions include a $500 metering cost per NEB facility and that the meters will recover a defined percentage of the full residential delivery rate at each NEB facility. Their analysis does not include the administrative costs associated with billing system upgrades for three utility districts, does not consider how rate design reduces the recovered revenue from residential NEB facilities, nor considers the significant difference in delivery rates for residential and commercial customers.
August 2, 2017 – Legislative Effort to Eliminate Gross Metering Provision Fails in House
The Maine House of Representatives sustains governor’s veto of LD 1504, which would have eliminated the gross metering requirements of the revised Chapter 313 rules. Instead of decreasing delivery benefits based on the gross output of the NEB facility, the bill would have based the revenue recovery on the net output of the NEB facility. As a result, the rule changes adopted on March 1, 2017 are slated for implementation on January 1, 2018.
September 1, 2017 – CMP Provides Cost Estimates to the PUC for Installing Gross Meters
In its Biannual Net Energy Billing Report, CMP provides estimates for the additional metering costs of $660 for residential applications and $420 for commercial applications.
September 27, 2017 – CMP Recognizes That Their Initial Estimates Were Low
CMP submits a Petition for Advisory Ruling Regarding Interpretation of Chapter 313 (Docket No. 2017-00264) to the PUC that demonstrates the first occasion that CMP publicly acknowledged their failure to account for the full costs of installing the gross meters in their earlier estimates. The document states that “CMP would estimate that the cost per customer would be in the thousands of dollars. CMP sees no reason why non-net energy billing customer should be responsible for such costs.”
November 20, 2017 – Insource Renewables Asks Commission to Address Lack of Guidelines for Implementing Gross Metering
Insource Renewables files a Petition for Waiver in Docket No. 2017-00308 due to a lack of details provided by CMP and Emera for how the revised Chapter 313 rules will be implemented on January 1, 2018. In this petition, Insource requests that the Commission grandfather all NEB customers who have signed an installation contract and submitted an NEB application to the utility.
December 1, 2017 – CMP Indicates that Minor Billing System Changes Are Expensive
In comments related to its petition in Docket 2017-00264, CMP estimates that the incremental costs for a relatively small change in its billing system related to the location and wiring configuration of the gross meter would be $300,000.
December 11, 2017 – PUC Delays Gross Metering Implementation and Confirms that Ratepayers are Responsible for Gross Metering Costs
In response to CMP’s petition dated September 17, 2017, the PUC issues its Central Maine Power Company, Request for Advisory Ruling Chapter 313 Clarification, which explicitly disagrees with CMP’s interpretation that it is only responsible for the costs associated with the equipment it owns (the meter). In this clarification, the PUC reaffirms that the Chapter 313 rule prohibits the utilities from charging NEB customers for the additional work required for gross metering.
The PUC also issues a response to Insource Renewables’ petition. It denies Insource’s specific request to grandfather NEB facilities based on the date of the customer’s submission of interconnection application. Instead, the order delays implementation of the nettable energy provision of the rule until May 1, 2018. The PUC also directs stakeholder to continue with discussions to resolve the outstanding implementation questions related to the revised NEB rules.
January 15, 2018 – CMP Revises Cost Estimates for Installing Gross Meters
CMP updates its estimates for additional metering costs in its Biannual Net Energy Billing Report submission to the PUC. The utility estimates that residential gross meters will cost $1,410 for residential applications and $3,200 for commercial applications. CMP also communicates that the meters for three-phase commercial installations could be as high as $7,800.
January 31, 2018 – Solar Industry Provides First Detailed Estimates of Costs of Additional Equipment
As part of the stakeholder discussions to resolve the remaining implementation details, Insource provides a memo to the PUC and utilities on behalf of Maine’s solar industry with estimates of reasonable costs to install the additional equipment required of gross metering. The figures contained in this memo are the first rigorous estimates provided in the proceedings related to gross metering. These estimates were provided with acknowledgment that there may be additional costs once the utilities provide detailed installation requirements.
February 26, 2018 – PUC Shortens Implementation Delay of Gross Metering
The PUC issues its Order on the Motion to Reconsider of Governor Paul R. LePage, which suspends the waiver established by the PUC’s December 11, 2017 order. This moves the implementation date of the nettable energy provisions of Chapter 313 from May 1, 2018 to March 17, 2018.
March 17, 2018 – Gross Metering Era Begins
Nettable energy provisions go into effect. NEB installations that were placed under contract prior to March 16, 2018 for installation prior to May 1, 2018 are granted waivers based on affidavits submitted to the PUC.
March 23, 2018 – CMP Provides Installation Requirements for Gross Metering
At a meeting between CMP, Emera, and representatives of the solar industry, CMP provides its Gross Metering Requirements for MPUC Chapter 313. This document details the specific installation requirements for the additional metering equipment. Emera attends and provides similar requirements.
April 10, 2018 – Second Legislative Effort to Eliminate Gross Metering Provision Fails in House
The Maine House of Representatives sustains the Governor’s veto of LD1444, which would have prohibited gross metering.
June 7, 2018 – Insource Renewables Files Motion with PUC Due to CMP Nonpayment to Installers
Insource Renewables files its Motion for an Order Requiring Central Maine Power Company to Conform its Net Energy Billing Practices to the Commission’s Chapter 313 Rules in Docket 2018-00037 in response to CMP’s refusal to reimburse NEB customers for the reasonable costs of the additional equipment required for gross metering.
August 21, 2018 – PUC Orders CMP to Pay for Additional Equipment
The PUC issues an order in response to Insource’s June 7, 2018 Motion that reaffirms the cost obligations related to gross metering and requires CMP to reimburse NEB customers for the reasonable costs to install the additional equipment required to enact the nettable energy provisions of Chapter 313.