STATE OF MAINE CIVIL ACTION PUBLIC UTILITIES COMMISSION MAINE SUPREME JUDICIAL COURT DOCKET NO: 2016-00222 CONSERVATION LAW FOUNDATION, REVISION ENERGY LLC, NATURAL RESOURCES COUNCIL OF MAINE, and INDUSTRIAL ENERGY GROUP, NOTICE OF APPEAL STATEMENT OF THE ISSUES Appellants v. PUBLIC UTILITIES COMMISSION, Appellee. Pursuant to 35-A M.R.S. 1320(4) and Maine Rule of Appellate Procedure Appellants Conservation Law Foundation ReVision Energy LLC (?ReVision?), Natural Resources Council of Maine and the Industrial Energy Consumers? Group (collectively ?Appellants?), hereby submit this brief statement of the nature of the proceeding before the Public Utilities Commission (?Commission?) and statement of the issues as an attachment to the Notice oprpeal, Form On March 1, 2017, the Commission approved by ?nal written order amendments to the Customer Net Energy Billing rule, 65?407 CMR, ch. 313. See generally Public Utilities Commission Amendments to Net Energy Billing Rule (Chapter 313), No. 2016-00222, Order Adopting Rule and Statement of Factual and Policy Basis (Me. P.U.C. Mar. 1, 2017). Pursuant to Commission rule, 65?407 CMR, ch. 1 10 1 Rules of Practice and Procedure, Appellants filed a petition for reconsideration ofthe Commission?s order on March 21, 2017, which the Commission denied by allowing 20 days from the date offiling to pass without action, on April 10,2017. CLF, ReVision, NRCM and appeal the Commission?s Order AdOpting Rule and Statement of Factual and Policy Basis and amendments to the Customer Net Energy Billing rule as unlawful because: 1. The Commission?s promulgations of amendments to the Customer Net Energy Billing rule and the Order AdOpting Rule and Statement of Factual and Policy Basis are unsupported by evidence in the record and based upon the Commission?s selective analysis of only certain record evidence; The Commission?s promulgation of amendments to the Customer Net Energy Billing rule are inconsistent with and fail to follow the mandates of applicable statutes establishing Maine?s solar policy, see, 35-A MRS. 3474(2); The Commission?s promulgation of amendments to the Customer Net Energy Billing rule are in excess ofits statutory authority, see, 35-A M.R.S. The Commission?s imposition of transmission and distribution charges on net energy billing customers for energy generated and consumed behind the meter is unsupported by evidence in the record, constitutes unjust discrimination, and is inconsistent with statute, see, eg. 35-A M.R.S. 3209(3); The Commission failed to adhere to the Maine Administrative Procedure Act?s requirements relating to the fiscal impacts ofa prOposed rule, 5 MRS. The Commission failed to request comments from the public concerning changes made to the proposed rule after the close of the initial comment period, as required by the MAPA for a rule that the Commission intends to adept that is substantially different from the proposed rule, 5 MRS. and The Commission failed to prepare an economic impact statement as required by the MAPA for ?any proposed rule that may have an adverse impact on small businesses,? 5 MRS. 8052 (5-A), rendering the ?nal rule ?void and ofno legal effect,? id. 8057(1). Attached are copies of the Commission Order Adopting Rule and Statement of Factual and Policy Basis, the amended Customer Net Energy Billing rule, 65?407 CMR, ch. 313, and Appellants? Petition for Reconsideration. 7 . - ?4 Inily K. en, sq., Bar No. 005095 Attorney C0 ervation Law Foundation 53 Excha ge St Suite 200 (207)21 ?643 egreen le.0rg Steve Hz?nehman Steve Hinchman Chief Counsel for ReVision Energy LLC 142 Presumpscot St. Portland, ME 04103 (207) 837-8637 steveh@revisi0nenergy.com Dylan Voorhees Dylan Voorhees Natural Resources Council of Maine 3 Wade St. Augusta, ME 04330 (207) 622-3101 Andrew Landry Andrew Landry Counsel for Industrial Energy Consumers? Group PretiFlaherty PO. Box 1058 Augusta, ME 04332-1058 (207) 623-5300 alandry@preti.com 35-A M.R.S 1320(4) CERTIFICATE OF COUNSEL I, Emily K. Green, am of the Opinion that there is probable ground for the appeal as to make it a ?t Subject for judicial inquiry and that it is not intended for delay. Dated at Portland, Maine, this Day of May, 20 7. milyK. reen, sq. Attorne for nservation Law Foundation CERTIFICATE OF SERVICE I, Emily K. Green, hereby certify that this Notice of Appeal Statement of the Issues and the attached Notice of Appeal form, and Transcript and Audio Order Form, 165, were hand ?led with the clerk of the Public Utilities Commission and were ?led in the underlying docket through the Commission?s electronic ?ling system on May 1, 2017. Dated at Portland, Maine, this 1St Day of May, 2017. ily K. een, Esq. ttorney or nservation Law Foundation STATE OF MAINE PUBLIC UTILITIES COMMISSION Docket No. 2016-00222 March 1, 2017 PUBLIC UTILITIES COMMISSION Amendments to Net Energy Billing Rule (Chapter 313) ORDER ADOPTING RULE AND STATEMENT OF FACTUAL AND POLICY BASIS VANNOY, Chairman; McLEAN and WILLIAMSON, Commissioners I. SUMMARY Through this Order, the Commission adopts amendments to the net energy billing rule (Chapter 313). Specifically, the Commission amends the rule to reduce over time the amount of a generation facility’s output that can offset, or be netted against, the transmission and distribution (T&D) utility portion of a customer’s bill. Netting regarding the supply portion of the customer bill remains unchanged. Under the amended rule, the phase down will apply to facility installations on or after January 1, 2018, and existing net energy billing customers will be grandfathered for a fifteen year period. II. BACKGROUND A. Net Energy Billing Rules Chapter 313 of the Commission’s rules governs net energy billing (NEB) in Maine. NEB is a metering and billing mechanism that is generally used to promote the development and operation of small renewable generation facilities. Under Chapter 313, customers that own or have an interest in an eligible generation facility are billed for electricity on the basis of “net energy” over a billing period. Net energy is defined in the existing rule as the difference between the kilowatt-hours (kWhs) a customer consumes and the kWhs produced by that customer’s generating facility over a billing period. Excess generation from a customer’s generating facility in a given billing period may be used as a kWh credit to offset that customer’s electricity usage in a future billing period when the customer’s facility did not generate enough to offset the customer’s electricity usage. Excess kWh credits can be used to offset customer usage over a twelve month period. 1 The Commission first adopted a net energy billing rule in the early 1980s and significantly modified it in 1998 to adapt the rule to industry 1 For a more detailed description of net energy billing see Maine Public Utilities Commission, Commission Initiated Inquiry Into Market-Based Solar Policy Design Stakeholder Process, Docket No. 2015-00218, Report to the Legislature Regarding Market-Based Solar Policy Design Stakeholder Process (Feb. 3, 2016). ORDER 2 Docket No. 2016-00222 restructuring. Order Adopting Rule and Statement of Factual and Policy Basis, Docket No. 2004-396 (Sept. 8, 2004). As the Commission has consistently recognized, NEB supports State energy policies in favor of the promotion and development of renewable, diverse and indigenous electricity supply resources that do not rely on fossil fuels and do not contribute to greenhouse gas emissions. 2 Additionally, the 126th Maine Legislature found “that it is in the public interest to develop renewable resources, including solar energy, in a manner that protects and improves the health and well-being of the citizens and natural environment of the State while also providing economic benefits to communities, ratepayers and the overall economy of the State.” 3 The Commission has also consistently recognized that the NEB mechanism results in a shift of T&D utility revenue responsibility from NEB customers to non-NEB customers with corresponding impacts on the rates of non-NEB customers. 4 For this reason, to ensure costs are examined, Chapter 313 contains a provision for the review of the NEB rules. 5 Section 3 (J) of Chapter 313 specifies: Commission Review. A transmission and distribution utility shall notify the Commission if the cumulative capacity of generating facilities subject to the provisions of this Chapter reaches 1.0 percent of its peak demand. Upon notification, the Commission will review this Chapter to determine whether net energy billing pursuant to this Chapter should continue or be modified. 2 For a full discussion of the history and operation of NEB in Maine, including costs and benefits, see Maine Public Utilities Commission, Report on Net Energy Billing, submitted to the Legislature on January 15, 2009. 3 35-A M.R.S. § 3472(1). 4 Several commenters argue that there is no cost shift, that the Commission has not conducted an analysis of the amount of any cost-shift, and that any cost-shift is outweighed by the benefit of solar installations. These matters are discussed in section III(B)(1), below. 5 As stated in the Commission Orders that initially adopted and modified the review trigger provision, the purpose of the provision is to assure that reexamination occurs as NEB costs increase over time. Public Utilities Commission, Customer Net Energy Billing (Chapter 313), Docket No. 98-621, Order Adopting Rule and Statement of Factual and Policy Analysis at 11 (Dec. 10, 1998); Public Utilities Commission, Amendments to Net Energy Billing Rule to Allow Shared Ownership (Chapter 313), Docket No. 2008-410, Order Adopting Provisional Rule and Statement of Factual and Policy Basis at 13 (Jan. 8, 2009). ORDER B. 3 Docket No. 2016-00222 Commission Inquiry On January 14, 2016, Central Maine Power Company (CMP) filed a letter stating that, at the end of calendar year 2015, the cumulative capacity of the generating facilities for which CMP has net energy billing agreements under Chapter 313 is approximately 1.04% of CMP’s annual peak demand. 6 At that time and related to the 1.04%, CMP identified forgone T&D revenue of over $1.2 million. Consequently, CMP requested that the Commission undertake the review of net energy billing required by Section 3(J) of Chapter 313. In response to the CMP letter, the Commission, on June 14, 2016, issued a Notice of Inquiry to obtain comment and information from interested persons regarding Maine’s NEB rules and whether the rules should be modified in light of changes in small renewable markets, technology developments and costs. Maine Public Utilities Commission, Commission Initiated Inquiry into Net Energy Billing Rules (Chapter 313), Docket No. 2016-00120, Notice of Inquiry (June 14, 2016). The Commission received written comments from the following interested persons: David Russell, Maine Association of Building Efficiency Professionals, Conservation Law Foundation, Acadia Center, Governor’s Energy Office (GEO), Revision Energy, LLC, The Nature Conservancy, Central Maine Power Company, Emera Maine, Clean Energy Collective, LLC, Energy Freedom Coalition of America, Natural Resources Council of Maine, Sunrun, Inc., Office of the Public Advocate (OPA), Municipal Street Lighting Group, Ethan Strimling, Mayor of Portland and Jon Hinck, City Councilor, legislators and several joint respondents. The Commission also received a large number of public comments. The OPA and GEO recommended fundamental changes to the NEB rules and several interested persons suggested more moderate changes to improve the current rules. Many of the commenters urged the Commission not to initiate a rulemaking proceeding or make any changes to NEB. C. Rulemaking Process On September 14, 2016, the Commission issued a Notice of Rulemaking (NOR) and a proposed rule that contained several proposed amendments to the net energy billing rule (Chapter 313). 7 The proposed amended rule would reduce over time the amount of the output of a generation facility that could be netted against the T&D portion of a customer’s bill (referred to as “nettable” energy). No change was proposed for the supply portion of the bill. The proposed amended rule grandfathered existing 6 CMP stated that the 1.04% is based upon the ratio of 16.261/1,565.300, where the numerator is the megawatts of nameplate capacity of contracted net energy billing facilities and the denominator represents the Company’s 2015 annual hourly peak demand. 7 Hereinafter, proposed amended rule refers to the rule included in the September 14, 2016 NOR and amended rule refers to the rule as approved by this Order. ORDER 4 Docket No. 2016-00222 NEB customers for a fifteen year period. In addition, the proposed amended rule increased the maximum size for an eligible generating facility from 660 kilowatts to one megawatt and added specific provisions that would allow and provide consumer protections for community net energy billing and net energy billing leases. The reduction over time in nettable energy would reduce, and ultimately eliminate, the shifting of T&D costs from NEB customers onto non-NEB customers. In addition, the proposed reduction in nettable energy tracked the continuing declining costs of renewable technologies, in particular solar photovoltaic (PV) technology. Consistent with rulemaking procedures, the Commission held a public hearing on October 17, 2016 and received written comments on the proposed amended rule. The Commission received comments from the following: Office of Public Advocate (OPA); Governor’s Energy Office (GEO); Central Maine Power Company (CMP); Emera Maine, Industrial Energy Consumer Group (IECG); Natural Resources Council of Maine (NRCM); Conservation Law Foundation (CLF); Maine Audubon; the Nature Conservancy, A Climate to Thrive (ACTT); American Lung Association; Revision Energy, LLC; Maine Association of Building Efficiency Professionals (MABEP); Clean Energy Collective, LLC (CEC); Sunrun, Inc.; Maine Community Solar Farm Association (MCSFA); Solar Energy Association of Maine (SEAM); Arrowsic Conservation Commission (ACC); Islesboro Energy Team (IET); Ashley Brown, Harvard Electricity Policy Group; Barbara R Alexander, Consumer Affairs consultant; Ahmad Faruqui, The Brattle Group. The Commission also received a large number of public comments from individuals and groups (including customers both with and without solar facilities) which primarily supported solar incentives to address climate change and promote jobs in the solar industry. These comments were in opposition to changes to the NEB rules. 8 Other individual commenters supported changes to the NEB rules to minimize impact on non-NEB customers. 9 8 Many individual commenters make the erroneous assumption that proposed changes are to the benefit of the utilities. Under traditional utility ratemaking, utility rates are based on actual costs and are established to provide utilities with an opportunity to earn a reasonable return on their investments. Therefore, although lost revenue may be borne temporarily by a utility between rate cases, the revenue requirement is ultimately shifted to other customers. Moreover, under certain ratemaking mechanisms, such as the revenue decoupling mechanism currently in place for CMP, lost revenues are automatically recovered from customers through an annual adjustment to rates. 9 The Commission also received comments regarding CMP’s recent decision to require that each NEB account be assigned a specific percentage of the output of generating facilities. CMP also requested that, to the extent that NEB customers are allowed to hold multiple accounts, the NEB customers be prohibited from shifting banked credits between those accounts. These matters were not raised in the NOR or the proposed amended rule and will not be addressed in this proceeding. ORDER 5 Docket No. 2016-00222 The Commission addresses the comments it received in this rulemaking process relative to each issue in the following sections. III THRESHOLD MATTERS Several threshold matters were raised in the rulemaking process. These are discussed below. A. Consideration of NEB Rule Changes Several commenters, including NRCM and Sunrun, commented, as they did in the Inquiry, that the Commission should not pursue changes to its NEB rules because it is the Legislature’s role to determine State energy policy and the Legislature is expected to consider solar policies. Other commenters supported the consideration of NEB rule changes, including the OPA, GEO, CMP, Mr. Brown and Ms. Alexander. Comments in support of rule changes included providing an appropriate subsidy for small solar installations, while minimizing the rate impact on other customers, including low income customers. Fundamentally, it is the role of the Legislature to establish energy policy. 10 However, it is the Commission’s responsibility to continually monitor and review rules it has promulgated and to update or modify them in light of changed circumstances. This is especially the case when a rule implements a program that raises costs to ratepayers in general; and here, the rule explicitly directs review. In this case, a failure to change the NEB rules would result in an ever increasing incentive going to NEB customers (funded by non-NEB customers) as retail rates increase and the cost of the technology decreases. Such an approach would be inefficient and would provide little or no market-based incentive to drive down the installed cost of facilities, nor for solar installers to flow through any cost reductions that are realized to customers. Solar installers, like most for-profit businesses, set their prices based on what the local market will bear, which is not necessarily in line with actual costs. The predominant NEB technology in Maine is solar PV. Because PV costs have been declining and are projected to continue to decline substantially, economic efficiency dictates that NEB should be structured so that any incentive reflects these cost trends. 11 10 In its January 8, 2009 Order Adopting Rule, the Commission recognized that fundamental decisions regarding the structure of NEB is ultimately a question of State energy policy to be determined by the Legislature and that the consideration of rule changes by the Commission can be helpful to the Legislature in this regard. Public Utilities Commission, Amendments to Net Energy Billing Rule to Allow Shared Ownership (Chapter 313), Docket No. 2008-410, Order Adopting Provisional Rule and Statement of Factual and Policy Basis at 3-4 (Jan. 8, 2009). 11 The declining cost trends of solar PV installation are discussed in section III(B)(3) below. ORDER 6 Docket No. 2016-00222 This situation is not unique to Maine. For example, according to the NC Clean Energy Technology Center, which publishes a comprehensive quarterly update on state solar policies across the country, “At the state level, the general trends are that solar rebate incentives are decreasing, solar tax incentives are expiring, renewable portfolio standards are nearing their targets, net metering caps are being reached, and net metering and rate design are undergoing regulatory and legislative review.” The 50 States of Solar, NC Clean Energy, 5 (Q3 2015). Thus, in light of the undisputed substantial cost reductions for small renewable generation (particularly solar PV) and the growing cost shift to non-NEB customers as the number of NEB facilities increase, the Commission concludes that it is now appropriate to consider and adopt amendments to its NEB rules to over time reduce the incentives for new NEB customers, and to reduce the corresponding impact on the rates of non-NEB customers. The reductions will be phased in over a ten year period. B. Costs and Benefits of NEB Many commenters, including the NRCM, MABEP, MCSFA, Sunrun, SEAM, ACTT, Revision, Nature Conservancy, ACC and IET strongly oppose any change to the NEB rules that would reduce the monetary benefits to NEB customers. These commenters generally state that the Commission failed to conduct an analysis of the benefits and costs of solar installations and has no factual record to support changes to the NEB rules or the conclusion there is any harm to ratepayers (such as crosssubsidization). Commenters also stated that NEB customers are not receiving the value their installations provide to the system, including climate change benefits, and that the Commission did not consider its own value of solar study. The IECG suggested that Commission conduct an investigation to consider whether the benefits outweigh costs and to determine if a cost shift occurs. Others commented that the rule should be modified to lessen the rate impact to customers that do not have their own generating facilities. There are three basic categories of cost and benefit issues related to NEB. These are: 1) current and ongoing cost shifts from NEB to non-NEB customers and the resulting rate impacts; 2) longer-term system value provided by NEB facilities; and 3) declining technology costs. These are discussed below. 1. Costs Shifts and Rate Impacts NEB customers, as all customers, use and benefit from the T&D system but, as a result of the rule’s billing mechanisms, do not pay the full costs for this use. Specifically, the only time an NEB customer is not using the T&D system is at those instantaneous points in time when their load exactly matches their generation output. At all other times ORDER 7 Docket No. 2016-00222 NEB customers are either importing or exporting energy from or to the electric grid. 12 In this case, the customer is using the T&D system in lieu of its own battery system. Under current NEB, rather than paying for its use of the T&D system at a given time, the customer’s generation and usage would be netted against each other over the billing period and the customer would be billed only for any net kWh usage. 13 Because the costs of the T&D system to serve NEB customers are still incurred by the utility, these costs are ultimately paid for by other customers. This is what is referred to as a “costshift” and there can be no doubt that it exists. Moreover, the actual amount of this cost shift can be determined with reasonable accuracy and Maine utilities track this lost revenue as part of their annual NEB reports. 14 Some have argued that the fixed minimum or customer charges cover the costs of the T&D system that is used to serve NEB customers. The Commission does not agree. The fixed or minimum charges in utility rates are established in utility rate design proceedings in which a host of factors are considered, including cost studies, rate stability, and complexity. The fixed charges in utility rates have historically accounted for only a small portion of the T&D fixed costs, most notably the customer-related costs such as metering and billing. For residential and small commercial customers, the remainder of the T&D utility’s costs (which are generally fixed and do not vary with customer usage) for the investment in, and operation and maintenance of, facilities such as poles and wires, are recovered through volumetric kWh charges which are currently subject to netting. Thus, there is no validity to the argument that the existence of fixed or minimum charges eliminates the cost shift issue. 15 2. Value Studies A central component of the debate over “costs and benefits” of NEB is the question as to whether the costs to the general ratepayers through the cost shift is outweighed by the societal benefits or value of small solar installations. Many of the solar advocates in this proceeding have relied upon the Maine Distributed Valuation Study (Apr. 14, 2015) (VOS study) 16 to support arguments that 12 This is particularly the case in a scenario where solar output is about 14% of its nameplate capacity meaning that, on a daily basis, solar panels are producing energy at rated output for approximately 3.36 hours of every 24 hour period. 13 In addition, the customer would also not pay for its use of the T&D system when it was exporting energy to the system. 14 In its latest report, CMP determined that the lost revenue for calendar year 2016 was $1.8 million. 15 Some commenters have argued that NEB customers should not be assessed the minimum charge. However, as described above, NEB customers use and rely on the system and should, therefore, contribute to the costs of maintaining the system. 16 This Study was conducted pursuant to An Act to Support Solar Energy Development in Maine. P.L 2013 Chapter 562 (codified at 34-B M.R.S. §§ 3471-3473). ORDER 8 Docket No. 2016-00222 there are no cost shifts or subsidies involved with NEB billing. The study concluded that distributed solar facility output has a long-term levelized value that is significantly higher than the value being received by NEB customers. However, the Commission emphasizes that the Maine VOS study, as well as other “value” studies, must be viewed in the context of the methodology and purpose of such studies. Fundamentally, the methodology is an explicit application of an avoided cost methodology. The cost of solar technology is not even a component of the method. Rather, the methodology “values” solar PV by what technical and environmental matters would be avoided if current generation means were replaced by solar PV. Unique to the “what would be” approach of avoided cost, and in sharp contrast to established cost of service ratemaking, it does not matter to the calculated “value of solar” if a panel costs fifty cents per kilowatt or five thousand dollars per kilowatt. In addition, these value studies are long-term in nature, and include difficult to quantify externalities, such as environmental effects. Their results are highly dependent on assumptions about longterm energy cost and the choice of discount rates. Because energy market conditions are continually changing, such long-term studies can very quickly become outdated. The Maine VOS study, as well as similar studies, calculates the value of attributes in two broad categories: those which are monetizable in the wholesale markets; and those that are not, generally, environmental attributes that are assigned administratively derived social costs. It is the categories that can be monetized – market-based costs identified – that can be relevant in comparisons with cost of service based utility rates. The Maine VOS study concluded that distributed solar facility output has a long-term levelized value of $0.337 per kWh over twenty-five years. 17 In terms of the first year values, for CMP’s territory, the report determined there to be societal benefits of $0.092 per kWh. The monetizable benefits, including avoided energy cost, avoided capacity costs, avoided reserves, and avoided transmission, were calculated to be only $0.09 per kWh. The Maine VOS study assumed a twenty-five year life of the technology and reflected projections over that twenty-five year period of avoided costs to analyze the value of solar. Costs and benefits over the period were levelized. In such a levelized This Act set forth guidance and a process by which a methodology was to be developed to value distributed solar energy generation. The Study was conducted by Clean Power Research in collaboration with a team that included Sustainable Energy Advantage, Pace Energy and Climate Center at the Pace Law School, and Dr. Richard Perez. Commission Inquiry into the Determination of the Value of Distributed Solar Energy Generation in the State of Maine, Docket No. 2014-00171, Final Value of Solar Study (Revised April 2015) (Apr. 15, 2015). 17 This rulemaking record identifies at least 13 different value studies conducted in 11 different states, commissioned by utilities, public utility commissions and other organizations. The reports range in findings from as high as 33 cents per kWh to 3 cents per kWh. The widely varying range can be attributed to differing assumptions including time horizons, levelized cost approach and benefits to be counted, and whether an avoided cost or a cost of service approach was taken. ORDER 9 Docket No. 2016-00222 cost analysis, current and future costs and benefits are reduced to a series of cash flows, discounted to the present. Such an analysis can inform long-term investment decisions, such as technology choices. For instance, one technology may have a low capital cost but a high operation and maintenance expense, while another technology might have a low operation and maintenance cost but a high initial capital cost. 18 In the utility regulatory context, such analyses are commonly used in evaluating utility capital investments and long-term contracts for energy supply. The results of this type of analysis, however, are of limited use in the design of a program like NEB that requires ratepayer-funded incentives. The avoided cost methodology is not helpful in cost of service ratemaking because it does not refer to the known specific costs of concern in designing rates. Ratepayer funded incentives are evaluated based on costs (similar to cost of service ratemaking), not a concept of “value.” 19 For example, when an efficiency program is designed for appliance rebates, the actual dollar rebate is based on a certain portion of the cost of the appliance, not on the “value” that the installation of the appliance may have for other customers or society in general. It is also important to emphasize that the actual costs and benefits of distributed resources, including solar PV, depends largely on the site specific, local characteristics of the electric grid and the concentration of distributed solar installations. For example, in states that have reached relatively high penetrations of distributed solar, reverse power flows actually result in net costs to the transmission and distribution system not savings. 20 Thus, the value of distributed generation is highly location dependent, a factor that was not examined in the Maine VOS. 21 3. Technology Costs 18 The VOS Study, in its application of levelized cost, adds an additional twist. It develops avoided costs in year one. The difficulty in avoided costs is much the same as the difficulty the Commission runs into in prudency disallowances. One has to assign a cost to a path not taken. This is further complicated by projecting these assumptions forward over a 25 year period. The output is a projection on what is avoided. 19 The same is true in competitive markets in which prices and incentives are generally based on the cost of the product or service, not the “value” to customers. 20 See Rich Seguin et al., High-Penetration PV Integration Handbook for Distribution Engineers, National Renewable Energy Laboratory (January 2016). 21 Maine does have a mechanism in which distributed generation is considered on a location specific basis to maximize ratepayer value by paying for distributed resources where it is needed. The Commission is required to consider non transmission alternatives whenever a T&D utility files for a certificate of public convenience and necessity to make a transmission investment. 35-A M.R.S. §§ 3132, 3132-A. ORDER 10 Docket No. 2016-00222 With respect to actual technology costs, there is no dispute that the costs of solar PV installations have decreased significantly in recent years and are expected to continue to decrease in the future. According to information provided by the U.S. Department of Energy (DOE), the installed cost of residential solar PV is currently in the range of $3/WattDC. 22, 23 Over the past five-to-six years, according to the DOE, the installed cost of residential solar PV has declined from about $5/WattDC to $3/WattDC. Over the next ten years, the installed cost of residential solar PV is projected to decline by about 40% relative to the current $3/WattDC level. Relative to the cost in 2010 of about $5/WattDC, the projected installed cost of solar PV in 2026 reflects a decrease of about 60%. 24 In addition to the DOE information, a diverse set of government and industry sources of information on installed costs project further cost reductions between now and 2025. 25 Although there is no certainty about the precise level and timing of these reductions in solar PV costs, there is no dispute that costs have and will continue to decrease. These cost trends indicate that incentives for solar PV should also decline over time, rather than increase over time as the retail cost of electricity services increases. It should be emphasized that the discussion of these cost trends is not meant to represent a comprehensive cost analysis or suggest that NEB compensation be based on a precise calculation of eligible technology costs. Instead, these cost trends are used in this rulemaking context to inform the Commission’s determination regarding amendments to the NEB rules. Finally, although these changes apply to all distributed 22 Photovoltaics, U.S. Department of Energy, http://energy.gov/eere/sunshot/photovoltaics (last visited Sept. 8, 2016). These costs do not reflect an additional reduction due to the federal Investment Tax Credit, which is currently 30%. 23 Unless otherwise noted, the costs provided by DOE are in 2014 dollars. 24 The predicted timelines for a 40% to 50% reduction from 2015 costs in the installed cost of rooftop PV range from three to ten years when looking over a diverse set of industry and government sources. For a range of predictions, see David Feldman et al., Photovoltaic System Pricing Trends, Historical, Recent, and Near-Term Projections, 2015 Edition, U.S. Department of Energy (Aug. 29, 2015); U.S. Energy Information Administration, Assumptions to the Annual Energy Outlook 2015 (2015); Vishal Shah, Solar: Grid Parity Beyond 2016?, Deutsche Bank (Dec. 2015); International Energy Agency, Technology Roadmap, Solar Photovoltaic Energy (2014). 25 See, e.g., id.; see also The Power to Change: Solar and Wind Cost Reduction Potential to 2025, International Renewable Energy Agency (June 2016) available at https://emp.lbl.gov/sites/all/files/pv_system_pricing_trends_presentation_0.pdf; The Future of Solar Energy, Massachusetts Institute of Technology (2015) available at http://energy.mit.edu/wp-content/uploads/2015/05/MITEI-The-Future-of-SolarEnergy.pdf. ORDER 11 Docket No. 2016-00222 technologies, solar predominates now and may continue to do so in the future. See Table 1 below. TABLE 1 26 C. Legal Authority CLF argues that the proposed amended rule is beyond the scope of 35-A M.R.S. § 3209-A, the statutory section regarding NEB rules, and is therefore beyond the Commission’s authority to implement. CLF argues that through Section 3209-A, the Legislature defined NEB to closely reflect definitions already in Commission rules and, because the structure of the proposed amended rule differs from the structure of the NEB rule at the time the statutory definition was enacted, the proposed amended rule is beyond the authority of the Commission to adopt. CLF’s interpretation of legislative intent into Section 3209-A is overly restrictive and beyond the plain meaning of that statute. Section 3209-A states: 26 Table 1 utilizes data provided by T&D utilities pursuant to their annual reporting obligations under the former NEB rule. ORDER 12 Docket No. 2016-00222 The commission may adopt or amend rules governing net energy billing. . . . “Net energy billing” means a billing and metering practice under which a customer is billed on the basis of net energy over the billing period taking into account accumulated unused kilowatt-hour credits from the previous billing period. Section 3209-A is a permissive grant of authority that, as CLF points out, codified the Commission’s long-term practice of allowing for NEB by rule. It did not, either explicitly or by implication, foreclose other rate structures or mechanisms applicable to ratepayers that install grid-connected energy generation facilities. Moreover, the amended rule is consistent with the Section 3209-A definition of net energy billing and maintains the basic structure in the current rule. The amended rule changes the inputs that go into the netting calculation, maintaining a net energy calculation to compute the NEB customer’s bill and to account for accumulated unused kilowatt-hour credits from the previous billing period. The statute does not specify that only imported and exported energy is netted, and to read in such language would be an overly restrictive interpretation of Section 3209-A. D. APA Procedures CLF argues that the Commission has violated two provisions of the Maine Administrative Procedures Act (APA). CLF’s arguments are supported by NRCM, Sunrun, IECG, and MABEP. The OPA and CMP submitted comments disputing CLF’s statutory arguments. First, CLF argues that the Commission’s finding that “the fiscal impact of the proposed amended rule is expected to be minimal” was insufficient to satisfy 5 M.R.S. § 8057-A, which requires a fact sheet accompanying a proposed amended rule that includes an estimate of the fiscal impact of the rule. CLF asserts that the Commission’s rulemaking could “profoundly alter” the solar industry and, therefore, its fiscal impact will be more significant than indicated by the Commission. However, contrary to CLF’s argument, the fiscal impact of a proposed rule is commonly understood to refer to the monetary impact on governmental entities. For example, 5 M.R.S. § 8063 defines fiscal impact as “the estimated cost to municipalities and counties for implementing or complying with the proposed rule.” The Commission has historically interpreted fiscal impact consistent with this definition and is unaware of an instance when this provision was applied to the economic impact on private industry. Accordingly, as the proposed amended rule change did not require the expenditure of public funds, the Commission’s statement that its fiscal impact would be minimal is accurate. Second, CLF also argues that the Commission has not prepared a small business economic impact statement as required by 5 M.R.S. § 8052(5-A). CLF asserts that the proposed amended rule would have “significant and severe impacts” on the solar industry, requiring an economic impact statement be prepared prior to the notice ORDER 13 Docket No. 2016-00222 of rulemaking, and that the notice of rulemaking should have indicated where it could have been obtained. The Commission’s violation of these provisions, according to CLF, renders the rule “void and of no legal effect,” in accordance with 5 M.R.S. § 8057(1). In its supplemental comments filed on November 1, 2016, CMP responded to CLF’s argument. CMP states that the small business economic impact statement is only applicable when the proposed rule actually regulates small businesses and that the Commission’s practice has been consistent with this interpretation. The OPA also suggests that CLF’s interpretation of subsection 8052(5-A) is not consistent with other provisions of the statute regarding reporting requirements and timelines. 27 The Commission concludes that the language of the statute clearly indicates that it is only applicable in instances when a rule would directly regulate a small business and, therefore, the mandates regarding reporting requirements and timetables are only relevant under a direct regulation of small businesses. In this case, the rule at issue only regulates the metering and billing activities of Maine’s T&D utilities, and does not regulate the solar industry. Therefore, small businesses are not subject to or regulated as part of this rulemaking and compliance with this rule requires no projected reporting, record-keeping, and other administrative costs from small businesses. IV. AMENDED RULE PROVISIONS A. Overview The amended rule maintains a netting approach contained in the current rule with altered inputs, but reduces by ten percent per year over a ten year period the portion of the output of the customer’s facility that is eligible to be netted (referred to in the rule as “nettable energy” ) against the customer’s T&D bill. For instance, a customer with an effective in-service date on their installation of January 1, 2018 would receive a credit for 90% of nettable energy on the T&D portion of their bill for fifteen years; a customer with an effective in-service date on their installation of January 1, 2019 would receive a credit for 80% of nettable energy on the T&D portion of their bill; and so on. Netting regarding the supply portion of the bill remains unchanged. Under the amended rule, the gradual reduction in nettable energy will begin for new NEB customers with facility in-service dates on January 1, 2018. In each successive year until December 31, 2026, a new customer will receive that year’s designated percentage for a fifteen year period. Existing net energy billing customers will be grandfathered for a fifteen year period. The OPA commented that the rulemaking approach appropriately recognizes that NEB is not a suitable long-term approach for promoting distributed generation and takes 27 Despite its interpretation of 5 M.R.S. § 8052(5-A), the OPA argues an economic impact analysis may be procedurally prudent and helpful to understand the ratepayer impact of the proposed amended rule. ORDER 14 Docket No. 2016-00222 an important first step in separating compensation paid to distributed energy resources (DER) from the retail rate and recognizing that compensation for new resources should be reduced over time as the costs for these resources decline. However, the OPA does not support the rulemaking approach and proposes instead that DER be compensated for net exported kWhs on an hourly basis at a set per-kWh rate that is reduced over time to the wholesale rate plus any monetizable ratepayer benefits. Similarly, the GEO opposes the basic approach of the rule in favor of a market-based approach, and states that if the Commission adopts its proposed rulemaking approach, the netting ramp down should be quicker to minimize the cost shift to other customers. CMP also advocates a market-based approach in place of what it considers an arbitrary ramp down approach. 28 CMP agrees that the pace of transition should recognize rapidly declining costs, but should be faster than in the proposed amended rule. Ms. Alexander also commented that the phase down should be shorter than ten years. Emera Maine generally agrees with the rule’s approach of gradually reducing T&D cross-subsidies. Mr. Brown generally agrees with the phase down as a means to reduce cross-subsidies, inefficiency and unfairness to competing resources. The NRCM, CLF, Revision and other commenters stated that the phase down specifics are arbitrary and that the proposed amended rule is complex, unworkable and costly. Revision commented that the Commission should look more broadly at distributed generation in general through proper rate structures using smart meter technology. As discussed in detail below, the Commission adopts the phase-down approach in the proposed amended rule. In recognition of the role of the Legislature to make broad energy policy decision, the Commission takes a narrow and tailored approach in this proceeding by maintaining the basic net billing mechanism and reducing over time the amount of generation that can be netted against the T&D bill. The Commission does not address issues that are properly in the purview of the Legislature regarding more fundamental changes to small renewable incentive programs, such as the proposal by the OPA, GEO and CMP for a utility long-term purchase and monetization approach. The Commission leaves open for future ratemaking proceedings issues of rate design changes that may provide other approaches to the cross-subsidy and incentive level issues addressed by the amended rule. The completion of CMP’s new billing system later this year will provide the necessary technology of a flexible billing software architecture coupled with the wide scale deployment of advanced metering infrastructure. This technology will enable the consideration of rate design mechanisms that lay the groundwork for equitable treatment of all customers and more granular application of cost causation principles in rate design. The Commission encourages parties to participate in a constructive manner in a future rate design case. 28 CMP and the GEO also both recommend that advanced metering infrastructure (AMI) be utilized to measure the hourly net output of the NEB facilities and to obtain the wholesale market value for these generators. ORDER 15 Docket No. 2016-00222 While the GEO, OPA, and CMP advocate for some form of hourly netting with excess energy sold onto the market, this approach does not account for ongoing use of grid services by NEB customers. There would still exist a significant transfer payment due to the nature of the volumetric charge used to recover T&D costs and the fact that this approach does not account for behind the meter consumption. Existing metering data does not capture this clearly nor allow for precise modeling of its growth trajectory. Incorporating this approach in the rule at this time may result in significant transfer payments between customers going forward. The Commission also acknowledges that approaches like these espoused by the GEO, OPA, and CMP may be preferable once the AMI system has been fully deployed and more data has been gathered pursuant to this amended rule. In response to comments regarding the specific phase down of T&D netting, the approach contained in the amended rule is not arbitrary, as some commenters have asserted. As discussed above, the phase down approach reflected in the amended rule is intended to maintain a return on investment by reducing over time the incentives to NEB customers in recognition of expected ongoing technology cost declines for small renewable installations. Moreover, the fifteen year grandfathering period for existing NEB customers would likely extend current net billing past the breakeven point of capital investment that has been made prior to the rule amendments. 29 In particular, with the installed cost of solar facilities in 2012 at approximately $5.25 per Watt for an average installation size and with the inclusion of the federal tax credit of 30%, under the current rule the simple payback period would be about 21.5 years. For year 2014, with installed costs dropping to about $4.27 for the same average customer, all other assumptions being equal, and the federal tax credit remaining in place, the payback under the current rule would be about 17.4 years. For year 2028 when the T&D phase down is complete, with installation costs having fallen to $2 per Watt for the same average customer and with no federal tax credit, the payback period is approximately twenty-three years. If the tax credit remains at 30%, the payback period is sixteen years, with a range between sixteen and twenty-three years depending on how the federal tax incentive was modified. B. Nettable Energy (section 3(E) and (F)) i. Netting Mechanism The gradual phase-down of the incentive to NEB customers is accomplished in the amended rule (section 3(E) and (F)) through gradual reductions to “nettable energy.” Nettable Energy is defined in the amended rule (section 2(L)) as: 29 As discussed in section IV(D) below, the amended rule contains a new provision that will allow for “REC aggregation.” This provision will allow future NEB customers to participate in the REC market. ORDER 16 Docket No. 2016-00222 the energy in kilowatt-hours generated by an eligible facility that may be netted against a customer’s kilowatt-hour consumption . . . . As reflected in the amended rule, the inputs to nettable energy have changed from the existing rule. Nettable energy is now the entire amount of energy generated by the facility, including the amount consumed by a customer “behind-the-meter”. Hence, the amended rule nets on a gross basis rather than a net basis. In recognition of the cost declines described above, under the amended rule the nettable energy applicable to the T&D portion of a customer’s bill is reduced over time, while the nettable energy for the supply portion of the bill is unchanged. The amended rule specifies that, for customers that become NEB customers over the next ten years, the “nettable” kWh applicable to the T&D bill would decline for newly installed facilities by ten percentage points each year such that for customers that become new NEB customers after the year 2026, there would be no netting on the T&D portion of the bill. Specifically, for customers that become NEB customers in 2018, 90% of the kWhs would be nettable against the T&D bill, for customers that become NEB customer in 2022, 50% of the kWhs would be nettable, and so on until, for new customers after the year 2026, the T&D component of the bill is no longer netted. Assuming a T&D component that is approximately one-half of the customer’s total electricity bill, for new customers after the year 2026, the approach in the amended rule would result in a reduction in the value of NEB credits equal to about half of that that would be provided under the current rule. As noted above, this end-state would be achieved gradually over the next ten years and NEB customers would receive the nettable energy percentage applicable in the year in which they first became NEB customers for a period of fifteen years. 30 Section 3(H) of the amended rule specifies that the facility’s inservice date determines the applicable year for netting purposes. This approach phases out the shifting of T&D costs from NEB customers to nonNEB customers that is inherent in the current rule. With respect to the supply bill, under the current market settlement rules, any netted kWhs are treated as a reduction to the supplier’s load obligations such that little or no cost is shifted to other customers as a result of the netting. For this reason, the amended rule achieves all of the reductions to “nettable” kWh on the T&D bill. Under the amended rule, the value to NEB customers on their supply bill tracks retail supply costs, such as for standard offer service, rather than a value based on wholesale market prices. From an economic standpoint, the use of a wholesale rate would be the preferable approach in that NEB customers are providing a wholesale energy product. However, netting of the retail standard offer rate (or a CEP retail rate if customer is taking competitive service), which is a bundled product at an annual fixed 30 As specified in section 3(G) of the amended rule, a customer continues netting on the specified percentage until December 31st of the fifteenth year. ORDER 17 Docket No. 2016-00222 rate, 31 provides price certainty. Netting of the retail standard offer rate also provides a reference to competitive electricity markets in that standard offer rates are established annually though a competitive bid process. As noted above, the amended rule uses a “gross” approach to determine nettable energy. This approach requires the total energy produced and the total energy consumed during a billing period be determined. This is in contrast to the approach in the current rule in which both energy produced and energy used are measured on a “net” basis (e.g., generated energy offsets simultaneous load) and any excess is “netted” against current and future bills. Thus, the approach in the amended rule accomplishes the goals of: (1) reducing the NEB incentive to track reductions in technology costs in a manner that maintains comparable payback periods for NEB customers; and (2) reducing, and ultimately eliminating, the shifting of T&D costs from NEB to non-NEB customers. ii. Treatment of Self-Generation Several parties opposed the gross netting approach in the proposed amended rule as a violation of a customer’s ability or right to self-generate (i.e., use generation behind a customer’s meter to serve its own load). The IECG strongly supports customers’ “right” to self-generate and views the gross netting approach as a violation of this principle. NRCM, MABEP, MCSFA, Sunrun, Maine Audubon, ACTT, the Nature Conservancy and Mr. Grassi commented that NEB customers should not be charged when self-generating and, by assertion, not using the system, and generally argued that gross netting is unfair, unworkable, and violates the exit fee statute or is otherwise illegal. The OPA points out that NEB is optional and the GEO argues that selfgeneration is allowed and the superior approach is to net on an hourly basis. The GEO’s position of hourly netting does not address the so called “lost T&D revenue” issue. Such an approach will result in a reduction of volumetric T&D rates due to the behind the meter aspect of the generation. This perpetuates the shift of T&D utility revenue responsibility from NEB customers to non-NEB customers with corresponding impacts on the rates of non-NEB customers. The Commission’s gross approach as reflected in the amended rule addresses this issue. NEB is a program offered under Commission rules as permitted by statute. It is not a required program, but an option provided for customers. The Commission concludes that the gross approach in the amended rule is not a violation of the exit fee 31 The standard offer rate is the price for a bundled product that includes not just energy but also ancillary services, voltage control, frequency control, reserves, capacity, bad debt, and likely some type of risk premium incorporated by the supplier to cover its forward load obligation. This approach may need to be revisited if the components of standard offer shift in such a way that capacity services become a more significant component of the bundled price. ORDER 18 Docket No. 2016-00222 statute or otherwise unlawful and does not impinge in any way on a customer’s “right” or ability to self-generate. First, the exit fee statute (35A M.R.S. § 3209(3)) prohibits utility charges or fees for exit or reentry for the reduction or elimination of consumption or reestablishment of service with a T&D utility. The establishment of or change to the NEB rules is in no sense an “exit” fee in that the customer is not being charged a fee to compensate the utility for lost consumption. Second, and most importantly, NEB is a voluntary incentive program and in no way mandates customer participation. Thus, the existence of the rule does not in any way alter a customer’s ability to self-generate and use its generation to offset load in real time. 32 As discussed in Section IV(E) below, the purpose of the NEB rule is to provide for an incentive for the adoption of distributed generation that is generally matched to a consumer’s consumption. Notably, customers who wish to self-generate do not have to participate in the optional NEB program. Some customers (if their generating facility is 5 MW or less), may find it more advantageous to use the provisions of Chapter 315 (Small Generator Aggregation) of the Commission rules. Under Chapter 315, customers can self-generate and export any excess generation to the grid. The rule requires the standard offer provider to purchase the excess generation and settle it in the real-time wholesale electricity market on behalf of the generator. The customer receives payment for that excess generation at the wholesale price for the hour in which the energy was generated. C. Grandfathering (section 3(E)) Section 3(E) of the amended rule specifies that existing NEB customers will continue to net bill under the current rule’s approach for a fifteen year period. As discussed above, this fifteen year grandfathering period for existing NEB customers addresses the likely breakeven point of capital investments made by existing NEB customers prior to the rule amendments. After this fifteen year period, customers would continue to net the full output of their facility against the supply portion of their bills. The IECG recommends that the period be changed to twenty years to more closely match the likely term of financing periods. NRCM also requests that this period be extended, and argues that the term should be beyond what is necessary to reach the payback period to allow NEB customers to receive a return on their investment. NRCM also questions the fairness of a single time period that is applied to all existing NEB customers. The Maine Association of Building Efficiency Professionals also contends that fifteen years is too short, as it does not align with the twenty-five to thirty year 32 Likewise, the amended rule does not conflict with 35-A M.R.S. § 3305(2), as suggested by the OPA. Section 3305(2) forbids the Commission from imposing approval or regulation requirements on a small power producer’s or cogenerator’s ability to self-generate. NEB is a voluntary incentive program and under the amended rule these individuals remain free to self-generate without participating in the NEB program. ORDER 19 Docket No. 2016-00222 service life of many NEB facilities and would result in a tangible loss for a number of existing NEB customers. Sunrun recommends that the grandfathering period be set at the average useful life of the NEB facilities out of basic fairness towards NEB customers who relied on the status quo in making long-term financial decisions. CMP generally supports a limited grandfathering period which considers the declining costs of NEB facilities and extends the break-even point for existing customers. CMP considers such a period to be ten to fifteen years. The GEO suggests a time period of three to ten years and notes that the Legislature limited contract lengths between T&D utilities and NEB customers to ten years through An Act to Expand Net Energy Billing, P.L. 2011, ch. 262. Further, the GEO asserts that the Legislature chose this time period as appropriate for NEB customers to recover their costs, and these costs have been in decline since that time. Although Commission rules and utility programs can be expected to change over time, the Commission recognizes that customers may expect, or have been told to expect, certain paybacks when they make an investment. The Commission concludes that a grandfathering provision at fifteen years strikes an appropriate balance. Based on the current capital costs of installation, the payback period is approximately equal to the fifteen year period. While some customers may have made a decision based on the assumption that the current program would stay into perpetuity, the current NEB rule allows for contracts of up to ten years and NEB contracts are explicitly subject to regulatory changes. Accordingly, it is reasonable to grandfather existing customers for fifteen years. D. REC Aggregation (Section 4) The amended rule contains a new provision for renewable energy credits (REC) aggregation. Section 4 states that new NEB customers with an in-service date on or after January 1, 2018 may elect to have the RECs associated with their eligible NEB facility aggregated by the T&D utility and sold into the regional market with proceeds from such sales returned to the participating NEB customers. Consumer-owned utilities (COUs) may, but are not required to, offer a REC aggregation program. 33 In the NOR, the Commission requested comments on how to aggregate and monetize RECs associated with NEB facilities. The Commission received several comments. The GEO recommends that the T&D utilities aggregate and sell RECs into the regional market, using the resulting revenue to offset lost T&D revenue. The OPA similarly suggests that the Commission retain rights to the environmental attributes of facilities participating in NEB (along with associated energy and capacity) and use the revenue from the sale of the aggregated RECs to offset any existing subsidy. If customers retain ownership of the environmental attributes, however, the OPA recommends that NEB facilities automatically receive ME Class I REC certification and that T&D utilities report on behalf of NEB customers their hourly export data to a 33 As a general matter, COUs have not been required to implement changes or expansions to NEB. See Sections 3(B)(6) and 3(C) of the former Chapter 313. ORDER 20 Docket No. 2016-00222 designated NEPOOL-GIS account. The OPA also suggests designating a buyer to offer to purchase a customer’s RECs at a default rate. CMP also recommends that RECs be aggregated and sold to a single market buyer. Emera supports efforts to monetize RECs and suggests a working group to examine REC aggregation and evaluate the benefits against the costs of administration. The decision to include a REC aggregation provision in the amended rule is an effort to obtain on an optional basis a value stream that is not currently being monetized. Because the details of such an aggregation program require further review, the amended rule requires that the T&D utilities file proposed terms and conditions, including expected administrative costs, which would be subject to further process. For purposes of administrative ease, the amended rule provides that NEB facilities participating in the REC aggregation program will be automatically certified as a Class I resource 34 and the T&D utilities will be required to retire RECs in an amount such that the customer’s usage meets Maine’s new renewable resource portfolio requirement. 35 Under the amended rule, this REC aggregation option is available to new customers on or after January 1, 2018. This will provide an optional revenue stream for new customers that could allow new customer payback period to be kept in line with the payback period for existing customers, given the scheduled reductions in the federal ITC. E. NEB Size and Structure Expansions The proposed amended rule included expansions to NEB in Maine in several respects. First, the proposed amended rule would have increased the size cap for an 34 Chapter 311, section 3(B)(4) of the Commission’s rules establishes a Maine Class I REC certification process that requires generators to pre-certify facilities as a new renewable resource under the requirements of the rule and provides for a Commission determination of resource eligibility on a case-by-case basis. The rule also contains the information that must be included in a petition for certification. The amended NEB rule allows RPS eligible NEB facilities to avoid this process and receive automatic certification. 35 Although the Commission has historically permitted REC certification of behind-the-meter generation, these generators have been required to retain or obtain certificates necessary to satisfy Maine’s RPS for that portion of their load that is served by the facility. See Lincoln Paper and Tissue, LLC, Request for Certification for RPS Eligibility, Docket No. 2008-173, Order Granting New Renewable Resource Certification at 8 (Jan. 27, 2009). Under current law, this would equate to ten percent of the NEB facility’s generation that is consumed behind-the-meter for Class I RECs and thirty percent for Class II RECs. The logic for this requirement is that behind-the-meter generation is serving the load of customers that would otherwise have been served by a CEP or standard offer provider to which the RPS requirement applies. It is therefore consistent to require this behind-the-meter consumption to adhere to Maine’s RPS requirements. ORDER 21 Docket No. 2016-00222 eligible facility from 660 kilowatts to one megawatt. Second, the proposed amended rule explicitly allowed for “community” NEB. Third, the proposed amended rule would have eliminated the number of meters limitation in the current rule. Fourth, the proposed amended rule contained specific provisions regarding “NEB leases,” including customer protection provisions. A number of commenters supported these proposed provisions, while others expressed concern about increasing the facility limit to one megawatt and allowing for community solar and larger scale joint ownership projects which are not behind the meter and for which economies of scale reduce the need for a subsidy compared to residential rooftop installations. Specifically, NRCM, SEAM, Maine Audubon, the Nature Conservancy and CEC supported the community and shared ownership provisions and the removal of the limit on the number of meters. The GEO commented that new, larger projects should not be eligible for NEB because the NEB incentive is not necessary for these projects and adopting NEB expansion provisions would increase costs to other customers by expanding the number of NEB customers and NEB eligible facilities. CMP expressed concern with the proposed expansion of NEB, noting that community solar and larger scale joint ownership projects are not behind the meter and therefore use the T&D system for all customer usage. With respect to the removal of the limit on the number of accounts or meters permissible under a single NEB billing arrangement, CMP commented that such an expansion would negatively affect its billing system performance and recommended a cap of 200 customers. Emera similarly suggested that expanding the cap on eligible customers allowed for an NEB arrangement that will increase its administrative costs. The GEO argued that the final rule should retain the ten customer cap rule until a full market compensation approach for NEB facilities is adopted. For the following reasons, the amended rule does not include these provisions. First, as discussed in section III(B) above, the Commission focuses this rulemaking on addressing technology cost decreases and reducing cost-shifting and to do so in a manner that maintains the current NEB structure consistent with statute. Fundamental changes to NEB in Maine and promotional programs for larger renewable and community solar projects are the purview of the Legislature as a matter of State energy policy. Second, the purpose of NEB, as has consistently been articulated by the Commission, 36 is to incentivize the installation of small renewable systems used primarily to provide a customer’s own electricity needs. The expansion of NEB to larger projects and community solar, which would not be behind the customers’ meters, may be inconsistent with this articulated purpose. Third, it is recognized that there are economies of scale for larger projects and, accordingly, such projects do not need the same subsidy as smaller projects, such as residential roof-top installations. 36 See, e.g., Re Customer Net Energy Billing (Chapter 313), Docket No. 98-621, Order Adopting Rule and Statement of Factual and Policy Analysis at 3 (Dec. 10, 1998). ORDER 22 Docket No. 2016-00222 The Commission notes that the NEB rule will continue to allow for facility leasing consistent with precedent. The Commission has authorized leases consistent with the standard that the lease arrangement be “akin to ownership.”37 See Central Maine Power Company, Request for Review of Notice of Eligibility for Net Energy Billing Arrangement, Docket No. 2014-00114, Order (June 23, 2014); see also Union Atlantic Electricity & Union Atlantic Hydro, LLC, Petition for Advisory Ruling Regarding Interpretation of Chapter 313, Docket No. 2012-00466, Advisory Ruling (Jan. 31, 2013). F. Effective Date (section 3(H)) CMP requested that the final rule clarify how utilities are to determine which calendar year applies to each system, for example, by application date, contract execution date, interconnection date, or in-service date, and how to address existing NEB customers that request additional accounts. The amended rule contains a provision (section 3(H)) that specifies that the effective date to determine the applicable calendar year pursuant to section 3(F) is the in-service date of the facility. The timing of the other potential approaches suggested by CMP can vary to a large degree among new NEB customers. Thus, to treat potential NEB customers similarly, the more meaningful in-service date is appropriate for this purpose. G. Billing Requirements (section 3(I)) CMP stated that, as structured, the proposed amended rule would create a number of different rates for NEB customers over time, which will have to be accounted for in the utility’s billing system. CMP also suggested that the final rule allow T&D utilities to require uniform billing cycles for all types of arrangements where there are multiple accounts receiving credits from a single facility. The amended rule may result in added complexity regarding utility billing and metering practices, but the additional administrative complexity should be manageable for the utilities. However, CMP’s request regarding uniform billing cycles is a reasonable approach to mitigate the utility’s incremental administrative obligations associated with NEB and has therefore been included in the amended rule. H. 37 Competitive Electricity Providers (section 3(J)) While some ambiguity exists under current precedent, simply allowing all leases has the potential to create significant consumer protection concerns. Leases in many ways as practiced in other states are more akin to power purchase agreements than they are ownership. This raises the question of whether such arrangements would be more appropriately viewed as retail sale involving a competitive electricity provider. ORDER 23 Docket No. 2016-00222 CMP recommends that the language of section 5(G) of the proposed amended rule be modified to be consistent with current NEB billing practices for CEPs. Currently, CEPs are required to bill the NEB customers they enroll on a net basis, but the proposed amended rule stated that CEPs may, but are not required to, bill on a net basis. CMP asserts that if CEPs are allowed to enroll NEB customers, but do not bill those customers on a net basis, then CMP will have to make a number of system modifications to account for the resulting mismatch in the amount of usage metered by CMP and the amount of usage to be billed by the supplier. The Commission agrees with CMP in this regard and the amended rule requires that CEPs, if they enroll NEB customers, must bill on a net basis. I. Additional Meters and Equipment (section 3(L)) As noted above, the amended rule will require the output of the facility and the customer usage to be measured on a gross basis. To the extent this requires additional metering relative to the current rule, the additional costs may not be charged to the NEB customer unless allowed by Commission Order. J. Consumer-Owned Utility Exemptions (sections 3(B)(6) and 4(E)) Sections 3(B)(6) and 4(E) of the amended rule contain certain exemptions for consumer-owned utilities (COUs). The existing rule explicitly exempts COUs from the shared ownership requirements of the rule. This was done in recognition of potential COU administrative difficulties and expense in providing for shared ownership NEB. For a similar reason, the amended rule explicitly exempts COUs from the REC aggregation requirements of the rule. K. Reporting and Commission Review (section 5) The amended rule re-sets the Commission review trigger at 3% of peak demand, rather than 4% of peak demand included in the proposed rule. In addition, the amended rule contains a biannual utility reporting requirement. This will allow the Commission to actively monitor developments, including whether installations are declining, increasing or holding steady, and consider whether rule changes may be warranted. Accordingly, the Commission O R D E RS 1. That the amendments to Chapter 313, Customer Net Energy Billing, are hereby adopted: 2. That the Administrative Director shall file the adopted rule and related materials with the Secretary of State; ORDER 24 Docket No. 2016-00222 3. That the Administrative Director shall notify the following of the adoption of the amended rules: a. all transmission and distribution utilities in the State; b. all person who filed comments in the inquiry, Maine Public Utilities Commission, Commission Initiated Inquiry into Net Energy Billing Rules (Chapter 313), Docket No. 2016-00120; c. all persons who have commented in this rulemaking proceeding, Docket No. 2016-00222; and d. all persons who have filed with the Commission within the past year a written request for notice of rulemakings; 4. That the Administrative Director shall send copies of this Order and attached amended rule to the Executive Director of the Legislative Council, 115 State House Station, Augusta, Maine 04333-0115. Dated at Hallowell, Maine, this 1st day of March, 2017. BY ORDER OF THE COMMISSION /s/ Harry Lanphear __________________________ Harry Lanphear Administrative Director COMMISSIONERS VOTING FOR: Vannoy McLean Williamson ORDER 25 Docket No. 2016-00222 NOTICE OF RIGHTS TO REVIEW OR APPEAL 5 M.R.S. § 9061 requires the Public Utilities Commission to give each party to an adjudicatory proceeding written notice of the party's rights to review or appeal of its decision made at the conclusion of the adjudicatory proceeding. The methods of review or appeal of PUC decisions at the conclusion of an adjudicatory proceeding are as follows: 1. Reconsideration of the Commission's Order may be requested under Section 11(D) of the Commission's Rules of Practice and Procedure (65-407 C.M.R. 110) within 20 days of the date of the Order by filing a petition with the Commission stating the grounds upon which reconsideration is sought. Any petition not granted within 20 days from the date of filing is denied. 2. Appeal of a final decision of the Commission may be taken to the Law Court by filing, within 21 days of the date of the Order, a Notice of Appeal with the Administrative Director of the Commission, pursuant to 35-A M.R.S. § 1320(1)(4) and the Maine Rules of Appellate Procedure. 3. Additional court review of constitutional issues or issues involving the justness or reasonableness of rates may be had by the filing of an appeal with the Law Court, pursuant to 35-A M.R.S. § 1320(5). Note: The attachment of this Notice to a document does not indicate the Commission's view that the particular document may be subject to review or appeal. Similarly, the failure of the Commission to attach a copy of this Notice to a document does not indicate the Commission's view that the document is not subject to review or appeal. 65-407 PUBLIC UTILITIES COMMISSION Chapter 313: CUSTOMER NET ENERGY BILLING SUMMARY: This rule establishes the requirements and terms for net energy billing. TABLE OF CONTENTS §1 PURPOSE ....................................................................................................................................... 3 §2 DEFINITIONS ............................................................................................................................... 3 §3 NET ENERGY BILLING REQUIREMENTS AND PROCESSES ......................................... 5 A. Customer Qualification ....................................................................................................... 5 B. Shared Ownership Customers Qualification ...................................................................... 5 1. Ownership Interest ................................................................................................. 5 2. Contact Person ....................................................................................................... 5 3. Competitive Electricity Provider ........................................................................... 5 4. Application ............................................................................................................ 5 5. Eligibility Dispute.................................................................................................. 6 6. Consumer-owned Utility Exemption ..................................................................... 6 C. Eligible Facilities ................................................................................................................ 6 D. Service Territory ................................................................................................................. 6 E. Nettable Energy for Customers that are Existing Customers as of December 31, 2017 .... 6 F. Nettable Energy for Customers that are New Net Energy Billing Customers After December 31, 2017 ............................................................................................................. 6 1. Supply Bill ............................................................................................................. 6 2. T&D Bill ................................................................................................................ 6 G. Term ............................................................................................................................... 7 H. Effective Date ..................................................................................................................... 7 65-407 Chapter 313 I. §4 §5 §6 page 2 Billing Requirements .......................................................................................................... 7 1. Excess Generation ................................................................................................. 7 2. Excess Usage ......................................................................................................... 7 3. Unused Credits ...................................................................................................... 8 4. Non-usage Charges ................................................................................................ 8 5. Shared Ownership Billing ..................................................................................... 8 6. Limit on Accounts ................................................................................................. 8 J. Competitive Electricity Provider Billing ............................................................................ 8 K. Standard Offer Provider Service ......................................................................................... 8 L. Additional Meters and Equipment ...................................................................................... 8 M. Interconnection Requirements ............................................................................................ 8 N. Standard Contract and Application..................................................................................... 9 RENEWABLE ENERGY CREDIT (REC) AGGREGATION OPTION ................................ 9 A. New Renewable Resource Certification ............................................................................. 9 B. Option ............................................................................................................................... 9 C. GIS Certificates .................................................................................................................. 9 D. Terms and Conditions ......................................................................................................... 9 E. Administrative Costs .......................................................................................................... 9 F. Consumer-owned Utility Exemption .................................................................................. 9 REPORTING AND COMMISSION REVIEW ........................................................................ 10 A. Commission Review ......................................................................................................... 10 B. Biannual Report ................................................................................................................ 10 WAIVER OR EXEMPTION ...................................................................................................... 10 65-407 Chapter 313 §1 page 3 PURPOSE The purpose of this Chapter is to implement the State's policy to encourage electricity generation from renewable resources through the adoption of requirements and standards for customer net energy billing. §2 DEFINITIONS A. Competitive Electricity Provider. "Competitive electricity provider" means a marketer, broker, aggregator, or any other entity selling electricity to the public at retail in Maine. B. Consumer-owned Transmission and Distribution Utility. “Consumer-owned transmission and distribution utility” has the same meaning as specified in Title 35-A M.R.S.A. §3201(6). C. Customer. “Customer” means a person or an entity that takes electricity service through a transmission and distribution utility. D. Customer Usage Behind the Meter. “Customer usage behind the meter” means a customer’s kWh usage in any billing period that is met or offset by energy from the customer’s eligible facility. E. Eligible Customer. “Eligible customer” means a customer that is eligible for net energy billing under this Chapter. F. Eligible Facility. “Eligible facility” means an electric generating facility that uses a renewable fuel or technology as specified in 35-A M.R.S.A. §3210(2)(C) or is a microcombined heat and power system. G. Gross Output. “Gross output” means all of the energy generated by an eligible facility during an applicable period, including all energy that is used to offset the usage of eligible customers. H. GIS Certificates. “GIS certificates” means certificates created pursuant to the NEPOOL Generation Information System that represent attributes of electric power and that may be traded separately from the energy commodity. I. Micro-Combined Heat and Power System. “Micro-Combined Heat and Power System” means a system that: 1. Produces heat and electricity from one fuel input, without restriction to specific fuel or generating technology; 2. Has an electric generating capacity rating of at least one kilowatt and not more than 30 kilowatts and a fuel system efficiency of not less than 80% in the production of heat and electricity or has an electric generating capacity of at least 31 kilowatts and not more than 660 kilowatts and a fuel system efficiency of not less than 65% in the production of heat and electricity; 65-407 Chapter 313 page 4 3. May work in combination with supplemental or parallel conventional heating systems; 4. Is manufactured, installed and operated in accordance with applicable government and industry standards; and 5. Is connected to the electric grid and operated in conjunction with the facilities of a transmission and distribution utility. J. Net Energy. "Net energy" means the difference between (i) the kilowatt-hours consumed by a customer or shared ownership customer over a billing period and (ii) the customer’s nettable energy. K. Net Energy Billing. "Net energy billing" means a billing and metering practice under which eligible customers are billed on the basis of net energy. L. Nettable Energy. “Nettable energy” means the energy in kilowatt-hours generated by an eligible facility that may be netted against a customer’s kilowatt-hour consumption in accordance with this Rule. M. Ownership Interest. “Ownership interest” means a legally enforceable ownership interest or legally enforceable rights and obligations in an eligible facility. N. Renewable Energy Credits (RECs). “RECs” has the same meaning as defined in statute at 35-A §3210-C (1)(E). O. Shared Ownership Customers. “Shared ownership customers” mean customers that have a shared ownership interest in an eligible facility. P. Shared Ownership Interest. “Shared ownership interest” means a legally enforceable ownership interest in, or legally enforceable rights and obligations for, an eligible facility by which a shared ownership customer has the rights to a portion of the output, and the obligation for a portion of the costs, of a shared ownership facility. A shared ownership interest must be sized to represent a least one kilowatt of the capacity of the shared ownership facility. Q. Shared Ownership Facility. “Shared ownership facility” means an eligible facility in which more than one customer has a shared ownership interest. R. Standard Offer Provider. "Standard offer provider" means a provider of standard offer service chosen pursuant to Chapter 301 of the Commission's rules. S. Supply Bill. “Supply bill” means an eligible customer’s bill, over a billing period, for standard offer or competitive electricity provider supply service. T. T&D Bill. “T&D bill means an eligible customer’s bill, over a billing period, for transmission and distribution utility service. 65-407 Chapter 313 U. §3 page 5 Transmission and Distribution Utility. "Transmission and distribution utility" has the same meaning as specified in Title 35-A M.R.S.A. §102(20-B). NET ENERGY BILLING REQUIREMENTS AND PROCESSES A. Customer Qualification. Any eligible customer may elect net energy billing for the customer’s accounts or meters within the transmission and distribution utility’s service territory. B. Shared Ownership Customers Qualification. Shared ownership customers may elect net energy billing pursuant to the requirements of this subsection. 1. Ownership Interest. Shared ownership customers must have a legally enforceable ownership interest or legally enforceable rights and obligations in the eligible facility under which the customers have joint responsibility for the costs of the shared ownership facility and have the rights to the benefits of the output of the shared ownership facility in proportion to the cost responsibilities. 2. Contact Person. Shared ownership customers must designate a single contact person to be responsible for all communications with the transmission and distribution utility regarding the shared ownership net energy billing arrangement. The contact person shall promptly inform the transmission and distribution utility of any material changes to the joint ownership interests or arrangements of the shared ownership customers, including any changes in the meters or accounts subject to net energy billing. 3. Competitive Electricity Provider. A participant in a shared ownership net energy billing arrangement pursuant to this section shall not be considered a competitive electricity provider under Title 35-A, chapter 32. 4. Application. Shared ownership customers must submit to the transmission and distribution utility an application for a net energy billing arrangement that contains the information specified in this subsection and other information that the transmission and distribution may reasonably require. a. Customer identities. A list of the names, addresses, telephone numbers and account numbers of each of the shared ownership customers. b. Ownership interest. Documentation that the shared ownership customers have a valid ownership interest in the shared ownership facility as required by this section, including the proportional ownership of each shared ownership customer. c. Contact person. The name, mailing address, telephone number, and email address of the shared ownership customers’ contact person. d. Accounts. A designation of the accounts or meters that will be subject to the shared ownership net energy billing arrangement. 65-407 Chapter 313 e. page 6 Facility. A description of the shared ownership facility, including the facility’s location, capacity, and fuel type or generating technology. 5. Eligibility Dispute. A transmission and distribution utility may dispute the customers’ eligibility for shared ownership net energy billing arrangement under this section by filing a Notice of Dispute with the Commission. The transmission and distribution utility must file a Notice of Dispute within 21 days of the submission of an application for a shared ownership net energy billing arrangement. 6. Consumer-owned Utility Exemption. Consumer-owned transmission and distribution utilities are not required to provide shared ownership net energy billing arrangements pursuant to this section. Consumer-owned transmission and distribution utilities may elect to provide shared ownership net energy billing arrangements in accordance with this section. C. Eligible Facilities. An eligible facility located in a service territory of an investor-owned transmission and distribution utility must have an installed capacity of 660 kW or less. An eligible facility located in a service territory of a consumer-owned transmission and distribution utility must have an installed capacity of 100 kW or less unless the consumer-owned transmission and distribution utility elects to allow facilities with an installed capacity of up to 660 kW. An eligible facility must be used primarily to offset the customer’s, or shared ownership customers’, own electricity requirements. D. Service Territory. The eligible facility and the customer and shared ownership customer accounts subject to net energy billing must be located within a service territory of the same transmission and distribution utility. E. Nettable Energy for Customers that are Existing Customers as of December 31, 2017. One hundred percent of the gross output of an eligible facility is nettable energy for customers with a net energy customer effective date on or before December 31, 2017, and will remain at this level through December 31, 2032. After December 31, 2032, nettable energy is (i) one hundred percent of the gross output for determining net energy for the customer’s supply bill and (ii) zero percent of the gross output for determining net energy for the customer’s T&D bill. F. Nettable Energy for Customers that are New Net Energy Billing Customers After December 31, 2017. For customers with a net energy customer effective date after December 31, 2017, nettable energy will be determined as set forth below: 1. Supply Bill. For the purpose of determining net energy for the supply bill, nettable energy is one hundred percent of the gross output of an eligible facility. 2. T&D Bill. For the purpose of determining net energy for the T&D bill, nettable energy is the portion of the gross output of an eligible facility set forth in the table below: 65-407 Chapter 313 Perc ent of Output that is Nettable T&D Bill Nettable Energy page 7 Applic able Through Dec ember 31 of Year Show n For existing NEB Customers as of December 31, 2017 100% 2032 For customers that become NEB Customers during calendar year 2018 90% 2033 For customers that become NEB Customers during calendar year 2019 80% 2034 For customers that become NEB Customers during calendar year 2020 70% 2035 For customers that become NEB Customers during calendar year 2021 60% 2036 For customers that become NEB Customers during calendar year 2022 50% 2037 For customers that become NEB Customers during calendar year 2023 40% 2038 For customers that become NEB Customers during calendar year 2024 30% 2039 For customers that become NEB Customers during calendar year 2025 20% 2040 For customers that become NEB Customers during calendar year 2026 10% 2041 For customers that become NEB Customers after calendar year 2026 0% NA G. Term. The applicable nettable energy percentages set forth above shall apply for the period beginning on the customer’s net energy customer effective date and ending on December 31 of the year indicated. After this period, nettable energy is (i) one hundred percent of the gross output for determining net energy for the customer’s supply bill and (ii) zero percent of the gross output for determining net energy for the customer’s T&D bill. H. Effective Date. The effective date applicable to a customer or shared ownership customer shall be the date that the customer’s eligible facility is placed in service. I. Billing Requirements. For eligible customers that have elected net energy billing, transmission and distribution utilities must bill on the basis of net energy in accordance with the following provisions: 1. Excess Nettable Energy. If the nettable energy generated during the billing period by the eligible facility plus any kilowatt-hour credits from prior billing periods exceeds a customer's or the shared ownership customer’s kilowatt-hour usage during the billing period, the customer shall be billed on the basis of net energy kilowatt-hours equal to zero, and the excess nettable energy shall be applied to the customer's or the shared ownership customer’s bill for the following billing period to determine net energy for that billing period, subject to the 12-month period set forth in subparagraph 3.. 2. Excess Usage. If a customer's or shared ownership customer’s kilowatt-hour usage exceeds the sum of (i) nettable energy generated by the eligible facility during the billing period and (ii) any excess nettable energy pursuant to subparagraph 1, the customer or the shared ownership customers shall be billed 65-407 Chapter 313 page 8 on the basis of net energy at the applicable retail rates for electricity supply and T&D service. 3. Unused Credits. A customer or shared ownership customers may accumulate unused nettable energy kilowatt-hours and apply them against kilowatt-hour usage within a given 12-month period. At the end of each 12-month period, any accumulated unused nettable energy shall be eliminated and may not be applied against any future usage by the customer or shared ownership customers. The customer or the shared ownership customers will receive no compensation for unused nettable energy. 4. Non-usage Charges. Net energy billing only applies to kilowatt-hour usage charges. Net energy billing customers or the shared ownership customers are responsible for all other charges applicable to the customer's T&D rate class or supply service and recovered either through fixed amounts or over units other than kilowatt-hours. 5. Shared Ownership Billing. The transmission and distribution utility shall allocate the nettable energy of the shared ownership facility to customers in proportion to each customer’s ownership interest in the facility. The transmission and distribution utility may place shared ownership customers on the same billing cycle. 6. Limit on Accounts. Customers or shared ownership customers may designate no more than 10 accounts or meters for net energy billing. 7. Uniform Billing Cycle. If a single customer or a shared ownership customer has multiple net energy billing accounts the transmission and distribution utility may place those accounts on a uniform billing cycle. J. Competitive Electricity Provider Billing. A customer or shared ownership customer that elects net energy billing may obtain supply service from any competitive electricity provider that agrees to provide service on a net energy basis. If a competitive electricity provider enrolls a net energy billing customer, the competitive electricity provider shall provide service on a net energy basis. K. Standard Offer Provider Service. If the customer or the shared ownership customers receive standard offer service, the standard offer provider shall provide service on a net energy basis. L. Additional Meters and Equipment. Nothing in this section shall prohibit a utility from installing additional meters to record gross output and customer usage separately, provided, however, that no customer that is billed on a net energy basis shall be charged for the cost of the additional meters or other necessary equipment. M. Interconnection Requirements. A customer or shared ownership customers that elects net energy billing must comply with all interconnection, safety and reliability requirements of the transmission and distribution utility applicable to the eligible facility. 65-407 Chapter 313 N. §4 page 9 Standard Contract and Application. Each transmission and distribution utility shall develop a standard contract and application form for customer net billing consistent with the provisions of this Chapter. The standard contract shall allow customers to choose a contract with no specified term or with a term length of up to ten years. In the event a customer chooses a contract term length, the contract shall include a provision that obligates the parties to negotiate in good faith to revise the contract terms if there is a change in statute or rule that materially alters any right or obligation of a contracting party. Renewable Energy Credit (REC) Aggregation Option A. New Renewable Resource Certification. An eligible facility, except for microcombined heat and power systems that do not use a renewable fuel or technology as specified in 35-A M.R.S.A. §3210(2)(C), shall be deemed to be certified as a new renewable resource (Class 1) pursuant to Chapter 311 of the Commission’s rules and exempt from the requirements of Section B(4) of that rule if the eligible facility: 1. has a net energy customer arrangement effective date on or after January 1, 2018 and 2. conforms to Section 3(C) of this Rule. B. Option. An eligible customer or shared ownership customer with a facility certified pursuant to Section 4(A) of this Rule may elect to have the RECs associated with its facility aggregated by the transmission and distribution utility and sold into the regional market. All proceeds realized from such REC sales shall be returned to customers that participate in REC aggregation pursuant to this section as a credit on their T&D bills. C. GIS Certificates. A customer that participates in REC aggregation pursuant to this section must allow the GIS certificates associated with its facility to be transferred to the transmission and distribution utility. The transmission and distribution utility shall retire the quantity of GIS certificates needed for the customer’s usage behind the meter to conform to the new renewable resource requirement pursuant to Chapter 311(3)(A) of the Commission’s rules. A customer that does not participate in REC aggregation pursuant to this Rule is not required to transfer any of the GIS certificates associated with its facility to the transmission and distribution utility. D. Terms and Conditions. Transmission and distribution utilities shall develop terms and conditions to govern REC aggregation for net energy billing customers. E. Administrative Costs. The treatment of the costs for the transmission and distribution utility in administering REC aggregation will be established by Commissioner Order. F. Consumer-owned Utility Exemption. Consumer-owned transmission and distribution utilities are not required to provide a REC aggregation option pursuant to this section. Consumer-owned transmission and distribution utilities may elect to provide a REC aggregations option in accordance with this section. 65-407 Chapter 313 §5 §6 page 10 REPORTING AND COMMISSION REVIEW A. Commission Review. A transmission and distribution utility shall notify the Commission if the cumulative capacity of eligible facilities in its service territory subject to the provisions of this Chapter reaches three percent of its peak demand. Upon notification, the Commission will review this Chapter to determine whether net energy billing pursuant to this Chapter should continue or be modified. B. Biannual Report. On March 1 and September 1 of each year, transmission and distribution utilities shall file with the Commission a biannual net energy billing report. The March 1 report shall reflect the prior calendar year and the September 1 report shall reflect the prior July through June period. The biannual net energy billing report shall include: (1) a list of all net energy billing arrangements in the transmission and distribution utility’s service territory; (2) the capacity, energy output and fuel type or generating technology of each eligible facility; (3) the number of accounts or meters associated with each shared ownership net energy billing arrangement; (4) an estimate of the revenue loss associated with the net energy billing arrangements; and (5) estimated installed costs per wattDC for eligible facilities, including costs for recently installed facilities and projected costs for facilities over the next several years. WAIVER OR EXEMPTION Upon the request of any person subject to this Chapter or upon its own motion, the Commission may, for good cause, waive any requirement of this Chapter that is not required by statute. The waiver may not be inconsistent with the purposes of this Chapter or Title 35-A. The Commission, the Director of Electric and Gas Utility Industries, or the Presiding Officer assigned to a proceeding related to this Chapter may grant the waiver. BASIS STATEMENT: The factual and policy basis for this rule is set forth in the Commission’s Order Adopting Rule and Statement of Factual and Policy Basis, Docket No. 2016-00222, issued March 1, 2017; Commission’s Order Adopting Final Rule, Docket No. 2011398, issued on 1/11/12; Commission’s Order Adopting Final Rule, Docket No. 2008-410, issued on June 9, 2009; Commission's Statement of Factual and Policy Basis and Order Adopting Rule, Commission Docket No. 98-621, issued on December 10, 1998; and Order Adopting Provisional Rule and Statement of Factual and Policy Basis, Commission Docket No. 2008-410, issued on January 8, 2009. Copies of this Statement and Order have been filed with this rule at the Office of the Secretary of State. Copies may also be obtained from the Administrative Director, Public Utilities Commission, 101 Second Street, Hallowell Maine 04347, 18 State House Station, Augusta, Maine 04333-0018. STATUTORY AUTHORITY: 35-A M.R.S.A. §§ 104, 111, 1301, 3203(9), 3209-A and 3210 EFFECTIVE DATE: This rule was approved as to form and legality by the Attorney General on December 15, 1998. It was filed with the Secretary of State on December 15, 1998 and became effective on December 20, 1998. 65-407 Chapter 313 page 11 EFFECTIVE DATE: This rule was approved as to form and legality by the Attorney General on June 10, 2009. It was filed with the Secretary of State on June 15, 2009 as filing 2009-249, and became effective on July 15, 2009. EFFECTIVE DATE: This rule was approved as to form and legality by the Attorney General on January 20, 2012. It was filed with the Secretary of State on January 24, 2012 as filing 2012-7, and became effective on January 29, 2012. STATE OF MAINE PUBLIC UTILITIES COMMISSION PUBLIC UTILITIES COMMISSION Amendments to Net Energy Billing Rule (Chapter 313) ) ) ) ) ) ) ) ) ) ) ) ) ) PETITION FOR RECONSIDERATION OF NATURAL RESOURCES COUNCIL OF MAINE, CONSERVATION LAW FOUNDATION, REVISION ENERGY, INSOURCE RENEWABLES, AND INDUSTRIAL ENERGY CONSUMER GROUPS March 21, 2017 Docket No. 2016-00222 INTRODUCTION Under the Public Utilities Commission Rules of Practice and Procedure, chapter 110, section 11(D), Natural Resources Council of Maine, Conservation Law Foundation, ReVison Energy, Insource Renewables and Industrial Energy Consumer Group, (hereinafter “Petitioners”) request reconsideration of the Commission’s Order Adopting Rule and Statement of Factual and Policy Basis (“Order”) in Docket No. 2016-00222 issued March 1, 2017, regarding the Net Energy Billing (NEB) Rule.1 The Petitioners are joined by supportive Maine organizations, businesses and individuals listed at the end of this petition. The Commission’s amendments to the NEB rules (“NEB amendments”) fail to advance the public interest, in part because they are primarily focused on limiting benefits and values for families, communities and businesses that generate solar power, rather than based on the interest of ratepayers more broadly. The NEB amendments are not based on a sound, objective review of the NEB Rule and are more likely to raise unnecessarily electricity costs for Maine ratepayers without any countervailing benefits. Petitioners request that the Commission grant this Petition for Reconsideration and reopen its rulemaking proceeding to remedy these flaws.2 ARGUMENT I. The NEB Amendments Are Not in the Public Interest. A. The Purposes of the NEB Amendments are Too Narrow and Exclude Fundamental Issues of Public and Ratepayer Interest. The Order states that the NEB amendments were focused on “addressing [solar] technology cost decreases and reducing cost-shifting”. Order at 21. These purposes are 1 Amendments to Net Energy Billing Rule (Chapter 313), Maine Public Utilities Commission, Docket No. 2016-00222, Order (March 1, 2017); see 35-A M.R.S. § 3472(1). 2 Petitioners hereby incorporate by reference in this Petition our comments submitted as part of this rulemaking docket. Failure to include any argument, fact, or issue herein does not constitute a waiver by any of the parties to raise any arguments, facts, or issues on an appeal. 1 woefully inadequate to advance the public interest. The Order fails to address how or whether the NEB amendments reduce costs for ratepayers or indeed would achieve any broader regulatory purpose. Worse, in pursuit of these extremely narrow purposes, the Order fails to consider whether the NEB amendments could have a net impact that is counter to the public interest. Fundamentally, the Order limits participation in, and ultimately eliminates, NEB, and, as the Order acknowledges, that will fundamentally limit the growth of distributed solar energy generation in Maine. Order at 11. This purpose is at odds with statutory policy, including: When encouraging the development of solar energy generation, the State shall pursue cost-effective developments, policies and programs that advance the following goals: … C. Ensuring that the production of electricity from solar energy meaningfully contributes to mitigating more costly transmission and distribution investments otherwise needed for system reliability; … E. Increasing the number of businesses and residences using solar technology as an energy resource; and F. Increasing the State's workforce engaged in the manufacturing and installation of solar technology. 35-A MRSA §3474 [emphasis added]. There is overwhelming evidence that distributed solar energy generation is an important tool for mitigating transmission and distribution costs, which are born directly by all electricity customers and comprise the largest portion of monthly residential electricity bills. The Commission’s Order entirely fails to consider how the NEB amendments will affect those costs.3 The Commission’s purpose and framework for considering amendments to the NEB Rule was limited to reducing so-called cost-shifting of transmission and distribution rates between customers. The Commission did not even consider what impact its cost-shifting focus would have on transmission and distribution costs. In setting rates, the law directs the Commission to “give equivalent consideration to the goals of minimizing costs and minimizing transmission and distribution rates to consumers.” 35-A MRSA §3153-A. In this Order, the Commission fails to give substantial consideration to either. Moreover, the Order fails to explain why decreasing costs to install solar is a problem that needs to be addressed in the first place. All else equal, it is undisputable that decreasing technology costs will result in increasing installation of solar energy systems. 3 Similarly, the Order fails to give sufficient consideration of statutory policy regarding transmission and distribution: “The Legislature declares and finds that improvements in transmission and distribution utility rate design and related regulatory programs have great potential for reducing the cost of electric utility services to consumers, for encouraging energy conservation and efficient use of existing facilities and for minimizing the need for expensive new electric transmission capacity.” 5-A MRSA §3152. 2 Given the ratepayer benefits from increasing distributed solar broadly identified by the Commission in its Maine Distributed Valuation Study (Apr. 14, 2015) (“VOS”) analysis, decreasing technology costs are a boon to both individual solar energy system owners and as well as other ratepayers. The Order attempts to skirt this issue by merely labeling NEB as an “incentive,” which it does more than a dozen times. Order at 5, 6, 9, 10, 14, 15. Whether NEB is an incentive may be a matter of semantic dispute; there should be no dispute that distributed solar energy generation is a resource that affects electricity markets and grids in important ways. The Commission should reconsider its Order because it has not considered these impacts of the NEB amendments on the public interest. B. The NEB Amendments are Likely to Raise Electricity Costs Without Providing any Countervailing Benefit. In late 2015, the Commission sought and received assistance from the National Renewable Energy Labs to project that NEB under the status quo would result in approximately 150 MW of distributed solar energy generation by 2021.4 The Commission’s adoption of the NEB amendments will undoubtedly reduce that projected level of generation by Maine homeowners, communities and businesses that use NEB to properly size their installation and offset its capital costs. When the Commission conducted its VOS analysis in late 2014, showing that distributed solar reduced certain ratepayer costs.5 Specifically it found that each marginal kilowatt-hour of production would reduce transmission costs by 1.4 cents in the “firstyear” and 1.6 cents on a levelized basis over the long-term, and would reduce market prices for energy by 0.9 cents in the first-year and 6.6 cents on a levelized basis over the long-term6. VOS at 5 and 6. The NEB amendments will slow the penetration of distributed solar and almost certainly forego the projected savings identified in the Commission’s own report. The Order’s discussion of the economic VOS analysis is deeply flawed, as set forth below in III.C. The Order also includes factual misstatements. For example, the misstatement that the first-year “monetizeable” benefits were calculated to be 9 cents/kwh. Order at 8. In fact, they total 9.9 cents/kwh7. VOS at 5. As the Commission is aware, the levelized value of financial over 25 years was 17.5 cents/kwh. Some of this value will be foregone under the NEB amendments, at the expense of ratepayers as a whole.8 4 Pieter Gagnon and Ben Sigrin. “Distributed PV Adoption in Maine through 2021.” NREL. November 6, 2015. Powerpoint presentation entered into Docket 2015-00218. 5 VOS 6 We understand that the Commission may now dispute its own findings on these values. However, as described below, the Commission made no attempt to quantify the forgone benefits of distributed solar, nor the purported ratepayer benefits from eliminating so-called cost-shifting, the net of which might generally be seen as a ratepayer impact. 7 The Order left out market price response. Market price response is not an attribute that can be sold in any market, but nor can avoided transmission. The term “monetizeable” is therefore somewhat vague—all of the values in the study were expressed in dollar terms or “monetized”. We understand that some values correspond to financial components of rates and others to environmental values. Both market price response and avoided transmission, and the other values cited in the Order at 8, are financial components of rates. 8 The Order correctly observes that long-term values are highly dependent on assumptions about market 3 C. The NEB Amendments Impose Unnecessary New Metering and Billing Costs. The NEB amendments require new NEB customers to meter their gross generation so that it can be netted against electricity consumed for the transmission and distribution portion of their bill. The effect of this change is to levy a transmission and distribution fee or penalty on power that is generated and consumed behind the customer’s primary meter. Below, Petitioners argue that this is a violation of the right to self-generate. Additionally, the NEB amendments impose significant new metering costs which are themselves unnecessary burdens on ratepayers as a whole. The provision will require additional metering equipment to measure gross output, at a likely cost of several hundred dollars per participant. If each existing NEB customer had been required to have a meter on generation, the cost could exceed $1 million, for example. At the same time, the NEB amendments state that customers may not ordinarily be billed for this equipment, therefore implying that ratepayers as a whole would bear these costs. The Order provides no clear rationale for this unreasonable requirement. The NEB amendments also establish a phase-out of NEB credits from the retail rate to Standard Offer rates over a 10-year period, with new customers in each year receiving a fixed percentage for a 15-year period. We are not aware of any comments or arguments in the record in support of this approach. In addition to the concern of Petitioners stated above that this reduction will slow the penetration of distributed solar generation, there is widespread concern that this approach would require a complex and likely expensive billing arrangement. It will require utilities to sort NEB customers into up to 11 different categories of crediting, for a period of approximately 25 years, at a great deal of cost to all electricity customers.9 It is even possible that the new costs all ratepayers will have to pay for this complicated billing scheme will outweigh any purported savings the rule would achieve. The Commission should reconsider its Order after it has attempted to determine what those costs would be. D. The Commission Should Clarify that Customers May Continue to Choose a Rolling 12-Month NEB Credit Cycle. The Commission has long recognized that the annualized net metering concept under conditions in the future. Order at 8. However this same caution should be extended with regard to future technology costs, which is the primary basis for the Commission’s proposed phase down of net metering credits. 9 Indeed, the Commission repeated CMP’s claim that lifting the arbitrary limit on the number of community solar accounts would “negatively affect its billing system performance” (although the Order fails to mention that CMP further recommended raising the limit to 200 instead of eliminating it.) Order at 21. Any billing complexity from expanding participation in community solar farms is minimal compared to that contemplated in the NEB Amendments, with the costs and complexity to be borne by ratepayers as a whole. 4 the Chapter 313 rules would be frustrated if the utility required customers to use all credits within a given 12-month contract period that did not match the variability of certain renewable resources: Mr. Bertl raises a valid concern that, depending on the net billing anniversary date, the intent of the annualized approach could be frustrated. This could occur, for example, if the net billing contract begins after the high hydropower output months. The result is that there are no “credits” to be used to offset usage during the low production months at the beginning of the 12-month period, and the customer would have limited ability to take advantage of the high output months that would occur near the end of the period. HYDROTRICITY, Request for Waiver Under Section 4 Of Chapter 313, No. 2001-027, Advisory Opinion, at 6 (April 3, 2001). To avoid this result, the Commission has interpreted the rules to allow a NEB customer to either choose its “anniversary date” or to use a 12month rolling methodology for individual months in which credits accumulated in any given month could be used to offset usage over the succeeding 12 months. SUNGEN SOLAR CENTER LLC, Request for Commission Investigation into Chapter 313 Implementation, No. 2011-316, Order at 3 (Feb. 6, 2012) (“‘We therefore interpret Chapter 313 to allow a customer to choose either approach for implementation of the annualized net billing methodology,’” quoting HYDROTRICITY at 7.) In the portion of the NEB amendments relevant to the determinations above, the Commission has changed the wording of former §3(E)(3) (“over a 12-month period”) to new language in new section § 3(I)(3) (“within a given 12-month period”). The Commission offered no explanation for this change at any stage in the 2016-00222 rulemaking. It is Petitioners’ understanding that the Commission did not intend the new language to change its longstanding and well-settled precedent. To avoid confusion or further litigation, Petitioners ask the Commission to confirm that net energy billing customers may continue “to choose either the anniversary date or the individual month rolling methodology.” SUNGEN at 3. II. The NEB Amendments Constitute Unjust Discrimination and Violate Customer Rights to Self-Generation. The NEB amendments require NEB customers to meter their gross generation so that it can be netted against electricity consumed from the grid for the transmission and distribution portion of their bill. The Order entirely fails to justify this change or provide any regulatory principle that it is based on. The Order argues that this change does not constitute an exit fee and that NEB is optional. Order at 18. While Petitioners reject those arguments below, neither of Commission’s arguments constitute a positive rationale for this extreme change, which gives the appearance of arbitrariness. Even the Commission’s arguments about NEB customers not paying for incurred transmission and distribution costs when they are credited for exports do not provide a basis for interfering in a customer’s generation or usage behind the meter. Rates for utility service subject to the jurisdiction of the Commission must be just and reasonable. 35-A M.R.S. § 301. Implicit in the concept of just and reasonable rates is 5 the requirement that rates and charges not be unjustly discriminatory. Unjust discrimination in the context of utility rates and charges includes charging a rate to one customer or group of customers that is “higher than that charged by the same utility for the same service or service of similar value and cost rendered to other users or consumers.” 35-A M.R.S. § 1304. The NEB amendments include provisions that result in NEB customers being charged for transmission and distribution service for energy that they have supplied to themselves that never enters the utility grid. The Order asserts that these charges are necessary because NEB customers are still consuming transmission and distribution service and it is therefore necessary to charge customers for such service to avoid “cost shifting.” Order at 6-7. This finding lacks factual support and the rates and charges that would be imposed by the NEB amendments are therefore unjust and unreasonable. Specifically, the Commission has made no inquiry into whether the consumption of NEB customers is adequate to support the cost of serving them. Rather, it assumes that their gross consumption is the proper measure for collecting costs. However, it is even possible that NEB customers use a larger amount of electricity than average customers because they may pursue additional technologies that rely on electricity. Further, other similarly situated customers may reduce their consumption by installing energy efficient equipment or by fuel switching. Similarly, industrial users who generate power behind the meter by using waste products also reduce their consumption. Under the logic of “cost shifting,” these customers should be charged additional rates to reflect the lost revenue resulting from such decisions. Singling out NEB customers for such charges results in rates that are “higher than that charged by the same utility for the same service or service of similar value and cost rendered to other users or consumers,” 35-A M.R.S. § 1304, and therefore results in rates that are unjust and unreasonable. The Order’s finding with respect to cost shifting is also inconsistent with prior Commission determinations. Maine has a long history of self-generation, both in practice and in regulation, and multiple statutes protect the ability of customers to produce and consume their own power without penalty or interference. In its 1996 order on industry restructuring, the Commission explicitly found that the loss of revenue due to customer self-generation is a risk borne by utilities for which they are compensated in their rates of return.10 Not all costs that become unrecoverable are "stranded" by retail competition. Customers may reduce or even eliminate electricity usage by self-generating, fuel switching, production cutbacks, energy conservation, and bypassing the utility's system entirely. All these activities result in fewer revenues available to the utility to pay the fixed costs of operations. These customer options, however, exist under current regulation as much as they would after retail competition begins. The Order’s finding with respect to cost shifting effectively reverses this fundamental 10 Re Electric Utility Industry Restructuring, Docket No. 1995-462, Report and Recommended Plan (December 31, 1996) (the “Restructuring Plan”). 6 finding adopted by the Commission in the Restructuring Plan. Finally, the Order’s finding with respect to “cost shifting” and related determinations with respect to calculation of transmission and distribution charges violates the statutory prohibition against imposing exit fees. 35-A M.R.S. § 3209(3) provides: 3. Exit fees. A customer who significantly reduces or eliminates consumption of electricity due to self-generation, conversion to an alternative fuel or demand-side management may not be assessed an exit or reentry fee in any form for the reduction or elimination of consumption or reestablishment of service with a transmission and distribution utility. (Emphasis supplied). The Order’s determination to impose transmission and distribution charges on energy that customers have supplied to themselves that never enters the utility grid is unambiguously a fee for reduction in use due to self-generation. Prior to the Legislature’s enactment of § 3209(3), the Commission addressed the policy reasons for not allowing exit fees in its Restructuring Plan.11 The Commission does not believe exit fees are either practical or appropriate. Proponents of exit fees claimed that the demand for electricity of particular customers has caused utilities to incur certain costs on their behalf, and that these same customers should pay these costs. This claim is doubtful. Power purchases are rarely customer-specific. Moreover, if the idea is to match cost-recovery with cost-causation, some daunting questions emerge. Should customers have to be on the system any particular length of time before any exit fee would apply? Should customers who entered the system last year be required to pay an exit fee if they leave the system next year? If so, should the amount of the exit fee be the same as for a customer that has been on the system for 30 years? Should exit fees apply to customers that enter the system in the future? None of these questions has a felicitous answer. Exit fees could also adversely affect Maine's business climate. If exit fees applied to businesses who were utility customers on a specific date, only newer businesses could switch power suppliers without paying an exit fee. If exit fees applied to new customers, it could dissuade businesses from entering the State. What business would move to Maine if its flexibility to move in the future were so constrained? Exit fees are an extraordinary remedy. That approach might be justified where its absence would result in either extreme financial stress on the utility or unacceptable rate increases for utility ratepayers. An exit fee or similar rate design should not be adopted without a substantial demonstration of ratepayer harm. In addition to the NEB amendments’ plain violation of statute with respect to this issue, the same policy considerations exist here with respect to imposition of transmission 11 Id. 7 and distribution charges on energy customers have supplied to themselves that never enters the utility grid. The Commission should reject the aspect of the NEB amendments that impose transmission and distribution charges on gross energy as being unjustly discriminatory and a violation of the prohibition on exit fees. Identifying NEB as “voluntary” is not sufficiently persuasive as to justify the NEB amendments. Order at 18. Simply buying power from the grid is likewise “voluntary,” but that does not give utilities or the Commission free license to charge any fee whatsoever or excise burdensome or arbitrary regulatory requirements. Under the NEB amendments, pre-existing NEB customers who already made investments in self-generation capacity will be subject to the gross metering approach after their grandfathering time period expires. For these customers, NEB is not “voluntary” in any practical or fair way. Furthermore, NEB is a mechanism that allows customers to size generation in an economically efficient manner and reduce their load on the electricity grid (including on an instantaneous basis, not just on an annualized basis), which reduces well-understood cost drives for the grid and electricity markets, as described above. III. The NEB Amendments Are Not Based on Sufficient Evidence or Sound Economic Ideas. A. The NEB Amendments are Not Based on Evidence of Meaningful Cost-Shifting. The Order asserts that there can be “no doubt” that cost-shift is occurring and that “the actual amount of this cost-shift can be determined with reasonable accuracy.” Order at 7. However, the Commission has presented no factual evidence of this shift and made no attempt to quantify it. As the Commission is aware, rates never reflect a perfect alignment of the costs that individual customers incur on the system. Customers in a given rate class pay the same rates regardless of geography, for example, even though the costs incurred by rural ratepayers are significantly higher than those incurred by urban ratepayers. This long-standing and widely recognized “cost-shift” is deemed acceptable by regulators in Maine and elsewhere because the cost-shift is likely relatively modest and any remedy worse than the disease. Setting aside the Commission’s failure to include any claim of cost-shift in a broader context of NEB’s total ratepayer impact (see below), even the utilities’ purported amount of cost-shifting appears to be inconsequential. The Commission’s decision to singleout this form of cost-shifting is arbitrary, especially lacking any effort to quantify it or evaluate the potential negative impacts of the remedy. In addition, the Commission conflates cost-shifting from NEB with lost revenue from decreased utility sales as a result of self-generation. This not only leads to a significantly exaggerated measure of any cost-shift, but provides a flawed basis upon which to consider NEB from a regulatory perspective. Put simply, reduced demand for electricity is not a cost, indeed it is a savings, so it 8 can’t be called a cost-shift. In its description of cost-shifting, the Order describes how NEB customers use the grid when they are importing or exporting energy from the grid. Order at 6-7. However, the Commission would presumably agree that when they are importing electricity, they are subject to the same rates as any other customer and no cost-shifting is occurring. We understand that the Commission’s concern is with regard to the value at which exports should be credited, and whether providing transmission and distribution credits for exports improperly exempts NEB customers from some of those costs. Therefore the proper way to assess the costs this might shift to other ratepayers is to measure the value of the transmission and distribution portion of the credits granted to NEB customers for their exports. From an empirical and regulatory perspective, this amount is distinct from the revenue the utilities lose from reduced sales and it is arbitrary to conflate them as one cost. The cost of providing net metering credits as a form of lost revenue, could be “determined with reasonable accuracy,” but to our knowledge it is has not been disclosed by the utilities. Instead, the utilities appear to base calculations of the cost of net metering on lost revenues from gross generation by NEB customers, even that generation consumed behind the meter. Not only is this not reflective of the cost of NEB itself, this amount is not so easy to determine accurately and requires the utilities to make assumptions about patterns of generation and consumption behind the meter. If lost revenue from self-generation of electricity is labeled a “cost-shift”, then so should that from energy efficiency and every form of energy conservation, as well as from any self-generation not relying on NEB.12 It implies that customers who consume less electricity from the grid have some load obligation which, if they fail to consume, burdens others. It begs the question of what is the baseline amount of load that the utilities or other ratepayers are “owed” by NEB customers, which would be impossible to establish in any rational way. Finally, in its Order the Commission restates CMP’s claim of lost revenue from NEB of $1.8 million, but nowhere in the rulemaking or preceding “review” of NEB in Docket 2016-00218 did the Commission subject this claim to any meaningful, transparent evaluation. Failure to do so was certainly arbitrary and capricious and the Commission should reconsider its decision after doing so in order to more plainly reveal the conflation of lost revenue from NEB crediting with that from decreased sales, allowing the public and interested parties to examine the evidence and methodology behind this claim. 12 The Commission claims that NEB should not be equated with self-generation. Order at 18. However if the Commission believes NEB is completely distinct from self-generation, then the lost-revenue from self-generation on the part of NEB customers cannot be considered a cost-shift resulting from NEB. 9 B. The NEB Amendments are Not Based on Any Test of Ratepayer Impact. There is nothing in the Order to suggest that ratepayers will be better off on the whole as a result of the NEB amendments. The Order discusses some categories of costs and benefits related to NEB, but does not propose any approach for weighing those. The treatment of benefits from NEB and distributed solar is flawed. The Commission improperly dismisses the use of avoided cost or value of solar analysis as “of limited use in a program like NEB that requires ratepayer-funded incentives.” Order at 9. This is circular reasoning. NEB shouldn’t be labeled an “incentive” if it reduces (or avoids) more costs than it incurs. The Order’s assertion that “ratepayer funded incentives are evaluated based on costs” is confusing. Ratepayer funded incentives should be evaluated based on costs and benefits. For example, in 2012, when the Commission evaluated the Renewable Portfolio Standard, which the Commission presumably considers to be a ratepayer-funded incentive, it asked London Economics to evaluate both costs and benefits of the policy. The Order incorrectly states that avoided costs are not relevant in related regulatory contexts like energy efficiency. Order at 9. In Maine, energy efficiency is funded based on an avoided cost methodology. Rebates for individual efficient appliances are set by Efficiency Maine Trust based on fluctuating market economics, but the determination of how much ratepayers should pay for efficiency rebates (in aggregate) is based solely on the costs that can be avoided.13 Those costs include avoided transmission and distribution, capacity, market price response and most of the other components of the VOS—determining the specific avoided costs is determined in an adjudicatory process. While there are important differences between NEB and energy efficiency, the Commission has erred significantly by completely dismissing any consideration of avoided costs or the VOS. The Order states that “the avoided cost methodology is not helpful in cost of service ratemaking because it does not refer to the known specific costs of concern in designing rates.” Order at 9. Petitioners contend that, in fact, the NEB amendments do not refer to known specific costs either. The Commission did not assess the cost of serving NEB customers. With regard to distributed solar technology costs, we fail to see how these costs are particularly relevant. The rate impact of NEB does not vary as a result of the cost of solar installation. The cost of solar will affect the volume or growth of NEB uptake (an economic response that the Commission has failed to consider) but it will not affect whether NEB imposes a cost or benefit on ratepayers. Some of the Petitioners commented during the rulemaking about arbitrariness of the proposed phase down of NEB credits. That was not because we failed to observe 13 In principle, Efficiency Maine could offer rebates up to the “value” for customers as a whole (i.e. the avoided cost), if doing so would not lead to undue free ridership. 10 the Commission’s linkage with technology cost reductions; rather the phase out is arbitrary from a regulatory basis because it is not based in any test of ratepayer benefit. The Commission also failed to consider whether perpetuating the cap on the number of customers participating in a community solar farm was in the public interest. The 10-person limit is arbitrary and neither the Commission nor any other party has argued otherwise. CMP recommended a cap of 200 customers. The Order claims that community solar is a policy matter that lawmakers should address. Order at 21. However the limit is entirely a creation of Commission rules and in no way reflects legislative direction. In addition, the Commission appears comfortable making very fundamental changes to the structure of NEB that Petitioners and others argued should be left to lawmakers. The Commission’s adoption of proposed amendments that slow the growth of solar while rejecting proposed amendments that might expand it are further evidence of the one-sided nature of the decision. C. The NEB Amendments are Based on Flawed Economic Ideas. The Order incorrectly states that under NEB there is no incentive for solar providers to reduce costs as installation costs decrease. Order at 5. This assertion grossly mischaracterizes the market for solar installation products and services, which are subject to competitive market forces completely unrelated to the value of NEB credits. Unlike regulated monopolies with which the Commission is very familiar, solar suppliers and installers compete with each other, resulting in lower prices for consumers. The Order states that solar installers base their prices “on what local markets will bear, which is not necessarily in line with actual costs.” Order at 5. According to basic economics, in a functioning market, prices will reflect actual costs. The Commission’s stated goal of reducing NEB credits is to “maintain a rate of return on investment.” Order at 15. But the Commission’s function is not generally to regulate rates of return outside of the monopoly framework. Furthermore, by holding return on investment steady, you will see steady state changes in penetration, as opposed to increasing rates of penetration as returns improve. As argued above, improving economics for installing distributed solar does not impose a cost on ratepayers and indeed is likely to yield a benefit in the form of reduced grid and market costs. Therefore the Commission does not need to amend NEB in order to foster competition and drive down costs to install solar, nor is it inherently proper to try to regulate profits for installers or consumers as opposed to seeking the lowest costs for ratepayers as a whole. The Order states that costs of the transmission and distribution system are incurred regardless of whether a NEB customer pays them in full or not. Order at 7. However, transmission and distribution costs are not fixed—if only they were! According to the Commission’s most recent annual report, transmission and distribution rates have risen 80% in the last decade. If transmission and 11 distribution costs were fixed, then there would be no justification for demand charges. Instead, any cost of service analysis, including the most recent one by CMP, demonstrates that significant portions of the marginal cost of transmission and distribution are linked to annual peak demand. As the Commission’s VOS identified in considerable detail, distributed solar on the margin reduces annual peak demand. The Commission’s failure to recognize these basic principles in this proceeding leads to the wrong price signals from the point of view of economic efficiency and thus to higher long-term costs for ratepayers. IV. The NEB Amendments Fail to Take Advantage of Technological and Market Opportunities to Modernize Grid Infrastructure and Increase Economic Efficiency. In issuing this Order, the Commission has failed to move Maine toward the objectives of a “smarter grid”, with modern rate design and integration of distributed energy resources. Indeed, by slowing the deployment of distributed generation, penalizing self-generation, and advancing regulatory changes on distributed generation without any analysis of how they impact rates or grid costs, the Commission has violated legislative policy with regard to grid modernization. The legislature established a broad set of policies with regard to a “smart grid”, including: It is the policy of the State to promote in a timely and responsible manner, with consideration of all relevant factors, the development, implementation, availability and use of smart grid functions and associated infrastructure, technology and applications in the State through: A. Increased use of digital information and control technology to improve the reliability, security and efficiency of the electric system; B. Deployment and integration into the electric system of renewable capacity resources, as defined in section 3210-C, subsection 1, paragraph E, that are interconnected to the electric grid at a voltage level less than 69 kilovolts; … 35-A MRSA §3143(3) The NEB amendments make no use of the smart meters that were installed, at considerable expense, across the entire state. Many years later, ratepayers are still waiting for utilities and the Commission to provide most of the promised benefits smart meters were meant to provide (indeed, the rule requires installation of additional meters, adding further metering costs without regard to benefits). The NEB amendments use no hourly metering, give no consideration to time of use rates, provide no valuation of grid services, and make no attempt to locate distributed generation resources for maximum advantage.14 14 The Order only cites location-dependent value of distributed generation as a justification for ignoring locational value completely. Order at 9. 12 The NEB amendments send the wrong price signals for distributed generation, consumption and storage. For example, the Order states that the monetized first-year benefits of solar were calculated in the VOS as “only $0.09 per kwh.” Order at 8. (As mentioned above, the value is actually $0.099 per kwh.) The NEB amendments would ultimately pay Standard Offer rates for solar, currently 6.7 cents/kwh. We lack a clear supply curve for distributed solar, however it is not economically efficient to only pay for distributed solar that costs 6.7 cents when it would be valuable to consumers to pay up to 9.9 cents. RECONSIDERATION REQUESTS For all the foregoing reasons, we request that the Commission grant this Petition and reconsider its Order and Rule as follows: 1. Order that Chapter 313 NEB rules be reverted to those that existed prior to the recent amendments. 2. Conduct a complete analysis of the costs and benefits of net metering from a ratepayer perspective. 3. Pending the completion of the current legislative session, re-open a rulemaking to consider changes to NEB that are consistent with the public interest and address the arguments made above. Respectfully submitted, Dylan Voorhees Climate & Clean Energy Director Natural Resources Council of Maine 3 Wade St. Augusta, ME 04330 Steve Hinchman Chief Counsel Revision Energy Presumpscot St. Portland, ME 13 Emily Green Staff Attorney Sean Mahoney Executive Vice President Conservation Law Foundation 53 Exchange St., Suite 200 Portland, ME 04101 Vaughan Woodruff Owner Insource Renewables 113 N Lancey St. Pittsfield, ME 04967 /s/ Anthony W. Buxton Anthony W. Buxton Counsel to the Industrial Energy Consumer Group 45 Memorial Circle, PO Box 10058 Augusta, Maine 04332 14 The following organizations and businesses join in support of this petition: American Lung Association of the Northeast City of Belfast Energy Committee Coastal Enterprises, Inc. Crystal Spring Farm Community Solar Association Goggin Energy Heliotropic Technologies Maine Audubon Maine Conservation Voters Maine Public Health Association Maine Small Business Coalition Maine Solar Solutions, LLC The Milkhouse PeaceWorks of Greater Brunswick Physicians for Social Responsibility, Maine Chapter Polaris Associates Portland Climate Action Team Renewable Energy Development Associates Sierra Club, Maine Chapter Solar Energy Association of Maine St. Joseph’s College Sundog Solar SunRaise Investments SunRun Union of Concerned Scientists 350 Maine 15 The following individuals join in support of this petition: Darlene Purington, Acton Edward Riggs, Albion Betsey Kneeland, Alexander George Davenport, Alfred Gerald Flanagan, Alna Carol Gardner, Alna Chris Kenoyer, Alna Anneliese Pugh, Alna Malcolm Hunter, Amherst Gertrude Akers, Andover Lorie Costigan, Appleton Shelley Johnson, Appleton Thomas Ward, Appleton James Galuza, Arrowsic Charles Hudson, Arrowsic Jesse McMahon, Arrowsic Robert O'Leary, Arrowsic Karen Robbins, Arrowsic Amy Smith, Arrowsic Wiebke Theodore, Arrowsic Teddi Myers, Arundel Stacey Raymond, Arundel Charles Watson, Arundel Kirstan Watson, Arundel Melissa Bilodeau, Auburn Annika Black, Auburn Walter Burbank, Auburn Christopher Carson, Auburn Edmund Claxton, Auburn Jillian Close, Auburn Sandy Doctoroff, Auburn Juliette Dzija, Auburn Diana Iwaszkiewicz-Carson, Auburn Katherine Langelier, Auburn Jennifer Lapierre, Auburn Jonnie Maloney, Auburn Dustin Marquis, Auburn Celia McGuckian, Auburn Rebecca Pape, Auburn James Pare, Auburn Kevin Simpson, Auburn Bob Sipe, Auburn Elizabeth Treble, Auburn Jamie Verrill, Auburn Benjamin White, Auburn Marlis Whittier, Auburn Nancy Crocker, Augusta Marsha Dulac-Swain, Augusta Vickie Fisher, Augusta Teen Griffin, Augusta Christopher L Hunter, Augusta Sandra Hutchings, Augusta Robert Kellerman, Augusta Jim Kidwell, Augusta Lian Kim, Augusta William McGuire, Augusta Paris Perez, Augusta Abigail Stratton, Augusta Margaret Terrill, Augusta Patten Williams, Augusta Jeffrey Young, Augusta Andrea Nurse, Avon Marcey Lachance, Bailey Island Michael McNally, Bailey Island Mary Ann Nahf, Bailey Island Jeffrey Allen, Bangor Grace Bartlett, Bangor Stephen Boardway, Bangor Jane Bragg, Bangor Robin Buckley, Bangor Miriam Devlin, Bangor Emily Dexter, Bangor Christina Diebold, Bangor Sean Flannigan, Bangor Patricia Hammill, Bangor Lisa Hand, Bangor Marsha Higgins, Bangor Pamela Johnson, Bangor Sharon Klein, Bangor Hannah Kreitzer, Bangor Jennifer Lipka, Bangor Dana Lippitt, Bangor Laura Mackay, Bangor Elizabeth Manalo, Bangor Ann Marston, Bangor Karen Marysdaughter, Bangor Libby Norton, Bangor Kevin Proctor, Bangor Carol Quagliotti, Bangor Jeff Reynolds, Bangor Donna Roberts, Bangor 16 Andrew Sarto, Bangor Catherine Schmitt, Bangor John Sherblom, Bangor Loretta Slowikowski, Bangor Jane Smith, Bangor Margaret Snell, Bangor Jennifer Staples, Bangor Linda Stearns, Bangor Ray Strickland, Bangor Wendy Waterman, Bangor Jo Ellen Waters, Bangor Vesa Wuoristo, Bangor jon archer, Bar Harbor John Avila, Bar Harbor Carole Beal, Bar Harbor Cyndi Bridges, Bar Harbor Anne Damm, Bar Harbor Joshua Ehrlich, Bar Harbor Gary Friedmann, Bar Harbor Sean Hall, Bar Harbor Wendy Kearney, Bar Harbor Peter Lindquist, Bar Harbor Celeste Lindsey, Bar Harbor Deborah Loftus, Bar Harbor Robert Moran, Bar Harbor Andrew Smith, Bar Harbor Scott Stevens, Bar Harbor Mary Ann Hale, Bass Harbor Richard Hanelius, Bass Harbor Nika Beauchamp, Bath Sarah Becker, Bath Sheldon Bird, Bath Will Blake, Bath Beatrice Blakemore, Bath James Brown, Bath Alicia Dole, Bath Laurie Hauptli, Bath Donna Henry, Bath Sally Howell, Bath Pat Moore, Bath Kimberly Nichols, Bath Julie Nolon, Bath Suzanne Paule, Bath Timothy Richter, Bath John Sisson, Bath Sanford Stein, Bath Laura Walters, Bath Curtis White, Bath Sharon Wilbraham, Bath Janice Wright, Bath Rainer Wucherer, Bath Neva Allen, Belfast Mike Bird, Belfast Happy Bradford, Belfast Sally Brophy, Belfast Noah Burditt, Belfast Paula Cannon, Belfast Douglas Chamberlin, Belfast Julie Cook, Belfast Suzanne Coolbeth, Belfast Donald Cox, Belfast Susan Cutting, Belfast Jenny Davis, Belfast Derek DeJoy, Belfast Louisa Dunlap, Belfast Anne Feeley, Belfast Elizabeth Garber, Belfast Sue Garrett, Belfast Tom Groening, Belfast Conny Hatch, Belfast Beth Henderson, Belfast Tony Kulik, Belfast Jacquie Lacoste, Belfast Barbara Maria, Belfast Betty Miliano, Belfast Cory Morse, Belfast Ann Mullen, Belfast Diane Oltarzewski, Belfast M Pease, Belfast Belinda Pendleton, Belfast Lily Piel, Belfast Arline Rauch, Belfast Kenneth Rhoads, Belfast Margie Shannon, Belfast Paul Shepherd, Belfast Kristina Shula, Belfast David Smith, Belfast Jude Spacks, Belfast karin spitfire, Belfast Wendy Trefry, Belfast Elaine Tucker, Belfast Karl Watkins, Belfast Marty Weaver, Belfast Eileen Wolper, Belfast Terrance Campbell, Belgrade Loyce Hayslett, Belgrade Linda Warner, Belgrade Fox Buck, Belmont Nora Flanagan, Belmont David Lewis, Belmont Sonya Weaver, Belmont Jeanie Piecara, Benedicta Joan Frisina-Bowles, Benton Jonathan Rogers, Benton Donna Gann, Bernard Kathleen VanGorder, Bernard Bill Voorhies, Bernard Marilyn Voorhies, Bernard Ellen Brouillet, Berwick Robert Keyes, Berwick Steven Kloppenburg, Berwick Paula Lepore, Berwick Rosanne Martin, Berwick Rick Tibbetts, Berwick Eric List, Bethel Mary Alice Madden, Bethel Samantha Mullen, Bethel Kirk Siegel, Bethel Lyndsey Smith, Bethel Peter Southam, Bethel Jennifer Corral, Biddeford Holly Culloton, Biddeford Denise Dreher, Biddeford James R. Flint, Biddeford David Fortier, Biddeford Wendy Johnson, Biddeford Allyson Merrill, Biddeford Albert Nickerson, Biddeford Mary Nolette, Biddeford Kimberly Roseberry, Biddeford Matt Schermerhorn, Biddeford Lucille Seymour, Biddeford Sarah Wells, Biddeford Susan Yarmey, Biddeford Dawn Zammuto, Bingham Stephen Hobart, Blanchard Twp Rick Alexander, Blue Hill Tom Bjorkman, Blue Hill Leslie Clapp, Blue Hill 17 Bonnie Dean, Blue Hill Mary Della Torre, Blue Hill Linda Deming, Blue Hill Blaise deSibour, Blue Hill Margaret Donohue, Blue Hill P & B Grant, Blue Hill Leda Beth Gray, Blue Hill Emily Hawkins, Blue Hill Melinda Lecomte, Blue Hill William MacDowell, Blue Hill Chris Nelson, Blue Hill Bonnie Preston, Blue Hill Suzanne Torrey, Blue Hill Marianne Anthony, Boothbay Nancy Hurst, Boothbay Denise Marr, Boothbay Katherine Schwehm, Boothbay Sara Walbridge, Boothbay Tim D'Angelo, Boothbay Harbor Maria Jenness, Boothbay Harbor Richard Macdonald, Boothbay Harbor Michael Mayhew, Boothbay Harbor Teresa Coffey, Bowdoin Meresa Erving, Bowdoin William Gerencer, Bowdoin Benjamin Grant, Bowdoin Ralph Harmon, Bowdoin Paul Sarli, Bowdoin Edith Bailes, Bowdoinham John Capron, Bowdoinham Susan Drucker, Bowdoinham Christopher Scerbo, Bowdoinham Patricia Walchli, Bowdoinham Thomas Walling, Bowdoinham Lisa Wesel, Bowdoinham C Boone, Bradford Lynn Gelhar, Bremen Edith Kearney, Bremen Eleanor Kinney, Bremen Marc Poirier, Bremen Mary Voskian, Bremen Lisa Wallace, Bremen Arthur Gardiner, Brewer Marie Keane, Brewer Bill Bent, Bridgton Carol Bent, Bridgton Jonathan Chappell, Bridgton Ken Converse, Bridgton Catherine Crago, Bridgton John Hornstein, Bridgton Joan Jenness, Bridgton Robert Jones, Bridgton Donna Joss, Bridgton Jim Hatch, Bristol Edward Hodgdon, Bristol Alan Littlefield, Bristol Cleo Mook, Bristol Kathleen Riess, Bristol Warren Riess, Bristol Daphne Lehava Stern, Bristol Jody Telfair-Richards, Bristol Claire Mortimer, Brooklin Michael Percy, Brooklin Kevin Poland, Brooklin Holbrook Williams, Brooklin Jennifer Albee, Brooks Jared Crawford, Brooks Lynn Heasley, Brooks Bruce Littlefield, Brooks S McKay, Brooks Lesia Sochor, Brooks Ed Sousa, Brooks Christopher Tomalty, Brooks Galen Davis, Brooksville Deborah Ludlow, Brooksville Darene Powell, Brooksville Jane Anderson, Brownfield Jamie Riel, Brownfield Barbara Smith, Brownfield Nathan St. Saviour, Brownfield Joan Veilleux, Brownfield Jeff MacDonald, Brownville Salina Pierce, Brownville Janet Adams, Brunswick Elizabeth Andrews, Brunswick Dana Baer, Brunswick Michael Banks, Brunswick Rosemary Barnhart, Brunswick Bruce Bishoff, Brunswick Jen Blood, Brunswick Helen Boucher, Brunswick Claudine Bravo, Brunswick Robert Broderick, Brunswick Robert Burgess, Brunswick Bruce Burnham, Brunswick Philip Carey, Brunswick Ellie Christie, Brunswick Walter Christie, Brunswick Barbara Clark, Brunswick John Cotton, Brunswick Peter Countway, Brunswick Mary Cunningham, Brunswick Cynthia Dechenes, Brunswick Karen Demers, Brunswick Eliza Donoghue, Brunswick Rae Duval, Brunswick John Fischer, Brunswick Bruce Found, Brunswick Neil Gallagher, Brunswick Susan Goodwin, Brunswick Mercedes Grandin, Brunswick Gale Greenleaf, Brunswick Elizabeth Grobe, Brunswick Douglas Hardy, Brunswick Kevin Hart, Brunswick L. Hart, Brunswick John Harte, Brunswick Betty Hartley, Brunswick Valerie Heath, Brunswick Michael Hetzel, Brunswick Sandra Hodge, Brunswick Robert Howe, Brunswick Leslie Hunt, Brunswick Barbara Kantner, Brunswick Sandra Kauffman, Brunswick Monika Kirtland, Brunswick Diane Knoop, Brunswick Bruce Kohorn, Brunswick Susan Kohorn, Brunswick William McCullough, Brunswick Leo Menard, Brunswick Richard Mersereau, Brunswick Scott Overbey, Brunswick Elisabeth Paige, Brunswick Rosalie Paul, Brunswick Elizabeth Pierson, Brunswick Martha Post, Brunswick Stephen Prescott, Brunswick Nat Rathbone, Brunswick Michelle Rudgers, Brunswick 18 Susan Russell, Brunswick Jean Shaw, Brunswick Jennifer Sherwood, Brunswick Peter Simmons, Brunswick Chris Simonson, Brunswick Gordon Smith, Brunswick Priscilla Smith, Brunswick alida snow, Brunswick Bette Spettel, Brunswick Sue Stableford, Brunswick Charles Strauss, Brunswick Mary Lee Ward, Brunswick David Webbert, Brunswick Susan Webbert, Brunswick Susan Weems, 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David Dodson, Camden Lyn Donovan, Camden Gretchen Ebbesson-Keegan, Camden Heather Ellsworth, Camden Laura Evans, Camden Judith Gove, Camden Anthony Grassi, Camden Sally Grassi, Camden Nancy Jenkins, Camden Polly Jones, Camden Peter Kalajian, Camden Eileen Kurtis-Kleinman, Camden Kristen Lindquist, Camden Nancy Linkin, Camden Pamela MacBrayne, Camden Judi Macomber, Camden Barbara Malone, Camden Carol Miller, Camden Denis Moonan, Camden Jessica Neves, Camden Elizabeth O'Connor, Camden Barb Ohland, Camden Steva Parkman, Camden Bridget Qualey, Camden Michael Remsen, Camden Petra Remsen, Camden Denyse Robinson, Camden Bonnie Rukin, Camden Amy Russell, Camden Ken Russell, Camden Amy Smereck, Camden Linda Spicer, Camden Robert Tassi, Camden Jan Warren, Camden Candi Soll, Canaan Sharon Balzer, Cape Elizabeth Julia Beckett, Cape Elizabeth Anna Brogan, Cape Elizabeth Becky Brosnan, Cape Elizabeth Joan Carrier, Cape Elizabeth Jan Chapman, Cape Elizabeth Bettye Ridge Davies, Cape Elizabeth Claudia Dricot, Cape Elizabeth Barbara Egan, Cape Elizabeth tracy floyd, Cape Elizabeth Sarah Gabrielson, Cape Elizabeth Madeleine Garmey, Cape Elizabeth Wendy Keeler, Cape Elizabeth Bill Laverty, Cape Elizabeth Eric Matheson, Cape Elizabeth Mary McVey, Cape Elizabeth Nancy Miles, Cape Elizabeth Walden Morton, Cape Elizabeth Tony Owens, Cape Elizabeth Susan Payne, Cape Elizabeth Gail Rowe, Cape Elizabeth Mitch Sheldon, Cape Elizabeth Tim Soley, Cape Elizabeth Nina Trowbridge, Cape Elizabeth Carey Armstrong-Ellis, Cape Neddick Jasw Deperrio, Cape Neddick Karen McElmurry, Cape Neddick Theresa Neill, Cape Neddick Emilia Pepen, Cape Neddick Erik Howell, Cape Porpoise Sandra Huck, Caribou Darlene Martin, Caribou Sandra Watson, Caribou Steve Allen, Carmel Barbara Baeslack, Carmel Andrea O'Neill-Knarr, Carmel Ilsa Shulman, Carmel Renata Camenzind, Casco Meredith Morehouse, Casco Anne Toepker, Casco Jackee' Wurslin, Cascot John Albertini, Charleston Joan Morrison, Charleston Leonard Passano, Chebeague Island Benjamin Yosua-Davis, Chebeague Jani Clark, Chelsea Wayne Kostiw, Chelsea Cassie Nixon, Chelsea 19 Don Bush, Cherryfield Trevor Dinsmore, Cherryfield Claiew Hanlon, Cherryfield Patricia Olsen, Cherryfield Sharon Perry, Cherryfield Judy Rawlings, Chesterville Heidi Holloway, Cliff Island Faith Rawding, Cliff Island Teresa Montague, Clifton Linda McGraw, Clinton Justin Blomgren, Columbia Margie Gilbert, Corinna Nick Kondax, Corinna Scott Cecil, Cornish Patrick Harrigan, Cornish Theressa Harrigan, Cornish Robert Tims, Cornish Allison Collins, Cumberland Nancy Artz, Cumberland Center Rose Bradshaw, Cumberland Center Emily Gray, Cumberland Center Dudley Greeley, Cumberland Center Kathleen Harper, Cumberland Center Sue Hartman, Cumberland Center Gordon McGriff, Cumberland Center Patrice Miller, Cumberland Center Christina Mitchell, Cumberland Peter Rubins, Cumberland Center Ayres Stockly, Cumberland Center Becky Warnock, Cumberland Center Jean Woodward, Cumberland Center Nancy Anderson, Cumberland Foreside Susan Curtis, Cumberland Foreside Dale Gowen, Cumberland Foreside Stephen Heinz, Cumberland Foreside Sarah Lakeman, Cumberland Foreside Kathleen Zambello, Cumberland Foreside Stephen Heddericg, Cushing Alan Magee, Cushing Pat Ryan, Cushing David Vickery, Cushing William Bausch, Damariscotta Jennifer Begin, Damariscotta Chris Elliott, Damariscotta Michele Fink, Damariscotta Gabrielle Grunkemeyer, Damariscotta Carol Higley, Damariscotta Sharon Keisch, Damariscotta Patricia Krebs, Damariscotta Joan Panek, Damariscotta Andrea Parker, Damariscotta Bruce Rockwood, Damariscotta Bailey Romaine, Damariscotta Cecily Warren, Damariscotta John Weinrich, Damariscotta Leslie Carr, Deer Isle Darwin Davidson, Deer Isle Jacqueline Davidson, Deer Isle Richard Esten, Deer Isle Maureen Farr, Deer Isle Marion Foss, Deer Isle Candace Hall, Deer Isle Ann Hooke, Deer Isle Roger Hooke, Deer Isle Herman Kidder, Deer Isle Marcia Kola, Deer Isle Karen Lester, Deer Isle Frederica 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Steven Smith, East Millinocket M Leach, East Waterboro Lora O`Rourke, East Waterboro Kathleen Molatch, Eastbrook Thomas Millay, Eastport Oliver Pratt, Eastport Anne Burt, Edgecomb Forrest Carver, Edgecomb D. Santillo, Edgecomb Rebecca Schaffner, Edgecomb Margaret Schuler, Edgecomb Lee Cooper, Eliot Mary Marcinkowski, Eliot Richard Moore, Eliot Jeff Volk, Eliot A Anonymous, Ellsworth Martha Dickinson, Ellsworth Marti Flint, Ellsworth Nicole Grohoski, Ellsworth Ryan Hartley, Ellsworth Treasure Murphy, Ellsworth Kathie Petrie, Ellsworth Wayne Simmons, Ellsworth Christopher Spruce, Ellsworth Mary Turner, Ellsworth 20 Mark Whiting, Ellsworth David Woolsey, Ellsworth Jacqueline Grohoski, Ellworth David Evans, Embden Gerald Michaud, Embden Debbie Bartlety, Exeter Laura Sholtz, Exeter Dawn DiBlasi, Fairfield Al Dyer, Fairfield Bonnie Dyer, Fairfield David Easton, Fairfield Ed Griffith, Fairfield Dawn Wilbur, Fairfield Corrine Adamowicz, Falmouth Michael Blake, Falmouth Betsy Bradford, Falmouth Bren Cagle, Falmouth Jack Chellis, Falmouth Alexander Clark, Falmouth Thomas Czyz, Falmouth Laura Fuller, Falmouth Lillian Harris, Falmouth Susan Howe, Falmouth Jennifer Jones, Falmouth Emily Kopans, Falmouth David Leonard, Falmouth Anita Liou, Falmouth Bente Lundh, Falmouth Robert Margiloff, Falmouth Patricia L. Ritzo, Falmouth Brian Russell, Falmouth Doris Salzman, Falmouth Nancy Lee Snow, Falmouth Barron Stallman, Falmouth A. Stockly, Falmouth Annette Waterman, Falmouth David Wilcock, Falmouth Sue Kistenmacher, Farmingdale Renee Page, Farmingdale Richard Page, Farmingdale Lucy Poland, Farmingdale Patricia Aishton, Farmington Richard Aishton, Farmington Andrew Barton, Farmington Jacob Bogar, Farmington Patricia Chick, Farmington Folger Cleaveland, Farmington Richard Fecteau, Farmington Sylvia Howes, Farmington Willena Jennings, Farmington Sandra Keith, Farmington John Murray, Farmington Donna Wheeler, Farmington Fred Jackman, Fayette Linda Pudder, Fletchers Landing Twp Valerie Walker, Frankfort Kelly Scott, Franklin Medea Steinman, Franklin Glen Bridges, Freedom April Turner, Freedom Rhoda Waller, Freedom Passivhausmaine .Org, Freeport Jane Baxter, Freeport Pam Blake, Freeport Scott Burrill, Freeport Maryellen Carew, Freeport Leland Chisholm, Freeport Beth Edmonds, Freeport Kimberly Haynes, Freeport Kristy Johnson, Freeport Vicki Kilborn, Freeport Robert Lyman, Freeport Russell Martin, Freeport Kristy McKibben, Freeport Jess Moore, Freeport Robert Moore, Freeport Mary Mraz, Freeport Randy Mraz, Freeport Dan Nickerson, Freeport Theresa Oleksiw, Freeport Josh Olins, Freeport Kate Olson, Freeport Cristina Post, Freeport Sukie Rice, Freeport N David Semon, Freeport Kristen Sheehy, Freeport Kay Sullivan, Freeport Caroline Thorne-Lyman, Freeport Ian Toal, Freeport Chris Uraneck, Freeport Shri Verrill, Freeport Mary Wade, Freeport Jesse Weyl, Freeport Suanne Williams-Lindgren, Freeport Peter Christine, Frenchboro Mary Ann Brown, Friendship Thomas Byrne, Friendship Richard Nelson, Friendship Donna Rock, Friendship Cynthia J. Alden, Fryeburg Susan Meeker-Lowry, Fryeburg Ralph Smith, Fryeburg Kate Buehner, Gardiner Elizabeth Cuprak, Gardiner Stacy Ladner, Gardiner Clare Marron, Gardiner Terri Lynn Pulley, Gardiner Richard Rambo, Gardiner Karin Sargent, Gardiner Donald Strickland, Gardiner Karen Tucker, Gardiner Karen Wentworth, Gardiner A Bunn, Garland Kandie Cleaves, Garland Kevin Cleaves, Garland Peter Devine, Garland Elaine Thomass, Garland Chris Gosster, Georgetown James Madsen, Georgetown sandy maggied, Georgetown Charles Saufler, Georgetown Maureen Stanton, Georgetown David Tudor, Georgetown Michael White, Georgetown Jim McClymer, Glenburn Laurie Walton, Glenburn Nathan Broaddus, Gorham Karen Curtis, Gorham Kathleen Douglas, Gorham Ruth Kelly, Gorham Barbara Martin, Gorham Jack McCormack, Gorham Marla Stelk, Gorham Lisa-Jo Warren, Gorham Eileen Whynot, Gorham Susan Dickson-Smith, Gouldsboro 21 Holly Duesenberry, Gouldsboro Susan Smith, Gouldsboro Leah Cook, Grand Isle Jeff McEvoy, Grand Lake Stream Jean Adams, Gray Aaron Ames, Gray Jayne Chandler, Gray Jayne Chandler, Gray Genni Chandler-Jean, Gray Barbara Gauditz, Gray Valerie Razsa, Gray Anneliese Schultz, Gray Philip Sears, Gray Morgan Mayfair, Great Pond Bob Allison, Greene Memarie Christoforo, Greene Gary Dethlefsen, Greenville Paul Duclos, Greenwood Jesper Kruse, Greenwood Stacey Sandvoss, Greenwood Elizabeth Betit, Hallowell Nancy Bixler, Hallowell Harold Booth, Hallowell Deborah Fahy, Hallowell Erika Johnston, Hallowell Beth Jones, Hallowell Caroline Karnes, Hallowell Deb Sewall, Hallowell Mary Simpson, Hallowell Emmie Theberge, Hallowell Adam Turner, Hallowell Barbara Vellani, Hallowell Maggie Warren, Hallowell David Wood, Hallowell Jean Adamson, Hampden Michele Caitlyn-Strout, Hampden Katherine Carter, Hampden Bruce Cole, Hampden Roger Frey, Hampden Thomas Frey, Hampden Jim Larson, Hampden Megan Leach, Hampden Julia Mahon, Hampden Diane Miller, Hampden Sarah Novak, Hampden Douglas Poulin, Hampden Stephen Rideout, Hampden Kathryn Walsh, Hampden Caroll Marston, Hampden Highlands David Johnston, Hancock Stephen Weber, Hancock Ben Alford, Hanover Lisa Jae, Harborside Tina Brierley, Harmony Maggie Strickland, Harmony Sarah Armstrong, Harpswell Mary Brennan, Harpswell Lynette Breton, Harpswell L. 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Betts, Industry Sharon E. Betts, Industry Laura Farnsworth, Island Falls Lauren Bruce, Islesboro Linda Gillies, Islesboro Marjorie Mills, Islesboro Peggy Pike, Islesboro Langhorne Smith, Islesboro Jennifer West, Islesboro Jayne Costa, Jay Alison Gingras, Jay Stephanie Labrecque, Jay Bruce Stevens, Jay Joanne Cook, Jefferson Carol Howell, Jefferson Donald Johnston, Jefferson Suzanna Lasker, Jefferson Eileen Lewandowski, Jefferson Jon Olsen, Jefferson Laura Sullivan, Jefferson Barbara Zucchi, Jefferson Lisa Noreen, Jonesport Philip Browne, Kennebunk Sheila Bukowski, Kennebunk Claire Doheny, Kennebunk Emily Fontaine, Kennebunk Jim Foyles, Kennebunk 22 Andrea Kimmich, Kennebunk William Paige, Kennebunk Janet Perry, Kennebunk Chris Smith, Kennebunk Cynthia Smith, Kennebunk Jacqueline Wilson, Kennebunk Juliet Altham, Kennebunkport Robert Collins, Kennebunkport Denise Deschenes, Kennebunkport Waylon Holbrook, Kennebunkport Susan Inoue, Kennebunkport Larry Landau, Kennebunkport Carol Lane, Kennebunkport David Manyan, Kennebunkport A. 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Todd Hoffman, Lebanon Wendy Wentworth, Lebanon Ginger Martin, Lee Kenneth Dickey, Leeds Richard Fochtmann, Leeds Christopher Trider, Leeds Shawn Kimball, Levant Janet Allen, Lewiston Deborah Burd, Lewiston Steven Dubois, Lewiston George Fiske, Lewiston Evan Gilbert, Lewiston Julia Gordon, Lewiston Julia Harper, Lewiston Lynn Moore, Lewiston Nancy Orr, Lewiston Brian Pickett, Lewiston Alicia Rea, Lewiston Bryant Richardson, Lewiston Dana Rickman, Lewiston Catherine Singleton, Lewiston Hannah Slattery, Lewiston Landon Smith, Lewiston Sophia Thayer, Lewiston Tom Twist, Lewiston William Wallace, Lewiston Ted Walworth, Lewiston Emma Wheeler, Lewiston Blake Whitaker, Lewiston Elise Brown, Liberty Richard King, Liberty Richard King, Liberty Bob Kohl, Liberty Diane Messer, Liberty Louis Pelletier, Liberty Sara Salley, Liberty Dixie Searway, Limerick Victor Wakefield, Limerick Richard Jarrett, Limington Mary Lawrence, Limington Kimberley Ackerman, Lincolnville Jessica Decke, Lincolnville Cynthia Dunham, Lincolnville Jean English, Lincolnville Josh Gerritsen, Lincolnville Douglas Grant, Lincolnville Gary Gulezian, Lincolnville Jane Hardy, Lincolnville Dryw Hunt, Lincolnville Arlene Jurewicz-Leighton, Lincolnville Jane Kurko, Lincolnville Laura Mantello, Lincolnville David McLean, Lincolnville Christina Philoon, Lincolnville Chris Polson, Lincolnville Janet Redfield, Lincolnville Sharon Sampson, Lincolnville Diana Sanderson, Lincolnville Susan Silverio, Lincolnville Abby Stocks, Lincolnville Lynn Tauss, Lincolnville Michelle Terry, Lincolnville Priscilla Thomas, Lincolnville Janet Veditz, Lincolnville Kathleen Williams, Lincolnville Dudley Zopp, Lincolnville Greta Zorn Gulezian, Lincolville Linwood Crosby, Lisbon Gregory Mann, Lisbon Nancy Ridley, Lisbon Kristi Clifford, Lisbon Falls David Gay, Lisbon Falls Karen Gay, Lisbon Falls Gifford Jenkins-Davis, Lisbon Falls Jean E Litchfield, Lisbon Falls Jill Spencer, Lisbon Falls Dale Berry, Litchfield Diane Clay, Litchfield Mary-Jo Foley, Litchfield Ann Gosline, Litchfield Jeffrey Lipton, Litchfield Dawn Pushard, Litchfield Gerald Rodman, Litchfield Andrew Rosenthal, Little Deer Isle 23 Jeff Titon, Little Deer Isle Deanne Urmy, Little Deer Isle Ann Van Buren, Little Deer Isle Tom van Buren, Little Deer Isle Douglas E. 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Monmouth Andy Smith, Monmouth Rebecca Stanley, Monmouth Norman Thombs, Monmouth Tina Barrett, Monroe Noami Brautigam, Monroe Joan Cheetham, Monroe Braden Gow, Monroe Rachel Norgang, Monroe Greg Purinton-Brown, Monroe Duke Tomlin, Monroe Marjorie Walsh, Monroe Katherine Wilkin, Monroe Tom Boothby, Montville Sarah Troutman, Montville Ed Wynn, Montville Joan Bromage, Mount Desert Jaki Erdoes, Mount Desert Penelope Evans, Mount Desert David Macdonald, Mount Desert Ignacio Pessoa, Mount Desert Caroline Pryor, Mount Desert Hannah Faulkner, Mount Vernon Carl Rogers, Mount Vernon Melissa Romac, Mount Vernon Deborah Stahler, Mount Vernon Karen Woodcock, Mount Vernon Sandra Wright, Mount Vernon Rachel Allen, Naples Beverly Krainin, Naples Nancy Kristiansen, Naples Sandra Merlim, Naples Thomas Wreck, Naples Penelope Hilton, New Gloucester Patricia Morris, New Gloucester Michael Pelletier, New Gloucester Lenore Sivulch, New Gloucester Kathryn Armstrong, New Harbor Nancy Dickinson, New Harbor Jeanne Hathaway, New Harbor Henry Newhouse, New Harbor Gail Ruwe, New Harbor John Stolecki, New Harbor Stephen Gorr, New Portland Jeff Brown, New Sharon Henry Washburn, New Sharon Julie Cyr, New Sweden Nancy Adams, Newcastle Dave Carpenter, Newcastle Michael Devin, Newcastle Leonard Duffy, Newcastle Adele Gale, Newcastle Anne Geisler, Newcastle Zanda Gutek, Newcastle Cecile Horowitz, Newcastle Marfie Lavendier, Newcastle David Merrill, Newcastle Alex Obregon, Newcastle Julia O'Brien-Merrill, Newcastle Olga Oros, Newcastle Erin Rhodes, Newcastle Dana Tavares, Newcastle Jeffrey Guesman, Newport Nancy Babcock, Newry Ken Hotopp, Newry Anthony Lawless, Newry David Walker, Newry Steve Wight, Newry Christine Ruffley, Noblebore Sharon Abair, Nobleboro Dru Barkalow, Nobleboro Robert Barkalow, Nobleboro Louise Riley, Nobleboro Jonathan Smith, Nobleboro Betty Welt, Nobleboro Deb Wilson, Nobleboro MaryAnn Anderson, Norridgewock Kristina Gossman, Norridgewock 24 Sidney Smith, Norridgewock Harriett Varney, Norridgewock Sandra Wright, North Anson Julie Fernee, North Berwick Lynn Manley, North Berwick Robert Pelletier, North Berwick Pat Seavey, North Berwick Jon Emerson, North Haven David Mckechnie, North Haven Eric Bigelow, North Waterboro Susan Conley, North Yarmouth Kathleen Conrad, North Yarmouth Amy Eshoo, North Yarmouth Elaine Fletcher, North Yarmouth Michael Fletcher, North Yarmouth Brian Goldburg, North Yarmouth Cindy Guernsey, North Yarmouth Stew Guernsey, North Yarmouth Patty Langkopf, North Yarmouth Ken Lanik, North Yarmouth Joshua McHenry, North Yarmouth Linda Routhier, North Yarmouth Scott Routhier, North Yarmouth Kristen Stetson, North Yarmouth Karen Strattard, North Yarmouth Robert Taisey, North Yarmouth Mary Ellen Tetreau, North Yarmouth Gordon Beck, Northeast Harbor Francis Minot Weld,Northeast Harbor Lisa Abbott, Northport Judy Berk, Northport Curt Bovee, Northport Mary Brown, Northport Deborah Eversage, Northport Elizabeth Grant, Northport Todd Hall, Northport Gayle Koyanagi, Northport Barbara O'Brien, Northport Paul Sheridan, Northport Johanna Strassberg, Northport Deborah Tonner, Northport Cory Upton, Northport Beth Whitten, Northport Joan Beal, Norway Janice Cardoza, Norway Albert Judd, Norway Ruth McAllister, Norway Richard McSherry, Norway Lynne Schott, Norway Glenn Tikkanen, Norway Ben Woodard, Norway Jewel Currie, Oakland James Easton, Oakland Bridget Gehrlinh, Oakland Ann Grant, Oakland Michael Grant, Oakland Andrew Mitchell, Oakland Linda Woods, Oakland Denise Larsen, Ogunquit Pamela Anderson, Old Orchard Beach Judy Bullard, Old Orchard Beach Diane Dion, Old Orchard Beach Beverly Dwyer, Old Orchard Beach Robert Fox, Old Orchard Beach Kathleen Gannon, Old Orchard Beach Cris Johnson, Old Orchard Beach Avis Landaw, Old Orchard Beach scott OBar, Old Orchard Beach Janet Ordway, Old Orchard Beach Laurie Thompson, Old Orchard Beach Amy Baron, Old Town Cheryl Daigle, Old Town Mary Dolan, Old Town Carol Gregory, Old Town Jeannine Hashey, Old Town Virginia Nees-Hatlen, Old Town Judith Noonan, Old Town Bryan Wells, Old Town Carolyn Bennatti, Orland Tacy Dorr, Orland Wayne Mayo, Orland Rosalani Moore, Orland Kyle Reynolds, Orland Christine West, Orland Carol Gorecki, Orneville Twp David Blodgett, Orono Ronald Davis, Orono Shirley Davis, Orono Irja Frank, Orono David Frankel, Orono Nancy Hall, Orono Leslie Hudson, Orono Roger King, Orono Jason Langley, Orono Albert Larson, Orono A Theodate Lawlor, Orono Laura Lommler, Orono Ian Maddaus, Orono Steve Philbrick, Orono Louise Small, Orono William Small, Orono Sharon Tisher, Orono Gail White, Orono Paul Wilson, Orono Marcel Bastide, Orrington Kerrie Damboise, Orrington B Todd, Orrington Jeanne Brooks, Orrs Island Robin Brooks, Orrs Island Garrick Johnson, Otisfield 25 Shawn Kane, Otisfield Linda Poto, Otisfield Lise Desjardins, Owls Head Jim Krosschell, Owls Head Sally Perkins, Owls Head Christopher Bezio, Oxford Norma Bisucla, Oxford Kevin R. Farr, Oxford Emily Foss, Palermo Richard Roughgarden, Palermo Barbara Kafka, Parkman John Flannery, Patten Nate Richardson, Patten Ann Cannon, Peaks Island Vicki Flanagan, Peaks Island Mary Anne Mitchell, Peaks Island Judith Nelson, Peaks Island Lisa M Penalver, Peaks Island Marina Penalver, Peaks Island Robert Villforth, Peaks Island Don & Linda West, Peaks Island Michael Hope, Pemaquid Mary Copper, Penobscot Marianne Vandiver, Penobscot Theresa Weigel, Penobscot Richard Giero, Perry Ronald Rosenfeld, Perry William Conley, Peru Samara Ebinger, Phillips Sylvia Lambert, Phillips Pamela Matthews, Phillips Debbie McCarthy, Phillips Charles Cummings, Phippsburg Rebecca Halbrook, Phippsburg Anne Heminway, Phippsburg Samuel Jones, Phippsburg Dot Kelly, Phippsburg Michael Levy, Phippsburg Robert Reyes, Phippsburg Christopher Sewall, Phippsburg Laura Sewall, Phippsburg L. 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Jean, Portland Robert Jeffrey, Portland Lesley Jones, Portland Judy Katzel, Portland Leslie Kaynor, Portland Morgan Kiser, Portland Dan Kolbert, Portland Victoria Kostadinova Bernard, Portland Denis Lachman, Portland maryann larson, Portland Ethan Lavendier, Portland Paul Ledman, Portland John Lemieux, Portland Loraine Lowell, Portland Karen Luse, Portland Paula MacVane, Portland Elizabeth Manduca, Portland Berry Manter, Portland Don Marietta, Portland Caitlin Marshall, Portland Chloe Maxmin, Portland Patricia McClure, Portland Elaine McGillicuddy, Portland Joe McGrath, Portland Harold McWilliams, Portland Marilyn McWilliams, Portland Judson Merrill, Portland Don Miller, Portland Laura Miller, Portland David Milligan, Portland Patricia Milligan, Portland Roger Milliken, Portland Alexander Mitchell, Portland Sally Moon, Portland Jackie Moreau, Portland Catharine Moser, Portland Mary Murphy, Portland Susan Nielsen, Portland Sally Oldham, Portland Caitlin O'Reilly, Portland Alice Osborn, Portland Erik Osborn, Portland Elizabeth Parsons, Portland Susan Pastore, Portland Gregory Pellerin, Portland Derek Pelletier, Portland Delene Perley, Portland Richard Peterson, Portland Michael Petit, Portland Jack Phillips, Portland Lisa Pierce, Portland Patricis Proulx-Lough, Portland Marlies Reppenhagen, Portland John Ritzo, Portland Stephen Robnett, Portland Nicholas Rosenblum, Portland Michael Roylos, Portland Ben Rubins, Portland Thomas Ryan, Portland Luette Saul, Portland Gretchen Scheibel, Portland Jenny Scheu, Portland Priscilla Skerry, Portland William Slavick, Portland Leonard Smith, Portland Mel Smith, Portland K Spahn, Portland Wanda Stahl, Portland Clara Steeves, Portland Richard Stevens, Portland Beth Stickney, Portland Robert Stoddard, Portland Susan Swain, Portland Emilie Swenson, Portland John Tabb, Portland Meg Thurrell, Portland Ann Tracy, Portland David Trafton, Portland Sally Trice, Portland Colleen Tucker, Portland Jennifer Tuemmler, Portland Susan Tureen, Portland Frank Turek, Portland R. Valentine, Portland F.R. Vance, Portland Chris Wall, Portland Tyson Weems, Portland Jane Weinstein, Portland Hattie Welch, Portland Jason Wentworth, Portland Carol Willauer, Portland Margaret Williams, Portland Baxter Wilson, Portland Polly Wilson, Portland Katharine Wojcik, Portland Margo Wood, Portland Kelly Worster, Portland Saras Yerlig, Portland Peggy York, Portland Zachary Zaitlin, Portland Madolynne Zimmerman, Portland Catherine DiPietro, Pownal Jeffrey Hicks, Pownal Judith Hopkins, Pownal M.Angela King-Horne, Pownal Jeannette Lovitch, Pownal Katherine Macleod, Pownal Meghan Metzger, Pownal Joan Mueller, Pownal Kirk Niese, Pownal Wendy Pollock, Pownal Joe Tucci, Pownal Danny Martin, Presque Isle Bonnie Wood, Presque Isle Gary Vencill, Prospect Richard Fisher, Prospect Harbor Teri Gerson, Prospect Harbor Robert Moody, Randolph Jeffrey Warren, Randolph Jane Weeks, Randolph Claudia Comstock, Rangeley Tamara Richel, Rangeley Vincent Richel, Rangeley Carol Sullivan, Rangeley Tom Sullivan, Rangeley Joanne 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Strauss, Rockland Susan Wind, Rockland Sarah Prindiville, Rockoprt Nikos Apollonio, Rockport Christie Banow, Rockport Amy Campbell, Rockport Marcia Dietrich, Rockport William Farland, Rockport Jean Matlack, Rockport Jim Payne, Rockport Teresa Randolph, Rockport Richard Remsen, Rockport Nancy Stevick, Rockport Craig Sweeny, Rockport Vicki Tracy, Rockport Peter Webb, Rockport Katrinka Wilder, Rockport Brian Willson, Rockport Susan Wright, Rockport Peter Kallin, Rome Peter Roderick, Rome Barbara Russell, Rome Marianne Masters, Round Pond Christopher Rheault, Round Pond Heather Clark, Roxbury Glen Deroche, Rumford Melissa Fallon, Rumford Thomas Fallon, Rumford Gabrielle Johnson, Rumford Lauren Spargo, Rumford Garett St. Pierre, Sabattus Eric Blow, Saco Michael Cassidy, Saco Carolyn Curtis, Saco Danielle Deason, Saco Drew Dumsch, Saco Kathryn Garrity, Saco Marilyn Ives, Saco Lawrence Marshall, Saco Lisa Petit, Saco Sharon Robinson, Saco David Timmerman, Saco Diane Whitmore, Saco Linda 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Cove Richard Smith, Seal Cove Sydney Rockefeller, Seal Harbor Carly Weinberg, Seal Harbor Sara Adams, Searsmont Martin Bartlett, Searsmont Charles Leroyer, Searsmont Sadie Samuels, Searsmont Lynn Cottrell, Searsport Phyllis Rackliffe, Searsport Lisa Ripley, Searsport Colin Sarsfield, Searsport Lauren Schweikert, Searsport Rebecca Tripp, Searsport Janet Williams, Searsport Octavia Brown, Sebago Ann Phillips, Sebago Kathleen Quintero, Sebago Christine Welsh, Sebec Lynn Carroll, Sedgwick Peter Collier, Sedgwick Tom Goodman, Sedgwick Rebecca Pease, Sedgwick Jennifer Trowbridge, Sedgwick Carolyn Waite, Sedgwick Parker Waite, Sedgwick Diana Garry, Shapleigh 28 Carole Mahoney, Shapleigh Judi Reis, Shapleigh Lorraine Duffy, Sherman Cynthia Buschmann, Sidney Keith DuBois, Sidney Tom Vigue, Sidney Troy Arbogast, Skowhegan Donna Conkling, Skowhegan Linda Hoyt, Skowhegan William Reid, Skowhegan Mark Roman, Solon Lisa Savage, Solon Christopher Johnson, Somerville valarie johnson, Somerville Claire 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Portland Tyler Gleason, South Portland Thomas Glendon, South Portland Robert Harlow, South Portland Joe Hemes, South Portland Joan Herzog, South Portland Anna Hewitt, South Portland R. Anton Hoecker Ii, South Portland Peter Ingram, South Portland Jamien Jacobs, South Portland Thomas Keller, South Portland Heather Kelly, South Portland Dorothy Kosinski, South Portland Rachel Lerose, South Portland Patricia Macdonald, South Portland Catherine Merrow, South Portland Patricia Mew, South Portland Jill Mullin, South Portland Nancy Murray, South Portland Jennifer Nielsen, South Portland Betsy Parsons, South Portland Marby Payson, South Portland Eva Platt, South Portland Rory Platt, South Portland Alix Pratt, South Portland Robert Pratt, South Portland Gregg Raymond, South Portland Patty Renaud, South Portland Lois Seewald, South Portland Karen Silverman, South Portland lucie Springman, South Portland Donna Thompson, South Portland M. Ward, South Portland Bethany Woodworth, South Portland Mark Zema, South Portland Anastasia Alley, South Thomaston Sarah Baldwin, South Thomaston Patrick Florance, South Thomaston Tom Goettel, South Thomaston Arthur Karker, South Thomaston Carl Leonardi, South Thomaston Vivian Newman, South Thomaston Roger Christie, Southport Lauren Stockwell, Southport Jodie Aragona, Southwest Harbor Betsey Bess, Southwest Harbor Jan Church, Southwest Harbor Marjorie Monteleon, Southwest Harbor Terry Powers, Southwest Harbor Jim Vekasi, Southwest Harbor Tammy Welch, Southwest Harbor Susan Whitby, Southwest Harbor John Moore, Springfield Stephen Blaisdell, Springvale Joshua Dracup, Springvale John McAdam, Springvale Jean Noon, Springvale Aleen Thomas, Springvale Meredith Walton, Springvale Susan Ellis, Spruce Head Peter Hill, Spruce Head 29 Amy ODonnell, St. George David Daniels, Standish Jodee Davidson, Standish Christina Dupuis, Standish Herman Lerner, Standish Lisa Magnacca, Standish Sandra Magnacca, Standish Elizabeth Phipps, Standish Janet Ray, Standish Michele Winterberg, Standish Peter Cook, Starks Kelly Roubo, Steep Falls Peter Starostecki, Steep Falls Christy Ayers, Steuben William Collins, Steuben Laura Doble, Steuben Peggy Drake, Steuben Donna Salisbury, Steuben David Struck, Steuben Sarah Winne, Steuben Donna Gold, Stockton Springs Valerie Haskins, Stockton Springs Ann-Marie Oberholtzer, Stockton Springs Jm Payne, Stockton Springs Lorna Russell, Stockton Springs Elizabeth Smith, Stockton Springs Bruce D. 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Elaine Kurtz, Topsham Ronald Kurtz, Topsham Victor Langelo, Topsham Jeanette MacNeille, Topsham Arthur Mary, Topsham Stanley Moody, Topsham K Olson, Topsham Sam Saltonstall, Topsham Michael Timberlake, Topsham Jay Westra, Topsham Nick Whatley, Topsham Ann Williams, Topsham Linda Wilson, Topsham Ellen Wood, Topsham Bruce Cassaday, Trenton Michael Gilmartin, Trenton Starr Gilmartin, Trenton Edward Lyon, Trenton Marcia Chaffee, Trescott Twp Daniel Halter, Trescott Twp Heidi Herzberger, Trescott Twp Peter Felsenthal, Trevett Bill Hammond, Trevett Jennifer Litchfield, Trevett Richard Montana, Troy Trish Stevens, Troy Kent Thurston, Troy Judith Reed, Turner Shannon Burns, Union Donna Busch, Union Gail Copeland, Union Jon Ellis, Union Jamie Gillette, Union Sharon McDermott, Union Joseph Skalecki, Union Diana Avella, Unity Charles Cinnamon, Unity Kelly Desrosiers, Unity lyn grotke, Unity James Huntsberger, Unity William Wade, Unity Nancy Zane, Unity Harry Bonish Sr., Vassalboro Eve Foley, Vassalboro Art Kingdon, Vassalboro Jessica Madison, Vassalboro Randy Trahan, Vassalboro Teri Attean, Veazie Claire Mooney, Veazie Linda Swackhamer, Veazie 30 Mick Bransky, Vienna Martha Floyd, Vienna Meghan Willing, Vienna Norma Wing, Vienna Jackson Gregory, Vinalhaven Britta Lindgren, Vinalhaven Penelope Lord, Vinalhaven Linnell Mather, Vinalhaven Adam Osgood, Vinalhaven Margaret Qualey, Vinalhaven Dwight Quayle, Vinalhaven Peter Richards, Vinalhaven Carol Bullock, Waldo Susan Lauchlan, Waldo Sadie Lloyd, Waldo Ann Marshall, Waldo Trisha Rose, Waldo Sonya Skoog, Waldo Dozier Bell, Waldoboro Kathleen Cartwright, Waldoboro Dylan Cookson, Waldoboro Melani Darrell, Waldoboro Melani Darrell, Waldoboro Chris Davis, Waldoboro Tatyana Eckstrand, Waldoboro Jane Farlow, Waldoboro Stephen Gorry, Waldoboro Allison Lakin, Waldoboro Albert Maloney, Waldoboro Natalie Masse, Waldoboro Janet McMahon, Waldoboro Sarah Mismash, Waldoboro Wayne Myers, Waldoboro Rod Niemeyer, Waldoboro alan sicard, Waldoboro Susan Simpson, Waldoboro Sue Thieme, Waldoboro Louann Thompson, Waldoboro Susan Valaitis, Waldoboro Linda Veblen, Waldoboro Kyle Lincoln, Walpole Bill Mook, Walpole Scott Barrows, Warren Barrie Brusila, Warren Katherine Holland, Warren Lynne Tallberg, Warren Lisbeth Whitney, Warren Judith Boudman, Washburn Amy Donaghy, Washington Jean Feldeisen, Washington Neil Gross, Washington Charlotte Henderson, Washington Karen Jelenfy, Washington Gail Neptune, Washington David Anderson, Waterboro Ruth Buck, Waterboro Christopher Easton, Waterford Mary Ann Holme, Waterford Anita Long, Waterford Donna McCarraher, Waterford Earl Morse, Waterford Eliza Baker-Wacks, Waterville Matt Connolly, Waterville Sally Harwood, Waterville Susan Hillman Bourne, Waterville Sophie Janeway, Waterville Steve Kahl, Waterville William Kapaldo, Waterville Michael Leggett, Waterville Elizabeth Levesque, Waterville Carolyn MacRae, Waterville Ellen Maier, Waterville Kyle Marrache, Waterville Ronnie Marrache, Waterville Gregory McLaughlin, Waterville Janine Moore, Waterville Sylvia Niles, Waterville Stuart Silverstein, Waterville Eric Walton, Waterville Leslie Burhoe, Wayne Jennifer Dox, Wayne Daniel Omalley, Wayne David Stevenson, Wayne Joan Braun, Weld Michele Jeffrey, Weld Susan Angelakis, Wells Kaitlyn Bennett, Wells Dorotea Marisa Caputo, Wells Mary Crace, Wells Joseph Hardy, Wells Monique Libby, Wells Cheryl Mills, Wells Jamie Reynolds, Wells Richard G. Robertson, Wells P Santoro, Wells Tammy Williams-Dufort, Wells Nathaniel Hyde, West Bath Louise Janelle, West Bath Stephen Moriarty, West Bath Victoria Pilgrim, West Bath Mary Ellen Wilson, West Bath Norm Greenberg, West Bethel Kevin O'Reilly, West Bethel Laurie Fenwood, West Enfield Rachael M Rollson, West Gardiner Joshua Rollson, West Gardiner Diane Lane, West Newfield Hilary Wallis, West Newfield Lee Dolleman, West Paris Sharon Dolleman, West Paris Ellen Gibson, West Paris Kathleen Grillo, West Paris John Rodes, West Paris David Walton, West Paris Lucie Bauer, West Rockport Heather Chandler, Westbrook Deborah Davidson, Westbrook Michael Diemond, Westbrook Martha Goodale, Westbrook Marjorie Kleibacker, Westbrook Warren Lain, Westbrook Ann Laliberte, Westbrook Cynthia Leblanc, Westbrook Heidi Michaels, Westbrook Taylor Smith, Westbrook David Travers, Westbrook Rowena Walton, Westbrook Andrew Woody, Westbrook Joan Yates, Westbrook Richard Barker, Westport Island Particia Mendes, Westport Island Seth Mirsky, Westport Island Drew Porter, Westport Island John Swanton, Westport 31 Island Janet Thompson, Westport Island Adam Webber, Westport Island Roger Baston, Whitefield Bambi Jones, Whitefield Max Katler, Whitefield Tony Marple, Whitefield Natasha Mayers, Whitefield Katherine Morse, Whitefield Stephen Pellecchia, Whitefield Kit Pfeiffer, Whitefield Kathi Sutton, Whitefield Karyn Townsend, Whitefield Jeffrey Harmon, Wilton Norman Hurlburt, Wilton Barbara O'Reilly, Wilton Bob O'Reilly, Wilton Nancy Prince, Wilton Joel Alder, Windham Sue Butler, Windham Daniel Comeau, Windham Rosanne Dombek, Windham William Keller, Windham Hilary Knott, Windham Rebecca Lockridge, Windham Priscilla Payne, Windham Barbara Peaslee, Windham Denise Varney, Windham Donna Walter, Windham Kellie Lapierre, Windsor Ann Carrigan, Winslow Paul Gregory, Winslow Walter Keene, Winslow Kayla Kimball, Winslow Bart Shattuck, Winslow Pauline Veilleux, Winslow Jason George, Winterport Donna M. Gilbert, Winterport Sarah McVeigh, Winterport S Beckwith, Winthrop Marc Chamberlain, Winthrop Jamie Hannum, Winthrop Priscilla Jenkins, Winthrop Emmanouil Karamousadakis, Winthrop Elizabeth McKenney, Winthrop Amanda Meader, Winthrop Cynthia Oakes, Winthrop Debra Richards, Winthrop Barbara Snowadzky, Winthrop Marty Fox, Wiscasett Douglas Henderson, Wiscasset Sam Selby, Wiscasset Kathryn Steed, Wiscasset Susan Van Alsenoy, Wiscasset Robin Buzzell, Woolwich Julie Erb, Woolwich Michael Fear, Woolwich Diane Gilman, Woolwich Delores Lake, Woolwich Erik Missal, Woolwich David Morton, Woolwich Jennifer Oddleifson, Woolwich Bonnie Raymond, Woolwich Emily Bates, Yarmouth Bill Carter, Yarmouth Susan Feiner, Yarmouth Jackson Hall, Yarmouth Linda Kozel, Yarmouth Becky Marvil, Yarmouth Isabella Pardales, Yarmouth Evelyn Rysdyk, Yarmouth Rebecca Sentementes, Yarmouth Kate Simpson, Yarmouth Mariana Tupper, Yarmouth Lisa Wilson, Yarmouth Mary Boardman, York Wayne Boardman, York Janice Cassidy, York Hilary Clark, York Laura Creagan, York Kassia Davies Decker, York Douglas Frazier, York Dennis Kepner, York Susan Kepner, York David Koorits, York Alan McDonald, York Kim Oates, York Michael Young, York Jim Bernstein, York Harbor Sherrill Fawcett, York Harbo 32