Joint Principles on Net Metering Reform in Connecticut Endorsed by: Acadia Center Ashford Clean Energy Task Force Citizens Campaign for the Environment Clean Water Action Connecticut Fund for the Environment Connecticut League of Conservation Voters Connecticut Roundtable on Climate and Jobs ConnPIRG Eastern Connecticut Green Action Efficiency for All Energy Efficiencies Solutions Environment Connecticut Joel Gordes, Energy Security Strategist Natural Resources Defense Council Northeast Clean Energy Council People’s Action for Clean Energy Portland Clean Energy Task Force The Alliance for Solar Choice The Nature Conservancy Sierra Club Vote Solar The endorsing organizations would like to express our concerns with the customer-sited solar proposals in the Department of Energy and Environmental Protection’s 2017 draft Comprehensive Energy Strategy (CES). We represent a diverse group of interests in Connecticut, including clean energy businesses, clean energy and environmental public interest groups, labor unions, and consumer advocates, all who oppose the proposed changes to net metering in the draft CES, particularly changes that would require two utility meters for residents and small businesses who install solar, one to measure gross generation from the solar unit and another to measure gross consumption on-site (“two-meter proposal”). Other solutions, described below, are possible to balance concerns about cost while respecting key rate design and public policy principles. We are happy to work with Connecticut policymakers on these important issues. The two-meter proposal, sometimes referred to as “buy-all, credit-all”, bills a customer’s gross consumption and credits a customer’s gross production at separate rates. This is in contrast to net metering, where a customer can reduce the amount of energy purchased from the grid when the energy is produced and consumed directly on-site. This lowers the customer’s bill at the retail rate for selfgenerated electricity. The two-meter proposal has numerous conceptual and practical flaws and should not be adopted. The only state in the country that has adopted this counterproductive two-meter approach is the Maine Public Utilities Commission under Governor Paul LePage.1 These flaws include:  Price discrimination against clean distributed generation – Clean distributed generation consumed directly on-site should be treated the same as reductions in demand from energy efficiency investment or conservation;  Violation of the right to generate, store, and consume your own clean energy – Customers should have the choice to be independent and the ability to use their own energy;                                                              1 The implementation of this policy has been delayed until 2018 because of uncertainty over who would bear the cost of additional utility expenses and the policy is still facing a judicial challenge: https://www.utilitydive.com/news/maine-net-metering-battle-heads-to-court/512771/. In addition, a bill to change this policy was passed by the Maine Legislature in 2017, but the House narrowly failed to override Governor LePage’s veto: https://www.utilitydive.com/news/maine-lawmakers-fail-to-overridegovernors-veto-of-solar-bill/448550/. December 22, 2017 1  Imperils future of smart homes with storage and energy management – Integration of clean distributed generation, storage, electric vehicle charging, and smart appliances is most efficiently done jointly through one meter that measures imports from and exports to the grid; and  Higher metering and billing costs - Requirement for two utility meters increases metering and billing costs. However, current policies can be substantially improved going forward. Numerous other reforms are possible to make solar incentive programs more cost-effective and improve the fairness and accuracy of compensation for distributed generation. Productive reforms must be consistent with key principles for rate design, as well as relevant policy goals. In the short term with existing metering, these reforms include:  Implementing monetary crediting and removing system benefit charges from net metering credit value;  Changes to rate design that send better price signals to customers, such as reflecting temporal cost causation, and address any proven and material cross-subsidies, in either direction, as shown by an independent and publicly scrutinized analysis; and  Continuing to improve the cost-effectiveness of the solar incentive programs and adjusting the overall mix of solar installations between rooftop, stand-alone distributed generation, and utilityscale projects. With additional analysis and improved metering, further reforms will be possible in the medium- and long-terms, including:  Moving to more granular netting periods (e.g., from monthly to time-of-use netting) when there is more granular pricing; and  Value-based credits for exports, taking into account long-run benefits and costs. The endorsing organizations look forward to continuing to work with the Department of Energy and Environmental Protection and the Connecticut General Assembly to find a path forward that promotes continued growth of solar and addresses key concerns about current policies. December 22, 2017 2