DC Solar owners were surprised this week to read a proposed new ruling by the DC Public Service Commission (PSC) requiring them to upgrade to a revenue-grade meter within the next year. This change would mean that current solar owners will need an equipment upgrade costing between $500-$600, and face the possibility of losing their SRECs if they do not comply.
DC PSC is only accepting comments on this new rule through the end of the week, so we must act quickly--if possible, please post your comments by the end of the day on Friday!
Here's a look at the reason behind the ruling—which in general terms we support, but would like to see implemented more fairly. We hope you'll submit comments to help ensure that the new rule does not cause undue burden to homeowners. You can scroll to the bottom to take action immediately or read on for more info.
Historically, DC solar owners with systems under 10kW were not required to prove their solar production amounts. Instead, their production was based on estimates provided by their installers. Obviously, solar production varies on a minute-by-minute basis depending on the weather, the age of your panels, whether everything is in good working order, how clean your panels are, and this list goes on. Clearly, estimated production will not be accurate, so implementing a way to measure actual production is, overall, a good thing.
But if solar owners can't do the upgrade to comply with this proposed rule, they could lose income from their solar production. As we know, your solar production generates not only renewable energy, but also valuable Solar Renewable Energy Credits (SRECs). For each 1,000 kilowatt-hours (kWh) of electricity your solar energy system produces, an SREC is created. An average DC residential solar installation at Ipsun is about 7kW. With a system of that size, you could generate roughly 10,000 kWh/year to create about 10 SRECs annually. In DC's SREC market, that's worth about $4,500 per year.
Why Ipsun Supports the New Rule in Principle: Climate Change
The main reason we support the rule change is the inaccurate accounting for renewable energy that's being placed on the grid. DC's Renewable Portfolio Standard (RPS) states that the district must have 1.85% of its energy come from solar in 2021, and that percentage grows incrementally to 5% in 2032. DC has one of the most ambitious RPS plans in the country, and we are saddened to see it diluted in this way.
The new ruling would ensure that solar producers keep their systems in good working order, and thus producing at maximum capacity. Even more important, it would also eliminate fraudulent reporting that games the system and makes us all pay by limiting our progress in the fight against climate change.
About That Fraud...
An active lawsuit (2019 CA 0000165 B) filed at Superior Court of the District of Columbia Civil Division alleges that bad actors have been registering systems with fraudulent azimuth and tilt readings that increase their estimated production, and therefore boosts their SREC generation. With SRECs worth about $450 apiece, the scale of this fraud is alleged to add up to about 8 million dollars.
But Here's the Problem: Equity
DC PSC is proposing that all solar owners under 10kw in size participating in the DC SREC market must have a revenue grade production meter or inverter-based production measurement equipment in order to qualify for DC SRECs. This solution is not logistically or financially feasible for many solar owners and will hit low-to-moderate income customers the hardest.
Many states across the country, particularly those with SREC markets, have requirements for production measurement. The difference with the DC PSC proposal is that the burden of the upgrade is not on the state or utility, but on the homeowners.
So while we support this rule change in theory, we think the PSC should take more time to think through ways to implement it in an equitable manner.
Ipsun supports the idea of allowing systems below 10kW to be counted with a non-revenue grade meter, which most systems will already have with typical inverters. This would account for generation more accurately than an arbitrary (or possibly fraudulent) estimate. The level of accuracy attained by revenue-generating meters should not be necessary for this use.
Enphase IQ Inverters are Already Compliant
It's important to note that the Enphase IQ inverters that Ipsun installs measure with 0.5% accuracy. Any Enphase inverter model with the Envoy built-in to the combiner box will be accurate to 0.5%. This is compliant with the proposed new requirements, so our customers with Enphase IQ inverters won't need to upgrade. Older versions may not be compliant--you can reach out to us with questions any time to ask about your specific situation.
Anyone thinking of going solar with Ipsun can also rest assured that it won't increase your cost of going solar, because Enphase is the only brand we install and any current or newer version will be compliant. That being said, we still encourage you to submit your comments to the PSC for the good of the solar community.
So what can I do?
Contact the Public Service Commission using its online form. Tell them why you support solar energy and want more of it in the District. If you have solar, tell the PSC how it has benefited you and your family and why you are concerned with rushing this ruling without public input. If you don’t yet have solar, tell the PSC why this rule would make it harder for you to do so.
Contact the Commission!
(Use case number RM29-2021-01-E)
Below is a sample message to give you a start. But please personalize your message as well.
While I support the proposed new rules in case number RM29-2021-01-E, I disagree with the implementation. I applaud the effort to accurately account for the amount of renewable energy on the grid so that DC's admirable RPS can be fulfilled. However, I do not agree with putting the burden to upgrade systems on homeowners. I believe there is a better way to accurately measure homewoners' production with their current non-revenue grade inverters.
We hope you can make time to click through and post your personal comments. You can see many of the comments that have already been submitted here. Thanks, as always, for being an important part of the Ipsun family and making our collective voices heard!
The Public Service Commission exists to protect the interest and trust of the public when it comes to utility regulation. This proposed rule would put an unfair burden on solar owners. I urge you to rethink the way this proposed rule will place an undue burden on homeowners.
Many states across the country have requirements for production measurement. The goal of these requirements is to ensure that Renewable Energy Credits are being counted correctly. This is a laudable goal. However, the D.C. PSC’s proposal unfairly puts the burden of making the upgrade on homeowners, not the state and/or the utility.
The PSC’s proposed rule is unfeasible for many solar owners. This is particularly true for those who have older systems. It will also make going solar more expensive in the District. This will impact less-well-off customers the hardest.
The PSC should consider a fairer solution. I think systems below 10kW should be allowed to be counted with a non-revenue grade meter, which most systems will already have with typical inverters. The level of accuracy attained by revenue-generating meters should not be necessary for this use.
I’m also concerned by the rushed nature of this entire process. The rule was proposed less than thirty days ago, in the middle of summer. There have not been, nor does the commission plan, any public hearings. The District homeowners who could be forced to pay to comply with this rule have not had an opportunity to properly weigh in.
Thank you for reading my letter and listening to my concerns. I appreciate your time.