Rager’s Comments in Response to Senate Bill 2371 Concerning Solar Renewable Energy Portfolio Standards

March 8th, 2012

Rager’s comments in Response to “An Act concerning solar renewable energy portfolio standards, energy efficiency and renewable energy and amending P.L.1999, c23.”  Submitted January 9, 2012

  • Renewable Energy Classification
    • Efforts to create requirements for different sized solar projects are welcomed. The large-scale solar industry is fundamentally different from the small residential industry. While language in the revised Bill places a ceiling on the allowed percentage set aside for systems under 20 kW, a floor percentage is also advisable.
  • Registration Program
    • A registration program for the purposes of ensuring power reliability is certainly appropriate so long as the administrative process is not overly burdensome and that information requested is reasonable.
    • Will unsatisfactory information submissions prevent a project from interconnecting and how will the EDCs be involved? What is the ultimate purpose of this registration process?
    • What purpose does the filing fee serve?
    • Is this related to Interconnection Fees?
    • Why was March 2012, Impact Study parameters arbitrarily chosen as the Grandfathered Date?  If selecting a date it should be Either Prior to January 2012 or “those who have entered the PJM “queue” and have an interconnection point of connect as scripted in the feasibility study as “PJM” states after you have a connection its yours to lose.  PJM has determined a project has a connection as stated in the first study “Feasibility”, not “Impact”.  The project owner runs con-currently with the remaining studies by submission to township, county and state agencies approval is to say as stated in the ASSEMBLY COMMITTEE SUBSTITUTE FOR ASSEMBLY, Nos. 4226 and 3731 per Impact study is not acceptable.
  • ITC
    • Efforts to supplement the 30% ITC at a state level should it not be extended is applauded.
  • Long-term Contracts
    • Long-term SREC contracts will certainly help developers and system owners obtain low interest financing for solar projects. The language in revised Bill is vague as to what percentage of the total GWhr requirement can be purchased under contract and what size facilities will be eligible for contracts.
    • The language needs to be explicit in how an electric public utility will offer contracts, to whom, at what price and for how long.
    • Will the “competitive process” be uniform throughout the state, or will utilities be able to devise their own process?
    • Would like to see 10MW and under offered
  • Public Utility Project Ownership
    • Efforts to monitor the impact of utility owned, SREC generating projects is applauded.
  • Revised SREC Schedule
    • The accelerated SREC schedule shows commitment to a robust solar industry in New Jersey
    • Parameters for adjusting the SREC schedule in the future are important.
  • Revised SACP Schedule
    • In combination with the ability to engage long-term contracts, the revised SACP schedule is reasonable.
  • COMMUNITY SOLAR  (Township’s Host)
    • Add Provision for Community Solar for the Municipalities who host the larger solar farms of systems ((A proposed solar facility that is greater than five megawatts in capacity)) of 5MW to 10MW within 5 miles of municipal consumer to have a bilateral agreement with generator to offer a 30% reduction of the town’s electric bill, which in effect will benefit the town, ratepayers and all parties:
      • When power is wheeled to town The EDC will charge fees according for the distribution, for example, .02 cent/kWh
      • SREC generating long-term contract to apply to their RPS
    • This should be the only Community Solar provision offered in the bill for providing a vehicle for the State to reduce taxes indirectly to the rate payers through offering the town the freedom to allow solar farms in their area to reduce budgets
    • This also will help and can be added to the efforts of the Sustainable Jersey Clean Energy Program

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