Massachusetts Utility Net Metering Cap

Hello Readers,

Earlier in this series, I described how utility net metering caps conflict with renewable energy installation goals. In this post, I will build upon the context established in the previous post about the Massachusetts Renewable Portfolio Standard (RPS), and I will explore the purpose of and issues with the net metering cap in Massachusetts.

To begin, let us consider the question: What is the purpose of capping net metering rules in the first place? There are two possible reasons why a net metering cap would have been introduced into the regulations: (1) there are physical safety concerns related to allowing significant percentages of net metered systems to interconnect or (2) utility companies lobbied for its introduction.

Safety Concerns with Net Metering

As I described in my graduate dissertation, the addition of a large percentage of intermittent renewable generation, such as solar and wind DG systems, has the potential to cause power quality problems on a non-smart utility grid. In other words, without sufficient demand response and/or energy storage capacity incorporated into grid, the modern utility grid infrastructure may not be able to handle large swings in power output (such as those that may be associated with changing wind speeds or clouds passing over a photovoltaic system) especially if intermittent renewable systems account for roughly 20% or more of a utility company's annual peak demand.

Even so, it is important to note that both DG-scale and large-scale (non-DG) intermittent renewable systems have the potential to cause physical stress on the utility grid infrastructure. In fact, the spikes and falls in production that can be problematic for the grid as a whole have a tendency to average-out across an aggregate of many DG systems, and therefore provide more stable grid voltages compared to a single large-scale system. Again, renewable DG systems should theoretically be favorable for the grid and provide a reason to encourage as much net metering as possible.

So, again, why put a cap on net metering? Understandably, no one wants huge swings in grid voltages to cause rolling brown-outs and damage to appliances, so perhaps a cap at 15-20% of the annual peak demand may be warranted if the grid is too 'dumb' to handle the input of renewable DG systems. However, in Massachusetts the cap has been established at 1% of annual peak demand for homeowners and businesses and at 2% of annual peak demand for municipalities and other government entities (for at total cap of 3% of annual peak demand).

National Grid's Net Metering Cap

National Grid’s historical peak load of 5,131 MWs occurred on August 2, 2006 in Massachusetts Electric territory; making the 1% limit 51.31 MWs and the 2% limit 102.62 MWs. As of July 5, 2012 in Massachusetts, there are 45,244 KWs with net-metering service under the 1% limit and 11,291 KWs with net-metering service under the 2% limit. As of July 5, 2012, there are 443,588 KWs with applications in the process of being interconnected under the 1% limit and of those 64,211 KWs have returned the Schedule Z.

Excerpt from National Grid Net Metering Website

Keeping in mind that 1,000 kW equals 1 MW, it is clear that, utility companies such as National Grid, already have more applications to interconnect net metered DG systems than they have room under their 1% private cap. This begs two questions:

• Why is there a larger set aside for public entities (i.e. a 2% cap for municipalities and other government entities) in Massachusetts?
• What is going to happen to all of the private entities that are applying to interconnect DG systems in Massachusetts?

As it turns out, the Massachusetts DPU is already arranging for the creation of a waiting list for entities attempting to interconnect DG systems after the cap limit is reached (see pdf). However, what good will this do if the net metering cap does not increase? The answer is appears to be little-to-no good at all.

Lobbying for a Net Metering Cap

Ostensibly, it is plausible that utility companies would have lobbied the state legislature on the issue in order to protect their profit margins. That is, logically, offering more net metering credits to DG system owners results in a proportionate decrease in the revenue that a utility company is able to collect, and therefore a proportionate decrease in profit margins. Thus, it would be equally logical in most cases for utility companies to lobby the legislature in support of a cap on net metering credits, thereby protecting utility company profit margins.

As I said, in most cases this would be logical, and in many states this may very well be the case. However, in Massachusetts in particular this makes very little sense due to a provision known as decoupling, which connects utility company profits with the number of customers served rather than the amount of electricity consumed.

Decoupling

The Department of Public Utilities (DPU) [...] issued an Order that will begin the process of "decoupling" rates from sales volume for all of the state's electric [...] distribution utilities, in order to encourage utilities to help their customers reduce their energy consumption and take advantage of on-site renewable energy, as required by the Green Communities Act, the comprehensive energy reform law [...] signed by Governor Deval Patrick. [E]lectric utilities will file rate plans that separate, or decouple, their sales of electricity [...] from the revenues they need to collect in order to maintain the electricity [...] distribution system they are responsible for. [...] Utilities are expected to file decoupled rate plans with the [DPU] as existing rate plans expire - for most companies, by 2012 - though companies can file sooner on a voluntary basis.

Excerpt from Mass DPU Press Release

Thanks to Massachusetts' implementation of decoupling, there is little-to-no direct financial incentive for utility companies to obstruct customers looking to take advantage of renewable DG systems. Under current regulations, utility company profits will remain the same regardless of how much electricity is consumed.

Unfortunately, I do not have the personal resources to thoroughly investigate the lobbying practices of the utility companies on this matter. However, given this understanding of decoupling, it is tough to imagine that utility companies would have invested much effort or money into lobbying in favor of a net metering cap.

Although, on a related note: in a personal, off-the-record discussion with an employee of a utility company, it was suggested that part of the reasoning behind the net metering cap may simply be a lack of qualified personnel. That is, in Massachusetts, which has only recently seen a significant private sector interest in renewable DG systems with the introduction of the Solar Carve-Out of the RPS, utility companies in Massachusetts do not have enough qualified staff to safely and responsibly handle the incoming interconnection requests in a timely manner.

A Possible Solution

To summarize, capping net metering may be providing utility companies some breathing room needed to retrain current staff and/or hire qualified staff. Likewise, it may also be providing the utility companies with an opportunity to figure out how to make the smart-grid smarter (i.e. better able to handle high percentages of intermittent renewable systems).

If either of the above justifications for a net metering cap are the case in Massachusetts, that ought to be made clear to the public and the policymakers. Also, instead of setting a single net metering cap, which provides homeowners and businesses no opportunity to make plans beyond the limits of the current cap, legislators should layout a growth schedule for the net metering cap.

This growth schedule should be clearly defined and - importantly - must lead the growth of the RPS goals by at least a year. If the net metering cap remains stagnant or does not out-pace the RPS in Massachusetts: DG installers, financiers, and potential DG system hosts will continue to be frustrated and delayed by an inability to plan ahead, which will be detrimental to everyone interested in meeting the RPS goals or holding a job in the green energy industry in Massachusetts.

Requiring the utility companies to increase the net metering cap at a pre-defined rate will offer everyone involved some project planning certainty. Also - if implemented correctly - a scheduled net metering cap increase will provide utility companies the incentive they need to safely and responsibly implement beneficial smart-grid technologies, which will improve grid efficiency and reliability regardless of the success of the RPS in Massachusetts.

Sincerely,

Sean Diamond

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