Testimony of Mark D. Sylvia, president of SEBANE before the Massachusetts Joint Committee on Telecommunications, Utilities and Energy, Delivered Tuesday January 30, 2018
Good afternoon Chairmen Golden, Barrett and members of the of the joint committee. My Name is Mark Sylvia, President of the Solar Energy Business Association of New England (“SEBANE”) and Managing Director of External Affairs for Boston based BlueWave Solar. Thank you for holding this hearing today to review the Department of Public Utilities’ recent order approving Eversource’s proposed minimum monthly reliability charge (“MMRC”) on new net metered solar customers.
SEBANE, representing over 50 member solar companies throughout Massachusetts and New England joined other solar advocates in opposing Eversource’s proposed MMRC before the Department of Public Utilities. The reasons for our opposition then, remain the same reasons we oppose the MMRC now.
First, the MMRC is inconsistent with the Solar Energy Act of 2016, an Act Relative to Solar Energy. Specifically, the MMRC excessively burdens ratepayers by creating a separate set of charges for those who adopt solar, particularly residential customers, who will now be burdened with thousands of dollars in new costs for their solar PV systems. This will in turn unreasonably inhibit the development of net metered facilities by creating a financial disincentive and confusion for those wishing to adopt solar. And Eversource did not demonstrate that the MMRC is designed to collect costs that solar customers cause but do not pay for.
Though Eversource had a cost study, there was no evidence that supported this assumption – in other words, Eversource offered no proof that costs to be collected through the MMRC were both uniquely caused by customers with solar and were not offset by benefits of those customers’ solar installations. So it is impossible to know whether the approved MMRC was actually consistent with the statute.
Second, the MMRC includes a mandatory demand charge, directed to residential and small C&I solar customers – making Massachusetts the only state to impose a mandatory demand charge on residential public utility customers in the United States. Not a distinction we should have or strive for.
Third, customers will incur this demand charge though their actual demand likely will not coincide with system peak demand, which is the problem we are all trying to address. As a result, the demand charge will not have the intended effect, which is to reduce overall system costs.
Fourth, Eversource has not provided smart meters to customers, so they won’t know what or when their actual peak demand is, so they can’t control their usage to moderate the demand on which they are charged.
So how will this affect your neighbor who wants to go solar? When an installer explains to them that they must pay a new charge that will increase the cost of their system by thousands of dollars depending on their consumption over the next 20 years – after they’ve already explained how the incentives work, and if they don’t get a smart meter, if they are cooking, doing laundry or running their air conditioning, their overall solar costs will go up, without the ability to determine when or how to reduce their demand. It’s confusing, it’s punitive and it seeks to specifically punish those who have invested their hard-earned money in reducing our reliance on fossil fuels.
Many of SEBANE’s members, including my own company BlueWave Solar and our customers will be negatively impacted by this MMRC. We would absolutely lose business. We are all working hard to make going solar a simple, fair and seamless process. The MMRC will negatively impact the choice we as a Commonwealth have worked so hard to provide to as many of our citizens as possible. Our industry is proud of the work we have done collaborating with the legislature and the executive branch over the past several years while working together to drive down the cost of solar from SREC I to SREC II to smart, to build the robust solar market that exists today in Massachusetts.
We now find ourselves at a crossroad. The solar industry will continue to do all we can to support the Commonwealth’s clean energy and climate goals while making access to solar more affordable. But with recent actions such a new federal tariff on imported solar cells and a change in the federal tax system impacting tax equity financing, this new MMRC has now made our shared goal even harder.
In light of the concerns raised by SEBANE and the collective testimony you will hear today from others in solar industry and beyond who share sebane’s concern about the MMRC, we ask that the legislature delay the implementation of the MMRC and clarify to the DPU your intent regarding the criteria that must be met before imposing a MMRC. Massachusetts has been a national leader in solar, the people of Massachusetts overwhelming support it – we must ensure that our policies reflect that.
Thank you for holding this hearing and listening to our concerns.