 So, good morning again, thank you for having us. Yeah, thank you for joining us. Good work, my name is Andrea Cohen. I'm with Vermont Electric Cooperative. I think we're good with technology, that's great. Good morning. For those of you who are not that familiar with VEC, we're a second largest utility in the state of Vermont. We're a member-owned, not-for-profit utility. And we're the whole northern part of the state. We go from the islands all the way to Canaan up to the Canadian border. In our primary interest is a non-profit utility, member of the utility industry, if I can manage this. Let's see, hold on. Oh, just scroll, okay. It's actually not, okay, it's a pack. Is, our primary goal is to make sure we're providing safe, reliable, cost-effective, and environmentally responsible electric service. And, you know, our service territory is very rural and it's very low income, where a lot of the state is rural and low income. Ours is particularly rural and low income. Almost 40% of our members aren't fixed incomes, which is incredible when we do our member survey. And out of the top 10 towns in the state that are low income, and out of the three of the five counties that are the lowest income are in our service territory. So sometimes people ask us about our low income strategy and we say everything we do is our low income strategy. You know, our goal is to keep rates as low as possible so we can meet the needs of the low income vermonters in the rural businesses. So that's, and doing that while we're meeting our state requirements and aspirational goals around renewable energy and carbon. We've worked really hard to keep the rates stable. We haven't had a rate increase since January 2014. I'll let you know that's not gonna stick forever because we're kinda running out of ideas, frankly, but over the last 10 years our rate increase has been an average of less than 1% a year. We're really proud of that because, again, given the demographics of our service territory, the bill today that we're talking about, H423, where you're trying to bring more renewable energy to public institutions, the state of Vermont, the disability schools, nonprofits, if you take away anything from my testimony today in the VEC service territory, we already have an option for all of those entities to go solar. So our big position on this bill is that we don't need to expand net metering to do that, we already have a co-op community solar program and I'll talk about the program and why we think it's so great. We're very proud of the program, we work really hard to bring this option to our members. What we like about the program is it brings low-cost, local renewable energy to all of the co-operative members. This is going into our power supply as part of our portfolio and we're doing it in a way at market rates. So we're essentially, when out to bid, we have contracts for this energy that is competitive at market rates. So we're not paying more than we need to to bring the local renewable energy to our members, so we're really thrilled about that because we want to do renewable energy, we just don't want to pay more than we need to. Why would we, right? So we purchased this energy at market rates, we offer the members, let's kind of think of it as like a CSA, like a food CSA, you pre-buy and then you get a fixed monthly bill credit. You can pre-buy by financing and still come out ahead so you don't have to have all the money up front, there's ways to do this, but essentially you get fixed monthly credit on your electric bill for 10 or 20 years depending on which you want. You have access to the financing options and the beauty of this program is you can opt out at any time for any reason. So you're doing this and you change your mind, you can get basically paid back, pro-rated share of what you paid in at any time, no questions asked. It's also really great because if you're a renter or you just don't have a home that's suitable to host solar, this is an opportunity for you as well. So it's open to everybody and it brings value to the whole co-op. We have three projects in the program right now. One is in Alberg, one is in Grand Isle, one is in Hinesburg. We have just over seven megawatts in the program and the three different sites. What we really also like about this outside of it being cost-effective for the co-op members, we can cite the projects and have them sized appropriately for our service territory. They're in locations that are near load so they're cited effectively and they're sized effectively. We're kind of able to do all those things because frankly we're controlling the project. We don't own or operate them, we contract, we got essentially a PPA. We currently have 28,000 panels, about 13% of them are sponsored so we still have capacity. If you know a school, you know a business, you know an entity that is a member that might wanna get it and we're very happy to talk to them about it and you can basically sponsor the equivalent of your annual electric bill. So including customer charges, everything else, we can get you to a point where your bill is zeroed out and like I said, we have a financing partner. So it's cost-effective. Yeah, and you're welcome to ask questions as I'm going. Yeah, I'm just trying to compare and contrast. Between net metering. And this program. Yeah, I'll get there, yeah. So it's cost-effective, it's well-cited and we retire all the racks so it's renewable energy that goes towards our renewable energy standard. Yeah, so this is not net metering. So there is no limit on how much a school district for instance could purchase into it. Right, you could go up to your entire bill. When we first launched the program we had a limit of 60 or 67 panels depending on which program because we didn't know what kind of the uptake and we didn't want people to get shut out. We still have that limit for large commercial because we don't want like one entity like buy out the whole thing but for public and schools and whatnot there's it's up to your full bill. I mentioned it's inclusive because if you don't have a good site for solar you can leave it anytime and it's affordable and I won't go into the detail here but in your packet you can see these are this is just an excerpt of like the rate sheet basically and you can see how that works if we have time and there's questions. So these are two of the three, Alberg and Heinsberg. These are the smaller ones, the one megawatt and the 1.3 megawatt. So they're permitted and operational on the Grand Isles over five megawatts. So how does it compare to net metering and why do we prefer this? Net metering, just a little background net metering in VEC territory does continue at a good pace. And I think some of our policy positions around net metering is a little misconstrued in the media. We have no problem and we're very happy to support kind of the smaller scale. The rooftop, the residential, they're not our problem. It's the big ones and this bill speaks to larger projects. That's where there's cost pressures and we feel like there's other options that are better for the membership. So just to summarize a little bit here about the status of net metering and not going too into the weeds. We had the data for 2017 and then I just added the 2018 but essentially in 2017, we first started looking at this in that year, we had more net metering and we ever had all the years before that. So you can say 2017 was pretty robust. Turns out that the same is the case in 2018. We had the program open the entire year and we had the same number of applications but the interesting column to look at is the percent of applications compared to the percent of capacity. So basically the number was the same but the amount of net metering capacity that was applied for was larger. So, sorry, yeah. I don't have that. Yeah? The term, the capacity. Right. Metering capacity. Two 15 KW applications. If you put them together, that's 30 KW. That's the total capacity of all the applications. So all the applications just looking at 2017, we had 389 applications but the amount of solar that was being applied for or renewable was 5,000 plus KW. And you'll see in 2018, we have even larger amount being applied for. Now, this is just applications, not all of them happen, not all are granted. So this is just what I could have pulled easy in anticipation. So what is the percent of capacity that we're referring to? Right, so all those, so you see on the left, you got small, medium, and large, let's just say projects. And the percent of applications, so if you're looking at 2017, 96% of the applications were for the small ones. But only 34% of what was being applied for was the small ones, understand? So more smaller ones but not as much energy. So you've got 2,593 kilowatts of capacity there in the small ones and 2,240 large ones. And the percent of capacity is 34% for the 2,500 and 62% for the 2,200, so I don't know. Yeah, you know what? I think I might have a typo in there because that doesn't make sense. Let's look at 2018. They're very similar, I know something must have been, I must have done some bad math. You could see like in 2018, and I'll get back to you on that, I apologize for that, that the smaller ones and the larger ones are about the same in terms of capacity and the percent of capacity. So the number of applications continue and in 2017 the total capacity was more than we ever had before and it's keeping pace. So I just want to share net metering is robust and does continue and it's about 25% of our peak right now is just net metering. And again, to reiterate the small ones, the rooftops, and that's not what you're talking about here in this bill. That's not what we're talking about is problematic from cost pressures as much. It's really the larger ones. And the larger ones do continue to make up the majority of the capacity. So in 2017, the larger ones were 4% of the applications and 66% of the capacity, the medium and the large. And I'll check that total capacity number because that's wrong. So the large ones are continuing to make up a large percentage of the capacity. And what's the problem with that? Well, the problem is we must take it and we must pay what the rate is set and we don't have an opportunity to maybe put it out to bid or be competitive. So we have no ability to negotiate like we did with our projects where we've got really competitive market-based rates. So for the larger projects, the last time we ran the numbers and here's a cost comparison and again, depending on how much time we have this morning, we originally were paying over 60% more for net metered renewable energy than what we were paying in our own community solar program under our negotiated PPA. With net metering 2.0, the gaps got smaller and what we're still paying over 30% more for net metered renewable energy, which is kind of like the same energy. It's there and it's there and it's just because we're able to negotiate and we're able to do the projects the way we want it to. So Andrea, under these projects where the community projects where people can buy in, the rate at which they buy them does that vary year by year? No, it's a set rate and that sheet of feedback you can see they pay up front either directly or financing and they essentially get a set bill credit every month for the term of the 10 years or 20 years, whichever one. And they can go everywhere from one panel to their full bill and they get that set. So it doesn't matter the generation, it doesn't matter if it's a sunny day or not a sunny day, they're gonna be able to know that they'll get the same amount every month. We're taking the risk. So how much does cost them to buy into a panel? One panel is $234 under the 10 year program and $412 under the 20 for the, so you get the same amount. They pay that amount up front and then they get this annual credit. They get a monthly bill credit. So if they, okay, okay, so over 10 years they're getting $326 total credit. So you see over here. They're gonna save $91 because. Right, is that? Okay. If you can't call it an investment, it's not an investment, the securities, that's not, but it's a sponsorship with a fixed bill credit every month for that amount. So we must take this chart here was meant to just show, if you just look at that first row, net metering 1.0, net metering 2.0, what we're paying under our PPA and what standard offer is, and the woman helped me post together is on jury duty. So if you have questions, I'll have to get back to you tomorrow on that one. But the point is 19 cents, 15 cents, 11 cents or 10 cents. You'd rather pay as little as possible for this. And what's the bottom portion of the table? The last 15 years portion. The last. Right. I think they adjust. So much. Right, our agreement changes with our contract has a different value over the course of the contract with our contractor, our PPA. So just to be clear, I understand what the numbers are, so if a customer signs up with VEC for a net metering project today, the price per kilowatt hour that VEC is paying is 0.15417. No. So but champion might be able to answer that better. I'm looking at 2.0. 2.0, we're in 2.0. 2.0 is 1.3. 2.15. That's how much you would pay. That's what we're paying, right. And you get the record with that? Yes. Then how much do you sell the record with? Those markets are changing, we're getting less. And again, I'm not the best person to answer that, but I can, can you answer that when you testify? Yeah, Monica can answer the previous question. Okay. I mean, I'm just wondering, is it two cents and the three cents twice? It used to be three cents. Well, we're not selling the ones. We're retiring ours, but the market itself, I don't know what's RECs are these days, three cents, three cents maybe. But we're retiring everything that comes through our community solar program. We're using it towards our renewable energy goals. I just, again, I want to be clear on the economics of it. So you don't sell any RECs. Not from our community solar program. And what about net metering? No. Okay. So you've retained all of this? I believe we're retaining all of it. You're not allowed to sell the record. Yes. Not net metering. Great. Thank you. Yeah. So for clarification, the net metering 2.0 with RECs means that you get the RECs, right? Correct. Okay. And if the person who's net metering doesn't allow you to take the RECs, then what is the price? Yeah. It goes down for that right? It goes down. I don't think that's happening. Like I don't think we have that situation. And the other question I have is, when you say the standard offer is 10 cents, that's for new standard offer projects, right? That's the new one for the solar. Because we were just trying to do a little comparing apples to apples. So for the solar for standard offer projects, being done in Europe, in California, there are. Yeah. I'll speak though. We are starting to intervene in the ones, and we have started to intervene in things in the Shi'i. You're a little familiar with that, I imagine. So if we're gonna pay more than we want to, it's not only that we're paying more than we need to to bring renewable energy, we also have a concern again with the larger projects of the ones with more concern, because there's fewer off-takers for these large projects. And what happens is, yeah, they're saving some money, but somebody else has to pick that up, because we're paying more. So you hear some discussion about the cost shift. And again, our concern again is with larger projects. There's fewer members when we looked, the last time we looked at the 500s that were online, they had only 10 members that were benefiting. So that wasn't the low-income residential person. That was the folks that had the capacity to get their act together, to be an off-taker. And so that's a concern. So we're paying more than we want, as well as that gets shifted to folks who often are already struggling to get their bills paid. And we just don't wanna keep doing that. So a lot of folks might ask, what is this really costing you? What's the impact on your rate increase? And those are all fair questions. I just spoke to our finance person. The reason we included this was to show we're paying more. How does that translate to rates? Well, our rates haven't gone up in five years. So I can't say X% of our rate increase was due to that. I can say it is a post-pressure. And we are doing everything we can to sharpen our pencils to mitigate any kind of upward-pressure on rates like everybody. And so I can certainly say this doesn't help. The last time we looked, we had, they looked at those 500s, and that looked like over $4 million over the 25 years. So we can try to pull numbers here and there for you. It's really hard to isolate what percentage of a rate increase this might be. I'll ask you what this might be a better question for Robert or somebody else. Just looking for, if you can walk me through, how the billing works with Met Meadering. I mean, I mean. But you know, if I'm so, I have a small residential project in my house. What I'm generating and consuming at that time is not, well, the question is, is that meter registered? It doesn't go back to your meter. Maybe I'll just wait for. It's a very complicated billing. You have a generation meter, and then you have a lot of meter. I think that's a pretty good understanding of this. I have another question that has to do with how many school districts or municipalities have actually applied to do Net Meadering projects? I couldn't get back to you on that. I'd have to look in our, we have like 1300 Net Meadering members. And how many are schools? And I'm wondering whether compared, as far as Net Meadering goes, how does that compare to the number of schools or municipalities that bought into your power purchase agreement projects? This was on Net Meadering. I'll send an email in with that data. We have a pretty lean operation, and we don't do a lot of marketing of our programs. So we often find a lot, I mean, we do it in newsletters and whatnot, but a lot of times when we have an opportunity, if you know a school that might be interested, we'd love to talk to them and give it to them as an option. So somebody in the face school decided, the school district decided that they wanted to put solar on their property. Would you then try to talk them into buying part of that? Seven Leguettes? We like to let them know all their options. We don't do a hard sell on anyone. You know, that is hard. Well, I'm not saying do a hard sell, but you let them know what you could buy into that. Yes. As opposed to putting it on their own building. We try to make, let everybody know about the availability of the program. Sometimes folks come in, they already have a relationship with a developer. They want to do net metering. We don't do anything to try to slow them down, or you know, we're a member-owned member. So whatever is the best option for you is what we want to support our members, so. And is there still capacity for members to buy into the Seven Leguettes? Yes. Being 13% of all of the capacity is sponsored. So we have more capacity. 13% so you have 87% left. Now the good news is what we really like about this program is whether anybody sponsors or not, we are buying this renewable energy. It is being produced and it's going into our power supply. So it's really just a matter of if there's a member that wants to take advantage of the sponsorship opportunity, they're really committed to going solar. They're already getting solar energy through our power supply, but you know, if they want to really commit and be a partner in this project, they can. So right now you want to let the co-op in any other utility has a requirement of being at least 57% or 60% renewable energy that you have to retire to RECS for. Do you have access to RECS that you then sell into the market? We have sold RECS and we will if we don't need them just because we don't like to leave money on the table. Again, we're trying not to have rate increases. So we play by the rules and we're meeting our exceedings so we can find value for our members in that way we will. So. I think it's back to my earlier question and I'm certainly not confident in my knowledge of very specifically how the net metering economics work but if you have extra RECS and have them available to sell into the market and you're purchasing that metering power with the RECS that are two, three, whatever the RECS is worth. Thinking about the fungibility of the REC that you may retain relative to that specific power that allows you to sell another REC. Right. What I'm trying to understand is the economics of the net metering that is truly the net cost of the net metering power you're buying that allows you to sell another REC in your portfolio equal to the net metering cost you're paying less the value of the REC that you can sell elsewhere in your portfolio. I think I got three quarters of the way through that with you because I was saying we're also using RECS potentially for tier three. Sure. We don't retire the net metering RECs so it means, I mean we do retire the net metering RECs so we're not selling those so if that frees up other RECs we can use either sell them or use them for tier three if we need them. It gives us, which is nice, it gives us opportunity to be a little nimble and be responsive, which we kind of need. And if I'm missing some part of this somebody else can fill in. So when I'm trying to get down to, again just to kind of level this out on a factual basis, the headline cost for net metering power is clearly more than other power that you can purchase. What I'm trying to get to is net metering power that you would purchase above 500 kilowatt level, how much would that? It's relative to 15kw. And I think there's differences in the... It's a problem of scale. So that's one question. But then also trying to understand truly what the net cost of that net metering power is if it allows you to sell RECs elsewhere in your portfolio. So, and, you know, we've got limited time to talk to you. That's what part of this was trying to do some apple sales. And it's helpful, it's helpful. It's not quite there in terms of understanding the net cost. So digging into net metering value, we often also will say, we need to look at all sides. How much is the cost to put that, like, transparency and openness, like when we go out to bed, we know we're getting implemented. If we're at a must take, must buy, you guys are setting a rate and it doesn't change, that doesn't allow us to really go with low cost. Like, so how much does it cost to put that energy in the system? That's kind of the other part of the equation. That's not necessarily transparent. It seems like the most expensive net meter power you buy is from the small projects. Larger projects, you pay less for net meter power. No, you pay the same. Okay. And above five, if the cap is lifted, above 500 KW. Right, so if the cap was lifted. And so you're buying power, net meter power from larger projects. This is just generally a question I have. I don't know if we've thought through this in terms of how this bill would work, but the price that would be paid for net meter power above any larger project. So I think that somebody else should talk about net metering to Cornell and compensation just to make sure you get the right information because that is not. The lucky person who's doing the first thing. It's lovely, it's great. So above 500, I guess the whole purpose of the testimony is to say when you're getting bigger, let it be competitive, let it be open, let us get the best price we can get. That's what we do. And we do it well and we've kept rates down and the more we have that flexibility to do that, provided people can go solar. I mean, we're not trying to stand in the way we just don't wanna pay more than we need to. It's just fundamentally, and I guess this is for other folks who are gonna be testifying in addition to information we'll collect in future days, a fundamental issue that we're getting our arms around here is does it cost more to purchase net meter power? I'm hearing the answer is yes. And I'm trying to get very specific about how much more. And again, there's a headline rate to that. 15.417 cents, but truly understanding what's part of the cost. And the value, you're speaking of what's the value. And so the cost, the value, that's good things to dig into. We're happy to be part of that. Question? I'm sorry, did you, I think, ask me, okay. Okay. Go ahead. I don't expect you to have this off the top of your head, but I'm looking for something, I guess I call it demographic information and I would be asking the same from Green Mountain Power, which is I'd like to know the percent of your customers are meters that are residential and then the percent of your meters that are commercial, large, industrial, et cetera, you know, broken out that way. And then the percent of your total revenue that comes from the residential and the percent of the total revenue that comes from the other classes. We sell half of our general, half of our sales is commercial and half is residential. Okay. People are often surprised about because we're pretty rural. Okay. But the number of meters I'll have to get back to you on, there's a lot more residential, but we sell the same amount of power. Okay. I think one of the things that this bill is trying to address is specifically school mergers. You know, last year we had disparate entities that each could do their own 500 and now next year it'll be one entity, which theoretically would be capped at 500 for the whole unit. So how can we make that, how is that gonna impact the grid, the economics and what can we do to make that fair while at the same time being cognizant that, you know, a single entity last year doesn't pretend to be five disparate entities next year to be able to gain the system. So kind of but for the merger, they could have. Right. You don't want them to lose by merging. Exactly. Right. And you're not necessarily talking about on-site systems. You're not saying. They think most of the school ones are on-site, right? I'm looking at the guys that might have more information on that, but whether it's on-site or not is. Yeah, like whether their off-takers is different than like larger projects. And we have a lot more concerns about like larger projects and locations that aren't strategic. Right. Electrically and whatnot. So there's like a paperwork, you know, accounting difference, like, but maybe not a reality difference in terms of like size of actual projects and where they're located. Right. Those are two different things for us. Perhaps the ideal solution would be one location, one meter, it gets one cap. And it's based on production that's consumed on that site or something instead of relying on the grid to transport it, you know, across the county year. Yeah. I mean, most of these systems are integrated with the grid because the sun isn't always shining. You know, we talk about the grid being the battery. You know, if you wanted to be off-grid, you could do that. But, you know, until the batteries come down in price and whatnot, it's gonna be tricky to not need the grid. Right. I just, yeah, get to your other witness. Yeah, leave a little meat on the bone for Robert. Please do. And for clarifying the details of net metering 2.0 because I'm not an expert at that in terms of what the compensation is, you might want to make sure you get that. Thank you. Thank you. Appreciate it. Do you want more? You have nothing to say. It's okay. If it's okay, can I just have a moderate please? Please, that'd be great. I'm sure you're trying. That's right. That's what I'm gonna have to say. Thank you. Thank you. That's a pleasure. So I'm Robert Dostos with Green Mountain Power and with me is from Monica Trombley. So I brought Monica in case there were any questions about the billing. I told her, it probably won't be. What you're doing. But she got him before she got up. So I'm gonna start with just sharing some slides and information that you probably already heard of or have seen. But I just think it's really important that we identify what the real challenge that we have before us and what we really need to tackle as a state and truthfully as just a human species. Right? As you well know, the Intergovernmental Panel on Climate Change released a report in October of 2018. 6,000 scientific papers, 91 authors, 20 different countries all saying we got some real significant problems and we need to do something about it. Otherwise, the worst is going to happen and then they kind of spell out what the worst is. We are set to hit an increase in global temperature of 1.5 degrees Celsius. We're gonna, that's gonna happen, right? Now what the panel is saying, if we go above that, what are the consequences gonna be? And we have an opportunity, when this report was released, they said we had 12 years. Now it's 11 and a half years and the clock is ticking to keep us to below 1.5 degrees Celsius increase. Really shippin' my glasses on. It's bad. So increasing, so this, I mean, we know about these fires. Increasing global temperatures above 1.5 degrees Celsius, hitting two degrees Celsius will significantly worsen the risk of drought, floods, extreme heat and worldwide consequences for human and of course, all like to live on this planet. This to me is one of the more shocking kind of facts and while I was aware of the impact that climate change was having on our coral reefs, I wasn't aware of the magnitude. I wasn't aware that by 2050, 90% of all coral reefs in the world will be dead, right? That's gonna happen. What we have before us now, the choice we have, we can cut our carbon emissions. We can at least say the last 10%. Why are coral reefs important? Not only are they very pretty, I have a little fish tank. My little fish tank may be used to kind of repopulate the oceans at some point. I say that jokingly, but you know, I've always thought about that and I see the beauty in my little fish tank and really what it encompasses is just think about the reefs that we're having, what we're losing. It's really a shame. 25% of all known marine life depends on coral reefs. 50% of the Great Barrier Reefs are right now dead or dying. And 90% of our reefs will be dead by 2050 and dying up till then. And the question is, can we save the last 10%. The author of this article, I'm just quoting her here, there were startling colors here just a year ago, a dazzling array of life beneath the waves. Now this Maldivian Reef is dead, killed by stress of rising temperatures. The world has lost roughly half of the coral in the last 30 years. And this obviously has significant impacts for ecosystems, the marine life that depend on that as well as a half billion people around the world who also depend on these reefs. So when you say if we can cut our carbon emissions, you're talking about the world. The world, yeah. Absolutely. Thanks. The world. And I do relate this to 4.23. So I've always done with this part. Can I reuse your slides by the way? Absolutely. And what I found is you just Google, just ask the question. Reef is impacted by climate change and boom, you get all these articles that come in. Yemen has been in a severe drought. And this same report says that the event like drought will become even more frequent and devastating under 2.0 warming compared to 1.5 degrees Celsius warming. So I wanted to have the oceans, the world, I mean it's affecting everybody, right? And here at home, I don't know if you heard that it was last week, this week, a great little state did a report on climate change and the impact that it's happening here in Vermont. And it's real. And what's happening is what... That was on VPR, right? VPR, what did I say? No, no, no, no. Yes. Okay, VPR. Yes, thank you. And what the scientists have said is going to happen in Vermont, more severe weather, more wet weather, more precipitation is happening. And as electric utility, we monitor the weather all the time and we prepare for storms. We've gotten really good at preparing for storms. Those storms have been more fierce. They have been wetter. We've had, I think, over the past five years, four of our worst storms ever in our history have happened in the past five years. So it's having a significant impact. It's only going to get worse. We are taking precautions to harden our system or even now looking at places we can underground stuff because actually technology has changed into becoming more cost-competitive to do that in certain areas. Last night, I was down in Putney having a meeting with all the fire chiefs and emergency management folks to talk about how we communicate during storms and what we need to do after storms is happening during the restoration period and what can we expect moving forward as these storms get more severe and how it just gets more widespread and resources get thinner. It's going to be a whole different challenge and we're starting to have these conversations because communities need to start thinking differently about how people survive in the aftermath of a major storm when power outages are going to take a lot longer to get restored. So it was a good conversation, but it was only the first of many. So reducing your carbon footprint, it's something we've all talked about. And this slide here came from Energy Action Network and it tells you what you already know and there's been a lot of folk in the conversation about this in this building. We know that our carbon is coming from our transportation sector and from our building thermal sector. Electric generation is a very small percentage now of carbon emissions. We have a pretty green portfolio. We have two utilities that are 100% renewable. GMP, as you know, is 90% carbon-free, about 60% renewable. Everyone is meeting or exceeding the renewable energy requirements that we have in the state, one of the largest renewable energy requirements in the country. So we're doing really well in that regard. In these other sectors, we're not doing well. How this relates to 423, if you're going to give public institutions and that list is pretty long, access to the net metering program to get more renewable generation, they're going to derive a financial benefit from that. That's why they're doing it. Rather than them simply taking that financial benefit and maybe reducing a tax or something, require that they take that money and invest it into carbon-reducing technologies, programs, whether that's like the vehicle or new heating system, whatever it is, let them use that money to reduce carbon because simply building another solar project is not reducing our carbon footprint because we already have a very clean portfolio. But if we use that as a vehicle to reduce carbon, then there'll be some societal benefits for the money that other customers are paying to make that happen. So that's our request if this bill is moving forward to tie this in a way that actually helps to reduce carbon because that was the purpose of all those slides I showed before because it is. Even though I know about climate change and I take it very seriously and have for a long time, there was something about going through this little bit of research yesterday to get these slides that really drove us home and said, holy cow, we actually we have 11 and a half years to save 10% of the coral reefs. So, and one way to do that is we combine our policies in a way or undertake energy policies in a way that ensures that we're reducing our carbon. And to the point, you know, this is just for months and we all have to do our part and there's no, they're not doing it so we should it's like, we gotta do everything we possibly can and hopefully others will do the same and in the end, as I hope people learn about the challenge before us because I'll tell you still there are many people out there who don't know about this challenge that we have the more they learn, the more they understand what we, as utilities, as a state, as individuals are trying to do, they'll get on board and help us achieve that as well. So, specifically on H, on H423 and why I brought Monica with me, there's a language in here that says that a public institution may participate in more than one group net meter, right? And that's how you seemingly will get an entity to get more, to participate more in the group net metering program that will have no limit on the amount of energy or credits they can get from a group net meter project. Right now an institution can have multiple groups and this is really confusing to me and that's why Monica's here that kind of straightened me out so you can have an institution one institution, so the town of X right? And town of X has multiple accounts because they have a meter at the water treatment facility, they have a meter at the ballpark, they have a meter on the municipal building. Each one of them is a separate account. It's all part of though the town of X. Right now the town of X can have belong to multiple groups but no one account can belong to multiple groups. So you may have let's say 10 accounts each account is part of a different group then the town of X has 10 different groups but each account is only has one group. We want to make sure that stays that way and that would have to be clarified I think in the language because if an account were part of more than one group we would not we do not have the ability to bill it and there would be significant challenges that we would have to overcome to actually even first figure out how to do it and then to actually implement it would be quite resource intense. So if you've got new school district that has separate buildings now does each building have its own account? Most likely it does each building have its own meter so it's own account and in that case any one of those accounts could be part of a group but right now that's limited. Right they could be part of the same group or they could be part of different groups. The difficulty is when you have one account that's if you kind of think of it it's a person and a premise a person and a location. So one location getting allocation or generation from two different groups is kind of a difficult concept from a billing perspective. So in this 500 total account are you saying that it doesn't necessarily apply to merged districts because they've got probably multiple buildings and everything? Well I think so the merged issue so right now let's say before the merger each one of those schools and let's make it easier it's just two buildings two accounts. The schools different districts has a 500 kilowatt cap right if you were to combine them right and now they're under one entity then presumably then that 500 kilowatt cap would apply and then that school would lose that opportunity right so you've never limited them but if that's the issue you're trying to address that's an easy fix right you just allow people when they merge to maintain their 500 they'd be able to one entity would be able to exceed the cap for schools and public institutions in the cases of the merger I'm really confused yeah it sounded like I'm sorry sorry I just want to make sure that I'm with you on the accounts so account is like that's somebody's getting a bill right and it's one location so it's the meter at your house it's not integrated into seven different locations it's that one location so I don't actually know it in rural Vermont so like would potentially a larger consolidated district get one bill for all their buildings now or would they get separate bills so then each one of those would be a separate account right so do we even have a problem well again no but if you are consolidating then that's the question that's raised does it mean that then so if you are all a separate account each one of you is a separate account you used to merge you still get to get your 500 so right now I have a merged district Dover has a system Wardsboro don't believe Wardsboro has a system they've merged into one governance unit they have two different buildings I think we'll have two different bills for each of the buildings and so right now with that merger can Wardsboro still do a project in your opinion that's a good question I'll just make sure Wardsboro can still do that project in my mind so it's the customer that has the 500 kilowatt limit and the customer can have multiple accounts so the customer would be the new merged district that has two accounts and so we want to make sure each of those accounts can still do and so the question is are they prohibited right now I would think they would be well it depends on the size of the system if it's over the 500 KW or the combination of systems right it's the cap so they would so if you too separate schools each one of going that meter and you have enough load and you each want to do 500 you can do that you're two separate entities two separate customers thank you two separate customers now you merge now you merge and now you call yourself something different customer Y customer Y is one entity one customer so you presumably would be limited now to just 500 of course if you had already hit the max before you're coming together now you're still nice a lot so the limit is on the customer now that you count right yes okay and so what we're trying to do theoretically is allow the customers to hit the limit as opposed to the no allow the accounts to hit the limit as opposed to the customer yes in the case of a merged system in the case of a merged system I want to step back from this particular batch of weeds and it seems to me that so we are looking at net metering as the goal and I want to step back to the goal being affordable renewable energy for all customers net metering being one of the tools to accomplish that and I've pointed this out in her testimony and I'm wondering is net metering the best tool for that it's great for distributed power generation but I'm wondering at the 500kw level where these problematic issues are at it isn't it metering the best tool to accomplish that larger goal of affordable renewable energy you know the lens that we are looking through now obviously it's the carbon lens every one of my presentation but it's also the resiliency lens so as I said things are changing and the more resilient we become as a state the better what does resiliency mean resiliency means that we don't solely rely on the electric lines and poles you know for our power all the time because they got to come down so resiliency means having generation that is near low behind the building or near enough to the business the community so that as technology continues to change a new battery storage opportunities come to play and costs come down we can microgrid the home, the business, the community the state of Vermont then that will improve our resiliency so to me it's the size is important to the extent that it helps to achieve that objective so having a large system like we have we're building a 5 megawatt we have no it's a 2 point something megawatt facility down in Rutland right attached to battery storage that will serve as a microgrid for the local school which is also an emergency shelter my home I have power wall battery and I have solar power goes out and it's gone out a couple of times recently 7 minutes 7 minutes hey but I'll have power and I'll have power you know as long as there's some sunshine and my batteries I will have power and I'll have neighbors coming to my door asking to shower but that's the kind of future that we need to create whatever we do I think we need to get that in mind is the investment that we're making in the solar whether it's net metering or standard offer or just solar companies building them and sending their power to utilities putting up on your own roof what's going to get us closer to more self-sufficiency that is to me the important question that we have to ask and answer okay that's a good question the question that I had before when I was confused about this I thought you said we have 500 we have 500 kilowatt applied to it and capped but then you just clarified your belief is it applies to the customer which is what we understood from the previous testimony but more interesting is Robin's question and your in response how do we foster the development of portable microgrids that are more resilient what it's happening how do we do that so it's happening think about the projects that we're doing all the large solar projects that we're building we're coupling with battery storage a couple of years ago we unveiled a pilot in partnership with Tesla and rolling out the Tesla power walls before we got involved in that software did not exist for us to be able to access them and use those batteries to be able to manage the grid width we can do that now we do it actually quite successfully we deployed 2,000 of those batteries we opened that pilot up now and you have other businesses solar businesses other battery businesses who want to get into that space now also being able to sell their batteries that's the ability to access them and use them for grid support and then we're paying them for that purpose the more of those batteries that we get out there and the more players that we have selling those wares the more that these batteries are going to be sold we have a lot of solar development out there so there's incredible opportunity for that microgridding with a lot of existing solar generations as well as more coming online so I know it's all new to me but I'm trying to understand how you divvy up the grid to to create microgrids in fact and I guess I'm just thinking about guessing that your legs, they go off down one road and down another road so the way you would create a microgrid is if a tree came down over there then what's left of this leg in order to be able to still have power would have to have generation and battery storage and in fact on each of these little legs is this the left? Yes, absolutely so that would suggest that the thing to do is to find ways to incentivize all the legs so that you create microgrids is that the GMP doing that? Exactly, so you were identifying places where you need storage and you need generation and finding ways to get those customers to participate? I think on the bigger more macro level we're looking for areas of the state where we know that local generation and battery storage is going to help with resilience sake but also is a more cost effective way of some other alternatives in dealing with accounts and then you have what's happening with the individual homeowner and that's providing the battery technologies and working with other companies to do the same thing and providing a significant incentive for them to participate and the value of that incentive that we're offering actually still yields value for all our customers so it's a win-win-win for everybody so now this has only been two years ago I think we started to pilot I think we've deployed a thousand batteries or still a thousand in the pipeline so things are changing pretty rapidly but we're still pretty in the early stages of all this I expect based on what I've heard about the battery cost coming down that we'll see a lot more deployment of that in relatively short time and it's going to be the market forces that are going to drive it but the utility GMP has provided that additional incentive to kind of facilitate but you're contacting people that would benefit your the grid or microgrids yes and that just says the beauty of bringing other businesses into the equation is that now they're also doing their marketing and getting people to buy their batteries but of course you're the only one to know where the grids are and how the grids are dipping down so on the small scale stuff we're not saying we maybe down the road we have an issue here this greater value and we're going to give you some additional guys I'm sure that's part of the conversation we don't have a game for that plan right now it's like you want to do a battery, do a battery here's some incentive to make that happen okay Mark can you elaborate a little bit you talked about the savings that folks read from these projects and some of it substantial from our school we just heard from the day and put that money back to the how would that work who would make the decisions what yeah I think that would need to be figured out I think utilities have a requirement on the tier 3 right to reduce fossil fuels the requirements for that are very steep I will tell you there's much more than I thought we actually were signing up for which is good given the problem we have but I had to like whoa they are very significant in terms of what we need to achieve what we thought we would be able to do to achieve them doesn't even scratch the surface which again the good news there is that it's forcing us to be very creative in finding new ways in which to reduce carbon and that's why we're doing so much work with the large fossil fuel users so the large businesses tons of fossil fuels that they use tons is not the right word maybe this to help them reduce that so we're looking everywhere the reason why we're promoting electric vehicles is for the same reason there's so much opportunity there so if these public institutions had a pot of money and they were instructed to work with it could be efficiency per month if their mandate changes utilities there's ample opportunity for them to partner with us and others to figure out ways to reduce their carbon so that's kind of and the thought where this came from partly was a presentation that RAP the regulatory assistance program gave at one of NEAN event where they were talking about a report that was released you probably know it's been an idea I'm not sure if it was carbon tax report basically the findings was if you simply just increase the tax you're not going to get the result that you want you're not going to see a lower of carbon but if you take that money and invest it into technologies programs that reduce carbon that's where you're going to see the real results happening so that was the thinking these public institutions will get financial benefit from this paid for by other customers will let them invest in ways that's actually going to have a benefit to all customers and that is by lowering carbon so that's what I was thinking I just wondered though if that would be a deterrent because if I was a customer voting on a school project and realizing that I wasn't going to meet any tax benefit I mean really you're looking at lifting caps on that metering there's going to be a cost to all customers that's you as well even in your district if you take away the incentive for that reaping that benefit from having that project take that away from them again I think what we're getting into a cost increase across the board that to me might be more of a deterrent than it is yes I guess it would depend on the reason they're deciding to participate in the program and want to get more energy if it's simply to lower their taxes then yeah this would be a deterrent but then I would ask the question is that the purpose of the metering program to help communities lower their taxes I'd much rather see that money being used for lowering carbon and if that doesn't fit with the community's desire then yeah then they probably wouldn't they wouldn't participate and that might be fine I would actually look at it I mean this is your idea I'll give you credit in playing for it I would look at it a little more broadly which is you know the school district was to invest in that metering project to lower its ultimately its electric bill but then was plowing some of those savings into you know whatever its thermal efficiency I would presume that that is an investment that is also going to further lower the carbon footprint that costs for that district whether its energy consumption or however you look at you know what the energy load is in that facility whether its heating oil or further electric versus I'm sorry and I'm going to go so when we're talking about a 500 kilowatt cap right now on school district I'm wondering about the actual load that school districts have and I don't know whether 500 kilowatts is just a part of that or whether it exceeds what most school districts use on electricity what I don't want to do is have school districts get into a situation where they're merchant generators generating more electricity than they consume and then getting credit for the excess electricity that that then reincreases costs and everything and I'm also wondering whether whenever we consider a larger project whether we should require storage to be part of that because again the sun doesn't shine all the time and we need to shave the peak in the evening and the one way to do that is by using storage and large systems seem to be to me to be the most cost effective way of using that storage so the first question I can say it depends on how the school is moving forward with the net metering if they could decide just to pay for let's say a solar array or it could be a wind turbine on their roof or in their backyard and serve their school directly serve their school that's the net metering and then any excess generation it has is just basically held on the grid and then they get credited for it they won't build a solar generator or a wind tower that's going to be greater than what the school uses because they would just lose those credits over time and that's intentional right you don't want them for you know so that's one way they can do it more likely is that you'll have a solar company build an array somewhere else and the school will be the off taker of that how much they take from that will depend on their load and that will be the conversation between the solar company and the school the school only uses 300 kilowatts right then they'll get two thirds of the off taker and then that solar company is going to look for another school or another entity in which to give the rest or portion of we have a net metering project down in Brattleboro that has over 100 acres so they'll want to build a larger system because it's more economical and they're going to try to fill up with as few as possible because they're less to administer but they'll go down the line until they finally got the full amount subscribed and those off takers are both municipalities or municipal entities school districts and residential users these bit usually it's the large usually the large ones yeah it could be anything it could be a mix so we have one more witness this morning what about the store yeah I worry about I worry about requirements because for the same reason I wouldn't want if someone wanted to build a solar facility near their business again so it's where you want it and then you have a requirement that batteries and it requires additional investments will that deter them from doing the solar I see this has been a step-by-step process so we've seen incredible growth of solar in the state good thing now we're starting to see the battery storage giant being deployed we'll see more and more that happen I don't think we need to require it just yet we should require more carbon reduction but that's not so if you get money we also have less coming I can ask them when they're done if you want to move on something specific with regards to you know kilowatt hours of storage for per kilowatt of generation is there an ideal ratio for solar or wind that from a technical perspective you would like to see in order to have a stable microgrid so you're going to really ask me a last question one I have absolutely no clue about that but I have something we could answer that good morning thank you for having me Melissa Bailey with Vermont Public Power supply authority I will try not to retread the ground we've covered this morning and potentially fill in some of the gaps and respond to some questions the committee has already raised around net metering and specifically in the context of Vermont's goals and requirements for renewable energy quickly that's again comprised of 12 municipal electric utilities around the state as public power entities I would say our key objective is serving all customers and ensuring that the transition to renewable energy happens in an equitable and sustainable manner with equitable benefits being shared among customers who are also community members in these municipalities so again we're nonprofit utilities committed to the value of local decision making and fairness among rate payers overall in general with regard to net metering I would say we're cautious about opening up portions of the net metering role back in 2014 at 99 was passed charging the PUC with fulfilling a series of criteria in the development of the rule that process took several years there was multiple opportunity for stakeholder input and the PUC I think was fairly successful in striking a balance again in the overall net metering rule and so looking at small portions of the rule such as the per customer cap risks throwing that out of balance this is a wordy slide but again this is from section 8010 these are the criteria that were legislated through act 99 and this is what the PUC was charged with doing as you'll see there are a series of goals that are intended to be met through the net metering rule meeting renewable goals is one of them minimizing cost shifts is another and again the PUC worked diligently to try to hit all of these to the extent possible so this is the statutory criteria again governing the net metering program in Vermont what's the oh I'm sorry short transmission and distribution transmission so that would be again targeted that if you do cite net metering close to load you have the ability to potentially defer or avoid transmission distribution upgrades that again wouldn't be the case if you have larger projects that are remote from load also on that same slide I'm looking at day and be there advanced goals targets system system so I my interpretation here is that the legislature is saying if the so the comprehensive energy plan is something put together by the Department of Public Service I believe every six years and if the legislature's view was that the legislature would have made that plan consistent with statutory goals goals and statutes to proceed the plan so the outcome of the act 99 proceedings that led to the net metering 2.0 rule that took effect in 2017 was that the PUC concluded it was appropriate to reduce cost over time of the net metering program they concluded that there is a significant subsidy and they included certain cost containment provisions in the role of providing any individual customer to 500kw of capacity of net metering in order to minimize the impacts on other rate players that are non-participants this just shows net metering deployment in pepsas territories we have seen robust deployment over and continuing through 2017 and 2018 this is as a percent of peaks of peak load for each of those individual systems so typically between 10 and 20 percent of peak load can be served through net metering systems we have close to 500 projects have been deployed and I did just want to spend a little bit of time on net metering in the context of Vermont's renewable policies so the renewable energy standard which was implemented in 2015 is now seen as the overarching renewable policy for the electric sector in Vermont and that will dictate how much small scale renewable generation is deployed in Vermont so that's under tier 2 of the renewable energy standard which set a requirement that 1 percent of retail sales ramping up to 10 percent of retail sales by 2032 be met by small in-state generation and so the res defines small as under 5 megawatts and again it must be located within Vermont so when we look at net metering we're looking at net metering in comparison to other strategies other projects generation that could meet tier 2 of the RES the comprehensive energy plan the RES is now the overarching renewable policy around renewable energy generation and directs utilities directs the state to look at the cost effectiveness of different alternatives to meeting all three tiers of the RES so getting into H423 it's from my reading of the bill somewhat unclear what the overall goal is although I think it's one of the stated goals has been to lower energy costs for public institutions in schools specifically and specifically schools that have been affected by consolidation plans so lowering economic costs clearly as a driver here I think there's been some conversation around providing renewable energy to public institutions allowing them to take advantage of net metering and have renewable energy either on their roofs or located elsewhere there could be tradeoffs between these goals to the extent that for instance if the actual driver is for the schools schools that are motivated by actually consuming renewable energy would in order to make that claim need to retain their recs rather than transfer them to the utility that would affect their compensation they would be compensated at a lower rate under net metering so hence the goal of providing lower costs to schools is in conflict under net metering with providing renewable energy so there are potentially tradeoffs that I think need to be highlighted and also these goals can be met through other mechanisms other than net metering do you expand on that? no sure these goals can be met through other yeah and I do have a slide on alternatives to net metering but it really gets at again what the customer motivation is so is the customer motivation to say I am 100% renewable I am generating renewable energy and consuming renewable energy that claim can't be made by most net metering customers under the current rule the vast majority of net metering customers transfer their recs to their utility which means they give up that claim so let's assume that the the real goal in the school is to reduce the costs so what role can it means to net metering to suggest that well I think that you could direct utilities to offer preferential rates to public institutions if you wanted I mean if it's really about getting money into the hands of schools there are a variety of ways you could do that right if it's really about writing a check if it's the economic bottom line that is the driver we could for instance with respect to renewable energy so a school may want to do net metering because it's both going to lower their energy costs and have green or electric generation yeah and I think that the point is net metering when you transfer the recs to the utility it becomes a slice of their power supply portfolio so the customer the school really can't any any renewable project that the utility has in its portfolio is furthering that goal of having all customers not just the school so net metering doesn't get you to having both lower costs and renewable energy as a school here well I don't see that as a conflict but putting up solar and your generating electricity even if you give the recs to the utility you're still doing your part for renewable energy and I don't some people may see a conflict in that but I I don't I give my recs to and my solar panel to the utility but I still consider the fact that I'm generating renewable energy I don't really care about renewable energy nobody else does either I think there's been some federal movement on that and what kind of claims you can make that will create commission weight in on that it's not like I'm getting any money for double counting but I think my point being that once you transfer your recs your net metering just becomes a slice and I'm sorry that I took out my power supply portfolio slice it's just like any other renewable generator showing up in the utility's portfolio and so the question I think the utilities justify well does it make sense to pay that much more for net meter in generation when the end effect is the same the same effect is that all of the utilities will have started in 2017 1% of in-state generation in their power supply portfolios and by 2032 they will have 10% under the RIS should the legislature decide those are not sufficient levels the RIS would be the place to make that change to the extent there's more renewable deployment in Vermont those recs would be sold out of state or they would be saved for future use for meaning tier two or tier three of the RIS but increasing that metering just means you'll decrease other renewable generation projects in the state because you're looking at that is don't produce any more renewable energy than that so if we have more net metering as part of that it would automatically constrain other renewable development you're going to do exactly because that's the directive we've received from the legislature and the PUC and does that 10% ceiling is the cap and we're bound by at least cost integrated planning delivering meeting state goals at the lowest cost of repairs yeah I know which we're not making it so so I just wanted to touch on benefits and costs of net metering and then talk briefly about some alternatives which we've already started doing benefits of net metering especially traditional rooftop net metering can lead to generation cited close to load and as we talked about that can help alleviate strains on the distribution system not generally the case with large 150 to 500 KW projects those are not typically located close to load so they can strain the distribution system it allows customers to self-generate to the extent that that's a driver for customers I'm wanting to say I have panels on my roof and I'm producing my own electricity there's clearly a financial benefit to the developer and the participating customer net metering traditionally has been fairly lucrative there's economic development there are job benefits through having a robust solar industry in Vermont but again RES will ultimately dictate how much renewable generation is developed in Vermont we can't say as a unique benefit of net metering that there's more renewable generation drawbacks again really deciding larger projects typically are located remote from the load that they serve and therefore that TND benefit is eliminated and you can actually see the opposite effect where there's a strain on the distribution system because the distribution infrastructure doesn't tend to be as robust in the rural areas we're seeing large projects deployed there are significant there have been and continue to be significant cost shifts under the current rate structure it's not sustainable to pay above retail rates taken to an extreme if all customers decided to net meter the only revenue that utilities especially nonprofit utilities get is through retail rates and to the extent that we are required to pay out rates higher than retail the program would essentially collapse on itself it's not sustainable and one of the charges with the PUC is to ensure that anyone who wants to net meter can so we don't think that that can be met if you're paying out above retail rate there would literally be nowhere else to get that revenue to pay customers and I think this is getting to some of what the committee is particularly interested in net metering is the most expensive way to meet the state's goals the current net metering rates for there will be an effect I think until July or 14 to 18 cents a kilowatt hour this is the wreck in all of these prices I'm going to include the value of the wreck to make sure it's an apples to apples comparison standard offer projects which also provide wrecks to utilities are developed in the range of 9 to 12 cents a kilowatt hour and utility projects are being developed for slightly less than standard offer projects right now and while net metering is often cited as having an economic development benefit related to solar jobs there's also an economic development cost to the extent there's rate pressure and increased rates for all customers and again customers that transfer their wrecks in order to get additional financial benefit then lose the ability to claim new ability so these are the compensation rates this is from the PUC's most recent rate order under the current program they update net metering rates every two years as you see they the PUC has decided that it's appropriate to ratchet down net meter and compensation over time I think that's been a measured ratchet so as not to create a shock to the industry these just get to the different size projects and how they are cited and the value of net metering generation is estimated at 9 to 10 cents so as you and that's the value to the utility and other rate payers so if a school is currently net metering where would they show up on this chart so as fast as it is looking at putting in more net metering I believe that they have I'm not sure how big their field is but it's certainly not in category 1 it is likely in category 3 so if they extended that this year they would be getting 14.4 cents a kilowatt hour am I reading that correctly if there was a new project bill in 2019 that was on a preferred site and larger than 150kw they would be getting 14 cents a kilowatt hour assuming they transferred the wreck to the utility if they didn't they would get through cents lower than that so they'd only be getting 11.4 but if so if they do transfer the wreck they would get 14.4 and I had to repeat myself I had the same question that I had earlier Andrea which is what the utility does with that wreck and it has to be retired but then does that allow other wrecks in your portfolio to be sold thinking about the fungibility of the wreck and kind of what the net cost is to the utility so net metering wrecks do have to be retired and applied against the renewable energy standard requirements by statutes utilities don't have a choice about selling those you're right to the extent that we have excess net metering wrecks we could sell standard offer wrecks or other wrecks I think there's a question about pricing right now we're seeing fairly low wreck prices 10 to 20 dollars a megawatt hour so 1 to 2 cents of this compensation so that's included in the value to rate payers of net meter generation so the wreck would be 1 to 2 cents and the other benefits the energy and the capacity that's all baked into the value so it's baked in on the cost and the benefit side so you're actually paying more than 14.4 cents because you're netting out of the wreck that you can sell we're paying 14.4 cents for an entire package of renewable energy energy capacity and the renewability the actual market value of that package is 9 to 10 cents 4.5 cents is a premium that we're paying I want to dig in we don't have time to get to that clarifications of the customer these rates and is this different from how it used to be with a 6 cent adder and then a decreasing adder over the years or what I'm asking is what was in the requirements was it a certain sent adder or was it a fixed rate that the utilities are paying to customers? under the previous net metering rule is that what you're asking? that was developed it used to be an adder and now it's a fixed rate so it's a rate differentiation by size so it's a rate and there is an adjuster for the wreck so I bought into a community solar field four years ago and just before the adder the amount of the adder went down so I have a 6 cent adder I'm getting paid retail plus 6 cents for every kilowatt hour that gets generated I'm not getting flat I'm getting for 10 years what's fixed is the adder not the rate so I'm just trying to clarify whether that setup has changed that structure did change with the 2017 net metering rule so now there are fixed rates that get adjusted each year there's a no so these are locked for your contract term right but the the rate that's locked for 10 years changes every year as you're showing here yes for projects that come online any project that comes online in a given year is locked into that rate for 10 years and then the adjuster changes I'm not saying I'm trying to ask very well the case that the rate itself may go up and down but the adder stays the same for the 10 years that's what I'm trying to ask so if the current rate per kilowatt hour if you're net metering and the current rate per kilowatt hour is 14.5 cents then the kilowatt hour of electricity you get is getting that 14.5 cents even because you're not getting that electricity from the grid but you're getting paid for all the electricity you generate even if you don't use it at the rate of the adder so you're getting paid retail plus an amount whatever retail is in 2021 getting paid retail plus six cents is it the same currently or are you people who get into a contract now getting paid the same equation one equation so these are based on current retail rates how much you get as an adder for the first 10 years is based on when you had your system installed yes and I do and I believe that the retail rate can change every two years the PUC revisits a statewide average retail rate so yes and I believe that that can float over the life of the contract sorry I was having a hard time understanding your question I didn't articulate but anyway these rates that you have on your table here are based on current rates the current rate that came out several months ago for 2018 that will be in effect for two years sorry I was so confused the value figure 90 to 10 cents is that the PUC that's utility calculations for market values of energy capacity also and avoided transmission and distribution upgrades and the value of a rack renewable credit pretty consistent across utilities I know you all heard some testimony earlier I think last week about a report that Synapse did valuing solar I think significantly higher than that the PUC and its analysis squarely rejected the Synapse analysis there were several several flaws the Synapse analysis excluded value values and costs of wrecks essentially just that they didn't have good projections so they didn't include it that's clearly an area that's applicable and also volatile and also extremely relevant to the analysis they also a substantial credit for transmission and distribution deferral that's an area that now that we've seen the peak go past sundown additional solar capacity really does not have a benefit of deferring transmission and distribution upgrades today because your peak is no longer occurring when solar generation is occurring so those are just some concerns we have with that methodology and just I want to speak to what the difference between the value numbers that you're seeing from different sources and Synapse is going to be here on Friday to talk about that report I'd like to give you time to finish your presentation I think I'm pretty close yep sorry so again as you know, we sit in a unique situation because we are municipals and could potentially be affected by this public institutions provision that's contemplated under age 423 as well as utilities this just speaks to the cost shifting we've done this analysis for several of our members because several of our member utilities are within municipalities that have contemplated net metering themselves and many of them have decided once they learned about the impact on the utility itself and other rate payers they decided not to go down the net metering road because essentially there was going to be a benefit to the municipality of net metering through lower energy costs but the utility would then incur additional costs from those projects so upward rate pressure you have heard this and I think similar to VEC we've done everything we can to avoid having rate impacts, found efficiencies, found operational efficiencies we've also been in a period of fairly low power purchasing costs but the economic effects of net metering do put upward pressure on rates and depending on the size of the system again we have fairly small utility members that's 1-3% rate impact and these 500 KW projects specifically which are the biggest cost drivers do have a substantial above market cost and again when I say above market cost I'm talking about as compared to other renewables I'm not talking about as compared to system power to renewable power just for your first bullet point that's a historic observation that in the last three or four years you've seen that 500 KW net metering projects have increased your rates 1-3% depending on them so these projects did not go forward so when we did the financial analysis and provided that I believe that was in the Swanton context through the municipality the municipality decided not to move forward with net metering Swanton actually isn't the situation of being 100% renewable and when the electric utility manager communicated with others in the municipal government about the cost shifts that occur they decided not to go forward with net metering so they did not have a rate impact this is the town I think I only a couple more slides again alternatives to net metering again it gets at what is the motivation if the customer's motivation is truly to be 100% renewable or to be a portion renewable some utilities have green purchasing programs by a portion of my power from green or mountain power where I pay more to consume renewable energy renewable energy credit purchases anyone can purchase RECs a REC entitles you to claim that you are consuming renewable energy currently we are seeing fairly low REC prices I think I said in a 10 to 20 dollar a megawatt hour range so again this is for customers or institutions specifically that want to say I am a 100% renewable institution also community solar is developed one for their community solar project hardwick is in the process of doing that this would be similar to the VEC model that you heard earlier where the utility as PPA for renewable energy and customers can buy into that in terms of just increasing rather than having customers claim renewable increasing overall renewable in Vermont power purchase agreements utility on projects and I should have included standard offer on here these are all alternatives that provide the exact same benefits as net metering at a lower cost and this the last two are just a couple of slides on VEPSA solar development in our various territories we are actively pursuing solar with on for renewable and planning to deploy 5 to 10 megawatts in total those would be power purchase agreements and again that renewable power would go into our power supply portfolio and benefit all customers that we delivered at rates that are in the 10, 9 to 10 cent range VEPSA is also actively participating in standard offer there is provision within standard offer for utilities to own projects and we have developed several projects through the standard offer this is a picture of the Lynda Mill project that was developed on brownfield under the standard offer program are you guys supportive of a continuation of standard offer or is that something that standard offer has some separate implementation issues our biggest concern around standard offer is wheeling charges which I think you did hear testimony on that there are these transfer payments among utilities that have posted a disproportionate amount of renewable energy specifically VEC and the Shiai area so I think that that is another way that great payers are incurring additional costs that aren't necessary I think standard offer is a preferable mechanism to net metering because it leverages the competitive mechanism standard offer went from being a fixed price contract similar to net metering several years ago I think now it was 2013 to a competitive bid mechanism which drove prices down almost overnight so to the extent that it's competitive we prefer it to net metering but I think the other implementation issues around wheeling are problematic and again the RIS dictates how much renewable energy utilities are going to procure so if we weren't getting standard offer power we would be going out to bid and having developers come to us with projects and potentially leveraging the lowest cost for rate payers so why would unis develop a project using standard offer instead of just developing a project so part of that is this issue of wheeling so the way standard offer works is everybody gets their percentage share and if you don't have your percentage share in the ground of standard offer generation you get charged by other utilities to transmit power so we're paying Vermont Electric a lot because they're hosting all of this standard offer power so there's a benefit to VEPSA members to having projects located within our service territory and I think standard offer I think Vermont's renewable goals do contemplate distributing renewable generation around the state so that was part of the standard offer not an oversight I think that's part of the goal although this wheeling yes for things like load charges and is VEPSA treated as one entity or are each of your members VEPSA is treated as one entity and we desegregate costs among our members so last question you mentioned the peak shifted to the evening is the new peak in the evening higher or lower than the old peak that was during daylight hours we are at a lower peak than Vermont's historic peak now I think peak peaks peaked in the early 2000s and we've seen overall load decline and the peak now occurring between 7 and 9 at night is lower than historic peak thank you years ago when I spent more time in the building we really operate from the belief that everyone has the right to a healthy environment and the clean energy is a big part of that big part of where it starts really quickly sun common at a glance I mentioned we were founded in 2012 a chartered benefit corporation that's how we are chartered with the state we are a certified B Corp it just means that we try and use our business as a force for good and are legally required to try and do so we are a majority owned by our founders and some institutions here in Vermont like the Vermont Community Foundation and Fresh Tracks Capital we are Vermont's largest clean energy business by employment there are others that install more megawatts out there but when we look at the impact of our employment we are the largest residential company and we've helped around 5000 Vermont homes go solar over the past 7 years 8000 total customers 3000 of those are over in New York state we've expanded beyond Vermont's footprint over the last couple of years we have 122 full time staff here in Vermont we're hiring more to serve our growth in New York we have a young workforce so we had the pleasure of having the governor come visit us at our office the other day and he shared that the average age of a trades person in Vermont was 58 years old nearly 58 and the average age in our office is 32 it's a fun place that draws people, people want to work there these are jobs that are bringing people back to Vermont or keeping them here which we like 8 million roughly in total annual compensation 220 Vermont employees and family members providing full benefits for our staff over the 7 years we've done some innovative approaches to try and accelerate the market and adoption of solar offering consumer financing most of that through the Vermont employees credit union and we actually helped them in their process to expand their charter so that they can offer loans and bring in capital to their states around the region so we actually worked with the Vermont employees credit union over in New York community solar we about a thousand of those Vermont households are folks that signed up with community solar that program stopped for us and pretty much stopped across the board in after that changes to net metering and the permitting rules in 2017 I should clarify when I speak about community solar our focus is helping households that couldn't go solar or businesses that couldn't go solar on their own to participate in a community array that is a slightly different flavor than signing up institutional organizations municipalities or large companies to take large our focus was on helping community individual residences for the most part access community solar are you familiar with VECs we just heard testimony about their community solar program are you familiar with that can you tell me the difference between yours and theirs from so benefit to the resident yeah so I haven't looked at theirs accessibility actually to the resident I haven't looked at theirs in a while and probably a couple years because they started a number of years ago in part we looked at that and we looked at the VEC market said this is a challenging place for us to want to expand our business and deploy community solar because we'd be in direct competition with the utility who has a monopoly access to a customer base and frankly it was that one was a pilot granted originally proposed in this committee and I think that that poses some challenges if we want a competitive market so we have done little to no community solar in VEC in part because the utility which has a monopoly has access to that customer base so just to follow up on that I'm hearing so I'm hearing you reference them as a monopoly which they are because they're a regulated utility right and they are required to keep the lights on yes you have a similar requirement as part of your community solar are there regulations on your projects like that yeah our projects all of our projects go through the same permitting process effectively that where a community solar project went through at the public utility commission and had the same requirements I don't mean I'm not trying to disparage the fact that they're a monopoly I think that they are they serve a fantastic purpose we have states that have monopoly utilities and states that don't and I actually think that the monopoly structures are pretty good one and efficient it's I'm just trying to clarify we don't have a solar community solar offering in Vermont electric co-op's territory in part because we actually had customers we had some early projects we had customers call the utility and say how should I be thinking about community solar and they were told oh don't do theirs do ours and that the experience soured us in part so can I just add another clarifying question so out of VEC territory presumably all the other utilities also have a monopoly they're regulated utilities so I'm not maybe following you on why it's better to do it in other companies which is not what my original question was it was more just trying to understand if you are offering access for residents but maybe this is something to follow I'm happy to I think yeah we could probably do a longer conversation so one distinction and I see your question is that this is net metering that you were talking about community solar is net metering whereas VECs VECs is it's power purchasing right right and so I think my question we're not getting the net metering rates VEC territory but they are my question was around access to resident because he was talking about the ease of access to residential customers I think and so I was trying to understand the difference in this project as opposed to the one we heard about from VEC isn't the difference that VEC was interested and decided to build their own effect on communities or is that the difference I mean the question may be being over complicated that I had it was really about you know if I am an average Ramonter VEC territory or apparently you're not in VEC territory we're in a different territory trying to access this community solar what is the difference for me in terms of average Ramonters are not thinking a lot about this am I getting more technical assistance is it costing me more am I getting better benefits I was just trying to get a sense of if we have comparable even products I probably just put it in a nutshell when we did one community solar project in VEC territory probably three years ago it was the earliest days of their community solar project and it was a comparable proposition kind of value proposition to the homeowner sorry I probably just gone there we do primarily focus on residential customers and or businesses so our focus is on kind of home business and community based energy we haven't been in the development space doing the 500s or that we are fully supportive of that being part of our energy mix it's just not been the space that we've been participating in we do offer solar heating and cooling to probably a quarter of our customers also choose to install air source heat pumps when they go solar reducing usually oil or propane usage we have developed a smaller residential solar canopy we offer home storage the Tesla power wall primarily and we've started to install electric vehicle charging stations for folks as well and the Segway being to the first commercial scale solar parking canopy was installed in representatives hometown and that's what I was going to mostly talk about today the electric vehicles charging stations so who owns those you said you installed them almost all of the ones that have been that we've installed are like home charging stations or level 2 business where the homeowner owns the station or the residential residential or or at businesses you know they want to install for their customers or for their employees something they would drive up to and plug in a parking lot or something like that it's a tangent that I'm happy to talk about if you're interested we did apply for some of the VW money and we are selected in the first round of those grants and we intend to be installing a fast charger that will help and part of it goes back to our mission of trying to drive the adoption of clean energy technologies faster across the board so why on earth do solar parking canopies these are the hardest solar to build hands down you've got massive foundations that go into the ground 14 feet down we're erecting a brand new significant steel structure and then putting the solar on top solar is probably the easiest part it's a civil engineering project and the reason that we do that is because to align with our company's mission we really want to utilize the built environment when we look at climate change the amount of change that we need to see in our energy economy in a very short period of time we can't leave our built environment out of that and just do it elsewhere so we need to be utilizing the built environment that we have here that's why we focus on rooftops that's why we focus on trying to make these parking canopies work Melissa Bailey was in the chair before and mentioning that you get slightly less benefit from a project that's a little bit farther from load these parking canopies are always almost by definition near load near usage they are you know at the alchemist the power is getting used right there on site almost all the time probably all the time it's probably very little that actually flows off site there so that makes for a stronger grid it also means that it's slightly more valuable to the electric grid we also wanted to put a value on is a visible solution to our climate crisis and again we fully support larger scale solar which is usually out of site but when it's out of site it's often out of mind and we want to help drive the public awareness around these solutions provide some hope and inspiration and ideally faster adoption of climate solutions and then the final link was that we want to physically link clean electricity with clean transportation so we have one parking canopy in the permit process right now front of the public utility commission and I think with that one we're going to be installing 24 electric vehicle charging stations serving more than half of the covered parking spaces so it really does help make that connection for folks which we believe is valuable in terms of accelerating adoption of electric vehicles is that right here in the mobility? no that one happens to be in cultures in cultures so this is viewed there's actually you can see there's another half of the array over here on the far side of the parking lot this is the alchemist Marie that's Amber she was our commercial project manager on the project construction manager and gives you a sense of what we're talking about and the scale this project was 110kw AC 110 or 120kw AC so when you think about these parking canopies you actually start to get a fair amount of solar generation in a concentrated way I heard testimony somebody saying 500kw parking canopy would take up three to four acres it's nowhere near that because it's way more concentrated than when it's out in a field and you're talking about on racks and in a row spacing and shading from trees it's a fairly efficient way space wise to deploy solar what? this is irrelevant but why is that more to one side of the parking area than the other so they had this kind of island in the middle and frankly it's just customer aesthetic desires we would have been happy to cover more parking spaces they liked the look of this better it is nice because the snow basically to the extent this is in snow so this was designed to the highest snow load capacity that we have in the state of Vermont and it drops there at the drip edge and so that also meant that they didn't have to in dealing with their snow management it was easier too but the other one is slightly wider so I want to touch briefly there are three permits your legislation is being considered obviously addresses the CPG the certificate of public good portion but I did want to share that we also get work notices with the state and building permits so these are treated as new buildings as far as the state is concerned there is some I think there is a question in the committee on another day about well gosh what about are these being designed and built safely we have a separate permitting process for that and we absolutely get them structurally engineered PE stamp reviewed inspected separate permit process is that mandatory process or is that voluntary that your company elects to take on and if it wasn't but did you what kind of approval did you get from the town we worked we reached out to the town I think select board and planning board I'm not sure we got a letter of support ahead of time from the town so we let them know about it we shared what the plan was and asked if they'd be willing to write a letter of support we didn't have to that wasn't like required support to whom in support of the project to the PUC to the PUC same but you didn't have to go to the town you didn't have to get their approval in general what's the role of municipalities yeah so in the current permitting process we absolutely so there's a before we even allowed to file our permit there's a 45 day period where we send our idea rough draft permit application basically to the town and to a number of state agencies and we didn't want the town to be surprised by that so we reached out prior to the 45 day even to let them know this what it is did they have any concerns yeah exactly what does the town have any jurisdiction over these the jurisdiction lies on the siting side our belief is that the jurisdiction lies on the siting side with the PUC the town is granted party status in that process at the PUC so if they had an issue an objection they would be able to raise their hand and weigh in at the PUC and they have automatic party status there so one of the questions that came up in the PUC testimony last week was should the PUC have jurisdiction on the structure itself or just the solar part of it in other words if somebody wanted to put up a parking lot canopy with solar on it should they go to the town first to make sure that they get the proper permits for building the structure and then once they get those permits then go to the public utility commission for the CPG to install solar on that structure on that the amount of time, the extra time so I actually think that the PUC is a body that's well suited to address the siting of electric generation facilities and that's effectively what it is I think it's important that folks who need to have a say and an opportunity in that process to have a job on that and I think that I believe that when it came up the other day I listened to the tape on some of that testimony it wasn't clear that there were these other existing permit processes that determine is it a safe building is it electrically sound that also run after we get the certificate of public good for the other state processes so I actually think it can work well how it is for clarification correct me if I'm wrong but I think the state differentiates between a parking structure and a structure that was primary purpose is not to support solar panels is that correct so prior to the 2017 rule change all of the rules and regulations were written with rooftop or ground mount solar in mind and I think that's why we're in this middle ground because the utility commission in parts that look there are no parking canopies effectively no commercial parking canopies in our state like this isn't working as an avenue if we want any of that then obviously something needs to change and I would highlight that over the two plus years since that change that specifically called out parking solar parking canopies we've had two so it's still not it's still not exactly a robust marketplace and if we want the solar in the built environment over impervious parking lots whether they be asphalt or gravel or a sure pack or whatever then I think we need to consider some changes and I think there are some changes I can get into some of those that will ideally make these more viable projects are parking lot canopies economically viable or money losers or developer so I think when you're asking that for the developer we don't do that kind of project development here in Vermont where it's a third party so there's a middle entity that's looking to play match maker build a project, find somebody else and contract for the power so the parking canopies that we've considered are direct sale to the business so there's no kind of middle developer there and from the business perspective I think there's no doubt they're more expensive you're building a significant structure that you don't have to do if you're just in a field and you don't have to do on a roof so if the compensation is the same as a roof the money is going to flow from those developers to developing or if it's cheaper to put a solar project in a field than it is in a parking lot from an economic standpoint the developers are going to develop the fields really what we've been seeing I think the parking canopies that we've looked at the customer has had more than just a pure economic focus so the alchemist wants to generate more power on site through clean resources that was a big part of that for them they wanted to show that and represent that they didn't want to put it on their brand new roof and it wasn't perfect for it and it was is it a good financial decision they believe yes I believe yes although the payback is much longer on a parking canopy structure than it is on a rooftop project or a green field why because it's more expensive to build it's a lot of steel it's a custom job to tailor to every parking lot and then you've got rather than poking holes in the ground with metal posts in a field you've got a 12 to 14 foot 3 foot round foundation that requires that's the drill bit it's just a different project and it's that deep because it's a compaction from cars driving on the parking lot why is it so deep? because you've got to hold up a big sale and make sure it doesn't go anywhere is there a median price range for a square foot of rooftop green field or parking lot that you can share? that's a great question it probably would take a 200kw rooftop or 150ac rooftop you're probably talking about a price premium of 25% for a parking canopy okay and compared to doing it in a field is that more or less expensive than a rooftop? the fields generally are even less because you get a lot or it's a different economic value proposition because you get more generation out of a field your panels are tilted perfectly south at 30 degrees rather than on a flat roof at 5 degrees so the value proposition for a field is probably the highest that's why the utilities are looking to develop solar projects they're looking to go as big as they can in a field somewhere because that's the cheapest but it's also there are other tradeoffs there and this is kind of on the other end of it's right in the built environment you can still get some scale it's building a lasting infrastructure and I think we need probably D all of the above from a climate perspective so an interesting note I think it's D DC in New York actually just classified parking canopy structures in New York state as non-environmental classified them as having no environmental impact so basically outside of their regulatory purview so they basically just said look we don't want to be bothered with the environmental impact of a parking canopy and they classified that across the state as a means of their dream new deal and here in Vermont because the parking canopies are treated like a ground mount we talk with our friends at A&R about wetlands when we're installing a parking lot canopy and a parking lot we talk to the agency of agriculture about prime ag soils when we're installing a parking lot stormwater issues when we're installing over previously classified and pervious surface aesthetics it's a parking lot canopy over a parking lot seems like an incredibly appropriate place or thing to have there we also notify all of the butters much commercial parcel that could be a lot of individuals that might not be actually anywhere near the actual array as well as the various municipal and town committees I will say that our first foray into this permitting was the alchemist and it was great working with our state agencies they were fabulous but it adds time and it adds money and frankly they're busy doing other really important work but also say the permit coming through the public utility commission was quick the public utility commission reviewed it turned it around pretty quickly and so it's not that we have egregious complaints about those agencies or the PUC it's more that that it adds $15,000 to $30,000 of extra cost that we believe is completely unnecessary the department of historic preservation we go there too so just in terms of H366 I guess I have two questions is there a specific portion of this bill that you would suggest we keep we add or is it not in this bill that you're asking us to do you have a suggestion I think we're on the right slide so in terms of our recommendation we appreciate the direction that you all are contemplating in this bill which is basically to ask the public utility commission to establish a recommendation process similar to that of a roof or a really small solar project so that's at the beginning right at the beginning of the bill and I do think this speaks a little bit to representative Chairman's questions I do think that there's an important role to allow municipalities also to see what's happening raise their hand if they've got questions so our recommendation would be that the legislature ask the PDC to create a registration process that's substantially the same as a roof mount except let's make sure that our municipal bodies still get the notification status to participate if they want to because these are different if it's up on a roof there's really zero view or impact in the community these are at least going to be visible and to the extent that we can make sure that they're included we believe that would be a good thing so I think this is section one two are you on the bill do you is this a change so this is a slight modification so I believe what's in the bill has two challenges to it one is this just incredibly big in this particular section in that particular section in this draft it basically says create a registration process but there's no guidelines about what type of registration process should it be similar to a roof should it be totally different should it be five times longer than the current permit process so I think some additional guidance would be probably be appropriate if the committee is moving in that direction the second piece is there's no timeline so it's asking the public utility commission to create a registration process guidance on when they should do that by when they so the time crimes are in a different section of the draft I believe it's still a silent on when the public utility commission would be asked to actually perform this work that you contemplate in section one in terms of exactly how much time so we've asked them and this bill asks them to establish the timeline for priority projects and identifies canopies as one of those types but it doesn't actually give us the time for me that you're asking for so I think two different things that second section of the bill speaks to timelines for all these projects and how quickly the utility commission is supposed to turn them around and what not I'm not speaking to that I'm speaking to if section one of the bill asks the public utility commission a registration process when should they be done with that work are you asking them to be done with that in June or next June or December in the creation of the process I apologize lots of timelines in there and one of the challenges that I will share and we're very reluctant to do these projects as excited as we are about them in part because the way that we've perceived ground mounts to move forward at the public utility commission is that if a neighbor raises their hand and say I've got concerns it automatically sends it into a hearing process which we believe from our own experience and from what we've heard from others would double the permitting costs at least and probably the associated timeline and these projects are so thin and on the margins already and I don't know if it was the intent of the public utility commission or of this committee and your colleagues to allow those who doesn't like the look of a parking canopy over a parking lot to effectively kill the project because that would kill the project so I think that's a real question of do you want neighbors to have that same ability regarding these projects as they currently have regarding some of the larger green field projects and that's a policy decision for you all to make so just in terms of understanding the impacts so if we were to change this what would be the primary benefit of changing this who would it be, what would it be? so I think there are two main impacts one is on permit costs so they would shrink which would drop directly to the project costs for us it's just costs of what it takes for us to build the project plus an operating margin and so reducing the permitting cost benefit to you well actually I don't imagine that they'd be we aren't going to do projects that we don't think are financially sound as a business so what it changes is it makes more projects possibly financially sound so we would potentially be able to do more than one every two years and that's I think what we want to see so it would reduce some of that frankly it reduces a tiny bit of workload on some of the agencies it's on the on the margin I don't want to overplay that but they're often overworked or have very full plates already and then I think the other thing that would do is it would make these projects dramatically easier to do stage and move through a development pipeline because right now we've got a 45 day we've got a ton of work to do to prep for a 45 day notice then you've got a 45 day notice then you've got to prep the actual permit package then you've got to submit the permit package and wait 30 days and then you've got to wait so it just condenses all of that and makes it less risky from our end and from the customers end putting out a whole lot of development investment up front at risk in the projects because we have greater certainty that it will likely that it will actually get built so less risky and easier to move more projects forward Going back to Laura's first question about who benefits so what I didn't hear you say directly was the client benefit because development costs are a pass through is that sorry I wasn't clear I think that is the direct benefit is it would reduce the sell price which would make it even more available to more people and make it an easier project and it would reduce the sell price which makes it we've had clearly the just the economics for these projects don't move them forward but they do in the state's history you look around to other states they're much more common so how do we cut out all the costs that we can so that the existing compensation rates can make the projects work the alternative is if you want more leave the exact process but ask for an increase in compensation rates in the other direction you said incentives and that's what a lot of other states have done they say we want solar in these places we want people to install it we're going to put in a whole bunch of additional state money towards it we don't have those I don't believe we have those resources any other questions for James thank you thanks for having me excuse my awkward seating the ice the ice got me about four weeks ago and I broke my kneecap you don't want to do it especially your driving leg when you live in castleton far away um alright let me see can you operate your presentation okay well I have cheat sheet notes and if you could also oh I will do that okay good morning good morning I'm Leslie Cadwell I'm not a paid lobbyist I am a lawyer I'm here because I have a passion for getting stuff done in a way that um satisfies the policy objectives that the legislature has established in a cost effective way and gives people an opportunity to participate and have a say in what goes on around in their communities by way of background some of you know me many of you do not just for some perspective um I have a unique history as an attorney here in Vermont I graduated from Vermont law school to become a Vermont lawyer I clerked with Ernest Gibson of the Vermont Supreme Court after law school I went for a short time into private practice and learned that insurance defense wasn't the reason that I wanted to practice law so I took a job at the department of public service where I served as special counsel um that's the fancy name for a staff attorney at the department I served at the department under three governors and three Rich Zidano, Christine Solombie and David O'Brien Republicans and Democrats I'm not a registered of any party I have served twice as director for telecommunications for the department of public service I was the staff attorney assigned for those of you who were here in 2006 and 2007 legislative session I spent most of the legislative session here in the state house helping to usher the a bill that got unanimous support on the floor to establish permitting requirements for telecommunications facilities it's broadband and wireless goals I think it was Act 48 can't remember now that established the 248A process I'm particularly interested in your efforts, Representative Sebelia because it continues to be an issue that we haven't been able to achieve those goals but I'm here today to tell you why adopting deadlines for net metering along the lines of what you did for 248A back in 2006 and have continued to evolve that process makes sense for net metering so that we can achieve state policy objectives I've worked at the department at a time when the telecommunications act was passed we had both the department and the public utility commission then the public service board saw a percentage but I would say it was probably in the 500 to 1,000 percent increase in the number of telecommunications filings that came in, certificates of public good to operate consents to transfer control and that kind of thing we did not the commission then the board and the department instead of coming to the legislature and asking for more money or for a change in law we forced together and worked to figure out a way we could process those applications in a timely way while still meeting the requirements to make sure the companies were financially sound and that kind of thing and if you go on the website the PUC's website today you'll actually see some of the frequently asked questions that I helped draft back in the early 2000s that process has worked so I also spent after some time at the department I took my box of things and I went across the street to the Vermont Supreme Court where I served as a staff attorney for four years there I developed a law clerk training program as a staff attorney you're responsible for writing the rocket docket decisions so every month you'd have two weeks six decisions in an appeal where you could have paperwork something like this so I know what it's like to be a drafter of a decision maker's decisions with a very short timeline and a lot of stuff to read so with that background I've been in private practice now I'm on my own since 2013 and I've also served oh my gosh I almost forgot for a time as general counsel of Velco during a time when the NRP was under construction and a number of the other large infrastructure projects were going through both permitting and condemnation so I have experience a wide variety of experience in Vermont government and the private sector and I have been before the legislature in the past has testified on a number of different issues and I'm just aside from the fact I'm really happy to be out of my house after being held up by this injury it's just really I'm delighted to be here to do what I can to help inform your consideration of these bills so if I do that you can see it back there this is the first time I've done this it wasn't paperless the last time I was here and you were done it was a long time ago yeah it was really not that was not a bad session to spend most of my time I will say okay why deadlines and I'm here really about age 366 deadlines my fingerprints are all over that language I'll be honest this is an issue near and dear to my heart because I know the PUC can do better I know they can deadlines work that's one main reason and the 248A statistics bear that out I think you'd see originally the 248A statute was adopted to sunset and it turns out it's the the only permitting process in Vermont where developers actually have a choice of forum you can either go to the PUC or you can go to your local zoning or act 250 that was built into the process give flexibility to telecommunications providers so they could get their equipment deployed quickly and cost effectively I won't I think Olivia presented some slides on at least the fiscal 2018 telecommunications filings which when you dig into the data they are many antenna attachments as I think Mr. Faber had testified before I do have a couple handouts that I'll leave you with on what a antenna project can include antenna projects can include emergency backup generators propane tanks structures and other electrical equipment some of the shelters have HVAC systems and that kind of thing and there is one that was permitted in the at least one that I found permitted in fiscal year 2018 that includes all of that additional equipment in addition to these just antennas that go through the process I'm going to turn back to this first slide on as we go through but I want to talk briefly about the 248A in 2011 the legislature you all had the opportunity to get some air money and the legislature looked at what the PUC had been doing with the telecommunications filings and learned that their review process that they established pursuant to your direction was working they had an average of 44 days for reviewing and turning around the 288A application and the longest period was 77 days and that was as a result of modifying the process to distinguish projects not by capacity like they are in net metering but much more about what the physical impact and size and some of the dimensional requirements for example a project may be considered limited size and scope if it doesn't involve a tower that's over 140 feet tall that was a determination that something that size 140 feet or less would be considered limited visibility that kind of thing if there isn't more than 10,000 square feet of permanent earth disturbance not the temporary disturbance associated with constructing or temporary access roads or doing the underground conduit communications lines and electrical lines that kind of thing that was a threshold under the requirement for stormwater permit and the process allows projects that meet these sort of dimensional impact requirements to go through a more expedited process and that those impacts which you'll see on the slides the impacts from a solar project for example and a telecommunications facility are not identical but they're both construction projects they both require earth in most cases some kind of earth disturbance in pervious surface with net metering projects you're not going to have a backup generator that has gas or propane you're not going to have any buried tanks you're not going to have weekly testing of a generator that runs on fossil fuels so as a result of the 2011 legislative findings the legislature actually adopted by statute the process that the public utility commission had established for telecom towers and other communications equipment by distinguishing the different projects based on these various types of impacts and what I did to help sort of help you think about why these deadlines can can work I have some I have some I brought three examples three actual tower projects and three 500 kilowatt solar array projects when the commission was tasked with implementing 248A and creating this process because there were deadlines it had to make choices about what was important for it to review and as a result we have success so for example in this sorry my leg is shaking it's just happens it's just happens oh you'll hear me scream um no no it's really not painful it's the rest of it it's awful hopefully no one's taping this okay so um this February the commission approved 80-foot tall tower on top of a mountain this actually is a pico locations actually in an area called ryanha it's rare irreplaceable natural areas I looked to billy coster to tell you a little bit more about what the sciences but it's basically there are a lot of really important things that you want to keep together there are natural communities there is an endangered plant and a threatened bird species there the project required 700 feet of tree clearing and included a 12 by 36 building that was on concrete to house the electronic equipment and like every one of these towers that isn't um if the antennas aren't mounted on a pole on a utility line where they can just plug right in um they all require a backup generator so that when the power goes out their customers don't lose service all of those generators are fueled by fossil fuels they have to be tested weekly um and they do only run um when there's an emergency this project like every other 248a and the net metering projects has a 30 day comment period from the time of filing there were you can see the timeline here there were department A&R comments um a petitioner's response the regional commission weighed in A&R filed some reply comments um and the commission was able to complete its work in 76 days um excuse me in August 2018 100 foot tall tower was permitted with 2500 square feet of tree clearing 5800 square feet of permanent earth disturbance again another building this one was on a 10 inch thick concrete pad for the electronic equipment 25 kilowatt emergency propane or diesel generator um when it says diesel or propane um it depends on what the um uh installer ultimately decides to um to put in they don't necessarily specify if it's going to be this particular propane depends on whether they're allowed to use diesel um and I'd leave to uh the environmentalist to explain more this one uh had a 500 gallon propane tank if propane was going to be used to fuel a generator 500 square feet of new impervious surface area again a 30 day comment period um this one A&R did not file any comments the only comments were from the department and neighbors who opposed the um the project um the commission was able to um uh consider the neighbors comments and uh decide the the case within 50 days uh November 2017 um this one is a 110 foot tall uh tower with uh 8,400 square feet of tree clearing uh 3200 square feet of permanent earth disturbance um 2,700 of uh impervious surface area again another building on a concrete pad a 35 kilowatt emergency propane or diesel generator 1,000 gallon tank um and this one involved a 3,800 foot on a long access road um with wetlands on both sides um that access road as I understand it would be receded but um if you think that nobody ever goes back to visit the telecom tower um uh that I let me disabuse you of that belief um what equipment needs to be changed out if there's something that happens with the generator they still need some uh some access so somebody's going to be driving up to that tower they don't just leave it there to sit you look like you have a question I do and I would love to I want to wait until you're done I'd like to I'm anxious to see a couple of questions access road or on paper no that's um it was a gravel basically a dirt and then you know enough so that it's got to be improved enough so that the equipment you know because it's not um 110 foot tall tower um is you know that's not a small piece of equipment right um right exactly um so there has to be some kind of access um so let's turn to the impacts of 500 kilowatt um solar project and I have uh three for examples um I chose these partly just because I wanted to give you some kind of comparison um it's not to say just like with the telecom towers um that every solar project is the same they're all a little bit different um the point is that they're not so different that experienced uh regulators who see these things all the time can't look through and I'm going to leave you with um copies of filings this is what they claim they can't do in the time period this right here these are your copies that's one you like one this is for one project and this is for this is for a project that these two projects are in my slides how big these are 500 kilowatt um solar base these do not include the comment letters these are just the filing so this one um uh was done in uh 69 days it was filed in uh November of last year there was 7800 square feet of shrub and sapling removal it was basically a mode field and there's like little scrub here and there so they got to get that down to put the racks in um 5000 square feet of impervious permanent earth disturbance and impervious surface free pole mounted transformers and when I talk about the pole mounted transformers or the transformers you see outside the building like around there's you know comment um electrical meeting and uh a disconnect stuff were mounted on a panel and James and um Mike Norris who uh drove me here today thank you very much um basically a big like our stand yeah pedestal I know it's called a pedestal but I think of a pedestal like as a table but now it's kind of like a this and they attach this way um 30 day comment period we had um the natural resources board the division of historic preservation department of public service and the agency of agriculture all file comments and the commission was able to turn that around in 69 days Matt something about the impervious surface what was considered the impervious surface so that would be um like a permanent gravel driveway um like a gravel turnaround the actual um equipment the itself um you know the the disconnect equipment um the posts no no the posts that hold the racking that holds the um the solar panels up and then the fence posts and all of the the 500 kilowatt they have a fence I just didn't put it in here because I was late honestly and I figured I could tell you they all have fences um unless they're trappers and the trappers generally don't have uh fencing um but these are all fixed ground um this one had a 30 day comment period and the reason there's an asterisk there is we had an issue that came up with A&R and we agreed with A&R to for a two week period so that we could work out um the issue that we had um that issue was resolved on august 27th and we didn't get the CPG until january it took 202 days nothing happened at all between august and january of this year if there were deadlines um we would have been able to uh see this project probably constructed before the end of last year uh the last one um and the the one that I just described is in that packet of materials and so is this one this uh site was a former rock extraction site it was actually a site that they took rocks to help um after uh tropical storm Irene and uh there was really um the only vegetation that had to be removed was some again sapling and shrub that grew up over time as it was left uh undisturbed um about 1190 feet of permanent um earth disturbance in impervious surface area a new gravel turnaround that's included in that impervious surface three multi pole mounted transformers again the pedestal with the electric equipment um 30 day comment period and as you can see from the timeline uh the comment period uh ended around july 31st something like that there was silence until um uh october um and it took the commission 107 days from the complete filing to um uh to do this and these again are projects where they have the 45 day notice actually um this last project um had two 45 day notices and uh um and uh uh hearing at the local drb um the many developers will tell you even though uh local um authority is preempted by to the 248 um some communities really want you to go through their zoning process um and some developers will do that because it's the right thing to do for them and their relationship even though the drb doesn't have authority to say yay or nay they do have authority to say yes we like this project and that's very helpful when you go to the public utility commission so in this case um uh the local development review board approved the project this is after the second 45 day notice if I'm right um uh and the project proceeded and uh no no go ahead follow up so uh you know I think uh showing the different projects is uh it's helpful I'd like to understand um I think maybe a little bit more on the individual projects where they're getting hung up I don't know if that's a question for you I would note that I don't find the comparison to 248a particularly helpful um I think 248a has contributed to a pretty significant um expansion of vulnerability and we're over a month with regard to telecommunications infrastructure um it has allowed our telecommunications companies to build where it's profitable and I'm actually worried about that with regard to renewables and our electric utilities and what we have found with that is in rural areas their system the network that is there is deteriorating and it's costing you know it's really impacting quality of life so I would just caution but I don't know that that's the strongest correlation to make um the comparison of three like size projects in three different areas um it's helpful and I'd like to understand I think a little bit more about specifically where those get tripped up well I have been dying to actually talk to you about this because I actually the um the permitting provisions um that were passed in 2006 the 248a that was one piece the problem with deployment and this is the topic for another uh hearing on telecom um isn't about um uh if you don't have um the money to subsidize rural areas um I have been working on this for well since 2000 and probably I've been doing telecom since 1999 um and my own view based on that experience is the only way you're going to achieve and close the gap is with public subsidies in areas where they're needed you need to shift money from one place to another it's the only way um uh and until there is a will to do that um uh we will not solve the process problem the permit process isn't the problem the problem is the fact that it's rural and there aren't enough customers over which to spread the cost I'm not convinced that the permit process hasn't exacerbated a problem in rural Vermont with telecommunications but that's a different story and I and I defer to your better judgment how to sit here and listen to folks but you know it's uh been the comparison was made so there's also a federal uh and state regulation difference as well so the let me give you an example the Velco statewide radio project for example that it was essential for it to meet its um uh the safety and communications needs that would not have been possible without 248a there are some um really important benefits and part of that is because they have deadlines so let me go back to that um the reason you have and this is coming from someone who has experienced the pressure of having to produce quality work in complicated issues in a short period of time it's just the way things are um with the deadlines agencies can prioritize their work and that's exactly what you see if you look at the e-p-u-c um if the commission didn't have a deadline on 248a I would bet and I'm not a betting person I'm very risk averse in that way um with my money in that way I would bet you wouldn't see these things being issued you know the bulk of what comes out of the commission the reason that they do it is because they have to they have to decide what's important and how are we going to prioritize our work maybe it requires them to rethink how they're doing business very similar to what we did after the 1999 telecom um uh act was passed federally when the states were um I mean from all over the country filings were coming in um what were we to do um we could just continue business as usual and require every telecom company to provide but no it was what is the most important um thing that we need to protect the public um consistent with the fact that we've got all this workload and um uh we have other important things to do let's revise the system so can I ask another question so with okay is it lunchtime lunchtime uh the uh just with regard to um getting deadlines um accelerating this process do we um do you believe or think that we are creating any risk in terms of uh our overall grid and our ability to provide electricity to all of our monitors in other words creating any kind of imbalance in terms of this transition that might harm our utilities which are required to keep so um like there's well yeah there is a um so there are two sides of that um one is yeah they are required and there's state policy and everybody knows it and you ought to be organizing your work and your resources so that you can meet those objectives so for example if gmp did not install the equipment up in the shii for example um that it was supposed to that it told the public utility commission and iso and wingland it was going to install but didn't do it whose fault is shii right um so if the um if the utilities know that it is important for us to keep the earth's temperature below two degrees the rays would blow two degrees celsius within a certain amount of time or we're faced with just catastrophic consequences they have the protection from regulators to make sure that they're fulfilling those obligations if our and this is not a um perhaps a popular opinion but my own personal view is if it means that my electric bill is going to go up a little bit because my niece and nephew are going to have a planet where they can live safely then I'm really happy for my electric bill to go up a little bit to do that um I reinvested in a net metered system on my house so that we could do what we can to get off fossil fuels and thank you for some common for doing a great installation and using um local labor to do it my question is just around assessing we mean we have to think about what are the consequences of the actions that we take and are we taking them in a way that balances um the things that we're trying to do transform our utility or our our energy system and also take care of our model in many ways so that's really where my question is around I don't see deadlines when the testimony that I heard suggested that the PUC can actually accomplish these goals in most cases so um either you decide not to allow projects all together or if you're going to allow them you have some kind of predictable process customers, the public even folks that oppose these projects they have a right to expect a decision within a reasonable period of time for some folks and this is where I speak with my former staff attorney hat on folks that are caught up in a court case or litigation their lives are affected in ways that people may not understand and as a working as a staff attorney in the court of the court my job was to do everything I could so that the court could make a decision because somebody was waiting for that now those cases are usually redressing past harms as opposed to trying to you know as a gatekeeper for some permit process for installation of an infrastructure in that case in my view timelines are even more important because if you can't get the permit you can't you'll never achieve the policy objective now in the case that I showed you with the 202 day turn around okay that's all our project I think that what happened somebody forgot about it because finally I have a process we wait a little while and I write what I call this is Leslie Cadwell's terms and those who know me know I have all kinds of terms my nasty gram where's the permit hello did you forget now why would they forget well let me tell you why they would forget and I actually had an experience where I was at the department went to the Supreme Court and came back to the department a case that I had inherited from somebody before before I went to the court I came back from the court four years later and in my inbox I get a notice of appearance from an attorney in a case that I was like oh the Barton elector declaratory ruling what seven years had passed they forgot about it the PUC just completely forgot about it the case had gone packed up into public records had never been decided and it was because I looked I was like what happened with this I make phone calls and it turned out we eventually did get the decision but they forgot about it why did they forget the public utility commission does not have a case management process when I went to the public records request to find out how do you like when a case comes in what do you do with it who gets a sign what are the timelines what time do they have to review where does it have to go whose sites check these are things that the court has because the court is a just like the PUC is a body of statewide jurisdiction it doesn't have a discretionary docket it has to hear everything that comes before it with the exception of very very very few in order to manage its work among all five justices their law clerks and four staff attorneys there's a process and the court chief staff attorney he knows what's been filed how long it's been pending who's holding it up and why it's being held up and there's weekly check-ins with everybody at the court to make sure those deadlines the justices know I am the justice for these counties for these motions the motions for extraordinary relief those go to staff attorneys the staff attorneys in this area gets a sign the PUC at least based on the response I got from public records requests does not have any internal case management procedures to know who has what why it's held up how long it's taking there's no accountability and that's why if you're gonna this goes to if you're gonna have the PUC collect more fees because of from that meeting customers there's got to be some kind of accountability otherwise you are creating more work as someone's got to collect those fees manage those fees track those fees make sure they get paid without any without any benefit finally in terms of the deadlines provide also clear target for performance standards the committee should be aware that the commission will tell you that it resolves it meets its performance objectives by disposing of a certain amount of cases within a certain the cases know this is the cases that it decides within a certain time are decided within the prescribed timeframes what does that mean let me give you an example this is how the public utility commission reports its performance for budget purposes if they decide 10 cases and those 10 cases were all done within prescribed timeframes they get 100% I'm shouting sorry they get 100% but it doesn't tell you that they actually had a thousand cases they were supposed to decide they only decided 10 should they really get 100% for deciding only 10 of a thousand cases within the prescribed time no the public utility commission's performance standards need to account for how they're actually disposing what the disposition timelines are not how good they were at the few things they did okay and I verified that performance standard in a phone call with general counsel and and bishop because I when I read it I couldn't believe that that's what they were reporting to the legislature and to the governor was look how well we did for the few things we actually got done so if you have deadlines performance standard and hopefully a case management process where they can have their staff achieving the policy objectives that the legislature established so may I ask another question so you had me on the case management system but we have EPUC that's just a okay so tell me what's not where I love this question so let's get right into where this is like at my dream now you understand stars all over so and this was my fear when they adopted EPUC and after the first conversation I had with somebody there I was kind of afraid this is the direction they were going so let me briefly say in my pre-law school life I have actually I'm not a computer person I just love technology but I have been responsible for being on a team to computerize the last luxury hotel in Boston that went from a manual system to a computerized system I was on the team to implement that I've also was on responsible for implementing the document management system when I was general counsel at Velco that is a tool to interface filings it is not a case management system it is an external system how the EPUC interfaces with the external world very similar to the papers I filed if you file those in the court the court says you need to put that in these many copies it has to be done by this time that kind of thing is it a public filing cabinet is that what you're calling it it's basically a public filing it's a document management system there are things there are some reports that you could if you designed it well use to help you with these what I found in doing the stats and providing some support for Olivia you have to have a lot of time and a burning desire and an inability to stop work and enjoy your life with friends to figure out the best way to pull the data from EPUC as a member of the public I don't know what reporting the PUC gets from EPUC but in order for the tables that Olivia showed you that was probably four days of work for me to come up with that just pulling the numbers out of EPUC you couldn't do it with a fast and easy search the case management system would be or procedures would be how once it's filed what do they do with it where does it go internally what are the deadlines so for example when of course because I asked them for it and they said they don't have one this is what they gave me hearing officer evaluate performance evaluation forms the performance measures the budget we do 10 things really well and I was told I don't think you want our regular personnel policy state personnel policies sick leave and all that they don't have I don't know Greg can tell if they have procedures that govern how cases they are assigned who gets what what the time frames are reviewing is that an external requirement meaning a rule of civil procedure or the the 248A amended procedures order these are what a a person seeking the assistance of the commission or invoking the commission's jurisdiction what they must do and what the commission does in response what happens behind the scenes I have no idea there is no documentation unless they've held it from me I don't think so they're really awesome like that they are very responsive with public records requests and really helpful on the phone clarifying information but that's how I know they don't have a procedures that govern how they actually get their work done so turning to the last slide second class slide so the process that Olivia presented that I think came from the PUC the PUC said they need a minimum of 80 days to turn around a net metering petition or application that means they're saying that once all comments and all issues are resolved they need at least 50 days a minimum to decide it and I don't that's just not reasonable they should be able to turn it around in 30 if the person assigned reviews it and they have a template for a decision because there's boilerplate language in every single one of these the person writing the decision can actually get a head start in fact the party filing these for these 500 actually has to file a proposed decision so there's one already written for a while when the commission was still using word perfect because I'm a believer in doing everything I can to help my clients to remove barriers to get projects built it was part of my job at Velco was to remove obstacles to get sticks in the ground sort of speak I lost my train of thought word perfect thank you I actually bought word perfect and had the word perfect version I would have all of our proposed decisions done in word perfect so that they didn't have to worry about conversion when I found out that some hearing officers liked word perfect and others were using word it was like what format can I send it so that it's easy for you to get it written and decided so they only need 30 days thank you