Wednesday, November 4, 2015

Timeline of Xcel's Community Solar Garden Delay Tactics.

In September 2013, Xcel brought forth some program rules that were in blatant violation of legislative intent. It was a proposal to cap community solar to 20 megawatts of capacity through 2015. Their additional tactics included various ways to reduce compensation for community solar subscribers, and therefore limit market demand for the program. Xcel also rejected a helpful tool the state legislature offered to them, the “value of solar” payment mechanism. That required the Commission to use it precious time to craft an alternative payment that would allow community solar projects to be financed.

The Public Utilities Commission eventually resoundingly rejected Xcel’s proposed plan. But the whole ordeal ran the clock on six months of public comment and debate. The PUC then gave Xcel another month to file a revised program, and an additional two months for public comment as a result of having to start over. Xcel then came up with a low-ball offer on community solar rules. That successfully delayed the program opening by at least nine months. In the meantime, Xcel helpfully produced a full animation video called “Solar Done Right” which subtlety suggested that solar is done most economically at “large scale” as opposed to distributed generation or community solar.

The PUC erred on the side of trusting Xcel with their next order they issued.

The interconnection rules the PUC set gave community solar projects extended time to connect to the grid if Xcel delayed, but offered no consequences if and when the Xcel acted too slowly.

In September 2014, the PUC finally approved Xcel’s modified plan. Thus far Xcel had succeeded in drawing out the clock 15 months after the State Legislature approved community solar.

But then just a few weeks later, Xcel brought forth their next delay strategy. It involved filing comments raising concerns about the “co-location” of community solar projects.

The PUC’s comments that April approved of the concept of solar gardens sharing grid connection location, with an additional PUC statement of support following in September. Xcel’s own comments in June were in agreement with the PUC.

At first, Xcel said it would accept these applications as long as “each solar garden must have its own metering, its own program application and separate interconnection agreements.” However, Xcel’s comments ended up being a confusion tactic for developers since it injected uncertainty into the process of how projects would queue up for grid connections.

During this time period, community solar developers kept asking Xcel for clarification on how they would treat big business subscribers as subscribers to multiple solar gardens. In two separate replies in November, Xcel replied unhelpfully, “We believe there is no need for additional clarification.”

Finally, on December 12th 2014, the program officially opened and Xcel started taking applications. But only week prior, Xcel launched another confusion tactic that led several CSG developers to feel duped. Despite earlier comments to the contrary, Xcel now said that developers who had jumped into the grid connection queue before the program opened could keep their spot in line.

Once the program opened, Xcel’s strategy was to slow the program by fanning the flames of uncertainty. Despite attempts to inject uncertainty, Xcel received over 400 applications for 400 megawatts of community solar projects, 20 times the capacity they had proposed to allow by the end of 2015.

In February of 2015, CSG developers said they still lacked clarity about the multiple location issue which Xcel had refused to clarify in November. So the CSG developers, were left with no method to identify decent grid connections before submitting their application, nor a way to see their place in line. Again, the Commission was forced to step in to provide some guidance while Xcel was offering new ways to curtail the amount of new solar capacity from the flood of CSG project applications. In March, Xcel made another attempt to lower compensation for CSGs. and strategies to curtail the amount of new capacity from solar projects. On both issues, the PUC held firm and would not change their order.

In response, Xcel on April 28th launched a dramatic tactic to shrink community solar by 80%.
 announced they would take unilateral action to dismantle all community solar projects owned by the same developer that shared a grid connection, within 30 days. That move was in direct opposition to the previous PUC order.

Xcel’s reply comments to the PUC in May hinted at their motivation: “The strongest evidence of the program’s dysfunction is the volume of applications that have been received which neither the Company nor the Department [of Commerce] anticipated before the program was launched.” In addition Xcel admitted in their revised 15-year resource plan, filed on October 2nd, that they only expect just 20 megawatts of community solar by the end of 2016 regardless of the fact they have over 300 megawatts of projects with completed applications).

The PUC resolved this latest tactic by approving a partial settlement between Xcel and a few smaller CSG developers. The PUC gave Xcel what they wanted by retroactively limiting co-located CSG projects to five 1-megawatt projects, with a size cap of 1 megawatt for new co-located projects. By October, 300 CSG projects that have been awaiting interconnection approval since February still have received no response. 

No comments:

Post a Comment