NEM is now closed - Oct 2015 Regulatory Update

Posted on Wednesday, October 14, 2015

Aloha  Everybody,


Today the Commission issued the D & 0 on the DER docket that we’ve been waiting for these last months.  I’m in the process of reviewing it now, but I wanted to address some of the most pressing questions this evening.   I will deliver a more detailed analysis later.  Here we go:


The Commission states that the D & O addresses three key concerns:  the interconnection process and rules for self-supply systems; the new NEM structure; and TOU opportunities. 


1.  Interconnection: 


a.  report parameters to be expanded


The Commission mandates that the utility must continue to do monthly reports on interconnection progress, and the Commission has expanded the requirements of the report to include the number of days an application has been in queue.  The report will now include both grid supply and self supply systems.


b.  technical requirements for self-supply established


The Commission has ruled on the requirements for self-supply, something that we have been working on for some time.  In a nutshell:  self-supply systems that will fall under the expedited rules can be up to 100 kW (systems over 100 kW can still apply for SIA), inadvertent export can be up to 60 seconds no more than 2 times/day, and  reverse power relays will not be included in the list of possible requirements to ensure non export.


c.  RSWG stipulation


The Commission did not approve the entire stipulation, and specifically questioned the return to service parameters.  I’ll get you more information on this later.


2.  NEM Changes


a.  As of today, the Commission has closed NEM.  All systems already installed and applications that have been submitted as of 10/12/2015 will be grandfathered under the old NEM system.  I will get more clarification as to what this means for applications that have been submitted—do they simply need a post mark, or do they need to been a complete application?


b.  The Rates for export will be as follows for this transitional rate:


Oahu:  15.07 (cents/kWh)

Big Island:  15.14

Maui:  17.16

Molokai:  24.07

Lanai:  27.88


c.  Two year guarantee:


These transitional rates are guaranteed for the next two years


d.  Credits reconciled monthly:


In order to discourage oversizing, the Commission has ordered that export amounts will be trued up each month.  Any credits exceeding load on a monthly basis will be lost.


3.  TOU


The Commission has ruled that TOU makes a lot of sense.  They have ordered the utility to submit a tariff for TOU in the next 30 days.  After that a three-tiered system will be in place for customers to join.  The good news here is that we do not have to wait for widespread adoption of AMI before TOU is an option.  I’ll supply more details on this later.




There’s a lot to take in, and I’ll be sending out a more detailed summary and analysis in this next week.  These new rules are clearly going to impact rooftop, and especially pre-paid leases—which will hit lower income customers the most .   At the same time, the Commission has given storage a boost, and is asking industry to take the lead here.  Also keep in mind that this is the first part of the process as we will now move onto phase 2 of the docket.  Our industry is resilient.  Let’s absorb what we have here and consider our next steps.

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