Click here to see my account of the WV PSC’s attempts, over the recommendations of their own engineering staff, to obstruct solar power development in WV. It took almost exactly a year for WV solar power producers to be certified to sell renewable credits in our own state, when it takes us about a month to be certified to sell out of state credits in surrounding states. All the while, the PSC Commissioners wanted us to provide information that their own staff should have researched before they created WV’s faulty rules.
The whole Alternative and Renewable Portfolio Standard program in WV is a bad joke, as I have pointed out before. Gov. Manchin and the 2009 Legislature designed the law to appear to be a renewable portfolio standard while actually preventing new investment in renewable power in WV.
When the PSC created rules for the ARPS program, they knew that no solar power producers would ever be able to sell credits in WV, because the law was designed to prevent them from ever doing it. So the staff and the Commissioners didn’t even bother to look at other states that had real renewable portfolio standards when they created the rules for WV solar power producers.
As a result, the WV rules contained no application procedure and were inconsistent with PJM’s own rules for producers of renewable energy credits. To apply for certification to sell credits, applicants have to open a new PSC case and provide 12 copies of everything they file. In OH and PA, where many WV producers are certified to sell out of state credits, you file one application form, and, in three weeks or so, you get a certificate.
WV PSC rules also require that WV solar producers must provide their power production records from specialized “revenue quality meters” instead of reading their power output directly from the meters on their inverters or charge controllers. PJM specifically exempts small solar power producers from this requirements, and allows them to report production from their own equipment.
In our year long case at the WV PSC, PSC engineers urged the PSC Commissioners to change their rules to be consistent with practices in other states and PJM. The Commissioners refused, granting us only a “hardship” exemption from existing rules. In other words, solar power producers are truly second class citizens under the WV ARPS rules.
I have since spoken to a few people at the PSC who whined to me how complicated it was to change PSC rules and how I should be happy that we got certified.
So look what happened a few weeks ago. It looks like the PSC is going to open a case to change their rules:
The Commission opens this proceeding to receive comments regarding revisions to the Commission Rules Governing Alternative and Renewable Energy Portfolio Standard (Portfolio Standard Rules), 150 C.S.R. Series 34, relating to 1) the revenue quality meter requirement and 2) the format of an application for certification as a qualified energy resource.
Note in the order that the PSC only required notice of this rule change case in 19 papers around the state. Why not all 55 counties?
And the PSC has all the contact information for all of us who were involved in last year’s case. We were the people who actually knew more about PJM’s rules than the PSC’s own staff. The PSC did order that the power companies should get notice of the rules hearing. The PSC also ordered that everyone involved in the original rules case back in 2010 should get notice. But did the PSC order that the people who actually raised the issue and had been directly involved in educating the PSC about the need for this rule change, for a whole year, should be notified? No. We never got a thing.
Well, now that the PSC’s secret is out, here is the information. Everyone in WV who has an interest in solar power in WV should comment and participate in this case. The case is filed at the WV PSC under General Order 184.31. Here is the case schedule:
It is most helpful to the Commission when suggested revisions are accompanied by proposed language to revise specific rules. In this proceeding, the Commission will only consider proposals to modify the Portfolio Standard Rules that relate to the two issues identified in this Order. Upon review of the comments and proposed language to revise specific rules, the Commission will consider whether to open a rulemaking proceeding and issue proposed amendments to the Portfolio Standard Rules.
IT IS THEREFORE ORDERED that the following schedule is adopted to receive written comments:
Initial Comments 4 p.m. Tuesday, August 6,2013
Reply Comments 4 p.m. Thursday, September 5,2013IT IS FURTHER ORDERED that all comments must contain this case number, General Order Number 184.31, and be addressed to Sandra Squire, Executive Secretary, Public Service Commission of West Virginia, P.O. Box 8 12, Charleston, W. Va. 25323.
Now you know the PSC’s secret that they were trying to keep just between themselves and the power companies. You can bet they will be hearing from me.
