great to be with all of you at the recent TREIA policy workshop, and I look
forward to working along side you toward the next legislative session in
2009. As we discussed in the solar policy group meeting, however, there
is an important opportunity to help affect policy right now! As we
discussed in the roundtable, the legislature passed legislation that increases
funding for demand-side management programs in areas of
Texas where there is competition (Coops and
Muni areas remain self-regulating). The law has stimulated the PUCT to
reconsider and revise the existing rules underwhich utilities operate the
efficiency incentive programs. At this point the PUCT has held hearings,
taken public comment, and published a proposed Rule (Project 33487). We
anticipate that the rule will come up on the 22nd of February for consideration
and final adoption by the Commissioners. Mostly the news is good.
The commission rules have already allowed on-site solar or "demand-side
renewable" resources to qualify for the program incentives, and this new
rule will set a higher "avoided cost" value for defering or delying
the need for additional power generation. And that will in turn allow
utilities to increase energy payments. But, the proposed rule does not include
in the value of energy savings, or renewable energy, the value of transmission
and distribution costs that are delayed or defered or avoided.
Fortunately, we were able to have the staff include in the preamble to the
proposed rule a question as to whether T&D avoided costs should be credited
to demand-side resources. WE SAY YES, and ask you to help us communicate
the importance of this to the Commission. While this will not avoid the
need to go back to the legislature for further support, it will be a step in
the right direction.
is a letter dealing with the avoided cost calculation formula. Thank you
in advance for your support.
J. King, PE
Congress Avenue, Suite 1400