DERTF: Use Case Studies (IR070) (20210830)

Solarize Indiana is an Indiana not-for-profit corporation organized “exclusively for charitable and educational purposes under section 501(c)(3) of the Internal Revenue Code.,” In particular, Solarize “seeks to protect the environment and the public welfare by accelerating the adoption of clean, renewable energy through well-informed public and private energy choices.” See Articles of Incorporation, filed August 29, 2019, esp. Article II.1

The founders and directors of SI believe that climate change is an existential threat to life on Earth as we have known it and would like our progeny to experience it for the next seven generations and beyond. Accordingly, we believe that the accelerated adoption of clean, renewable energy is essential to protect the environment and public welfare.

The founders and directors of SI also believe in energy freedom, not energy serfdom, for energy consumers. Accordingly, we also believe that the accelerated adoption of clean, renewable energy is best achieved through the well-informed public and private energy choices of a free people, not the dictates of energy oligarchs or political autocrats.

The founders and directors of SI are also all clean energy activists who have spent many years and countless hours of our own scarcest resource – our time -- studying, evaluating, discussing, debating and experimenting with alternative approaches to the accelerated adoption of clean, renewable energy through the well-informed choices of a free people. We have also all spent considerable sums of our own scarce financial resources “practicing what we preach” in that regard and then learning further from that experience.

As a result of our shared learning experiences, SI’s founders and directors have come to believe that the so-called “Solarize Model”2 of collective action and social diffusion of technological innovation is the best way by which we as individuals and SI as an organization can accelerate the adoption of clean, renewable energy, including distributed solar generation and associated distributed energy resources (DERs), through the well-informed public and private choices of a free people.

Nationally, the first Solarize campaign began in 2009 with southeast Portland, OR residents who wanted to install solar power, but did not know where to start. They imagined that if they could organize a group of neighbors to “go solar” together, they could collectively make an informed purchase and negotiate a volume discount. They turned to the local neighborhood coalition, Southeast Uplift, for assistance. Southeast Uplift approached Energy Trust of Oregon for technical and program planning support. By coincidence, Energy Trust had developed a solar PV volume purchasing program and was eager to test the model. With community volunteers, neighborhood association staff, and Energy Trust support and rebates, the first Solarize campaign was born.

Within six months of starting their campaign, Solarize Southeast had signed up more than 300 residents and installed solar on 130 homes. The 130 installations added 350 kilowatts of new PV capacity to Portland and created 18 professional-wage jobs for site assessors, engineers, project managers, journeyman electricians, and roofers. Given these results, the neighborhood collective purchase concept spread quickly. With support from a DOE Solar America Communities grant, the City of Portland’s Bureau of Planning and Sustainability helped other community organizations take Solarize Portland to their neighborhoods, eventually completing projects that encompassed every neighborhood in the City. Taken together, these follow-on projects produced another 400 Solarize installations in 2010, increasing total PV installations almost 400% over the previous year. In 2011, the number of Solarize neighborhood campaigns and installations fell, but overall, PV installations in Portland remained high, with an increasing number of non-Solarize installations.3

In short, the Solarize Model worked initially in several Portland neighborhoods, so it was extensively copied elsewhere, where it has also worked effectively. Since 2009, the Solarize Model has been replicated in numerous Oregon communities, including additional Portland neighborhoods outside the City’s southeast quadrant. Indeed, more than 20 Solarize efforts were initiated throughout the state with 3,100 enrollments resulting in approximately 1,000 solar system installations. The peak year was 2010 with more than 500 Solarize installations representing 50 percent of the Oregon Energy Trust’s residential solar activity. That same year, the Energy Trust also received a State Leadership in Clean Energy award for its involvement in helping develop the initial Solarize effort in Portland.4
Other states then adopted the Solarize Model as well. Massachusetts5 and Connecticut6 followed Oregon’s lead in developing successful Solarize projects in many New England communities. Subsequently, the Solarize Model has been applied in communities in many states, far and wide, including Alaska,7 New York,8 North Carolina,9 and Texas,10 as well as here in Indiana.

Solarize Indiana mobilized initially as a short-term effort to respond to a new law, SEA 309, that was signed into law in May 2017. Between January 1, 2018 and June 30, 2022, the law reduces regulatory support for new distributed solar investments from full net metering to no net metering, thereby dramatically increasing over that four and one-half year period the time distributed solar owners would need to recoup their solar investments. With the law’s initial downward step scheduled to take effect in January 2018, Solarize Indiana aimed to quickly expand the number of solar owners by making it simpler and cheaper to have panels installed by December 31, 2017. By late July, a steering committee had formed, developed tools to equip local teams, disseminated a request for proposals to 30 solar installers, and recruited and trained local Solarize teams from South Bend in the north to Evansville in the south.

By late September, thirteen Solarize teams had promoted and organized 65 information sessions that reached over 1400 Hoosiers. As a result, over 280 property owners signed solar contracts through the 2017 Solarize program – increasing the number of recorded solar rooftop installations in Indiana by over 20%. Of the eight solar firms selected as Solarize partners, five expanded as a result of their participation. The initiative attracted dozens of news stories including a national VICE News Tonight clip and a syndicated report by the Energy News Network. Due to these stellar efforts following the enactment of SEA 309, Solarize Indiana was honored as “Sustainability Champion of the Year” by the Hoosier Environmental Council at its statewide Greening the Statehouse event in December 2017.

Solarize Indiana successfully reorganized as a tax-exempt, not-for-profit corporation in 2019 and, in that organizational form, has continued to recruit, train and support new Solarize Teams for state-wide impact. SI is an all-volunteer network governed by a Board of Directors comprised of leaders from each local Solarize community (known as Team Leaders), as well as others with special skills to perform key statewide functions of the organization. In addition to providing a corporate structure for its local teams, Solarize Indiana also hosts annual training sessions to leverage the experience of existing teams in launching new teams and adapting the Solarize program to new Indiana solar policies.

Impelled by their initial success, many of the local SI teams opted to continue their efforts in 2018, 2019 and, COVID-19 notwithstanding, 2020 and 2021. From May 2017 through April 2021, these local teams have recruited over 100 volunteers, most of whom have participated in one or more SI s training sessions and many of whom have served their communities for multiple years. To support local teams, SI provides ongoing consulting advice, a complete array of customizable online tools, and various templates for solar installation, promotion and monitoring, as well regular conference calls to discuss technical challenges and lessons learned from around the State. Statewide, from January, 2019 through April 2021, these teams have facilitated the execution of 230 contracts for distributed solar installations -- notwithstanding the onset of the COVID-19 Pandemic in March 2020 and its continuation into 2021.

As a result of its organizational experience to date, SI believes that the approval of Order 2222 by FERC and its timely, systematic implementation by MISO in the State of Indiana will facilitate the adoption of distributed solar generation and associated distributed energy resources (DERs) by small residential and commercial customer-generators and thereby accelerate the electrification of the buildings and transportation sectors of the Indiana economy as required for the State -- in conjunction with the deep decarbonization of its electric power sector -- to effectively confront the global climate crisis.

However, due to the scale of the systemic change proposed, the complexity of the technologies involved, and the controversy of the public policies required, SI also believes that MISO’s implementation of Order 2222 with respect to small residential and commercial customers will be especially challenging throughout its footprint but particularly in jurisdictions like Indiana having important vertically-integrated electric utilities still imbued with monopolistic corporate mindsets and owning significant amounts of stranded central-station generation assets.

Accordingly, Solarize Indiana welcomes with great interest and expectation MISO’s initial DERs “use cases” for further study, analysis and discussion, especially but not exclusively Use Case Chestnut (presented on slide 7 of the “Utilizing Use Cases to Explore Design” presentation given at the August 30 DERs Task Force Meeting). To advance such further study, analysis and discussion in more depth and detail, SI joins in the insightful Comments of Solar United Neighbors on Order No. 2222 Use Case Studies from 8/30/2021 MISO DER Task Force.

Thank you for your consideration of SI’s views on these monumental matters for the future of the electric industry not only within the MISO footprint but in the nation and the world.

Respectfully,

Michael A. Mullett, Advocacy Team Lead
Solarize Indiana, Inc.
mullettgen@aol.com
(812) 350-0707

Notes:

1 Available at https://bsd.sos.in.gov/PublicBusinessSearch/GetBOSNameReservationFilingDocuments?FilingNo=8368055
2 See L. Irvine, A. Sawyer and J. Grove, The Solarize Guidebook, at 6-7 (U.S. Dept. of Energy 2012), https://www.nrel.gov/docs/fy12osti/54738.pdf.
3 See Id., at 3-4.
4 Solarize efforts successful in Oregon, model for other states, https://blog.energytrust.org/solarize-efforts- successful-in-oregon-model-for-other-states/.
5 See https://www.masscec.com/solarize-mass-1.
6 See http://www.grentowns.com/initiative/solarize-connecticut.
7 See http://kenaichange.org/solarize/.
8 See https://nhnsolarize.org/landing/.
9 See http://solarize-nc.org/.
10 See https://solarizetexas.org/.

Xcel Energy appreciates the opportunity to provide feedback requested in the DERTF on 8/30/21.  We are supportive of MISO's proposal to align DER aggregation registration and revisions with the schedule of topology model updates. 

Regarding the use cases, we would like to see a use case that consists of a group of small batteries that each have the ability to inject to the system.   One of the benefits of the use cases is the depiction of the metering requirements so we would ask that a metering requirement diagram (like the one on slide 63 in the third iteration of the Coordination Framework, presented on 8/30/21) be developed for each of the use cases. 

Comments of Solar United Neighbors on Order No. 2222 Use Case Studies from 8/30/2021 MISO DER Task Force

Solar United Neighbors (SUN) is a national, grassroots 501(c)(3) nonprofit organization that represents the needs and interests of solar owners and supporters. Since 2007, we’ve helped more than 6,000 families and businesses install DG solar representing more than 50 MW of nameplate capacity. In MISO’s territory, SUN has state programs in Minnesota and Indiana, where we have facilitated nearly 250 DG solar installations representing more than 2 MW of nameplate capacity and have educated thousands more about solar technology, economics, and policies. Many of our supporters own other DERs like smart thermostats, EVs, and battery storage.

We envision a clean, just, and equitable electric power system that directs benefits, choice, and control back to local communities, with rooftop solar as the cornerstone. Properly implementing Order No. 2222 in MISO would be a step in the right direction towards reaching that goal.

Thank you for the opportunity to provide comments on MISO’s early use cases that have been developed to help guide implementation of Order No. 2222. As an organization that represents thousands of current and potential small-scale DER owners in MISO, we wanted to share comments focused on fair market design and access, transparency, and data ownership that we believe are most relevant to Use Case Chestnut (presented on slide 7 of the “Utilizing Use Cases to Explore Design” presentation given at the August 30 DER Task Force Meeting), but that can also be generalizable to broader program implementation considerations.

• Market Design:

• In general, we favor markets with competition and transparency. 

• Market rules should enable participation (entry and exit), facilitate innovation, and enable participants to realize value.

• Fair Market Access:

• Individual DER owners should be eligible to participate in relevant programs without discrimination.

• Any monitoring and/or telemetry requirements for individual DER owners to participate should be reasonable and designed so that additional costs or regulatory burden do not disincentivize or bar participation by eligible customers.

• Individual DER owners must be provided with accurate information regarding how participation in aggregator programs might impact any retail or other programs in which they may already be enrolled.

• The market should be structured with fairness and equity in mind so that all eligible customers have an equal opportunity to participate.

• Transparency: 

• The necessary data to make those decisions should be available to individual DER owners in a timely fashion as well as the other parties operating in the market. Market products should be simple, transparent, and easy to access for all eligible customers.

• Data Ownership: 

• Individual DER owners retain ownership rights of the data used by other parties engaging in the market (aggregators, LSEs, etc.) and control of decisions about who to transact with, who gets to use that data while servicing the grid, and on what terms.

 Thank you again for the opportunity to provide comments at this time. We look forward to continuing participation in MISO’s implementation planning process going forward.

Sincerely,

Zach Schalk
Indiana Program Director
Solar United Neighbors