http://www.env.state.ma.us/dpu/docs/electric/...
Ronald DiPippo, Ph.D.
RENEWABLE ENERGY CONSULTANT --GEOTHERMAL& WIND SPECIALIST
October 2, 2009
Re. DPU 09-71, 09-72, 09-73, 09-74 – Net Metering Tariff Comments from Town of Dartmouth Alternative Energy Committee
Dear Ms. Collins:
Town of Dartmouth has been closely tracking the DPU Net Metering Tariff setting process and are quite concerned over one aspect of the near-final Tariff.

Unfortunately, the draft Tariff as currently written fails to establish a coherent rate structure or objective standards for Rate Class setting. This, we believe, is a big problem for the following reasons:
1
1.
Finance plans for community wind projects do not have large margins and are predicated on locking in a favorable rate under the Tariff. These projects take a tremendous effort to get approved at the local and state levels. If the return is too small, communities will simply choose not to pursue these projects and instead focus on other initiatives;
2.
To satisfy lenders/bond issuers, as much uncertainty as possible needs to be eliminated as early as possible in the process, so a well-defined process is highly important;
3.
Forcing communities to negotiate with their distribution companies in an open-ended process adds an administrative/legal burden that many towns will have a hard time funding and many distribution companies would likely prefer not to be involved in;
4.
The distribution companies are entitled to cost recovery regardless of the Rate Class used, so specifying a favorable rate for community wind projects will not adversely impact the distribution companies financially;
5.
Establishing a single Rate Class sufficiently favorable to effectuate community wind and other eligible projects will not harm ratepayers. The primary goal of the Green Communities Act is to create an economic framework that allows renewable energy projects to be built, and moves us closer to meeting Renewable Portfolio Standard objectives.. However, if too low a Rate Class is established, or if the matter is left to the distribution companies’ discretion, potentially viable projects will not be built, and the goals of the Green Communities Act will very likely not be realized;
6.
Giving the distribution companies veto power on setting the Rate Class would give the utility the power to kill good wind projects or punish municipal customers they may have issues with on other fronts - simply put, they may choose to be difficult, as has certainly been the case in other matters.
We encourage the DPU to specify a single, favorable Rate Class in its final Tariff, rather than leaving in place an open-ended, ill-defined process whereby the utilities are turned into regulators, and the future of renewable energy development in Massachusetts is left to chance.
Specifically, the DPU should establish a simple net metering tariff in which full retail value for all excess generation is either credited to the customer’s next bill or paid to the customer monthly in cash. This would replicate the successful systems in place in thirty-one
(31) states plus Puerto Rico and the Virgin Islands; Interstate Renewable Energy Council, October 2008:
http://www.irecusa.org/fileadmin/user_upload/... .
Thank you for your consideration of these comments.
written signature of Ronald DiPippo, Ph. Dwritten signature of Ronald DiPippo, Ph. Dwritten signature of Ronald DiPippo, Ph. D
Ronald DiPippo, Ph.D.
Chairman, Dartmouth Alternative Energy Committee
Members of the Dartmouth Alternative Energy Committee:
Edward F. Iacaponi, Ex-Officio; Nathalie Dias, Kevern Joyce, Arthur Larrivee, Paul Lopes,
Raymond Medeiros, Roger Race, Saul Raposo and Joseph Sousa
Cc/ Mark D. Marini, Secretary, Department of Public Utilities, One South Station, Boston, Massachusetts, 02110 (Original + 2 copies, mailed)
John K. Habib, Esq., Keegan