IEEE & UL & "Guerrillas" [RE-wrenches]

[Bill Brooks]

Todd and Jeff,

These are good examples of bad utility experiences, and I could share a
dozen more that are equally bad, but what do these have to do with the IEEE
929 standard? The standard is being challenged and yet it is the very thing
that is not the problem here. PacifiCorp's left hand doesn't know it has a
right had and New Hampshire has an anthropod in their posterier, but neither
case shows that the standard needs dramatic change. I sympathize with these
problematic situations but they require different types of solutions. The
law is clear in California so using the legal approach is appropriate as my
friend Tom Starrs has done on many occasions. Keep up the good work but
don't lose the big picture. You are part of creating a change that will last
for generations.

Bill.

-----Original Message-----
From: Todd Cory, Mt. Shasta Energy Services [mailto:toddcory at jps.net]
Sent: Friday, May 03, 2002 9:02 AM
To: RE-wrenches at topica.com
Subject: Re: IEEE & UL & "Guerrillas" [RE-wrenches]


Some of you have heard this before, but in light of this thread it seems
appropriate for me to re-tell my experience with grid-tied RE in our area.

I have a similar story to Jeffrey Wolfe's. I was dealing with PacifiCorp
here
on the West coast... in Northern California... this is a case of the utility
blatantly being in violation of the California net metering law. They were
requiring a $500.00 interconnection for a "special dual-register digital
meter"
so they could "measure individual buy and sell totals". Since it is net
metered
there is NO reason for this and if they want to do so the law states:
1) it must be done with the customers permission &
2) it must be done at their expense.

I sent tons of letters had tons of telephone conversations with them, and
sent
tons of e-mails... month after month, all patiently explaining the law and
how
their rules were in violation of them. After I repeatedly got the "brush
off"
(thinking & perhaps hoping I would go away) I decided to get the California
Energy Commission involved. They agreed with my assessment of the violation
and
contacted them on my behalf, again explaining how their rules were in
violation
of the law. No reply. More e-mails, telephone conversations and months
later, I
finally sent them a particularly strong letter demanding they change their
policies to comply with their legal mandates. This resulted in a letter
saying
they would review my concerns at an upcoming meeting. About a month later, I
got a reply stating the finding of their meeting was... (are you ready?)...
that they were in compliance and would not change their policy. Mind you
this
is a company that likes to pat themselves on the back (and include such spam
in
with their utility bills) about how green and concerned with the environment
they are. I wrote them back explaining how sorry I was that they were
refusing
to comply with the law and that I would have to take this case to the
California PUC.

Next I approached the PUC and started jumping through all their hoops. First
an
informal complaint was filed. After another period a month or so, it was
affirmed that the the utility was indeed out of compliance, which allowed
the
next step, a  formal complaint. I filed this. This is when Tom Starrs (who
wrote the California Net Metering law) helped out and spoke to some of his
friends within the PUC giving them a "heads up" about the case. I believe
this
seriously (thankfully) expedited the whole process. Soon, I received copies
of
the official litigation papers the PUC sent to PacifiCorp indicating they
were
suing them on my behalf.

Suddenly, the utility company saw the light, understood what I had been
politely and patiently saying to them for the last ~10 months. They said
they
would change their tariffs so as to comply. I find it interesting that it
took
litigation to get this "green" company to "understand"... (sigh). As a part
of
our settlement agreement, as asked for them to comply with the law, refund
the
$500.00 fee to everyone they had charged it to, and pay me $3500.00 for the
time I spent screwing around with them as they obviously and intentionally
obstructed their mandate to allow net metered systems in our service area.

CLEARLY if there had not been litigation to force them to comply, they would
still be in violation of the law.

End of story? Wait there is more.

Last summer, seeing a (since canceled) net metered system in the pipeline
for
this summer, I contacted them for a sample contract and details regarding
what
interconnection equipment they would allow. I got a call back in about
November
saying they had received my request and "were working on it". It is now May
and
I am still waiting...

And some people get upset because folks don't want to hassle with this BS
and
just "go guerilla"? Give me a break. Some people do have lives to live and
better things to do then fight obstructionist utilities all day long. If you
enjoy fighting the strong arm tactics of their defiance, great. But I know
of
many that choose an easier way, just do it anyway. I have seen several
guerilla
systems. They use listed equipment installed in a safe, code compliant
fashion.
The only difference is they do not have the "utility seal of approval". Some
people have found that the price for that seal is just too costly in terms
of
money and mortality spent on such. Can you blame them for just "doing it
anyway"?

This kind of things happen in many aspects of most people's lives. Some
people
prefer to do it all "by the book", above the table, ducks all in a row. Some
don't want the hassle and bother, so here and there they do some things
under
the table. There is so much red tape and BS to deal with every where you
turn
these days. Most of which is aimed at "collecting fees" (another word for
taxes) or insuring "safety" and so forth. When the "right way" becomes the
simple (and inexpensive) way, everyone will do it. Until then, there will be
many that will prefer the simpler, cheaper and easier way. I put forth that
it
is those that take this route that actually promote less bureaucracy in
everyone's lives. The regulators want their user fees, taxes, permits,
licenses
etc. AND they are also smart enough to know if they make it too difficult,
they
will regulate themselves right out of their income.

Maybe someday the utilities will get the message that distributed RE is here
to
stay and they need to "get with the program" here and be the concerned,
green
folks they like to promote themselves as. Until then, those working on the
front lines:
at the negotiation tables towards easy, boilerplate interconnections  and
those guerillas down in the trenches will have to keep at it.

Both are working through different means to achieve the same ends.

my .02

Todd


"Jeffrey Wolfe, Global Resources" wrote:

> Some facts, some rant, some rally.
>
> It's not just the backyard folks who are being pushed to guerrilla status.
> We've got two systems right now, one 3 kW on a private school, and one 52
> kW on a state government building, in different states, that are being
held
> up purely for obstructionist reasons. Cases in point:
>
> 1.  Trace ST2500, installed in the state of NH. Thius inverter has been
> instaled in how many states, in how many utility jurisdicitons? But in NH,
> the ST must undergo another test, a test that requires the destruction of
> several units, to prove that when they are destroyed (through a simulated
> lightning strike) they fail properly. Seems prudent, and other states
> require this. But NH also requires that this test be completed when the
> inverter is not putting out any power at the time of the strike (0 power
> state). No other state rquires this. What do the NH utility folks, who
> pushed for this, know that no one else knows? (In fact, a friend of mine
> who is a local manager for a small segment of Nat Grid, opposed the rule,
> but NU (PSNH) pushed for it, and being the dominant utility, they won.
>
> Documentation, including a letter from UL stating that the 0 power test is
> functionally equivalent to a 50% power test (which has been completed) has
> been submitted to the NHPUC. No action. We started this in December 2001
> (Thought I'd write the year, in case I need to dig this email up in a
> couple years for documentation.) No, the PUC is not the utlity. But, they
> certainly are not really independent of them. Each week, Xantrex inquires
> and gets the answer that there should be an answer Friday. (Guess we need
> to ask "which Friday")
>
> This school, made up of fine law abiding citizens, may go guerrilla. Of
> course the whole thing is stupid. Its a 3 kW array. The building will
never
> let the power get to the meter. Of course, if there is a failure...
>
> 2.  We just finished installing a 52 kW PowerLight system in NY. Of
course,
> the inverter is not in yet (held up by UL, but I just got word it ships
> tomorrow ) and Niagra Mohawk (the local utility) just responded to the
> interconnection application with a 6" thick pile of paper, a request for a
> $3000 fee for "review" and a statement that they will meter the power WE
> produce and charge US 2.5 cents per kWh generated. (This is actually
> allowed in NY for systems over 50 kW, but ours is rated at 40 kW AC, and
> the inverter is only 45 kW, so the rule shouldn't apply, but they still
try
> to throw it at us, thinking we might not know better.)
>
> Of  course, the same building already had 15 kW of fuel cells tied into
the
> building with net metering (yes, the utility actually DID meter those, and
> the building PAID 2.5 cents/kwh for the net metered power). The building
> also has already paid over $5000 to the utility for the engineering study
> for the interconnection of the fuel cells. So what's the big difference
> with the PV? Also, since the Trace Tech 45 kW inverter has not been "type
> tested" for the state of NY, we need to install a separate relay system
> with a shunt trip device to duplicate the UL1741 grid tie equipment. Not
to
> worry though, we'll probably need the shunt trip breaker anyway, since the
> utility will probably require a disconnect switch at the main electrical
> service entrance, for the PV. Too bad we put the PV on the roof of a 6
> story building. Lots of copper coming through a completed building if they
> wont let us use the shunt trip.
>
> All this in a state where the Governor has declared that 10% of the
> electricity in state building will be provided through RE and efficiency
by
> 2005 (I think) and 20% by 2010 (I think). All this in a state where
NYSERDA
> funded over half the project. And this project is within several blocks of
> NYSERDA and the state capital.
>
> On a side note, Rochester (NY) Gas and Electric has a customer with an
> installation of several capstone turbines (which are allowed to
> interconnect in NY). RG&E charged $350 for the interconnection study, and
> did it quickly. They have been cautious, prudent, and non-obstructionist.
>
> Ok, enough detail, you get the picture. It really is the utilities that
are
> forcing the issue with guerrilla solar (what shall the customer with a 52
> kW(DC) system do, with all UL listed equipment and complete, stamped,
> enginering designs, if the utility will not reasonably allow
> interconnection? (Sure, we should have gotten the approval first. It's
> called, "Grant Deadlines".) Having constructed millions of square feet of
> buildings, working with utilities from ComEd (Chicago, ooooo so
regressive)
> to Boston, and NH (some great small ones) I've seen how utilities work.
> They are not easy to work with even in getting a new service for a large
> commercial. They have their ways. But they do get the job done, and they
> are predictable. This is NOT how many of them act with interconnection.
>
> Yes, we can work through the standards process, but really, who does
> control the standards process? Yes, we can be involved, but if my business
> card says "behomouth utility", people listen more than if it says "solar
> bozo". People want to trust people, and the utilities take advantage of
> that, and control the standards process through lies and half-truths and
> unfounded claims. Having been deeply involved in the creation of the net
> metering regulations for VT, I saw first hand how everything we said was
> discounted, because "obviously" we were just trying to get the least
> restrictive laws passed, whereas the utilities were "only concerned with
> public safety". The day before we finally got a hearing in front of the
> joint rules committee of the House and Senate, the Chair of the Public
> Service Board publically asked all utilities to show up at the hearing and
> show public support for the PSB position and proposed regs. Guess they got
> a few chits for it...
>
> Come on. Pull off the gloves. Sure, we need to work with the folks, but
> "work with" doesn't mean "expose body parts for flailing". We need to be
> aggressive on ALL fronts. The utilites are. Seen the newspaper adds in DC?
>
> Enough Rant, back to work.
>
> Jeff
> Jeffery D. Wolfe, P.E.
> Global Resource Options, LLP
> A Woman-Owned Limited Liability Partnership
> 4 Kibling Hill Road
> P.O. Box 161
> Strafford, Vermont 05072
> 800-374-4494 Toll Free
> 802-765-4632 Phone
> 802-765-9983 Fax
> global at sover.net
> http://www.GlobalResourceOptions.com
>
> Nextek Certified Distributor
> SolarWall Certified Distributor
> Trace Certified Dealer - Charter Member
> Bergey Windpower Certified Dealer

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