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

Fri May 3 13:21:41 PDT 2002

Bill,

I work both (and sometimes 3) sides of the table. While both of my examples 
do not reflect poorly specifically on IEEE 929, they do concern established 
state laws and regulations in each case. Laws and regulations that were 
crafted under "more than equal" influence of the utilities. All too often 
the local utilities, in my somewhat limited experience, will work to have 
IEEE 929 adopted into the law and regulations in a way that negates much of 
the "openess" that the standard was supposed to acheive. Such as putting on 
"one additional test", or a difficult / bureacratic standard for connection 
procedures. This way they can "support national standards" but totally 
pervert the intention of those very standards.

Working with the utilities, creating grassroots support, creating 
demonstrative action (unfortunately both legal and illegal), legislative 
lobbying, political action, and more, are ALL required to move our culture. 
No one method will work. Never underestimate how much some folks at the 
very top of the US energy industry want to exclude renewables from our 
energy mix. It is beyond anything you and I would call reason. I am not a 
conspiracy person, and I don't believe it's a "conspiracy". To them, it's 
just "business". They see us as competitors now, and a future theat to 
their very existence (profitability). (Personal conversations with Vermont 
utility lobbyists, who I know socially, have completely firmed up what used 
to be simply "my belief". It's a fact.)

The established energy industry has pulled out the stops with the current 
administration. They have pulled out legal, and I believe many illegal, 
stops. (Subverting clean air legislation, illegal accounting and political 
contributions, etc.) So while I truly do support, appreciate, and encourage 
your (and my) continued efforts in the standards and policy arena, I also 
suport, appreciate, and encouage all efforts that go outside those 
boundaries.

Jeff

On Friday, May 03, 2002 2:23 PM, Bill Brooks 
[SMTP:billbrooks7 at earthlink.net] wrote:
> 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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