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Interconnection Insurance Requirements for Renewable Energy

Insurance requirements as part of interconnection procedures continue to be an area of debate among utilities, legislatures and renewable energy cogeneration operators.

Utilities and regulators often start from the view that, if a customer's generator damages the grid, then, as a matter of fairness, the customer generator should pay for the damage.

From a cost causation standpoint, this view has intuitive appeal on fairness grounds: ratepayers should not bear the burden for damage to the utility grid caused by customer generation.

However, with over 70,000 solar arrays interconnected across the United States, the authors at the IREC are not aware of any case of line worker injury or significant utility property damage attributable to solar energy systems.

Property Owners Insurance..."Green Insurance?"

Moreover, solar arrays are expensive assets that are almost always covered under a property owner's insurance which would typically provide protection if damage or injury occurs.

Because of this, prohibiting additional insurance requirements in order to interconnect appears to have little practical cost impact for utility ratepayers, but requiring additional insurance does add cost for the system owner.

Virginia has recently implemented interconnection procedures which require customer-generators to carry insurance, but the amounts are no more than what property owners would generally carry:
  • systems under 10 kW must carry $100,000,
  • systems between 10 kW and 500 kW must carry $300,000, and
  • systems between 500 kW and 2 MW must carry $2,000,000.

Net Metering and Interconnection

The IREC participates in state and municipal level workshops, proceedings, and rulemakings focused on net metering, interconnection, and financing of distributed renewable energy technologies.

Net Metering

Twenty-two states and DC changed or adopted net metering laws/regulations in 2009.

New in 2009?  Kansas and Nebraska established new net-metering policies, raising the national state total to 42.

Old news? Many states have seriously flawed rules that inhibit market growth.

According to the IREC, changes implemented in the other states address increasingly complex policy issues, including
  • the treatment of net excess generation
  • renewable energy credit (REC) ownership
  • community-owned systems
  • third-party ownership
Net metering rules by state, using the grades applied in Freeing the Grid 2009, are available at
www.newenergychoices.org.

"Super-sized" net metering (i.e., a 1-MW or greater individual systems capacity limit for at least one customer type) now exists in 20 states.

The most important issue for net metering continues to be the treatment of energy delivered to the electric grid.

The touchstone of the debate centers invariably on concerns over the potential for inter-class subsidies when implementing or expanding net metering programs. This issue was front and center in several states including California due to legislative efforts to expand the aggregate program cap for net-metered systems and the California commission's consideration and ultimate adoption of a cost-benefit methodology for assessing the costs and benefits of distributed generation including net metered systems.

Utilities typically view any framework which values net metered excess generation above avoided costs rates as an undue subsidy to customer-generators from non-participating ratepayers.

Many utilities continue to hold this view despite the ever mounting research finding that the benefits of renewable distributed generation justify valuing net metered excess generation from renewable resources well above a utility's typical avoided cost of generation.

Concerns over the potential for inter-class subsidies underpin many decisions legislatures or state utility commissions make in placing arbitrary caps on the aggregate capacity of net metered systems allowed to participate in state net metering programs.
 

Interconnection Standards

Interconnection standards continue to serve as an essential component of state renewable energy policy. Seven states and Puerto Rico improved interconnection standards over the last year.

For a comprehensive description of IREC's positions on net metering and interconnection issues, see IREC's newly revised model procedures and other documents on IREC's website. For a thorough analysis of the procedures developed in the states in which IREC was active in the past year, see www.dsireusa.org.


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