Solar San Antonio
Board of Directors
Resolution in Response to CPS Energy Proposed Distributed Generation Program
Whereas, the mission of Solar San Antonio is to increase the adoption of renewable energy
within San Antonio; and
Whereas, solar energy is a major source of renewable energy; and
Whereas, the extensive deployment of solar energy – both utility scale and distributed – is
critical to San Antonio’s energy future; and
Whereas, representatives of the solar industry, including Solar San Antonio, have met with
representatives of CPS Energy in a Solar Working Group over the past year to
identify effective distributed solar utility programs in the CPS Energy service area;
and
Whereas, CPS Energy developed a plan for a distributed solar program that involved
various elements, including:
-- the addition of a monthly grid fee to be paid to CPS Energy by new solar
adopters for the life of their solar systems;
-- a commitment to increase the solar rebate budget by $21
million;
-- a commitment to deployment of 25 megawatts of
distributed solar from the date the new program is implemented;
-- a commitment to adjust the solar rebate to maintain a ten year or less payback
period for residential solar adopters as long as that adjustment does not result in
CPS Energy paying more than 50% of the total cost of the installation; and
-- the addition of a commissioning fee to recover CPSE costs of setting up a
new solar installation with a fixed fee for residential installations and
a cost of service fee for commercial installations; and
Whereas, CPS Energy announced its proposal on May 13, 2014 without contact or
agreement of the Solar Working Group, with a projected schedule of CPS Energy
Board approval on May 19, 2014; City Council approval in June 2014; and
implementation beginning on July 1, 2014; and
Whereas, the Solar San Antonio Board passed a resolution urging the CPS Energy Board to
refer the proposal back to the Solar Working Group for further discussion; and
Whereas, the CPS Energy Board, instead, did approve the proposal on May 19, 2014; and
Whereas, the Solar San Antonio Board appreciates the intention to support distributed
solar in the proposed program; and
Whereas, the Board of Solar San Antonio appreciates that CPS Energy participated
promptly and fully in the discussion held by the Board over the past four weeks; and
Whereas, despite the positive elements of the proposal, the Solar San Antonio Board of
Directors cannot support the proposed grid fee as part of the new program for
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1.
the proposed grid fee is a matter of great contention nationally; and
2.
the imposition of such a fee could damage San Antonio’s reputation nationally as a
solar leader; and
3.
the proposed grid fee raises serious questions of fairness in that the fee is only
assessed on solar adopters and not on other customers, who also reduce their usage
producing a reduction in the utility’s fixed cost recovery, such as those adopting
energy conservation and energy efficiency measures; and
4.
CPS Energy has not provided a methodology for determining how much fixed cost
recovery is actually reduced by a solar adopter on a net basis taking into account the
extra value added by solar distributed generation; and
5.
there have been two studies to date documenting that the economic benefits to the
utility of distributed solar outweigh any costs attributable to solar adoption; and
6.
CPS Energy has used total income reduction, rather than only fixed cost recovery
reduction, in calculating their fixed cost recovery reduction; and
7.
there can be no serious liability attributable to reduced fixed cost recovery by solar
adopters at this time because solar represents less than .17% (less than 1%) of the
total CPS Energy capacity; and
8.
the imposition of the grid fee only on future solar adopters does very little to solve
any longer term problem of a generalized reduction in ratepayer contribution
towards fixed cost recovery resulting from reduced demand; and
9.
Solar San Antonio has received numerous expressions of concern from local solar
installation companies, national solar organizations, and national solar companies
about the grid fee and its potential impact on the industry nationally; and
10.
the imposition of the grid fee may suppress the adoption of solar by home owners,
business owners, and builders of new homes and commercial buildings; and
11.
The grid fee can stifle solar economic development potential in possible new local
industries, such as batteries and solar control technologies
Therefore, Be It Resolved, that the Solar San Antonio Board of Directors urges the San
Antonio City Council to reject the CPS Energy proposal to impose a grid fee on new
solar adopters; and
Be It Further Resolved, that the Solar San Antonio Board urges City Council to encourage
CPS Energy to allocate additional solar rebate funds and conduct studies with local
and independent outside consultation to refine the solar program proposal to
account for distributed solar costs and benefits; and
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Be It Further Resolved, that the Solar San Antonio Board pledges the cooperation of Solar
San Antonio in seeking a solution that more transparently addresses the interests of
CPS Energy and other stakeholders through continued participation in a Solar
Working Group.
Be it Further Resolved, that the Solar San Antonio Board of Directors directs the Solar San
Antonio staff to transmit this resolution and accompanying document to the Mayor
and members of the San Antonio City Council.
Dated: June 11, 2014
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