Microgrid and Community Resilience Centers Pilot Grant Program - CBR Public Comment to PSC

Public Comment:                                                                                                           March 29, 2021
Ref: SEP Docket 9705-FG-2020
Steffany Coker
Public Service Commission
 
One barrier to the Microgrid and Community Resilience Centers Pilot Grant Program might be the legislative restrictions in place regarding metering and subsequent interpretation of those rules by the utilities.  Chapter PSC 113, SERVICE RULES FOR ELECTRICAL UTILITIES, Subchapter VIII — General Customer Metering and Meter Accuracy, paragraph PSC 113.0803 requires each tenant in a commercial building to have an individual meter. 

As an example of this potential barrier, in 2018 Bayfield County and the City of Washburn, co-owners of several Housing Authority buildings in that city, considered requesting a waiver to the Public Service Commission for master metering two of their buildings.  Each apartment in the buildings has a separate meter.  A master meter on each building would have saved hundreds of dollars per year in facility charges to the Housing Authority who pays all the utility bills, as well as readied the buildings for solar PV integration and battery storage for increased resilience.  Xcel Energy reviewed PSC 113.0803 and all parties agreed that the legal language written therein prevented the master metering of the buildings.  To make matters worse, two Housing Authority buildings, built prior to 1980, are master metered to which PSC 113.0803 doesn’t apply, but the buildings do not have a “solar window”. 

Xcel Energy has a current active docket before the PSC (4220-TE-106) Resiliency Service Pilot, but it is for large commercial customers who take service from a single meter.  Our other local utility, Bayfield Electric Cooperative, does not allow behind-the-meter transfer of electricity across property lines.

Under current regulations individual buildings with a single meter can successfully form a microgrid. An example is the Bad River Bad of Lake Superior Chippewa’s three recently installed microgrids.  These buildings are “essential” tribal facilities as outlined in their 2018 Pre-disaster Mitigation Plan.  This type of facility complies with current utility rules and might be the only focus allowed for the Microgrid and Community Resilience Centers Pilot Grant Program.  Community centers, schools, and government buildings are good examples of potential candidates.

To consider low-income housing as part of the Microgrid and Community Resilience Centers Pilot Grant Program, the PSC might review PSC 113.0803 and determine how it could be amended to allow master metering of apartment-style buildings or even a neighborhood or other groups of buildings. I believe the original intention of this rule in 1980 was to make tenants responsible for their electric consumption and thereby conserve energy (remember the Arab oil embargos of the 1970’s).  With today’s technology, submetering individual apartments via wi-fi and data loggers could easily accomplish this goal and also allow for the goals of the resiliency program. An example of this type of submetering is laid out in Xcel’s EVR-1 tariff, where EV charging is submetered without the addition of a “meter”.
​
Submitted by,
 
Bill Bailey
Cheq Bay Renewables
[email protected]