PUBLIC SERVICE COMMISSION OF WEST VIRGINIA

Transcription

1 PUBLIC SERVICE COMMISSION OF WEST VIRGINIA Bill Howley and Loren Howley I- WV PSC Case E-P Petition for Certification of Solar Power Facility fy,.i& FN R- h;; z&rt p as Renewable Energy Resource Facility under W. Va. Code Chapter 24-2F-4 and PSC Title 150 Series 134( 150CRS3.22, and c d EXEi $Et fi3 e PETITIONERS RESPONSE TO AUGUST 31,2012 COMMISSION ORDER The Petitioners, Bill Howley and Loren Howley, pro se, respectfully enter this response to the above-referenced Commission Order to provide further explanation of our system as ordered in that Commission Order. DISCUSSION In its Order dated August 3 1,2012, the Commission ordered that applicants should file the following information with the Commission: Additional information within thirty (30) days of this Order about the meter used at their facility to record the output of energy produced from the solar generator including: (i) the meter s design and manufacturer s specifications for energy output data collection, (ii) a description of how the energy output data is collected, recorded and delivered for use to GATS, (iii) the identification of any electrical codes and standards that apply to and are met by the meter, (iv) a statement regarding whether the generator is a net-metered customer, and (v) if the facility is certified in another PJM state or the District of Columbia, whether or not that certification process required a revenue-quality meter. We have already provided much of this information in our revised petition in this case, but in the interests of clarity, we will repeat that information below. As noted at several points in our Response below, Petitioners respectfully state that they believe that several aspects of the Commission s August 3 1,20 12 Order represent an undue burden on any applicants for certification to sell renewable energy credits in West Virginia. In page 1 of 7

2 prior pleadings in this case, the Commission s staff has provided well researched and clear statements of the facts of certification processes in the PJM Interconnection region and has recommended that the Commission revise its rules to conform to those standards. If the Commission wishes further information concerning engineering specifications or the legal reasoning or regulations used in other states, it has the services of a paid staff to answer those questions. The burden of this research should not be placed on the shoulders of applicants for certification who have acted in good faith and are making a valuable investment in our state s energy future. PETITIONERS RESPONSE 1. Meter s design and manufacturer s specifications for energy output data collection The following is the overall description of our system: a. b. c. d. e. Interconnection date with Mon Power system - 9/24/20 10 Array mount - awning mount on garage building Array orientation from North degrees Array tilt from horizontal - 38 degrees The system is grid tied with a battery backup consisting of 8 six volt deep cycle batteries. f. Photovoltaic module specifications - Manufacturer: Solar World Model #: SW230 Mono Number of modules: 6 Module (DC) rating: 230 watts Total rated output of array: 1.38 kilowatts g. Inverter specifications - Manufacturer: Xantrex Inverter Model #: XW /240 Charge Controller Model#: XW-MPPTGO-150 Number of inverters: 1 The meter measuring power output from our PV panels is integrated into the charge controller on the system as shown in Exhibit A of PETITIONERS RESPONSE TO page 2 of 7

3 MARCH 28,2012 COMMISSION ORDER AND FURTHER JOINT STAFF MEMORANDUM. Total cumulative output is one of a number of output data that is displayed by the system charge controller s digital meter. The meter can also display monthly output, daily output for the past thirty days and a number of other data. We have no engineering expertise, so we cannot offer any expert opinion concerning the value or problems with installing additional ANSI certified meters to our system, but we offer the following observations, based on our experience. It appears that installing an ANSI certified meter between the solar panel array and our inverter would not be practical because the panels put out direct current power at varying voltages which would make it impossible for a standard revenue quality meter to accurately measure output in kilowatt hours. The location of the meter between the PV array and the inverter would also, quite likely interfere with the operation of the system as a whole and could possibly damage our equipment. The only other possible location for a revenue quality meter would be as power is leaving the inverter. In the case of our hybrid system, this would entail the installation of two different meters, because power leaving our inverter is immediately routed to our battery array and to our main breaker panel. Power flows on these circuits are bidirectional, so readings taken by a standard ANSI certified bidirectional meter would be net readings. It would be impossible to calculate total output of the PV panels on the system from these meters. The location of our system PV system output meter as an integral part of our system s charge controller is thus the only logical and safe location for an output meter in our kind of hybrid system. page 3 of 7

4 We do have two ANSI certified mechanical meters on our system, but they measure bidirectional power flows between our battery array and our critical loads panel and power flows between the inverter and our main breaker panel. Because these meters measure some overlapping bidirectional power flows on the system as a whole, and because neither of the meters measures raw output from our PV array, it would be impossible to calculate total PV output accurately from the data on these meters. We have actually tried, and it is impossible to come up with a number that in any way matches the accurate readings on our charge controller meter. It is impossible for a producer/consumer to measure total output from the interconnected utility meter, because that meter only measures the net amount of power sold to the utility, and does not include the total amount of power produced by the PV array, but used by the producer/consumer for hidher own use. The most accurate measurement, on a hybrid system, therefore, is through the digital charge controller meter which accurately records total output by the PV array. We have no knowledge of the manufacturer s specifications concerning the meter on our system, because we do not have the engineering expertise to know what to ask for from the manufacturer. We have attached as Exhibit A the only certification of our charge controller available on the Internet. 2. Description of how the energy output data is collected, recorded and delivered for use to GATS We have an account with SREC Trade, a national broker of renewable energy credits. All of our applications for certification with PJM s GATS system, the District of Columbia, Pennsylvania and Ohio were handled through a single application form handled by SREC Trade through its EasySREC program. page 4 of 7

5 As noted in our Revised Petition, our system is currently certified to sell Solar Renewable Energy Credits (SRECs) as a Renewable Energy Resource Facility in Ohio, as certificate number EL-REN, and in Pennsylvania, as certificate number 11-SPV-WV-GATS Although we were originally certified to sell SRECs in in the District of Columbia, DC closed its SREC market to out of state SREC producers, and our system was certified after the cut-off date specified in the DC PSC s new regulations. We are also certified on PJM s GATS system with a GATS certificate number NON Every month, we enter our cumulative output reading from our charge controller meter into our SREC account page on the SRECTrade Web site. SRECTrade uses those readings to calculate the accumulated SRECs in our account, which it then sells in the relevant Ohio and Pennsylvania markets for out-of-state SRECs. We have no knowledge of how SRECTrade delivers SREC data to GATS. 3. Identification of any electrical codes and standards that apply to and are met by the meter Petitioners do not have the engineering expertise to make any statements concerning the codes or standards which apply to their meter. We believe it is an undue burden to expect applicants for certification to hire engineering expertise to qualify their systems to sell renewable energy credits in West Virginia, which is not required in any other state in which we are certified. 4. Statement regarding whether the generator is a net-metered customer Petitioners are inter-connected with Mon Power, and have the status of net metered customers with that utility. The Petitioners would like to make the Commissioners aware of the fact that the original digital meter, installed by Mon Power following our page 5 of 7

6 interconnection, proved to be defective and inaccurately recorded our net generation for a number of months before Mon Power discovered and replaced the meter. The Commission should be aware that this initial defective meter was an ANSI certified revenue quality meter. This experience indicates that ANSI certification is no guarantee of a meter s accuracy. 5. If the facility is certified in another PJM state or the District of Columbia, whether or not that certification process required a revenue-quality meter As noted above, our facility is certified so sell out of state SRECs in Pennsylvania, Ohio and is certified with PJM s GATS system. The certification process engaged in by the Petitioners through SRECTrade is also described above. The following information concerning SREC metering it taken from the SRECTrade Web site: Ohio - Meter Readings: Must report generation from revenue grade meters. If the system is less than or equal to 6kW, generation can be reported from an inverter meter. DC - Meter Readings: Facilities less than 10 kw can use estimated generation based on the PV watts calculator. All other facilities must submit monthly meter readings. Systems larger than 10 kw require a revenue grade meter. * Pennsylvania - Meter Readings: Facilities under 15kW eligible for estimated generation based on the PV Watts calculation, unless they receive funding from the PA Sunshine Fund. All other facilities must report monthly readings. Facilities that received Pennsylvania Sunshine funding and all systems larger than 15 kw require a revenue grade meter http ://www. srectrade.com/pennsylvania-srec,php page 6 of 7

7 Petitioners have no knowledge of the regulations governing certification processes for each of these individual states. Petitioners believe that it is an undue burden on applicants for certification in West Virginia to research and provide that information which is not required for certification processes in any of the states where we are certified or the PJM GATS certification. In its August 31, 2012 Order, the Commission ordered the consolidation of all applicants cases into a single case. However, the Commission did not specify whether any or all parties have filed electronic service agreements or whether Petitioners were to serve all parties to the new consolidated case with copies of responses to the August 31,2012 Order. In the absence of such direction, the Petitioners are only filing this Response with the Commission, along with twelve copies, as required by Commission regulations. Respectfully submitted this 4th day of September, 2012, page 7 of 7

8 Exhibit A

9 CSA INTERNA~IONA~ *-- --_ Certificate: Project: Issued to: Xantrex Technology Inc Nelson Way Burnaby, BC V5A 4B5 Canada Attention: Mr. Ralph McDiarmid Master Contract: Date Issued: The products listed below are eligible to bear the CSA Mark shown with adjacent indicators 'C' and 'US' Authorized by: Lindsay Clark, Product Group Manager PRODUCTS CLASS CLASS POWER SUPPLIES - Distributed Generation Power Systems Equipment - POWER SUPPLIES - Distributed Generation - Power Systems Equipment - Certified to U.S. Standards Maximum Power Point Tracking Solar Charge Controller, Model XW-MPPTGO-150, fixed installation, permanently connected, ratings as follows: Max PV Open Circuit Voltage: 150 V The 'c' and 'US' indicators adjacent to the CSA Mark signify that the product has been cvaluated to the applicable CSA and ANSIAJL Standards, for use in Canada and thc US., respectively. This 'US' indicator includes products eligible to bcar the 'NRTL' indicator. NRTL, i.e. National Recognized Testing Laboratory, is a designation grantcd by the US. Occupational Safety and Health Administration (OSHA) to laboratorics which have bccn recognized to pcrforni certification to US. Standards. DQD 5.7 Rev

10 Certificate: Master Contract: Project: Date Issued: Max PV Short Circuit current: 60A Range of Operating PV Voltage: Vdc Max. Input Current: 60A Nominal Battery Voltages: 12,24, 36, 48 and 60 Vdc Max. Output current: 60 Adc Max Output Power: 3400 W Note: Rated for use in ambient temperatures up to 45 deg C max. APPLICABLE REOUIREMENTS CAN/CSA-C22.2 No. 0-M91 - General Requirements - Canadian Electrical Code - Part I1 CSA C22.2 No Bonding of Electrical Equipment CSA C22.2 No General Use Power Supplies UL st Ed. - Inverters, Converters, Controllers and Interconnectioii System Equipment for Use With Distributed Energy Resources. This standard contains revisions through and including Nov