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Consideration of Changes to the Current Net Metering Tariff Structure, Including Compensation of Customer-Generators – Order Denying Liberty’s Request to Delay Net Metering Application
The New Hampshire Commission issues a net metering order in 27,088:
{***} “In Order No. 27,074 (November 18, 2024), the Commission authorized the electric distribution utilities to charge application fees to individual customer generators seeking to interconnect as net-metering customers starting January 1, 2025, as well as to implement a reconciliation mechanism to pass any over-collections to ratepayers. The purpose of these fees was to cover the administrative costs of processing application fees, which are currently borne by the electric distribution utilities and passed on to their ratepayers. The fees were first proposed by a coalition of parties in August 2024. At hearing, there was uncontested testimony that these fees were appropriate because they would help reduce cost-shifting between net-metered and non-net-metered customers, and all parties supported approval of the fees at both the hearing and in their post-hearing filings. The Commission approved these fees because it found that they would reduce cost-shifting by ensuring that the administrative costs of processing interconnection agreements were being borne by the direct beneficiaries of interconnection—the customer-generator filing the application— and not the utilities’ general ratepayers.
After the Commission issued Order No. 27,074. Liberty Utilities (Granite State Electric) Corp. d/b/a Liberty (Liberty) filed a request to allow the company to delay both the application of the fees and implementation of the related reconciling mechanism. In that filing, Liberty represents that the delay is appropriate because it has received significantly fewer interconnection applications in 2024 than it projected, having projected 1,226 applications but only receiving 283 as of late November, and believes this trend will extend into 2025. Due to this projected reduced volume of applications, Liberty represents that it is “adequately equipped to manage the current pace of new applications without the need for additional administrative resources and a corresponding reconciling rate component at this time.” Liberty’s Letter Requesting Delay of Application Fees at 1. Liberty’s filing does not provide a new timeframe for implementing a fee schedule and states only that the issue could be “revisited when Liberty expects to incur incremental administrative expenses.” Id.
The Commission DENIES Liberty’s request because the company has not provided a sufficient basis for delaying the implementation of the fees. Most importantly, while the lower volume of applications may make the fees less necessary than projected, they will still help to reduce cost-shifting by covering the costs of processing applications and Liberty has not explained why it would be detrimental to implement them. It does not seem particularly burdensome to implement a fee schedule for interconnection applications and, if anything, the lower volume of applications would make the process even easier. Finally, the Commission disagrees that it is appropriate to delay the implementation of fees based on the current volume of applications. Notably, if Liberty delays establishing a fee schedule until the company experiences an increase in applications, it will not be able to recover costs for processing at least some percentage of these applications because there will be no fee schedule in place at that time.” {***}
Order # 27,088
Consideration of Changes to the Current Net Metering Tariff Structure, Including Compensation of Customer-Generators, Order Denying Liberty’s Request to Delay Application of Application Fees
