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In the testimony, Karl Rabago addresses the deficiencies in the Company’s IRP related to renewable energy, distributed solar in particular. He identifies the major analytical weaknesses underlying the Plan – that the Company fails to recognize the value of distributed solar and that the value of solar is not reasonably reflected in the prices paid for solar energy.

This testimony responds to the Commission's request that parties file proposals on how to value distributed generation resources in Arizona.There is a developing consensus in the utility industry on the best practices for designing benefit-cost analyses of net metering and distributed resources, a consensus which draws upon the similar analyses which have become standard practice for other types of demand-side resources. These analyses assess the benefits and costs of these resources from multiple perspectives, including those of the principal

North Carolina Utilities Commission Docket No. E-100, Sub 140. In its order initiating this proceeding, "In the Matter of: Biennial Determination of Avoided Cost Rates for Electric Utility Purchases from Qualifying Facilities – 2014," the North Carolina Utilities Commission ("the Commission") signaled its intention to consider “changes to the methodology used to calculate avoided cost payments, particularly capacity payments,” including “whether the methodologies historically relied upon by the Commission to determine avoided cost capture the f

North Carolina Public Utilities Commission Docket No. E-100, Sub 140. The rebuttal testimony responds to certain points in the testimony filed by several other parties on May 30, 2014. Some points include: testimony from Duke Energy Carolinas and Duke Energy Progress witness Kendal C. Bowman regarding costs included in avoided cost calculations, testimony of Duke witnesses Bowman, Snider, and Makovich relating to value of solar analysis, and testimony of Public Staff witness Dr. Richard E. Brown relating to the effective load carrying capacity

North Carolina Utilities Commission Docket No. E-100, Sub 140. Direct Testimony on behalf of Southern Alliance for Clean Energy before the North Carolina Utilities Commission. The testimony recommends a full avoided cost analysis for solar technology, including utility-scale and distributed solar technology. This will reveal not only the full costs that can be avoided by solar resources, but demonstrate a comprehensive methodology suitable for assessing all manner of non-utility generation and resources.

Wisc Public Service Commission Docket 6690-UR-123. The Power Point is a short hand assessment of way to address rate of pricing issues of WE Energies. It assesses the advantages and disadvantages of several rate designs including: increased fixed charges, graduated/ratcheted facilities charges, declining block, two-part pricing, fixed billing, and revenue decoupling. Then, the Power Point reports its research findings and recommends mass market strategies and future steps to address rate and pricing issues.

Virginia State Corporation Commission Case No. PUE-2014-00026. This testimony explains why the Appalachian Power Company's ("the Company") proposed standby charge would constitute an unjust, unreasonable, and improper discriminatory rate charged on solar customer-generators. The testimony states the proposed charge is inadequately supported and fails to meet the requirements of Virginia Code § 56-594 F. Under this statute, the Company must prove that its proposed charge would recover “only the portion of the supplier’s infrastructure costs that

Virginia State Corporation Commission Case No. PUE-2015-00036. Addresses the legal and regulatory obligations imposed on Appalachian Power Company in seeking the Commonwealth of Virginia State Corporation Commission's ("Commission") approval for its 2015 Integrated Resource Plan and rules adopted by the Commission. In light of those requirements, the testimony makes several findings, reaches a conclusion about the Appalachian Power Company’s application, and makes a recommendation to the Commission.

Virginia State Corporation Commission Case No. PUE-2012-00064. Testimony on behalf of Environmental Respondents before the State Corporation Commission of Virginia to support full and fair evaluation of Virginia Electric and Power Company's ("the Company") Solar Purchase Program ("SP Program.") The testimony identifies positive and negative aspects of the SP Program proposal and alternative approaches and modifications to the proposal that could better serve the statutory and regulatory goals for solar energy in Virginia.

Georgia Public Service Commission Docket No. 36498. This testimony addresses the deficiencies in Georgia Power Company's ("the Company") Integrated Resource Plan ("IRP.") The testimony describes one of IRP's major, underlying analytical weaknesses -- the Company failed to recognize the value of distributed solar and that the value of solar is not reasonably reflected in the prices paid for solar energy. The testimony proposes the Company improves and increases the market opportunities for distributed solar technology in its service territory th

Georgia Public Service Commission Docket No. 36989. Direct Testimony of Karl R. Rabago on behalf of the Georgia Solar Energy Industries Association before the Public Service Commission ("the Commission") of the State of Georgia. Georgia Power Company (“the Company”) seeks to impose new rates and charges on customers who install and use solar energy generation systems at their homes, businesses and farms. The testimony urges the Commission to deny these new charges because the Company has failed to substantiate its need to implement tariff charg

Florida Public Service Commission Docket No. 130199-EI thru 130199-EI. This testimony presents the Commission with an evaluation of Florida Power and Lighting (“FPL”), Duke Energy Florida (“DEF”), Gulf Power Company (“GPC”) and TECO’s (collectively, the “Utilities”) Petition for Approval of Numeric Conservation Goals. Specifically, the testimony: 1. discusses why it is inappropriate and against precedent and legislative intent to use the Ratepayer Impact Measurement (“RIM”) test scores to set energy efficiency goals in Florida; 2. reviews the r

Virginia State Corporation Commission Case No. PUE-2013-00088. Testimony on behalf of Chesapeake Climate Action Network, Appalachian Voices, and the Virginia Chapter of the Sierra Club. The testimony evaluates the solar photovoltaic generation aspect of the Virginia Electric and Power Company's ("the Company") Integrated Resource Plan ("IRP.") The author's overall finding is that the Company's approach to solar energy is incomplete, inconsistent, and inaccurate. Given specific deficiencies explained in the testimony, the Company's approach to s

Wisc Public Service Commission Docket 6690-UR-123. The purpose of this testimony is to demonstrate many significant errors underpinning the wholesale attack by Wisconsin Electric Power Company (the “Company”) on customer generators. The testimony points out the deficiencies in and adverse consequences of the proposals by the Company to: 1. raise fixed customer “facilities” charges; 2. impose standby/demand charges on distributed generators; 3. impose a new requirement for monthly netting on net metering customers; 4. set a de facto avoided cost

Iowa Utilities Board Docket No. NOI-2014-0001. Clean distributed generation ("DG") is the most exciting development in electric service and technology since the negawatt. It offers a host of advantages, but also has been perceived as a threat by utilities. While industry experts and many in the utility business have moved on beyond initial reactions to impose fixed charges and demand charges in an effort to undermine DG economics, there are still important issues, such as data-driven issues, that need to be addressed. Data-driven issues are is

Louisiana Public Service Commission Docket No. R-31417. The comments assert the Louisiana Public Service Commission and Staff abate any action to adjust the benefits and burdens under Louisiana's net metering rule unless and until competent objective evidence is developed regarding the benefits and costs associated with distributed solar energy generation. The testimony makes recommendations based on the following: 1. the existing Louisiana Net Metering Rule is reasonable and consistent with the practice in the majority of U.S. jurisdictions; 2

Iowa Utilities Board Docket No. NOI-2014-0001. The comments assert the Louisiana Public Service Commission and Staff abate any action to adjust the benefits and burdens under Louisiana's net metering rule unless and until competent objective evidence is developed regarding the benefits and costs associated with distributed solar energy generation. The testimony makes recommendations based on the following: 1. the existing Louisiana Net Metering Rule is reasonable and consistent with the practice in the majority of U.S. jurisdictions; 2. solar c

Michigan Public Service Commission Case No. U-17302. The testimony addresses deficiencies in the Detroit Edison Company’s ("the Company") Renewable Energy Plan ("REP") related to distributed solar. The author identifies a major analytical weakness underlying the Plan and the Company’s approach to distributed solar energy -- the Company fails to recognize the value of distributed solar. The testimony proposes that the Company improve and increase market opportunities for distributed solar technology in its service territory through adoption of i

Kentucky Public Service Commission Case No. 2013-00475. Kentucky Power Company's ("KPC") Integrated Resource Planning Report ("IRP") is a plan to diversify its energy portfolio. However, Sierra Club's comments state KPC failed to evaluate a range of potential resource plans. The IRP does not incorporate the thorough and reasonable planning needed to achieve a least cost and least risk energy future. Sierra Club suggests the Public Service Commission Staff find the IRP to be inadequate and require KPC to address and correct the above errors in t

North Carolina Utilities Commission Docket No. E-100, Sub 140. Summary of Karl R. Rabago's testimony to propose the North Carolina Utilities Commission Commission address inadequacies the utilities' avoided cost proposals by implementing a short-term and a longer-term approach that will better ensure that "full," non-discriminatory avoided cost rates are offered to qualifying solar electric facilities in both the short-term and the longer-term.

Wisconsin Public Service Commission Docket No. 05-UR-107. Testimony for RENEW Wisconsin and Environmental Law & Policy Center before the Public Service Commission of Wisconsin re: Joint Application of Wisconsin Electric Power Company and Wisconsin Gas LLC to Conduct a Biennial Review of Costs and Rates for Test Year 2015. This surrebutal points out the flawed assumption in the witness' testimony and rebuttal. The flaw is that the broad and uncharacterized interests of "economic efficiency" will be advanced by aligning rate design with average c

North Carolina Public Utilities Commission Docket No. E-100, Sub 136. The testimony helps demonstrate that traditional avoided cost calculations are inadequate to objectively capture the "full avoided costs" associated with solar electric facilities and that valuation studies and analyses published over the last several years demonstrate this inadequacy with empirical data. The testimony recommends the Commission address this inadequacy by implementing a short-term and longer-term approach that will better ensure that "full," non-discriminatory

Florida Public Service Commission Docket No. 130199-EI thru 130199-EI. The purpose of the testimony is to make two points regarding the solar photovoltaic ("solar PV") pilot programs administered by Florida Power & Light Company, Duke Energy Florida, Inc., Tampa Electric Company, and Gulf Power Company ("the Companies.") First, the Companies should substantially revise and continue their solar PV programs. Second, the Companies' solar programs should be revised to improve valuation techniques for solar PV in order to more accurately characteriz

Iowa Utilities Board Docket No. NOI-2014-0001. The comments address Iowa's potential and untapped distributed generation market. They advocate that Iowa proactively catalyze its distributed generation market to prevent losing its distributed generation benefits to other states. The comments specifically address five issues relating to distributed generation in Iowa: 1. Iowa policy makers must take steps to catalyze the distributed generation market; 2. preserve, expand, and standardize Iowa's existing net metering policy to include all utilitie