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Comments of Karl R. Rábago (Rabago) In re: Distributed Generation before Iowa Utilities Board

Valuation, Analysis, BCA   
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 customers subsidize non-solar customers; and 3. cost of service ratemaking techniques confirm that the value of distributed solar generation is at least equal to the retail rate for electricity service.