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 full avoided costs.” Accordingly, parties filed direct testimony and exhibits and additional testimony and exhibits in response to the direct testimony filed by other parties to this proceeding. The purpose of this response testimony is to respond to the testimony filed by several other parties and recommend to the Commission a full avoided cost analysis for solar technology, including both utility-scale and distributed solar technology.