AriSEIA Files Reply Brief in SSVEC Rate Case

READ THE FILING

AriSEIA filed its reply brief in the Sulphur Springs rate case today. AriSEIA is the only intervenor in that case to provide any meaningful push back on the utility and its wildly anti-solar rate design. Our recommendations are as follows:
1.  Reject or modify the proposed settlement to the extent it establishes a Distributed Generation Exported Energy (DGEE) rate of $0.0307 per kilowatt hour for three years without demonstrating compliance with the avoided cost floor applicable and without showing substantial evidence supporting the value.
2. Reject the settlement provision that freezes net metering and limits grandfathering of existing customers to the earlier of twenty years from installation or November 17, 2035, because Decision No. 76465 stated that to deviate from that framework required a showing of good cause supported by evidence. (AriSEIA-22 at 12).
3. Preserve the ten year export rate lock in applicable to distributed generation customers because the Value of Solar decision requires a ten year lock in period (AriSEIA-22 at 10) and the Commission just reaffirmed that framework in the RCP Docket No. 23-0273.
4.  A six-month implementation buffer must precede elimination of NEM or adoption of new tariffs,
5. Direct SSVEC to perform the required annual update consistent with the Plan of Administration and demonstrate that export compensation is not less than avoided cost.
6. Require SSVEC to credit customers for the year in which they were paid below avoided cost for their exported solar (2023).
7. Reject imposition of interconnection fees that were not supported by record evidence, were first provided after the hearing, and were never subject to cross examination. (Joint Opening Brief at 12–13).