AriSEIA Submits Letter to SRP on Master Meter Rule Changes

Salt River Project
1500 N  Mill Avenue
Tempe, AZ 85281
RE: Salt River Project (SRP) Status Change Enforcement of Master Meter
 
Dear Board of Directors and Staff,
 
It recently came to our attention that SRP proceeded with a rule change that reduced or eliminated a multi-family development’s ability to meter their facility at a centralized location. This change has significant impacts on our industry and our collaboration efforts with property developers using the Low-Income Housing Tax Credit (LIHTC) who proceeded over the last 18 months with development plans incorporating solar projects to an almost ubiquitous degree to claim the 20% Qualifying Low-Income Residential Building or Benefit Project tax credit. These developments have executed contracts, ordered electrical gear, and proceeded on the basis that their ability to elect the metering infrastructure design of their own accord would be unhindered. The essence of the solar bonus from the LIHTC program is to ensure that solar benefits are passed through to Low-Income Residents to reduce costs, and we urge SRP staff to adjust the rule change allowing for both centralized and distributed metering arrangements subject to a developer’s preference.
 
It is also important to point out that in SRP territory, the lack of Virtual Net Metering, a program which allows multi-family developments across the country to apply solar benefits virtually from a single (most cost effective) interconnection point, is not an option and therefore the only sensible route for these properties to access solar is through a pre-meditated strategy to centralize their electrical infrastructure in a manner that allows for a solar project to be implemented.
 
We recognize that our request may relate to other circumstances for Limited/Moderate Income (LMI) residents who wish to access SRP’s existing bill assistance programs, and we understand the importance of SRP’s plight to continue providing value to these residents in every form possible; however, the millions of dollars that have been invested by numerous LMI residential developers (Ulysses Development Group, Weis-Dominium, DEVCO to name a few in the area with active solar interests) under the auspice of their ability to centralize metering for a cost-effective solar project should be considered.
 
We understand the argument that low-income residents will lose access to individual plans for low income residents, but also want to point out that individually metered solar projects have the same restriction, i.e., once solar is put on an apartment complex, the ability to access low income rate plans is eliminated.
 
This change will result in projects costing 10% - 20% more due to the multiple interconnections, and the challenge to manage the property will be increased. The benefits of allowing master metering with solar are that the developer can install a solar system, share the savings with the tenant, and have a much easier time administering the site than with numerous interconnections.
 
SRP is expecting massive new load growth. We would encourage SRP to work with developers and solar companies to create development friendly policies that encourage more generation on the grid. Solar and solar+storage can be a great asset to “beating the peak.” Putting restrictions on the most straightforward way to achieve those goals is a detriment to the projects and the residents.
 
Further, such significant changes should undergo a stakeholder process before being implemented. This is the first we have heard about this change and the impending change or its justifications was never discussed with AriSEIA.
 
We recommend changing the Electric Service Specifications in 9.I.F to:
 
F. A Master Meter Service is available for new commercial and multi-level residential projects where SRP’s billing meters cannot be located on the ground floor or one level below the ground floor, provided this is not the lowest level of the Building. Also, master metering is allowed when a developer is intending to install a solar system and it would be infeasible to install it on every meter of the building.
 
Sincerely,
/s/ Autumn T. Johnson
Executive Director
AriSEIA 
(520) 240-4757
[email protected]