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Wednesday, July 1, 2015

A bump in the road for Mercury control

On June 29, the Supreme Court issued its 5-4 opinion in Michigan v. EPA where it disapproved of the procedure used by EPA in promulgating its Mercury and Air Toxics Standards (MATS) rule for power plants. This opinion does not change the fact that Mercury, along with other metals and acid gases covered by the rule, are dangerous pollutants that can and should be regulated by EPA. (Mercury is of particular concern as it is known to impair the neurological development of children.) While there are those who seek to minimize the extent of the health impacts of Mercury, overstate the costs, and understate the benefits, the science and economics both come down clearly on the side of this rule. What, then, is the problem?

The key holding from the Court was that EPA unreasonably failed to consider the costs of the rule when deciding to regulate power plants. Despite press to the contrary, it was not that the EPA “failed to consider the costs.” The record is clear that there was extensive consideration of costs during the regulatory process. The problem in the Court’s eyes was when, exactly, that consideration took place.

The Clean Air Act treats the consideration of costs and other economic factors differently in different sections of the Act. When setting health-based standards for things like ozone pollution, for example, Congress expressly forbids EPA from considering costs. That makes a lot of sense. When you visit a doctor, you may be concerned about how much the treatment will cost, but you don’t want the doctor to change your diagnosis if it’s too expensive to treat what is really wrong. Just like a doctor, EPA gives the diagnosis first and then considers the costs when determining how to treat the problem.

The EPA followed that same general pattern here. It first decided that health impacts and other concerns made it necessary to control Mercury and air toxics emissions from power plants, then it considered the cost of doing so as part of its regulatory impact analysis. After exhaustive consideration of costs during a decade of analysis and multiple rounds of review, it found that the rule was highly cost effective. It determined the regulation would cost $9.6 billion to implement but would return between $37 and $90 billion in benefits. Satisfied with this conclusion, the EPA finalized the rule. The problem in the Court’s eyes was a matter of timing: the EPA didn’t consider the costs in the first step when it decided that regulation was necessary.

Justice Elena Kagan, writing for the four Justices in a sharp dissent, described this as “a peculiarly blinkered way for a court to assess the lawfulness of an agency’s rulemaking.” She goes on to point out the obvious issue that “until EPA knows what standards it will establish, it cannot know what costs they will impose. Nor can those standards even be reasonably guesstimated at such an early stage.” Despite the logic of Justice Kagan's dissent, the Court's decision stands.

What now?

It is not clear what, if anything, will change with regard to the MATS rule as a result of this case. The case will be returned to the D.C. Circuit Court “for further proceedings consistent with [the Supreme Court’s] opinion.” That doesn’t necessarily mean there will be any changes in the actual regulation. Since the cost analysis has been completed, this decision may be no more than a bump in the road with a little more homework and process required to satisfy the Court.

While this could certainly cause some disruption, it’s possible the existing rule will remain in effect. Back in 2008, the courts invalidated the Bush-era Clean Air Interstate Rule (CAIR) on far more substantive grounds than we see here, yet it left the rule in place for years while the EPA worked on a replacement. Hopefully, the same approach will be deployed here, leaving vital protections in place while the paperwork gets sorted out.

Rob Altenburg is director of the PennFuture Energy Center and is based in Harrisburg. He tweets @RobAltenburg.

Wednesday, June 17, 2015

Great news for Philadelphia and PA: Microgrid research center in development

Penn State and the energy technology company Alstom are working on a microgrid research center at The Navy Yard in Philadelphia.  Penn State's vice president for research, Neil Sharkey, says the University is “working to spur real innovation and job growth, as well as boost the efficiency of current technologies."

The center is just one part of the 10-year Energy Master Plan for The Navy Yard.  Other components of the master plan include alternative power sources, dynamic time-of-use tariffs, and energy efficiency and demand reduction incentives. From the plan: "The end goal is a modern microgrid capable of offering a variety of service options to Navy Yard tenants." The Philadelphia Industrial Development Corp (PIDC) is in charge of master development at the site. 

Penn State and Alstom’s work will allow for the ongoing development and demonstrations of microgrid technologies. The U.S. Department of Energy (DOE) is helping to fund the research center with a $1.2 million grant to Alstom and a $129 million grant to Penn State.

For those who aren’t familiar with the Philadelphia Navy Yard, it's touted as a “1,200-acre former naval shipyard, now transformed into a progressive and modern business campus with more than 145 companies in the office, industrial, and R&D sectors occupying more than 7 million square feet of space." Thanks to the microgrid, some of those businesses will be able to generate, manage, and store the energy needed to run their daily operations. The microgrid will also decrease the vulnerability of businesses to power outages due to large storm events like Hurricane Sandy. For more information, see my previous blog post on microgrids and distributed generation

Michael Atkinson, president of Alstom Grid North America, says, "This microgrid demonstration is in line with the DOE's national objective to improve grid resiliency, reduce emissions and increase energy efficiency, while protecting critical infrastructure."

Penn State’s research will help Pennsylvania and the U.S. advance distributed generation, demand response, energy storage, and grid resiliency. The DOE grants are all part of President Obama's Climate Action Plan. 

For more information on the project, check out The Navy Yard website.  

Jennie Demjanick is energy policy analyst for the PennFuture Energy Center and is based in Harrisburg. She tweets @JennieDemjanick.

PA Coal tells the same old (tired) stories

Yesterday, in Harrisburg, the Pennsylvania Legislature’s “Coal Caucus” invited representatives of the coal industry to tell them why they oppose the Environmental Protection Agency's (EPA) proposal to reduce carbon pollution from coal and other fossil fuels. We have heard the talking points before, often from a pundit decrying Obama’s “war on coal,” and they don’t get any better with age.

Industry analysts and insiders have been discussing the decline in coal for years and, while EPA is often blamed, many admit that even without the EPA, coal is less and less competitive. The Energy Information Agency tallies “all employees engaged in production, preparation, processing, development, maintenance, repair shop, or yard work at mining operations, including office workers,” and PA was down to 8,382 coal jobs in 2013—an over 6 percent decline from the prior year.

Those at the hearing continued blaming EPA and spun tales of more doom and gloom for the future. For example, it was claimed yet again that the EPA’s proposed rule would reduce Pennsylvania’s coal fleet by nearly 70 percent and that this would jeopardize 36,000 jobs. Compared to the actual number of coal jobs in the state, the job loss numbers are clearly inflated. It’s also common practice for the industry to blame all plant closures on the EPA, no matter how tenuous that claim, but this is an even worse exaggeration.

I wrote a blog post in August 2014 detailing the mental gymnastics that are required to conclude 70 percent of our capacity will be retired. In short, it assumes that the PA Department of Environmental Protection (DEP) will craft a plan where the only item they will take any credit for is the shuttering of coal plants and attendant replacement gas plants. That means deciding not to take allowable credit for our Act 129 energy efficiency program, nothing for our existing Alternative Energy Portfolio Standard, and nothing for maintaining our fleet of nuclear power plants. It also means doing nothing new to improve efficiency at those plants and not even considering other alternatives such as multi-state compliance options. Why on earth would DEP craft such a plan? Simple: They wouldn’t.

When folks like the PA Coal Alliance repeat that number, they are quick to claim that the source of the crazy 70-percent number was DEP itself. To be precise, that number was often repeated by Vince Brisini, who was a Deputy Secretary for DEP during the Corbett administration. In discussions I had with Vince on the topic, he justified the claim by assuming courts would eventually throw out all the parts of the proposed Clean Power Plan that would allow credit for any measure other than shutting down coal plants. Even if the courts were to agree with him, the EPA would be legally required to adjust their targets accordingly. There is no reasonable way to get to the number he was claiming—Vince was simply wrong. (Having left DEP, Vince is back working for the industry and testified at the hearing.)

We are a long way from seeing DEP’s plan on this issue. The EPA is expected to finalize its rule shortly and DEP may have two years or more to craft a state plan. DEP Secretary John Quigley has made it clear that he agrees with Gov. Tom Wolf on the importance of protecting Pennsylvania coal.

In spite of its decline, coal is going to be part of Pennsylvania's energy generation mix for years to come and the Clean Power Plan isn’t going to change that.

Rob Altenburg is director of the PennFuture Energy Center and is based in Harrisburg. He tweets @RobAltenburg.

Wednesday, June 10, 2015

Energy benchmarking ordinances: Not just for big cities anymore

Kansas City, Missouri this week passed a mandatory energy benchmarking and energy use disclosure ordinance. With a population of just over 440,000, Kansas City is one of the first "small cities" in the country to institute such a policy. Cambridge, Massachusetts, a city with just over 100,000 residents, also passed a benchmarking ordinance in conjunction with the city of Boston in 2012. They join the ranks of  many large U.S. cities, including Philadelphia, New York, Chicago, and Atlanta, that have added energy benchmarking to their toolbox of energy conservation efforts.

As is the case with similar ordinances across the country, Kansas City will require buildings above 50,000 square feet to record and report their energy and water use data. The city will then make that data publicly available online. Energy use becomes transparent and building owners, potential tenants, would-be investors, and the business community will be able to consider energy costs when searching for a commercial property. If the market demands it, building owners will also be encouraged to improve the energy and water efficiency of their buildings in order to remain competitive.  

It's likely that Kansas City is the first in a new wave of smaller cities to take this step for the economic benefits and competitive edge that it provides. Kansas City's public buildings are expected to save nearly $400 million over the next 15 years. The long-term economic impact for the city as a whole is still being analyzed. 

Pittsburgh (with a population of just over 300,000) and other smaller metropolitan hubs in Pennsylvania should take note. Benchmarking ordinances are no longer just for big cities. 

Evan Endres is program manager for PennFuture and is based in Pittsburgh. He tweets @ER_Endres.

Hawaii is leading the way to 100 percent renewable energy

A few months ago, I blogged about how Burlington, Vermont became the first city in the U. S. to use 100 percent renewable energy. Now Hawaii is on the path to becoming the first state to get its energy from renewable sources alone. On June 9, Hawaii Governor David Ige (D) signed House Bill (HB) 623 requiring electric utilities to supply 100 percent of their sales with renewables by 2045. The plan is for the 100 percent goal to be achieved in steps.  
Hawaii looks to have 30 percent renewables by 2020, 40 percent by 2030, 70 percent by 2040, and hit the final goal by 2045. The goal is quite ambitious but it is certainly a step in the right direction. I am cautiously optimistic that Hawaii will be able to reach its goal by 2045.

In order for Hawaii to achieve these goals, there will be a lot of pieces that need to fall into place at the right time. But as I have said previously, adding renewables onto the grid is not about achieving perfection. It is about taking that first leap and following through until the goal is achieved, whether or not it is by the initial end date. The Island State deserves a lot of credit for upping the ante and, hopefully, other states will follow suit. 
The newly signed legislation replaces Hawaii’s previous goal of achieving 15 percent renewables by 2015, 25 percent by 2020, and 40 percent by 2030. The governor says using local sources of energy instead of depending on oil imports will benefit the state's economy. Currently, Hawaii spends $5 billion a year on oil imports that provide roughly 70 percent of the state's electricity. In fact, Hawaii has historically been the state most dependent on oil. 
Gov. Ige is also increasing the ability of Hawaiians to use community solarCommunity solar is great for those of us who live in apartment buildings or have a lot of shade coverage. Additionally, the University of Hawaii now has a net-zero energy usage target to be achieved by January 1, 2035.
Check out this brief video for more information on Hawaii’s decision.
Hawaii’s move comes on the heels of a recently published report in the Journal Energy and Environmental Science that concludes, “wind, water and sunlight could meet demand for all energy -- not just electricity -- in every state by midcentury.” Notice that nuclear power and biofuels are not included. According to the researchers, all states could achieve 80 percent renewables by 2030 and 100 percent by 2050. They found that if we switched to using electricity to fuel our cars, homes, and factories, we would reduce power demand by 39 percent by 2050.

Making the right policy decisions such as having renewable portfolio standards, efficiency mandates, and electric vehicle incentives will be helpful, and implementing the EPA’s Clean Power Plan will help push states to act even more.  

Jennie Demjanick is energy policy analyst for the PennFuture Energy Center and is based in Harrisburg. She tweets @JennieDemjanick.

Thursday, May 21, 2015

PA builders' influence proves code adoption system needs a reboot

Pennsylvania’s building code adoption process is tainted by unprecedented access and control from the Pennsylvania Builders Association, subject to lack of impartiality from Advisory Council leadership, and generally beyond repair. Legislation establishing a new and workable system is the only path forward.   

As of midday on May 20, the Building Codes Review and Advisory Council (RAC) adopted a random selection of provisions amounting to less than ten out of 1,900 code updates, some of which serve to weaken safety and energy efficiency in our state.

Unprecedented access by the Pennsylvania Builders Association (PBA)

Through a series of correspondence obtained via a Right to Know Law (RTKL) request submitted by PennFuture, it was discovered that the Pennsylvania Builders Association (PBA) continues to receive unprecedented access, and impose inside influence, on Pennsylvania's (broken) building codes adoption process. Actions include inviting members of the RAC to a series of special Uniform Construction Code review meetings held by a PBA subcommittee. 

Lack of Impartiality from RAC Leadership

The porous codes adoption process is also tainted by the revelation that leaders of the RAC provided advice to the PBA on how to frame their argument against the energy efficiency code updates before the Council. This lack of impartiality further undermines confidence that the current system can adopt codes that are in the best interests of Pennsylvania. 

A system beyond repair

The wolves are guarding the sheep as the PBA fends off common sense code changes that may mean lower profits for them but safer and more efficient homes for us. How did this happen? The PBA has stacked the deck against Pennsylvanians through its unprecedented influence on the codes adoption process and via legislation that puts veto power in the hands of home builders and their allies, who make up one-third of the RAC. All this while proposing additional legislative action to stretch out consideration of new codes to once every six years, further guaranteeing complete control over the process.

Pennsylvania needs legislation to reinstate a predictable, transparent, uniform process to guarantee that all of our structures are built in accordance with the newest and best building codes. We must return to a process in which modern codes are adopted with adequate review.

Evan Endres is program manager for PennFuture and is based in Pittsburgh. He tweets @ER_Endres.

Wednesday, May 20, 2015

FYI: PPL electricity bill increase

PPL Electric recently asked the Pennsylvania Public Utility Commission (PUC) for a fixed rate increase. If you are a PPL customer, you likely already know that the monthly fixed distribution rate is $14.13. What you may not know is that the fixed rate is the highest in the state. If PPL's fixed rate increase is approved as requested, you will see your monthly fixed rate payment go up to around $20 a month, a 42 percent increase. This means PPL's more than 1.4 million customers will each be paying $60 more a year for electricity.

How you can make your voice heard

The PUC is currently investigating PPL's proposal, meaning the rate increase is suspended for up to seven months. At this point in the process, the Office of Administrative Law Judge (ALJ) will be holding public hearings, and a final decision must be made by January 1, 2016. More information on the ratemaking process is available on the Commission’s website.

In order to encourage public participation, the PUC announced the launch of its online “Smart Hearing” pilot project. The Smart Hearings will consist of live-streamed online hearings. As recently-appointed PUC Chair Gladys M. Brown emphasized, "It is vital to gather as much public input as possible to help the Commission determine what, if any, of each requested increase is justified.” 

During each hearing, anyone can call in and provide comments to the PUC. You'll be able to hear everyone else's comments live via the Internet stream; you can also go to Harrisburg if you wish and testify in person at the Keystone Building. 

If you are a PPL customer, this is a very important issue for you to be a part of and the PUC is obliged to consider your comments. Make sure to mark the hearing dates down on your calendar and call in. Don't assume other people will be calling in so that you don't need to. YOUR individual opinion matters because YOU will be paying for this fixed rate whether you have the most efficient home or building in the world or not. 

According to the PUC, the last time PPL asked for a fixed rate increase, only 13 people showed up during the five public hearings held across PPL territory. I am sure more than 13 people cared about the issue. Maybe you were not aware that this was happening, or maybe you figured a lot of other people would show up. Now you know that if you are concerned about having to pay over $5 more a month for your electricity, you need to speak up. And now the PUC is making it as simple as picking up the phone.

There will be two online hearings on Tuesday, June 2:  1 p.m. and 6 p.m. Both will be held in Hearing Room 1 on the 2nd floor of the Commonwealth Keystone Building at 400 North St., Harrisburg, Pa., 17120.  

If you want to call in, you need to contact the Office of Consumer Advocate (OCA) at 717-783-5048 or 1-800-684-6560 no later than Tuesday, May 26 (yes that is the day after Memorial Day) in order to register and receive additional information. Those who register to testify will be provided in advance with a 15 minute window of time when they can expect to be called in order to provide their testimony. Or you can go to Harrisburg and simply sign in when you arrive. Detailed information about the hearings is available on the PUC website.

The third hearing will be held on Thursday, June 4 at  6 p.m. in Allentown (home of PPL) at  Muhlenburg College Seegers Union, Rooms 108-110, 2400 Chew Street, Allentown, Pa., 18104. Only in-person testimony at this one so you do not have to contact anyone in advance. All you have to do is show up and state your concerns.

Please spread the word to all the PPL customers you know! And there is no need to feel intimidated that an Administrative Law Judge will be presiding over the hearing and the attorneys present may be asking you questions. This is a public participation process. As a PPL customer, you have every right to be heard.

From the PUC:

Offering Comment at a Hearing
Members of the public are welcome to attend the hearings and provide comments. Their testimony will become part of the record on which the PUC will issue its final decision.
The PUC and Office of Consumer Advocate offer tips on how to participate, including:
  • Prepare what you are going to say beforehand. Even though it is not required, you may want to write out your statement, which can be read.
  • Bring copies, if you are attending an in-person hearing. If you have a written statement you would like to give to the judge as evidence, please bring two copies for the court reporter and several copies for the other participants.
  • Plan to be questioned. Parties in the case may want to ask you a question to clarify something you said. 
  1. You may testify formally under oath or affirmation and be subject to cross-examination.
  1. You may make an unsworn or unaffirmed statement. It will be “off the record” and not subject to cross-examination. The court reporter will not transcribe your statement and your statement will not be considered.
  1. You may provide information to the Commission’s Bureau of Investigation & Enforcement, the Consumer Advocate, or the Small Business Advocate for their possible use at the formal evidentiary hearings in Harrisburg at their discretion.
You are encouraged to testify under oath so that your testimony can be used to the extent it meets the rules of evidence. If you do not want your testimony to be live streamed, you may testify after the live streaming equipment is turned off. Please tell OCA of your preference when you call to sign up as a witness. 

Jennie Demjanick is energy policy analyst for the PennFuture Energy Center and is based in Harrisburg. She tweets @JennieDemjanick.

Wednesday, May 13, 2015

Tesla Powerwall and Pennsylvania

Tesla shook things up recently with the announcement of a small, reasonably priced, large capacity battery system. The Tesla Powerwall comes in a 7 kilowatt-hour capacity for about $3,000 and is modular so additional battery packs can be added to work together. 

Courtesy Tesla Motors

Why is this such a breakthrough? First, low price -- other battery systems haven't been able to provide that level of capacity and compact size for such a low price. Battery systems that have were not considered to be high quality products. Second is the notion that battery systems, whether home scale or utility scale, are one of the key ingredients to developing an electric grid with "dispatchable" renewable energy. We're able to call on wind and solar energy when needed via battery systems, not just when the sun shines and the wind is blowing. Finally, this technology would allow for "grid defection," or the idea that you can manage all of your home's electricity needs, on site, without being connected to the grid at all. This is achieved through a combination of home renewable energy such as solar (or small wind, if you have the right conditions), batteries, and some sort of backup generator.

It may not prove to be an attractive option at first, but the Powerwall certainly completes the puzzle for those who want to explore the feasibility -- and legality -- of total grid defection.

Stepping back, the most immediate benefit to home battery systems would be found for those who have a Time of Use (TOU) electricity rate. TOU rates charge you more when electricity costs more, such as during times of peak demand on the grid, as opposed to a flat rate all day. When you combine batteries with solar energy under a TOU rate, you can "bank" the electricity your solar system produces at times when your daily rate is cheaper and pour it into the grid when the rate is higher, giving you more value for the energy you produce. Another scenario, absent solar, would be a homeowner on a TOU rate banking electricity when it's cheaper and then using the batteries when electricity is higher priced, saving money in the process. As I blogged recently, in Pennsylvania we have a TOU pilot in PPL utility territory, but net metering for home renewable energy systems, like solar, is not guaranteed. A big flaw. 

Demand response programs that take advantage of new behind-the-meter technologies like the Powerwall are also a prime target for our state. Currently, commercial customers can be paid to turn on emergency generators on days when the electric grid is strained. This often involves diesel generators running on the hottest days of the year, which is not a great thing for air quality. Developing a demand response system that allows Powerwall owners to participate in demand response programs, especially if using solar energy in conjunction with the Powerwall, would be a clean way to address grid strain while returning dollars to the pockets of residential ratepayers.  

Bottom line: If we hope to be a brick in the Tesla Powerwall, Pennsylvania will need to encourage a new wave of demand response programs and go beyond pilot Time of Use rates. 

Evan Endres is program manager for PennFuture and is based in Pittsburgh. He tweets @ER_Endres.

Wednesday, April 29, 2015

The State of the Air Report says pollute less

On April 29, the American Lung Association released its 2015 State of the Air Report. While it showed some improvement, the Pittsburgh metro area was one of three locales found to be one of the “Worst 25” areas in three different categories: daily particulates, annual particulates, and ground level ozone (better known as smog.)

We know what the problems are, and we’ve known the solutions for years: pollute less.

While we receive a failing grade based on current air pollution standards, we face an additional health problem because the current National Ambient Air Quality Standard for ozone is too lax to protect public health. In 2005, the U.S. Environmental Protection Agency's (EPA) Clean Air Scientific Advisory Committee (CASAC), a seven-member panel of experts on air pollution issues, consulted with professors, medical doctors, and other technical experts known as the Ozone Review Panel. As a result, they sent three separate letters to the EPA administrator between 2006 and 2008 wherein each unanimously recommended the standard be set between 0.060 and 0.070 parts per million (ppm). In 2008, the Bush-era EPA ignored their own expert’s unanimous advice and set the standard at 0.075ppm.

Just last year, EPA finally proposed a new standard in the recommended range, but the opposition is out in force. Eleven state governors sent a letter to EPA filled with the usual claims that it will cost too much and be bad for business. They were joined by the Senate Environmental Affairs Committee that advanced a similar resolution earlier this month. The same sort of folks peddle their doom and gloom scenarios every time we try to improve environmental protection. They are always telling us environmental regulation isn’t needed and doesn’t work.

They could look back and consider that thick black clouds of pollutants chugging out of smoke stacks was a common sight before the EPA started its work. But, they don’t have to look that far. As we discussed last week, the areas where we regulate the gas industry are reporting decreases in methane emissions whereas the areas we ignore don’t. When it comes to controlling pollution, the simple fact is that regulations work.

While this is true, it’s not just an academic policy discussion as we continue to experience the impacts of pollution on our families and society. For example, we know that ozone and particulate pollution are linked to respiratory diseases such as asthma. This is a major problem in Pennsylvania where, according to the PA Department of Health, about 274,000 children and 877,000 adults currently suffer from asthma. In 2012, there were over 20,000 hospitalizations costing nearly $518 million dollars. That's just hospital charges—it does not include physician charges, lost work, and ancillary impacts. More importantly, it does not address the tragic 145 deaths asthma caused by fouled air.

It’s a good thing that groups like the American Lung Association are there to remind us that the fight isn’t over.

Rob Altenburg is director of the PennFuture Energy Center and is based in Harrisburg. He tweets @RobAltenburg.

PUC proposal to water down net metering re-emerges

Last February, in the midst of multiple attempts by utilities and utility commissions across the county to water down net metering rights or add fees to net metered customers, our own Pennsylvania Public Utility Commission (PUC) introduced a slate of proposed changes to our net metering rules. See blog post from February 2014. Among the changes was a proposal to limit the capacity of new net metered systems to "110% of historic usage;" a change to the definition of "customer generator" and "utility" that creates more confusion than it solves problems; and "clarifications" on virtual net metering.

PennFuture, along with a coalition of nonprofits, submitted a barrage of comments, encouraging citizens and energy industry representatives to push back. 

Now, the PUC has updated this proposal to address concerns, and protests that were echoed by stakeholders and citizens. Unfortunately, the amendments to proposed changes remain unnecessary, overly burdensome, and amount to an overstepping of authority by the Commission to reinterpret the Alternative Energy Portfolio Standard Act of 2004.

Among these revisions is a proposal to limit new net metered systems to 200% of historic annual usage; they've again added descriptors to the definition of utility in yet another attempt to reduce confusion initially caused by the first proposed definition change; and clamped down on virtual net metering proposals that "do not comport with the intent of the virtual net metering rule."

The 200% of historic annual usage rule is an improvement over the originally proposed 110% limitation, but remains unnecessary as net metered systems already have a limitation of 50 kW for residential systems and 3 MW for commercial systems. How much paperwork, time, and money, will be added to customers who are then forced to make a case to utilities that their system proposal does or does not comply with this usage cap is a major concern. Moreover, there is no incentive to install a renewable energy system that offsets more than 100% of your annual usage, but some customers choose to because of  future plans or an understanding that their energy use may change. Why limit the choices of these consumers?

PennFuture will be following this issue as it develops.

Evan Endres is program manager for PennFuture and is based in Pittsburgh. He tweets @ER_Endres.