NCSEA files Joint Reply Comments Regarding the Solar Integration Services Charge in CPRE

On October 7, the Commission issued an order requesting comments from parties about whether Duke’s solar integration services charge (SISC) should apply to the Competitive Procurement of Renewable Energy (CPRE) and, if so, how it should be implemented. On October 17, the Commission subsequently issued a Notice of Decision in the avoided cost docket approving in concept but modifying the SISC for PURPA contracts. In response to the CPRE order, on October 18, NCSEA filed comments jointly with the North Carolina Clean Energy Business Alliance (NCCEBA) and on October 29 NCSEA and NCCEBA jointly filed reply comments

In our Comments and Reply Comments, NCSEA advocated that integration costs should not be imposed on CPRE projects because CPRE projects are dispatchable, and therefore should have lower integration costs. If the Commission determines that an integration charge is appropriate for CPRE participants, NCSEA argued that the charge should be lower than for PURPA projects because of Duke’s dispatch rights for CPRE projects. Finally, given that the Commission dictated that integration costs should be incorporated into avoided energy costs for PURPA projects, NCSEA argued that integration costs should be incorporated into the avoided cost in the CPRE as well, which serves as the cost-effectiveness cap for bidders. In essence, bids would remain the same, but there would be a lower cost-effectiveness threshold for bidding projects. 

In addition, NCSEA recommended that an integration charge should not be imposed on controlled solar generators or solar + storage projects that mitigate their need for ancillary services. 

An order on the application of integration costs in the CPRE is expected soon, given that Tranche 2 of the CPRE is already open for bidding. 

As always, the NCSEA team is here to answer any questions you might have about this or other proceedings. Don’t hesitate to e-mail with any questions. 

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