NCSEA Submits Reply Comments in Solar Rebate Docket

On July 6, NCSEA filed reply comments to the initial comments of The Public Staff and the Southern Alliance for Clean Energy (SACE) regarding Duke Energy’s solar rebate program. NCSEA’s initial comments discussed the demand for rooftop solar rebates has consistently exceeded supply in each year of the program. NCSEA encourages the North Carolina Utilities Commission (NCUC) to address this issue by increasing the supply of rooftop solar rebates; the Public Staff has requested the NCUC to adopt policies to decrease the demand.

In its initial comments, the Public Staff states its belief that increasing the nonprofit rebate amount and decreasing residential and non-residential rebate amounts will result in higher nonprofit participation. NCSEA has learned that slow uptake of rebates by nonprofits does not indicate a lack of demand; rather, it evidences a different purchasing cycle. A nonprofit governed by a board of volunteers and government agencies needing to comply with procurement requirements take significantly more time to make a decision compared to homeowners or facility managers.

Below is the breakdown of solar rebates following the Public Staff’s proposal and NCSEA’s proposed options:

• Public Staff proposal: an 8 kW residential solar installation would receive a rebate of $4,000
  • NCSEA Option 1: provides for a maximum rebate of 5 kW for residential systems; an 8 kW residential solar installation would receive a rebate of $3,000
  • NCSEA Option 2: requires a 1:1 ration of rebate-eligible and rebate-ineligible solar; an 8 kW residential solar installation would receive a rebate of $2,400

Under NCSEA’s proposals, a customer would receive a smaller rebate relative to the current paradigm, but significantly more residential customers would be able to participate in the rebate program. Under the Public Staff’s proposal, a residential customer would also receive a smaller rebate relative to the current paradigm, but no additional customers would be able to participate. 

NCSEA is concerned by the uncertainty of the rebate values under the Public Staff’s proposal. The Public Staff proposes that Duke further reduce the residential and commercial rebate amounts in order to cover any increased administrative costs for its proposed lottery program and to reduce the nonprofit rebate amount in order to cover any increased marketing expenses. The vague nature of this proposal is problematic to solar installers and customers as the value of the rebate may be unclear or difficult to calculate. NCSEA believes this proposal will lead to an unacceptable amount of regulatory uncertainty. 

The Public Staff’s initial comments suggest that a lottery system is a more equitable approach to Duke’s solar rebate program than current enrollment window system that distributes rebates on a first-come first-serve basis. However, NCSEA believes that a lottery system would be more unfair than the current process. First, moving to a lottery system removes what little control customers have over a rebate process. Second, in the 2020 enrollment period Duke experienced technological problems with its website and back-end software that led to flawed enrollment. Requiring Duke to utilize a lottery would only increase the likelihood of further technological issues. 

In its Annual Report, Duke proposed moving from a single application window per year to two application windows per year. NCSEA does not object to this, but the realities of the COVID-19 pandemic prompts NCSEA to suggest that the opening of the first 2021 rebate application window be in October of 2020, which is supported by SACE’s initial comments. The Public Staff is against the use of biennial enrollment windows stating that the solar industry would experience a decline of installations between when the subscription limit is reached and the beginning of the 90-day window for the next enrollment period; however, this drop-off in installations is not supported by evidence. 

NCSEA will continue working with Duke Energy and other parties to formalize areas of agreement and will keep members informed of any updates regarding Duke’s solar rebate program.