GPC GRC

Question 1

GENERAL: Do we respond to the lawyers or the commissioners?

Answer 1

Respond to the commissioners. Use the title ‘Mr. or Ms. Commissioner’ or ‘Commissioner’.

Question 2

GENERAL: What do you do before every response?

Answer 2

Take a breath and collect yourself. No reason to go quickly!

Question 3

GENERAL: Which content areas are yours for response?

Answer 3

Any Bonbright material and any RNR material

Question 4

GENERAL: Important thing to remember about every response

Answer 4

Each question is an opportunity to get our talking points out there

Question 5

GENERAL: Any countermeasures?

Answer 5

You can: Ask for line and page of your testimony; ask for a moment to collect your thoughts

Question 6

CE: Don’t you agree that the volumetric rate includes more than energy costs?

Answer 6

I would defer to Justin Barnes on that, whose work on cost-of-service and cost allocation we appreciate

Question 7

CE: Would you call this netting a subsidy? Will this make the playing field uneven?

Answer 7

No, we do not think this is a subsidy. It in fact sets the rules of the game so everyone can participate evenly in the energy economy. But we also see the netting rules as prescribed by legislation.

Question 8

CE: What about ‘delivery’ costs?

Answer 8

1) I would defer to Justin Barnes on the nature of volumetric charges and what costs are included in them.
2) We would say that it’s a matter of price signals. Currently, DG is valued at a mix of exports and the retail rate. That would be the case under our recommendation here. The issues is whether there’s an appropriate price signal.

Question 9

CE: Isn’t Vote Solar a solar trade group?

Question 10

CE: The stakes are higher for us because they represent real costs

Answer 10

We agree with you that these decision has stakes and that’s why it’s important that the Commission take all helpful information into account when they’re making a decision.

Question 11

CE: Mr. Fitch, are you generally familiar with these issue? Have you practiced before in Georgia? Are you a trained expert?

Answer 11

I think expertise is borne out of focused effort, and I’ve worked on these issues for 6 years. I have a master’s with a concentration on energy policy and have reviewed the relationship between DG tariffs and policy in several other states, and I believe that’s important to this case.

Question 12

CE: Isn’t there a cost shift from customers reducing usage / solar customers selling back to the grid?

Answer 12

1. Simply put, solar customers in Georgia Power territory still use more energy than average and penetration is very low. Although it is a convenient talking point across the country, it needs to be backed up with empirical evidence and we do not find that support in this proceeding. And solar is likely to have highest generation at the Company’s peak summer demand.

[We don’t like this as much] 2. There needs to be a balance here. The argument we make in our testimony is that the right of consumers to use energy in the way they see fit is fundamental, and we don’t calculate cost-shifts for energy efficiency in general.

3. In any case, though, that’s a separate issue from whether this policy empowers customers and appropriately implements the 2001 Cogen Act. And we find a discrepancy there.
4. Finally, for the specifics, talk to Justin Barnes.

Question 13

CE (Bonbright): Can’t reasonable experts disagree?

Answer 13

Yes, but to a point. The purpose of enumerating Bonbright’s 10 principles is that each of them need to be considered and balanced when determining a sound rate design. Experts can disagree about how to balance those principles, but it would be inappropriate to forego any of these principles. Customer empowerment alongside cost reflectivity

Question 14

CE Bonbright): But isn’t cost-causation designed to eliminate undue discrimination?

Answer 14

There are many principles we hold that would cause undue discrimination. A toaster is a regular high-demand item that households use, but billing toasters differently would be inappropriate. Rural customers, Apartments, etc.

Question 15

CE (RNR): You say DG is about fairness. What about non-DG customers?

Answer 15

It comes down fo fundamentals and customer empowerment. The customer empowerment changes we recommend throughout the testimony will empower all residential customers. And we believe the changes to the RNR tariff will make that resource more accessible, not less.

Question 16

CE (RNR): Isn’t this just net metering? Just call it net metering?

Answer 16

First, we’re not asking for a new policy here; we’re recommending that the policy implemented here be that of the Cogen Act and Georgia Powers’ community solar bill.

Second, I think we want to be precise about what net metering means. Net metering involves a netting on an annual basis–kWh can roll over month to month. What we’re recommending is monthly netting, sometimes called ‘net billing’, that values exports over a month at the rate determined at the RCB framework. However, every utility that has DG customers has a mechanism for netting and compensating exports.

(If pressed): There are many different net meterings across the country. Does GPC implement like Duke? Or Dominion? or Consumers? No.

Question 17

CE (RNR): Are you looking for a change to the RCB framework?

Answer 17

No, we are not. The Commission to our knowledge has not made an affirmative determination on netting period. TWO components here.

Question 18

CE (RNR): You’re not a lawyer, why are you interpreting Georgia Law

Answer 18

I am interpreting it because the RNR Tariff directs any reader to the Cogen Act as a matter of understanding how the tariff will ‘net’ imports and exports. No other tariff that I reviewed across Georgia Power’s peers did. We are offering a reading of the plain language, interpreted by experts in DG policy and DG tariffs.

Question 19

CE (RNR): Any specific language parsing?

Answer 19

Look – Georgia Power customers are steered to this legislation and engage in the same parsing that you and I are. So it’s reasonable to parse what exactly these terms would mean to a normal cusotmer?

Question 20

CR (RNR): Doesn’t it make sense to bill community solar differently?

Answer 20

The argument for netting in this way is actually more appropriate for rooftop consumers because a substantial amount of that energy is consumed onsite. We agree with the Company and COmmission’s approach for community solar and the same should apply to rooftop

Question 21

CR (RNR): What does ‘billing period’ mean to you?

Answer 21

It’s written on Georgia Power Company’s monthly bills, which if I am understanding correctly are distributed about once a month. It’s also written into the netting mechanism in the Community Solar tariff included in the Company’s rate case

Question 22

CR (RNR): Will solar customers receive benefits at the expense of low-income customers?

Answer 22

First, we don’t agree that there’s a cost shift. We think the solution to equitable solar is not to make the technology harder to get, but make it easier to get. More customers who have the opportunity to go solar mean more savings.

Question 23

See page 16. Are you admitting here that energy costs may sometimes have allocations to customers or demand instead?

Answer 23

Our understanding of Bonbright’s recommendation here is not of the specific cost-of-service-study, but of how those contribute to cost signals. I think the lesson there is there are legitimate reasons to change the actual charges compared to the Cost-of-service-study based on the other ratemaking fundamentals we’ve discussed;

Question 24

Why is flatbill recruitment so high?

Answer 24

PIA-5-16.

Question 25

Why re-open this now?

Answer 25

While we haven’t been privy to the parties’ previous participation in these proceedings, we believe it’s always appropriate to align with rate fundamentals and appropriately apply the law.

Question 26

What makes you so sure what ‘billing period’ means?

Answer 26

Based on a common understanding, but also several of the materials filed in this proceeding by the comapny, including the Rules and Regulations Section E, the Community Solar tariff, and physical customer bills.

Question 27

Why not use the power of AMI here? Are you saying that normal metering practice would not use these?

Answer 27

When we see ‘normal metering practice’ in the 2001 cogen act, we apply it specifically to the billing practice and not data recruitment practice. Just like AMI didn’t immediately result in customers on real-time pricing, there should be the same discretion with DG.

Question 28

So if you’re not making a legal opinion then how should the Commission treat your testimony?

Answer 28

There’s a clear discrepancy based on a plain language reading and our recommendation is that the Commission review in greater detail!

Question 29

Following up – did you think the Commission didn’t see this coming? That they hadn’t reviewed for compliance over the last 18 years?

Answer 29

Of course we trust the Commission to review judiciously–in this case, this is simply what we noticed when we reviewed the application and the perspective of experts on DG rate design may be helpful for the commission