Good morning and welcome to the House Environment and Energy Committee. This morning we are taking up H-289 and relating to the Renewable Energy Standard. We have Dave Ford with us from the Public Service Department. Welcome back. Thank you. For the record, T.J. Poor, Director of Regulated Utilities in the Public Service Department. Thank you for having me again. So I'm going to talk about our initial reactions to H-289 today, but first I'm really going to talk about balancing priorities and how the, we think the Public Service Department's proposal is the proposal that best balances the priorities for monitors. I'll then get into a little more detail than I provided last time about the community renewables program that we're proposing. And then if there's time, I'll provide a few, some more specific comments about certain line items and pieces of H-289. I'm sorry I don't have handouts for you today. The printer is not working at the office this morning, so he's stuck with online. So we're just going to pull up the slides. Okay. So I'm going to start with our, with environmental justice and equity today. And so I don't have pictured on the slide the energy plan. I talk about the energy plan a lot. Of course that is centered around equity and it's one of the themes of the energy plan. But also the climate action plan and the environmental justice legislation that was passed in 2022, like 154 of that year, both call for Vermonters to be part of determining solutions to our climate and energy needs. And the public service department's proposal has really carried that principle forward in both engagement prior to the proposal and in the process that we're proposing, sorry, for community renewables. And specifically the climate action plan calls on Vermonters must be part of not only the solutions but in determining them. We want to make policy with Vermonters, not just for them. The guiding principles adopted by the council include ensuring inclusive, transparent and innovative engagement in the development of the plan and policies program and moving at the speed of trust. So if we don't take what, so we think that the department's process has been at least a very good attempt at ensuring inclusive and transparent engagement. And we're worried that if the participants in that process don't actually see their recommendations and the results of it put forth in policy that they're going to be disillusioned. We're not going to be moving with their trust at all. And then specifically act 154 called for meaningful participation of all individuals. And really we really think our proposal hit these marks the best we could in the 18 months that we moved forward. And this has been kind of core to how we've been thinking about moving forward here. I want to, I know I showed a couple of these slides. I'll just go quickly on a couple of these slides about what Vermonters said about their priorities. And in short, it's affordability, reducing carbon emissions and reliability. That you can see that those are, when asked what your single most highest priority is, those are the three highest priorities. Point out that whether the source is produced in state is down near the bottom of somebody's highest priority. And that is both the initial survey of 700 participants and then a follow-up survey in focus groups. Also, in addition to the affordability, reliability and emissions, they want to ensure access. This is focus groups, our regional planning commission events. We heard this a lot. Vermonters are really concerned about their neighbors, tying that back to affordability and affordability of our climate policies for their neighbors. And they overwhelmingly want to ensure that our policies are designed to help, provide help for disadvantaged communities or support for community solar, which is kind of the how community renewables and community access is presented to us a lot. It's in the form of community solar. Representative Smith. Thank you. Has there been a lack of support for disadvantaged Vermonters? Has there been a lack of support for disadvantaged Vermonters? You mean in our current policies, our current renewable energy policies? Overall, I mean, are there people in back roads somewhere that aren't getting any attention? Well, I think our policies, I'll use net metering as an example, is net metering is paid for by all ratepayers. And really, those, for the most part, those who have the wherewithal to sign up for net metering, whether it's the funding, the financing, or just like the skills to be able to, in the time, capacity to actually sign up for a group net metering system, those are the ones that are benefiting. And those who do not go into those categories of having the funding, financing, and wherewithal time and capacity to do it, those are the ones who are paying. And that is disproportionately lower income that are paying. And so I think there is some of our policies are not equitably distributing the benefits and burdens. Thank you. Okay, I said I would go quickly on those two slides. So I'm going to go to the affordability priority. So this chart on the you saw last time, which is the average projected rate increase incremental from the scenarios we analyzed in the technical analysis. And you see those scenarios are anywhere from three to five percent average rate impact over time. And I've circled scenario two, Mr. Sterling last week, or maybe it was the week before when he's testifying, also kind of circled scenario two is saying that's the one that's kind of like H 289. It's not exactly like that. I'll get into a little bit of differences. But so I just using that one as an example here. And so that's a, you know, five percent rate impact from the modeling that was done with a stakeholder advisory group that included Rev and a number of broad array of stakeholders. And that what that equates to is $800 million over 10 years. So, you know, 10 years, if our revenue is a billion to a billion and a half dollars a year, you know, so we're like talking about 10 to $15 billion, $800 million is is what that equates to in terms of what that scenario is. And those are costs above the benefits. So net cost to Vermont ratepayers. It does not account for the social cost of carbon in this analysis. We talked about that last time, social benefits Vermont costs. But it and it doesn't account, you know, cost reductions to Massachusetts or Connecticut, but it's the costs and benefits that hit Vermonters pocketbooks. 800 million over 10 years is what the model said. Now, do you want to do a question from representatives? Do you want to do a question? I'm sorry, actually, do you want to? It's up to you. Okay. Let me just say one more thing and then and then we'll start to. Now, I actually don't think that that scenario lines up exactly with $800 million. There's a number of carve outs and different provisions that are different than the scenario modeling.  And so let's say it's say we're off say it costs $500 million over 10 years. Well, what does that $500 million buy us if we were to kind of put it into other things? It could buy us $5,000 incentive for 100,000 vehicles or it could buy us 50,000 homes weatherized over the next 10 years. So we're we're doing that stuff. You as a legislative body have decided to move forward with a clean heat standard. We're already moving on the thermal sector. We have transportation incentives as well. But this is another $500 million on top of what we're already doing. And so I just want to make that really clear on what what the H 289 is spending. And there's a range of options. I'm not saying $800 million is the number. I'm not saying $500 million is the number, but it's there's there's a significant cost to to H 289. I will one more slide and then questions. This is really relevant. And this is a quick one. And those costs in the model also don't I've mentioned this before I've been very clear about this. They don't account for cost to the transmission and distribution system necessary to create headroom for all of that other generation. So there's no costs there associated with that today. And I think the reason they're not testifying today, Velco is presenting under the draft results of their long range transmission plan, where they're there's some emerging information and data showing that there are significant transmission costs to getting the amount of solar that would be likely to be cited under a 20% tier two. Our proposal really mitigates these costs. Velco being on Friday and I think it's appropriate for them to talk about that. But I just wanted to be clear that the cost structure we're talking about does not account for this additional impact. Velco only talk about the transmission sector and the distribution side. There are also costs. And so we're still trying to work with GMP and VEC at least to get a sense of what those costs are. But again, our proposal will mitigate those on both the distribution and the transmission. So that's my last point of cost. So now might be a good time to. Yes. So just one question around the working group proposal, proposes to eliminate group net metering. How does that factor into your projective cost, TJ? So in the scenarios that reduces the amount of net metering and the higher costs that are in the model, those costs in the model were declining already. It's a group net metering. And the way that's shown in the model is by the amount of megawatts that are assumed to be developed by net metering. And those were assumed to be declining even in the business as usual because the cost structure of group net metering, I think I think it's been said here before by others than me that there are less and less group net metering projects already being proposed now because of the cost structure isn't quite working out. And so with that the case, removing group net metering definitely helps, but it doesn't help as much as you would think. I would say it helps on that order of but when I did it for our proposal, it was like a 25 to 50 million out of the out of the five point dirt to 800 million. So it was savings. It was savings. Yeah. So it was you could reduce those costs by like $25 million for 10 years over 10 years because you're still replacing that. So instead of 14 cent power or 12 cent power, which group net metering, all excess generation is around that range, you're at 11 cents. So it's that three cents a megawatt hour difference for the amount of group net metering, which was already assumed to be declining. So that's why it's kind of a small, it's a savings and $25 million, $50 million is real, but it is not as big as I thought it was going to be. It's one way. That might be obvious, but just what is driving those costs to be significantly different? Well, they are significantly different from the other scenarios. What's driving those five percent cost? It is the cost of the power that is above what is above the value of the power. So if in the model, we based on recommendations from our stakeholders change the model to have the cost for solar be around 10 and a half cents to 11 cents per kilowatt hour for larger solar above 500 kW to up to five megawatts. But the market value of that is lower. The energy value assumed in the model has it being between three and five cents, and then you have a capacity value on top of that, and you have some avoided transmission, which is small because our transmission charges are incurred based on our monthly peak load, which happens at night. So the value proposition for that energy, when it's being produced, it's kind of at the lower value times. If you look at market costs, and I don't have a slide with me, I could pull it up and take a little too long. But in our annual energy report, which we sent in this week, there is a comparison. There's a graph with a wholesale market energy prices by month over time. And you'll see in the winter, prices are really high, and especially in the shoulder months, when April to May to June, and then in the fall, prices are really low. And so that solar is generating at the lowest value times. And so that's how it's kind of framed in the model is like, well, utilities could otherwise purchase this energy for this cost. And that increment is the above market cost that is represented here. Representative Tory. Thank you. Thank you for sharing this and all your good work on the engagement. I think that it really stands out how much participation and input you got. But I do have a question for you about, within this 10 years, what we can expect to happen from an investment in storage, for example. And the fact that we're talking about a dynamic energy system, it's changing. I know Connecticut is pretty all in storage. And with the amount of money available from the feds, that could be true for my as well. Do you have any thoughts about, you know, what or any insight into what kinds of rate impacts a more dynamic pricing experience because of storage, the opportunities that's going to open up what that could look like for ratepayers. Yeah, so a few things. One, in terms of the federal funding, the department has put into competitive solicitation for $100 million for storage in partnership with all of our distribution and transmission utilities. And so we are looking and trying to take advantage of those opportunities. There's a value proposition now for storage. And that value proposition is, well, we can avoid, there's a number of values you can stack, just like with any resource. We can avoid some peak costs. We can avoid, maybe we can avoid some infrastructure costs. We could avoid it. And, you know, arbitraging energy is challenging, a little more challenging, right? Because those differences are not within an hour. Sometimes they are. But the ones, the large scale ones that I was talking about with high prices in the winter and lots of generation in the summer, storage is a lot shorter duration and it's not going to really help with that. I think we need to be careful about saying, well, if we pass a REZ that requires storage, then storage will then have a value proposition because we don't want to create a policy that creates a problem that we need another policy to fix. And so I think we need to be a little bit careful about just saying we can solve all this with storage. I'm going to skip ahead really quickly because I brought a couple additional slides just to haven't shared these with you. This is where we are with storage right now. And a storage comes up a lot in this committee. So right now we have about 55 megawatts of operational storage and on average that is three hours per megawatt, so 154 megawatt hours of storage. There's another 20 megawatts under development in specific dockets and then also residential storage added every month with fire utilities. Say those numbers again, maybe slower because you're used to them, but we're not. Yeah, I'm sorry. So we have about 54 megawatts of storage that's operational in context and another 20 that are under development in different dockets. And so the list here, the top half are operational, the bottom half in italics are under development. So about 74 megawatts worth of storage total. And storage, you gave a really nice, how long it lasts? What do we get for that storage? About three hours. If you've turned it all on at once, you have three hours with that 74 megawatts for the whole, well then for all Vermont, yes. So that is, so just 74 megawatts in context is about 10% of Vermont's peak last year. So we're at about 10%, if we're just looking at our peak load, about 10%. And we put together a summary of some of the goals and in other states. And so what we have, Connecticut was mentioned, there's a goal and milestone out here. They have 12 megawatts of storage deployed 2023. They're at 0.2% of their current peak. Maine has a target, they have about 63 megawatts of storage deployed, about 3.6%, Massachusetts 0.7%. Vermont, if you count the 20 megawatts under development, we're at 10.3% already of storage. So storage value proposition as it is, is working, we're deploying storage. And then the last thing I'll stay on storage is that we also need to be careful of if we decide to use storage to better gain value with our energy system and do energy arbitrage, then we may not have it available for a use case for outages or for frequency regulation, which provides a value for making sure the system's balanced all at once, or any of the other use cases, avoiding transmission costs. And so we ought to make sure we don't double count those. And we do have a few questions of Representative Clifford. Thank you, Madam Chair. Thank you for your presentation. The question I had is, was there any discussion about what the impact would be on electric rates over the next 10 years? Can you say that? I couldn't hear you. I thought about what electric rates would be over 10 years. What the impact would be over the next 10 years for the H-289? Yeah. So that's the slide that I was talking about here. It's three to five percent, seems like a small percentage, but that scenario too was $800 million to electric rates. And so, like I said, maybe $500 million. And when you adjust for all the carve outs in different pieces. Thank you. Representative Stevan. So I have three questions. The first relates to what you just said. Just so the committee has a sense, and I'm not discounting that there was a cost to everything, and that five percent over 10 years is not important. But could you give the committee a sense of what we've been seeing in terms of rate increases from different utilities over the last year or two? Sure. Yeah, there have been rate increases in the five to 10 percent range. There's been requests for over 10 percent in the last few years as markets, especially when markets spiked in 2022 and the open position, any open positions that utilities had where they were not already hedged with power, they needed to cover those at higher rates. And so there were rate increases. Thanks. Just for me, when I hear five percent, I'm like, well, how does that compare to other things that are going? Yeah. My second question. So storage, I've thrown a few bills at the wall. For me, the storage piece, like I keep thinking about the communities that go out of power for a full week in Christmas of last year. And for me, storage, I did not know those stats. Thanks for that. For me, it feels not necessarily, it feels like each utility has sort of their storage goals that they probably put into their planning processes. But as someone not deeply involved in that, for me, it feels like it's the storage going where we need it. And that's the part where I keep thinking from a, yes, there is the resiliency. If you have storage and you combine it with solar, then you can reduce costs depending on how things are structured. But there's also just the resiliency of like if we're having more winter storms, if we're having more flooding and power is cut or whatever. Do you feel like our approach to storage right now, which is sort of, I would say, utility driven and then perhaps somewhat developer driven and homeowner driven? Is there a plan there? Is storage going where we really need it to be? Not that we don't need it a lot, but I just feel like that's the piece that's missing for me when I think of rural communities that are stuck for a week. It'd be great to have storage and solar, big F100 lightning right there to plug in so people can have a backup. Yeah, I think that we were heading in that direction. Right now, storage is penciling out on the kind of cost benefit evaluation in a lot of use cases that doesn't necessarily include the use case that you're talking about. And we need to find a way to value that a little more clearly so that we can ensure that the projects are going where they need to go. There's a lot of work being done with the climate council on a municipal vulnerability index, which will also, I think, highlight other locations or locations where storage would be most valuable and start to help to direct us to point in that direction. Thanks. And my last question, which maybe if we have time, you could touch on that at the tail end when you've finished. I am aware of some of the things the department slash Clean Energy Development Fund are going for in terms of grants at the federal level, but I don't really know the full gamut. So just wondering if you could give a high-level summary of like these are the five grants we went for, just so we're aware and so that we can see whether or not the policies that we're working on are supportive or not. Sure. Do you want me to wait to do that? Well, I definitely want you to get to what you came to share with us today. Reminds me that the question that I wanted to ask you was about solar for all and helping us understand that because it's come up a lot in our conversations. I think it's related to Rep Stevin's question. So I hope there's time. Representative Sibilia. Just terminology actually going back to the storage and you were talking about the use case. Can you just for us merely people explain what that? Yeah, so thanks. I use that term to just say this is what we're using the storage or the resource for in this instance. So if we are using storage to avoid our transmission peaks, will it be also available to help us better manage supply and demand with our generation supply generation and demand imbalance? And that's a different use case, right? A different use case is balancing the system regionally to help make sure that supply and demand are matched up as part of ice underway. And so when I say use case, I just mean like different ways that you can use the storage and value propositions and they interact. And so you can't count 100% of the benefits for each one because they might overlap and one might eat into another. So that's proposed by each utility? When they're proposing storage, they'll say what this is how we're going to use it and this is the value proposition. Yes. Thank you. Representative Pat. Just some things. I mean if a storage facility, whether it's a home storage facility or a larger scale facility, if it ends up being used for an extended outage and it may not last for for the total amount of the extended outage, that then would not since it would how would that affect the I mean the power supply and the power supply cost of the utility that would otherwise be using it as part of their energy supply to customers when in this case that's not what's happening during an outage? Yes. So my point is really that the different use cases interact and you can't just say that well we get 100% of the value from avoiding outages and 100% of the value from using it for frequency regulation and 100% of the value elsewhere. In one instance that that utility is not paying for power supply at all in that instance because there's an outage, right? And so the battery hasn't provided any value there in terms of power supply, but it may have provided value to the customer and so you just can't count both of those values. So at the same time. Okay. So emissions was described as another priority. Just doing a time check. Emissioned was another priority of Vermonters and so I want to just bring us back to our starting point of what our current portfolio is. On the left hand side of this chart you see our physical deliveries. That's just our contracts. I use the word entitlements. Utilities either own or contract for power and so they are entitled to that energy regardless of the attributes of it. This is on the left hand side this is what they were utilities were entitled to in Vermont for 2020. You can see that 65% of it came from renewable resources and the additional 21% came from nuclear. On the right hand side is the after we account for the attributes and who owns the actual environmental credits associated with those and so the mix changes but overall we're 90% emissions free. This is what this is what how our greenhouse gas inventory currently tracks our emissions and how our requirements towards our G. W. S. A. Gold Global Women Solutions Act goals are tracked in that so we're starting from a spot where we are 90% emissions free now. Both as counted by that greenhouse gas inventory both the public service department and each 289 proposals are have the exact same impact. There's no emissions difference as it relates to our G. W. S. A. Bolls. So both proposals close the gap from 90% non-emitting currently to 100% non-emitting by 2030 and that's done through the trading of those renewable energy credits and nuclear attributes. But so emissions was a priority and affordability was a priority. They have this both proposals have the same exact emissions impact and the public service department proposal is much more affordable. That's a good question on affordability. The 5% on a bill on the average bill what is that? Well it depends on what your bill is. I mean if you if you just say your bill is $100 that's in a month. You're at $5 a month right $60 a year over 10 years $600 that you an individual who has a $100 bill is paying did not mean to hit that button. Okay so there is an emissions impact difference societally though and I know that I think there's not there's not a disagreement here that the only societal emissions impact is from when you add new renewable generation. And so the department's in agreement I think with with everybody I haven't heard anybody say anything different. The only time you actually societally make a difference to emissions is when you add something new and then now you're avoiding usually whatever is on the margin in iso anew England usually a natural gas generating plant. And so the difference in our proposals societally so this top bullet is Vermont difference as we track to the global warming solutions act in our requirements. This bottom bullet is societally the difference and it's the difference between 30% new renewables in the department's proposal and 40% new renewables and those are rough numbers with the carve outs and different nuance to both the proposals so it's not exact but so we're talking about 10% difference of new renewables and just a reminder again our greenhouse gas inventory there's a slide at the end of the deck I won't scroll to it it just shows our greenhouse gas inventory the electric sector is a really tiny portion of the state's emissions as we track to those G.W.S.A. requirements. Representative Clifford. Thank you Madam Chair. I hope we understand what a societal emission is versus just emissions. Right so it's a very good question and I take it for granted a lot. So I often in the energy plant calls for this and so the department does analysis based on what the impact to Vermont is and our borders and so draw the borders of the analysis around Vermont and then we take a broader look and say what's the impact to society. We don't have any natural gas generating plants in Vermont but when because we're part of ISO New England if we add new generation somewhere in New England we're going to reduce a natural gas plant somewhere in New England. Those benefits don't accrue to Vermont directly and so they don't count in our in the rate impact that I showed you for instance but they do count for society. We've stopped a certain amount of emissions going into the atmosphere and so they so that's the difference is kind of the scope of the analysis from global is societal to Vermont specific and it's important for us to evaluate both things. What I said last time when I was talking about the economics of these proposals is that all of the scenarios we evaluated had a societal benefit and you count those emissions benefits that accrue to helping reduce sea level rise and other climate change impacts reducing natural disasters but they come at a cost of Vermont rate payers and that's the tradeoff we have to balance right is how much does Vermont pay for those societal benefits and I think my point here on this slide is that there's a significant difference in how much Vermont pays with the two proposals and not that much of a significant difference in how much emissions are reduced society. How do you count for societal costs of say disposing of nuclear waste because the two scenarios use nuclear what significantly differently right. Yes so those are those they both assume that nuclear is included in the business as usual so there's no there's no difference nuclear remains a part of New England's power portfolio and so there's no difference in the two cases the same amount. Yes nuclear is a you know a base load resource there's there's a plant in Connecticut called the Yellowstone Generating Plan and they need to be re-licensed in the next couple of years by FERC and right now there's a regional discussion going on as to you know the owners of that plan are saying well we don't know if it's worth it to actually re-license and so New England the New England states are saying this provides a real reliability benefit it's base load power we we need to talk about keeping you around and keeping you operating there's a net and so those are you know discussions that are happening there's nothing super solid but what's happened in the last two years is that there's the mystic generating stations the natural gas plant another base load power plant that is in Connecticut also they were going to retire and ISO New England said no we need this plant for reliability and so we are going to pay you anything above market to that you need to stay online and so whatever they got from selling their energy they got and then they sent ISO New England what it cost to operate and ISO New England sent them a check for the difference and ratepayers paid for that and it was significant like regionally hundreds of millions of dollars representative Tory regionally I was just curious on the other New England states do they consider nuclear renewable not renewable no but they include it Massachusetts in particular specifically includes it in their clean CES E it's their clean energy standard existing and there they specifically allow nuclear and I believe I'm not sure about Connecticut I think Connecticut is on that track with the queen energy procurements as well and so and the department's proposal doesn't define that as renewable it's not a renewable resource it but it does it does call it quote unquote clean at least as far as emissions at the point of combustion okay so I'm going to move on to access and the other things that we really heard we touched on reliability with some of the nuclear but I focused on that last time so so I want to have listened to a lot of the discussions or you know gotten notes from the discussions and want to be clear that net metering is not necessary to ensure access net metering is a program that we've constructed to deliver it to allow for self-generation and group net metering etc the department's proposal says well net metering should continue but we should compensate it to avoid cross subsidies and to do that we are proposals to compensate the excess generation at avoided cost so excess generation means any generation beyond which is used on site so anything that's exported onto the grid and avoided cost is what utilities could otherwise buy it for so our proposal is to compensate net metering what's not used on site as at what utilities could otherwise buy it for so without without the subsidies that are currently there that portion of the proposal is estimated to effectively end group net metering and should be in there right now or effectively eliminate new group net metering for projects but if rates were to increase like the wholesale market rates increase then our proposal also allows group net metering to continue to exist and to be an option and there wouldn't be cross subsidy because the rates would support it what utilities could otherwise purchase the power for would support group net metering so it's a little more nimble in that respect and so both both our proposal and h289 effectively do right now eliminate group net metering but i'll talk about it in a second our proposal actually seeks to replace it with a more cost effective mechanism to ensure access to communities and that's not our goal is to provide that access at least cost that doesn't necessarily mean least cost generation because it's going to cost more than what utilities could otherwise buy it for but it's going to cost less than group net metering as it currently exists and then just another note because i've heard it here that the effective elimination of group net metering in our proposal or the explicit elimination of group net metering in the h289 doesn't affect the solar for all proposal that we submitted to the environmental protection so we submitted a hundred million dollar proposal that had three or parts to it one part was to support self generation from onsite net metering single family net metering for low-income customers another part is to support the pilots that utilities are already now undertaking with ten million dollars of arpa money in what we call the affordable clean sorry the affordable community renewable energy program that and to expand that program which it's an arpa program so as coven relief dollars provides bill credits to customers in a form of provides bill credits through giving them ownership of a portion of a solar plan and there's a lot of different flavors that were piloting the third portion and the biggest one is to support solar development on affordable housing or with affordable housing and there is flexibility in the way that we propose that group net metering could be an option to deliver that or you could do it in a more cost effective way through utility procurement a statewide procurement or otherwise otherwise support solar on affordable housing it is not limited to group net metering proposal is it one more in your book there's three those are the three parts of your solar for all those are the three parts of the solar for all yeah sevens and then severely the department's proposal related to what is it group net metering it still has to be all on site so we heard testimony at least that's what it sounds like we heard testimony from one affordable housing builder who said we can only build this much on site and you know a block away there's affordable land so would your proposal allow for you know or or a community like let's say a community wants to do solar on their municipal rooftop but then they run out and they still want to actually you know try to get as much solar to offset their typical daily load and demand what does your proposal allow for hey we ran out of space so this does make sense for us to go somewhere else where we also have land explicitly yes okay that was my first question my second question is again this is a context question if we're running out of time we can skip it but I just my understanding is that there are lots of cross subsidies within rate making and electricity design and you know fossil fuels compared to electricity I always struggle when I only see one type that is highlighted so if we have time if you could touch for a minute on some of the other cross subsidies that are out there that we all pay for and we don't highlight repeatedly in policy making sure I'm going to hold on that one okay and because your first question I want to really describe the concept in what would replace group net metering here and so we've tentatively named this the renewable energy for communities program re4c suggestions on the name are welcome what the proposal would do would be to require utilities to issue solicitations for community energy systems that meet a number of objectives that would be laid out in statute it would deliver benefits to meet the objectives of delivering benefits excuse me to customers who have historically been marginalized or faced with inequitable access to benefits of renewable energy this is in line with environmental justice legislation supporting community participation and development and governance of distributed generation support tenants affordable housing buildings and support benefits to school and municipal buildings so community really community focused utilities would require to be solicited a certain amount of energy over over the 10 years that the program covers that that energy could be you know it's not size restricted so one of the reasons that this can be more cost effective than net metering is that it could be a larger project that is offsite up to five megawatts and that affordable housing could or other community focused projects could take advantage of those economies of scale um in terms of process we would recommend a process that where we undertake a stakeholder engagement effort so that we actually develop the details of this program design and how the mechanics of it would work with the communities that would be affected by the program itself so we don't want to just say hey we're going to do a utility solicitation we're going to design that here hope it works for you we're going to we want to take some time to actually say what is going to work for you and to be able to respond to a solicitation and have successful projects deliver deliver power under this program then we would submit that to the public utility commission and they would by rule or order actually actually implement the program which would would be the actual requirement for utilities to to solicit this power um really this allows utilities to tailor solicitations to build utilities where there's room on the grid and that generate at times when energy is needed that on the utility side it helps contain both power supply and transmission distribution costs on the community side it allows communities to take advantage of economies of scale participate in a way uh is more cost effective for rate payers uh and um uh and delivers the same or similar benefits representative logan than pat thank you chair um thanks tj um really appreciate this proposal um i'm curious if you all have thought about ways in which this could potentially benefit tenants and i mean one of the issues that we're facing with tenants and is the split incentive typically that there is between a landlord and the tenants it seems like this has the potential to benefit tenants of you know that are um missing directly from private landlords as well yeah so well i think um that does have that benefit and we can decide in the design of the program how much to focus on different groups whether it is just tenants of affordable housing or if there are objectives we want to recommend to support tenants of landlords that don't otherwise have access and so i think there's room in the design of this program if we can lay out the parameters the broad parameters and the objectives of what we want to accomplish with the program then there's there's room for um really designing it in a way that supports um supports those goals and actually um and it gets to where we want to go we don't want to over design it in legislation here in the committee room or in the hallways because i think that we we would miss something but not all the right folks are around the table um and so um there there is room for that um the other thing i'll just say is you know net metering as i understand it now especially for her affordable housing folks net metering works for them right like and so the way i think about net metering it's it is like a contract they're getting a certain amount per kilowatt hour for every every kilowatt hour they generate and so um they may get less per kilowatt hour for the number of kilowatt hours they generate but because of economies of scale the efficiencies of this utility solicitation where it's going in spots where the grid can handle it that reduce the cost so the the margin that they're getting could it could still be the same and so we want to support affordable housing to you know in and we want us just like we want to support all communities and to ensure that the benefits of renewable generation are actually distributed more equitably and i think this is a way to do that and actually just reduce costs to the other rate payers who are paying for that isn't it pat my question is how how do you um when you say uh require utilities to issue solicitations do you have a sense of how you would determine like how how much a particular utility is expected to solicit for um and and then once the proposals come in is there a way would you what if the proposals come in at a very high cost um is that uh what what happens then and also again with net metering in general what if this is um simply displacing power that the utility already has yeah so um so a few quite a few pieces there i think one the starting point would be um and and i think a lot of this can be in the design details so i none of this is is rock solid but i would start with a spot of a pro rat a share of the whatever the requirement ultimately is is the requirement for each utility that said i think that for a hundred percent renewable utilities that are design designated in both h 289 and the department's proposal um the new required capacity could be limited to the to the load growth um so uh to requirements associated with their load growth and so um so there that i think answers part of your third question or is one potential solution there um and i think there still would be an alternative compliance payment um so that would cap the maximum but i think utilities could coordinate on their solicitations they could you know it doesn't have to just be one small utility that's what could coordinate or you know the co-ops could coordinate and that may provide like a bigger scope to provide the best project get the best projects that help the most people and so um i do think some cost containment provisions are appropriate and uh those are a couple of possible ways to get to them representative tory this is making me think um that plan is going to be really important like energy shed within on the community level um just like we talk in this committee about watershed planning in the face of all the risks um from flooding do you have some thoughts about how to to just grow uh the capacity to plan on that level yeah i think the regional planning commissions are doing a really good job right now in planning and helping municipalities plan there are a lot of municipalities that don't have energy plans still i think we're there um getting knocked off slowly and surely um you know my home town of pittsford uh is is developing an energy plan now which is exciting um where i grew up but they um um you know one of the objectives or provisions in this program could be to um support projects that on locations that have been designated by the regional plans or the towns town plans and so that would then provide another connection to the community saying this is where we want our our renewable energy to be located and that could um that could be a avenue to get it there so um that largely finishes well i maybe not quite um how much more time it's 10 o'clock i mean we can go 10 more minutes okay so um we like our proposal that's what we think of best balances uh brahmaner's priorities as evidenced by the stakeholder engagement that we went through our proposal is supported by the kind of the procedural equity components of the environmental justice law that we went through to to develop it um i put in here just a reminder of what our actual proposal is um because it was a few weeks ago maybe i should have started with us um again it's 100 clean energy standard within that 30 new half of which is from um distributed generation connected to the vermont grid so like tier two it's you can think about it in terms of it's a 15 tier two by 2035 and a 30 overall new renewable tier um by 2035 so anywhere in new england the current 75 percent renewable tier one target and then um i should mention our additional study and reporting requirements to just to understand better impacts to the tnd system it's it's not only impacts here like which is written on the slide but it's also solutions so that study wouldn't just you know velko is going to talk again about on friday impacts to the transmission grid utilities should be talking about impacts to the distribution grid well we want to so those impacts i think are are fairly well-defined and the study really would take that you know due diligence on what those impacts are what otherwise would have happened anyway etc but then also look at solutions can curtailment help can load flexibility help can storage as part of load flexibility help and what does that cost and then the other study is for more granular reporting to better match that supply and demand over uh you know quarterly um so i have some more specific comments on h289 i could go into i that was an hour of pretty high level um and i'm just going to pause for questions so okay so um this one's still a little level i think h289 is over complicated um one there's provisions in there that i read 15 times and i still didn't understand actually what they were doing but um but at a higher level it creates not just one renewable energy standard but several different renewable energy standard there's one for gmp there's one for global foundries there's one for vipsel utilities or small munis there's one for hundred percent utilities it's you know and and the department's proposal has some carve outs too don't get me wrong but the the h289 is very uh choose your own adventure and i don't know how i'd explain to my regional counterparts that say hey we're at um 30 by 2035 what do you what is vermont's um renewable policy land us at i i don't know somewhere between 30 and 40 percent maybe i i am still looking into that but i actually don't know and so our the department's proposals a little simpler and i think there's a lot of value in that in not only administering the program the compliance and verification it is going to be a challenge for the department h289 but also um but also communicating it to vermonters and how vermonters kind of interact with their energy policy when we did our webinars a year ago you know it was basic like what's a renewable energy credit what is a megawatt hour what is a megawatt and what's in-state generation and how come we don't count kind of the dams on the connecticut river as vermont and you know questions like that if we are really going choose your own adventure route vermonters are going to be even more disengaged with their electric supply there are i have some specific concerns about the net metering language that you know as it's written um group net metering and i know this isn't the intent so i assume that this could be changed but it may still be allowed as written and it's kind of a question if a system could still have its credits allocated to multiple offsite meters distillation is written our current net metering paradigm relies on more than one meter and the the language in the bill is very specific to limiting group net metering to uh it it's very specific around metering and so there's a i think there's easier ways to get it all there just a quick question uh on your slide alternative which you're probably getting to i probably preempted you here but what is dg oh distributed generation sorry um should talk faster i guess um we do have some concern about letting utilities sell attributes for older net metering generation that a customer owns uh you know it that it's uh customers who have that older generation are expecting to own their net metering credits and if utilities can now sell those one they're not really well tracked um as far as i can tell and um and to you know it yes i think a utility could go and say um you know get an agreement from a customer to say we're now going to sell your rex um your renewable energy credits but i don't believe that just going ahead and doing that is appropriate when customers had a value proposition 10 years ago and thought they owns the attributes of the power um i appreciate the sentiment of it trying to reduce costs um but i i'm just not sure if there's a high value there um and in the alternative we could lower the distributed generation obligation by the amount of rex we think are out there and so um that would achieve the same purpose um there's a there's a couple of provisions at least that i don't think have been well discussed or vetted one is just an increase in the allowable rate increases for small utilities with uh without much process right now there's a provision where if our if had a full blown rate case recently you can um up your rates by two percent with really a light regulatory touch and the bill increases that to three percent presumably that's to accommodate rate impacts associated with the res but i um and i just um i actually don't have a strong opinion on it right now but i want to highlight it that it's it hasn't been really discussed and whether that is a a good thing or not um the bill also allows tier three over compliance without regard for cost so it it says uh you can there's no penalty for over uh over complying your tier three obligation and i think that could be okay as long as it's still cost effective investments for the utility it basically the language takes um the prudency determination away from the public utility commission and that uh that isn't appropriate we don't want to give utilities a blank check to and uh do what they want with rate to pay our money in the name of tier three climate i think the alternative compliance payment language is unclear what happens if you don't if you don't do uh if you don't actually comply with the requirements and it seems to me that it could be read to require the ace cp the alternative compliance payment to be set in an amount that ensure the requirements are met so that it says the puc set the acp in a way that ensures that uh projects are built that's that's how i read it whether that was the intent or not and so then the puc is required to say well projects can't be built for more than 10 cents a kilowatt hour more than avoided cost we have to set the acp at 11 cents or 12 cents and that i don't think that's the intent what i recommend is a really clear statement from the legislature of this is the amount above which we're not willing to pay um and so i there's for the regional tier there's a clear statement in there 40 per megawatt hour is the alternative compliance payment so utilities will not pay more than 40 a kilowatt hour more to develop new renewable energy or to purchase it regionally they will choose to pay the alternative compliance payment and it kind of sets a cap and i think that's a really important cost containment measure i recommend applying that 40 a megawatt hour to all new generation and in maintaining the current tier one for alternative compliance payment and um with that 40 a megawatt hour i think it was set to align with massachusetts i think that makes sense we are in a regional market and so even with our local tier tier two aligning that value with the regional market makes sense as well and um because solar projects will be developed um in in vermont they'll be developed in the region and um as our polling showed vermonters don't care if it's in state or not as long as they have access and so let's just set it at 40 a megawatt hour and uh have it be consistent and then um finally uh reporting should be streamlined um there's a provision in 2029 for a joint report report between the department and the public utility commission i think that should be one or the other not not both of us together it could be a public utility commission process that we provide input into or but we need one entity to have responsibility and then we have a we have another a whole bunch of reports reporting efficiencies we could propose um we have an annual energy report we have a renewable energy standard report we have a renewable energy standard biennial report we have a net metering report and they all have different provisions on what to report on that are not all current and so we could propose some improvements generally to those these ones are really minor um self-managed utility is referred to as a retail electricity provider they only have one customer i'm not sure if that's quite accurate i recommend just referring to them by the statutory provision that enables a self-managed utility i think that makes a lot more sense and then um there's a provision in hydro credits which um actually was not changed on page 23 substantially but it actually hydro was given an exemption earlier on um those two provisions may um may be in conflict now and may need to be aligned okay so i think that that's the end of my prepared slide sorry i went a little bit long here thank you for your testimony members we've entertained questions along the way was really helpful we're going to take a five minute break you're going to read to me in our hearing on h 289 and welcome green mountain power um just organ and just josh casting day morning hi so we're here at the Candace Morgan from Green Mountain Power and i'm josh casting a green mountain power um i think we uh are here today to uh walk through um you know parts of the framework that really impact green mountain power and what we think about that and then we're listening obviously to the morning testimony a little bit so josh is our leader of innovation and engineering and can kind of talk a little bit about um you know what we see on the grid some of the other innovative work that we're doing um and can also talk about any questions that folks might have related to some of the programs that we offer for um income qualified customers and other work that we're doing in that space as well so those are kind of three big things i think we were planning to talk about but also happy to answer any questions that folks have um we don't have specific slides but that was kind of the big the framework that we were planning to work within and we'll keep it short because i know you also have a morning full of witnesses as well um so on the first part of it as we outlined when i was here i guess it was a couple weeks ago now i can't remember um we are supportive of the framework and i think the draft that you all have reviewed in committee um version 1.2 largely reflects a lot of what was a part of that consideration i think there's some you know technical changes and other items that folks have shared and will continue to work through that and review as you all look to finalize your work in this space um but for green mountain power we are supportive of going to 100 renewable by 2030 which is what the bill outlines for us and then also includes the increase to tier two as defined in the bill by 2032 um and so that is the smaller scale distributed generation um largely if you're here in vermont connected to our grid part of the reason why we are comfortable with that recognizing of course that it is a pretty big increase from current law there are some provisions in the bill that change the date kind of goes back to 2010 so can include projects that have come online and that are being supported in our communities already which we think is an important thing to reflect the good work that vermonters have done to bring on renewable energy projects and so that is a key part for us it also includes some of our smaller scale low impact hydroelectric facilities which are another key resource for us in our fleet I think as I hit last time it's all about balance both in types of resources where they're located when they operate and generate as well and so that's another key component there and then also the elimination of the more expensive group net metering which I know has gotten a bit of attention in conversations that folks have been having in this space it does not mean that we are eliminating a pathway for community solar and we've got a lot of great programs in line that josh can talk about and work that we want to continue to do in this space as well it's just a really about that compensation structure for those types of projects that drive up costs for all of our customers and then the other part of the framework for us would be the what we had been calling tier 1a but I think as drafted be under the sub four of that section the larger newer renewables which people have largely referred to as like a larger regional tier focused on potentially offshore wind or onshore wind if it you know is in other locations anything that is capable of being delivered into the region and that would bring us to 20% for that by 2035 and there's some of those provisions in there that are also key for us in terms of recognizing an opportunity to reflect on whether the resources are available in a way that can work for customers from a cost perspective so there's a check-in as well to reflect you know seeing what's happening in the region and so for us those are that's a sort of big framework and like I said I think the version that you all have before your committee largely reflects that too and so that is yeah that's where we're at with that I'm happy to answer any questions on that part and then can turn to some of the other items from Josh cool thank you so I think maybe if we want to hit the some of the conversations around grid impacts and you know what we see in terms of how we manage all of that at GMP and then can turn to some of the other programs that are under way yeah so you know when we think about the grid impacts so GMP like all the utilities we do these these studies we look ahead at the system we have something called integrated resource plan and IRP where we look at exactly this which is heavy electrification heavy distributed generation different scenarios when it comes to building more distributed generation on on the system one of the one of the best things that can happen that supports that is electrification so as we decarbonize transportation heating a lot of times that means electrification reviews heat pumps it just so happens that while doing that and at the right time soaking up say solar most of the distributed generation then alleviates some of those concerns so as you look at and you hear more about impacts to the overall system the assumptions behind what happens electrification are key so that is a big piece of allowing to continue this growth in addition to that you know through the electrification being flexible with the load we call it flexible load but you know in EV for example you can change when you charge it or not eventually you'll be able to discharge it like you you know for lightning it's yeah we'll mention this morning the you know you can you can leverage those vehicles to do more than just charge and drive around we can actually use them as grid resources so that electrification as we decarbonize for all the other programs that we have is actually going to support the growth of the distributed generation at the same time we've been doing a lot around battery storage I know there's been a lot of discussion around storage that continues to be a resource there's you know we see it as one you know an incredible resiliency resource for customers helping customers ride through power outages during more and more severe weather and storms then number two leveraging it to do all of these different things including managing the grid it's an incredibly flexible tool that we use to soak up solar in the middle of the day hit the peak time which may be at seven or eight or nine p.m. at night cold February night discharging the storage so leveraging those resources as well there was there was mentioned to a curtailing and managing the the generation itself you can curtail resources I always look at that as kind of a last resort you know if we can produce the renewable energy and then soak it up and then use it later that's going to be preferred but that is that is an option so when we lay out these studies we look at you know 10 20 years out and all of these scenarios in terms of high penetration of distributed generation both what if it just goes anywhere and what if it's more optimized in terms of where it gets built and the electrification and you know everybody has an ep everybody's switching to a heat pump and heat pump systems and what does that look like on the grid and how do we manage that so those two things together are really key as we as we look forward I mean income just to quickly hit I know there's been a lot of if you don't mind representatives thank you what can you tell me about EVs not charging well when it's very very cold is the truth of that or it's fucked no god do you mean not yes they are so if you're talking about fast charging so you're driving an EV and you get to a fast DC fast charger depending on the temperature of the battery and things going on it may it won't be zero but it may not be as fast as you possibly could charge so a lot of times if a charger a fast charger is rated for 150 kilowatts and you just show up to it you haven't been driving for a little while which usually isn't the case but if you just get there the car is still cold it's going to charge at like 50% rate so it'll be slower until things warm up the batteries like to be kind of warm when they go to fast charge they plug in at home or on what's called a level two charger you're usually always going to get full power there so so cold batteries will start to charge a little slower but it's not zero and then it it warms up and you get full there are some issues that I mean I usually so the way that fast charging works is you've been driving for a while you get to the fast charge you plug in usually things are warm so you're getting full power so I call it a very minimal issue okay good thank you sorry good so income equal just to quickly hit you know gmp like like the other utilities in the run have done a lot of work and continue to focus on how to make sure one all of this is accessible to get to all of our customers and all their monitors to how it benefits all of our customers whether they're participating in the program or not and how we you know make sure as we decarbonize we do resiliency everybody can take part regardless of income or their ability to and so you know we've had a number of programs over the years from our straight up we have a eap energy assistance program very straightforward income qualified program where customers get a 25 percent discount on their electric bill period if they meet if they're at 185 percent of the federal poverty level that's just cross the board anybody can apply they meet that income threshold criteria that is funded through a fee that's been on the electric bill for decades there's we've had a salt we call it a solar eap similar similar approach allowing customers to connect and get that same credit connected to a solar project so no cash or capital outlay from the customer they simply have a connection to a solar project essentially and they get that same credit so it's a way to sort of take part in a solar project something we piloted this was on a multifamily home in berlin actually and same sort of thing there's a credit on the bill works out to about 25 percent and they've got the solar facility that's connected to that we've done a few other programs connecting solar and have a few coming out you've probably heard of acre affordable community renewable energy program that is funded through some funds that have come through the state of ramon the department of public service where similar to the eap folks that qualify for eap would essentially qualify for this and again they just get a discount on their electric bill tied to a solar project that's feeding that with no no cash or no need so all of our programs have been focused on providing that benefit directly to the customer so the income qualified customer and what has come up i think on the on the affordable housing side there's some scenarios now and not just now this i think some of the houses multi units have been built with like a central meter so usually you know each customer has a meter there's a program in place and it connects with that customer so that customer sees that benefit with the single meter multifamily we just need to you know rework so what we've been doing is developing new programs that essentially do the same thing we just need to make sure that you know connection happens that somehow that that benefits the customer which can be in through a number of different ways directly or indirectly but they would have a similar program using either type of acre scenario solar for all which is happening and other programs there so the proposal that we have includes eliminating group net metering so there's some concern about community solar right that you from folks can you talk about if this proposal passes nation group net metering can you talk about community solar in your territory Jordan what will be the case if it passes yeah so right now we have we have a tariff that was filing i think it's approved that got through so which is essential we call it solar sharing it's a community solar program using it can use different sources of funds but it allows you to to leverage economies of scale to when you build solar projects one of the things to me that's been almost a little limiting with group net metering is there's a size limit it's 500kw today and like anything if you can find a more ideal location and you can actually build a larger project you can do two things you can lower the cost of that system for everybody which just benefits the whole program and two you can get more customers on one project you just have more energy more projects so you can connect more customers more units so we have a call a shared solar program which is designed to take advantage of projects that take advantage of bonus investment tax credits there's there's something in inflation reduction act that provided folks fairly know that it provided additional tax incentive it's a competitive process so the developers still have to go and apply but as long as you show a connection to the income qualified folks as part of that process so we have a tariff now that's going to take advantage of that we have the acre program that is using dollars that are already available today and we're in the process of taking those and essentially mirroring them to be able to do something with a you know multi-family affordable housing that has the central meter situation going on there Senator Logan then Morris thank you share um I have a couple of questions one is more directed to what I would call the inability of low and moderate income home owners to take advantage of on-site solar installations and if you have given much thought to how to improve access to that for for home for low and moderate income homeowners owners or homeowners yeah okay yeah because what we you know there's been there's been this kind of why it was important to come up with these community solutions so there's obviously a lot of different scenarios physically where you live if you're surrounded with tree canopy that you know it's going to be challenging the condition of your roof there's a lot of things that that make it more difficult to do it physically at your location which is why having off-site and other programs you know obviously we're not a solar developer so I'm sure there's a whole host of other concerns and then there's the the renting side of the thing if can you get the landlord on board right but yeah that's another question I would also say you know some of the considerations in the solar for all application that the department put forward I think helps to focus some um dollars at those households as well so not just I know there's a big portion of it that's a acre 2.0 and then some other work related to affordable housing communities so there's also the individual homeowner options for additional funding for deploying solar panels on their roofs as well and we we were happy to sign a letter of support that work as well across the department because I think it's a helpful tool and I will be look forward to sort of seeing what the results are but I think it's a good option to help um happen to those households and deploy renewable energy for them as well yeah it seems really beneficial because uh then they do own the equipment and there is a you know 20-30 year benefit to them in terms of like a much larger reduction in their energy costs over the course of the life of the equipment which seems like an advantage that higher income households are getting right now that low and moderate income households um homeowners don't have access to it in quite the same way and seems like it would be a huge benefit to those households um so I'm curious about um learning more about how Solar Pearl can help address that yeah um the other question and this is maybe something that um that you've already been discussing internally regarding affordable housing um is and so I'm happy to talk about this separately um but one of the and we keep asking the same question of everybody at this point but um one of the things that we've learned from affordable houses is that at the development level um in order to offset the operating cost increase for electrification and solar solar installation um that would allow them to keep the per unit costs within the federal guidelines for affordability for those units um group net metering rates are what they've been using as part of the calculation to offset offset the increase in operating costs and um so we're hoping to find us to that as we help offset group net metering that helps make the develop like the individual development level maps work yeah and and I should hit two things there too because there's there's so something that happens in fact we're working with another multi-family um development in in the St. Albans area through our tier three program um especially on the affordable housing where we use the low income income qualified bucket there's a considerable amount of contribution that goes in right up front to make the system cost just much lower you know or provide a lot of benefit there when they're electrifying either doing heat pumps or geothermal or something there so start you know lowering that up front capital for the developer has to I assume have a you know positive benefit overall and then um two you're exactly right so my uh what I've heard was that um in natural gas territories they the affordable housing has said it's around 20 to 30 percent more on the and our EAP is 25 percent so that's you know it seems to me it'd be a pretty good match essentially you know net that out or pretty close so that is um our the solar EAP design does does exactly that puts that on that um central meter and it's good like yeah like I said up until now it's been really focused on the the ultimate customer the end user this is a little different in that okay it's it's the the owner operator of the building that has operating costs um and this will benefit that probably more so than what's happening when they had oil and propane at other sites obviously yeah um and so then it's just about developing a program that could then serve aside that the central metering the developer who is or the owner rather of that um central meter it has tenants who qualify exactly yeah exactly okay thank you representative morris thank you uh quick question uh you mentioned tariff in some of the installations or some of these programs tariff means there's somebody's paying something uh can you just explain what yeah definition sure yeah I mean so in in the regulated utility space anything we do that involves a customer requires a a tariff so different not quite the it's it's basically the regulatory process we go through so our rates all of our electric rates are tariff they get approved by the public utilities commission if we um our our energy assistance program our eap is a tariff um the one thing we can do prior to tariff is pilot we have in our regulation the ability of pilot which is a a limited term up to 18 months kind of test to see does this program work and then we move it to a full-blown tariff but it's basically the regulatory speak for just or approved to do it yeah and offer it I think this is pretty quick um the uh tariff that you said you you think was just approved so would this be news to the multifamily affordable housing groups like I'm just hoping you guys can connect and coordinate if this is relatively newly approved by the puc or um it's not it was approved a couple of little while ago I'll have to double check the dates um so it's not news in the sense that it has been offered I think the challenge and Josh hit it briefly was that um it presumes that that they're awarded some of the competitive ITC adder credits at the federal level and so that program has been pretty slow to roll out at the federal level and so I think it's just a matter of seeing what comes to Vermont and Vermont specific developers that remains a little bit influx but also outside of our control so the tariff is enabling that um if folks are successful in grabbing those credits we would have a pathway that kind of immediately allows them to use that in the same in that space but um it's TBD I think in terms of what the timeline is going to be at the federal level for that one yep if you have like a one pager then you can describe it for the multifamily housing folks um and others interested in this area yeah we can send that to the committee and also obviously the folks that were continuing to chat with about it all thank you we need we really need to be aware of the time representative Tory can you be very quick you mentioned flexible load and valuing that so when you were if you had a customer like that affordable housing build would there be flexible load investments that you would recommend and work with them on that they could then leverage the offset absolutely yeah so especially as you electrify the one that I was just mentioning in in St. Almond's is going to be doing geothermal and so we have a um another pilot not a tariff yet but a flexible load management pilot which essentially compensates you for flexing you think about it if I can ramp down the heating system during a key time but the building stays comfortable and then there's value to that and then we compensate so yes and yes we work with them on that yeah do you have any other things you wanted to cover no thank you thank you thank you all okay so we our next witness is joining us by zoom rebecca town from rebecca electric co-op morning i'm rebecca town from ceo of vermont electric co-op thanks for having me in this morning I will aim to be brief because I know you've already heard a lot about this bill and just generally talk about the fact that before you is a comprehensive package that has a complexity that reflects our desire to move to a fully renewable world while also respecting affordability and appreciating the unique aspects of VEC's power supply portfolio the draft 1.2 we are generally supportive as written and we'll be watching closely as it um as any changes get added just a quick note about VEC we are already 100 carbon free in our annual power supply and have made a commitment to be 100 renewable in 2030 this draft is consistent with that and also consistent with the fact that we are looking beyond that to a world where we are not just renewable on an annual basis but really considering a world that both for vermont and our region were renewable much closer to 24 7 and the types of investments both in state and regionally that will be required to make that happen we also really appreciate that this draft provides high level goals and a lot of flexibility for utilities to procure or build in a way that works for their geography grid aligns with current power supply portfolio which is unique for VEC and also for other utilities in vermont so that that flexibility around how those goals get achieved is pretty critical and we also support as gmp mentioned very consistent around some of the offsets in that are in there around recognizing existing renewables and offsets around net metering are an important part of that whole affordability piece of how we're how we're seeing this will play out also for VEC we're very reliant on hydro cobalt VEC has five different connections to HQ along the canadian border where we serve right now we're at 55 percent hydro cobalt and this does provide the ability for us to expand that while also recognizing we will still need to invest in new renewables both regionally and in state i did just specifically want to touch on one quick thing that came up this morning and then i'll just open it for questions one is tj mentioned this morning one of the pieces about net metering which is about the ability to use net metering attributes from existing pre-17 otherwise called net metering 1.0 pieces as part of tier two and his concern around selling that and i did i want to just note that the the way that it's written the intention is not that it would those would be available to sell it's rather that those would be available to count towards tier two requirements so it's really about making sure that we're allocating and understanding that we already have a lot of these in-state renewables and recognizing that those exist and are generating on our system in a renewable way on a daily basis and then one quick small change an error that we caught on page 33 which again is around that same piece around using net metering attributes towards tier two it references this section which is a net metering section when really it should reference the section around tier two which is which is the interplay between those two pieces so just a wording issue to flag those are the points i really wanted to hit this morning and then answer any questions you might have thank you for your testimony we have a couple representatives and civilian thank you madam chair good morning i had raised the fact that i i personally think as a cooperative or as someone who wants to support your members you should be a learning people who invested in these solar arrays that hey thank you for helping your cooperative thank you for helping us to keep rates low effective this state you know we're going to be acquiring your recs or some sort of bill insert and i i would really hope you'd be comfortable with providing that level of transparency to people who've invested in that i understand and i don't necessarily disagree with the request i just think you need to communicate with your customers yeah that would absolutely be the intention i think what we were trying to do with the wording is to avoid an administrative piece where we then had to both notify and get affirmation back and required on their required their action on that part um so but certainly that expectation fully supportive of notifying that that would be the case um and and particularly knowing that it's the smaller arrays that would have a notification process and the bigger ones again has written over 150 would have a much more interactive affirmation process yeah i'm literally talking to bill insert great thank you representative sabilia yes thanks rebecca for your testimony this morning uh one of the um proposals in this stakeholder in draft 1.2 is the elimination of group net metering and we've heard some concerns about community solar with that type of a proposal so can you talk about if we pass this bill what community solar will look like for vec customers sure so vec has and has for many years have a we have a community solar program it's about 25 percent ascribed so anyone who wants to participate in um sub uh sponsoring panels that are part of larger arrays i think you heard from gmp that those are more cost effective to build um then they're able to do that in a way that doesn't um provide them the need to host the panels themselves on their roofs those can be for um 10 years 20 years we have people who really appreciate participating in that um we also similar to gmp we are just about to roll out our acre program which is a low income um again same idea of using this community solar uh and ascribing those panels to low income households and i would also just say that our our big focus here is really about thinking and i know you heard from andrea cohen from vec last week when we think about our membership we know about half of them are on fixed incomes and we think about that all the time and so really the value of this bill is getting to everyone to 100 percent renewable and trying to do that as affordably as possible and understanding that um that provides renewability for everyone on our system and then those who have the ability or the capacity to uh move forward with solar and it's important to them or own or host a solar array then they're able to do that thank you all right thanks thank you for your testimony great thank you still we have lewis porter from washington luck good morning lewis porter general manager washington electric co-op uh thanks for having me i'm recognizing the length of your witness list here i'll try to be brief i'm testifying on draft 1.2 which the committee uh took took a first look at last week wash electric is generally supportive of this draft as as our colleagues at vermont electric co-op are uh and largely over the same reasons we're 100 renewable utility have been for a number of years now and uh support and appreciate they move towards 100 renewable portfolio for all the utilities so uh we're uh the most rural territory in the state uh we have enough power lines to stretch from here to the state of georgia and we have 13 people on our line crew to keep them up so you can imagine the challenges both in terms of costs and in terms of practical operations that that entails um we're also very highly residential uh have a very high penetration of net metering in our territory and are working hard to move towards uh a a utility of the future in which the utility grid acts bi-directionally instead of one directional as it was designed and there are a lot of challenges that we can talk about it when we have more time in doing that and particularly in doing that in a rural uh highly rugged and mountainous uh territory as we have but generally we're supportive of this bill there are a couple of things I wanted to highlight for the committee um today and I'll do do that as quickly as I can um most important from our perspective is the uh section of the top of page five uh dealing with washington electrics uh hq contract there is I guess I'd call it a quirk of uh of the circumstances of timing load growth the fact that we're 100 renewable that come together to cause uh a challenge I think an unintentional challenge in this bill which is that in 2010 2011 was the puc board order that authorized the hydro quibac contracts as we've talked about this year already washington electric did not need its portion of that contract but we still uh took that power and then sleeved it as they say sold it at the same price to vermont electric co-op the a provision in that allows us to take that power and use it for our members as load grows and we are seeing load growth for the first time in quite a while due to beneficial electrification and other and other factors because of the way um things are set up in this bill and the and the uh and the provisions of this bill we will not be subject to the same tier one a tier two obligations that the other utilities are but we are subject to a load growth obligation that we meet our load growth on a schedule that's in the bill through new renewables the challenge for us with this hq contract is we are obligated to take that power we're under contract we will want to take it because of the advantageous price that it gives our members but it will not qualify as meeting our load growth requirements because it's not a new renewal so what we're proposing here and what's in the bill draft right now and thank you to the people who've worked on this for including it there is a narrow provision that will allow two megawatts of power that we are currently under contract with hq to count towards our load growth obligation to count towards that new renewable obligation it's quite narrow it's quite limited but the financial impact for washing electric is quite significant to buy new renewable wrecks to match up to that power would cost about uh uh about uh uh four hundred and forty six thousand dollars a year we would be able to sell the hq wrecks that came with that power for about forty eight thousand leaving us uh would net to the bad of about three hundred ninety eight thousand a year that's significant for a small operation that's only one point three percent of the state's power load it represents about two percent on our rates um and so that's why we have asked to have this provision included in the draft as it is and it is included I think it's very narrow it's limited to that as far as I'm concerned and our intent was it's limited to our unique situation of timing and that two two megawatts of additional hq power that we have under contract are obligated to to take and that we have not yet reached the load growth this that would necessitate us using it so I know it's complicated and uh I apologize for that but we we've tried to draft this as narrowly and limited in in as limited a ways as possible so happy to have any questions about that or talk about that at all any questions or legislative council does don't check out the office of legislative council so can I follow up on what you're just talking about is the energy in that contract with Hydro Quebec is it do you know if it's hydroelectric power yes it is do you know if it's old hydroelectric power it would predate 2010 it would yeah okay is the contract you signed was does that contract go on forever I know it ends in I believe it's 2036 and whatever is that right ever I don't sign it sorry I'm just laughing because it's a long time yeah I believe it's 2036 it's something in that range I don't just thank you that was a lot more clarity on that okay yeah thank you um very briefly I wanted to address just two other things that we're working on in the bill that I think are are more making the wording fit what everybody's intent is so I don't think they're a significant issue but but making the work we're working with other parties in our in our framework agreement to make sure the language lines up with what the intent was and those issues are we own the right so hydroelectric dam we would like it to to count as the other hydroelectric dams small hydroelectric dams that are that are owned by utilities in the state would count towards our low growth obligation the the one the one thing there is that we are not yet low impact hydro certified but we expect to qualify as we're just about to complete a new FERC license that is quite you know fairly restrictive in terms of our operation and environmentally responsible and so we would expect to qualify we just want to make sure that that language the languages I guess I would say the language is a little bit unclear there and we've been working with uh v perk and renewable energy vermont on that language to make sure that it does qualify so I'm just flagging that I don't think there's anything that needs to be addressed by the committee but and I think it was the intent of everybody involved that it do qualify that does qualify the second is the renewable attribute provisions that you heard about from vermont electric co-op related to net metering we think that those should also qualify for the hundred percent renewable utilities including us and I think that was everybody's intent I don't think there's an issue there it's just not again a question in making the making sure the language is clear and we are fine with notifying and making sure our members who are net meters are aware of that and have the opportunity to win you claim any of that now no no no none none that would be claimable under this bill is now no what other you do I don't think we claim any net metering no frankly it's a testament to the success of the program I don't think uh I don't think it was anticipated that it was going to be as large a share of the renewables that came online as it was so I don't think it was contemplated that it would be as large a share of our portfolio as as it's become how much of yours is sort of net metering 1.0 versus 2.0 do you know I don't know the split between the two about just under 10 percent of our members are net meters so you know a significant share and if if nameplate capacity which of course being solar doesn't doesn't typically reach frequently but nameplate capacity is over 40 percent of our total load could be supplied through net meter so it's a very significant share of our of our load and of the of the load in our territory I'm not sure about the split between 1.0 and 2.0 in our territory okay it's clarification right thanks for your great thank you very much I appreciate it Ken Nolan morning Ken Nolan I'm general manager for my public power supply authority thank you for the opportunity this morning I too will try to be brief that points you to my testimony last week for specifics on how the bill interacts for the small utilities I have one slide in there that really pulled out exactly how the the red's proposal would operate from our standpoint today I'll just say that we were supportive of the framework that the working group members negotiated age 289 is essentially an embodiment of that so we are very supportive of the bill that's before you we recognize that there are a few things still being negotiated the affordable housing group net metering component is one that I think we still need to really work through but getting rid of the new group net metering as a general concept is pretty important to us in the bill both from an economic standpoint the cost for the the energy that's provided and also from a reliability resiliency standpoint net metering is really originally intended for customers to be able to reduce load at their site when you start building 500 kw generators out on farm fields and then having to move that power to the load you actually can create systems on the issues on the distribution system instead of improving the situation so we'd like to get back to a structure that is primarily focused on load reduction at the load point for net metering in particular as this bill will move us in that direction there were I understand there was one question on how Vermont public power would handle the future new renewables there was a section in the statute the bill proposed talking about carving out swanton from the rest of our load that is actually a result of swanton being 100 percent renewable and their their treatment in the bill is with the 100 percent renewable utilities which have their own path of how they're going to meet new load growth after 2035 where the rest of the VEPSA members would be required to meet 100 percent of their load growth after 2035 with new renewables swanton actually falls in that 100 percent utility section which requires 50 percent of the load growth to be met so we wanted to make that differentiation that was the intent of language there I also have three I think are minor corrections that we would ask you to consider one is literally changing a number from 6 000 customers to 7 000 customers it's on page 16 line six of the bill there was a provision that small utilities can petition the public utility commission for an exemption if certain thing certain purchases can't be met when the bill original statute was put in place that 6 000 customer limit worked fine for small utilities we now have one member that is approaching that six thousand dollar limit that's six other member limit and so we want to make sure that all of the VEPSA utilities are treated the same way so by just changing that one number from six thousand to seven thousand allows us to be continue to treat them as a group and not be worried about one utility kind of breaking the threshold the second item that we're looking at is the definition of how you become a 100 percent utility originally in the statute there was a test that said you needed to be 100 percent renewable by 2015 that was based on retail sales when we went through the bill that's before you in 289 all of the tests get turned to load so instead of saying it's retail sales the requirements are now based on the load that the utility serves so it brings into it any usage that's unbilled any losses things of that nature well in that search and replace the section that originally did a test for the 100 percent reach utilities also got changed to load so now it states in this proposal that you had to be 100 percent of your load in 2015 and that actually creates some issues so if we could put that one one instance one reference back to retail sales it would be helpful what page is that on T. 21 line 18 and lastly I'd like to address the comment that T.J. or made this morning around the hydro and the conflict in the definitions of hydroelectric qualifying for distributed generation the original statue allowed had a provision in it for small hydro that was newly built to qualify as distributed generation in order to meet that definition the new hydro had to be less than five megawatts connected to a utilities distribution system and then either have one of two things be why high qualified low-income hydro institute qualified meaning you were low impact or you had to have a water quality certificate from ANR that was issued after 1987 that's been in statute since the original passage of the res what we're proposing in 289 is to pull out the utility owned generation the hydro generation and treat that differently and say the investments that the utilities have made for some of them over a hundred years and where they've built small hydro plants that are connected inside their communities those will qualify as distributed generation regardless of any other requirements so there was a definition change made in definition of distributed generation to say if you're a small hydro plant owned by an municipality or you're a hydro plant that's owned by another retail electric provider and you're high qualified you meet one of those two things then you automatically qualify as distributed generation the hydro language that was originally in the statute remains in place so now there's a conflict because you've got a group of hydro plants that are owned by utilities that qualify in one place and you've got this section referring to any new hydro being built down below our proposed solution is just on sorry that's right line line page 23 line 18 to insert in that a clause that says that are not owned by a retail electric provider so it would separate out the two if you're hydro plant it clearly say if you're hydro plant owned by a retail electric provider then you would fall under the definition inside distributed generation section if you're not owned by an electric provider then you would fall down and have to meet fly higher FERC license section and the universe of those that do not meet by high the universe of non utility owned that don't meet by high well the ones that you'd be asking us to bring in that wouldn't be lie high um i'm not sure i'm sorry i think that the assets don't enter into it i think it's utility owned that are not high is the point yeah there are there are only a few utility owned lie high qualify that i'm aware of um and would you know what keeps one from not qualifying lie high typically wants to have a newly issued uh FERC license the rightsville that the wek was talking about earlier once you get a new license then you can qualify for lie high most of the utility like for us barton hydro is lie high qualified um but the the ones in morrisville uh annesburg swanton um that are going through the FERC relicensing right now they're they're not able to get a lie high certification until they actually finish that FERC process so it typically requires a new FERC license and uh uh proving to the association it's an independent auditing company basically um that you have fish passage and your uh run a river things of that nature so i think um most of them if they actually took the effort to go through and apply they could get that certification once they have the new FERC license issued but most of them do not right now because the licenses in many cases were issued 30 or 40 years ago so they're going through that process right now so how long does the FERC license last typically very varies by hydro plant um but they normally are at least 30 years kind of seventh are uh are there any it sounds as though um good morning um it sounds as though all of the facilities you're talking about are currently going through the process but is that accurate or are there some that by changing this language um are not currently going through lie high process or you know the FERC relicensing um there there are some that would not hard hard to a generator for example um does not have a FERC license it's grandfather what this change was really intended to recognize is most of these communities so the VEPSA members are all municipalities those municipalities in many cases started their electric company around a hydro plant so they've built a hydro plant that provided the street lighting and then ultimately grew into an overall utility they've maintained these plants or in some cases a hundred hundred and ten years and what they're finding is as they're coming into compliance with the new require new federal and state requirements it's getting harder and harder to economically operate the plants because there's higher water quality standards there's reduction in the output uh what we're seeing for enosburg lindenville and morrisville who have just recently gone through the process their production was dropped by about 25 percent in order to meet the latest water quality standards so this change would actually allow them to count the hydro generation as a higher value renewability credit a wreck which brings them some economic economic value so that they could put the investments in to maintain the hydro plants and still meet the new water quality standard you go ahead i guess i'm just concerned um about and i understand the balancing of if you're reducing your flow you're not creating as much and so how can you balance that with a higher value wreck i am concerned about the locations that might not be going through the lihi and by putting this language in you know um what that means for right now we're talking about an energy bill but what that means for our other committee responsibility which is environment yeah i mean the all of the hydro plants that require a FERC license which is the vast majority need to go through the water quality standards and that they need to comply with the latest regulations there are a couple of hydro plants that because of their timing of when they were built and the criteria that went place they have not required a FERC license or a 401 certification from ANR that to me is a separate issue from whether they're economically able to be viable and maintain the plant it may be a separate environmental conversation as to whether those should be pulled in and have some further permitting done but right now the focus that i have on this is trying to make sure that economically we can comply with the tier two changes that are going on and keep those local hydro plants operate and you think there are a couple that are grandfathered they the only one in the VEPSA membership that i'm aware of is the hardwicks generator which actually was pretty much destroyed by the recent flooding and they're going through the process of rebuilding right now so where do we um can you give us a list of the dams that are in the different categories here in your which ones have lihi which ones are FERC licensed and then which ones aren't i don't have that with me but i can certainly give the committee that that would be really helpful if we consider this request all right representative Clifford thank you madam chair um thank you for your presentation i just in your january 11 testimony um under conclusions it said the working group report accurately captures the significant conversations but lacks many of the nuances needed for effective legislation does this just today's testimony help with that yeah so i think the the working group report was very focused on putting guardrails it was a lot of what we did in the in the committee was take take surveys right yes or no the various questions so it gave a very broad guidelines for what should happen i think since that report was issued the working group members have continued to talk and try to come to some sort of compromise which is is a lot of that is in 289 the bill before you now and i think we've been able to address a lot of those nuances that didn't really get pulled out in the committee report um in trying to put the statutory language together that you're seeing in the bill thank you thank you for your testimony it's brian evans and we have seven witnesses left and uh running short on time so i just remind you that thank you again i'm brian evans mentioned i'm the general manager for the village of hide park um i wanted to do a couple of things here today first of all i think that based upon my previous testimony it may have been perceived that i am not in favor of the renewable energy bill that is not the case i want to be very clear that i recognize and support the value of what this bill will do where i'm at is that based upon the historic bill that got us to the point of where we are today i'm fine with the provisions of 2035 and beyond it is the point between excuse me between now and 2035 that is raising a concern for for me in the village of hide park and and to that end i wanted to try to provide a little bit more detail on the previous testimony where based upon our calculations we've estimated that between 2030 and 2034 in that five-year period the incremental cost exposure to the village of hide park customers is going to be about five hundred and thirty seven thousand dollars that translates into six dollars and 83 cents per customer per month now seemingly that doesn't seem like a lot but when you contrast that against the previous testimony that indicated that the highest amount at another unit the average utilities were going to pay which was four dollars and seventy cents per customer per month our cost is going to be 43 percent or 45 percent higher than all the others in the state of vermont okay that that is that is a cost and recognizing that you know that the poverty rate in hide park is at about 11 percent under when we take a look at the environmental justice act requirements that we're now having to take a look at as we move forward with other regulation when we take a look at that that's going to put even a more disproportionate burden on the people that are low income and we don't we don't have the mechanisms within hide park to create offsets to that so when we take a look at the the previous decision which enabled the portfolio that we put in place which is over 90 percent clean which is based upon a combination of the legislative directive plus what the board of trustees did in adding to the further resources the only resources that we have that are beyond renewable or clean are those that come from our interchange with iso new england where iso new england system power backfills in where we have needs that being a combination of all the iso resources that's the only part that we have not established as being either clean or renewal so i just wanted to kind of illustrate the fact that hide park has aggressively put forward a portfolio that is a recognition of the legislative policies plus the local policies that were established over the years now one of the things that i think in the bill you've highlighted is a recognizing a difference between the categorization of utilities and there are many mechanisms that could be done one that i wanted to share with you and i provided my testimony today is a mechanism that the federal agencies the department of energy the energy information administration and the federal energy regulatory commission use as a threshold to differentiate between large utilities and smaller utilities a retail sales value of four million kilowatt hours that is a threshold that allows for the feds and to allow for differentiation and performance requirements as you know in various federal requirements so i just i've offered a suggestion for how that could be built into the bill going forward recognizing the differences but you know we're open to anything that recognizes a deferral of the current of the current 289 proposal until 2035 we're happy to plan for and build for the period beyond that which is after our retirement the retirements of our existing portfolios go away we're happy to plan for the new requirements as of 2035 with that that concludes my testimony thank you for your testimony representative tory very quick question just my own ignorance what is how does your current electric rate compare with other utilities are you i've been asking that question myself um and i'm trying i'm trying my our retail rate i believe right now is probably mid-ground to the other uh utilities but we are also looking at a number escalating factors that are going to be hitting our utility in the next five years in order to keep up with some of the other activities that the other utilities are doing for for example we do not have am i metering we are the only utility in the state of vermont that does not have am i metering we've forecasted right now that that cost could be upwards of three quarters of a million dollars for hide park to put in am i metering that and that will have to be recovered somewhere so these are some of the things that we're looking at members have further questions just a simplest form are you simply really asking to the exempt until 35 yes bottom line yes um thank you very much for your time okay michael azoreshuk michael azoreshuk so electric department hello i uh submitted a filing that has a series of fact sheets just for your information about our system and what we're doing the uh two key points just to bring out on the first fact sheet is just our current r.e.s portfolio so it's all out there for folks to see it and understand it it also shows our resource mix and it shows the value of cbook to our carbon free portfolio now 18 percent so again i mentioned before large hydro nuclear we see it as a valuable resource and a bridge resource to the future grid laying it out there for folks to see and then some quick bullet points on our micro hydro project that's what we're thinking for the hydro it's a major series of questions for the committee don't think it's worth going through all the questions saving folks time but we'll jump down to four which is on page 18 lines 18 to 21 my reading of that is it narrows the the focus of munis to just vexa munis so if i'm correcting that reading i just ask to apply to all municipal utilities not just to the vexa members which height park still electorate members of vexa number five which is what ken was getting to about the lihi certification for hydros unbeknownst to ken's testimony i put in what i think is a a valuable change which is essentially just recognizing micro hydro so our facility is about 168 kilowatt i went through the lihi website took a quick look at it and for me if you were to exempt muni owned hydros 500 kilowatts or less from the lihi certification that would be a benefit to stow benefit to small munis i think we'd see an encouragement for other munis to repower dams we know that's a much broader more complicated question i personally see value in repowering certain dams removing other dams where it makes sense i think this would bring some clarity to that and potentially move forward either dam removal or dam repowering i think ken's proposal is actually cleaner and easier just allow munis to own hydros to be exempt from lihi certification you know i'm not going to pretend to be an expert in lihi certification but we will go through the first process which we're doing now so to my mind there is no additional benefit to stow's micro hydro for lihi certification except additional staff time my staff time expense the utility and more things for me to keep track of so i can pause there or just suggest that i think we should consider smaller hydros especially that a muni own because i think there's a value to the grid a value to what municipalities are doing as you see with our program it's going to be an on-bill credit for low-income customers so to me that's the value of the program again i've got to go through FERC licensing that's all the folks a and our core the whole whole group there so i do not personally see an additional value to our hydro for an additional certification from from lihi other than that um just here in ken's testimony i agree with the 7 000 meters still we're pretty far from that number but i'm always here to advocate on behalf of munis and i do think that's helpful to his membership so we should allow for that beyond that that's all i have are any questions i'm happy to take them thank you for your testimony for coming in today um how many do you have to use is it just the one that you're trying to get online the hydro or are there others there there was a there was a potential one potential in so and then in another hydro in a different service territory which we want to owner operate that we've been asked to provide feedback on but there is an additional dam in sto's territory that we've been asked to look at in terms of repowering right now we have no plans to do that in quite honestly i don't know that i could manage two hydros but the point is is that there's a potential here to move the needle on dam removal or repowering dams which i think will will flow beyond just simply energy and hydro i think what i try to do is think of decision points right forcing people having people make decisions and i think there's ways we can move the needle on that conversation while benefiting sto electrics facility right so but to be clear you have no hydro right now that you're drawing about one that's in the pipeline and right another one that you've been asked to comment on or just look at which is within our territory members have questions okay thank you right jeffrey cram from global foundries morning thank you jeffrey cram local founders i'm going to provide a quick slide to share to guide our testimony here this and the slide i'll provide so a very similar slide last time that we were here we spent a lot of time last time talking about who global foundries was why we were here and didn't spend a whole lot of time talking about the the alignment of global foundries goals and and the renewable energy standard i want to spend a little bit more time on this and and go through some of the some of the places that there's really good alignment between between global foundries and and the standard as a reminder very quickly jeff power is the utility for global foundries it's a single customer utility and we're in the process of developing on-site solar on our campus that we can utilize in our manufacturing process we have a significant transmission distribution system on our campus that we manage with our with our own electricians and electrical engineers and then all the all of the solar locations that we're talking about today are basically on already developed industrial campus primarily in the industry of campus so to start with we're committed to 100% renewable by 2030 and on each of these if you have questions please interrupt as we go along there's enough uniqueness and in the discussion points on each one of them the questions in the process may be of value we are we're looking to for the tier two renewables we're looking to hit 20 percent by 2035 and that's a combination of developing on-site on our on our campus messics in williston and then purchase of of in-state renewables as well 2035 gives us enough time to develop some of these projects as we're going through the process now we understand that better than before is the amount of time that takes to bring new projects online and this gives us time to to develop those projects the uniqueness of of our of our campus load is whatever we can put on our campus we can use at the time of generation we can't fit enough solar on our campus to actually have to expect renewables we can always use that that at that time of generation so it's a it's a real asset for that that area if we fully build out our campus if we can use every spot that we have that's really develop a developable we're still only going to cover about 89 percent of our of our load which is far shorter than 20 percent requirement so we'll have to in order to meet that 20 percent requirement partner purchase get enter into other contracts to allow us to meet that that threshold so it really will become for us a procurement conversation at that point and the other the other thing we want to just add clarity is there's as kind of mentioned there's really good benefits for citing solar right where we're going to use it but depending on how you look at the the various locations that we would cite it you could you could total them up and say that they would be in excess of five megawatts total and and may not fit with the tier two definition today and so we're looking through this language to to make sure that because we have all these other good things going with the the sighting of the solar that we can whatever we can build we can apply to the tier two tier two threshold stop there for set good the next was a discussion on the tier three and part of having local boundaries at the table is we're looking at this with a little different lens as a manufacturer than solely as a utility with manufacturing we have a number of we have greenhouse gas emissions as part of our manufacturing process and we're looking for an ability to to append the tier three to allow us to meet the tier three requirements through reduction manufacturing emissions rather than just additional renewables or rather than just fossil fuel conversions we step back and look at the overall goals of reducing emissions this is a really effective opportunity for for gf to reduce emissions for gf and for the state and very in a in a more efficient manner for global finance you have other reasons that you i mean are there other obligations that you have we we passed an hfc bill in this committee that's not too long ago don't you have other reasons and and motivations for reducing those emissions so we're so global so we have globally we're we're working on manufacturing emissions across our company and so there there's motivations for us to do this as a as part of our i would say our esg program where we're trying to reduce reduce emissions what is esg environmental social governance all right so it's our corporate policy on safety emissions climate energy reductions so we have we have reasons that we're trying to voluntarily move these along we also have the most of our sites we have we have permit limits of air permit limits as well these would go above and beyond in the air permit limits that we have um stars these reductions it's not it's not to maintain compliance with an existing set of permit conditions but it's it's a it's a to go above and beyond those conditions but um are there other statutory obligations that you have maybe ellen has some thoughts well i think they actually i think manufacturing hfcs are not included in this the base down under our statute i'm double checking now but i think the specific horns they use are not included yeah i wasn't aware of others what's up i wasn't aware of other requirements so thank you i know okay um and then the the last would be the additional new regional renewables the tier four again global founders is looking at this is because another 10 by 2035 um and that we as i mentioned in the in the tier two discussion once we build out the the relatively smalls campus or service territory we have we're ultimately a procurer of new renewables rather than a generator so the request that we had here is just to allow us to to supplement tier two or tier four through any combination of of additional purchases what it means to have a state to help to meet the overall what was the testimony for today thanks to members of course to members have questions i feel like we have a cool question do you have one all right um do you so there's an existing statute in the bill that's referenced with just the greenhouse gas reduction credits which we were just talking about a little bit and i'm sorry if i missed it um did you mention how is that are you using that statute currently and how to how much so we've not we've not used it to that okay all right thanks for your testimony okay thank you just to know Jeff again there's just a confirmation okay so the power that you're generating on site it's 100 contained on site so the power that we are going to be from the from the solar we would are to be interconnected into green mountain powers distribution system shortly it's a very short route from the remount power's lines to velco back back to us the first 10 megawatts does not directly connect into the global found respectful system but it is it it will be far less than we're using at the time it's generating answer your question yes thank you so i'm sorry thank you thank you thank you well driscoll manager and before i start i don't know if any of the other witnesses have to me have time but constraints because it's obviously pretty easy for me to come back if you want to get a few so well thank you for the record William Driscoll with associate industries of Vermont glad to have the opportunity to come back um i think our general take on the current draft before you is very similar to our feelings about the framework that came out of the working group it's certainly an improvement over some earlier ideas and past proposals we feel like that it would be improved a bit further on some on some basic categories i think very similar to the department's discussion earlier today we would support having rather than a renewable only have renewable plus clean to be able to maintain more options on the table both now and in the future i know a lot of discussion about this has been around nuclear and specifically seabrook and i don't think it's just it's not just about that although it's worth noting that nuclear is pretty widely recognized as part of the as part of a climate strategy around the world and also there's support for that in vermont as the department indicated with their public outreach i think it's worth noting that for all intents and purposes if folks have concerns about anything regarding seabrook um i don't think anything that vermont does one way or the other is going to change the future operation and other issues with seabrook as a as a plant um other issue though i think it's good for legislation to be future-proofed as much as possible um you know we don't know where things are going to go with either you know next generation nuclear or there's hydrogen or there may be other clean technologies that may not qualify as renewable under the bill and it would be good to have the ability to efficiently pursue those in terms of contracts and development without having to come back and change something in the legislature in order to move forward with that um and lastly although to be fair this was discussed in the working group and and pretty much everybody in the working group uh indicated that they didn't want to go down this route we certainly got a lot of testimony input and there are folks out there who would very much like to see um hydrocobac or a certain biomass a certain large hydro not considered as renewable even though they are renewable and i think if we put that need to be renewable aside and focus more on clean uh plus renewable plus clean i can make it can avoid a lot of fights over that uh or at least perhaps minimize some fights over that going forward which could be valuable um beyond that in terms of sort of these subcategories or restrictions on um you know mandating uh certain levels of new or mandating certain levels of distributed uh energy i think as i've sort of said before um you look at distributed generation that has advantages which are you know very site specific and utility specific um and i think left to their own devices utilities will certainly seek to develop the distributed generation that takes it takes advantages of those um as best fit for the need um and so to have mandates on top of that that could uh lead them to maybe do some projects which are simply not necessary um and i don't see really the point of doing that to the extent that that raises cost concerns um without making any technical real advancement in terms of climate goals um and similarly with new renewable uh i think everybody recognizes that uh even with a renewable plus clean there's going to be a lot of new renewables uh developed because that's just going to be needed to meet uh both our goals for uh load growth but also cycling out um the non-renewable elements that are currently in our portfolio it currently in our portfolio um so uh not having increased mandates on new renewables doesn't mean that there won't be no new renewable what it would avoid is a couple of things one developing new renewable if if there are alternatives on the table uh is a more expensive path inherently but also the more you restrict the the the options of utilities um the more you you take away left in terms of negotiating uh contract prices and so um the more you mandate new renewables beyond what the utilities would naturally pursue on their own um you just raise those uh risks of higher of higher costs without again really furthering um overall climate goals as sort of on that point i just want to sort of flag this could be a longer discussion but i do um have concerns with or take issue with uh incorporating into this legislation the concept of the source of societal benefits or the um what's called the sort of the additive effect of pushing uh new renewable as opposed to um existing or clean alternatives as necessary to reduce the overall region's uh emissions um there's a couple of problems with that again it's not that new renewables will not be built it's a question as to whether we build more than we need um uh that sometimes folks seem to want to have it both ways vermont is either too far behind or or or we need to lead the way um there's an assumption and under the argument that the other states in new england are not going to go down a similar path as we so if we don't build the new renewables beyond what we need they're not going to get built and i just don't think that that's a believable argument uh on practical terms i think we are going to build the new renewables that we need to have whether it's 100 renewable or 100 renewable plus clean we're going to build the new generation we need and i think the other states are going to be moving in that direction too um whether they're currently ahead of us or we'll catch up with us i don't think it's realistic to believe that we're the only ones that are going to take the burden to build new renewables um so why should we force the utilities to contract for new renewables that they may not need simply to take that take that uh uh step i think that raises cost concerns it raises the possibility of stranding some of the existing renewable contracts that they have um it's just i i don't see it as a as a warranted uh public policy um to go down that route in terms of cost impacts and you're not really making i don't think arguably a change on climate in the end in the long run um i think a few to address some of the discussion earlier today about again obviously i'm talking about costs a lot um uh i think there is concerns on the rate front i think the department raised quite a few uh that are worth considering we don't in terms of the additional cost of transmission i think it would be good to know more about how reliable our assumptions are about the cost of storage um in terms of how that technology is both developed and implemented and and also i don't know how much the modeling captures the competitive impact that that wasn't noted before about you know the more you restrict the alternatives and leverage of utilities uh the more risk there is that we end up with more expensive power that we need i think the sort of final two points on this front uh as i said before we are already in a high stress environment because we are a high cost state for electricity when you especially want to look at the lower 48 states that manufacturing and similar businesses can eat in so that's an existing pressure so to unnecessarily choose a more expensive path whether it's even if it's a couple of percentage points um i don't see the just i think it's concerning if we would go down that road um you know we saw the news uh with sound view just the other day about how even now electric costs are a serious drain on and concern for manufacturers and other companies in this state and you have to also remember you know businesses make longer long-range plans they look several years down the road and make the decisions on where they're going to go if we have to simplify two paths toward a clean portfolio and one is more expensive than the other and we choose the more expensive path that's not a positive signal that you're sending to businesses in terms of policy is going to develop in the state and how their costs that they're trying to deal with now are going to evolve over time so again i think i think we can have a clean portfolio and we should try to do it in the most flexible and affordable way possible with regard to net metering rex and some other issues like that i think i need to we need to sort of consider that more in sort of talk with some of the some of the stakeholders about whether we have any specific recommendations on that i think generally we are supportive of a lot of the tweaks that the utilities and global founders have have asked you for uh voting forward right thanks for your testimony yeah darin springer is joining us by zoom hi good morning um it's going to be with you um i'll be very brief i know you're you're up against the clock here um darin springer general manager with burlington electric department we shared during the last time i visited the committee the four priorities we had within the legislation continuing to recognize 100% renewable utilities for early action with continued exemption from certain requirements aligning the need for new renewable energy for those utilities with increased load growth to ensure affordability ensuring we can count our existing renewables towards vermont's targets even as we grow new renewables and providing support for ut