Stuart Ormsbee
Vice President,
Power Supply Strategies
Colonial Power Group
Guest Contributor
Freedom Energy’s strategic partnership with Colonial Power Group (CPG) enables us to offer cities, towns, counties, municipalities, and other qualifying governmental entities value when it comes to choosing their Community Choice Aggregation (CCA) electricity provider.
I am so sick of talking about helping low-income consumers. In Massachusetts, the concept of Environmental Justice has been elevated to organize thoughts and resources to advance equitable distribution of benefits created from energy markets. Governor Healey is making Environmental Justice a priority within the Executive Office of Energy and Environmental Affairs (EEA), sharing top billing with offshore wind, transmission upgrades, and stretch building codes. Legit.
Placing Environmental Justice (EJ) at par with other energy priorities that all promise to create benefits in the future suggests that the concepts of EJ will require additional analysis and examination before any real outcomes can be realized. I acknowledge that EJ comes to the fore most frequently in the context of infrastructure development and the risk of burdening certain segments over others: reasonable sharing of benefits but with inequitable cost burden. These can be complex cases. The converse situation is also applicable in context of EJ principles, where cost burdens are being reasonably shared, but where resulting benefits are not. We should not resign ourselves to thinking that EJ principles only involve long-range issues. In fact, there are opportunities available now, shovel-ready, to begin delivering on the promises of EJ. In some cases, the only thing lacking is a requisite signature.
The Solar Massachusetts Renewable Target Program (SMART) commenced in late 2018. Soon after the program was launched the Department of Energy Resources (DOER) identified that SMART benefits were not being shared equally across customer groups. Important to understand, all ratepayers were paying for the program through a line-item charge on their electric bills, but low-income households were barely participating in the benefits accruing from SMART. In response, the DOER created a novel option for a municipal community choice aggregation (CCA) program to create a low-income solar component within its own aggregation program. Smartly, the DOER did not attempt to script or dictate an approach but rather invited CCA’s to create their own designs and demonstrate compliance with SMART rules. The DOER’s proposal was scrutinized in a high-profile public process by a large and diverse set of stakeholders, none of whom raised serious objections.
As a leading energy consultant working with CCA programs, Colonial Power Group (CPG) was excited by the challenge. After months of whiteboarding and engagement with the solar industry, CPG created a program deemed acceptable by the DOER. CPG then facilitated the execution of several solar contracts between solar developers and CCAs, including a 100MW contract with the City of Boston in late 2020. Once fully constructed, the solar facilities committed to Boston were expected to deliver over $50 million in discounted electric rates to over 20,000 low-income consumers over 20 years. Excited by its accomplishment, the City issued a press release after reaching out for a comment from then Secretary of the EEA congratulating the City on its creative vision. Quite unexpectedly, the Department of Public Utilities (DPU), an agency within the EEA, issued a cease-and-desist letter in December 2020, preventing the City from moving forward. Here we are almost two and a half years later and the DPU still has not acted.
Granted, there has been some activity. The low-income solar solution received a second regulatory review (following the DOER’s multi-year process) after the DPU inserted the issue into a utility tariff review docket. Once again, it received no objections from stakeholders. On the contrary, the Attorney General’s Office (AGO) weighed in with firm and authoritative support for the DOER’s design. The AGO confirmed that it was consistent with Massachusetts General Laws “for a municipality…to facilitate a community shared solar program through a municipal aggregation.” The AGO attested that the program design “would further the goals of universal access, reliability, and equitable treatment of all classes of customers by ensuring that low-income customers are better able to participate in and benefit from the SMART Program.”
Perhaps nothing lost? While CCA programs remained benched by the DPU, did low-income consumers somehow find their way to the SMART program by other means? No. Filings made by the electric distribution companies in March 2023 show that low-income customer participation in SMART remains well below 5%. For context, the AGO during the DOER’s SMART review advocated for a 20% set aside for low-income consumers.
This is not just low hanging fruit. This is a neatly arranged bowl of perfectly ripe strawberries resting on the opposite side of the desk. The process was completed long ago, twice. There is nothing left to do other than for DPU to finally say, “approved” to let us put good policy into action. We want to help low-income consumers instead of just discussing it.
For more information or to provide support for this approval, please contact us at solutions@felpower.com.
Published: June 20, 2023
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