The Public Utility Commission has proposed changes to the net metering rule that arbitrarily limits the ability of local communities to site net metering projects and harms early adopters of solar power. These proposed changes will unnecessarily slow the pace of renewable deployment and hinder the fight against climate change.
Arbitrary Restrictions on Tree Clearing Limit Local Input
The Public Utility Commission proposes to arbitrarily limit the ability of local and regional planning entities to support renewable generation within their own jurisdictions. It would strip these entities of the ability to assess the value of a site for net metering if the use of the site would require more than 3 acres of tree clearing, regardless of the habitat value of the site. The Commission’s proposal for a 3-acre threshold for “significant forest clearing” does not align with meaningful climate or ecological impacts.
Forests and Carbon Sequestration:
Forests play an important role in sequestering and storing carbon. However, given the heavy dependence of the ISO-New England grid on fossil fuels, and Vermont’s interconnection with the market, solar is substantially more effective at reducing atmospheric CO2 concentration than forests. A 2021 analysis by Synapse Energy Economics has calculated that converting an acre of forest in New England to a solar array will result in 470 tons of CO2 savings each year. Other assessments point in the same direction. REV is unaware of any scientifically grounded assessment that contests the fact that solar development is more beneficial than maintaining tree cover from a carbon perspective.
Forests and Habitat Value:
The habitat quality of a specific site and the importance of preserving the tree cover on a site depends on many factors such as species diversity, the proliferation of invasive species, and proximity to existing roads and powerlines none of which are addressed by the proposed rule. A more ecologically sensible approach would limit forest clearing in locations with the highest habitat and habitat connectivity value.
Limits on System Expansion Hurt Early Adopters
The Commission also proposes to make system expansions significantly more expensive by reducing the rates that are paid to the existing system if it is expanded by more than 10 kW or, if the system is larger than 200 kW, 5%. The Commission rejected a Public Service Department proposal to compensate the existing system at the existing rate and the new system at the new rates in favor of a policy that will make system expansions significantly more expensive and that is inconsistent with the state’s climate goals and the intent of the net-metering program to support self-generation.
At the residential level, Vermonters who move to electric vehicles and heat pumps, as encouraged by the state’s climate policies, could see their electricity usage more than triple. This means that a household with what is currently an average-sized net-metering system, approximately 7 kW, would need to increase its system size by 14 kW to maintain the same level of self-generation but such an expansion could reduce the value of the value of the electricity generated by several thousand dollars (the exact amount would depend on when the original system was installed) making it less practical to self-generate.
In many instances, the disincentive to expand larger, group net-metered systems would be even more severe as the pre-existing system would represent a larger percentage of the total capacity of the expanded system so the revenue lost would be proportionally higher. Given the current focus on reducing the sites that are eligible for preferred site status, the Commission should be doing everything in its power to maximize the utilization of existing preferred sites. Expanded systems will have a smaller total footprint than would be required to create a separate system with the same capacity as the system expansion.
 Synapse Energy Economics (2021). “Carbon Dioxide Emissions Tradeoffs: Forests or Solar Panels?” https://www.synapse-energy.com/carbon-dioxide-emissions-tradeoffs-forests-or-solar-panels
 Eisenson, Matthew (2022) “Solar Panels Reduce CO2 Emissions More per Acre than Trees” State of the Planet: News from the Columbia Climate School.