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  • Member Spotlight: Primmer, Piper, Eggleston, & Cramer

    New Hampshire is privileged to host the headquarters of several top law firms, and Clean Energy NH is even more privileged to have the very best of the best as members, including the law firm of Primmer, Piper, Eggleston, and Cramer (PPE&C). With offices in Manchester, Portsmouth, and Littleton as well as several offices in Vermont and Washington D.C., PPE&C’s team of attorneys is well-suited to serve clients in the renewable energy industry and beyond. PPE&C is a full-service law firm that can assist clients with virtually every business-related issue, including the oftentimes complex area of taxation. In fact, they been awarded “Best Tax Law Firm” for the past three years in a row in VT. Nicole Bodoh is a member of the taxation team, and she brings a wealth of knowledge and experience in both federal and state tax issues to assist her clients. “I enjoy working with a diverse group of clients, some of whom are local and some of whom aren’t based in the state,” says Nicole, who has been with the firm for six years and is licensed to practice in NH, VT, MA, and PA. “Our firm can assist businesses of all sizes with regulatory issues, corporate and governance issues, mergers and acquisitions…we do it all!” Nicole’s specialty is tax law. “There tends to be a lot of confusion regarding New Hampshire tax laws. It’s a unique state because there is no income tax, but the state does have complex businesses taxes with requirements that some may not be aware of. New Hampshire tax laws can be very different from the federal level or even those of other states.” It’s for these reasons that Clean Energy NH will be hosting an event sponsored by PPE&C on May 23 at the UNH School of Law in Concord on “Renewable Energy Taxation 101”. Featuring attorney Nicole Bodoh from PPE&C and several other topic experts, the event will provide an overview of various tax issues and attendees will leave with a better understanding of the complex world of taxation. Registration is available online here. For Nicole, the topic is one that never fails to spark her professional interest. “It’s like putting together pieces of a puzzle,” Nicole says of her work negotiating contracts and working with her business clients, a task helped by her previous experience working as an English-as-a-second-language teacher and helping students with interpretations. PPE&C also serves clients in the energy, utility, and environmental spheres. Clean Energy NH has worked with another of the firm’s top attorneys, Elijah Emerson of the Montpelier, VT office, in our regulatory initiatives at the Public Utilities Commission. Says Eli about working with Clean Energy NH: “I love working with CENH and its members because it invigorates me and reminds me why I became a lawyer – to help people make the world a cleaner, better place.” Learn more about Primmer, Piper, Eggleston, & Cramer and connect with their attorneys here!

  • REC Sweeping: The Loophole Undermining the Renewable Portfolio Standard

    The cornerstone of clean energy policy in New Hampshire is broken. But this legislative session, SB72 presents an opportunity to fix it. New Hampshire is one of twenty-nine U.S. states that have implemented a Renewable Portfolio Standard (RPS). These state-level policies have been responsible for roughly half of all growth in U.S. renewable electricity generation and capacity since 2000.[1] New Hampshire’s RPS is a policy that obligates electricity suppliers (e.g., distribution utilities like Eversource, Unitil, and Liberty Utilities) to acquire a certain percentage of their electricity mix from renewable energy sources every year. Renewable obligations are divided into four categories: · Class I – New Renewable Energy · Class II – New Solar · Class III – Existing Biomass / Methane · Class IV – Existing Small Hydro The table below depicts the annual obligations of electricity suppliers across these categories. RPS Compliance There are three ways electricity suppliers can comply with renewable energy obligations under the RPS: 1. Buy Renewable Energy Credits (RECs): Every megawatt-hour of electricity generated from a renewable energy system produces a REC: a certificate acknowledging its potential contribution to the RPS. Electricity suppliers can purchase RECs from homeowners, businesses, municipalities, or any other owners of renewable energy systems to comply with RPS obligations through the REC market. 2. Pay Alternative Compliance Payments (ACPs): Instead of purchasing RECs, electricity suppliers can pay into the state Renewable Energy Fund. The Public Utilities Commission uses money generated by ACPs to fund rebate programs for residential commercial, municipal, and low-income renewable energy projects. 3. Build renewables: due to hefty regulatory challenges, this option is scarcely utilized. The REC Sweeping Loophole – A Vicious Cycle Not all owners of renewable energy systems follow the necessary bureaucratic protocols to register and sell their RECs. “REC Sweeping” is a loophole in the RPS that allows electricity suppliers to “sweep up” unregistered RECs without paying the owners of the systems that generated them. This surplus of “free” RECs distorts the market by causing REC prices to collapse. REC prices in New Hampshire are incredible low right now (less than $10, if not less than $5). The low price of RECs is both a symptom of REC sweeping, and the cause of REC sweeping. Because prices are so low, many residential and small-scale systems do not bother to register and sell their RECs, which lead to an even greater surplus of free RECs and even lower REC prices. Figure 1 depicts the vicious cycle of REC sweeping. The Solution – SB72 SB72 closes the REC sweeping loophole that allows utilities to take unregistered RECs from renewable energy system owners at no cost. Contact your legislator and urge them to support SB72 in order to fulfill the original intent of the RPS and allow the market to function as designed! [1] Barbose, L. (2018). “U.S. Renewable Portfolio Standards: A 2018 Update.” Berkley Lab: Electricity Markets Policy Group. Retrieved from:

  • Two Paths to Grid Modernization: The Market and the Monopoly

    “As I read the @NHPUC grid mod document, I find myself wondering if the whole paradigm isn’t too utility-centric – focused on ‘what can we encourage the utilities to put into rate base?’ rather than ‘how can we transform utilities into platform providers?’” –D. Maurice Kreis, The Consumer Advocate The new Public Utilities Commission report on electric grid modernization envisions a 21st century energy grid designed around distributed energy resources (e.g., solar, storage, electric vehicles, load management, smart meters, and synchronization of these and other technologies). The question remains: will the market or the monopoly be the path taken into the distributed energy future? While the report calls for broad stakeholder input from customers and energy service providers, much of the framework offered revolves around integrating elements of grid modernization into existing five- and ten-year distribution system plans which are utility focused, lead, and driven. The report gives less attention to the potential for market forces, enabled by smart rate design and time-based price signals, to stimulate competitive investment of private capital to achieve the goals of grid modernization. There are two schools of thought on the best approach to grid modernization: 1. Customer-Centric: the Competitive Market Approach 2. Utility-Centric: the Central Planning Approach In the end, both of these paths will have a role to play in modernizing our electric system. That being said, thus far in New Hampshire, the competitive market has been responsible for nearly all distributed energy resource deployment. Over the past decade, market forces have succeeded in establishing a robust and growing distributed solar industry, which is already delivering benefits to more than 12,000 homes, businesses, and municipalities. Customer-Centric Grid Mod: The Competitive Market Approach The success of the solar industry is a result of the simple but effective price signal established by net metering, the policy that allows owners of distributed generation to receive credit from their utility for electricity fed into the electric grid. Net metering has been invaluable in developing New Hampshire’s local energy economy, but the realization of a fully modern electric grid will require a more sophisticated form of net metering. Distributed energy generated during the late afternoon is more valuable than distributed energy produced mid-morning. This is because overall demand for electricity, and stress on the electric grid, is generally greater in the late afternoon. Despite these differing values, current net metering compensates distributed generation (e.g., rooftop solar) at the same rate regardless of the time of production. Innovative rate design is one critical component of leveraging competitive markets to modernize the electric grid. For example, net metering can be modernized to compensate distributed generation based on how valuable that electricity is given the time of production, a practice known as “time-variant” or “time-of-use” rate design. Offering customers time-based rates for both for consumption of electricity, and as compensation for distributed generation, will allow market forces to better deploy distributed energy resources to the benefit of the individual user and the ratepayer generally. For example, time-based rates can motivate customers to pair their solar with energy storage, which would enable them to strategically discharge stored solar energy when the grid needs it most. Beyond time-variant rates, peer-to-peer energy trading, Non-Wires Alternatives (utilizing distributed energy resources to avoid traditional utility investments in sub-stations and the like), and data access and transparency are all necessary components of a modern electric grid. Utility-Centric Grid Mod: The Central Planning Approach The new Public Utilities Commission Staff report on grid modernization acknowledges that competitive markets, guided by time-based price signals, have a role to play in bringing our electric grid into the 21st century. However, the lengthy report exhausts most of its focus exploring the central-planning approach to grid modernization. The report recommends utilities submit Integrated Distribution System plans that include 10-year roadmaps of how the utility plans to achieve grid modernization objectives and 5-year capital investment/operational expense plans. These Integrated Distribution Plans will be added to an existing planning process known as Least Cost Integrated Resource Plans. The plans will address a series of complex forecasts and analyses including distributed energy resource forecasting, load forecasting, hosting capacity analysis, and locational value analysis. The plans will address distributed energy resource interconnection and strategic electrification. The plans will include performance metrics, opportunities for utilities to earn revenue based upon their successful implementation of grid modernization objectives. Conclusion Markets tend to move faster than regulators, which is why for the most part, competitive businesses are deploying modern grid solutions at a faster rate than utilities. This is not to say utilities will not play a critical role in modernizing the grid. They most certainly will. The risk is that in the quagmire of the slow-moving regulatory arena, the opportunity of market approaches to grid modernization will be overshadowed by an approach that relies too heavily on utility-led initiatives. Clean Energy NH favors a balanced approach to grid modernization, one that empowers utilities to implement new technologies while also creating opportunities for businesses and residents to invest their private capital in innovative energy solutions.

  • A Glimpse into the Future of Energy: Liberty TOU Storage Pilot

    Energy storage is coming to New Hampshire! Well, at least for a small subset of Liberty Utilities electric customers. In January 2019, Liberty Utilities received approval from the New Hampshire Public Utilities Commission to roll out a cutting-edge energy storage program for selected residential customers. Over the coming year, Liberty will install and own between 100 and 200 Tesla Powerwall battery packs in residential homes. What makes this storage program especially innovative is the accompanying time-of-use rate that each participating customer will enroll in. The time-of-use rates send a price signal to the batteries, directing them to shift energy consumption away from times of high cost to times of low cost. Under the new rates, customers will charge up their batteries overnight at about $0.07 per kilowatt-hour (kWh), less than half the typical price of electricity. Then, between 3pm and 8pm, prices jump up to approximately $0.36 per kWh, roughly double typical pricing. During these “critical peak periods” when demand for energy is high, the battery will power the customer’s home and the customer can avoid drawing expensive power from the grid. As a result of this kind of storage-enabled load shifting, customers can save money by buying cheaper, off-peak power, and Liberty Utilities can save money by reducing stress on the system when demand for energy is high. This saves money for all Liberty Utilities customers, not only those with home batteries! The program gets even more interesting for participating customers with solar-powered homes. Customers with solar arrays can use the sun to charge up their batteries. Then, when the 3pm-8pm critical peak comes around, excess solar can be exported to the grid when the grid needs energy the most. Think of it as a better way deploy solar as a grid resource. It’s called “dispatchable solar” because the battery allows for solar energy to be dispatched on command. While the Liberty Utilities Pilot is for residential customers only, New Hampshire’s other electric utilities have plans to achieve similar demand reduction goals. As part of their NHSaves energy efficiency program offerings, Eversource and Unitil will be committing $343,765 toward developing “demand reduction initiatives” for their commercial and industrial customers. These pilots will not necessarily involve energy storage and time-of-use pricing, but the goal is the same: reward energy users for shifting consumption to times of low cost. Efforts to reduce energy costs with energy storage, load shifting, and creative policy approaches are spreading across New England. Massachusetts recently became the first state to make energy storage an eligible technology to receive energy efficiency funding through Mass Saves, the counterpart to NHSaves energy efficiency programs in New Hampshire. The Liberty Storage Pilot may be small, but it is significant. If Liberty’s approach proves successful, the program will be expanded to allow for competitive market actors to provide energy storage solutions to customers who wish to take advantage time-of-use pricing. This essentially means you could “bring your own” energy storage system to participate in the program instead of Liberty owning your battery. The pilot gives us a glimpse into the future of the electric grid, and it is looking good for customers who want innovative solutions to their energy challenges.

  • Member Spotlight: Preti Strategies

    If you’re on the hunt for a partner in government relations and public policy and the magic words “elite”, “experienced”, and “exceptional” are on your wish list, then look no further than member Preti Strategies. Featuring talented employees that love and know the Granite State inside and out, Preti Strategies can provide you with a diverse toolbox of government relations, advocacy, and communications services. Based in Concord, Preti Strategies works with a variety of clients, developing a strategic approach that best reflects their unique policy positions and priorities as they develop over the course of an engagement. In New Hampshire, the Preti Strategies team includes two former lawmakers from each side of the aisle and access to an extensive network of relationships developed over decades of legislative work. Whether you’re looking for a partner in state, federal, and local government affairs, strategic communications, public affairs, or grassroots and community relations, Preti Strategies can develop the strategic approach that meets your needs. The firm has extensive experience in energy-related government and public affairs and understands the complex and rapidly-evolving energy policy landscape. Clients can also benefit from Preti Strategies unique ability to, in partnership with their affiliated law firm Preti Flaherty, offer an integrated multi-state approach to government relations. As members of the former NH Clean Tech Council (NHCTC), now rebranded under the Clean Energy NH banner, Preti Strategies has been a valued, engaged member since 2017. The firm’s commitment to New Hampshire and to energy solutions was evident when members of the team joined NHCTC’s October 2018 international trade delegation to Denmark for offshore wind supply chain development. This event helped spur the Granite State’s forward movement in the offshore wind industry. “The team at Preti Strategies is fantastic to work with,” says Michael Behrmann, lead organizer of the Denmark trip and Director of Business Development at Clean Energy NH. “They truly bring an unparalleled level of experience and initiative to the table.” Learn more about the firm, the team, and their services online at

  • NH's Transmission Problem, and How to Solve it

    Electric transmission infrastructure: you know, those large steel towers and cables you see crisscrossing I-93 on your way up to the mountains or down to Boston? Much like the smaller poles and wires distributing power to every home and business, these omnipresent scaffoldings tend to go unnoticed during our daily commutes. The average citizen gives scarcely a thought to transmission towers, neither recognizing them for the essential daily service they provide, nor thinking critically about the role they play in driving the cost of electricity for New Hampshire ratepayers. But if New Hampshire doesn’t start thinking critically about transmission infrastructure, and the associated costs, it is going to be left holding a bag with a multi-million dollar price tag while looking around at its neighboring states and wishing it had seen the writing on the wall. The Independent System Operator for New England’s electric grid, ISO New England, forecasts that each of the New England states, with the exception of New Hampshire, will experience declining annual peak load over the coming ten years. This is an important finding because our regional electric grid divvies up transmission costs among the six New England states based upon each state’s share of the total peak load. In other words, while Vermont, Maine, Massachusetts, Rhode Island, and Connecticut take steps to reduce their annual peak demand for energy, and thus reduce their share of the cost of the transmission system, transmission costs for New Hampshire are headed nowhere but up (see Figures 1 and 2). That is, unless policy makers start implementing solutions. The good news is that solutions are becoming more readily available. Figure 1 – NH is the only New England state forecasted to have peak load growth Figure 2 – NH is forecast to continue to increase its share of peak & capacity costs Energy efficiency and distributed energy resources including solar and energy storage lessen the need for energy coming across the transmission lines from centralized power plants. This is especially the case on days when the demand for energy is at its highest. Peak energy events in New England tend to occur in the mid- to late-afternoon during summer heat waves when air conditioners across the region are cranking away at full blast. Fortunately, these hot summer days also happen to be when distributed solar is generating the most, oftentimes right at the site where the energy is needed. Distributed solar can be a valuable tool to help reduce New Hampshire’s peak demand and lower the high cost of transmission infrastructure. When it comes to mitigating rising transmission costs, more distributed generation is a good start. But policymakers can do more to better guide the deployment of solar and other more versatile technologies like energy storage. The Liberty Utilities Residential Time-of-Use Energy Storage Pilot program, which was approved by the Public Utilities Commission on January 17, 2019, is one example of the policy and regulatory innovations that can be used to solve New Hampshire’s transmission problem. In short, the pilot will deploy up to 500 batteries in residential homes. Each recipient will enroll in a Time-of-Use rate under which they will charge their battery at approximately $0.07 per kilowatt-hour at times of low demand, which is less than half the typical price. The battery then supplies the energy needs of the customer at times of high demand, allowing the customer to avoid drawing power from the grid when the Time-of-Use rate is closer to $0.36 per kilowatt-hour. The customers save money on their electric bill, and all Liberty customers save money on transmission. Net metering, distributed generation, Time-of-Use rates, and energy storage – these policies and technologies present readily available solutions to the problem of growing transmission costs in New Hampshire. It’s time for New Hampshire to start thinking critically about how best to harness them. *Charts courtesy of Clifton Below*

  • The Best Kept Secret About Clean Energy

    Cities and towns, businesses and homeowners, when it comes to the future of energy for our state, they all want the same thing: a cleaner, New Hampshire-based energy economy. In many ways, the prospect is a no-brainer. Clean energy creates local jobs and boosts domestic economies by supporting a growing workforce of high-skilled and high-paid contractors, electricians, installers, financiers, and other professions. Clean energy reduces air pollutant emissions, including carbon dioxide, and lessens the impacts of climate change. But while the economic and environmental benefits are readily apparent, there is another critical benefit clean energy provides that is perhaps less well understood. If you pay attention to energy media in the northeast, you may be aware that the high cost of electricity is an ongoing challenge for our region. Incumbent energy players scarcely miss an opportunity to remind us that New Hampshire suffers some of the highest electric rates in the country. What generally gets left out of this narrative is the somewhat ironic cause of the crisis, namely, the steadily increasing in the cost of utility-owned transmission and distribution systems. If only there were some suite of tools energy users could employ to reduce the ever-growing cost of monopoly poles and wires… If only there were technologies that could be deployed in a distributed fashion to reduce system peaks, and reduce overall energy flowing from centralized generation to the point of consumption… According to the regional grid operator ISO New England, energy efficiency and distributed solar provide exactly this benefit. ISO-NE projects that by 2027, solar and efficiency will have reduced summer peak demand by 6,500 megawatts and avoided 40,000 gigawatt-hours of annual energy use. By lowering peak demand and annual energy consumption, efficiency and solar offset the need for massive investments in traditional energy infrastructure, thus saving money for all ratepayers. A separate analysis conducted by Synapse Energy Economics had similar findings. During the weeklong heat wave of July 2018, distributed solar saved New England ratepayers more than $20 million dollars by reducing total demand for energy and by reducing wholesale energy prices. The collective benefits of clean energy are already being demonstrated across the system. As markets for distributed energy technologies continue to develop, policy innovations like time-of-use rates can be used to more precisely guide the deployment of resources like solar and energy storage to maximize benefit for both the individual customer, and electric grid as a whole. It is true that New Hampshire and its neighbors face some of the highest energy costs in the country. But the solution has become readily available. The solution to high energy costs, both for the individual energy user and for the collective ratepayers, is a clean, distributed, New Hampshire-based energy economy.

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