FP&L Publishes False Findings To Get Out Of Paying For Solar Incentives

It came as no surprise when Sam Cochran, owner of Russell & Sun Solar called to tell me about his research on FP&L's latest attempts to get out of having to pay solar incentives to individual and business ratepayers, per the PSC's instructions last year. FP&L must think that they are above using FSEC's industry standard tested methodology to validate their findings. If they used FSEC's calculations for kWh output for PV modules and BTU's for solar thermal collectors they would not have any grounds for arguing against a solar incentive plan for their ratepayers. Thank you Sam for calling them out. I think everyone needs to write to the PSC and focus the spotlight on FP&L's outrageous fiction.


Florida Public Service Commission
2540 Shumard Oak Blvd.
Tallahassee, FL 32399-0850

To whom it may concern; July 9th, 2010

I am a solar contractor headquartered in Melbourne. I am writing to strongly encourage approval of FPL’s original proposal (dated March 30, 2010) with respect to the solar programs described. I also would like to explain why I believe FPL’s test results should be disregarded as a basis for rejecting solar programs; their numbers are inaccurate and misleading.

FPL claims that a solar water heating system consisting of an 80gal tank and a 4x10 collector will offset 1482kWh per customer per year at the meter1. Russell & Sun Solar has been installing solar water heaters for 28+ years here in Central Florida so we know that the numbers FPL uses to justify their tests are completely inaccurate. The Florida Solar Energy Center (FSEC) also knows: they have measured and rated these collectors in a controlled environment to produce 34,400 BTUs per day which translates into at least 3681kWh per year per customer, not 1482kWs as FPL claims. FPL’s number is so far off that it appears that they have fabricated numbers for their tests. It is no wonder that this program fails.

FPL further falsely claims that PV systems will produce 5373kWh2. Industry-accepted calculations for a 10kW PV system are 15,802kWh and 7901kWh for a 5kW system per customer per year. Our company has installed several hundred kWs of PV. We routinely measure most of our systems so we know that FPL’s number for PV savings is way too low - up to three times too low. Again, there is little wonder this program fails FPL’s tests.

FPL is even more misleading when citing the performance of Business Solar Water Heating systems3. Again, FPL should have consulted the national experts, FSEC, to make their determinations. We have two systems that we deliberately and accurately measure. Both have just four collectors; they are small systems for a business. Each of these systems produces at least 14,726 kWh per year, not 3652kWh as FPL claims. FPL is off in their calculations by 4X!

It is clear to me that FPL has supported their proposal with numbers that are inaccurate at best and deliberately misleading at worst. This tactic is not new to FPL. In a report authored by Washington Economics Group (FPL is one of their largest customers), 40,000 jobs will be created if Florida legislature authorizes the utility companies to build 700MW of solar power. This number has not been supported by anything we have seen. In fact, we have a recent example in Cape Canaveral at the 25MW solar farm installed by FPL. This project has created three, yes, just three, permanent jobs.

I believe it is important to emphasize the quasi-irrelevance of the testing methods used by FPL. The E-RIM test is highly suspicious for too many reasons to explain here. It is probable that this test should not be used at all. The E-TRC test is much more relevant, but it does not address adequately the many other factors important to Floridians today, such as our environment, GHG emissions, job creation, or long-term energy policy and sustainability. For example, it is clear that Florida must remain as pristine as possible, especially our beaches, in order to support our largest industry, tourism. How do any of these tests address this?

My final concern is this: is it really prudent or appropriate to allow our utility companies to dictate our energy policies? Energy policies must be a reflection of many factors, including recent events, societal trends, and what is good for Floridians and Americans.

I strongly believe that Florida must be a leader in the renewable energy industry. Utility incentives are one good way to grow renewable energies. Please support incentive plans through our IOUs. Thank you for your time and consideration.

Sincerely,
Samuel Cochrane, President
Russell & Sun Solar, Inc.
Melbourne


Notes:

1. On page 107 referencing the Residential Solar Water Heating program, FPL publishes this chart:

At the Meter
Year Per customer kWh Reduction Per customer winter kWh Reduction Per customer Summer kWh Reduction Total annual kWh Reduction Total annual Winter kWh Reduction Total annual Summer kWh Reduction
2010 1482 0.45 0.22 2,024,835 615 301
2011 1482 0.45 0.22 6,799,875 2065 1009
2012 1482 0.45 0.22 7,235,124 2197 1074
2013 1482 0.45 0.22 7,371,468 2238 1094
2014 1482 0.45 0.22 7,365,540 2237 1093
2015 0 0 0 0 0 0
2016 0 0 0 0 0 0
2017 0 0 0 0 0 0
2018 0 0 0 0 0 0
2019 0 0 0 0 0 0

 
2. Residential Photovoltaic System program, from page 110 of their amended proposal (dated July1, 2010):

Year Per customer kWh reduction Per customer Winter kWh reduction Per customer Summer kWh reduction Total annual kWh reduction Total annual winter kWh reduction Total annual summer kWh reduction
2010 5373 .05 1.70 605,222 6 191
2011 5373 .05 1.70 1,826,888 17 578
2012 5373 .05 1.70 1,826,888 17 578
2013 5373 .05 1.70 1,826,888 17 578
2014 5373 .05 1.70 1,826,888 17 578
2015 0 0 0 0 0 0
2016 0 0 0 0 0 0
2017 0 0 0 0 0 0
2018 0 0 0 0 0 0
2019 0 0 0 0 0 0

3. On page 109 referencing the Business Solar Water Heating program, FPL publishes this chart:

Year Per customer kWh reduction Per customer Winter kWh reduction Per customer Summer kWh reduction Total annual kWh reduction Total annual winter kWh reduction Total annual summer kWh reduction
2010 3652 .07 1.00 41,994 1 11
2011 3652 .07 1.00 155,555 3 42
2012 3652 .07 1.00 189,299 4 52
2013 3652 .07 1.00 229,171 4 63
2014 3652 .07 1.00 275,797 5 75
2015 0 0 0 0 0 0
2016 0 0 0 0 0 0
2017 0 0 0 0 0 0
2018 0 0 0 0 0 0
2019 0 0 0 0 0 0