Appendix C

Solar Energy Industries Association

Introduction

Current draft utility restructuring legislation does not include solar thermal water or space technologies within the definition of renewable energy technologies in regard to renewable energy portfolio standards (RPS). As a result, the legislation favors large-scale grid-tied projects over small-scale residential renewable energy producers. The Solar Energy Industries Association (SEIA) has drafted this primer in an effort to change this definition as it currently stands by demonstrating the value and necessity of including solar thermal technologies in a proposed RPS. First, here are some facts regarding today's solar thermal water and space heating industry:

• Today, over 1 million buildings utilize solar thermal generated energy to offset conventional water heating technology, which is primarily electricity.

· The industry consists of experienced small manufacturers that currently produce the highest quality solar thermal technologies in the world today.

· The non-profit Solar Rating and Certification Corporation and the Florida Solar Energy Center offer the most comprehensive rating and certification options available to solar manufacturers in the world. Ratings are based on actual field performance, thus resulting in one of the only few "real world" appliance certifications available today.

· In a recent study performed by the Florida Solar Energy Center (FSEC), if the potential market for solar water heaters in the US was fully realized, 41 million kWh equivalent would be generated per year - equivalent to the output of eight 100 MW fossil-fueled generating plants.

Proposed Change

Each of the proposed bills define renewables in the following manner:

"The term 'renewable energy' means electricity generated from solar, wind, waste, except for municipal solid waste, biomass, hydroelectric, or geothermal resources."

The national solar energy industry requests that this definition be expanded by adding the following phrase, "or electricity displaced by solar thermal energy technologies."

Rationale

The rationale for the proposed change includes the following:

• Many utilities studying the potential of using solar thermal water heating technologies as a tool or distributed generation and renewable energy deployment understand that allowing solar thermal technologies to be included in the definition of renewables may add significant value to future investments in solar water heating technologies.

· Solar thermal water heating systems can be measured in the exact same manner by which other end-use renewable energy technologies are measured. The addition of a low-cost Btu meter to the system with a readily available device that converts the Btus directly to kilowatt-hours is an easy way to measure energy output for the purposes of the RPS.

· Utility programs utilizing cost-effective solar thermal technologies may, in may cases, be the lowest cost means of complying with an RPS.

· As currently crafted, photovoltaic systems configured as rooftop distributed generation would be eligible to participate in RPS's, providing at least some electricity for electric water heaters. Heating water with solar thermal technologies can be accomplished at one-tenth the cost.

Conclusion

This change in the definition of renewable energy will most certainly give utilities an option that is low-cost and extremely valuable to fulfill renewable energy portfolio standard requirements and is essential to assuring that the US fully recognize its renewable energy generation potential.