December Low-Income Updates

The following is the Low-Income Recruitment Report that summarizes Low-Income Facilitator and Project Manager recruitment efforts, program development updates, waitlist management, and general policy updates that have occurred during the month of December (12/1/2020 – 12/31/2020).

If you have questions, comments, or feedback, please reach out to [email protected].

Thank you,
Program Administrator

Low Income Recruitment Penalty Proposal Released

The Oregon Public Utility Commission recently approved Commission Order 20-387, which temporarily waives, for 12 months, the requirement in the Oregon Community Solar Program Implementation Manual that a Project Manager must subscribe 10% of a project’s capacity to low income customers prior to certification, and instead requires Project Managers to meet the project’s low-income subscription requirement within 12 months after project certification, or be subject to a penalty.

Per the Commission Order, PUC Staff requests stakeholder comment and feedback on the proposed penalty. The penalty proposal is linked here, will be posted to the ORCSP website, and will be posted to the UM 1930 docket.

Please send all comments to [email protected] no later than January 28, 2021. Be advised stakeholder comments will be posted to the UM 1930 docket and the ORCSP website.

Questions can be directed to Kacia Brockman, [email protected].

Thank you,
Program Administrator

New Program Implementation Manual Released

On 1/12/2021, the Oregon Public Utility Commission approved revisions to the Oregon Community Solar Program Implementation Manual. The updated changes included but were not limited to:

  • Clarification to Project Manager Definition
  • Project Manager Marketing Disclaimer Language Update
  • Alternative Payment of Program Fees update
  • Correction to Bill Crediting Rules and Annual Bill Credit Reconciliation Policy

 Project Managers are encouraged to carefully consider the appropriate subscription size for their customers and may adjust subscription sizes at any time to avoid customer oversubscription payments, so long as this is consistent with participant contracts. The Program Administrator will review the process for monitoring consumption and adjusting subscription sizes for new customers during the next Project Manager workshop scheduled for early March.

The new Program Implementation Manual can be found on the Program Implementation Manual page. 

Program Administrator

Final Revisions to the Program Implementation Manual

Project Managers,

For your reference, the following version of the Program Implementation Manual includes the final redlines resulting from comments we received from and meetings we held with Project Managers, stakeholders, and the utilities in Q4 2020. As a reminder, we emailed you the updated language in Section 6.3—relating to the annual reconciliation process and treatment of oversubscribed capacity—on December 18, 2020 for your review.

This new version will be presented to the Oregon Public Utility Commission for approval on 1/12/2021. If you have any questions, please reach out to [email protected].

Thank you,
Program Administrator

November Low-Income Updates

The following is the Low-Income Recruitment Report that summarizes Low-Income Facilitator and Project Manager recruitment efforts, program development updates, waitlist management, and general policy updates that have occurred during the month of October.

If you have questions, comments, or feedback, please reach out to [email protected].

Thank you,
Program Administrator

Proposed Revisions to the Program Implementation Manual

(Originally posted 10/2/20; Updated 11/4/20)

OPUC Staff is requesting, by October 13, 2020, stakeholder feedback on proposed revisions to the Community Solar Program (CSP) Program Implementation Manual (PIM). 

Background

The PIM is an outward-facing document that explains program participation requirements for Project Managers and Participants. The PIM is necessarily subject to revisions over time as new issues arise and are resolved throughout program implementation. The PIM was last updated on December 23, 2019. The Program Administration Team is now recommending another PIM update to memorialize decisions made during the past nine months of program implementation, as well as to correct and clarify existing language in the PIM. The program is seeking public comment on the proposed PIM revisions. For your review, the proposed revisions appear as redlines in the version of the PIM linked below. The revisions are summarized on page 2 of the document:

Proposed Revisions to the PIM

Next steps 

Staff requests that stakeholders email comments on the proposed PIM revisions to the following two email addresses no later than October 13, 2020. All stakeholder comments will be posted to the CSP website. 

[email protected] 
[email protected]

The PIM revisions will be presented to the Commission for approval as early as the November 3, 2020, public meeting.


10/21/20 Update:

Stakeholder feedback submitted in response to Program Implementation Manual Revisions

The Program Administrator’s proposed changes to the Program Implementation Manual Revisions was posted to the UM 1930 Docket on 9/29/2020. The Program Administrator requested stakeholders to provide comments and feedback to the proposed revisions. Below are the comments submitted by the following stakeholders


11/4/20 Update: 

Updated Program Implementation Manual Released

The Program Administrator requested stakeholders to provide comments and feedback to proposed changes to the Program Implementation Manual revisions. After considering all posted comments and feedback the Program Administrator has revised the Program Implementation Manual accordingly. The updated version of the manual is posted here.

Interconnection Support Now Available

The Oregon Community Solar Program Administrator has selected an interconnection consultant, EN Engineering, who is now able to provide 3rd party interconnection reviewer services to Project Managers. Project Managers may request either a standard or enhanced review of interconnection study results ahead of implementing a CSP project, with standard reviews partially paid for by the CSP Program. The OPUC staff report outlines the interconnection services EN Engineering can provide to Project Managers.

To request interconnection reviewer services, please contact [email protected].

Visit the Project Manager Resources page for more interconnection resources, such as:

  • Interconnection Guide – Walks Project Managers through the process of sizing, prepping the interconnection package, and the entire interconnection preview process
  • PGE’s Eligible Feeder Capacity
  • PAC’s Eligible Feeder Capacity

Thank you,
The Oregon Community Solar Program Administration Team

Low-Income Updates and Resources

The low-income threshold has changed, as it always does on October 1st. Below, you may find several updated LI documents, an activity report, as well as program resources from our recent PM workshop.


We’ve also created a video about the program, viewable at the provided link and below. 

As always, if you have questions, comments, or feedback, please reach out to us at info[email protected]. Thank you!

RFP for 3rd Party Interconnection Reviewer Services – Questions and Answers

Below are the Program Administrators’ responses to some questions received about our recently released Request for Proposal. Please see our last news post for more information about the RFP.


Task 1.2 – Deliverables reads: Participation and attendance at meetings between PM and utility staff as requested by the PM. How many meetings do we budget for?  Are the meetings virtual?
Meetings will vary depending on the specific situation and the Consultant’s findings after reviewing each specific Utility Impact Study. However, to be as efficient and streamline the process as much as possible, the PM and Consultant should strive to have as few meetings with utility staff as needed while still meeting all goals. Consultant should expect that most Utility Impact Studies will include an average of 2-3 meetings with utility staff and the PM. Consultant should expect virtual meetings to be the standard practice with an occasional in-person meeting (but not for every Utility Impact Study and not while quarantine is still in effect).


Task 1.2 – Deliverables also reads: Other deliverables and due dates as agreed upon between PM and ConsultantThis is an open ended commitment, what is the expectation of Other deliverables and due dates? 
This is purposefully open ended as it depends on the findings of the Utility Impact Study. Consultant should be reviewing and potentially providing alternative pathways forward to the Utility Impact Study (Task 1.1), so additional deliverables are likely to only result if utility staff disagrees with the alternative pathways. The Consultant should expect to work closely with the PM to determine the best path forward, including additional deliverables in this case. In the case that additional deliverables are needed that go beyond the scope that the respondent outlines in the RFP response, then it will be on a Time and Materials basis under “hourly” consulting. In other words, we recognize it can be difficult to plan ahead for every possible scenario, so items that fall outside of scope will not be limited to the capped budget.


Task 1.2, page 6, reads: The consultant must attend a MINIMUM of two meetings as required by PM. Are the meetings teleconferences? MINIMUM is an open ended commitment, can it be changed to MAXIMUM?
Two meeting is the minimum required for each Utility Impact Study. However, if there are significant disagreements and/or issues found, this can escalate into additional meetings with utility staff. Similar to our response to question 1.2b, anything that goes beyond the scope will be on a Time and Materials basis under the “hourly” consulting.


Task 1.3, page 6, 1st paragraph talks about using a standardized template for the report to OPUC. Can a copy of the template be provided?
The template is being developed in coordination with OPUC and will be provided after contracting is set up. Preliminarily (but not finalized), we are thinking the template will include 4 parts: 1. Summary of the challenges; 2. Summary of the solutions and discussions with utility staff; 3. Insights into the utility process; 4. Any insights or proposals for process reform.


Task 1.3 – Deliverables reads: Report to the OPUC which summarizes the results of the review and documents utility coordination effort…. Is the intent that the report developed in Task 1.1 plus utility feedback in Task 1.2 be combined for the Task 1.3 report?
Correct, Task 1.3 is essentially summarizing all the efforts and information from Tasks 1.1 and 1.2 into a larger report.


Task 1.3 Deliverables reads: Other deliverables and due dates as agreed upon between PM and Consultant. This is an open ended commitment, what is the expectation of Other deliverables and due dates?
We expect that additional deliverables would be what is described in the 2nd paragraph under Task 1.3: “In addition to developing and delivering the report to OPUC, Consultant shall also ensure all reviewed materials and documentation of coordination with the utility will be available to OPUC and the PA Team. If Consultant does not receive at least 10 requests to review studies within the duration of the contract—including at least one study from PGE and PAC—OPUC and the PA Team may ask the consultant to review a sample of publicly posted studies and report to the Commission, in an audit-like capacity.”

We expect that additional deliverables beyond this are likely to be related to expanding upon / clarifications on what is delivered in the report to OPUC.


Task 1.4 – Deliverables reads: Bi-weekly status updates…. Is the format to be via email or teleconference?
Consultant should expect to have regular meetings with PA Team to check-in which would suffice the bi-weekly status updates (teleconference check-ins). However, there may be situations with little to report, so email would be acceptable as an update.


Task 2.1: What modeling software is needed to re-create utility analysis using the models provided by utility or third party models? CYME, PSSE, PSLF, Synergi?
This is open ended and is reliant on the Consultant’s expertise and/or recommendations. In other words, we are relying on the Consultant’s expertise to recommend what modeling software, methodology, etc.


Are all the generators proposing distribution interconnection? Or also transmission?
We anticipate that all CSP projects will propose distribution-level interconnection. CSP Projects are all Oregon-jurisdictional distribution-level generators.

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