February 1, 2022
Utility and Review Board
3rd Floor, Summit Place
1601 Lower Water Street
Halifax, Nova Scotia B3J 3P6
Roland A. Deveau, Steven McGrath, Steven M. Murphy,
Re: NSPI’s “system access charge” for solar net-metering and Matter 10341
We are writing to file formal complaint with the Utility and Review Board under section 83(1) of the Public Utilities Act regarding Nova Scotia Power’s recent application for a general rate increase. To quickly summarize the issue, we believe that the Public Utility, Nova Scotia Power Incorporated (“NSPI”), has unjustly and unreasonably begun charging a fee, known as the System Access Charge, that has not been approved by the Utility and Review Board as it is part of Matter 10431. This is a clear breach of the Public Utilities Act, specifically section 71 of that Act.
Contained within NSPI’s application to the Board under Matter 10431, NSPI has proposed a system access charge (the “fee”) which would apply to solar net metering customers. This proposed fee is so prohibitively high that it would effectively destroy the solar industry in Nova Scotia by disincentivizing homeowners from installing solar panels to generate renewable energy. Moreover, in proposing this fee, NSPI has requested that it be effective as of February 1, 2022, which would be a retroactive application of the fee (given that the Board’s decision has not been rendered in this matter).
NSPI has begun acting as if the Board has already approved both the fee and that it be applied retroactively. NSPI has begun sending letters to solar installers indicating that they will start applying this fe as of February 1, 2022. We are attaching a copy of one such letter.
The application of the System Access Charge is discriminatory against prospective solar customers and is being applied, or threatening to be applied, in contravention to section 71 of the Public Utilities Act
No public utility shall charge, demand, collect or receive a greater or less compensation for any service performed by it than is prescribed in such schedules as are at the time in force, or demand, collect or receive any rates, tolls or charges not specified in such schedules.
We would ask that the UARB respond to NSPI’s application and, using the authority provided under s.87(1) of the Act, cancel this unjustly discriminatory fee.
We earnestly request that the UARB investigate this matter with urgency as customers and the small businesses that serve them, are being directly and measurably harmed with every hour that passes while Nova Scotia Power continues this activity.
Sincerely,
(Five Members of Solar NS)