The Florida Solar Energy Industries Association (FlaSEIA) represents businesses engaged in the manufacture, distribution, contracting and installation of solar energy systems in Florida. As an Interested Party in this proceeding, we provide the following comments to the Florida Public Service Commission (FPSC) staff recommendation and proposed rule offered for consideration at this Agenda Conference.

First and foremost, FlaSEIA urges the Commission to approve the staff recommendation and move forward with the proposed rule as presented in the staff recommendation. For the past several years, a standard interconnection process for small photovoltaic systems (SPS) has been the subject of FPSC staff workshops, prior dockets, as well as a workshop sponsored by the Florida Solar Energy Center. Florida law and policy, and indeed FPSC orders, have accorded preferential treatment for solar energy. As a result of this preference, the FPSC may establish unique, innovative, and reasonable standards to encourage greater use of solar energy.

We are encouraged by the flexibility that the proposed rule has given utilities to address the interconnection of PV systems, while establishing a uniform process. FlaSEIA believes that the proposed rule reflects an equitable compromise that addresses the collective interest of those with a stake in the outcome of this proceeding. FlaSEIA believes that once all parties have gained a greater level of experience, confidence and comfort with SPS, that the rule, as drafted, will accommodate modifications that had previously been sought by our organization. However, time is of the essence to establish a uniform standard for interconnection to allow interested consumers to complete their transactions for procurement of SPS that depend on a tie to the utility grid.

The specific areas that FlaSEIA hopes to see flexibility in utility interconnection agreements filed within the parameters of this rule include: use of a single meter to allow net-metering; and, in the event that the utility requires dual meters, that they file an alternative to the COG-1 tariff that recognizes the distinction between the operating characteristics of a conventional small power producer and a solar energy system (24 hour day vs. 14 hour day);

Finally, this rulemaking contemplates small photovoltaic systems (SPS). Small is a relative term. What was small four years ago when this process began may not be small by today's standards, given the technology and market advances of photovoltaic systems. The commission

may wish to consider an option whereby IOUs may follow the standard established by this rulemaking for customers installing photovoltaic systems of up to 100KW. The flexibility accorded by such a provision would provide consumers who have greater energy requirements with a reasonable process by which to interconnect, and provide the electric utility with a blueprint for allowing such interconnection. In fact, IEEE 929 features a provision that makes the standard applicable to PV systems of up to 500KW at the option of the utility.

We thank the Commissioners for the opportunity to address you today. We also thank the Commission staff for its efforts to bring this proposed rule to Commission for adoption. Recent events will no doubt focus more attention on our need to conserve and diversify our energy resources not merely for the sake of efficiency, but for the sake of national security. As our central station power plants and natural gas pipelines operate under heightened security, distributed solar energy systems will certainly be considered a prudent and necessary resource which will benefit not only the host, but the utility and its customers as well. We encourage the Commission to move forward with this rulemaking in all due haste.

Submitted this 2^nd day of October, 2001 on behalf of the Florida Solar Energy Industries Association.