GSW Team member, Niels Wolter managed the Focus on Energy Solar Electric Program from 2002 to 2010.

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1 Note: this memo summarizes how solar electric systems should be scored based the criteria listed in the Renewable Resource Guidelines, docket 5- GF- 191 memo using the criteria outlined in Attachment A. GSW Team member, Niels Wolter managed the Focus on Energy Solar Electric Program from 2002 to Comments on Expanded Cost- Effectiveness Evaluation of Focus on Energy Renewable Resource Measures Comments of Niels Wolter Grow Solar Wisconsin Program Solar Rooftop Challenge U.S. DOE SunShot Initiative Comments only pertain to solar electric (a.k.a., photovoltaic) systems 1. Measures Focus cost effectiveness is good How is this defined? 2. Technology Risk: Technology s installation, operation & performance issues are known, product certification exist. Response: Tech is well understood with few performance or energy savings reliability issues Modules have 25 year performance warranty Inverters 10 year warranty UL and IEEE standards cover all components National Electric code governs installations, inspector are quickly becoming trained to inspect systems NABCEP Certified installers. In WI training offered by the Midwest Renewable Energy Association, IBEW and several Technical Colleges. About 25 GW installed globally, 17 GW in Germany, and 12 MW installed in Wisconsin 3. Technology Maturity: Technology is not under going rapid upgrades that affect cost or performance Response: Technology is well understood with few performance or energy savings reliability issues

2 Solar electric systems have been commercially available since the 1970s Technology is mature with some of the longest product warranties of any technology Significant innovation potential remains to further reduce cost and increase performance. Cost effectiveness is improving rapidly. Global insurance companies such as Chartis, Zurich, Swiss RE and Chubb are comfortable underwriting PV risks Recent very large photovoltaic investors include: Google, French oil company Total, General Electric, Berkshire Hathaway and many others 4. Supply- side market for technology is mature & seller/installer certification exist Response: More than five sellers and products in Wisconsin with national certifications 54 Wisconsin installers are fully NABCEP certified All modules and inverters sold in WI are UL certified, and inverters are IEEE certified 5. Customer Payback: Measures simple payback is within one measure lifetime (value of energy savings compared to the customer after tax investment) Response: Payback is between 15 years and one measure lifetime Residential, Assumptions: $5,320/kW (MadiSUN group purchase price July 2011), 1200 kwh/year per kw, 30% federal tax credit, electricity 12 cents per kwh. Simple payback: $5,320 x 0.7 / 1200 kwh/year x $0.12/kWh = 26 years Commercial, Assumptions: $5250/kW (MadiSUN group purchase price October 2011), 1200 kwh/year per kw, 30% federal tax credit, accelerated depreciation, owner at 35% tax bracket, electricity 10 cents per kwh. First cost: ($5250 * 0.7) ($5250 * 0.85 * 0.30) = $2345, Simple payback = $2345/$0.10/kWh x 1200 kwh/year = 19.5 years Estimated system life should between 30 to 40 years (20% to 60% longer than the module warranty period) 6. Additional customer maintenance costs to owner (not included in normal payback calculation)

3 Response: Over measure life, nonfuel costs are < 10% of the value of energy produced/saved Annual value of savings: $100 to $120/kW per year in 2011 and increasing as electric rates increase Solar maintenance costs are estimated at about $10/kW per year over the system s first 25 years 7. Federal Tax Credit returned to Wisconsin Response: 50% to 100% of the federal tax credit is returned to WI- based entities in the customer segment 100% of the residential investment tax credit offset Wisconsin individuals Federal taxes A large share of the Business Investment Tax Credit and the accelerated depreciation offsets Wisconsin- sited businesses Federal taxes. Some businesses, estimated at under 20%, of those that have received Focus incentives for solar electric systems, are head quartered outside of Wisconsin. 8. Measure produces or can cost effectively be designed to produce primarily on peak kwh (on- peak hours = 8 a.m. to 9 p.m. M- F, about 40% of all hours) Response: Measure produces >= 60% of it energy on- peak Based on PVwatts solar radiation data for a fix mounted solar electric system. Spreadsheet available on request (niels.solar@gmail.com). In Milwaukee 70% of the generation from a fix mounted system occurs between 8 a.m. and 9 p.m. on business days (does not include holidays or weekends). Other Wisconsin sites are very similar. 9. Supports jobs after system installation such as fuel collection and processing in Wisconsin. O&M jobs should not be included. Response: Has no (post construction) job impacts above conventional resources. Comment: However solar electric systems support job creation in Wisconsin for manufacturing components and installation. Wisconsin component manufacturing firms include: IngeTeam, ABB, Magnetek, Helios, DH Solar,

4 Cardinal Glass, Eaton, etc. Large installation contractors include: Johnson Controls, SunVest Solar, Alliant/RMT. 10. Increased diversity of energy supply. Response: Increases supply diversity in increments of > 300 kw of >100,000 therms/ year Rationale: Had systems of over 20 kw been funded by Focus on Energy than larger systems would have been installed. In California where larger systems are supported, the average commercial system size is 140 kw (see: CA solar statistics) The average size of a solar electric system supported by the New Jersey SREC program is over 80 kw (see: njcleanenergy.com) If the State of Wisconsin only wants to support systems of over 300 kw then a program could be designed to do so. 20 MW solar electric projects are common in Europe. It is a module technology and can provide power at any scale desired. In 2010 the Focus on Energy solar electric program supported over 2.8 MW of installations Regarding diversity of energy supply : No other technology uses sunshine to generate power. 11. Uses waste stream as a fuel Response: N/A Comments: 12. Helps meet energy shortfalls/emergencies Response: Helps meet energy shortfalls in increments of > 300 kw of >100,000 therms/ year Rationale: Had systems of over 20 kw been funded by Focus on Energy than larger systems would have been installed. In California where larger systems are supported, the average commercial system size is 140 kw (see: CA solar statistics)

5 The average size of a solar electric system supported by the New Jersey SREC program is over 80 kw (see: njcleanenergy.com) If the State of Wisconsin only wants to support systems of over 300 kw then a program could be designed to do so. 20 MW solar electric projects are common in Europe. It is a module technology and can provide power at any scale desired. In 2010 the Focus on Energy solar electric program supported over 2.8 MW of installations Regarding diversity of energy supply : No other technology uses sunshine to generate power. 13. Creates renewable byproducts other than energy Response: Unsure Comments: Solar Electric systems create no byproducts Modern/legal component manufacturers treat or recycle all industrial byproducts to meet code. Used components have significant resale value. Damaged modules are recycled (recycling firm 5N Plus is located in De Forest, Wi)