HomeMy WebLinkAbout2021-12-17; Clean Energy Alliance JPA; ; Receive Update on Proposed Changes to San Diego Gas & Electric Net Energy Metering Tariffs and Consideration of Sending a Letter Commenting on the Proposed Changes~-~
CLEAN ENERGY ALLIANCE
Staff Report
DATE: December 17, 2021
TO: Clean Energy Alliance Board of Directors
FROM:
ITEM4:
Barbara Boswell, Chief Executive Officer
Receive Update on Proposed Changes to San Diego Gas & Electric Net Energy Metering
Tariffs and Consideration of Sending a Letter Commenting on the Proposed Changes
RECOMMENDATION
Direct staff to draft a letter for Board Chair signature commenting on the California Public Utilities
Commission proposed changes to San Diego Gas & Electric Net Energy Metering Tariffs, to be delivered
to Governor Newsom and the California Public Utilities Commission.
BACKGROUND AND DISCUSSION
On August 27, 2020, a proceeding was initiated with the California Public Utilities Commission (CPUC),
commonly known as NEM 3.0, for the purpose of revisiting current Investor-Owned Utilities (IOU)
(including San Diego Gas & Electric) net energy metering (NEM) tariffs. Since that time, the CPUC has
heard various proposals related to changes to the NEM tariffs. A proposed decision (PD) on the
proceeding was submitted on December 13, 2021, and the earliest the PD can be heard by the CPUC is
January 27, 2022.
CEA Board will be provided a summary of the PD and may consider sending a letter to the Governor and
CPUC commenting on the PD.
FISCAL IMPACT
There is no fiscal impact by this action.
ATTACHMENTS
None
Net Energy Metering 3.0
Proposed Decision
R. 20-09-020
December 17, 2021
T n SDAL
ENERGY & ENVIRONMENTAL LAW
-Overview
• Export compensation
• Market Transition Credits
• Grid Participation Charges
• Eligible Rate Schedules
• Grandfathering
• Implementation
•
Export Compensation
• Export compensation reduced as much as 20 to 25 cents/kWh.
• Compensation rate is now based on avoided cost calculator.
• Customer incentives for rooftop solar are now limited.
•
Market Transition Credits
Residential $1.62/kW $3.59/kW $0/kW
Low Income $4.36/kW $5.25/kW $0/kW
Non-Residential $0/kW $0/kW $0/kW
•
Monthly Grid Participation Charge
Low-Income $0/kW
Non-Residential
$0/kW
•
Eligible Rate Schedules
• Eligible rate schedules limited to one schedule per utility.
• Commission explains "requiring highly differentiated time-of-use rates will vastly
improve the pricing signal to customers and meet several guiding principles in
this proceeding."
• SDG&E rate schedule is EV-TOU-5.
• Limits consumer choice and may further reduce incentive to participate.
•
Grandfathering
• Residential customers (non-CARE) on NEM 1.0 and 2.0 will transition to NEM 3.0
no more than 15 years after the customer's interconnection date.
• NEM 2.0 tariff customers who voluntarily transfer to NEM 3.0 receive a $0.20/Wh
storage rebate for four years, decreasing by 25 percent per year over the
subsequent four years.
• The 15-year legacy period is replaced with a 20-year legacy period for future
NEM 2.0 customers, applicable to customers who enter into NEM 2.0 service
after NEM 3.0 decision is adopted, or who later take control of a residential
system that is operated under NEM 2.0 service.
•
Implementation
D + 30 days -Utilities file Tier 1 advice letter with NEM 3.0 tariff.
D + 45 days -Utilities file supplemental advice letter with rate elements and tariff sheets.
D + 100 days -Energy Division decision on advice letters.
D + 120 days -NEM 2.0 tariff sunsets. No additional customers permitted to take service.
D + 12 months -Utilities finish billing system changes and complete implementation .
•
_;('ii-, SAN DIEGO ( J. "t COMMUNITY
\.!._,• POWER
815 E Street, Suite 12716
San Diego, CA 92112
sdcommunitypower.org
Governor Gavin Newsom
1303 10th Street, Suite 1173
Sacramento, CA 95814
California Public Utilities Commission
505 Van Ness Ave.,
San Francisco, CA 94102
RE: SDCP Supports the Sustainable Growth of the Rooftop Solar Industry via the
Net Energy Metering (NEM) 3.0 Proceeding
Dear Governor Newsom and CPUC Commissioners,
As one of the largest Community Choice Aggregators (CCA) in California, San Diego
Community Power (SDCP) requests your support to protect rooftop solar, ensure that it
continues to grow sustainably through the existing Net Energy Metering (NEM) 3.0
proceeding, maintain the existing structure for current NEM customers, and have it
available for future customers in our Communities of Concern.
California has suffered the devastating effects of the accelerating climate crisis in the past
year with wildfires displacing hundreds of thousands of people and producing some of the
worst air quality in state's history. SDCP believes that rooftop solar is a key solution to
fighting climate change as many of the jurisdictions which joined the organization did so
with a vision of 100 percent renewable energy by 2035 or sooner, including distributed
energy resources, such as local rooftop solar and storage. California has long been a
leader in adopting solar energy with over a million residents generating their own
renewable energy onsite, creating more than 75,000 jobs, and helping contribute billions
of dollars of economic benefit to the state through the existing NEM structure.
Net Energy Metering allows customers to power their homes, apartments, nonprofit
organizations, businesses, cities, and schools using clean solar energy by giving them a
bill credit for the excess clean electricity they send to the grid. Today, the sustainable
growth of the industry is under question. California's investor-owned utilities (IOU) and
other parties in the proceeding are proposing to make changes via the proceeding which
would impact the financial incentives existing NEM customers have enjoyed. The
proposed changes would make going solar more expensive to future customers, increase
the amount of time it takes to pay off their investments and ultimately have the potential
to seriously harm the rooftop solar industry in California. The proposed changes would
also create monthly fixed fees that SDCP customers could not avoid on the San Diego
Gas & Electric (SDG&E) side of the bill, regardless of the Net Surplus Compensation
(NSC) that is provided by SDCP.
As San Diego Community Power works to provide competitive rates and cleaner energy,
we acknowledge that reaching our 100% renewable energy goal requires a diverse
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portfolio of resources including rooftop solar. Ensuring the sustainable growth of the
industry through a supportive NEM 3.0 proceeding is in line with the increase of
renewables needed to meet the state's Senate Bill (SB) 100 goal of 100 percent clean
energy by 2045. Doing so has the potential to reduce greenhouse gas emissions and
create thousands of green jobs that can benefit our Communities of Concern.
In prioritizing an equitable and survivable future, the NEM 3.0 proceeding shall continue
the sustainable growth of the industry which helps increase grid resiliency and lessen the
impacts of the climate crisis such as the frequency of wildfires. Particularly, it is important
to consider potential impacts to our low-income communities like those on the California
Alternate Rates for Energy (CARE) and Family Electric Rate Assistance (FERA) rates,
who may wish to enroll in NEM but may be discouraged from doing so if the financial
incentives are decreased. Expanding NEM benefits to residents on 80 percent of the area
median income would also help in these efforts.
As such, drastic changes to the NEM program by the CPUC has the potential to negatively
impact the financial incentives customers have enjoyed, and what future customers could
have enjoyed as well. California has long been a model on the clean energy transition,
and what happens here will shape the clean energy landscape across the United States.
Lastly, as we emerge from the economic and public health crises caused by COVID-19,
we urge you to maintain the benefits of solar energy for all Californians, ensure that the
industry continues to grow sustainably from the NEM 3.0 proceeding, and invest in
Communities of Concern who are at the forefront of the climate crisis.
Sincerely,
cc: Members of the California Public Utilities Commission
MCE I My co"'!munity.
My choice.
MARIN COUNTY NAPA COUNTY UNINCORPORATED CONTRA COSTA COUNTY UNINCORPORATED SOLANO COUNTY
BENICIA CONCORD DANVILLE El CERRITO FAIRFIELD LAFAYETTE MARTINEZ MORAGA OAKLEY
PINOLE PITTSBURG PLEASANT HILL RICHMOND SAN PABLO SAN RAMON VALLEJO WALNUT CREEK
Governor Gavin Newsom
1303 10th Street, Suite 1173
Sacramento, CA 95814
California Public Utilities Commission
505 Van Ness Ave.
San Francisco, CA 94102
December 08, 2021
RE: MCE Supports the Sustainable and Equitable Growth of Rooftop Solar, Particularly
for Low-Income and Disadvantaged Communities, via the Net Energy Metering (NEM) 3.0
Proceeding
Dear Governor Newsom and CPUC Commissioners,
As one of the largest Community Choice Aggregators (CCA) in California, Marin Clean Energy
(MCE) requests your support to ensure that rooftop solar coupled with storage continues to grow
sustainably, and equitably, through the existing Net Energy Metering (NEM) 3.0 proceeding.
Robust adoption of distributed energy resources (DERs ), such as solar plus storage, is fundamental
in the fight against climate change. Further, increased solar plus storage adoption increases
resiliency for the entire grid, and has the potential to lessen the impacts of the climate crisis via
reductions in greenhouse gas emissions. High DER penetration also creates green jobs to benefit
our communities.
NEM allows customers to power their homes, apartments, nonprofit organizations, businesses,
cities, and schools using clean solar energy by giving them a bill credit for the excess clean
electricity they send to the grid. Today, the sustainable and equitable growth of rooftop solar is
under question. California's investor-owned utilities (IOU) and other parties in the proceeding are
proposing to make changes which would impact the financial incentives of NEM customers.
coNCORDOFFICE: 2300 Clayton Road, Suite 1150, Concord, CA 94520
SAN RAFAEL OFFICE: 1125 T amalpais Avenue, San Rafael, CA 94901
mceCleanEnergy.org
Some studies show that historically, rooftop solar adoption has disproportionately benefited higher
income, white, single-family homeowners. 1 MCE is focused on creating sustainable and equitable
outcomes for our member communities. When determining the structure of the program under a
NEM 3.0 framework, MCE urges you to consider those customers who have traditionally been
excluded from the benefits ofNEM, such as those who are lower-income and/or live in multi-unit
dwellings and disadvantaged communities (DACs).
MCE is focused on getting battery storage, coupled with solar, into our communities to help with
resiliency during emergency outages and PSPS events, and to improve grid health and reliability.
Battery storage is especially important for medically vulnerable customers, critical facilities, and
in DACs, where Public Safety Power Shutoff (PSPS) events have been an added burden. These
battery solutions, coupled with solar, shift the benefits of solar to the evening, when the energy is
needed most, and they reduce the need for fossil-based generation in the 4-9 pm timeframe. NEM
solutions should bolster and incentivize storage to improve grid health and community resilience.
The proposed policy changes to NEM would make going solar more expensive to future customers,
increase the amount of time it takes to pay off their investments and ultimately have the potential
to limit the amount of rooftop solar ( and solar plus storage) in California. Some of the proposed
changes would also create monthly fixed fees that MCE customers could not avoid in their
transmission and distribution charges to Pacific Gas & Electric (PG&E), regardless of the Net
Surplus Compensation (NSC) that is provided by MCE.
In particular it is critical to consider impacts to our low-income communities like those in the
California Alternate Rates for Energy (CARE) and Family Electric Rate Assistance (FERA)
discount programs, who may wish to enroll in NEM but may be discouraged from doing so if the
financial incentives are decreased too significantly.
To promote a sustainable and equitable NEM future, MCE urges a strong focus on incentivizing
solar plus storage adoption (particularly among low-income customers and those living in
DACs), avoiding punitive fees for installing solar, and ensuring any changes do not dissuade
customers from installing battery storage. There may be a need for a modest grid-use charge for
NEM customers who rely on the grid during non-solar hours, relative to their actual grid impact,
to avoid cross-subsidization, but there should be no "penalty" fees for NEM customers. Any such
grid-use charge should be carefully researched and developed before implementation to confirm it
would not act as a disincentive to battery storage adoption.
Therefore, we oppose any CPUC proposal that imposes a penalty fee on past or future solar and
solar + storage adopters. It is critical that low-and middle-income customers (including
1 Barbose, Galen L., et al. Residential Solar-Adopter Income and Demographic Trends: 2021 Update. Lawrence
Berkeley National Laboratory (LBNL), Berkeley, CA 2021.
homeowners and renters) as well as those living in disadvantaged communities are not discouraged
from enrolling in NEM programs. Potential solutions to consider include:
Expanding NEM benefits for residents with household incomes at or below 80 percent of
the area median income, as determined by the Department of Housing and Community
Development;
Exempting low-income customers, especially those that live in High Fire Thread District
(HFTD) areas or DACs, or those who have experienced multiple PSPS events from
additional fixed charges.
Providing stronger incentives for low-income customers that live in HFTD areas to install
solar plus storage systems;
Exempting low-income customers and those who live in DACs from additional fixed
charges;
Providing stronger upfront incentives for low-income customers and those who live in a
DAC to install solar plus storage systems; and
Exempting customers who install batteries from any proposed fixed charges ( and
providing compensation for those DERs ), as their batteries provide additional grid benefits.
California has long been a model for the clean energy transition, and what happens here will inform
the clean energy landscape across the United States. As we emerge from the economic and public
health crises caused by COVID-19, MCE urges you to maintain the benefits of solar energy for all
Californians when storage is included, ensure that rooftop solar plus battery storage continues to
grow sustainably and equitably, and focus investment on the ratepayers and communities who are
at the forefront of the social justice and climate crisis.
Sincerely,
Dawn Weisz, Chief Executive Officer
Cc: Members of the California Public Utilities Commission
DocuSign Envelope ID: DACBCD47-DC62-4975-A42E-23F7861834D5
RESOLUTION No. -2021-35
A RESOLUTION OF THE BOARD OF DIRECTORS OF THE EAST BAY COMMUNITY
ENERGY AUTHORITY SUPPORTING A REGULATED NET ENERGY METERING
(NEM) PROGRAM THAT ENCOURAGES CLEAN ENERGY DISTRIBUTED
GENERATION AND HELPS MEET VITAL CLEAN ENERGY AND CLIMATE GOALS
WHEREAS, Net Energy Metering (NEM) is designed to encourage and support the
installation of customer-sited, behind-the-meter renewable energy generation in order
to reduce emissions of heat-trapping greenhouse gases and bolster a clean energy
economy; and
WHEREAS The East Bay Community Energy Authority ("EBCE") was formed as a
Community Choice Aggregation agency ('CCA') on December 1, 2016, under the Joint
Exercise of Power Act, California Government Code sections 6500 et seq., among the
County of Alameda, and the Cities of Albany, Berkeley, Dublin, Emeryville, Fremont,
Hayward, Livermore, Oakland, Piedmont, San Leandro, and Union City, followed by
the addition and inclusion in March of 2020 of the cities of Newark and Pleasanton,
located in Alameda County, and the City of Tracy, located in San Joaquin County, to
study, promote, develop, conduct, operate, and manage clean energy and climate
programs in the member jurisdictions.
WHEREAS, NEM allows customers to receive bill credits for power generated by their
solar system and shared with the power grid and ultimately save money on their
electricity utility bills, which also over time helps reduce costs to the power grid; and
WHEREAS, NEM is what has helped behind-the-meter solar become increasingly
accessible to lower income households; and
WHEREAS, Assembly Bill 327 (Chapter 611, statutes of 2013 as amended) includes a
sub-section that directs the California Public Utilities Commission to adopt a NEM
policy that ensures solar distributed generation will continue "to grow sustainably and
include specific alternatives designed for growth among residential customers in
disadvantaged communities."
WHEREAS, California is much less likely to adequately meet its 2030 and 2045 clean
energy goals in time with utility scale solar alone and needs to substantially increase
the amount of rooftop solar and associated storage, as reported by the California
Energy Commission 2021 SB 100 Joint Agency Report Summary; and
WHEREAS, Customer-sited solar distributed generation leads to overall savings on
future transmission costs in California; and
WHEREAS, protecting rooftop solar and expanding access to rooftop solar in
communities of concern will help California and cities in EBCE service territory to
DocuSign Envelope ID: DACBCD47-DC62-4975-A42E-23F7861834D5
move toward 100 percent clean energy, lessen our contribution to the climate crisis,
and reduce air quality injustices from dirty energy; and
WHEREAS, we are in a worldwide climate crisis and need to make the transition to
clean energy more accessible by keeping all types of eligible renewable energy in the
mix.
NOW THEREFORE, BE IT RESOLVED that the East Bay Community Energy (EBCE)
authority supports protecting and expanding rooftop solar via a strong succeeding NEM
tariff and expanding clean energy access by making it easier, not costlier, for people to
adopt rooftop solar and related energy storage in order to meet California's important
clean energy targets and deploy solar in all communities and households, particularly
those most struggling to pay their electricity bills;
BE IT FURTHER RESOLVED that East Bay Community Energy (EBCE) respectfully
urges the CPUC to strengthen the NEM program in a manner that
(i) Expands clean distributed generation access to all households,
particularly of low-and moderate income ratepayers;
(ii) Expands access to other clean energy technologies that pair with solar,
such as battery storage;
(iii) Ensures that the solar installations continue to grow in order to help
meet State and local climate goals; and
(iv) Excludes provisions for high monthly fixed fees.
(v) Integrates Time-Of-Use rates into NEM 3.0 as appropriate to
incentivize solar distributed generation, electrification and energy
efficiency.
(vi) Ensures that customers in Environmental and Social Justice
communities who have not had much access to rooftop, behind-the-
meter solar are provided generous incentives so they can be a greater
part of the clean energy solution to the climate crisis.
(vii) Ensures that low-income customers have the opportunity to access the
bill savings and resilience benefits associated with the NEM tariff.
(viii) Provides a pathway for Environmental and Social Justice communities
to own and operate distributed generation and related storage projects
in their communities and to their benefit, and
(ix) Ensures low-income customers are incentivized with retail rates to
participate in the NEM program.
BE IT FURTHER RESOLVED that elements of any NEM 3.0 program should take into
account expected job impacts in the solar industry and seek to avoid job loss in the
solar distributed generation sector.
BE IT FURTHER RESOLVED that that copies of this Resolution shall be sent to each
member of the California Public Utilities Commission and to Governor Gavin Newsom.
DocuSign Envelope ID: DACBCD47-DC62-4975-A42E-23F7861834D5
ADOPTED AND APPROVED this 3rd day of December, 2021.
Dianne Martinez, Chair
GDo'"Slgood by,
WD ~"'
90Efl8A3222CE44E
Clerk of the Board