Proposed Decision 20-08-020 Doesn’t Go Far Enough to Correct Unfair Cost Burden on Customers Without Rooftop Solar
Submitted February 02, 2022
Dear Commissioners:
On behalf of more than 100 organizations representing the interests of millions of low-and middle- income Californians; seniors; faith-based; environmental; community groups, and thousands of small businesses, we appreciate this Commission for conducting the most comprehensive and objective review of Net Energy Metering (NEM) since the program was launched more than 25 years ago. We also appreciate the meaningful steps the Proposed Decision takes toward reducing the unfair cost burden on customers without rooftop solar.
Unfortunately, the changes fall short of addressing the Commission’s own guiding principle to “ensure equity among customers.”
The Proposed Decision makes progress toward reducing the cost shift by ensuring that customers who have and will be installing rooftop solar panels begin contributing to the maintenance of the electric grid and state mandated public policy programs. But it stops short of ensuring solar customers pay their fair share.
The Proposed Decision would continue to have customers without rooftop systems pay an unfair burden on their electricity bills so that other customers can install rooftop solar. The Commission’s own findings of fact conclude that the current NEM program:
- “…has negatively impacted non-participant ratepayers,”
- “…is not cost-effective,” and
- “…disproportionately harms low-income customers not participating in net energy metering “
The Affordable Clean Energy for All Coalition supports the state’s transition to a cleaner energy future and recognizes rooftop solar will continue to play a key part of meeting our state’s goals. It remains perplexing, however, that the cost of solar technology has dropped 70 percent, but the current NEM program has continued to mandate steady subsidies over the past two decades. Those subsidies have contributed to the growth of and profits to large publicly traded rooftop solar companies.
We encourage the Commission to revise the Proposed Decision to be certain that the glide path to protect the interests of the rooftop solar industry does not ultimately protect the profits of large solar companies over the interests of customers without rooftop solar, nor interfere with the goal of helping California achieve its clean energy goals in an affordable and equitable manner.
The Commission has done a commendable job of balancing numerous competing interests and we appreciate the complexity of this issue. From a customer perspective, however, it boils down to the simple fact:
Everyone relies on the electric grid – customers with rooftop solar and those without – and everyone should pay their fair share.
So, while we celebrate progress in the Proposed Decision, we should not pretend the problem of unfair subsidies has been solved. Doing so will prevent us from continuing the hard work ahead.
Thank you in advance for your consideration.
Sincerely,
Jodi Reid, Executive Director
California Alliance for Retired Americans
Deborah Howard, Executive Director
California Senior Advocates League
Susy Borlido, Co-Executive Director
Sustainable Works
Norma Quinones, Executive Director
San Gabriel Valley Conservation Corps
Jesse B. Johnson, Jr., Founder
100 Black Men of Long Beach, Inc.
Nancy Yap, Executive Director
Center for Asian Americans United for Self Empowerment (CAUSE)
Pilar Pinel, Founder and CEO
Embracing Latina Leadership Alliances
John Gamboa, President
California Community Builders
Hunter Stern, Assistant Business Manager
IBEW 1245
Matthew Hargrove, President and CEO
California Business Properties Association
Pat Fong Kushida, President & CEO
California Asian Pacific Chamber of Commerce
Thomas Hudson, President
California Taxpayer Protection Committee
Jennifer Ward, Sr. Vice President of Advocacy and Government Affairs
Orange County Business Council
Jim Wunderman, President and CEO
Bay Area Council
Christine Baginski, Director of Energy and Environmental Services
Community Action Partnership of Orange County
Vickie McMurchie, Executive Director
Dana Point Chamber of Commerce
Michael Turnipseed, Executive Director
Kern County Taxpayers Association
Ortensia Lopez, Executive Director
El Concilio of San Mateo County
Rev. Frank Jackson Jr., Chairman and CEO
Village Solutions Foundation
Meredith Staples, Policy Specialist
Engineers and Scientists of California Local 20, IFPTE
Andrew Caldwell, Executive Director
COLAB Santa Barbara County
Mike Brown, Government Affairs Director
COLAB San Luis Obispo
Edward J. Rendon, Executive Director
San Gabriel Valley Civic Alliance
Mark Hemstreet, CEO
Antelope Valley Chambers of Commerce
Isela Perez, Editor
The Latino Journal
Nick Hill, President and CEO
Kern County Black Chamber of Commerce
Nick Ortiz, President and CEO
Greater Bakersfield Chamber of Commerce
Andrew Quinones, CEO
Southern California Service Corps
Johnny Garcia, President
Central Valley Hispanic Chamber of Commerce
Anthony Duarte, CEO
Regional Chamber of Commerce-San Gabriel Valley
Ron Garcia, President
Reliable Energy Management, Inc.
Dan Skopec, Senior Vice President, State Government Affairs & Chief Regulatory Officer
San Diego Gas & Electric
Luis Portillo, President and CEO
San Gabriel Valley Economic Partnership
Joe Partida, President and Chairman of the Board
Oakland Latino Chamber of Commerce
Erin Stream, Executive Director
The Arc of Riverside County
Robert Kenney, Senior Vice President Regulatory and External Affairs
Pacific Gas & Electric
Regina Weatherspoon-Bell, Founder
Dreamers, Visionaries, and Leaders
Nahla Kayali, Founder & Executive Director
Access California Services
Patricia Gillum, Vice Chair, Internal Operations, Treasurer
Modesto Chamber of Commerce
Lisa Baca, Executive Director
California Latino Leadership Institute
LaNiece Jones, Executive Director
Black Women Organized for Political Action
Adriana Ayala, Executive Director
The Chicana Latina Foundation
Jenn Lowe, Legislative Director
Association of California Cities – Orange County
CiCi Rojas, President
The Latino Coalition
Jose L. Perez, President and CEO
Hispanics In Energy
Allen Rago, Co-Chair
Energy Efficiency Council
Robert C. Lapsley, President
California Business Roundtable
Antonio Sanchez, Political Director
IBEW Local 11
Julian Cañete, President and CEO
California Hispanic Chambers of Commerce
Ramiro A. Cavazos, President and CEO
United States Hispanic Chamber of Commerce
Matthew Hargrove, Statewide Administrator
ICSC (International Council of Shopping Centers)
Matthew Hargrove, Statewide Administrator
Building Owners and Managers Association Caiforna
Matthew Hargrove, Statewide Administrator
NAIOP of California
Rachel Michelin, President
California Retailers Association
Maria S. Salinas, President & CEO
Los Angeles Area Chamber of Commerce
Anna Solorio, Director of Community Development
Community Housing Opportunities Corporation
Jeannette Ross, Executive Director
San Fernando City Chamber of Commerce
Val Martinez, Executive Director
Redwood Community Action Agency
Gil Jaramillo, Executive Director
Tulare Kings Hispanic Chamber of Commerce
Luis H. Sanchez, CEO
Community Resource Project
Emma Hernandez, CEO
Southeast Community Development Corporation
Betsy Chou,VP of Finance & Operations
Sharefest Community Development
Michael Salazar, President Elect
Rio Hondo Vernon Rotary Club
Robert McDonald, President & CEO
Black Chamber of Orange County
Thomas Hudson, President
Placer County Taxpayer Association
Tammy Martin-Ryles, Chairman
Black Chamber of Commerce Inland Empire
Scott Alevy, President and CEO
Laguna Niguel Chamber of Commerce
Herman Bhatti, President
Ceres Chamber of Commerce
Cesar Zaldivar Motts, Executive Director
Newstart Housing Corporation
Kim Huggett, President and CEO
Hayward Chamber of Commerce
Michael Backstrom, Vice President of Regulatory Affairs
Southern California Edison
Joe Solache, President
Greater Lakewood Chamber of Commerce
Caron Nunez, President
Lincoln Training Center
Scott Ashton, CEO
Oceanside Chamber of Commerce
Sukisha Kahey, Executive Director
Ujima Housing Corporation
Patricia Donaldson, President and CEO
Hawthorne Chamber of Commerce
Iris Gutierrez, Board Member
High Desert Hispanic Chamber of Commerce
John Gamboa, Co-Founder
The Two Hundred Project
Iris Gutierrez, Founder
La Dulce Vida Publications & Events
Jorge DeNava, Executive Director
Central Valley Opportunity Center
Bernard Ashcraft, CEO
Bay Area Business Roundtable
