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.


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