Proposed Decision 20-08-020 – Reforms to Rooftop Solar Program, Long Overdue

Submitted on December 09, 2022

Dear Commissioners:

Our organizations represent millions of residential electricity customers who are disproportionally lower income and small businesses struggling to keep their doors open. We are surprised and disappointed that the new Proposed Decision (PD) in Rulemaking 20-08-020 fails to enact meaningful reform to the state’s Net Energy Metering (NEM) rooftop solar program. As drafted, the PD will forever perpetuate billions of dollars in excessive subsidies paid for by non-solar customers.

We are surprised to see this because the extensive two-year record of this proceeding, and even the new PD itself, repeatedly validates the existence of and need to correct the unfair cost burden that falls disproportionally on renters, seniors and low-income families. Yet the resulting PD fails to do that.

We are disappointed the PD locks in excessive subsidies for the existing 1.5 million solar customers forever. These subsidies are currently $4 billion annually. That means low-income Californians will continue paying hundreds of dollars extra in their energy bills in perpetuity, so rooftop solar homeowners, who tend to be wealthier Californians, can continue to receive bill discounts decades after they have paid off their solar systems.

Failure to fix this problem means:

  • The state’s rooftop solar program will continue to benefit the wealthier at the expense of the poor.
  • Solar energy from rooftop panels will remain the most expensive form of clean energy in California.
  • The state’s rooftop solar program will continue to jeopardize the state’s electrification goals by needlessly driving up electricity bills.


There is no ambiguity as to the main beneficiaries of the PD. Immediately after it was released, the stock prices of the largest rooftop solar companies rose 20-30 percent.

The objective of this proceeding was to address the unfair cost shift inherent in today’s NEM program. Clearly, that objective was not accomplished.  

We strongly encourage you to modify this PD before voting to ensure non-solar customers who are disproportionally renters, low-income families and seniors, are not forced to pay higher electricity bills to fund inflated subsidies provided to solar customers.


Adriana Ayala, Executive Director
Chicana Latina Foundation

Deborah Howard, Executive Director
California Senior Advocates League

Susy Borlido, Co-Executive Director
Sustainable Works

Faith Bautista, President & CEO
National Diversity Coalition

Kimberly Fuentes, Policy & Communication Director
League of United Latin American Citizens

Mike Meador, Founder & CEO
California Greenworks

CiCi Rojas, President
The Latino Coalition

Antonio Sanchez, Political Director
IBEW Local 11

Eunice Hur Song, Esq., Executive Director
Korean American Coalition Los Angeles

Norma Quinones, Executive Director
San Gabriel Valley Conservation Corps

Edward J. Rendon, Executive Director
San Gabriel Valley Civic Alliance

Jesse B. Johnson Jr., Founder, President Emeritus & Corporate Relations Chair
100 Black Men of Long Beach, Inc.

Nancy Yap, Executive Director
Center for Asian Americans United for Self-Empowerment

Adam Briones, CEO
California Community Builders

Jose Perez, President & CEO
Hispanics in Energy

Johnathan Sandville, President & CEO
African American Board Leadership Institute

Julian Canete, President & CEO
California Hispanic Chamber of Commerce

Christine Baginski, Director of Energy and Environmental Services
Community Action Partnership of Orange County

Val Martinez, Executive Director
Redwood Community Action Agency

John Castillo, Executive Director
Walking Shield

Susana Sngiem, Executive Director
United Cambodian Community

Isela Perez, Editor
The Latino Journal

Pilar Pinel, CEO
Embracing Latina Leadership Alliances 

Matthew Hargrove, President & CEO
California Business Properties Association 

Maria S. Salinas, President & CEO
Los Angeles Area Chamber of Commerce

Tom Hudson, President
Placer County Taxpayer Association

Luis Portillo, President & CEO
San Gabriel Valley Economic Partnership

Andrew Quiñones, President/CEO
Inland Valley Volunteer Resource Center  

Ortensia Lopez, Executive Director
El Concilio of San Mateo County

Jorge De Nava Jr., Executive Director
Central Valley Opportunity Center 

Jennifer Bullard, Sr. Vice President of Advocacy and Government Affairs
Orange County Business Council 

Luis H. Sanchez, CEO
Community Resource Project

Nahla Kayali, Founder & Executive Director
Access California Services

Andres Herrera, Board President
El Concilio Family Services

Tom Hudson, President
California Taxpayer Protection Committee

Victoria Hernandez, Executive Director
South Orange County Economic Coalition 

Benjamin Lopez, Director Public Policy and Advocacy
Inland Empire Economic Partnership 

Michael Salazar, Executive Director
Rio-Hondo Vernon Rotary Club

Robert Apodaca, Executive Director
The Two Hundred Project 

Andrew Caldwell, Executive Director
COLAB of Santa Barbara County 

Fabiola Ortiz, Vice President Energy Division
Community Housing Opportunities Corporation

Michael Turnipseed, Executive Director
Kern County Taxpayer Association 

Robert McDonald, President & CEO
Black Chamber of Orange County 

Gil Jaramillo, Executive Director
Tulare Kings Hispanic Chamber of Commerce 

Nick Hill III, President & CEO
Kern County Black Chamber of Commerce 

Caron Nunez, President
Lincoln Training Center

Jose Luis Solache, President
Greater Lakewood Chamber of Commerce

Doug Zielasko, Chamber CEO
Mission Viejo Chamber of Commerce

Carla Peterman, Executive Vice President Corporate Affairs
Pacific Gas & Electric 

Jason M-B Wells, Executive Director
San Ysidro Chamber of Commerce 

Vicky Ventura, CEO
Antelope Valley Chambers of Commerce 

Dan Skopec, Senior VP State Government Affairs & Chief Regulatory Officer
San Diego Gas & Electric 

Rick Rungaitis, President & CEO
San Marcos Chamber of Commerce 

Anthony Duarte, CEO
San Gabriel Valley Regional Chamber

George D. Peppas III, CEO & President
San Juan Capistrano Chamber of Commerce 

Regina Weatherspoon-Bell, DVL Project Founder & CEO
Dreamers, Visionaries & Leaders Project 

Carol Rosen, Program Director
Soroptimist International of Manhattan Beach 

Scott Alevy, President & CEO
Laguna Niguel Chamber of Commerce

Erin Stream, CEO
The Arc of Riverside County 

Iris Gutierrez, President
High Desert Hispanic Chamber of Commerce 

Michael Backstrom, Vice President of Regulatory Affairs
Southern California Edison

Scott Ashton, CEO
Oceanside Chamber of Commerce 

Nick Ortiz, President & CEO
Greater Bakersfield Chamber of Commerce 

John Bwarie, CEO
Alhambra Chamber of Commerce

Patricia Donaldson, President & CEO
Hawthorne Chamber of Commerce 

Vickie McMurchie, Executive Director
Dana Point Chamber of Commerce 

Iris Gutierrez, President
La Dulce Vida Publications & Events