The talk over rooftop photo voltaic via NEM 3.0 in California positioned the photo voltaic trade at odds with shopper teams and unions, however a distinct photo voltaic coverage challenge has now united them in a brand new battle. The state’s group photo voltaic program revision introduced collectively shopper teams, union employees and the photo voltaic trade to attempt to make this sector of photo voltaic work for builders, employees and customers alike.
The unlikely alliance first fashioned when the Coalition for Group Photo voltaic Entry (CCSA) included a group photo voltaic proposal throughout the NEM 3.0 dialogue.
“When California went to revisit net-metering in 2020, it appeared like a pure time to say, ‘Hey, right here’s a mannequin that, at the very least for brand new DERs [and] group photo voltaic, could possibly be a mannequin the place we will handle the important thing concern about distributed photo voltaic, which was cost-shifting,” stated Brandon Smithwood, senior director of coverage at Dimension Renewable Vitality, a group photo voltaic developer.
The CPUC didn’t advance the proposal then, however The Utility Reform Community (TURN) and the Coalition of California Utility Workers (CUE) started working with CCSA behind the scenes to attract a plan to remodel the stalled group photo voltaic market within the state.
In feedback to the CPUC throughout the brand new group photo voltaic proceedings, CCSA stated the fee has tried unsuccessfully to develop a group photo voltaic program to equitably broaden entry to renewable vitality assets since 2013.
“Current packages are duplicative, they don’t lead to sturdy participation amongst low-income Californians, and they’re inefficient in serving prospects,” the feedback learn.
The coalition’s efforts at reform culminated within the passage of AB2316, a legislation requiring utilities serving 100,000 or extra prospects to create and implement group solar-type packages that serve at the very least 51% low-income prospects and are constructed by employees paid prevailing wages.
The teams continued working collectively afterwards on a proposal to the CPUC about what these packages may appear to be, and ended up with the Internet Worth Billing Tariff (NVBT). This tariff program would compensate subscribers to group photo voltaic initiatives as much as 5 MWAC based mostly on the worth of a undertaking’s era on the time it’s supplied to the grid. The construction would require initiatives to be co-located with storage to be worthwhile.
The group photo voltaic proposal united these sometimes opposed teams for a couple of causes. Each TURN and CUE say they opposed NEM 3.0 due to the cost-shift of photo voltaic incentives to non-solar prospects. However the brand new group photo voltaic proposal was typically supported by these teams due to the completely different worth construction used within the incentive methodology.
The NVBT used the state’s Prevented Value Calculator (ACC) to find out the compensation for initiatives — the state’s official photo voltaic incentive analysis instrument, which measures the utility’s averted prices from solar energy. The calculator contains metrics like “environmental worth” and “era capability.”
“The usage of the averted price calculator, to us, looks as if the correct method to anchor the valuation of output from the shared amenities, as a result of it’s in step with our view of delinking the compensation from retail charges, which embrace all of those prices that don’t have anything to do with the worth of era,” stated Matthew Freedman, workers legal professional for TURN.
CUE supported the ACC technique too, because it’s designed to keep away from shifting the prices between collaborating and non-participating prospects. The utility employees group additionally stood behind the NVBT as a result of it could require initiatives to be interconnected to the distribution grid as a substitute of the bigger transmission grid.
“In California, we have now a really huge backup within the ISO interconnection queue. This group photo voltaic proposal would deliver extra photo voltaic and storage on-line sooner. Not solely is that nice for our local weather objectives, but it surely’ll create new jobs all around the state,” stated Rachael Koss, legal professional at Adams Broadwell Joseph & Cardozo who represents CUE earlier than the CPUC.
Each teams additionally supported the NVBT for its potential underneath the Title 24 mandate for photo voltaic on all new properties. Title 24 technically permits group photo voltaic as an alternative choice to rooftop for compliance, however the present group photo voltaic program didn’t incentivize builders to decide on that path. CUE want to see extra group photo voltaic as a substitute of rooftop to fulfill this requirement.
“That’s rather more cost-effective for non-participating ratepayers, while you use group photo voltaic for Title 24. So we have now been urging the PUC to undertake the joint proposal for this small section of the market,” Koss stated.
CPUC roadblocks
Regardless of the varied help for the NVBT, the CPUC rejected the proposal in March, saying it “conflicts with federal legislation and doesn’t meet the necessities” of AB 2316. As an alternative, the fee proposed that utilities PG&E and SCE ought to decide the fee cap accessible to deprived communities via group photo voltaic.
“We don’t assume that this program ought to have the utilities be accountable for deciding on the initiatives. We’ve got a decade of expertise of that taking place, and this system simply form of dead-ends. The utilities are essentially not motivated to make these packages succeed. They’re targeted on having them be area of interest merchandise,” TURN’s Freedman stated.
However rather more consequential than this system persevering with to languish is the fee’s assertion that the NVBT violated federal PURPA legislation, which requires utilities to buy renewable vitality from certified amenities if the price of vitality meets or is lower than fossil fuels. The coalition and others argue group photo voltaic linked to the distribution grid is underneath state jurisdiction reasonably than federal.
“You might have over 20 states with present packages that look similar to the kind of program that we’re proposing in California,” Freedman stated. “The concept that mainly all of those state packages are preempted as a matter of federal legislation is extraordinarily problematic.”
Different state and federal leaders agree that these small group photo voltaic initiatives aren’t underneath FERC wholesale market jurisdiction, together with Republican California legislators Sen. Shannon Grove and Assemblymember Vince Fong and former FERC commissioners Norman Bay, Neil Chatterjee and Jon Wellinghoff.
“Throughout my tenure as chairman of the FERC, we labored to make sure that FERC didn’t preempt decision-making on retail packages comparable to group photo voltaic, the place states have unique jurisdiction,” wrote Wellinghoff.
Together with these letters, Freedman stated different state governors together with New York Gov. Kathy Hochul and Massachusetts Gov. Maura Healey have contacted California Gov. Gavin Newsom to precise their concern with the proposed choice and PURPA implications. Even the White Home known as Newsom, because the administration set a aim for group photo voltaic techniques to energy the equal of 5 million households by 2025.
“The aim is to not have California’s final result take down different state packages. That may be a complete epic catastrophe,” Freedman stated.
The fee has postponed a vote on its proposed choice twice now and has had two closed-session conferences on the subject. Advocates have additionally continued to satisfy with fee workers and different leaders to induce them to alter course and revisit the NVBT. The coalition is holding out hope that the ultimate choice will take their proposal into consideration.
“It’s not that these are the identical folks, these are the identical dividing traces we’ve had on DG photo voltaic,” Dimension’s Smithwood stated. “I believe it’s a good guess that the fee is taking a while as a result of they’re listening to from these voices and saying, ‘Hey, perhaps this deserves a re-assessment.’”
