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Contract No. DE-AC36-08GO28308

A Valuation-Based Framework 

for Considering Distributed 

Generation Photovoltaic Tariff 

Design

Preprint

Owen R. Zinaman

National Renewable Energy Laboratory

Naïm R. Darghouth

Lawrence Berkeley National Laboratory

To be presented at India Smart Grid Week

Bangalore, India

March 2–6, 2015

Conference Paper

NREL/CP-6A50-63555

February 2015
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A Valuation-based Framework for Considering 

Distributed Generation Photovoltaic Tariff Design

Owen R. Zinaman, M.S.E

21st Century Power Partnership

National Renewable Energy Laboratory

Golden, Colorado, USA

owen.zinaman@nrel.gov

Naïm R. Darghouth, Ph.D.

Environmental Energy Technologies Division

Lawrence Berkeley National Laboratory

Berkeley, CA, USA

ndarghouth@lbl.gov

Abstract— Distributed generation photovoltaic (DGPV) costbenefit analyses (CBAs) can provide substantive insights into

understanding the potential flows of value among stakeholders

that grid-connected DGPV programs might induce. Tariff design 

has a significant impact on the level and accrual of such value –

thus, a cost-benefit analysis is a robust starting point for 

stakeholder engagement and discussion on DGPV tariff design. 

To that end this paper outlines a holistic, high-level approach to 

the complex undertaking of DGPV tariff design, the crux of 

which is an iterative cost-benefit analysis process. We propose a 

multi-step progression that aims to promote transparent, 

focused, and informed dialogue on CBA study methodologies and 

assumptions. When studies are completed, the long-run marginal 

avoided cost of the DGPV program should be compared against 

the costs imposed on utilities and non-participating customers, 

recognizing that these can be defined differently depending on 

program objectives. The results of this comparison can then be 

weighed against other program objectives to formulate tariff 

options. Potential changes to tariff structures can be iteratively 

fed back into established analytical tools to inform further 

discussions.

Keywords—tariff design, ratemaking, distributed generation,

photovoltaic, solar valuation, value of solar, cost-benefit analysis

I. INTRODUCTION

Stakeholders contributing to ongoing discussions over 

distributed generation photovoltaic (DGPV) tariff design will 

often have different perspectives on how export tariffs should 

be structured. This divergence of perspectives may at some 

level stem from disparate stakeholder interests and assessments 

of the net costs and benefits (C&B) of DGPV programs, as 

well as the distribution of how and to whom those C&B 

accrue. As Indian regulators look to emulate recent progress in 

certain states in India and quickly accelerate DGPV growth, a 

common analytical framework, which hinges on a transparent 

cost-benefit analysis process, might be employed to encourage 

more open, informed, forward-looking discussion over tariff 

design. A number of Indian states, including Gujurat, Tamil 

Nadu, Uttarakhand, Andhra Pradesh, West Bengal, Kerala, 

Karnataka, among others, have set up forms of net energy 

metering for DGPV, and many more are in the process of 

designing regulatory structures to compensate DGPV. It is by 

applying frameworks such as the one proposed in this paper 

that Indian policymakers can gain a system-wide understanding 

of the C&B of DGPV programs given their objectives, 

ensuring a sustainable solar market as DGPV penetration 

grows in India. This framework can make use of existing 

evaluations of the technical issues that will need to be 

addressed in Indian states (such as those found in Magal et al., 

2014 [1]) to quantify the C&B of DGPV.

This paper offers a high-level approach to the complex 

undertaking of a DGPV tariff design process, the crux of which 

is a program cost-benefit analysis (CBA) study. 

In the context of a larger regulatory framework, we choose 

to focus on tariff design because of the significant impact this 

DGPV program design component has on the various flows of 

value (benefits, costs, and risks) among power sector 

stakeholders. In that context, this paper is organized into a 

series of steps that can be taken during the design of a DGPV 

tariff. These steps are intended to serve as a roadmap of 

iterative or cyclical activities rather than an explicit, linear 

schedule.

II. STEP 1: DECLARE THE OBJECTIVES OF THE PROGRAM

The energy regulator and other relevant government bodies 

should consider publicly declare their objectives with respect 

to the DGPV program, as informed by public policy mandates 

and other goals. Objectives typically take the form of either 

desired aspects or desire outcomes of the program – they range 

not only in importance but in tangibility and measurability. 

Establishing such objectives ex-ante enables tariff design 

discussions and options to be appropriately assessed for 

alignment with a transparent set of values. Table I lists 

examples of potential objectives of a DGPV program. 

TABLE I. POTENTIAL OBJECTIVES OF A DGPV PROGRAM

Focus Areas Taxonomy of Potential Objectives

Example Objectives

Utility

preserve financial health of utility; ensure fair recovery 

of administrative and network infrastructure costs; 

establish new utility investment opportunities; efficient 

rate-making to ensure proper price signals to customers

PV Owner

simplicity and attractiveness of DGPV value 

proposition; ease of application process; incentivize

deployment; responsiveness to consumer demand and 

financibility

Ratepayer

protection from unjust rate increases or allocation of 

risk; mitigation of cross-subsidization impacts among 

participants and non-participants; protection of lowincome customers

Grid / Technical deployment goals and timeframes; alleviation of supply 

shortfalls, network congestion reduction, inducing of 
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Focus Areas Taxonomy of Potential Objectives

Example Objectives

load-shifting behavior; implementation feasibility; 

discourage illegal interconnections

Society

economic development and job creation; empowerment 

of small- or medium-size enterprises; energy security;

address environmental justice concerns

Environment global and local emissions reductions; water use and 

quality impact reduction

a. Some of the listed example objectives could be classified under more than one focus area

III. STEP 2: CONSIDER PROGRAM COSTS AND BENEFITS TO BE

ANALYZED

DGPV exhibits a range of C&B to various stakeholders. 

Table II lists a summary of those C&B, as synthesized from [2]

[3] [4]. The costs and benefits of DGPV are highly dynamic 

quantities, changing with time and location of energy 

production, local (i.e. feeder) and global (i.e. system) 

penetration levels, as well as the performance attributes of the 

system (e.g. reactive power support). The methodologies 

employed to valuate these C&B (see Step 3) range in the 

granularity and accuracy for which they characterize this 

dynamism [5]. Furthermore, they accrue in a distinct manner to 

a diverse set of stakeholders. 

TABLE II. COSTS AND BENEFITS OF A DGPV PROGRAM

Aspect Range of DGPV Costs and Benefits

Example C&B

Benefits

avoided utility energy costs; reduced consumer 

electricity bills; avoided ancillary service costs; reduced 

line losses; deferred/reduced utility generation, 

transmission, and distribution capacity investments; 

fuel price hedging; emissions reductions and air quality 

improvements; water use reductions; water quality 

improvements; grid security and reliability; economic 

development; regulatory compliance benefits

Costs

cost of DGPV system; cost of metering infrastructure; 

program administration; reduced utility fixed cost 

recovery; interconnection cost; lost margin on power 

re-sale; changes to conventional generator operations;

distribution system upgrades; cost of enabling 

information and communication technology systems

In Step 2, the presence of the various DGPV costs and 

benefits in a prospective CBA study (see Step 4) can be 

publicly deliberated among relevant stakeholders and evaluated 

against the backdrop of the program objectives established in 

Step 1. Furthermore, such deliberation should be informed by 

the relative difficulty to robustly assess various metrics (see 

Step 3).

IV. STEP 3: CHOOSE STUDY ASSUMPTIONS AND 

METHODOLOGIES TO ASSESS COSTS AND BENEFITS

Upon selecting which set of C&B will be included in a 

valuation exercise, a multi-stakeholder dialogue can then be 

focused on how selected costs and benefits are assessed, and 

what underlying assumptions will be used to serve as a 

foundation for that assessment. C&B quantification and costeffectiveness analyses can vary significantly based on the 

methodologies and input assumptions employed – thus, careful 

consideration of these aspects is key to producing credible 

valuation estimates. For example, when quantifying the 

economic value of DGPV, should it displace the costs of a 

marginal or average generator? Will DGPV be incorporated in 

integrated resource planning, or will it be layered on top of 

already-planned systems? At what level of spatial and temporal 

granularity will DGPV be valuated? What stakeholder 

perspectives will be considered? If included, how will societal 

benefits such as the health impacts of reduced particulate 

emissions from conventional generation or improved water 

quality be quantified? 

Denholm et. al [6] discusses the range of methodologies 

and tools that can be employed to generate estimates of various 

DGPV costs and benefits from the system perspective. For 

each C&B covered, approaches are described in increasing 

order of difficulty, with discussion focused on the relative 

accuracy of the approach and tools required. 

Keyes and Rábago [7] outlines key study assumptions 

where initial discussions might be focused, such as discount 

rates, demand and fuel price projections, stakeholder 

perspectives considered, and geographic and system 

boundaries. They emphasize that developing a robust set of 

base assumptions is critical to any study, and that transparency 

in both methodology and assumptions is key for fostering 

stakeholder buy-in and program success. Non-disclosure 

agreements may be a necessary tool to circumvent sensitivities 

with utilities.

Overall, stakeholders must balance a desire for theoretical 

accuracy against practical considerations. Table III outlines key 

questions for stakeholders to consider while evaluating a 

particular methodology as part of the CBA process. These 

considerations may change as they are revisited in more mature 

DGPV markets. For example, the value of accuracy may not be 

paramount when cumulative DGPV levels are still low, but 

may gain importance as with increased DGPV capacity. 

TABLE III. KEY CONSIDERATIONS FOR VALUATION

Aspect

Key Considerations for C&B Valuation 

Methodology Selection

Questions

Accuracy of 

Estimate

How accurate will the methodology be, relative to 

more simple or more complex approaches?

Value of 

Accuracy

How much value will additional accuracy yield for 

the process?

Cost of 

Estimate

How much will it cost (in time and money) to 

execute the methodology in question, relative to 

other approaches?

Execution 

Feasability

Is there technical capacity available to implement 

this methodology? Are adequate models and data 

sets publicly available in acceptable timeframes?

Implementation 

Feasability

How equipped and willing are relevant government 

bodies to implement complex study results?

Facilitating a focused, transparent, and pragmatically 

grounded multi-stakeholder discourse will help to establish 

methodological transparency when CBA studies are conducted. 

While consensus may never be reached among stakeholders, 

allowing for periods of public comment, addressing concerns, 

and encouraging focused discussions on study assumptions and 
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methodologies will help to articulate areas of disagreement, 

leaving room for consensus-building in other areas.

V. STEP 4: CONDUCT COST-BENEFIT ANALYSIS STUDY

The crux of the proposed framework is the DGPV CBA 

study – the results of which will be used to inform not only 

tariff design discussions (Step 5), but continued stakeholder 

dialogue over CBA methodologies and input assumptions 

(Step 3) as study results are assessed. An iterative process is 

envisioned where periodic updates to study assumptions,

valuation methodologies and tariff design are conducted, as 

informed by continued stakeholder discussions. 

Depending on the scale of the geographical and temporal 

resolution chosen for the analysis, a variety of approaches, 

spanning operations and planning models to power flow 

simulations to financial analysis tools, can be integrated to 

conduct a DGPV valuation study. No one tool is capable of 

accurately characterizing the range of potential technical and 

financial impacts of a DGPV program over various timeframes 

and system boundaries. Thus, utilizing a combination of tools 

and analytical techniques is likely key for conducting a robust 

valuation. As a matter of process, outputs from power sector 

simulation tools (e.g., bulk planning or operations models, 

transmission or distribution power flow simulations) are often 

used as inputs to financial analysis tools that assess utility rate 

and revenue impacts, as well as stakeholder cost-effectiveness 

metrics such as the Utility Cost Test, Ratepayer Impact Metric, 

or the Societal Cost Test. 

In formulating a DGPV program, regulators may also 

consider whether subsidies for DGPV are appropriate, and if 

so, the levels, types, and sources of subsidization. To this end, 

CBA studies can be used to understand how potential 

incentives and subsidies induce different levels and patterns of 

deployment or mitigate inequities. 

A key question to explore is who will be designated to 

conduct the CBA study. An appropriate balance can be struck 

between the desire for study transparency and practicalities 

around capabilities and data availability. In some contexts, it 

may be appropriate or desirable to enroll a third party 

consultant, or to install an independent monitor with the utility 

modelling teams. Utilities typically hold the grid data 

necessary to perform system-perspective valuation studies but 

may be perceived as biased towards promoting a lower value 

for DGPV. 

VI. STEP 5: PROPOSE TARIFF STRUCTURE

Understanding various flows of value among stakeholders 

will enable regulators to allocate costs during a tariff design 

process in a manner that is aligned with their stated objectives 

(see Step 1). Table IV lists key components of a DGPV tariff 

that can be considered. 

TABLE IV. KEY TARIFF COMPONENTS

Components Key Tariff Components

Examples

Compensation 

Structure

NEM; avoided cost compensation; FITa [8]; net FIT 

[9]; value-of-solar [9]

Import/Export 

Tariff Building 

Blocks

variable energy charges; fixed/variable network and 

administrative charges; time-varying rates [11]; 

demand-based rates; standby charges; bi-directional 

distribution charges [3]; minimum bills [12]

Export Tariff 

Level fixed rate; degression rate; inclining block rates

Export Tariff 

Contract Terms

term length; credit reconciliation terms and limits;

generation limits; exit clauses

Purchasing 

Arrangements utility offtaker; independent buyer office

a.Many FIT structures exist, including fixed rate FITs, degression rate FITs, and FIT premiums. 

For any proposed tariff structure, the long-run marginal 

avoided cost of the DGPV program can be compared against 

the costs imposed on non-participating customers. This will 

yield insight into the amount of cross-subsidization, if any, that 

would be expected to occur between non-participants, the 

utility and DGPV system owners. In the event that crosssubsidization is occurring, the terms of the tariff or program 

might be adjusted, via e.g., increases to fixed charges, 

minimum bills, limits on system size, or program caps. 

Potential changes to tariff structures can be fed back into 

established analytical tools to inform decisions and stakeholder 

discussions. On the other hand, some level of crosssubsidization may be tolerable if it results in a simple and easyto-implement program (e.g., NEM), or even desirable if 

incentivizing deployment using ratepayer funding is an 

objective. CBA studies will likely show a diverse range of 

value flow and accrual among customer classes which change 

with grid location and time of energy production. Table V lists 

potential incentives and pricing mechanisms that can be 

explored during ratemaking which may help tariffs better 

reflect the various value dimensions of DGPV. 

TABLE V. PRICING MECHANISM FOR CAPTURING DGPV VALUE

Dimension Pricing Mechanisms for Reflecting DGPV Value

Dimensions

Time of 

production

time-of-use pricing [11], panel orientation incentives

[13], hourly or dynamic pricing [11]

Location of 

production

locational incentives [14], distribution locational 

marginal pricing [5]

Local- and 

Grid- Level 

Penetration 

penetration-scaling tariff pricing, system capacity caps

System 

Performance

Attributes

Incentives for allowing system curtailment or 

encouraging specific inverter functionalities

While these mechanisms can be useful to some extent, it may 

not be pragmatic to design highly-customized tariff rates to 

ensure solar C&B are disbursed at a theoretical financial

optimum (i.e. one which attempts to reflect all value 

dimensions fully). Furthermore, if simplicity and feasibility of 

implementation are identified as key program objectives (as is 

often the case for early-stage programs), using a single tariff 

(i.e., NEM or FIT) might be desirable. 
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While the tariff structure is key in influencing the flow of 

value among stakeholders, tariffs must be formulated in the 

context of a larger regulatory framework. For instance, if a 

CBA study shows that fixed network and administrative costs 

may not be fully recovered from program participants for a 

given tariff structure, system or program size limits might be 

desirable. Frameworks must also select and allocate costs for 

the required meter technology, considering the metering needs 

of the proposed tariff and future needs with respect to data 

collection and advanced distribution system management. 

Smart meter and smart grid targets might be tied to DGPV 

deployment to help create new investment opportunity for the 

utility and promote longer-term DGPV integration. Sanctioned 

business models should also be identified (e.g., virtual NEM, 

community NEM, third party leasing, shared utility-consumer 

ownership, utility ownership), as aligned with objectives. 

VII. DISCUSSION

As formal decisions are issued, regulators might bear in 

mind that regulatory frameworks are not set in stone. While 

honoring existing contracts helps to preserve investment 

certainty, new terms can be proposed to steer the market 

toward desired levels and spatial distributions of deployment, 

as aligned with established and emerging policy objectives. To 

begin, and one may design and implement a pilot DGPV 

program in order to assess effects of distributed solar on the 

electricity grid (potentially calibrating valuation models), while 

evaluating and demonstrating new technologies or billing 

methods, increasing public acceptance, and gaining stakeholder 

buy-in. 

CBAs which holistically consider planning, operational and 

financial implications of DGPV programs are being explored 

in various contexts, typically under the purview of a value-ofsolar (VoS) tariff formulation process. VoS tariffs are intended 

to reflect the principle that DGPV owners can feasibly be paid 

for the costs they incur and be paid for the benefits they 

contribute to the system, with the understanding that these 

benefits can change over time with wholesale electricity 

market conditions. Formulating a tariff to reflect this principal 

fundamentally necessitates a detailed CBA methodology. 

The U.S. State of Minnesota established a VoS tariff 

formulation process where stakeholders were able to review all 

aspects of the methodology before a final rate was set [15]. 

While no true consensus was ever reached on the methodology 

employed (or the final tariff level, for that matter), the process 

nonetheless successfully garnered open dialogue and 

methodological transparency. As well, it will have enabled

stakeholders to continue to meaningfully contribute to VoS 

proceedings as the tariff is periodically reevaluated.

While a VoS tariff formulation process is a sound impetus 

for conducting a CBA study, we argue that there is 

nevertheless strong practical utility to conducting such a study 

even if VoS tariffs are not being actively considered. Provided 

that time and resources (both financial and technical) are 

available, establishing the analytical framework to understand 

the costs, benefits and expected impacts of a program will lead 

to informed decisions that are aligned with the objectives of the 

power sector regulator and other relevant government bodies. It 

also establishes the models, financial analysis tools and other 

technical capabilities which could eventually inform shifts

toward more systematically fair apportionments of DGPV 

costs and benefits (i.e. a VoS tariff). State Energy Regulatory 

Commissions in India might consider investing in building 

such capabilities, either internally, within their regulated 

utilities, or with a third-party consultant. 

VIII.CONCLUSION

A multitude of objectives and stakeholder perspectives are 

prioritized and harmonized during a DGPV tariff design 

process. CBA studies can provide substantive insights toward 

understanding the various flows of value that a program may 

create, and can be used directly or indirectly to inform public 

consultation processes and formal proposals and decisions. The 

framework presented in this paper strives to promote 

methodological transparency and active stakeholder 

participation in the often iterative CBA study process. The 

extent to which independent decisions must be made by 

empowered stakeholders (i.e. regulators, utilities) depends on 

the specifics of the consultation process, the DGPV program 

objectives, and surrounding institutional and governance 

arrangements. However, ensuring that stakeholders understand 

the full range of issues considered will help to enable focused 

and productive engagement. 

ACKNOWLEDGMENT

The author thanks the reviewers of this paper, Paul 

Denholm, Liz Doris, Bhargav Mehta, Ravi Vora, Ron Benioff, 

Doug Arent, and Karin Haas.

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