Appendix A – Public Utilities Code Section 2827.1 Appendix B – Public Utilities Code Section 2827(b)(4)(A) Appendix C – Summary of Standard Practice Manual Cost Tests Appendix D – Summary Tables of Public Tool Results Appendix E – List of Appearances
funding. In addition to a SASH extension, GRID Alternatives also proposes adopting a complementary program as long as it is designed to incentivize participation. GRID cites the Joint Solar Parties Disadvantaged Communities VNM (DAC-VNEM), SCE’s community/shared solar program or CleanCARE as potential complementary programs, but does not make a specific recommendation. IREC IREC proposes creating the “CleanCARE” program, which CARE customers could authorize the use of CARE funds to purchase renewable generation from a third-party owned facility. Participating customers would move to standard, non-CARE rates and receive kWh bill credits (assuming that the current NEM structure is carried forward) that would be guaranteed to result in a total bill less than or equal to the amount it would otherwise have been under standard CARE rates. IREC proposes that CleanCARE begin as a 5MW pilot program and expand if successful. In addition to CleanCARE, IREC supports adopting several complementary programs to create a suite of alternatives for disadvantaged communities. IREC specifically supports SEIA/Vote Solar’s DAC-VNM proposal and an incentive enhancement, which could include implementation of the AB 693 program. PG&E PG&E originally proposed creating the “SolarCARE” program under which CARE customers in disadvantaged communities would be eligible to receive 100% of their annual usage from a PV system located in their community.
The course of these two federal policies suggests caution in assuming that the current policy environment will continue indefinitely. This history provides an additional reason for the Commission’s commitment to review the NEM successor tariff in 2019. The Public Tool Developed by Energy Division staff with consultants, the Public Tool is intended to provide a vetted, neutral platform on which all party proposals may be tested and compared on an “apples to apples” basis. The Public Tool is not intended to generate “the answer” to any policy questions about the NEM successor tariff. The Energy Division Tariff Paper provided representative uses of the Public Tool and modeled how to use it. Parties were also allowed by the ALJ’s Proposal Ruling to make changes to inputs and assumptions and “states of the world” in their use of the Public Tool, so long as those changes were properly documented. Because of both limitations of the internal logic of the Public Tool, and uncertainty about the external conditions in the world in the future, the Staff Tariff Paper used two “bookend” scenarios: one in which customer-sited renewable DG is postulated to have a “high” value to all customers, and one in which customer-sited renewable DG is postulated to have a “low” value to all customers. Parties used these “bookends” to evaluate their proposals. Some parties also took advantage of the opportunity to create a third, customized scenario.
Parties and TASC (separately) argue that a warranty requirement could discourage innovation in product offerings. IREC and ORA suggest that equipment warranties are sufficiently common in the solar market now that it would be unnecessary, and potentially create an administrative burden, to impose a separate warranty requirement. Because warranties have been required both CSI and SGIP, it is reasonable and not burdensome to require a minimum 10-year warranty or service agreement to ensure proper maintenance and continued system performance. A warranty will help to protect against defects and undue degradation of electrical generation output caused by faulty manufacture or installation, and to cover any expenses generated from repair and replacement of the system that are not otherwise covered by the manufacturer. Parties express a range of views on whether additional safety requirements are needed for interconnection and other issues that are not strictly customersited equipment. CMUA, SCE, and SDG&E make a number of proposals for safety standards, including requirements for projects larger than 1 MW; and continuation of safety requirements in the existing NEM program. SDG&E urges that the possibility of technology-specific requirements should be expressly considered. Joint Solar Parties question whether any separate or additional safety standards are necessary, and that in any event the Commission's ability to impose safety standards on entities that are not regulated utilities is limited. On these issues, the Commission's and IOUs' normal processes, particularly those related to interconnection, should suffice to maintain an
The Commission also adopts the CALSEIA proposal that the VNM tariff should be expanded to allow multiple service delivery points at a single site under the tariff. This has been allowed under the MASH VNM tariff since the adoption of D.11-07-031, and has been used successfully by participants, without administrative problems. Net Energy Metering Aggregation The NEMA tariff should also be continued as a supplement under the NEM successor tariff. NEMA systems should be subject to the same requirements regarding nonbypassable charges and interconnection costs as systems under the standard successor tariff. Many agricultural customers have begun to use the NEMA tariff, which was implemented only two years ago in Res. E-4610. It is important to maintain continuity for NEMA, to allow additional customers, especially but not exclusively agricultural customers, to take advantage of NEMA to install renewable DG for their facilities. NEMA customers, like customers using the VNM tariff, are compensated the same way as all NEM customers; only the aggregation feature is different. Direct Access Customers and Customers of Community Choice Aggregation All the elements of the current treatment of DA and CCA customers should be maintained under the NEM successor tariff. These customers will be able to use the NEM successor tariff on the same terms as IOU customers. As is currently the case, the relevant IOU will credit the customer for the portion of the bill; the customer's electric service provider or CCA will credit the customer for the generation portion of the bill.