proposal.” C. Whether the NEM transition period should apply to the distributed generation (DG) system regardless of transfer of ownership. Vote Solar argued that the transition period should apply in full to DG systems that are transferred to new owners, because the original owner reasonably expected that the system’s value would not be diminished via the loss of NEM if the home or business with solar was sold. SEIA/Vote Comments p.8: “The right to continue under the current NEM construct should be tied to the physical system rather than the customer. In other words, the right should convey upon transfer of the system…” SEIA/Vote Solar Reply Comments p. 10: “The D.14-03-041, pdf p. 29: “We are persuaded that it is reasonable for the full transition period to apply to generation systems installed prior to July 1, 2017 or the attainment of the trigger level, whether or not those systems are transferred to new owners. This treatment preserves the value of these systems, and ensures that the cost of system installation may be recovered on the terms expected when the system is purchased.” D.14-03-041, pdf p. 40, Ordering Paragraph 5: “5. Renewable generation systems eligible for the 20-year transition period adopted in this decision not lose eligibility if transferred to a new owner, operator, or utility account at the original location.” Verified.
eligibility for the NEM transition period Vote Solar proposed that the PD be altered to state that eligibility is not based on when the utility issues the Permission to Operate letter, but rather when the customer submits the documentation needed to complete the application process. The final Decision adopted this change. Comments Of The Vote Solar Initiative On Proposed Decision Establishing A Transition Period Pursuant To Assembly Bill 327 For Customers Enrolled In Net Energy Metering Tariffs, March 12, 2014, pp. 6-7: “The Proposed Decision currently leaves open uncertainty about whether IOU lag times in issuing Permission to Operate letters could prevent customers from being eligible under the current NEM program. The Proposed Decision states that the start of the transition period “will be measured from the year the individual system was interconnected, indicated by the date on which the system received permission to operate,” i.e., the date of the Permission to Operate Letter... individual system was interconnected, indicated by the date on which the customer completes and submits all information required to receive permission to operate the system.49” D.14-03-041, pdf p. 23, Footnote 49: “Eligibility for the transition period is on the date of submission of the documentation needed to complete a NEM interconnection application, including the final building inspection. Customers that complete their application prior to reaching the date that the successor tariff is implemented will be eligible for the transition period once they receive their Permission to Operate letter. The date of that letter indicates the year in which a system was interconnected for the purposes of the transition.”
c. Allocation of hours by issue: Issue A. Whether a solar array’s expected system life should be used as a key metric for setting the NEM transition period 17.7 hours (32.8%) B. Whether one consistent NEM transition period should be used for all solar customer classes and vintages enrolling in NEM before the successor tariff goes into effect 9.7 hours (18.1%) Issue C. Whether the NEM transition period should apply to the distributed generation (DG) system regardless of transfer of ownership 8.5 hours (15.7%) Issue D. What precise milestone should be used to mark a customer’s eligibility for the NEM transition period 5 hours (9.3%) Issue E. General and Procedural 13 hours (24.2%) Verified. Specific Claim:* Claimed CPUC Award ATTORNEY, EXPERT, AND ADVOCATE FEES Item Year Hours Rate $ Basis for Rate* Total $ Hours Rate $ Total $ Susannah Churchill 2013 22 240 D.16-05-047 5280 22.00 240.00 5,280.00 Susannah Churchill 2014 20.3 240 D.16-05-047 4872 20.25 (rounding error by Vote Solar) 240.00 4,860.00 Subtotal: $ 10,152.00 Subtotal: $ 10,140.00 INTERVENOR COMPENSATION CLAIM PREPARATION **