Dear Central Coast Community Energy, 

 

California is a solar leader. We are asking you to make it easier, not harder, for more people in 3CE territory to go solar, to meet 3CE’s bold commitments to clean energy and to maximize the public benefits of our area’s transition to clean energy.

3CE rates for solar customers must be better than PG&E’s rates.  When 3CE launched service in 2018, it committed to providing solar customers rates based on the existing CCE program rate structure of mirroring the investor-owned utility’s (IOUs) rates and then applying a discount inclusive of relevant fees.  3CE’s proposal to no longer commit to providing solar customers with better rates than PG&E must be stopped. 

Utilities are lobbying you, your organizations and the California Public Utilities Commission (CPUC) to discourage distributed customer-sited solar by attacking rate terms for solar customers commonly known as “net energy metering” or “NEM”.  NEM disrupts the utility monopoly and hurts their profits by allowing renters, schools, homeowners, farmers and others to use the sun for their own energy needs and to share it with their neighbors in exchange for a bill credit. NEM is what makes the economics of distributed solar possible. 

This simple, groundbreaking policy has helped over a million Californians invest in solar. It should be expanded, not destroyed, to help us get to 100% clean energy as soon as possible.  The CPUC, which regulates IOUs and sets solar policies, has launched a formal process to review current NEM policy (NEM-2), and is planning to update this policy by the end of 2021 through creation of updated terms known as “NEM-3.”  This CPUC process is critical to protecting solar’s right to grow sustainably and urgently taking all of the solar industry’s focus right now.

3CE should not change its rates for solar customers until after PG&E’s NEM rates are determined by the CPUC.  Only once NEM-3 rates are established by the CPUC should 3CE be allowed to change its rates for solar customers.  And, importantly, any 3CE solar rate changes must be better than NEM-3 to encourage the implementation of renewable energy projects locally. As a local, nonprofit organization whose charter includes a commitment to local distributed solar, 3CE should maintain its commitment to be better than PG&E.

Don’t be fooled into thinking “Cost of Service” is anything other than NEM.  3CE is proposing to change its NEM terms and creating a new term of art called “Cost of Service” for that purpose.  Whether it’s called NEM or Cost of Service, the rates for solar customers are what is on the table.  These rates must be determined in a fair manner through the established CPUC process where solar has an equal voice and chance to participate in the extremely complex rate design process.

Legally, CCA’s are not bound to the same rate making restrictions as IOUs, so it is up to you to protect solar in 3CE territory.  At a minimum, 3CE should establish the same support for distributed solar that California requires of its IOUs. Those legal requirements for NEM are, as follows:

 

  • Ensure that solar continues to grow sustainably 
  • Include specific alternatives designed for growth among residential customers in disadvantaged communities 
  • Ensure that NEM is based on the costs and benefits of the generation facility 
  • Ensure that the total benefits are approximately equal to the total costs 

 

Rate-making is complicated and the CPUC is the place where solar rates should be decided. The CPUC rule making process allows for input from solar experts, utilities and other interested parties.  NEM-3 will be determined by independent CPUC Commissioners who are experts in energy markets.  The nature of 3CE’s governance process does not provide for this same type of fair rate-making process for solar customers.  I am asking you to let the CPUC NEM-3 process occur, and then make 3CE commit to do even better for our local solar community.

Consumers are watching and counting on you to take our side. Please stand up to the utilities and the dirty energy lobby by keeping distributed solar growing in 3CE.

Sincerely, 

Central Coast Residents and Business Owners