Another Letter to CPUC

Governor Newsom and CPUC Commissioners:

As an industry expert, professor and citizen of California I’d like to weigh in on the proposed the proposed solar tax and NEM 3.0 rules that would go into effect mid 2022. I currently work as a professor of management at University of San Francisco, focused on new and emerging transportation and solutions that address the climate crisis.

Put simply what the CPUC is proposing an ill-conceived policy proposal, that provides onerous tax that will disincentivize residential solar—which is the direction the market needs to take for grid stability and local climate resilience. While the PG&E has long argued at the importance of paying fees to cover energy transmission, this should not funded in a way that disadvantages the most sustainable and resilient solutions. In saying this I reference volumes of literature showing that a distributed energy network with local production and storage is the most climate sensitive solution to our energy needs. It also worth noting that the proposed pricing structure works against other state policy—specifically efforts to incentivize clean vehicles / EVs by 2035. By raising the cost of solar electricity on new and future adopters, the state provides an oppositional market force to the encouraged pivot toward electrified transport.

While we need to think about energy equity, the state should be funding the most resilient solar for priority populations from cap-and-trade dollars, not from fees that work against local solar proliferation. Needed funding to ensure equity of service could easily be made a priority of the Transformative Climate Communities Program from the Strategic Growth Council as opposed to base charges for all payers. Other options can and should considered, one of which could be raising the needed fees for transmission and infrastructure through VMT and other outcomes related to driving and energy consumption. This would also work to incentive local policy aimed at increasing transit, walking and cycling.

Electrifying our states energy can only be achieved we bring down the cost for ALL consumers to purchase residential solar. The proposed new fee structure works against that market dynamic and provides an unfair rate advantage to the (primarily wealthy) Californian’s able to be “first in” the door with local solar. The proposal should not be approved.

We can work together to ideate and develop alternatives that are more equitable and appropriate to scaling clean energy in our state.

All the best,

William (Billy) Riggs