Vote Solar and GRID Alternatives Letter to California Leadership on the Need to Increase Grid Reliability and Maximize Utilization of State and Federal Funding

 

Dear Governor Newsom, Senate President McGuire, Assembly Speaker Rivas, and CPUC and CEC Commissioners:

Vote Solar and GRID Alternatives (VS/GRID) appreciate the amount of complex energy policy California’s state agencies expertly work on. Advancing state interests is at the core of the California Energy Commission’s (CEC) day-to-day planning work and best exemplified through the market-moving Building Energy Efficiency Standards (Energy Code). The California Public Utilities Commission (CPUC) constantly works to ensure nuanced law and policy can be implemented fairly; this is no easy task and the reason why VS/GRID writes to you today. Together, the two state agencies advance world-leadingenergy codes, set historic clean energy procurement targets, and ensure all Californians can directly access the benefits of a clean energy economy. All this critical work is the result of forward-looking elected officials and strong executive leadership.

This past Earth Day, the U.S. Environmental Protection Agency (EPA) announced that it was provisionally awarding California a historic $248.5m Solar for All (SFA) grant. GRID Alternatives has also been provisionally awarded a multi-state and a tribal SFA grant and is busy planning to ensure the maximum amount of grant funding serves income-qualified Californians with solar bill savings, regardless of homeownership status. These grants are humbling, but our shared goals recognize the need to develop policies that are scalable and long-lasting. To this end, the California Infrastructure and Economic Development Bank (I Bank), coordinator of a Joint Interagency Working Group, is busy co-creating green financing products as part of the National Clean Investment Fund (NCIF) and the Clean Communities Investment Accelerator (CCIA) awards. The combination of these historic federal funding investments requires state leaders, non-profits, and other stakeholders to work together to design policy that can be depended upon to deliver clean energy bill savings and other benefits to all communities out to 2035 and beyond.As you know, the California SFA application specifically intends to utilize “the first year of implementation for planning to align policies with a focus and opportunity for community solar and storage projects.” VS/GRID appreciate the state agencies continuing to take the necessary time to ensure California’s SFA application is underpinned by stable and scalable renewable energy policy that meets the requirements of the federal grant funding.

As you know, the California SFA application specifically intends to utilize “the first year of implementation for planning to align policies with a focus and opportunity for community solar and storage projects.”2 VS/GRID appreciate the state agencies continuing to take the necessary time to ensure California’s SFA application is underpinned by stable and scalable renewable energy policy that meets the requirements of the federal grant funding.

The Details Matter
In 2022, the AB 2316 Coalition formed immediately after the CPUC issued Decision 22-12- 056 because cost-effective solutions that advance clean energy, assist grid reliability, and build community resilience were not available to all customers and communities in the state, particularly when rooftop solar is out of reach. The AB 2316 Coalition identified and ultimately supported the Net Value Billing Tariff (NVBT) because California’s existing programs were not fully supporting solutions to enable all income-qualified renters and many homeowners, in existing housing or new construction, to benefit from 100% clean energy generated bill savings.

Two years later, before the SFA grant was announced, the CPUC issued a Community Solar Proposed Decision (PD) in A.22-05-022. This first draft of history needs more work. VS/GRID urge state leaders to update the PD to deliver a modified NVBT that can be depended upon to deliver, at least, the minimum SFA grant requirements. This is critical because the current PD risks setting up a structure unable to utilize federal funding because the PD cannot currently meet the bill savings requirement of SFA: a “minimum 20% electricity bill savings to all households served under the program.” Additionally, the current version of the PD appears to rely on the SFA grant as key to increasing the bill savings, but this is not the purpose of the SFA grant. The intended purpose of the SFA grant is to expand existing programs and/or to develop new ones that respond to the responsibility that historic federal funding demands, which is to develop stable policy that assists income-qualified customers benefit and contribute toward state and federal 100% clean energy mandates. The SFA grant is not intended to supplant or backfill state responsibility; it is intended to supplement and advance responsible state policy. VS/GRID are available to meet with state leaders, potentially through the Joint Inter-Agency Working Group, to discuss the importance of using the NVBT to maximize federal funding and to establish stable and durable policy that provides income-qualified customers with bill savings for decades to come.

VS/GRID are available to meet with state leaders, potentially through the Joint Inter-Agency Working Group, to discuss the importance of using the NVBT to maximize federal funding and to establish stable and durable policy that provides income-qualified customers with bill savings for decades to come.

Respectfully,

Steve Campbell
Regulatory Director, West
Vote Solar

Andie Wyatt
Managing Policy Director and Counsel
GRID Alternatives

Cc:

Commissioner Reynolds, President
Commissioner Houck
Commissioner Reynolds
Commissioner Douglas
Commissioner Baker

Commissioner Hochschild, Chair
Commissioner Gunda, Vice Chair
Commissioner McAllister, Ph.D.
Commissioner Monahan, Ph.D.
Commissioner Gallardo

Senate McGuire, President Pro Tempore
Assemblymember Rivas, Speaker