Will California Protect Customers’ Right to Self-Generate?
Should you be able to reduce the amount of energy you buy from your utility by generating your own power? Or does a utility have the right to demand that you buy all your power from them, even if you have a solar system on your roof?
This question is at the heart of California’s new proceeding to determine the future of net metering in the state. In comments to the California Public Utilities Commission in October, California’s three big investor-owned utilities argue that net metering should be unavailable to new customers after the current 5% program cap is reached, and that customers should have to move to a ‘buy all-sell all’ feed-in tariff (FiT) instead. Customers who want to go solar after 2016, the utilities argue, should no longer be allowed under state law to reduce the utility-generated energy they buy by generating their own renewable energy onsite. Instead, they want their customers to have to buy all the electricity they use from the utility, and sell all their onsite renewable generation back to the utility at a pre-determined price.
What price, you ask? Well, the utilities are all over the map on that one.
- PG&E proposes the FiT price should vary by technology and should be set at “the avoided cost of the energy minus any costs incurred accommodating the generation that are not paid by the participating customer” (this would equal approximately 4 cents/kWh, minus integration costs). PG&E proposes an adder could be included if needed to allow continued growth of rooftop solar, with that adder declining over time.
- SDG&E proposes that the FiT price should vary by technology like PG&E, but argues the price should be set based on production cost, rather than on the value of the energy to the rest of the system. (SDG&E follows up by proposing yet another alternative for determining the price: that it be based on the competitively-set ReMAT price already being used for systems of 1-3 MW.)
- So Cal Edison agrees with PG&E that “the FiT rate should be based on market price benchmarks in the wholesale energy markets, such as the CAISO’s default load aggregation point (DLAP) prices” but says the price should not vary by technology and doesn’t suggest an adder to go on top of the short-run energy-only price.
We see some significant problems here. Foremost among them is that throwing out net metering and replacing it with a ‘buy all-sell all’ arrangement would be at odds with Americans’ fundamental right to self-generation. Net metering allows customers to first meet their own electricity needs with the clean energy they generate, and then receive full retail credit on their utility bill for excess electricity they send back to the grid. In California, about two thirds of the power generated from net metered systems is currently used by customers onsite. A FiT is something else entirely – the utility credits customers for all of their solar power production at a set price. In this situation, solar customers are no longer self-generators empowered to use their solar energy to primarily reduce their own load. They instead become power producers that must send all of their power to the utility.
A FiT that accurately values the net benefits of rooftop solar generation— fully building in public health, environmental, economic and grid benefits– is a fine option for those who want to be in the business of delivering power to the utilities, but it should be the customer’s choice whether they move to a FiT or choose to primarily use their solar energy onsite as a way of reducing their electricity purchases from the utility. PURPA, a federal law approved by Congress back in 1978, affirms this common-sense customer right to self-determination. (See our earlier blog post if you’d like to read our principles for designing an expanded net metering program, highlighting the importance of the right to self-generate.)
Beyond the issue of customer rights, there are other practical concerns. Arriving at the right FiT price to compensate customer-sited renewables is a difficult and contentious proposition. As outlined above, the utilities’ proposals for how that price should be calculated vary greatly from each other—and none inspire much confidence in reaching proper valuation. In fact, in recent years several CPUC proceedings considered developing value-based renewable procurement programs (AB 1969 expansion, AB 920 implementation, SB 32 implementation), and in each of those proceedings, utilities fought comprehensive valuation of clean energy tooth and nail. And the Edison Electric Institute, the trade association representing all investor-owned utilities in the US, has repeatedly stated its opposition to crediting distributed renewables with any value beyond the short term price of polluting fossil-fuel generation: see Greentech Media articles here and here. Until the monopoly utilities are willing to properly value distributed generation, a policy that secures value for customers by offsetting retail purchases is a much more pragmatic approach.
Net metering is a simple and proven policy tool for supporting self-generation, and has been enormously successful in California. The real issue here is rate design, where solutions are available, as noted in a recent DOE Sunshot paper that proposes three-pronged approach of revenue decoupling, a minimum bill and time-of-use rates that are gradually phased in for all customers. Since the CPUC is set to approve changes to residential rate structures in 2015 that will kick in over the next several years, we simply can’t know yet how the benefits of net metering to all Californians will stack up against costs (though a proper accounting of both sides is very likely to show continued net benefits for everyone). Meanwhile, California remains far from achieving its long-term goals to protect the climate, and we need to expand solar access to more Californians who live in disadvantaged communities. We hope that in 2015, solar supporters all across the state will come together to urge the CPUC take a common sense approach: extend and expand net metering beyond 2016, enabling more Californians to help tackle our collective climate challenge, and to control their own energy future.