Comments on the NEM Guiding Principles Proposed Decision

Joint CCAs:

• A Guiding Principle should be added: “The (NEM 3.0) tariff shall allow a customer-generator to consume electricity that is self-generated onsite and to determine what amount of onsite generation, if any, to deliver to the utility under a standard contract or tariff.”
• CPUC cannot compel customer-generators to export energy to IOUs.
• CA law prohibits regulation of self-generators/consumers.

Joint IOUs:

• Use the most recent version of the Avoided Cost Calculator(ACC).
• Statute prohibits using the Total Resource Cost (TRC) test and requires use of Ratepayer Impact Measurement (RIM) test.
• The RIM test measures impacts of the NEM program on all customers.
• A Guiding Principle should be added to include issues of whether and to what extent a cost shift exists.

SEIA and Vote Solar and Grid Alternatives:

• The PD interprets “grow sustainably” as “all customers can sustain the cost of that growth." This definition is too narrow- should be removed- or changed to:
• “Grow sustainably means that behind the meter clean distributed generation deployment will continue to increase year-over-year at a pace at least in line with historical average.”
• Measure of “value” of NEM tariff must go beyond value to the grid.

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