In D. 22-12-056, the CPUC adopted a “no netting” approach where all recorded imports are charged the import retail rate, and all recorded exports are credited at the retail export compensation rate. The CPUC ordered each IOU to submit a Tier 3 Advice Letter (“AL”) to propose adjustment factors to be used in calculating the difference in residential stand-alone solar customers’ net exports under no netting versus interval netting. The three IOUs submitted the following adjustment factors: SDG&E - 105.14% | PG&E - 105.64% | SCE - 102.51%. Following a Commission resolution on these ALs, the IOUs can incorporate the adjustment factor into bill savings inputs and assumption requirements for developers.