BILL ANALYSIS                                                                                                                                                                                                              1
          1





                SENATE ENERGY, UTILITIES AND COMMUNICATIONS COMMITTEE
                                 ALEX PADILLA, CHAIR
          

          SB 7 -  Wiggins                                   Hearing Date:   
          April 21, 2009             S
          As Amended:         April 13, 2009           FISCAL       B

                                                                        7
                                                                            
            
                                      DESCRIPTION
           
           Current law  establishes the California Solar Initiative (CSI), a  
          $3.3 billion program to subsidize the installation of  
          photovoltaic (PV) systems for customers of the state's  
          investor-owned-utilities (IOUs) and publicly owned utilities  
          (POUs).

           Current law  requires that PV systems be sized to offset part or  
          all of the customer's electrical demand to be eligible for the  
          CSI installation subsidy.

           This bill  permits a customer to size a PV system larger than the  
          customer's load, at the customer's expense, and still qualify  
          for the CSI subsidy up to the customer's electrical load. 

           Current law  requires IOUs, POUs (except the Los Angeles  
          Department of Water and Power), or any other entity offering  
          retail electric service, to credit all electricity generated by  
          a customer-owned solar or wind system against the customer's  
          usage of electricity sold by the utility, on a kilowatt hour  
          basis, a procedure known as "net metering."

           Current law  requires the CPUC to determine a benchmark price for  
          electricity commonly referred to as the market price referent  
          (MPR). The contract price for renewable generation is measured  
          against the MPR as a test of reasonableness.

           This bill  requires those utilities to compensate customers that  
          use net metering for any generation in excess of their load or,  
          for customers on time of use rates any net dollar value, on an  
          annual basis, or to roll that excess generation over, on a  
          kilowatt hour basis, to the next 12-month cycle. The  











          compensation rate would be set by the CPUC at a rate not less  
          than the MPR.

                                      BACKGROUND
           
           California Solar Initiative (CSI)  - The CSI calls for the  
          installation of 3,000 MW of new, solar-produced electricity by  
          2016 to be installed on the customer's side of the meter.  
          Targeted expenditures under the CSI, funded by a surcharge on  
          all ratepayers, is $3.3 billion over 10 years, distributed  
          between three distinct program components: The CSI ($2.167  
          million/1940 MW); the New Solar Homes Partnership ($400  
          million/360 MW); and the Publicly Owned Utility Programs ($700  
          million/700 MW).

          Homeowners, businesses, and government agencies in California's  
          IOU territories installed 158 MW of distributed solar  
          photovoltaics (PV) in 2008, doubling the 78 MW installed in IOU  
          territories in 2007. California now has a cumulative total of  
          441 MW of distributed solar PV systems, the highest level of  
          solar installations in the country.

           Net Metering  - The primary benefit of the CSI program is derived  
          from the solar customer's eligibility for "net-metering" which  
          is authorized under state law separately from the CSI program.  
          Utility customers that generate power from a wind or solar  
          system are eligible for "net metering" under which the  
          electricity purchases of the customer are netted against the  
          electricity generated by the customer's own solar or wind  
          electric system.  When the sun is shining or the wind is  
          blowing, the generated electricity spins the meter backward,  
          making it financially equivalent to using less electricity for  
          the customer with the same effect as the electric utility paying  
          the customer the full retail price for the electricity. 

          The full retail price includes the utility's cost of generating,  
          distributing and transmitting the power as well as other charges  
          including the energy crisis bond costs and public-purpose  
          program charges. By compensating the solar customer at the full  
          retail rate, the utility is using ratepayer funds to pay the  
          customer at a rate well above the value of the generated power  
          which is about one-third of the total cost of a typical  
          residential customer's bill. By compensating the solar or wind  
          customer at the full retail price, they do not pay any  










          transmission or distribution costs even though they are still  
          connected to the system and use it for all their generation  
          needs when the sun isn't shining and the wind isn't blowing.  
          Those unpaid transmission and distribution costs and public  
          goods charges are a subsidy, the cost of which is ultimately  
          shifted to all other ratepayers in the class. All customer  
          classes are eligible for net metering.

           Market Price Referent (MPR)  - The MPR is calculated annually by  
          the CPUC and represents the cost of a long-term contract with a  
          combined cycle gas turbine facility, levelized into a  
          cent-per-kWh value. This price is used in two programs. First,  
          under the RPS, it is used in order to evaluate the  
          reasonableness of prices of long-term power purchase agreement  
          (PPAs) for RPS-eligible electric generation. Second, the CPUC  
          has a 1.5 MW feed-in-tariff program for renewables and the MPR  
          is used as the purchase price for the renewable energy output  
          produced by an eligible renewable generating facility.

                                       COMMENTS
           

              1.   Super Size Me  - A fundamental principle of the CSI  
               program is that the subsidized PV system will be sized to  
               offset part or all of the customer's electrical load. This  
               bill deviates from that principle and permits a CSI  
               applicant to go beyond the size needed to meet their  
               electricity needs. The cost of the hardware for the excess  
               capacity would be paid for entirely by the customer (but  
               would be eligible for federal tax credits of up to 30  
               percent of the installation costs). Since the installation  
               costs of the excess capacity are being paid for by the  
               customer there would seem to be nothing wrong with this  
               provision. However, the excess capacity creates an adverse  
               ripple effect on the grid and for other ratepayers as  
               explained below.  


             2.   Grid Implications  - The need for a "Smart Grid" for the  
               delivery of electricity is a top priority for policy  
               makers. Why? Because we have a "dumb grid" in the United  
               States. This is acutely felt at the distribution level  
               where the grid is still largely in the same form it was  
               decades ago when it was designed to move electrons from a  










               generator, to a transmission line, to a substation, to a  
               distribution line, to the customer's home when they flip  
               the lights on. The structure and technology of the  
               distribution grid is so ancient that the utilities still  
               have little or no ability to determine when the lights go  
               out and still largely rely on phone calls from customers to  
               pinpoint the outage.  


                Efforts to make the grid smarter are underway by the  
               smallest utilities all the way to the White House but until  
               that grid is developed, it is not in the shape necessary to  
               send any great amount of electricity backwards on the  
               distribution system as this bill proposes. 


               To the degree that solar and other distributed generation  
               relies on the "dumb" distribution system to put excess  
               power back out onto the grid, the excess generation can  
               contribute to congestion and grid failure. Local  
               distribution grids were designed to deliver electricity to  
               homes and businesses, not to collect power from the  
               customers. While buy-back programs that have been created  
               in California are small enough in scale that distribution  
               systems can adequately handle the unscheduled power, if the  
               programs grow larger and larger before the grid impacts are  
               known and the grid upgraded, there will be risk of local  
               grid failures. Sizing customer systems to the power needed  
               for their own generation mitigates future grid impacts.  
               Because this bill allows customers to over-size their  
               generation systems, it will exacerbate those grid impacts  
               while providing little or no ratepayer benefits.


               This is one of the reasons why net-metering is limited in  
               law thus providing policy makers and the utilities the time  
               necessary to evaluate the impacts of excess generation back  
               onto the grid and to make the necessary improvements to  
               manage that excess.


               Generation from local PV systems, when strategically  
               placed, can be valuable to the distribution grid. An  
               example would be an inland area with high heat and high air  










               conditioning use. PV can mitigate the peak load and reduce  
               the congestion. However, if not strategically placed, PV  
               systems in great quantity can have the reverse affect and  
               actually shut down the grid due to congestion. Because the  
               placement and size of the PV systems would be completely  
               under the customer's control in this bill, adverse grid  
               impacts could not be controlled for by the utility.  


             3.   Customers as Generators  - Advocates of this bill and  
               similar proposals argue that increasing the generation of  
               green power at any point on the grid is a great thing for  
               ratepayers and utilities and should be encouraged. Some CSI  
               customers that already generate excess power coincident  
               with fluctuating weather patterns or other factors think  
               that the utility is "making money off of them." This is not  
               the case. When a customer generates excess power at the end  
               of the distribution system, the utility generally doesn't  
               know it's there until the end of a billing cycle when they  
               see that there was excess generation recorded on the  
               manually read meter. In the meantime, the utility has  
               procured power from other centralized sources for that  
               service area in which the CSI system is installed and  
               delivered it accordingly. Additionally, because the  
               customer is not a traditional generator under contract with  
               the utility, it is under no obligation to deliver power to  
               customers providing no reliable source of electricity to  
               the utility or other ratepayers. 


             If a customer wants to be a generator there is a program  
               specifically designed for customers that install renewable  
               resources up to 1.5 megawatts capacity. The customer is  
               offered a standardized contract for delivery, priced at the  
               MPR, and interconnected to the utility.  The customer is  
               then contractually bound to the utility to deliver power  
               and subject to other requirements that a CSI customer is  
               not.  The customer can use power generated to offset their  
               own electrical load, but they are not eligible for CSI  
               rebates or net-metering.
              4.   Excess Generation  - The author is also concerned about  
               perceived inequities in the current net-metering program  
               for CSI customers.  She is aware of constituents who have  
               installed solar but are generating more electricity in a  










               12-month net-metering cycle than they can use.   
               Consequently, the customer sees unused electricity for  
               which they receive no compensation and feel that they  
               should be compensated for that excess generation.

               The utilities and CPUC have reported that there is excess  
               generation occurring for some customers.  According to the  
               CPUC, "there are a number of customers whose systems for a  
               wide range of reasons -- ranging from not understanding net  
               metering?to changing utility rates, installation of energy  
               savings measures and/or climatic variation in a given year  
               -- have produced more electricity than the customer has  
               consumed?Better public outreach by the utilities about  
               optimal system sizing, and how net metering actually works  
               is also necessary to educate customers."

               The perception that the utility is receiving something of  
               value without compensating the customer ignores two  
               factors.  First, that the utility cannot generally plan on  
               generation being available or track it as explained in  
               comment #3 above.  Second, through net metering the  
               customer has not only received credit for electricity  
               generation but has been completely relieved of paying for  
               the costs of transmission, distribution, and public goods  
               charges which can add up to as much as 2/3 of the full  
               retail rate for electricity delivery.  Because the  
               net-metered customer does not pay for their portion of the  
               transmission and distribution costs those costs are shifted  
               to ratepayers that do not have net metering or solar PV.

              5.   Time-of-Use Rates (TOU)  - For the purposes of  
               net-metering, most residential customers are metered under  
               flat rates.  However, most business customers have  
               net-metering in association with TOU rates for service.   
               For a customer on TOU the result is often a credit balance  
               in dollars for TOU but a deficit on an hourly basis.  At  
               the end of the customer 12 month net metering cycle when  
               usage is "trued-up" the customer can think they are owed  
               money.  This bill proposes that the customer receive  
               compensation from the utility that corresponds to the TOU  
               rates even though the customer was a net user of  
               electricity. 












              6.   Ratepayer Impact  - Small scale solar PV remains the most  
               expensive means of generating electricity. The Legislature  
               recognized this factor when it adopted the CSI but intended  
               to subsidize installations through a limited program in an  
               effort to stimulate the market and bring down prices. In  
               the meantime the program is heavily subsidized through  
               ratepayer subsidies for installations (CSI), taxpayer  
               subsidies (30% federal tax credit) and net metering. This  
               bill further subsidizes installations by compensating  
               customers for excess generation that floats out on to the  
               electricity distribution grid at ratepayer expense but with  
               the ratepayer receiving little or no benefit due to the  
               fact, as discussed in comment #3 above, that the utilities  
               have no ability to schedule or plan for the delivery of  
               these electrons to other customers. Consequently,  
               ratepayers would be paying for the generation of  
               electricity but receiving no reliable electrons in  
               exchange.


                                       POSITIONS
           
           Sponsor:
           
          Recolte Energy
          Sustainable Napa County

           Support:
           
          Dolce Winery
          Family Winemakers of California
          Far Niente Winery
          Nickel & Nickel Winery
          Oakland City Council
          3 individuals

           Oppose:
           
          Pacific Gas & Electric (unless amended)
          The Utility Reform Network (unless amended)

          
































          Kellie Smith 
          SB 7 Analysis
          Hearing Date:  April 21, 2009