BILL ANALYSIS                                                                                                                                                                                                    �          1





                SENATE ENERGY, UTILITIES AND COMMUNICATIONS COMMITTEE
                                 ALEX PADILLA, CHAIR
          

          SB 489 -  Wolk                Hearing Date:  April 28, 2011      
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          As Introduced: February 17, 2011        FISCAL           B
                                                                        
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                                      DESCRIPTION
           
           Current law  requires the state's investor owned utilities 
          (IOUs), publicly owned utilities (POUs) (except the Los Angeles 
          Department of Water and Power), and other entities 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 (kWh), a procedure known as "net energy metering" (NEM).  
          Participation by all utilities is capped at 5 percent of each 
          utility's aggregate peak electricity demand and the size of 
          individual solar and wind systems is limited to those that will 
          offset all or part of the customer's own electrical requirements 
          to a maximum of 1 megawatt (MW).  This program also exempts the 
          customer from paying transmission and distribution costs.  This 
          is commonly referred to as full retail NEM.
           
          Current law  permits solar and wind NEM customers to roll-over 
          excess kWh beyond the first 12-month billing cycle or receive 
          compensation at a rate set by the CPUC for net surplus 
          generation. 
           
          This bill  expands eligibility for the full retail NEM to all 
          renewable resources eligible under the state's Renewable 
          Portfolio Standard program (RPS) and increases eligible systems 
          to a size of 1.5 MW.
           
          This bill  repeals an expired pilot project which for "wholesale" 
          NEM that permits biogas digester customer-generators to offset 
          their electricity usage with electricity generated from methane 
          emitted from manure or other forms of biogas digestion, sized to 
          offset part or all of the eligible biogas digester 











          customer-generator's own electrical requirements.

                                      BACKGROUND
           
          Net Energy Metering - The primary benefit of CSI program is 
          derived from the solar customer's eligibility for full retail 
          NEM 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 full retail NEM 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.  When 
          the sun stops shining and the wind stops blowing, the customer 
          draws electricity from the grid and their meter spins forward 
          using the credit on the meter.  In theory, depending on weather 
          patterns, system size and customer behavior, the customer will 
          have a zero energy bill at the end of a 12-month cycle.

          The full retail price of electricity includes the utility's cost 
          of generating, distributing and transmitting the power, public 
          goods programs (e.g. energy efficiency), low-income customer 
          assistance (e.g. CARE), energy crisis costs and other charges 
          not related to generation. By compensating the solar or wind 
          customer at the full retail rate, the utility is using ratepayer 
          funds to pay the solar or wind 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.  The solar 
          or wind customer does not pay transmission or distribution costs 
          even though they are still connected to the electrical grid and 
          use it for all their generation needs when the sun isn't shining 
          and the wind isn't blowing (approximately 18 hours a day).  
          Consequently, 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 NEM.

          Full retail NEM is really the foundation of what makes the CSI 
          so successful. Due to the intermittent nature of solar and the 
          costs of installation, rooftop systems would not pencil out for 
          most customers without the exemption from transmission and 










          distribution costs provided by full retail NEM.  The program is 
          known to be a subsidy but one thought worth its value by the 
          Legislature as part of its effort to stimulate the solar 
          industry and bring down the costs of solar.  The capacity of 
          full retail NEM is designed to coincide with the capacity goals 
          of the CSI and therefore has a form of sunset.

          NEM Cost Shift - The fundamental effect of NEM is that the 
          participating customer avoids the costs of transmission, 
          distribution and public goods charges which fund programs such 
          as the CARE and energy efficiency.  Because those costs are 
          fixed, if one class of ratepayers is excluded from paying those 
          costs, then those costs are shifted to the remaining ratepayers. 
           Transmission and distribution costs typically comprise one-half 
          to two-thirds of a customer's billing.  

          In March, 2010 the CPUC issued a report which analyzed the cost 
          of full retail NEM to non-NEM ratepayers.  At that point, based 
          on 386 megawatts of installed rooftop solar, the cost to non-NEM 
          ratepayers was estimated at $20 million per year.  Installed 
          rooftop solar is now over 800 MW so that cost has now at least 
          doubled.  Although the total net cost of the NEM at that point 
          was less than one-tenth of one percent of total utility revenue 
          average net cost, the more telling cost that was reported was 
          that full retail NEM amounted to a cost of $0.12 per kilowatt 
          hour (kWh) to non-NEM ratepayers.

          Biogas Digester Pilot - Another type of NEM is referred to as 
          "gen-to-gen" and was authorized for use for biogas digesters in 
          2002 as a pilot program.  The program netted out the customer's 
          generation from a biogas digester against generation charges by 
          the utility on a time-of-use basis. The eligible biogas 
          digesters were fueled by methane derived from manure and other 
          animal waste.  The program sunset in 2009 and was limited to 
          projects sized to 1 MW which offset part or all of a customer's 
          electrical load.  The CPUC was to report on the program but did 
          not.  Two utilities, San Diego Gas & Electric and Southern 
          California Edison, reported that they have, combined, only five 
          agricultural customers on this tariff; PG&E did not respond to a 
          request for data.

          Interconnection Challenges - At the heart of the issue presented 
          by the supporters of this bill is the time and cost involved in 
          connecting to the distribution grid, commonly referred to as 










          interconnection.  If a customer has renewable generation which 
          is sized to offset their own electric load such as a CSI 
          eligible solar system, a simplified interconnection process is 
          triggered and the interconnection fees for solar generation 
          sized less than 1 MW are waived.  These small-scale systems do 
          not export much power to the grid and by design have less risk 
          of negatively impacting the local distribution network. 

          The distribution grid was designed decades ago to move power 
          from the generator, to transmission, to distribution, and 
          ultimately to the end-user when they flip on the light switch. 
          Small scale generation (e.g. 1 to 3 MW) such as biogas digesters 
          call on the grid to move power backwards and are usually located 
          in very remote areas with even more limits on available capacity 
          on the distribution network which triggers extensive engineering 
          studies.  The resulting analysis calling for grid upgrades and 
          significant expense can make these small-scale renewable 
          projects economically unfeasible for the customer or small-scale 
          developer.

          This bill will not address that issue for small scale renewable 
          generators that want to sell excess electricity back to the 
          utility.  

          The challenges of interconnection are being studied by the CPUC 
          due to increasing demand for renewable interconnection on the 
          distribution grid.  According to the CPUC, small scale projects 
          can achieve quicker project development timelines compared to 
          largescale renewable energy projects as a consequence the 
          increase in market interest over the past two years has 
          overwhelmed the existing interconnection processes, leading to 
          an interconnection application bottleneck. 

          A number of challenges have been identified that impact both 
          project developers and grid operators as increasing volumes of 
          renewable DG attempt to interconnect to the grid.  As a result, 
          the CPUC's Energy Division created the Renewable Distributed 
          Energy Collaborative a working group that convenes utility grid 
          operators, renewable DG project developers, renewable DG 
          technology experts, and policymakers to better understand the 
          issues and identify solutions.  

                                       COMMENTS
           










              1.   Author's Purpose  . SB 489 proposes to open California's 
               Net Energy Metering (NEM) Program to all eligible forms of 
               renewable energy. This will allow agricultural businesses 
               and homeowners to more easily and economically convert 
               their renewable byproducts into clean renewable energy and 
               to off-set their electricity use, help reduce the need for 
               new power plants and transmission infrastructure and save 
               money on their power bills. Expanding the program will also 
               help the state reach both its greenhouse gas emissions 
               reduction goals and also its renewable energy goals. 

              2.   Baseload Generation & NEM  .  The unique characteristic of 
               wind and solar is the intermittency of the electrical 
               generation. Other renewables such as biomass and biogas 
               digesters can run to coincide with the customer's 
               electrical load. In doing so, the customer is able to avoid 
               using the electrical grid and incurring transmission and 
               distribution costs while running the generator. 
               Consequently, the need for full retail NEM is not the same 
               as it is for solar and wind. If the non-intermittent 
               customer-generator (e.g. biogas) were permitted to use full 
               retail NEM, they would be paid for excess generation not 
               just based on the price for the power generated and put 
               back on the grid but the retail price a customer would pay 
               for the power if they were drawing it from the grid which 
               would include transmission and distribution costs. 

               Moreover, it is not clear that the full retail NEM program 
               would actually serve the needs of these customers since the 
               eligible generation can only be sized to the customer's 
               average load over 12-months. Incidental surplus generation 
               created by fluctuating demand and weather patterns could be 
               compensated but the ag customer could not intentionally 
               oversize the system to meet the customers fuel supply (e.g. 
               manure, rice straw, nut hulls). 

              3.   Options  .  The committee is not aware of any reason why 
               all renewable generation on the customer's side of the 
               meter, and sized to offset all or a portion of the 
               customer's load, should not and could not take advantage of 
               net energy metering.  However, the cost shifts of full 
               retail NEM at $0.12 per kWh should be avoided by using the 
               gen-to-gen NEM.  The author and committee should consider 
               striking the content of this bill and instead reauthorizing 










               a gen-to-gen NEM program for all eligible renewable 
               resources.

               This bill also increases the size of an eligible renewable 
               facility under NEM to 1.5 MW from 1 MW.  One of the primary 
               reasons the sponsors are seeking a NEM tariff is that it 
               offers a simplified interconnection process at little or no 
               cost to the renewable generator.  If the facility size goes 
               over 1 MW this simplified process is lost due to increased 
               complexity required by the ISO and federal law.  The author 
               and committee should consider lower the facility size to 1 
               MW to ensure simplified interconnection is maintained.

              4.   Related Legislation  .  The following bills in the current 
               session also modify the NEM program:

                           AB 1023 (Wagner) - code maintenance bill.  
                    Status:  Set in Assembly Judiciary Committee, May 10, 
                    2011.
                           AB 1113 (Galgiani) - extends and expands the 
                    biogas digester gen-to-gen NEM program. Status:  
                    Pending hearing in Assembly Utilities & Commerce 
                    Committee.
                           AB 1361 (Perea) - increases the size of 
                    eligible generating solar and wind facilities under 
                    the NEM to 5 MW.  Status:  Set for hearing in Assembly 
                    Utilities & Commerce Committee April 25, 2011.
                           AB 1391 (Assembly Committee on U&C) - deletes 
                    an outdated reporting requirement.  Status:  Pending 
                    hearing in Assembly Natural Resources Committee.
                           SB 370 (Blakeslee) - permits aggregate NEM for 
                    agricultural customers.  Status:  Set for hearing in 
                    Senate Energy, Utilities & Communications Committee 
                    April 28, 2011.
                                       POSITIONS
           
           Sponsor:
           
          California Agriculture and Climate Network

           Support:
           
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          |Agriculture Council of          |Hedgerow Farms                  |










          |California                      |Lagier Ranches                  |
          |Almond Hullers & Processors     |Marin Sanitary Service          |
          |Association                     |Morris Grassfed Beef            |
          |California Alliance for Family  |National Center for Appropriate |
          |Farms                           |Technology                      |
          |California Certified Organic    |Okuye Almond Farm               |
          |Farms                           |Pena's Disposal Company         |
          |California Climate and          |Phippen Bros.                   |
          |Agriculture Network             |Ridge Vineyards                 |
          |California Farm Bureau          |Roots of Change                 |
          |Federation                      |Soil Born Farms Urban           |
          |California Refuse Recycling     |Agriculture &                   |
          |Council                         |     Education Project          |
          |Californians Against Waste      |Solano County Board of          |
          |Center for Land-Based Learning  |Supervisors                     |
          |Clean World Partners            |Sustainable Agricultural        |
          |Clover Flat Landfill            |Education                       |
          |Community Alliance with Family  |Sustainable Conservation        |
          |Farmers                         |Travaille and Phippen, Inc      |
          |Dixon Ridge Farms               |Upper Valley Disposal Service   |
          |Earthbound Farm                 |Yolo County Board of            |
          |Ecological Farming Association  |Supervisors                     |
          |Environmental Defense Fund      |                                |
          |Food & Water Watch              |                                |
          |Full Belly Farm                 |                                |
          |                                |                                |
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           Oppose:
           
          California Municipal Utilities Association
          Southern California Edison
          






















          Kellie Smith 
          SB 489 Analysis
          Hearing Date:  April 28, 2011