BILL ANALYSIS                                                                                                                                                                                                    �



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          SENATE THIRD READING
          SB 1537 (Kehoe)
          As Amended  May 1, 2012
          Majority vote 

           SENATE VOTE  :32-6  
           
           UTILITIES & COMMERCE            10-2                
          APPROPRIATIONS      11-5        
           
           ----------------------------------------------------------------- 
          |Ayes:|Bradford, Fletcher,       |Ayes:|Blumenfield, Bradford,    |
          |     |Buchanan, Fong, Roger     |     |Charles Calderon, Campos, |
          |     |Hern�ndez, Huffman, Ma,   |     |Davis, Gatto, Hall, Hill, |
          |     |Nestande, Skinner,        |     |Lara, Mitchell, Solorio   |
          |     |Swanson                   |     |                          |
          |     |                          |     |                          |
          |-----+--------------------------+-----+--------------------------|
          |Nays:|Fuentes, Knight           |Nays:|Harkey, Donnelly,         |
          |     |                          |     |Nielsen, Norby, Wagner    |
           ----------------------------------------------------------------- 

           SUMMARY  :  Prohibits the California Public Utilities Commission 
          (PUC) from adopting any new charges that only apply to customers 
          with a net metering tariff until January 1, 2014.  Specifically, 
           this bill  :   

          1)Imposes a moratorium on PUC from adopting any new demand 
            charge, standby charge, customer charge, minimum monthly 
            charge, interconnection charge, or other fixed charge that 
            applies only to Net Energy Metering (NEM) customers who 
            receive net metering pursuant to Public Utilities Code Section 
            2827.

          2)Sunsets this moratorium on January 1, 2014.

           FISCAL EFFECT  :  According to the Assembly Appropriations 
          Committee, negligible fiscal impact to PUC.

           COMMENTS  :   

           Author's Statement  .  A recent filing by San Diego Gas and 
          Electric Company (SDG&E), subsidiary of Sempra Energy, exposed 
          solar producers' vulnerability to drastic electric rate 
          restructuring.  In SDG&E's filing they proposed to increase 
          certain charges paid by solar producers by over 600% while only 






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          increasing the same charge to non-solar producers by 52%.  The 
          overall bill impact for a typical solar producer would be an 
          increase of 40% or more and only a 6% increase to a non-solar 
          producer.  The filing would disproportionately increase costs to 
          solar producers when compared to non-solar producers.

          In recent years, many entities that have gone solar have done so 
          using a financing mechanism which amortizes the cost of their 
          investments over as much as 25 years.  The savings these 
          entities realize on their electricity bills often times just 
          barely offset the cost of the financing. By introducing drastic 
          rate hikes on solar producers such as those contemplated by 
          SDG&E, many times these entities' investments will go upside 
          down, resulting in a solar producer having a total monthly cost 
          greater than those who do not have solar.  Among the largest 
          investors in solar technology in the state are school districts, 
          water districts, and local governments. Drastic electricity rate 
          fluctuations have the potential to derail this state's renewable 
          energy goals.

           Net Energy Metering  .  Under NEM, the electric utility is 
          required to "buy back" all electricity generated by a 
          customer-owned generator that is not consumed by the customer 
          on-site.  The price is set by the applicable retail rate under 
          the customer's existing contract.  When the customer generates 
          electricity, he/she uses most of it for his or her own facility. 
           At the end of each 12-month NEM period, the electric 
          corporation calculates the amount of electricity distributed to 
          the grid by the customer and reduces the customer's annual bill 
          by the amount of electricity generated by the customer.  If the 
          customer consumes more electricity than their facility 
          generates, the utility calculates a bill based on the net 
          consumption of utility delivered in kilowatthours.

           Who pays for NEM  ?  The cost of NEM is paid by ratepayers.  The 
          cost of NEM is  not  paid by utility shareholders (in the case of 
          a publicly owned utility, there are no shareholders, only 
          ratepayers).  NEM allows utility customers to avoid paying for 
          the costs of using transmission and distribution infrastructure 
          and maintenance.  Those costs are then shifted to the non-NEM 
          customers.  In addition, NEM customers are allowed to use excess 
          bill credits to offset their obligation to contribute to public 
          goods programs, such as the low-income assistance program, 
          energy efficiency programs, and renewable energy rebates 
          (customers on low-income assistance programs are exempt from 
          paying charges for public goods programs).






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           Who benefits from NEM  ?  If the customer leases or enters into a 
          Power Purchase Agreement (PPA) for a solar facility on their 
          premises, the financier monetizes the value of NEM by charging 
          customers either a monthly fee or a charge for electricity.  The 
          monthly fee or charge is calibrated to provide a net discount of 
          approximately 10% off of the customer's pre-solar electricity 
          bill.  This allows the financier to "monetize the value of NEM." 
           The financier also retains the federal tax credit and 
          depreciation, the state solar incentive, ownership of the 
          renewable and environmental attributes.  They also retain 
          ownership of the solar facility and retain the right to approve 
          any change in ownership of the premises upon which the solar 
          facility is located.  In some contracts, the monthly charge 
          escalates annually over the term of the contract. 

           NEM cost shift  .  Because the cost of NEM is paid for by 
          ratepayers, the Legislature has limited the total capacity 
          (megawatts) of NEM accounts (since its inception) based on 
          aggregated peak demand, in order to limit the costs that NEM 
          shifts onto other ratepayers utility bills.  The Legislature has 
          periodically raised the cap.  In 2010, the Legislature approved 
          a cap on NEM equal to 5% of aggregated peak demand.  Recently, 
          PUC decided to redefine the phrase "aggregate peak demand" which 
          resulted in a significant and controversial expansion of the 
          full retail NEM program.  The action was contrary to legislative 
          history.  
           
          Network Use Charge  .  In 2011, SDG&E, as part of its general rate 
          case proposed a new rate element called a Network Use Charge 
          (NUC) for all customers.  The impact of NUC would have been to 
          charge customers for their actual use of the electric 
          distribution grid as power comes in from the grid and, in the 
          case of solar customers, as power is exported to the grid.  The 
          solar industry complained that NUC charge would adversely impact 
          the market for solar because the facility economics would be 
          undermined.  PUC dismissed NUC proposal from the rate case.

           Moratorium on NEM applies only to Investor Owned Utilities 
          (IOUs)  .  While there are six IOUs serving Californians, there 
          are also 45 electric Publicly Owned Utilities (POUs) in 
          California serving approximately 25% of all Californians.  This 
          bill does not apply to POUs.  Most POUs in California already 
          limit NEM credits so that the cost of using and maintaining 
          utility services must be paid by NEM customers.  In regions 
          served by the Sacramento Municipal Utility District and Los 






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          Angeles Department of Water and Power, the solar market appears 
          to be thriving.

           PUC examining rate structures  .  PUC issued an Order Instituting 
          Rulemaking to examine residential rate structures.  Excerpts 
          from PUC order illustrates the complexity of statutory 
          restrictions on rate design that have allow NEM subsidy to be 
          maximized:

               A potential benefit of establishing a different rate 
               design could be a smoother transition for NEM 
               customers.  Each IOU has requested changes to the 
               rates structures to accommodate the increasing amount 
               of electricity generated by such customers.  The 
               current policy for NEM customers offers a bill credit 
               to offset the customer's electricity bill at fully 
               bundled residential rates.  NEM customers avoid paying 
               all charges that comprise the bundled rate for the 
               amount of generation they produce.  Some of these 
               costs are then borne by non-participating customers 
               who fall into Tiers 3 and 4, which have raised equity 
               concerns about cost-shifting.  Additionally, this may 
               also allow NEM customers to avoid paying for 
               distribution grid upgrades needed to integrate their 
               generation.  A more efficient and equitable rate 
               structure could address these "cost causation" issues 
               in a fairer manner, and in a way that does not harm 
               solar investments.


           Analysis Prepared by  :    Susan Kateley / U. & C. / (916) 
          319-2083 


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