Transmission Access Charges Campaign background materials

Key documents and presentations

Draft 2019 TAC bill language (December 2018)
SB 692, our previous TAC bill (2017)
Two-page TAC overview (October 2018)
White paper on TAC rate design (February 2018): Outlining the specific cost-shifting impacts, relationship to cost-causation, legal requirements, and specific technical aspects of TAC rate design.
Distribution System Operator (DSO) Future presentation (June 2017); download PPT and PDF
TAC Campaign Q&A (December 2016)
Transmission Access Charges market distortion explainer (November 2015)

Webinars

How to unleash DER in California by fixing transmission cost allocation distortions (May 10, 2018)
California’s transmission costs are exorbitant and growing fast, but the fix is easy (March 30, 2017)
CAISO avoiding fix to massive market distortion that harms local renewables and California ratepayers (December 1, 2016)
Local renewables are being robbed: Simple fix to massive market distortion caused by erroneous treatment of Transmission Access Charges (September 1, 2016)

Regulatory filings

15 June 2020 comments urging the Federal Energy Regulatory Commission (FERC) to deny a petition that constitutes federal overreach into an issue that must be left to the states. The petition would allow FERC to regulate any excess NEM energy sold to the utility as soon as it leaves the customer meter, which is a mistake considering that almost zero excess energy ever reaches the wholesale market (or uses the transmission system).
November 22, 2019 comments on the CAISO stakeholder process for Extended Day Ahead Markets (EDAM): Recommending a reform on measuring TAC.
October 9, 2018 comments on Transmission Access Charge Structure Enhancements: Draft Final Proposal: Comments on the CAISO draft final proposal that was published on September 17, 2018.
July 18, 2018 revised comments on CAISO’s second TAC structure straw proposal: Addressing the concerns and issues raised by CAISO with respect to its second straw proposal on the TAC structure.
June 15, 2018 letter opposing Assembly Bill 813 on CAISO expansion: Proposed CAISO expansion would not deliver the promised benefits and there are cheaper and more effective ways to address electric transmission issues.
April 25, 2018 comments on CAISO’s second TAC structure straw proposal: Addressing the concerns and issues raised by CAISO with respect to its second straw proposal on the TAC structure.
February 15, 2018 sign-on letter calling for TAC structural change: Submitted by the Clean Coalition; 29 distributed energy resource developers, environmental groups, and energy experts calling for a change in the TAC structure to charge transmission use charges for energy using the transmission grid.
February 15, 2018 Clean Coalition white paper developed on TAC rate design: Outlining the specific cost-shifting impacts, relationship to cost-causation, legal requirements, and specific technical aspects of TAC rate design.
February 15, 2018 comments on CAISO’s first TAC structure straw proposal: Addressing the concerns and issues raised by CAISO with respect to its first straw proposal on the TAC structure.
October 13, 2017 comments to the CAISO containing official Clean Coalition TAC proposal: Using the CAISO template based on the most recent stakeholder sessions.
September 27, 2017 comments to the CAISO proposing refinements to the flawed TAC estimating model: Pointing out that consideration of only approved projects will fail to account for projects that will be planned as new energy needs arise and therefore greatly underestimate future costs.
September 1, 2017 reply comments on Renewable Portfolio Standard (RPS) procurement plans from Load Serving Entities: Encouraging a steady market for distributed renewables and optimal usage of federal Production and Investment Tax Credits, and reiterating the importance of the TAC market distortion on distributed energy resources (DER) in any CPUC approved RPS procurement.
July 26, 2017 comments on CAISO’s “Review TAC Structure” stakeholder initiative: Proposing to change the TAC billing determinant to the transmission energy downflow. This would result in more accurate market signals for the cost of delivering energy, the deployment of more distributed energy resources, and massive ratepayer savings in avoided transmission costs.
January 10, 2017 comments to the California Energy Commission (CEC) on Renewable Energy Transmission Initiative 2.0: Emphasizing that California’s transmission needs to meet Renewable Portfolio Standards and greenhouse gas targets will require consideration of the growth of DG resources and paying close attention to the TAC issue.
January 9, 2017 comments on CAISO’s Stakeholder Initiative Roadmap: reviewing the TAC Structure stakeholder for inclusion in initiatives for January 2017.
September 29, 2016 comments in CAISO’s 2017 catalog of initiatives: Updating CAISO’s review of the TAC wholesale billing determinant and ensuring stakeholders are aware of the expanded scope and opportunity to participate in 2017.
August 25, 2016 comments in CAISO’s TAC Options initiative: Reviewing the working group proposals on how to assess TAC for new transmission projects under an expanded CAISO jurisdiction.
June 30, 2016 comments in CAISO’s TAC billing determinant initiative: Detailing the Clean Coalition’s proposal to fix the TAC market distortion by changing the billing determinant and responding to initial questions from CAISO staff.
June 10, 2016 comments in CAISO’s TAC Options initiative: Explaining how the Clean Coalition’s proposed TAC fix might apply in an expanded CAISO jurisdiction.
June 9, 2016 comments in CAISO’s ESDER initiative: Reacting to the creation of a separate stakeholder initiative and requesting a prompt review of the Clean Coalition proposal.
April 18, 2016 comments in CAISO’s ESDER initiative: Detailing the Clean Coalition’s proposal to fix the TAC market distortion by changing the TAC billing determinant.
February 10, 2016 comments in CAISO’s TAC Options initiative: Proposing a change in TAC billing determinant to resolve both the existing market distortion for distributed energy resources and assessing TAC in an expanded CAISO jurisdiction.
November 20, 2015 comments in CAISO’s TAC Options initiative:Identifying the distortive market impact of the current TAC assessment process on DER and highlighting ratepayer savings if the problem is fixed.
September 24, 2015 comments to the CEC: Raising awareness of the TAC market distortion.

Media coverage

How Two Simple Fixes Can Fairly Compensate the True Value of DERs in California | T&D World (2 June 2020)
How to protect California ratepayers, expand clean local energy and avoid bailing out PG&E | Utility Dive (May 13, 2019)
Making Energy Transmission Charges Fair To Solar Generators: A #CleanTechnica Q&A With Doug Karpa, Policy Director Of Clean Coalition | CleanTechnica (October 30, 2018)
CAISO Developing Transmission Access Charge Proposal | California Energy Markets (October 5, 2018)
Updating California’s Anti-Solar Utility Billing For Transmission | CleanTechnica (October 5, 2018)
California’s Alternative to Grid Regionalization: Expanding the Energy Imbalance Market | GTM Squared (September 7, 2018)
Exploding transmission costs are the missing story in California’s regionalization debate | Utility Dive (July 5, 2018)
Expanding the Energy Imbalance Market Is the Right Way to Regionalize California’s Grid | Greentech Media (March 13, 2018)
Let solar-roof savings shine on all ratepayers | Los Angeles Daily News (June 23, 2017)
California transmission fee overhaul could set a new deal for distributed solar | pv magazine (May 5, 2017)
Level the playing field for clean energy | The Sacramento Bee (March 6, 2017)
CAISO Ignores Massive Market Distortion that Harms Local Renewables | California Current (October 13, 2016)
Finding Equal Footing for Small Renewable Wholesalers | California Current (September 8, 2016)
California Weighs Fair Pricing for Distributed, Centralized Energy | Institute for Local Self-Reliance (July 18, 2016)
California local renewables are getting robbed, but CAISO can help | Utility Dive (June 16, 2016)
The Perils of Wholesale Distributed Generation: Can California Live Up to Its Promise? | Greentech Media (March 9, 2016)
Transmission Charges Penalize Local Clean Power in California | Microgrid Media (November 25, 2015)
In California, a Campaign to Take Transmission Charges Out of Distributed Energy | Greentech Media (November 17, 2015)

Press release

Legislation to level the playing field for local renewables in California is introduced by State Senator Ben Allen (March 1, 2017)