We influence energy regulation on the national and state levels by providing decision-makers with information, analysis, and proven solutions. To advance forward-looking energy policies, the Clean Coalition is in the trenches shaping regulatory processes that result in decisions that can make or break our nation’s clean energy future. Below is a list of filings and related documents that the Clean Coalition has officially submitted in 2019 and 2020. For the previous decade of Clean Coalition filings, see this page.
CPUC: Microgrids — ALJ Ruling Requesting Comment on Alignment with the CPUC’s Environmental and Social Justice (ESJ) Action Plan 2.0 | 19 April 2024
The Clean Coalition’s comments contextualize alignment with the ESJ Action Plan in this proceeding as meaning that the Commission should adopt a viable tariff that will result in Community Microgrid deployments in ESJ communities in a timely manner. We explain that our Resilient Energy Subscription (RES) proposal – a $/kWh subscription fee-based market mechanism – aligns with Goals 1, 2, 3, 4, 7, and 9 of the ESJ Action Plan 2.0. Promoting renewables-driven Community Microgrids will result in an unparalleled trifecta of economic, environmental, and resilience benefits in the ESJ communities where they are deployed. The RES enables such deployments to be scalable, serving additional parts of the Community over time, and financeable, with cost-effective resilience for critical loads at Critical Facilities and subscribers.
CEC: 2024 Integrated Energy Policy Report (IEPR) — Comments on Scope for 2024 IEPR | 5 April 2024
The Clean Coalition urges the Energy Commission to ask the fundamental question, “what steps are needed to get the state back on track to achieve its climate and energy goals?” as an overarching theme for the 2024 IEPR. We note the lack of development of community-scale renewables, point out the problem of long timelines for capacity projects to complete both a front-of-meter interconnection & the deliverability study process, underscore that the state can save the ratepayers billions by smartly siting distributed generation in addition to utility-scale resources, and identify the Transmission Access Charges (TAC) market distortion as a critical issue that artificially depresses the value of distributed generation and increases the difficult of reaching state procurement targets.
CPUC: Community Solar — Reply Comments on Proposed Decision | 1 April 2024
The Clean Coalition emphasizes consensus amongst parties that the CPUC’s proposed new Community Renewable Energy Program (CREP) will not work, diving into a litany of issues from insufficient compensation to flaws in the existing PURPA Feed-In-Tariffs to a lack of consideration of integral programmatic details to a lack of compliance with the CEC’s Title 24 Building Standards. We note vast support for the Net Value Billing Tariff (NVBT) and promote legal arguments that justify the NVBT as a retail program and not a wholesale transaction. These comments pave the way for the CPUC to reject the CREP and adopt the NVBT.
CPUC: Community Solar — Opening Comments on Proposed Decision | 25 March 2024
The Clean Coalition criticizes the Commission for rejecting the Net Value Billing Tariff and instead selecting two failed PURPA Feed-In-Tariffs (ReMAT and the Standard Offer contract (SOC)) as base compensation for a new Community Solar program. Both ReMAT and the SOC are priced far too low to interest developers, have program intricacies that are incompatible with Community Solar, and the Commission provides no detail about how a new Community Solar program would be counted toward capacity targets for the existing programs. We argue that the PD fails to properly value the full benefits from Community Solar, especially Infill Solar, and urge the Commission to use the Clean Coalition’s original Feed-In-Tariff design based on the Feed-In-Tariff we designed for the City of San Diego and LADWP’s FIT+ program. Lastly, we lament that requiring Community Solar projects to use a front-of-meter interconnection with the utility’s WDAT processes adds years to the interconnection process and at least $0.02-$0.04/kWh in costs which will prevent an already dormant Community Solar market from maturing.
CPUC: Virtual Net Energy Metering — Protest of PG&E Advice Letter 7175-E | 5 March 2024
The Clean Coalition protests PG&E’s implementation of the new Virtual Net Energy Metering (VNEM) tariff due to the lack of information or technical specifications on how a VNEM system can be used for resilience during a grid outage. The lack of clarity/additional information in the two years since language about resilience was initially added to the VNEM 2.0 tariff represents a lack of effort on PG&E’s part to create a standard process, effectively putting resilience out of reach for multi-unit housing and other multi-meter facilities. We promote master metering as a crucial solution that will solve the lack of options for resilience.
CPUC: Virtual Net Energy Metering — Protest of SCE Advice Letter 5203-E | 4 March 2024
The Clean Coalition protests SCE’s implementation of the new Virtual Net Energy Metering (VNEM) tariff due to the lack of information or technical specifications on how a VNEM system can be used for resilience during a grid outage. The lack of clarity/additional information in the two years since language about resilience was initially added to the VNEM 2.0 tariff represents a lack of effort on SCE’s part to create a standard process, effectively putting resilience out of reach for multi-unit housing and other multi-meter facilities. We promote master metering as a crucial solution that will solve the lack of options for resilience.
CPUC: 2024 Update to the Avoided Cost Calculator — Opening Brief | 21 February 2024
The Clean Coalition’s Opening Brief underscores the need to fully value avoided transmission in the ACC for proper compensation of distributed energy resources (DER). We acknowledge that a detailed study will be conducted in time for the 2026 ACC and urge the CPUC to use an interim value for SCE and SDG&E based on the methodology adopted for PG&E in the 2022 ACC update, Lastly, we support SEIA’s proposal to incorporate the costs of policy-related transmission projects (currently valued at $0) in the existing modeling for the state resource portfolio for more accurate ACC outputs.
CPUC: Virtual Net Energy Metering — Protest of SDG&E Advice Letter 4383-E | 19 February 2024
The Clean Coalition protests SDG&E’s implementation of the new Virtual Net Energy Metering (VNEM) tariff due to the lack of information or technical specifications on how a VNEM system can be used for resilience during a grid outage. The lack of clarity/additional information in the two years since language about resilience was initially added to the VNEM 2.0 tariff represents a lack of effort on SDG&E’s part to create a standard process, effectively putting resilience out of reach for multi-unit housing and other multi-meter facilities. We promote master metering as a crucial solution that will solve the lack of options for resilience.
CPUC: Income Graduated Fixed Charges — Reply Comments on ALJ Ruling on Implementation Budget and Timing Issues (Track A) | 12 February 2024
The Clean Coalition’s reply comments underscore the fact that the record of the proceeding does not support a Fixed Charge as being the best solution to increase the pace of electrification, nor even a solution that is beneficial. We protest the Joint IOU’s arguments about high charging costs limiting EV adoption to wealthier income as a red herring that ignores the main factor in switching: a high up-front capital cost priced beyond what many LMI customers can handle. We advocate for transitioning customers to electrification rates, reforming the volumetric rate with a lower winter off-peak rate, and reiterate the significant consequences from proposals for a high Fixed Charge.
CPUC: Integrated Energy Policy Report (IEPR) — Comments on Proposed Final 2023 IEPR | 9 February 2024
The Clean Coalition appreciates the detailed recommendations on interconnection reform in the proposed 2023 IEPR, including Clean Coalition’s suggestions on data transparency, improved ICA maps, and automation. We detail a number of other solution that should be included in the recommendations section, needed to greatly improve the viability of the interconnection process, particularly in the wholesale distributed generation market segment (that interconnects via the WDAT).
CPUC: Transportation Electrification — Reply Comments on Order Instituting Rulemaking | 5 February 2024
The Clean Coalition’s reply comments on the Order Instituting Rulemaking (OIR) support the Commission’s decision to create a single holistic proceeding that addresses the big picture when it comes to transportation electrification. We argue that the proceeding should consider a number of issues, including resilience & microgrids, lowering ratepayer costs through managed charging, the need for greater transparency and granular data related to grid planning, shifting consumer behaviors, EV uptake, and equity issues (such as most low-income residents working 9-5 jobs, making them unable to charge during ideal grid conditions, and low existing DER/EV deployment rates in disadvantaged communities).
CEC: Non-Energy Benefits — Petition for Rulemaking | 5 February 2024
The Clean Coalition joins the Center for Biological Diversity and other petitioners in requesting that the Energy Commission include non-energy benefits and social costs into the resource planning framework. Currently the Energy Commission acknowledges that these externalities have value and should be considered in the decision-making process, but do not have any any methodology in place, nor is there a plan to practically value the non-energy benefits from DER. If approved, this petition will fundamentally change the way that the state plans for new grid infrastructure and designs the electric resource portfolio.
CPUC: General Order 131-D (Expedited Transmission Planning) — Comments on Phase II Issues | 5 February 2024
The Clean Coalition’s joint comments with the Center for Biological Diversity and the Protect our Communities Foundation advocate that the CPUC should take the role of the lead agency in studying environmental effects from proposed transmission projects. We argue that the Permit-to-Construct (PTC) process should be differentiated based on projects constituting substantial impacts and non-substantial impacts, ensuring that the PTC process does not become a tool to avoid CEQA. We urge the Commission to include a greater analysis of DER alternatives, to consider lifetime project costs, and to reject any IOU proposals from the Phase I proposed settlement agreement.
CPUC: Microgrids — Reply Comments Responding to Opening Comments on Optional Community Microgrid Tariff Submissions | 26 January 2024
The Clean Coalition’s reply comments highlight the consensus support amongst parties for our Resilient Energy Subscription (RES) proposal. We discuss our support for allowing Community Microgrids to operate as one controllable entity (during blue sky operations), urge the Commission to value the full range of benefits created by Community Microgrids, note the need for front-of-meter interconnection reform, suggest that Community Microgrid resources should be studied in tandem, and support capacity compensation mechanisms proposed by other parties.
CPUC: Income Graduated Fixed Charges — Comments On ALJ Ruling on Implementation and Timing Issues | 24 January 2024
The Clean Coalition’s comments explain that high Fixed Charges do not promote electrification and instead recommend volumetric rate reform, to promote lower off-peak rates that best match the demand profile under electrification scenarios. We argue that adopting a high Fixed Charge is like bailing water on a ship with a hole in it and advocate that the Commission should prioritize rate reform along with curbing the underlying cost drivers of electric rates, namely spending on transmission infrastructure.
CPUC: Microgrids — Comments in Response to Optional Community Microgrid Tariff Submissions | 12 January 2024
The Clean Coalition’s response to Community Microgrid proposals supports the consensus around the need for more bankable value streams for Community Microgrids, including avoiding Transmission Access Charges (TAC), the vale of resilience, distribution deferral, non-energy benefits, wildfire mitigation, facilitating electrification, etc… We highlight GPI’s comments about the need to commercialize Community Microgrids through standard and replicable models rather than unique projects and non-replicable configurations and reiterate support for Sunnova’s Master Metered Housing Community Microgrid proposal.
CPUC: Microgrids — Optional Community Microgrid Tariff Submission | 15 December 2023
The Clean Coalition’s submission details the Resilient Energy Subscription (RES), a revolutionary fee-based market mechanism that enables the establishment, enhancement, and expansion of Community Microgrids designed around Critical-Community Facilities (CCFs). Our comments explain how to determine an appropriate level of resilience for individual facilities by tiering loads and underscore that the same can be done for an entire distribution grid area, with socialized costs for critical loads at CCFs. We demonstrate how the RES would be applied to different sized Community Microgrids using examples from the Goleta Load Pocket and highlight the multifaceted benefits of Community Microgrids (which will increase over time as we are more reliant on electricity due to electrification/decarbonization).
CPUC: Community Solar — Reply Comments on ALJ Ruling Setting Record Aside and Taking Comments | 7 December 2023
The Clean Coalition’s reply comments note that a successful Community Solar market is imperative to meet the state’s clean energy/reliability goals, which makes a program that properly values essential. We request a full valuation of the benefits of infill solar and inclusion of an option for deployments of unbundled storage. We also reject SCE’s critiques of the Net Value Billing Tariff (NVBT) and SCE’s proposal for a PURPA-based program, advocate for locational benefits, note that proposed program guardrails (program cap, sunset date, and siting limitations) are unnecessary at the moment, and advocate for streamlined interconnection of NVBT projects using Rule 21.
CPUC: DER Deferral (DIDF) — Advice Letters Requesting the Commission Allow No Further 2023 DIDF RFO Solicitations | 5 December 2023
The Clean Coalition’s protest urges the Commission to reject the IOU’s Advice Letters due to the millions of dollars’ in ratepayer savings from successful deployments of DER deferral projects. We note that SDG&E’s arguments for removal of resiliency as a DER deferral option entirely are concerning, given the opportunity for third parties to procure projects which have already approved by the Commission (meaning 100% certainty that a successful bid will lead to a constructed project) and out of scope for this proceeding. We note that SCE’s request to not solicit the deferral of a transformer ignores past success from similar deployments and global supply chain constrains for transformers and suggest that PG&E should solicit two substation projects with overall “positive scores”.
CPUC: Community Solar — Opening Comments on ALJ Ruling Setting Record Aside and Taking Comments | 27 November 2023
The Clean Coalition’s comments advocate for the adoption of unbundled (virtual) storage as the best way to increase the value to the ratepayers and result in direct grid benefits. We underscore that deployments under the Net Value Billing Tariff (NVBT) should reduce the local Load Serving Entity’s (LSEs) requirement for Local Resource Adequacy (RA) via a reduction in the CEC’s peak load calculation. We also note that the proceeding record does not support adding a sunset date or program cap and urge the Commission to allow for usage of Rule 21 for interconnection, rather than the time-intensive/costly WDAT (and deliverability) study process.
CPUC: Avoided Cost Calculator — Rebuttal Testimony on the 2024 ACC Staff Proposal | 20 November 2023
The Clean Coalition’s Rebuttal Testimony reiterates the need for a fully updated avoided transmission methodology, given the fact that the Commission is now using the ACC directly as a mechanism to determine compensation for DER programs. We argue that putting off the update to 2026 will actively result in an improper value stacks with less-than-appropriate compensation for customers enrolled in NEM, VNEM, Community Solar, and Energy Efficiency programs.
CEC: SB 100 Report — Comments on SB 100 Workshop on Modeling Inputs | 14 November 2023
The Clean Coalition’s comments support the Energy Commission’s focus on accurately modeling a reasonable target for distributed front-of-meter (FOM) capacity to help the state hit clean energy targets. We urge the Energy Commission to analyze the value of the Vibrant Clean Energy study, which concludes that ratepayers will save $120 billion with smartly sited DER (along with utility-scale deployments) and suggest that 12.5 GW is an ideal target. Through analysis of CAISO data from the near-outage situation on 6 September 2022, our comments demonstrate that 12.5 GW of local solar would have been more than enough to reduce peak transmission usage and ensure that an outage did not occur. Finally, we underscore that the value of DER deployed in load pockets or managed by a Distribution System Operator will increase over time, adding another incentive to include a high target for FOM DER in the SB 100 Report.
CPUC: Microgrids — Reply Comments on the IOU’s Community Microgrid Enablement Tariff (CMET) | 13 November 2023
The Clean Coalition’s reply comments underscore the need for overall certainty (with regards to process/timelines, design requirements, and expected costs) in a tariff intended to enable Community Microgrid deployments. We note that there is a complete lack of data from PG&E about the Community Microgrid Enablement Tariff (CMET) and correlate the lack of success with the need to make fundamental changes to fully commercialize microgrids. We advocate for a unified interconnection process for Community Microgrid resources, argue that islanding for economic reasons will benefit the ratepayers (through GridOptimal performance), underscore the fundamental need for a fee (like the Resilient Energy Subscription, RES) to recover costs, and discuss the benefits of residential master metering at multi-unit housing facilities.
CPUC: Income Graduated Fixed Charges — Reply Briefs | 3 November 2023
The Clean Coalition’s reply brief explains that our streamlined proposal meets the statutory requirements of AB 205, avoiding the creation of a massive subsidy from small residences to large homes, and urges the CPUC to adopt our three-tiered proposal (with tiers for CARE, FERA, & everyone else) as well as fixed cost categories. We then note that proponents of high Fixed Charges have been unable to mitigate the negative implications on energy efficiency, load shaping, and conservation; just as important, we explain that the record does not reflect that a High Fixed Charge is necessary to enable, or is beneficial for, electrification.
CPUC: General Order 131-D (Expedited Transmission Planning) — Response to the Joint Motion to Adopt the Settlement Agreement | 30 October 2023
The Center for Biological Diversity and the Clean Coalition’s response firmly opposes the IOU’s proposed settlement as illogically trying to change the Scoping Memo, not reflecting the proceeding record, and attempting to include solutions to issues from Phase 2. We urge the CPUC to focus on implementing SB 529 in Phase 1 as was scoped into the proceeding, rather than adopting a premature settlement agreement.
CPUC: Avoided Cost Calculator — Opening Testimony on the 2024 ACC Staff Proposal | 30 October 2023
The Clean Coalition’s testimony advocates that the CPUC should reject any ACC update that does not include an updated avoided transmission methodology, given the mandate requiring a methodology change in the decision adopting the 2022 ACC. In addition to our concern about the lack of initiative by Energy Division staff in making the required change to the specified avoided transmission value, we request the creation of an unspecified avoided transmission value, and explain why avoided Transmission Access Charges should be included (to value reduced congestion and line losses plus improved economic outcomes on the transmission system).
CPUC: Microgrids — Opening Comments on the IOU’s Community Microgrid Enablement Tariff (CMET) | 27 October 2023
The Clean Coalition’s comments underscore that a successful Community Microgrid tariff needs better certainty (process/timeline certainty, design certainty, and cost certainty) than what is contained in the Community Microgrid Enablement Tariff (CMET) submitted by the IOUs. We detail our Resilient Energy Subscription (RES) fee-based proposal to establish, enhance, and expand Community Microgrids around Critical Community Facilities and explain why this proposal will lead to the widespread deployment of Community Microgrids.
CPUC: Income Graduated Fixed Charges — Opening Briefs | 6 October 2023
The Clean Coalition’s Opening Brief underscores why our proposal meets the requirements of AB 205 and is the most practical to implement. We detail how high Fixed Charges upend incentives for conservation, energy efficiency, electrification, and on-site generation and advocate for volumetric rates with a higher on-peak off-peak price differential. We conclude by urging the Commission adopt our proposal and fixed cost categories, rather than authorized a second version Fixed Charge.
CPUC: General Order 131-D (Expedited Transmission Planning) — Reply to Motion of the Joint IOUs | 4 October 2023
The Joint Parties oppose the Joint IOU’s Motion to for Expedited Treatment and to Amend the Scoping Memo. We explain how the Joint IOUs are attempting to settle issues from Track 1 and 2 of the proceeding with relying on the existing proceeding record or the difficulty for other parties to fully analyze and comment in time.
CPUC: Distribution Planning Process — Reply Comments in Response to IOU’s Response to Amended Scoping Memo Appendix A | 28 September 2023
The Clean Coalition’s reply comments focus on the value of DER deferral and urge the Commission to prioritize the evaluations of DER solutions in the Distribution Planning Process. We note that two DER deferral projects in SCE’s service territory resulted in $7.56 million in ratepayer savings and that distributed projects will save both money and time.
CEC: SB 100 Kickoff Workshop — Comments on SB 100 Kickoff Workshop | 15 September 2023
We urge the Energy Commission to forecast a scenario with a high penetration of DER and underscore the multifaceted benefits from DER including economic, environmental, and resilience benefits. We also discuss how DER fit in with the state’s broader vision for the future and are vital to achieving clean energy & electrification goals.
CPUC: Upcoming Proposed Decision — Ex parte meeting with President Reynolds’ Office | 6 September 2023
This slide deck advocates that President Reynolds should write a Proposed Decision that compensates the full value of Infill Solar. We discuss how this additional value from Infill Solar (as opposed to remote ground solar projects) should be compensated through avoiding Transmission Access Charges and the Power Charge Indifference Adjustment. We discuss the significant siting potential of Infill Solar, advocate for virtual (unbundled) storage, using the ACC rather than LCBF, and the insufficiency of the existing programs.
CPUC: Proposed Decision Address Remaining Issues — Reply Comments on Proposed Decision | 28 August 2023
The Clean Coalition’s reply comments note the difficulty of getting information on the virtual net energy metering program (VNEM) from customer-facing divisions of the IOUs and note that this PD will make things more confusing for participating ratepayers. We request an Alternative Proposed Decision that includes property-level netting since energy flows to nearby loads and pathways to deploy storage and resilience solutions. Finally, we point out that this PD will adversely impact renters and low-income Californians, which is opposite to what the Commission is attempting to do.
CPUC: ALJ Ruling on Implementation Pathways for Income Graduated Fixed Charges — Reply Comments on ALJ Ruling | 21 August 2023
The Clean Coalition’s reply comments underscore the need to consider impacts on electrification, conservation, efficiency, and self-generation from implementing a fixed charge. We urge the Commission to adopt our low fixed charge, reject any high fixed charge proposal, and move forward with a greater time-varying TOU rate. Finally we explain why the Joint IOUs proposal is actually three different proposals that should not be adopted and highlight that NRDC/TURN including the PCIA in their proposal is enough to remove it from consideration.
CPUC: ALJ Ruling on Scope of Work for Consultant and Data Working Group — Opening Comments on ALJ Ruling | 11 August 2023
The Clean Coalition’s opening comments request the inclusion of resilience and interconnection-related data issues in the scope of the data working group. We also advocate for a discussion of non-energy benefits, since this proceeding is the appropriate forum to do so.
CPUC: ALJ Ruling Setting Aside the Record and Questions on Cost-Effectiveness — Reply Comments on ALJ Ruling | 10 August 2023
The Clean Coalition’s reply comments underscore the unique value that infill projects create beyond what is valued in the Avoided Cost Calculator (ACC) and make the case that avoiding Transmission Access Charges (TAC) and the Power Charge Indifference Adjustment (PCIA) is the appropriate way to compensate the value creation. We challenge the IOUs by proving why the ACC is the appropriate tool to use for valuing distributed generation and advocate for the Commission to allow unbundled storage in the program to maximize the value from economies of scale.
CPUC: Electrification Impacts Study Part 1 — Reply Comments | 7 August 2023
The Clean Coalition’s reply comments detail the multi-faceted value that microgrids can create in the grid planning process (using the example of a microgrid islanding a fleet of EV chargers), highlight the need to increase the timeframe considered in the distribution planning process and increase, and affirm the importance of proper/accurate assumptions & inputs prior to the start of Part 2 of the Study.
CPUC: Public Participation Hearings about Income Graduated Fixed Charges — Joint Reply to the Joint Utilities’ Response on the Joint Motion for Public Participation Hearings | 7 August 2023
The Joint Reply clarifies that Public Participation Hearings are not “unique” to this Rulemaking and underscores that the CPUC has the right to order such hearings in any proceeding. The Reply concludes with an explanation of why the initial Motion is not premature and should be granted.
CPUC: ALJ Ruling on Implementation Pathways for Income Graduated Fixed Charges — Opening Comments on ALJ Ruling | 31 July 2023
The Clean Coalition’s comments explain why our modest fixed charge proposal will guarantee savings for low-income residents and is the most practical proposal to implement. We underscore that high fixed charges will reduce the incentive for electrification and reward those using more energy with less efficient appliances, both of which are antithetical to the values held by the Commission. Finally, we argue that the Clean Coalition’s proposed fixed charge contains the only truly ‘fixed’ components that should be included in a fixed charge, meaning there should not be multiple iterations of new fixed charges moving forward.
CPUC: ALJ Ruling Setting Aside the Record and Questions on Cost-Effectiveness — Opening Comments on ALJ Ruling | 31 July 2023
The Clean Coalition’s comments note that the Net Value Billing Tariff (CCSA’s proposal) does not result in a cost shift and underscore that any cost-effectiveness tests must consider the full value created by Community Solar projects, including the additional value from infill solar projects as compared to ground mount solar projects. We advocate for a virtual storage pairing option to maximize the savings from economies of scale—via large energy storage (greater than the 4-hour requirement in CCSA’s proposal)—and increase the benefits of each project on the broader grid. Finally, our comments justify the value stack for Local Solar, showing that when considering the value created by avoiding Transmission Access Charges (TAC) and the Power Charge Indifference Adjustment (PCIA), remote wholesale generation is actually more expensive than truly Local Solar.
CPUC: Questions on Part 1 of the Electrification Impacts Study — Opening Comments | 14 July 2023
The Clean Coalition’s comments support the work that Kevala has done in Part 1 of the Electrification Impacts Study and urge the CPUC to consider analyzing the ratepayer savings that would be created by the widespread deployment of Community Microgrids and a Distribution System Operator to operate/optimize the grid.
CPUC: Public Participation Hearings about Income Graduated Fixed Charges — Joint Motion for Public Participation Hearings | 13 July 2023
The Joint Parties’ Motion for Public Participation Hearings requests that the CPUC hold eight Public Participation Hearings across PG&E’s, SCE’s, and SDG&E’s service territories, as well as convening customers of the small-jurisdictional utilities. The Motion seeks relief for the vast majority of the public, who have strong opinions about a residential income graduated fixed charge but have not been able to participate in the complex regulatory process occurring at the CPUC. Public Participation Hearings are common in any proceeding seeking a significant changes to rates; a fixed charge will result in substantial changes in the monthly bills of ratepayers, who deserve to have their voices heard.
CPUC: Ex parte communication — Presentation for Commissioner Houck’s office | 28 June 2023
The Clean Coalition’s presentation to Commissioner Houck’s office explained why a successful Community Solar program must have appropriate pricing for infill projects (deployed on rooftops, parking lots, and parking structures) and that infill projects create greater value than ground mount solar projects. We discussed exemptions from the Power Charge Indifference Adjustment (PCIA), Transmission Access Charges (TAC), defined Local Solar, and explained the economic benefits of infill projects (including job creation, using brownfield sites, additional reliability, and resilience). A similar slide deck was presented to representatives from Commissioner Reynolds, Commissioner Douglas’, and President Reynolds’ offices in the last three weeks.
CPUC: Update on Commission General Order 131-D — Opening Comments on Order Instituting Rulemaking | 22 June 2023
The Clean Coalition’s comments on the order instituting rulemaking urge the Commission to require a benefit cost analysis for each transmission project that includes a calculation of the lifetime costs the ratepayers will have to cover should a project move forward and any possible alternative distributed solutions.
CPUC: Solar on Multifamily Affordable Housing (SOMAH) — Reply Comments on ALJ Ruling Inviting Comments on Potential Modifications to SOMAH | 16 June 2023
The Clean Coalition’s reply comments support program modifications to enable deployments of storage and to allow new and existing master metered buildings, primarily for resilience. We also support improving the interconnection process by designating a single point of contact at each of the IOUs.
CPUC: High DER Track 1 — Reply Comments on ALJ Ruling and Questions on Phase 1 Track 1 | 5 June 2023
The Clean Coalition’s reply comments support GPI/IREC comments on the need for more effective and granular ICA data and maps. We then urge the Commission to use a longer distribution planning horizon, collect more data on interconnection application withdrawals, account for secondary distribution infrastructure in the distribution planning process (DPP), and continue to consider resilience in the DPP.
CPUC: Demand Flexibility — Rebuttal Testimony on Party Proposals | 2 June 2023
The Clean Coalition’s Rebuttal Testimony asks the Commission to approve our rebuttal proposal. We note that SEIA has the only reasonable proposal for an Income Graduated Fixed Charge (IGFC) of the nine parties that submitted proposals in Opening Testimony. Our testimony builds on SEIA’s model by proposing an ideal IGFC that both is easy to implement and results in savings for low-income customers. We conclude by analyzing a report by Flagstaff Research on the flaws of IGFC proposals made by the Joint IOUs, Cal Advocates, and NRDC/TURN and explain how an IGFC that is too high negates the benefits of electrification.
CPUC: Green Tariff Review Applications — Reply Brief | 30 May 2023
The Clean Coalition’s Reply Brief supports the Coalition for Community Solar Access’ Net Value Billing Tariff (NVBT). We explain why SCE’s legal challenge should not be persuasive to the Commission, suggest an exemption from Transmission Access Charges and the Power Charge Indifference Adjustment, explain the value of auto-enrolling customers, and detail why it is necessary to solicit additional information from parties before the proceeding record is complete.
CEC: IEPR Workshops on Interconnection — Comments on May 4th and 9th Interconnection Workshops | 23 May 2023
The Clean Coalition lauds the CEC for hosting two effective workshops and conveys the need to further streamline interconnection to ensure that decarbonization/electrification occurs on time. We discuss the need to streamline WDAT interconnection and implement the Clean Coalition’s Fixed Fee, Utility Pays (FixUP) proposal, address the need for better data collection on reasons for interconnection attrition, mention the potential for automation of interconnection processes, and highlight the key role that ICA data will have to play in interconnection if validated for accuracy/increased granularity.
CPUC: High DER Track 1 — Opening Comments on ALJ Ruling and Questions on Phase 1 Track 1 | 22 May 2023
The Clean Coalition’s comments support improving the accuracy of ICA data and extending the planning horizon for distribution planning. We support a discussion that considers a future with a Distribution System Operator and a pathway of upgrades that will enable complete electrification in time to achieve the state’s energy goals. We make the point that distribution planning cannot occur in a silo and must consider solutions that create the greatest value for the ratepayers rather than the lowest immediate cost. In addition, we address the need for community-focused planning to enable resilience solutions, the importance of viewing each incremental DER deployment as a step toward deploying Community Microgrids, and the fact that ensuring disadvantaged communities receive the necessary funding to achieve equity/ESJ goals must be a priority.
CPUC: Green Tariff Review Applications — Surrebuttal Testimony | 28 April 2023
Clean Coalition’s surrebuttal testimony addresses the flaws with SCE’s attacks on our position that Transmission Access Charges (TAC) should not be assessed on Community Solar Energy by noting that Community Solar value is intended to be commensurate with Net Energy Metering (which does not assess TAC for onsite generation) and explains why SCE’s claim that interconnection reform is not necessary is unreasonable given the lack of success with past programs. We also refute SDG&E’s claim that CCSA’s proposal has no merit by proving how the Clean Coalition’s modifications proposed in rebuttal testimony would address each issue that SDG&E raised.
CPUC: Data Access and DER Programs Order Instituting Rulemaking — Comments on ALJ’s Ruling Seeking Comments on Societal Cost Test and Air Quality Research | 28 April 2023
Clean Coalition’s comments strongly urge the Commission to adopt a Societal Cost Test (SCT) as the primary cost-effectiveness test due to the importance of externalizing costs that disadvantaged communities have been shouldering the brunt of for decades. We use the example of resilience (via the Clean Coalition’s VOR123 and RES) to show that societal benefits have a nonzero value that can be—and have been—quantified for individual facilities as well as a grid area. We also advocate for use of a High Social Cost of Carbon, the inclusion of an out-of-state methane adder, suggest that “society” should limited to California, and request that the Air Quality results should only be included in a SCT if they are remodeled using modern values (that account for recent inflation).
CPUC: Green Tariff Review Applications — Rebuttal Testimony on Party Proposals | 7 April 2023
Clean Coalition’s rebuttal testimony supports the Coalition for Community Solar Access’ (CCSA’s) Net Value Billing Tariff (NVBT) proposal for a Successor Community Solar program. We offer a few modifications, including that projects should be on the same distribution area as (or within 5 miles of) subscribers and that subscribed energy should be exempt from Transmission Access Charges (TAC) and the Power Charge Indifference Adjustment (PCIA). Our rebuttal testimony concludes by underscoring the value of autoenrollment and the need for streamlined front-of-meter (FOM) interconnection.
CPUC: Demand Flexibility — Comments on Proposed Decision Adopting Electric Rate Design and Demand Flexibility Design Principles | 6 April 2023
Clean Coalition’s comments are supportive of the Proposed Decision, though we request that the Commission makes two small changes. The first is adding the word “resilience” to Electric Rate Design Principle V and the second is adding the phrase, “required to deliver energy to the end-user,” to the end of Demand Flexibility Design Principle III.
CPUC: Net Energy Metering — Reply Comments on ALJ’s Ruling and Questions | 4 April 2023
Clean Coalition’s reply comments urge the Commission to adopt property-level netting for VNEM systems, support the deployment of storage and microgrids, and adopt Ivy Energy’s proposal. We also note that VNEM provides unique benefits including on-site energy usage, differentiate VNEM from the state’s Community Solar projects, and defend the avoided transmission value provided by VNEM systems against statements made by the Joint IOUs.
CPUC: Net Energy Metering — Comments on ALJ’s Ruling and Questions | 21 March 2023
Clean Coalition’s comments support maintaining virtual billing for the V-NEM tariff and encouraging paired installations of paired storage via a resilience adder and pathway for deploying single facility microgrids. We also request that the Commission consider increased compensation for NEM-A facilities based on the benefits they provide or an option to reduce demand charges.
CEC: 2023 Integrated Energy Policy Report (IEPR) Update — Comments on Scoping Memo | 17 March 2023
Clean Coalition’s comments on the 2023 IEPR Scoping Memo laud the Energy Commission for choosing to focus on interconnection and distinguishing between transmission and distribution-level interconnections. We lay out the case for front-of-meter interconnection reform using firsthand experience with the VGES project and other policy-analyses we conducted before offering a substantial number of WDAT-related interconnection reforms. Clean Coalition comments finish with an explanation about the need for template Single Line Diagrams for Title 24 Zero Net Energy facilities seeking Rule 21 interconnections as well as new Rule 21 configurations that allow distributed generation to provide distribution grid services.
CPUC: Microgrid Incentive Program Proposed Decision — Reply Comments on the MIP Proposed Decision | 6 March 2023
Clean Coalition’s reply comments urge the Commission to better prioritize the needs of Disadvantaged Vulnerable Communities by providing larger up-front grants and creating a determinative procurement process that will ensure a strong application definitively results in a deployed Community Microgrid.
CPUC: Sunnova Community Microgrids Application Proposed Decision — Opening Comments on Proposed Decision Approving Public Advocates Office Motion to Dismiss Sunnova Community Microgrids Application | 6 March 2023
These joint comments on the Proposed Decision express disappointment that the CPUC is choosing to dismiss the Application without any proper hearings, particularly given the widespread support for Community Microgrids and the benefits that these projects could bring to the community and grid. We urge the CPUC to throw this PD away and give Sunnova the opportunity to present its case in a full proceeding.
CPUC: Microgrid Incentive Program Proposed Decision — Opening Comments on the MIP Proposed Decision | 1 March 2023
Clean Coalition urges the CPUC to apply lessons learned from the lackluster Community Microgrid Enablement Program, including the need for fixed interconnection timelines, developer certainty, and a 36 month timeline between the signing of the Microgrid Operations Agreement and the Commercial Operations Date. We also urge the CPUC to approve a heat map that make eligibility criteria crystal clear and suggest that the maximum amount of funding for a pre-application grant should be increased from $25,000 to $100,000.
CPUC: Green Tariff Review Applications — Presentation on Clean Coalition Feed-In-Tariff Proposal for the Green Tariff Programs | 27 February 2023
Clean Coalition’s presentation explains why a Feed-In-Tariff with market responsive pricing, a dispatchability adder, and fixed interconnection is the most effective procurement method and should be used as the structure for the next iteration of the Green Tariff.
CEC: SB 846 Diablo Canyon Extension Analysis — Comments on Draft Report | 21 February 2023
Clean Coalition comments underscore the value of local solar in reducing: peak transmission usage, line losses, congestion, and transmission wear & tear. Our comments detail the importance of WDAT interconnection reform by laying out specific lessons learned from the Clean Coalition’s Valencia Gardens Energy Storage project.
CEC: DEBA Framework — Comments on January 27 DEBA Workshop | 17 February 2023
Clean Coalition demonstrates the need for an effective procurement process that enables developers to maximize the use of built environments for solar and solar+storage deployments. We urge the Energy Commission to invest in emerging grid management technologies (e.g., DERMS, d-STATCOMS, etc…) and make the case for deploying microgrids in three key areas: Solar Microgrids at schools, Community Microgrids at Load Pockets, and Single Parcel Microgrids that span multiple meters.
CEC: Draft Clean Energy Reliability Investment Plan (CERIP) Report — Comments on Draft CERIP Report | 16 February 2023
Clean Coalition’s comments urge the Energy Commission to address the need for WDAT interconnection reform and allocate money for the efficient deployment of microgrids. We also ask that the Energy Commission to consider speeding up the process for awarding deliverability and include distributed generation in the Integrated Resources Planning process.
CPUC: Application for Rehearing of D. 22-12-056 — Response to Application for Rehearing | 2 February 2023
Clean Coalition’s response urges the Commission to approve the Application for Rehearing of D. 22-12-056 and clearly demonstrates that the Commission’s analysis and reasoning in the Decision is incongruous with Public Utilities Code section 2827.1(b), legislative reports (SB 100 and SB 695), and the Commission’s own guiding principles in the Environmental Social Justice (ESJ) Action Plan and Distributed Energy Resources (DER) Action Plan 2.0.
CPUC: Data Access and DER Programs Order Instituting Rulemaking — Reply Comments on OIR on Data Access and DER Programs | 24 January 2023
Our reply comments underscore why a Societal Cost Test is necessary to value existing externalities and achieve the Commission’s goal of considering ESJ/DAC needs in the energy planning process. We also explain why including distributed energy resources (DER) in the Integrated Resources Plan (IRP) will help the state better consider cost-effectiveness of resource portfolios by including the actual cost of delivering energy to the end user.
CPUC: Demand Flexiblity Scoping Memo — Opening Brief on AB 205 Statutory Interpretations | 23 January 2023
Clean Coalition’s succinct Opening Brief explains that a fixed charge must not be viewed as a silver bullet solution to make rates affordable, since the majority of infrastructure-related costs should be assessed on a volumetric basis. Only public purpose program charges, billing administrative costs, metering costs, line transformer costs, and secondary voltage charges should be considered for a fixed charge. We also mention that ratepayers should be properly compensated for energy efficiency and DER deployment; a fixed charge should not punitively tax customers adopting electrification measures.
CPUC: Green Tariff Review Applications — Direct Testimony and Party Proposals | 20 January 2023
Clean Coalition testimony shows that the Green Tariff programs have not been successful at adding capacity and subscribers due to the disadvantages of the RFO process, a lack of focus on streamlined front-of-meter interconnection, and the over-complicated nature of the programs. We recommend a Feed-In-Tariff with a dispatchability adder and market responsive pricing as the most effective way to ensure that procurement matches subscriber rates. We note that the PCIA should not be included in the FIT rate and Green Tariff-customers should not be assessed Transmission Access Charges.
CPUC: Data Access and DER Programs Order Instituting Rulemaking — Comments on OIR on Data Access and DER Programs | 9 January 2023
Our comments highlight the importance of developing a Societal Cost Test, urge the Commission to make improve data sharing through increased transparency, and request parity among the IOUs when it comes to the Avoided Cost Calculator and valuing distributed energy resources.
CPUC: Demand Flexiblity Scoping Memo — Reply Comments on Phase 1 Assigned Commissioner’s Scoping Memo and Ruling | 4 January 2023
Our comments support amendments to the Rate Design Principles made by 350 Bay Area and The Climate Center, suggest a Critical Peak Pricing scheme, and underscore the need for greater data sharing. We also discuss the need to level the playing field for demand-side resources.
CPUC: Draft Integrated Energy Policy Report — Comments on Draft IEPR | 7 December 2022
Our comments request that the Energy Commission prioritize a cost-benefit analysis that fully values externalities – such as the value of resilience – and work with the Public Utilities Commission to finalize a Societal Cost Test. We also propose consideration of solar, solar+storage, and Solar Microgrid deployments at schools as an equity issue, suggest that the Energy Commission should consider targeted deployments of Distributed Energy Resources (DER) to maximize savings, and pose a few questions that we believe should be included to ensure a complete analysis of DER occurs in the final IEPR.
CPUC: Net Energy Metering Proposed Decision — Reply Comments on Proposed Decision | 5 December 2022
Clean Coalition’s reply comments suggest that the Commission wait to approve a Successor Tariff until all data assumptions and modeling is updated and request that data monitoring of the Successor be carried out on an annual basis. We also urge the Commission to change the oversizing allowance from 150% to 175% and note that the value of NEM deployments will increase when they are optimized as part of an aggregation or Community Microgrid.
CPUC: Demand Flexiblity Scoping Memo — Opening Comments on Phase 1 Assigned Commissioner’s Scoping Memo and Ruling | 2 December 2022
Clean Coalition comments support the removal of transmission charges (in the form of Grid Benefits Charge) and lambast the Commission for considering a proposal that doubles payback periods and slashes the export compensation rate by 75%. We note that the PD puts the Commission in a difficult position because it does not create a clear standard that can be used to evaluate it as successful, since it was modeled using different analyses from the Lookback Study, the first PD, and the party proposals. Most importantly, we address the fact that the cost shift argument overestimates the costs and underestimates the benefits of NEM, without considering Societal Benefits.
CEC: Clean Energy Alternatives for Energy RFI — Response to Request for Information | 30 November 2022
Clean Coalition comments provide context about the need to level the playing field for demand-side resources by fixing the market distortion caused because Transmission Access Charges are metered at the customer meter rather than at the transmission-distribution substation and urge the Commission not to adopt any fixed charge that is discriminatory toward ratepayers adopting electrification measures. We also recommend that both sets of Staff Guidelines should be adopted after incorporating party input and propose a few amendments.
CPUC: Net Energy Metering Proposed Decision — Opening Comments on Proposed Decision | 30 November 2022
Clean Coalition comments support the removal of transmission charges (in the form of Grid Benefits Charge) and lambast the Commission for considering a proposal that doubles payback periods and slashes the export compensation rate by 75%. We note that the PD puts the Commission in a difficult position because it does not create a clear standard that can be used to evaluate it as successful, since it was modeled using different analyses from the Lookback Study, the first PD, and the party proposals. Most importantly, we address the fact that the cost shift argument overestimates the costs and underestimates the benefits of NEM, without considering Societal Benefits.
CPUC: Avoided Cost Calculator Petition for Modification — Response to Joint Parties Petition for Modification on the 2022 Avoided Cost Calculator | 2 November 2022
The Clean Coalition response supports the Petition for Modification to exclude load-increasing DER from the DER removed for the No New DER counterfactual. We note that removing all load-increasing DER will result in a smaller-than-necessary portfolio for the Preferred System Plan, will lead to undercounting for DER valuation, and that the Commission should follow the same caution exhibited for ascribing avoided transmission values to the three IOUs.
CPUC: Sunnova Community Microgrids Application — Response to Sunnova Community Microgrids Application | 10 October 2022
Clean Coalition hails Sunnova’s Community Microgrid application as a step forward toward commercializing Community Microgrids through a non-investor-owned utility company that constructs housing communities to benefit from the resilience and clean energy, shoulders the liability of reliable service by forming a micro-utility, and avoids any concerns of affordability/cost-shifting.
CEC: Façade-Integrated Solar — Comments on Emerging Technologies for the 2022 IEPR | 14 September 2022
Clean Coalition comments introduce Façade-Integrated Solar and underscore reasons that it is more appropriate to categorize Façade-Integrated Solar as an energy efficiency measure rather than as generating resources. We request that Façade-Integrated Solar is included in the Emerging Technologies section of the IEPR as an energy efficiency measure.
CPUC: Informal Comments on August 23 Workshop — Reply Comments in Response to August 23 Workshop | 9 September 2022
In these joint reply comments, we support comments by the Green Power Institute that listening sessions should consider current and future barriers to DER adoption and reiterate the need for a joint community engagement plan that adheres to guiding principles.
CPUC: Informal Comments on August 23 Workshop — Opening Comments in Response to August 23 Workshop | 31 August 2022
In this joint filing we request that the CPUC work with the CEC to create a joint outreach plan to solicit ratepayer opinions on a High DER future. We provide specific questions that the Commission should ask in listening sessions and provide examples of ways that DER can benefit communities.
CPUC: Microgrid Incentive Program Staff Proposal — Reply Comments on ALJ Ruling and Staff Proposal | 19 August 2022
In reply comments, the Clean Coalition reiterates the need to launch the Microgrid Incentive Program as soon as possible, given the dire need for resilience in California. Our comments also rebut statements by the Investor-Owned Utilities about the difficulty of creating a heat map for eligibility criteria through the work of Bethany Kwoka, a graduate student at UCSD.
CEC: Community Energy Resilience Investment Program — Clarifying questions on opening presentations | 18 August 2022
Clean Coalition comments ask clarifying questions about eligibility for the granting process and types of resources that qualify for the grant.
CPUC: Microgrid Incentive Program Staff Proposal — Opening Comments on ALJ Ruling and Staff Proposal | 5 August 2022
Clean Coalition comments support amending the Microgrid Incentive Program to make it as determinative as possible. We suggest that the Commission add a specific point threshold so that developers know that strong applications will lead to the deployment of Community Microgrids and specify the layers of information that need to be included in a useful heat map.
CPUC: Bloom Energy Petition for Rulemaking — Petition for Rulemaking | 25 July 2022
The Clean Coalition supports Bloom Energy’s Petition for Rulemaking to create a resiliency/reliability capacity tariff, albeit with a few changes. We recommend lowering the number of baseline hours of consecutive exports to 10 and primarily relying on renewable resources (or green hydrogen) to effectively more utilize microgrids and speed up the commercialization of the technology across the state.
CPUC: Net Energy Metering — Reply Comments on ALJ Ruling | 1 July 2022
The Clean Coalition’s reply comments lay out reasons why applying nonbypassable charges to gross consumption of Net Metered systems is an overreach by the PUC, one that would further damage the economics of the Net Billing Tariff (NEM 3.0) and will set a terrible precedent for future DER programs. We address logical fallacies made by other parties, namely the Joint Utilities and NRDC, before returning to Facade Integrated Solar as an example of how generation that is produced and consumed on-site is functionally similar to energy efficiency.
CEC: DER Order Instituting Information (OII) — Comments on Kickoff Workshop | 17 June 2022
In these opening comments on the Order Instituting Information on Distributed Energy Resources (DER) in California’s Energy Future, the Clean Coalition poses a series of important questions to guide the focus of the proceeding. We consider what role DER will play in California’s energy transition, how to maximize the value of DER, the mechanisms necessary to cost-effectively procure DER, how DER should be included in the grid planning process, whether DER have a level playing field compared to other resources, and the role that interconnection plays in DER procurement. Clean Coalition comments also asks the CEC to reflect on the outcomes of this proceeding and whether lessons learned will be sent to the legislature (if significant changes are required).
CPUC: Net Energy Metering — Opening Comments on ALJ Ruling Setting Record Aside and Taking Comments | 10 June 2022
In opening comments, the Clean Coalition takes a strong stand against extending nonbypassable charges to gross consumption of NEM facilities. We demonstrate that self-consumption is similar to energy efficiency since no energy utilizes the utility grid and use the example of Facade-Integrated Solar as a case study, first showing the similarities with energy efficiency and then backing up the claim that Facade-Integrated Solar should be exempt from NEM/interconnection rules.
CPUC: Avoided Cost Calculator (IDER) — Reply Comments on Proposed Decision | 26 April 2022
In reply comments, we reiterate our support for a stronger avoided transmission value by requesting that the Commission assign an interim value for SCE, calling for an “unspecified transmission value” to consider the value of deferring non-planned transmission upgrades and urging the Commission to deny PG&E’s proposal to remove the word “uncontested” from the findings of fact. We also scrutinize the Coalition of Utility Employee’s proposal to cut the avoided distribution value by 98% and request that the Commission prioritize accuracy over harmonizing the Avoided Cost Calculator with the Integrated Resource Planning process.
CPUC: Avoided Cost Calculator (IDER) — Opening Comments on Proposed Decision | 19 April 2022
In opening comments, the Clean Coalition supports updated avoided transmission values for PG&E, but requests that the PUC adopt an interim value for SCE until a full calculation can be completed. We also underscore the need for a grievance process to remedy egregious errors if the Commission removes the minor update process and suggest that any gas forecast prices need to take short-term price fluctuations into account.
CAISO: 20-Year Transmission Outlook — Comments on Draft Report | 22 February 2022
In comments, the Clean Coalition praises the creation of a long-term transmission roadmap, albeit we advocate that the final report should include potential investments in distributed energy resources (DER) as part of the scenario planning process to prevent over-investment in transmission, keeping electric rates from skyrocketing. Our comments detail the ways in which DER can avoid transmission investment and demonstrate, via the Vibrant Clean Energy study, the significant ratepayer savings that come from a balanced grid planning process.
CPUC: Microgrids — Reply Comments on Microgrid Incentive Program Implementation Plan | 28 January 2022
In reply comments, the Clean Coalition underscores the need to extend the project commercial operations date, requests specified interconnection timelines, advocates for a single program website and suggests that the application scoring should reward applicants for projects that serve more customers instead of capping points in that category.
CPUC: Microgrids — Opening comments on Microgrid Incentive Program Implementation Plan | 14 January 2022
In opening comments, the Clean Coalition requests changes to make the Microgrid Incentive Program a deterministic program, where applicants will have certainty that a high application score will lead to approval and the eventual deployment of a Community Microgrid. To ensure this is possible, we advocate for allowing expedited approval of applications fully funded by third parties, urge the IOUs to publish information about Application Intake Windows in advance and streamline interconnection to ensure applicants can achieve their initial commercial operations date.
CPUC: DER Deferral — Comments on Draft Resolution E-5190 | 14 January 2022
In comments on the Draft Resolution, the Clean Coalition supports the changes and requests a few amendments before the Commission approves a Final Resolution. We request uniformity among the three IOUs through the selection of a single Independent Evaluator, applaud the inclusion of a DERMS analysis and propose the inclusion of other emerging DER in the DER Deferral Pilots, such as d-STATCOMS.
CPUC: NEM — Reply comments on proposed decision | 14 January 2022
In reply comments, the Clean Coalition notes that the Commission incorrectly relies on the Ratepayer Impact Measurement test rather than the Total Resource Cost test as the main cost-effectiveness test (and does not use a Societal Cost Test at all). We also address the fact that the Commission’s focus on solar+storage adoption will lead to a drastically lower level standalone solar adoption in all communities and urge rejection of the PD based on lackluster consideration of the full range of party proposals related to energy storage.
CPUC: NEM — Opening comments on proposed decision | 7 January 2022
In opening comments, the Clean Coalition explains why the Proposed Decision will drive ratepayers away from using NEM by making non-export options more economical. We demonstrate that the proposed Grid Participation Charge is an illegal distortion of Transmission Access Charges, which should not be assessed to NEM customers, and critique an insufficient allowance for facilities preparing for electrification to oversize their PV system.
CPUC: Renewable Market Adjusting Tariff — Reply comments on proposed decision | 6 December 2021
In reply comments, the Clean Coalition underscores the importance of using Time of Delivery factors to incentivize the export of energy during peak grid periods and explains why it is necessary for SDG&E to reopen its ReMAT program to meet state procurement requirements.
CPUC: Renewable Market Adjusting Tariff — Opening comments on proposed decision | 30 November 2021
In opening comments, the Clean Coalition supports aspects of the Proposed Decision, including the addition of co-located storage, reopening SDG&E’s queue, notifying queue customers of tariff changes, and expanding eligibility to facilities with shared transformers. However, we disagree with the Commission about flexible product categories and instead request a single product category combined with time of delivery factors to optimize the program with the addition of co-located storage.
CEC: Research on Valuation of Investments in Electricity Sector Resilience — Written comments for the docket | 19 November 2021
Clean Coalition comments urge the Energy Commission to consider our value-of-resilience (VOR) methodology, VOR123, and Resilient Energy Subscription (RES) market mechanism in its research on the valuation of investments in electricity sector resilience. VOR123 and RES will provide a pathway to the widespread deployment of Solar Microgrids and Community Microgrids, as well as helping to finance and expand Community Microgrids.
CPUC: Microgrids for Emergency Reliability — Reply comments on the Track 4 Phase 1 proposed decision | 16 November 2021
Clean Coalition reply comments remind the Commission that the core principle of this proceeding is to increase the commercialization of microgrids and that the decision making process should continue to prioritize input from local governments and tribal communities. With that in mind, we urge the Commission to approve the Regional Microgrid Pilot Program proposed by the County of Los Angeles.
CPUC: Microgrids for Emergency Reliability — Opening comments on the Track 4 Phase 1 proposed decision | 10 November 2021
Clean Coalition comments critique the Proposed Decision for ignoring the vast majority of party proposals and failing to reduce the inhibitions to the widespread proliferation of microgrids. We urge the Commission to consider the proposal made by the County of Los Angeles to deploy Critical Facility Community Microgrids and then explain why a Resilient Energy Subscription (RES) is the missing piece needed to cost-effectively expand a Community Microgrid at the cost of service.
CPUC: Microgrids for Emergency Reliability — Opening comments on the Track 4 Phase 1 proposed decision | 10 November 2021
In these Joint Comments, parties lambast the Commission for taking a step in the wrong direction by approving fossil-fuel generation. In addition, comments point out the inherent cost shift in SDG&E’s proposal and decry the Commission’s choice to reject the majority of party proposals as a sign that it isn’t properly carrying out the mandate laid out in the Governor’s Emergency Proclamation.
FERC: Transmission Planning — Reply comments | 9 November 2021
The Clean Coalition advocates that the Federal Energy Regulatory Commission’s rulemaking on regional transmission planning prioritize transparency, precise cost allocations, and transitioning to a two-way grid powered by distributed energy resources (DER). As an example, our comments point to the current market distortion caused by the inaccurate assessment of Transmission Access Charges (TAC) at the customer meter rather than at a transmission-distribution substation. We also note that even as transmission costs continue to drive up electric rates, the majority of utility transmission projects (greater than 80% in the case of PG&E from 2016-2019) are self-approved. Building an efficient grid requires balancing state and local needs in an effort to supply clean energy at the lowest cost to the consumers, not just building more unvetted transmission infrastructure.
CPUC: Draft DER Action Plan 2.0 — Informal comments | 8 October 2021
In these informal comments, the Clean Coalition calls on the Commission to acknowledge the value of DER and offers a series of action items, which can mostly be implemented in the next year and a half, to speed up the transition to a two-way grid. We focus on policy revisions that will change the planning process, including reforming the DIDF to include all clean DER, improving ICA/Data Portals to benefit developers, automating BTM interconnection, streamlining FOM interconnection, and implementing Performance Based Regulation in the near-term.
CPUC: High DER OIR — Reply comments on OIR | 7 October 2021
In these reply comments, the Clean Coalition requests that the proceeding be structured in parallel tracks, allowing low-hanging-fruit-solutions to be implemented quickly, while longer systematic change is properly studied. We suggest addressing ICA issues and Performance Based Regulation in the short-term and the value of resilience, DER opportunities assessment, and a solution to Transmission Access Charges in the long-term.
CPUC: Microgrids — Reply to Opening Comments in Response to Emergency Proclamation Proposals | 1 October 2021
In reply comments, we recommend the approval of behind-the-meter distributed generation aggregations and Community Microgrids rather than continuing to rely on temporary contracts with fossil fuel generators. Due to looming reliability concerns, we also support a relaxation of Rule 18/19 rules on private energy sharing between adjacent properties and continue to stress the importance of swift interconnection reform.
CPUC: Proposed Preferred System Plan — Opening comments in response to ALJ ruling seeking questions | 27 September 2021
The Clean Coalition comments express surprise that the Load Serving Entity’s Integrated Resource Plans did not meet either reliability or GHG reduction goals. We criticize the proposed Preferred System Plan as failing to consider DER as an alternative to transmission-interconnected resources, particularly with the increasing demand for resilience. Opening comments conclude by briefly introducing our Resilient Energy Subscription (RES) proposal, a way to fund Community Microgrids, which add a layer of local resilience and reduce congestion on the transmission system.
CPUC: Microgrids — Opening comments in response to emergency proclamation proposals | 24 September 2021
Using examples from the VGES Front-of-Meter Energy Storage Interconnection Case Study, Clean Coalition comments underscore the need for front-of-meter interconnection reform to truly enable Community Microgrids. We also urge the Commission to consider a joint report we drafted with the Green Power Institute on Automation on the behind-the-meter interconnection process.
CPUC: NEM 3.0 — Reply briefs | 22 September 2021
In reply briefs the Clean Coalition explains that the Successor Tariff should be crafted based on the intent of the original legislation: to ensure the sustainable growth of renewable technologies. We urge the Commission not to push ratepayers away from NEM with punitive fees for transmission and access to the grid and instead maximize benefits to the grid with a Feed-In Tariff for larger NEM systems. Our comments support extending VNEM, reforming NEM-A, and guaranteeing a reasonable payback period for all NEM systems.
CPUC: Order Instituting Rulemaking to Modernize the Electric Grid for a High DER Future — opening comments | 16 August 2021
Clean Coalition comments applaud the CPUC for developing a streamlined proceeding to manage the future of DER and optimize a two-way grid. We advocate for a full study of a DSO model (including all ownership models), the importance of reconsidering Transmission Access Charges/avoided transmission values, and creating a framework to balance all solutions as part of the distribution planning process.
CPUC: Proposed Decision on Order Closing Rulemaking 14-10-003 — reply comments | 26 July 2021
Clean Coalition reply comments support the opening comments of 350 Bay Area in requesting a full and detailed list of the proceeding’s history. We argue that the new High DER Planning proceeding (R. 21-06-017) can only succeed with a thorough foundation of everything that has been completed or still needs to be finished from the IDER proceeding. We provide an example of the recent confusion over what constitutes a Minor Update versus a Major Update to the Avoided Cost Calculator as an opportunity to demonstrate where progress has been made in the IDER proceeding, but CPUC clarity is needed.
CPUC: NEM 3.0 Direct Testimony — rebuttal testimony | 16 July 2021
In Rebuttal Testimony, the Clean Coalition points out the absurdity of charging a Grid Benefits Charge (GBC) based solely on on-site consumption and explains why CPUC precedent requires the use of the Total Resource Cost test as one of the main tools to measure the cost-effectiveness of DER. Our testimony exposes the flawed assumptions involved in the creation of proposed GBCs and details the multiple ways in which DER can defer transmission buildout.
CPUC: Microgrids — reply comments | 6 July 2021
In reply comments the Clean Coalition notes that the CPUC has not done a comprehensive analysis of the benefits a microgrid provides, nor has a study of any costs to the grid been completed. As a result, the proceeding has been needlessly limited, and while the Proposed Decision is an important step forward, it is only a portion of much broader solution necessary to overcome the barriers to the commercialization of microgrids.
CPUC: Microgrids — opening comments | 29 June 2021
In these opening comments on the Proposed Decision, the Clean Coalition supports the proposed exemption for microgrids from capacity reservation charges, and urges the CPUC to take it a step further. We request that all emergency charging situations prior to widespread outages not be counted toward increased demand charges and suggest that verification of microgrids be dependent on the emissions from component resources. Comments conclude by suggesting that microgrids that export fully during the critical peak period of the day should receive a full exemption from non-bypassable charges.
CPUC: DER Deferral Evaluation and Performance Criteria Implementation Advice Letter — protest of AL 3780-E | 23 June 2021
The Clean Coalition protests the Joint Utility’s implementation plan, arguing that the Distribution Planning Advisory Group (DPAG) should hire the Independent Evaluator (IE) for the program and only choose to ramp down one of the two pilots if there is a request from both the utility and the IE. We also request an analysis of DERMS for each pilot, to ensure that short-term results do not count against the long-term success of DER deferral.
CPUC: ALJ Ruling Seeking Updated Information Regarding the Renewable Market Adjusting Tariff Program — reply comments | 23 June 2021
Clean Coalition reply comments explain why now is the right time to amend ReMAT in order to regain market confidence, request that the CPUC consider expanding program allocations, demonstrate the need to remove product categories, and implement time-differentiated TOD factors, and we urge the CPUC to adopt a locational adder.
CPUC: NEM 3.0 Direct Testimony — opening testimony | 18 June 2021
In our testimony, the Clean Coalition focuses on pushing back against a grid benefits charge, especially one that would charge NEM customer Transmission Access Charges. We also underscore how essential it is for ratepayers that the debate over the Successor Tariff is not limited to the residential aspect of the tariff, precluding changes to the way V-NEM, NEM-A, and larger NEM systems are billed.
CAISO: Aggregate Constraint Capabilities Final Draft Tariff — comments | 14 June 2021
The Clean Coalition lauds CAISO’s final tariff as enabling the use of software controls as a technique to impose separate output limits at the point of interconnection, allowing multiple off-takers from a single project. We use the example of the Clean Coalition’s Valencia Gardens Energy Storage (VGES) project to demonstrate that with an option for Aggregate Constraint Capabilities, the original two-battery energy storage system design could have moved forward, rather than requiring a shift to a single smaller energy storage system.
CPUC: Comments on Advanced DER & Flexibility Management Workshop | 11 June 2021
Clean Coalition comments support Energy Division’s Real Time Pricing Proposal as an important step toward achieving more granular and transparent energy costs that will reduce the barriers to market entry for ratepayers interested in renewable energy systems. In particular, we note the importance of using an avoided cost framework to properly value the benefits of distributed energy and of including a Value of Resilience. Comments also emphasize the importance of deploying Distributed Energy Resources Management Systems (DERMS) to manage DER in real time and respond accordingly, optimizing the function of a two-way grid.
CPUC: ALJ Ruling Seeking Updates Information Regarding the Renewable Market Adjusting Tariff Program — opening comments | 9 June 2021
Clean Coalition opening comments advocate for the consolidation of the three ReMAT product categories into one large category with TOD multipliers to incentivize the deployment of co-located storage in order to maximize the value of energy exported to the grid. In addition, to ensure that full capacity is reached, we recommend that the CPUC change the definition of “fully subscribed,” remove de minimis status entirely, and reopen SDG&E’s ReMAT program.
CPUC: Avoided Cost Calculator (IDER) — reply comments | 1 June 2021
In reply comments, the Clean Coalition poses three questions and correlates a “no” answer to each question as providing the CPUC with sufficient reason to reject the proposed 2021 Minor Update. First, is there a consensus among parties that the changes are minor? Second, was the CPUC-specified procedure for a Minor Update followed? Third, can the CPUC be sure all inputs are accurate and will not result in unforeseen consequences?
CPUC: Avoided Cost Calculator (IDER) — opening comments | 24 May 2021
Clean Coalition comments critique the CPUC for attempting to sneak major changes into the Avoided Cost Calculator during a Minor Update cycle. The changes, which slash the value of standalone solar by 70%, did not go through a thorough public evaluation by stakeholders and rely on untested/unapproved modeling tools. We address improper inputs to the model, including the use of temperature data from 2013 to model heat rates in 2030, and explain why the missteps result in a drastically lowered avoided cost of DER when compared to the 2020 ACC.
CPUC: NEM Fuel Cell Tariff — reply comments | 17 May 2021
While the Clean Coalition acknowledges in comments that the NEM Successor Tariff should also apply to fuel cells, we strongly support proposals to require verification — via an independent inspector — to guarantee that no methane leakage is occurring before a facility is allowed to officially take serve under the tariff. We also support comments made by Protect our Communities Foundation advocating for the CPUC to request new acceptable greenhouse gas emission levels for fuel cells (from the California Air Resources Board).
CPUC: Rule 21 Track 1 Interconnection Proposed Decision — reply comments | 3 May 2021
Clean Coalition reply comments argue that the proposed two-year timeline for soliciting new interconnection issues needs to be shortened to ensure that the CPUC does not fall further behind at creating regulation than in the past. Our comments also advocate for the creation of single-line diagrams for Zero Net Energy projects, to ready the Joint IOUs for the influx of interconnection requests from new constructions complying with energy efficiency mandates.
CPUC: Provider of Last Resort — opening comments | 26 April 2021
Clean Coalition opening comments acknowledge the importance of discussing details about how the provider of last resort will operate in California and suggest that guidelines and a tentative schedule for inter-agency cooperation should be set within 30 days of the prehearing conference.
CPUC: DER Deferral Evaluation and Performance Criteria — reply comments | 14 April 2021
Clean Coalition reply comments aim at ensuring the pilots are administered all the way through to the original deadlines approved by the CPUC; we agree with a statement made by Cal Advocates that the pilots should continue if there is any long-term pathway to success. Furthermore, we acknowledge that analysis of the pilots should consider how the value of a long-term program might change with the inclusion of Distributed Energy Resources Managements Systems, which can optimize the value of a DER aggregation that includes resources deployed on both sides of the meter.
CPUC: DER Deferral Evaluation and Performance Criteria — opening comments | 9 April 2021
Clean Coalition comments argue that the most important way to evaluate these new pilots is to gather as much data as possible to understand the big picture, including resource types for each project, changing market conditions, the number of deferral needs met each year, and the type of aggregators bidding to meet the demand. We also argue that resources should receive value for the system benefits they provide in addition to deferring the need for distribution upgrades, such as greenhouse gas reduction and avoided tranmission. Comments conclude by suggesting that the CPUC should evaluate whether allowing aggregations of resources on either side of the meter, rather than separate pilots for behind-the-meter and front-of-meter resources, would optimize the value of DER.
CPUC: Proposed Successor to the Net Energy Metering Tariff | 15 March 2021
The Clean Coalition party proposal focuses on a few key areas rather than outlining a full Successor Tariff. We advocate for the development of a Feed-In Tariff (FIT) similar to the LADWP FIT+ Pilot Program, argue that Transmission Access Charges (TAC) should not be included in the final list of non-bypassable charges in the Successor Tariff, and suggest that all meters participating in aggregations for NEM-A be exempt from demand charges. Comments touch on the need for valuing resilience for paired storage and the benefits of including a pathway for sites to over-generate in preparation for a load increase associated with electrification.
CPUC: Microgrid Track 3 Amended Scoping Memo and Questions — reply comments | 10 March 2021
Our comments focus on the fact that all parties agree that discussing microgrid exemptions to standby charges is premature without first quantifying the value-of-resilience (VOR). The Clean Coalition underscores the need for the Commission to approve standby-charge reform in the microgrids proceeding and calls for exemptions for small microgrids under 1 MW and critical community facility microgrids.
CPUC: Microgrid Track 3 Amended Scoping Memo and Questions — opening comments | 3 March 2021
Clean Coalition comments make it clear that discussing exemptions to standby charges without defining and quantifying the grid services a microgrid can offer — resilience, in particular — makes the debate much less meaningful and granular than it otherwise would be. We argue that standby charges are outdated and the concept of the utility as the “provider of last resort” does not account for the reliable service a microgrid provides. We conclude that the Commission needs to entirely reform standby charges and that exemptions should be granted for multiple different types of microgrids, including critical community facility microgrids, microgrids that provide grid services, and microgrids completely disconnected from the grid.
CPUC: Proposed Decision Directing PG&E, SCE, and SDG&E to Seek Contracts for Additional Power Capacity for Summer 2021 — reply comments | 2 February 2021
In reply comments, the Clean Coalition aligns with party positions arguing that this proceeding should be used to set the stage for long-term solutions deployed in 2022, 2023, and beyond. While we still push for the necessary prioritization of energy storage, we suggest that the Commission tie energy storage together with other renewable resources in the optimal configuration, a series of Community Microgrids. Comments include Clean Coalition analysis showing that Community Microgrids are a more economical investment than gas peaker plants.
CPUC: Proposed Decision Directing PG&E, SCE, and SDG&E to Seek Contracts for Additional Power Capacity for Summer 2021 — opening comments | 28 January 2021
Clean Coalition comments request that the Commission prioritize the procurement of energy storage over any investments in fossil fuel generation. We argue that energy storage is dispatchable and offers other benefits to the electrical system — resilience, a reduction in greenhouse gas emissions, and lower demand during peak hours — that fossil fuel generation cannot compete with.
CPUC: Proposed Decision Adopting Guiding Principles for the Development of the Successor to the Current Net Energy Metering Tariff — opening comments | 25 January 2021
The Clean Coalition argues that the Proposed Decision should include a guideline about promoting energy storage. Our comments demonstrate that if Principle 5 — using a technology-neutral approach — is amended to specify “eligible generation resources,” the addition of a guideline about energy storage will complement rather than conflict with it. Comments conclude by pointing out the need for the Commission to prioritize guidelines that create specific metrics to be used when judging the success of a tariff. We identify the guideline about “considering fair competition between electric service providers” as an example of one that is difficult to prove one way or the other.
CPUC: Proposed Decision Adopting Pilots to Test Two Frameworks for Procuring Distributed Energy Resources that Avoid or Defer Utility Capital Investment — opening comments | 25 January 2021
In opening comments, the Clean Coalition offers support for the two pilots, also suggesting that the Commission should consider making the pilots permanent during the mid-project review rather than waiting five years for the scheduled end of the pilots if clear benefits are evident early on. The mid-project review should consider ways to optimize aggregations, including combining behind-the-meter and front-of-meter projects. We urge the Commission not to forget the importance of Distributed Energy Management Systems, which the utilities are not required to develop in the current iteration of the Proposed Decision. Comments conclude with an argument for the inclusion of a market-adjusting cost cap and a discussion of two scenarios where the use of a Feed-In Tariff would greatly benefit the deferral tariff.
CPUC: Ruling Directing Responses to Questions on Rule 21 Working Group 4 Report and Issues 11 and 13 — reply comments | 8 January 2021
In these reply comments, the Clean Coalition replies to the three parties in opposition — California’s three investor-owned utilities — to the proposal we sponsored, which would require the creation of template single-line diagrams for Zero Net Energy (ZNE) facilities. We reiterate that the proposal is a simple but elegant solution for streamlining interconnection by proactively reducing the imminent increased demand on interconnection staff as an influx of ZNE applications are submitted.
CPUC: Microgrid Track 2 Proposed Decision Comments — reply comments | 4 January 2021
In this reply to opening comments, we agree with parties that the Commission should make a strong statement to the legislature about the need to change the over-the-fence rule (section 218(b) of the Public Utilities Code). We also concur with the Microgrid Resources Coalition about the need for clarify foundational definitions such as “commercialization” and “cost-shifting,” adding the “value of resilience” as another phrase that will change the outcome of the proceeding. We end with a request that the Commission further discuss the value of microgrid grid services and specify some of the unintended consequences that caused them to limit proposals during Track 2.
CPUC: Microgrid Track 2 Proposed Decision Comments | 28 December 2020
Clean Coalition comments open with a strong critique of the Commission for rushing Track 2 of the proceeding, ultimately culminating with a Proposed Decision that does not achieve any of the goals listed in SB 1339 — commercializing microgrids and reducing greenhouse gases — and that does not even attempt to quantify the value-of-resilience (VOR). We make a number of suggestions, including calling for all critical facilities to be eligible for the Rule 18/19 exemption, asking for microgrid grid services and resilience to be valued in a microgrid rate schedule, and requesting that the utilities be held to a stricter standard for transitioning to renewable microgrids for substation-level backup power.
CPUC: Ruling Directing Responses to Questions on Rule 21 Working Group 4 Report and Issues 11 and 13 — opening comments| 18 December 2020
In opening comments, the Clean Coalition supports proposals that would reduce interconnection times related to anti-islanding studies, including a proposal requiring generation-to-load calculations to be performed with hourly profiles and a proposal to speed up the process by allowing applicants to hire utility-approved experts for a more detailed study. The majority of comments focus on responding to questions related to the proposal submitted by the Clean Coalition to require the creation of template single-line diagrams for Zero Net Energy facilities.
CPUC: Joint Assigned Commissioner’s Scoping Memo and Administrative Law Judge Ruling Directing Comments on Proposed Guiding Principles Related to Net Energy Metering | 11 December 2020
Clean Coalition reply comments on guiding principles for the Net Energy Metering (NEM) proceeding center around the need for a greater focus on sustainable growth of NEM projects in underserved communities, including promoting energy storage. We also request that the guidelines ensure that evaluation of NEM projects be based on the net benefits to the entire electrical system, not just the distribution system.
CPUC: Joint Assigned Commissioner’s Scoping Memo and Administrative Law Judge Ruling Directing Comments on Proposed Guiding Principles Related to Net Energy Metering | 4 December 2020
In opening comments, the Clean Coalition requests the inclusion of phrases in two guiding principles that will focus the proceeding on the impacts NEM has on the distribution and transmission systems and to ensure that the successor tariff will enable electrification in alignment with state policy. We also request the removal of the word “continue” from a third guideline to guarantee that the proceeding is not limited in discussions about solutions promoting equitable growth of renewable resources in all communities, especially low-income and disadvantaged communities.
CPUC: E-mail Ruling Introducing Distributed Energy Resources Tariff Staff Proposal and Directing Comments and Responses to Questions — reply comments | 11 November 2020
Clean Coalition reply comments center around refuting claims by Cal Advocates, SDG&E, and PG&E about the recklessness of including an over-procurement margin (since not all of the generation of a DER project will be used for deferral purposes), the utility preference that each IOU only be required to administer one of two deferral programs, and the opinion that DER aggregation is not yet commercially feasible.
CPUC: E-mail Ruling Introducing Distributed Energy Resources Tariff Staff Proposal and Directing Comments and Responses to Questions | 11 November 2020
In opening comments, the Clean Coalition commends the creation of a tariff that will allow utilities to leverage a combination of front-of-meter (FOM) and behind-the-meter (BTM) DER to defer the need for infrastructure upgrades on the distribution system. We argue that utilizing multiple sources of capital — including existing programs and private capital — will allow for the most efficient aggregations of projects to be deployed. Clean Coalition comments also suggest the need to properly assess Transmission Access Charges and advocate for a Feed-In Tariff as an ideal DER procurement mechanism.
CPUC: Presentation on Clean Coalition Proposal 19d in Rule 21 Working Group 4 | 16 October 2020
The Clean Coalition advocates for Proposal 19d, requiring the use of template single-line diagrams for Zero Net Energy Facilities. When a utility has 50 applications in a project category (e.g., NEM-paired storage, Rule 21 non-NEM export, Rule 21 grid services, etc.), they will be required to have a call with stakeholders within 90 days and publish the template diagram within 120 days of the stakeholder engagement. The proposal does not inhibit the utility review process or require duplicative efforts.
CPUC: Policy Questions on an Interim Approach for Minimizing Emissions from Generation during Transmission Outages — reply comments | 2 October 2020
The Clean Coalition supports proposals by Tesla and Sunrun to use solar microgrids for substation-level backup power and questions why their initial proposals were rejected by the Commission. Our comments also push back on PG&E’s assertion that diesel should be phased out over the next 7 years and requests that PG&E explain why existing proposals are not sufficient to proceed to an RFP.
CPUC: Rulemaking to Investigate and Design Clean Energy Financing Options for Electricity and Natural Gas Customers | 30 September 2020
The Clean Coalition advocates for the need to determine a standard value-of-resilience and suggests the Dispatchable Energy Capacity Services (DECS) market mechanism as two important value adders for electrification. Comments conclude by proposing our Electrification & Community Microgrid Ready (ECMR) guidelines as a way to transparently promote the standard costs associated with electrifying a facility in preparation for interconnection to a Community Microgrid.
CPUC: Order Instituting Rulemaking on Net Energy Metering Successor Tariff | 28 September 2020
The Clean Coalition’s comments suggest switching to inverter-based restrictions rather than generation-based restrictions and highlight the need to amend NEM to allow facilities with plans to electrify in the near term to oversize generation. For resilience purposes, the Clean Coalition calls for the removal of energy storage sizing limits.
CPUC: Policy Questions on an Interim Approach for Minimizing Emissions from Generation during Transmission Outages | 25 September 2020
The Clean Coalition lambasts the Commission for waiting to take action on the issue of substation backup power until August 2020, defaulting to the use of diesel fuel for 2021 after explicitly stating only three months earlier that it would only be acceptable for use in 2020. Instead of diesel fuel as a primary energy source, Solar Microgrids should be installed with diesel fuel as a secondary backup, to be disconnected as more PV resources are aggregated. Solar+storage resources provide everyday power and grid services that fossil fuel resources cannot, making them much more cost-effective in the long term.
CPUC: Proposed Decision Resuming and Modifying ReMAT — reply comments | 15 September 2020
The Clean Coalition reply to party comments supports the need for determining avoided cost using similar-sized RPS contracts, time-of-delivery factors, as well as adders for the value of resilience and locational pricing. Comments also specify the need for creating standards for co-located storage and explain why the use of price adjusting mechanisms is more effective than administratively set prices.
CPUC: Proposed Decision Adopting Recommendations from Working Groups Two, Three, and Subgroup — reply comments | 14 September 2020
Clean Coalition reply comments are in alignment with Tesla and CALSSA on a multitude of issues, including the need to lower standard fees to the level of NEM projects, the importance of designating one point person for each interconnection application, and a request that the Commission clarify the decision to remove the size limit for Fast Track eligibility. The Clean Coalition agrees that changing the size limit will only be effective if projects are eligible regardless of the available hosting capacity.
CPUC: Proposed Decision Resuming and Modifying ReMAT | 10 September 2020
Clean Coalition comments decry the Proposed Decision for refusing to consider any party proposals and suggest that at best, the Proposed Decision leaves the door open for the creation of an optimal successor Feed-In Tariff (FIT). Comments include reasons why the Commission must consider properly assessing Transmission Access Charges (TAC) for ReMAT projects and should include adders for resilience and locational pricing. Moreover, the Clean Coalition lambasts the Commission for using the explicit language of PURPA as an excuse not to innovate or logically create a tariff.
CPUC: Proposed Decision Adopting Recommendations from Working Groups Two, Three, and Subgroup | 9 September 2020
Clean Coalition comments support the Proposed Decision as helping to reduce the uncertainty in the interconnection process through the removal of the size limit for Fast Track eligibility and suggests that the Commission approve a proposal to lower upfront fees. The latter section focuses on reasons why the Commission should adopt a proposal to incorporate a GPI/Clean Coalition Roadmap to automation as a way to proactively address the issues the proceeding will need to consider in the next few years as well as a proposal to designate a point person at a utility for interconnection applications of projects over 100 kWA.
CPUC: Community Microgrid Enablement Program | 8 September 2020
The Clean Coalition response supports PG&E’s Community Microgrid Enablement Program, lauding PG&E for taking a role as a community partner to deploy Community Microgrids. The program creates a framework that allows communities to identify their resilience needs, promoting the inclusion of as many customers as possible that can be supplied with 20 MW of renewable resources. The filing concludes with a few Clean Coalition recommendations to increase transparency for the benefit of local governments.
CPUC: Microgrid Track 2 — reply comments | 28 August 2020
Parties, including the Clean Coalition, consider the lack of focus in Track 2 on Community Microgrids and the need for a full microgrid compensation tariff to consider normal instances when a microgrid is not in an islanded mode. Comments strongly address the conservative nature of the proposals in the Staff Proposal, lambasting the Commission for slowing the pace of progress by delaying the definition for a value of resilience and failing to value the public benefit it provides.
CPUC: Distribution Resources Planning IComp AFR | 24 August 2020
The Clean Coalition argues that the Commission is violating the spirit of the Intervenor Compensation program by only focusing on customer status, refusing to consider the Clean Coalition’s substantial contributions to the proceeding. Doing so limits the participation of groups like the Clean Coalition, thus overstating the positions of the utilities, who prioritize rates of return. Second, the Clean Coalition argues that with California’s clean energy goals, the entire state is aligned with the renewable energy industry; since the Clean Coalition has always focused on distribution-level renewable resources and resilience, it should not be discounted from customer status.
CPUC: Microgrid Track 2 comments | 14 August 2020
The Clean Coalition comments focus on criticizing the Staff Proposal for the lack of a standard microgrid tariff, including any type of discussion on resilience and the Value of Resilience. Before getting to the Staff Proposal, the comments note the complete absence of logic in choosing to include a detailed concept paper and then not allow any comments on the Concept Paper into the record for Track 2. For the five proposals, the Clean Coalition supports ambitious positions that enable Community Microgrids and Feed-In Tariff-like pilot programs rather than the Commission’s typical conservative steps that kick the can further down the road.
CEC: IEPR comments | 30 July 2020
In this comment letter, the Clean Coalition advocates that the California Energy Commission (CEC) develop a Community Microgrid pilot in a comprehensive grid area or on a substantial feeder (containing critical facilities). A CEC-sponsored Community Microgrid pilot will run in parallel with the California Public Utilities Commission (CPUC) microgrid proceeding, forcing the CPUC to consider current market distortions, including the assessment of Transmission Access Charges and the lack of a standard value-of-resilience. The Clean Coalition offers the Goleta Load Pocket as an ideal location for the siting of a Community Microgrid pilot.
CPUC: ReMAT ruling — reply comments | 28 July 2020
In reply comments, the Clean Coalition aligns with other parties about the need to deny the Staff Proposal in favor of a two-track proceeding to temporarily apply the Renewable Market Adjusting Tariff (ReMAT) program with modifications and to create the ideal ReMAT program by the end of 2021. Comments also focus on considering existing Petitions for Modification (the Clean Coalition has two), the importance of considering co-located storage, and denying the IOU Proposal, which calls for pricing ReMAT contracts on all resources (e.g., fosil-fuel generation, not just RPS prices).
CPUC: Resuming and updating ReMAT — reply comments | 21 July 2020
This filing represents the Clean Coalition’s reply comments on the Renewable Market Adjusting Tariff (ReMAT) ALJ Ruling and Staff Proposal. The Clean Coalition comments take the approach that the Staff Proposal must be denied since the administratively set prices are based on skewed data from larger RPS contracts that are over two years old, and do not represent a true cost of energy since they do not consider Transmission Access Charges or a value of resilience. Instead, ReMAT must be temporarily applied with the fewest possible changes to allow projects waiting in the interconnection queue to begin procuring, and then an ideal successor tariff must be created based on the Feed-In Tariff the Clean Coalition designed for the City of San Diego.
CEC: Solar+storage is superior to diesel generators for backup power at Microsoft data center | 21 July 2020
In this filing, the Clean Coalition urges the California Energy Commission (CEC) to consider solar+storage primarily, along with other suitable renewable alternatives, to determine how many of the 40 (3 MW) diesel generators could be replaced in Microsoft’s proposed data center project in San Jose, CA. The current proposal does not consider anything beyond diesel generators, which, if installed, will pollute a low-income and disadvantaged community in San Jose.
FERC: Urgency in addressing Transmission Access Charges when valuing DER | 15 June 2020
This filing represents the Clean Coalition’s 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). We submit that approving the petition would further depress the true value of DER, which is why FERC would be better off denying the petition and considering addressing Transmission Access Charges.
CPUC: Intervenor compensation eligibility | 12 June 2020
This filing represents the Clean Coalition’s comments opposing a CPUC Proposed Decision that would find us ineligible for intervenor compensation for participation in this CPUC proceeding, with implications for other proceedings. A finding was made in R.15-02-020 that mischaracterized the work of the Clean Coalition as a market participant rather than an environmental ratepayer advocate, negatively impacting eligibility for compensation for substantial contributions made in CPUC decisions. We argue that the finding erred both legally and factually.
CARB: Advanced Clean Truck regulation support letter | 28 May 2020
In this letter to the California Air Resources Board (CARB), the Clean Coalition applauds the Board for considering a more stringent Advanced Clean Truck rule and urges them to affirm the new rule, with the modification that it be reconsidered in three years (rather than five). We also argue that the rule should apply to all medium and heavy class trucks and request that the definition of “large fleet” be changed from 100 or greater to anything over 50.
CPUC: Microgrids and strategies for valuing resilience – reply comments | 26 May 2020
This filing represents the Clean Coalition’s support of requests from other parties, primarily related to issues surrounding utility transparency with the CPUC and other stakeholders, for assurances that fossil fuel generation is temporary and will be transitioned into renewable resources, including proposals to expedite microgrid interconnection.
CPUC: Microgrids and strategies for valuing resilience | 19 May 2020
This filing represents the Clean Coalition’s argument that PG&E (or any other IOU) installing natural gas generation for resilience should be required to submit a plan detailing a transition to DER and solar+storage microgrids within five years. We promote proposals to expedite interconnection, although we lambast the CPUC’s lack of interest in smart metering. The Clean Coalition also applauds decisions to remove energy storage sizing limits, though we request that the CPUC requires islanding — either in this track or in track 2. Our comments also focus on ensuring that this Proposed Decision promotes progress, not more of the business-as-usual approach by utilities and policymakers; to that end, we request that the Proposed Decision is modified to ensure that the CPUC considers key details (like the value of resilience) and promotes transparency in information sharing between IOUs and key stakeholders.
CPUC: Resuming ReMAT under PURPA | 28 April 2020
This filing represents comments filed by joint parties including the Clean Coalition, public agencies, and private energy firms supporting the proposed expansion of PURPA small renewable energy contract terms and necessary contract lengths to support financing. We additionally emphasize the importance of avoiding a delay in the adoption of PURPA terms in order to allow the associated Renewable Market Adjusting Tariff (ReMAT) procurement program to resume.
CPUC: DER Avoided Cost Calculator and transmission – reply comments | 7 April 2020
This filing represents the Clean Coalition’s reply comments on the proposed decision modifying the DER Avoided Cost Calculator. We reinforce the need for correction of the transmission value of DER in the calculator used across CPUC proceedings. We note agreement from multiple parties in opening comments for both the immediate adoption of interim methodologies and a full refinement before the end of 2020. We also rebut assertions that DER does not mitigate all drivers of transmission investment, detailing examples and expanding upon our opening comments.
CPUC: DER Avoided Cost Calculator and transmission | 2 April 2020
This filing represents the Clean Coalition’s comments on the proposed decision modifying the DER Avoided Cost Calculator. We largely support the proposal with the exception of the transmission valuation. Expressing the true value of transmission costs that can be avoided through the use of DER and microgrids is a critical component of the cost-effectiveness of any sort of DER project, program, or policy. We provide examples of billions of dollars of actual DER-driven avoided annual transmission costs, and argue that the Avoided Cost Calculator must reflect these savings.
CPUC: Proper valuation of DER | 26 February 2020
This filing represents the Clean Coalition’s comments on the CPUC’s Decision Adopting Staff Proposal on Avoided Costs and Locational Granularity of Transmission and Distribution Deferral Values, in which we dispute staff conclusions of negligible value of DER and call for a schedule for consistent valuation across utilities based on the record of factual data.
CPUC: Proving microgrid resilience benefits – reply comments |6 February 2020
This filing represents the Clean Coalition’s reply to the staff and investor-owned utility (IOU) proposals on short-term resilience strategies. The Clean Coalition’s comments prioritize holding the IOUs accountable by tracking the total cost of fossil-fuel generation (proving that renewables-driven microgrids are a more effective solution), sharing information with local agencies, annual verification reports, and pushing for a more widespread deployment of smart meters with islanding capabilities across IOU service territory.
CPUC: Proving microgrid resilience benefits | 30 January 2020
This filing represents the Clean Coalition’s reply to the CPUC administrative law judge’s questions about the staff and investor-owned utility proposals for microgrid resilience strategies. Our comments lambast the potential use of fossil-fuel generation near substations and prioritize DER generation, along with an increase in grid isolation switches, and we illustrate effective use of data sources to map priority microgrid siting. The Southern California Edison proposal includes a portion in Montecito, so our comments use the Montecito Community Microgrid Initiative and greater Goleta Load Pocket area to demonstrate the resilience that a true Community Microgrid can bring and a few of the policies inhibiting them from being built.
CPUC: Improving construction timelines and more under Rule 21 – reply comments | 27 January 2020
This filing represents the Clean Coalition’s reply comments on the CPUC’s administrative law judge’s questions following the submission of proposals for improving interconnection in the Rule 21 Working Group 3 Final Report and workshop presentations. In reply, the Clean Coalition focuses on correction of Cost of Ownership grid upgrade cost allocations improperly burdening new distributed renewables, as well as other issues.
CPUC: Improving construction timelines and more under Rule 21 | 13 January 2020
This filing represents the CPUC’s administrative law judge’s questions following the submission of proposals for improving interconnection in the Rule 21 Working Group 3 Final Report and workshop presentations. The Clean Coalition focuses on those questions related to our proposals regarding use of non-utility contractors to improve construction timelines and correction of Cost of Ownership grid upgrade cost allocations improperly burdening new distributed renewables, as well as other issues.
CPUC: The Avoided Cost Calculator and avoided transmission value | December 30, 2019
This filing represents the Clean Coalition’s support for the staff proposal (with the exception of the transmission valuation) that the Avoided Cost Calculator (ACC) needs to adopt an avoided transmission value pending future refinement in the DRP proceeding. Expressing the true value of transmission costs that can be avoided through the use of DER is a critical component of the cost-effectiveness of any sort of DER project, program, or policy. We provide examples of billions of dollars of actual DER driven avoided annual transmission costs, and argue that the ACC must reflect these savings.
CPUC: Streamlining interconnection in 2019 | December 24, 2019
The Clean Coalition submitted comments on the policy mechanisms needed to streamline interconnection via the Clean Coalition’s WDG Streamlined Interconnection Pilot and an Interconnection Roadmap for Automation written by Sahm White and Tam Hunt of the Green Power Institute. The comments mentioned interconnection difficulties experienced during the VGES interconnection process as well as the interconnection case study currently being prepared. The comments end with a short reply on the other proposals presented at the forum
CEC: Climate adaptation and the Clean Coalition’s work | November 27, 2019
This filing represents the Clean Coalition’s comments on the CEC’s Integrated Energy Policy Report Workshop on Climate Adaptation. The Clean Coalition appreciates the focus on supporting microgrids with distributed energy resources (DER) for critical facilities and believes it is crucial for the IEPR to consider measures needed to proliferate Community Microgrids in California. This proliferation can be ensured by reforming the way Transmission Access Charges (TAC) are assessed, divesting the IOUs of their transmission assets, streamlining interconnection for wholesale distributed generation (WDG), establishing effective procurement methods like a market-responsive Feed-In Tariff (FIT), and standardizing a Value of Resilience for all electric loads (VOR123).
CPUC: Extended Day Ahead Markets and Transmission Access Charges | November 22, 2019
This filing represents the Clean Coalition’s comments on the issue paper in the CAISO stakeholder process on Extended Day Ahead Markets (EDAM). Our recommendations focused on reforming Transmission Access Charges (TAC) so they are measured at transmission distribution stations rather than at individual customer meters. Implementing this solution in coordination with the CPUC would promote the deployment of Distributed Energy Resources (DER) for EDAM, saving 3 cents per kilowatt on local clean energy projects and reducing the need for transmission infrastructure expansion.
CPUC: Valuing resilience with Community Microgrids – reply comments | November 4, 2019
This filing represents the Clean Coalition’s reply comments on the opening comments made by 36 parties about the Preliminary Scoping Document for Rulemaking 19-09-009. The Clean Coalition called for a focus on Community Microgrids and focused on comments by parties explaining that they are an important alternative to expanding the transmission system for the sake of grid hardening and provide both baseload and backup power for a community. We recommended that based on the consensus about the importance of Community Microgrids as a resilient solution, an essential part of this proceeding must be to create a standard value of resilience. These comments were made regarding California Microgrid Bill SB 1339.
CPUC: Valuing resilience with Community Microgrids | October 21, 2019
This filing represents the Clean Coalition’s opening comments advising the CPUC to focus the upcoming proceeding on Community Microgrids, with a focus on the Goleta Load Pocket as the ideal location for a pilot program. We recommended the CPUC properly value resilience by using VOR123 as well as implementing a Feed-In Tariff mechanism, with Market Responsive Pricing and a Dispatchability Adder (DECS), to streamline the procurement of renewable resources for Community Microgrids. These comments were made on the Order Instituting Rulemaking (OIR) Regarding Microgrids Pursuant to SB 1339.
CPUC: Reopening ReMAT and supporting pending projects | August 13, 2019
This filing represents the Clean Coalition’s joint party letter in response to the Appleate Court ruling upholding a stay on the CPUC’s renewable energy market adjusting tariff (ReMAT) due to the failure to also offer PURPA compliant alternatives. We offered legal analysis to make it clear that there is no actual injunction against ReMAT and that pending projects should be allowed to contract without further delay following approval of the draft Proposed Decision.
CPUC: ICA maps and groundbreaking transparency into the California’s energy distribution system | August 1, 2019
This filing represents the Clean Coalition’s opening comments on refinements to the newly implemented Interconnection Capacity Assessment (ICA) maps and data access to improve their user functionality and continue development of this groundbreaking transparency into the California’s energy distribution system. While continuing to support the long term recommendations of the ICA working group in which we were a leading participant, we drew attention to issues with the initial statewide implementation. We also further promoted the use cases for the ICA beyond the interconnection process itself, addressing its important role in planning appropriately targeted local distribution investment and assessing the impact of policy options.
CPUC: Urging reinstatement of ReMAT | August 1, 2019
Ths filing represents a joint party letter in response to the Appleate Court ruling upholding a stay on the CPUC’s renewable energy market adjusting tariff (ReMAT) due to the failure to also offer PURPA compliant alternatives. The Clean Coalition urged the CPUC to promptly approve the PURPA options in the December 2018 settlement proposal and re-instate the ReMAT program without delay.
CPUC: Comments on Interconnection Practices and Distribution Resources Planning maps | July 17, 2019
This filing represents the Clean Coalition and Green Power Institute’s joint informal comments offering written feedback following the initial stakeholder meeting on publication of ongoing deployment data. The Clean Coalition strongly supports the framework currently utilized for CSI and NEM data with the addition of greater granularity by size, technology and location, and alignment with related Distribution Resources Planning maps (ICA, LNBA and GNA).
CPUC: Comments on the Interconnection Practices Evaluation Research Plan | July 10, 2019
This filing represents the Clean Coalition and Green Power Institute’s joint comments offering written feedback following the initial stakeholder meeting on the proposed Interconnection Practices Evaluation Research Plan. The Clean Coalition strongly supports the initiative, but calls for more extensive research questions, data development, and outreach covering all applications of 100 kW and above, and analysis of results prior to initial development of recommendations.
CPUC: Methodologies for calculating avoided distribution and transmission costs attributable to DER growth | June 21, 2019
This filing represents the Clean Coalition’s brief comments on the white paper prepared by the CPUC’s Energy Division related to methodologies for calculating avoided distribution and transmission costs attributable to DER growth in the Avoided Cost Calculator, Locational Net Benefits Assessment, and associated proceedings. While we support the distribution level methods, the estimated results at the transmission level are far below actual reported. We submitted evidence and cited examples of actual transmission savings and methodological factors for further consideration.
CPUC: Procuring energy storage with a FIT approach and market responsive pricing| March 9, 2019
This filing represents the Clean Coalition’s proposal to amend the Proposed Decision modifying the applications by SDG&E, PG&E, and SCE regarding procurement of new energy storage in compliance with AB 2868. We broadly support the PD but oppose the use of an RFO bidding procurement process and recommend use of a FIT approach with Market Responsive Pricing. This avoids the costly barriers to participation inherent in RFO bidding, which is inappropriate for distributed resource procurement. A FIT will result in greater market participation and lower costs for ratepayers.
CPUC: Appropriate allocation in interconnection | February 22, 2019
This filing represents the Clean Coalition’s review and reply to opening responses to the CPUC ALJ’s questions regarding the Final Report of Working Group 2 on Interconnection Streamlining. Our brief comments focus on the issues raised regarding assessment of costs and benefits of investment in improvements in interconnection processes and appropriate allocation.
CPUC: Intervenor compensation arguments | February 21, 2019
This filing represents the Clean Coalition’s comments opposing CPUC Commisioner Randolf’s Alternate Proposed Decision which would find us ineligible for intervenor compensation for participation in this CPUC proceeding, with implications for other proceedings. A finding was made in R.15-02-020 that mischaracterized the work of the Clean Coalition as a market participant rather than an environmental ratepayer advocate, negatively impacting eligibility for compensation for substantial contributions made in Commission Decisions. We argue that the finding errored both legally and factually and the Commission adopt the earlier Proposed Decision of Administrative Law Judge Hymes awarding compensation. The ex parte letter to the CPUC is located here.
CPUC: Reopening the ReMAT program in California | February 20, 2019
This filing represents a joint letter to CPUC commissioners urging the CPUC to proceed with adopting the PURPA Proposed Decision to enable the ReMAT program to be reopened without delay and proceed with approved procurement of the remaining 200 MW of capacity.
CPUC: Threats against the Green Tariff Shared Renewables program | February 8, 2019
This filing represents the Clean Coalition’s response related to Southern California Edison’s application to terminate the Green Tariff Shared Renewables program and replace it with five proposed Green Energy Programs. We argue that a Feed-in Tariff can be implemented consistent with Senate Bill 43 and is a better alternative.
CPUC: Final report on interconnection streamlining | February 1, 2019
This filing represents the Clean Coalition’s responses to the CPUC administrative law judge’s questions regarding the Final Report of Working Group 2 on interconnection streamlining, with a major focus on integration of newly available ICA hosting capacity results into the interconnection application review process and tariff, and other process and automation improvements.
CPUC: Opposing restricted access to PV RAM maps with IREC, SEIA, CSSA, and Vote Solar | January 9, 2019
This filing represents joint comments with the Interstate Renewable Energy Council (IREC), Solar Energy Industries Association (SEIA), California Solar & Storage Association (CSSA), California Community Choice Association, and Vote Solar to oppose the investor-owned utility Petition for Modification to restrict access to exising PV Renewable Auction Mechanism (RAM) interconnection maps and application of a non-disclosure agreement. We argue that utilities have not shown cause and note established compliance with prior rulings requiring publication, including the recent Ruling (R.14-08-013 Dec. 17, 2018) denying identical utility action related to the new Interconnection Capacity Analysis hosting capacity maps.
CPUC: Joint letter on Resource Adequacy Proposed Decision | January 3, 2019
This filing represents a joint letter to California Public Utilities Commission (CPUC) Commissioners urging the rejection the Proposed Decision issued November 21, 2018 regarding Resource Adequacy (RA) which puts investor-owned utilities (IOUs) in an exclusive central buyer role for local RA and allows IOUs to recover RA costs through non-bypassable charges. Most parties agree that a “residual” rather than “full” central buyer model is the better choice.
See this page for the previous decade of Clean Coalition regulatory filings
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