Experts Only Podcast #127: Unpacking the Proposed Decision on Community Solar in CA

Welcome back to Experts Only Podcast!

There’s been a lot of excitement about unleashing a community solar market in California, and the potential to make it one of the most equitable community solar programs in the country. However, a March 4th proposed decision by the California Public Utilities Commission has put a community-solar plan backed by lawmakers, pro-solar groups, environmental-justice advocates, unions and homebuilders in jeopardy. This episode, our guest host, Scott Elias, better known as “ScottySolar,” welcomes Derek Chernow from the Coalition for Community Solar Access, Matthew Freedman from The Utility Reform Network, and Alexis Sutterman from the California Environmental Justice Alliance to unpack the effort to revamp California’s community solar market amidst the CPUC’s proposed decision.

Thank you for listening!

For more information:

Comments of the Coalition for Community Solar Access on Proposed Decision Modifying Green Access Program Tariffs and Adopting a Community Renewable Energy Program

Former FERC Chair and CCSA challenge Proposed Decision on California community solar in opening comments

Our Sun. Our Power. California

 

Transcript

Jon Powers (00:02):

Welcome back to Experts Only. I’m your host, Jon Powers. I’m the co-founder of Clean Capital and serve as President Obama’s chief Sustainability Officer. On this podcast, we explore solutions to climate change by talking to industry leaders about the intersection of energy, innovation and finance. You can get more episodes@cleancapital.com.

Jon Powers (00:29):

Welcome back to Experts Only. I’m your host, Jon Powers. Today we have a special episode. There’s been a lot of excitement about unleashing a community solar market in California and the potential to make it one of the most equitable community solar programs in the country. But as of March 4th, the proposed decision by the California Public Utilities Commission has put a lot of that momentum at risk. The Community Solar plan backed by lawmakers, pro solar groups, environmental justice advocates, and others is in jeopardy. So today we have a guest host got Elia, who is known as Scotty Solar in the industry. He welcomes Derek Turnow from the Coalition of Community Solar Access, Matthew Friedman from the Utility Reform Network, and Alexis Suman from the California Environmental Justice Alliance to unpack the effort to revamp California’s community solar market amidst the California PUCs proposed decision is a very important topic and something we should all be paying close attention to for the future of our industry. I hope you enjoy the conversation.

Scott Elias (01:22):

Welcome back to Experts Only. I am your guest host Scott Elias. Though most folks in the industry know me as Scotty Solar, I’m the Vice President of Policy and Market Development at Clean Capital, and today we are speaking with Derek Cherno from the Coalition for Community Solar Access, Matthew Friedman from the Utility Reform Network and Alexis Sutter from the California Environmental Justice Alliance. There’s been a lot of excitement about finally unleashing a community solar market in California and the potential to make it one of the most equitable community solar programs in the country. This effort has resulted in the creation of a broad coalition focused on making this market opportunity a reality. And luckily we have three guests central to that story. So let’s dive in. Derek, can you start by explaining the work you and the Coalition for Community Solar Access have been doing the past few years that have brought us to this point?

Derek Chernow (02:10):

Yeah, absolutely, and thanks for having us on, Scott. Really appreciate it. California has got a failed history of community solar over the last decade, and CCSA working with the Broad Coalition, including the folks here on this podcast, have really been working diligently over the last several years spending the time, the effort, putting in resources to put in a community solar and storage program. That makes sense. So in 2022, we worked with assembly member Chris Ward on the passage of assembly bill 2316, and that laid out a few parameters for what would ultimately be a successful community and storage program, and that was signed into law by Governor Newsom as part of a suite of climate change bills. We really encourage and it called on the PUC, the Public Utilities Commission to do two things. One, examine current programs if they’re failing, then it tells ’em to do two, put in a community renewable energy program that makes sense again with these various parameters such as 51% low income subscribers and a number of other key points.

(03:12):

So we went through 2023 with a very intense regulatory process, submitting quantities of testimony and work papers and data supporting the net value billing tariff again with a broad coalition working together, making compromises as a coalition and coming forward with a generally broadly based support for the net value billing tariff supported by rate payer advocates, environmental justice groups, the building industry labor, just a really broad coalition. And then earlier this month, administrative law judge at the Public Utilities Commission came through with a proposed decision which completely upended all that. So here we are today going through a round of comments and trying to really reinforce the need for a program that makes sense, a rewrite of this proposed decision as the PUC looks to move forward.

Scott Elias (03:58):

Great. And I want to definitely dive in. Let’s put a pin for a second in what did the administrative law judge do? I definitely want to unpack that, but for those that are not familiar, what is the simple version? What is a net value billing tariff for those that are not familiar with

Derek Chernow (04:10):

That? Yeah, absolutely. So the net value billing tariff again, was a broad brace of support and it basically enables households that can’t access rooftop solar such as renters to subscribe to a community solar and storage. And the storage part is key, the storage project and then share that portion of the savings generated by the project and that will lead to lower monthly electric bills for so many under the NVBT, 51% of all project capacity is reserved for low to moderate income Californians and it guarantees LMI subscribers will save at least 20% of the savings generated. Those are some of the key points, but some of the other parts is that it really incentivizes the solar back onto the grid during those peak periods, those three months of the year, four hours of the day, those hottest summer months between six to 10 at night. But it allows that flexibility where those hours can shift if our peak hours shift as well. So the MVBT is really a tool that is based on the avoided cost calculator, which Matt is so good at describing, but it is really a distributed energy resource tool.

Scott Elias (05:17):

Right. Very helpful and I think we’ll get to that in a bit. I want to actually turn over to you, Matt. I mean I think it’s safe to say for those that have been following the conversations in California, there’s rarely a consensus in California over solar policy, right? There’s been battles over solar being pitted against clean energy and consumer advocates being pitted against each other in the past. And so Matt, from terms standpoint, what’s different about community solar in California?

Matthew Freedman (05:44):

Well, you’re right that groups have not been aligned with respect to the policy the state should pursue for distributed energy resources and particular, this really flared up around the reforms to net metering that the commission adopted back in 2022. And the big debate there is was it appropriate to compensate customers for distributed solar based on retail rates or some other measure of the value that those resources provide to the system? Historically, California and most states have compensated rooftop solar based on retail rates. And in my view, that was fine as long as there wasn’t a significant cost shift or subsidy that was creating rate distortions for everybody else. Well, distributed solar has been a huge success story in California. We’ve seen massive growth particularly over the last five years. At the same time, retail rates have skyrocketed due to a variety of factors. And so there’s been an increasing disconnect between the compensation level provided for distributed resources under net metering and the value they provided the system.

(06:49):

So with that debate in mind, enter community solar and the community solar proposal would have customers who subscribe to shared solar facilities getting bill credits based on the value that those solar facilities provide to the entire grid. And how would you measure that value? Well, it turns out that California has been engaged in a process to develop something called the avoided cost calculator. And the avoided cost calculator is an hourly measure, meaning there’s a metric and a value for every single hour of the year for the next 25 years that looks at what the value of an exported kilowatt hour to the distribution system would look like. This was the approach that the Public Utilities Commission took for valuing exports from rooftop solar as part of net metering reforms, but they also proposed including an adder. So it would be the avoided cost plus a subsidy on top of that.

(07:49):

Well, the community solar proposal would involve no subsidies. It would compensate all of the production from these solar facilities based on the avoided cost methodology that the state has adopted for exactly this purpose. And so that’s sort of what allowed us to break the log jam around the disputes between consumer groups and the solar industry about the way to move forward. Add on top of that, the fact that we’ve got these large new federal tax credits, particularly the 50% investment tax credit that was adopted in the inflation reduction Act for what are called low income economic benefit projects, which is another way to say community solar with a very interesting twist. The interesting twist on it is that the tax credits require that at least 51% of the output be credited to low income customers. This kind of flips the script distributed. Solar has always been criticized for being a toy of the wealthy and really catering to people who had money to spend on things like putting stuff on your roof or customers who actually owned a home. And were lucky enough to do so in a state like California where the costs of living are so sky high, well, community solar with a 50% investment tax credit really is focused on participation by low income customers, renters, people who have homes that communities can’t host, solar projects, commercial tenants that lease their spaces, all these customers that were shut out of traditional rooftop solar programs and providing the lion’s share of benefits to those facing the largest affordability problems. So that gets groups like mine really interested.

(09:40):

I’ll add one more thing which changed the conversation for us, which is the availability of a lot of federal money through the US Environmental Protection Agency, solar for all fund and state money coming from the state’s general fund because our view has been if you want to subsidize rooftop solar or distributed solar, let’s find sources of money outside of electricity rates because electricity rates are a very regressive way to collect money from customers. So if we can find more progressive sources of money, then we can layer that on top of what comes through rates. So this was really the confluence of a lot of things that got us to be supportive of this approach. And as Derek said, the proposed decision that came out recently is extremely disappointing and a number of us are working to try to turn that around.

Scott Elias (10:25):

Right. No, thank you. That’s helpful. I know some of my solar friends on the DG side would maybe pick at pieces of what you said there, but for the sake of focusing on this community solar conversation, I want to dive in a little bit on what you sort of ended with there. And I think it’s a good segue to Alexis, because what you’ve talked about here is we have this really broad coalition. Very rarely does everyone agree in California it seems like it’s basically everyone but the utilities and maybe the CPUC that are sort of in agreement on this. And one of the things here is, Alexis, I’m pretty sure that California has 17 million renters, which is more than the entire population of New York, which arguably has the most established community solar program in the nation. And so given that, how does community solar relate to environmental justice and where do you fit into this conversation?

Alexis Sutterman (11:11):

Yeah, thanks so much, Scott. Appreciate the invitation to speak here. Yeah, I think I want to start out by just naming, I think what we all know, which is that low income communities in California and disadvantaged communities are really the ones that are the most overburdened by pollution and also the least resource to actually protect themselves from intensifying climate disasters and threats that are just getting worse and worse every day. And as environmental justice advocates, we saw, we see a lot of promise in the clean energy transition to actually change that and really advance our vision for energy democracy and put more power in the hands of the people, yet decades into it, not really seeing this result. We’re not seeing the clean energy transition live up to this promise to really change who benefits in society and actually uplift those who have been the most harmed by environmental racism and institutional neglect.

(12:07):

And we’ve seen clean energy still benefiting largely wealthier homeowners while our lower income folks, renters a majority of population really being locked out of a lot of these benefits to improve their lives and see reduced bills and higher quality of life through solar energy. And so we see community solar really advancing environmental justice. And in many ways, I’ll point out three, one being kind of what we’re already talking about with access and savings. We’re at a time where bills and rates are skyrocketing and we know that this is especially harming our lower income folks who might have to make a decision on month to month of, do I pay my rent, do I pay my utility bills? Do I not get the food and medicine I need? So these are really dire conditions that people are in right now, and they really need a lifeline.

(13:01):

Community solar can be that lifeline and should be an option for folks to reduce their energy bills and having a more affordable bill while they’re contributing to the clean energy transition. A second huge promise we actually see in community solar and storage is that these projects can be utilizing the built environment with the incentivization of storage. We can get projects online in just the next couple of years, and this is critical to actually retire the polluting gas plants that are currently majority located in disadvantaged communities and contributing to really severe health issues. Higher NOx emissions and higher pollution in these areas are causing people to go to the hospital more, have their kids grow up with asthma or bronchitis. We cannot take this lightly. We have to be getting off of these gas plants as soon as possible, even yesterday if possible, and we’re severely delayed in getting these retired.

(13:58):

So anything that the state can do to actually promote the development of local community solar and storage in these key areas of California that are, especially the ones that are transmission constrained, we should be doing everything we can to get those projects built and get those gas plants retired. So that is also an EJ priority. And the last thing I’ll say on this is there’s also some really exciting energy democracy opportunities from community solar and storage development. We have some partners in our mix of things who are community-based organizations that want to support solar development and have really struggled on actually finding a program and a mechanism that can actually support them in doing what they could do to maximize benefits for their local community. So there is a huge opportunity for the NVBT to really be a foundation to unlock all of these ambitions in this project development, but we are really disappointed that the PD is not at all moving in that direction. And just want to echo Matt, that we’re going to be doing everything we can to reverse that decision.

Scott Elias (15:04):

Yeah, yeah. No disappointment, shock. I’ve heard all sorts of different words to describe how different stakeholders are viewing this, and I think you each bring a different voice to why you want to see a community solar come to California. And I want to focus now on the reasons maybe you all are disappointed. So let’s unpack this. So on March 4th, the California Public Utilities Commission released a proposed decision that in the words of many has put the California community solar market in jeopardy. Can you help me unpack what actually happened?

Derek Chernow (15:42):

Yeah, I’ll start off, and Matt and Alexis, I’m sure will chime in as well, but essentially the proposed decision, again from the administrative law judge declined to adopt the net value billing tariff, and I think doubled down on the pattern of failed policies here in California by really adopting a utility design program that relies on essentially a federal program called purpa. So it accepted the IOU’s radical legal argument that community solar facilities are wholesale generators akin to large transmission scale power plants instead of distributed energy resources. This absolutely flies in the face of the CPU C’S own definition of distributed energy resources and the accepted legal standards in 21 states in the District of Columbia. So the outcome of this is that if they are paying the purpa compensation, we’re not going to get any development. So we’re not going to get any of the clean storage and generation, we’re not going to get low income savings and subscribers.

(16:57):

We’re not going to get any of these things because there’s not going to be any projects built under purpose. There’s only been two solar projects built the entire history in California, one in 1993 and the other in 2014. So clearly Purpa or PURPA minus, if you want to call this proposed decision, a PURPA minus program doesn’t get us there. In addition, it flies in the face of a number of things besides the outlandish federal claim. It says that storage isn’t going to be voluntary. It really dismisses legislative intent. And what we’ve seen are some recent statements and actions by legislators that said, wait a second. Let’s be very, very clear on what our legislative intent is. And we completely disagree with the proposed decision. We saw that from assembly member Chris Ward, we saw that from Senator Josh Becker recently. So this proposed decision really takes a dramatic, misinformed, misguided turn away from where California should be heading and where California usually heads as a leader in clean energy programs, whether it’s cars and trucks, appliances, or building standards.

Scott Elias (18:07):

I want to get back to the national piece of that in a second, but I want to turn quickly back to that topic of equity. Before we go into anything else. I really think we should be prioritizing equity in the clean energy transition, but it sounds like what you’re saying is the proposed decision is basically a program that relies on a model with a failed track record. And so I guess my question is what are the implications of this proposed decision to California’s objective of ensuring that renters in low income Californians are afforded the same opportunity to participate in the clean energy transition? Alexis, I don’t know if you want to start. Yeah,

Alexis Sutterman (18:39):

No, yeah, for sure. Thanks. And I mean, I think when we took a look at this proposed decision, it was worse than even our, I mean, this was worst case scenario for us for sure, just looking at this being unworkable, unworkable methods that have a proven track record of failure. It’s just for us, even when you look at the AB 2, 3 16 requirements, some of them being robust access by low income customers, and we see a nod to encouraging low income customer subscriptions in the pd, but the fact of the matter is if there’s no projects being developed, we’re not going to actually see subscribers actually get these bill savings. And to the other point that I mentioned earlier, we need clean energy to come online as soon as possible with the storage to get our gas plants retired. So this, in addition to not providing access, is just not furthering our clean energy and environmental justice goals and is extremely unworkable.

(19:37):

I think one more thing I want to add as a point of irony and genuine frustration from environmental justice advocates is that the commission and the administration constantly talk about affordability as if that’s their number one priority. And yet we question affordability for who, if we’re not going to allow an option for renters and low income communities to actually see more affordable bills or a path forward there, it does feel particularly ironic and inequitable to not provide that option and to actually use the affordability framing as kind a cop out. I think the commission is pretty obsessively focused on not creating any cost shift. And I’m sure Matt can speak to this a bit more, but I think it’s just really, really tone deaf for us and not really looking at the full scope of what’s needed on energy affordability.

Scott Elias (20:36):

Yeah, I think Matt, it would probably useful to go to you now. I mean, we’ve heard the industry perspective. We’ve heard the environmental justice perspective and in the pd, it’s effectively making this, that it’s community solar is wholesale generation, and it’s creating sort of a cost shift. So what’s turn’s perspective on this?

Matthew Freedman (20:54):

Well, the proposed decision compares the pricing for community solar under the proposal that CCSA put forward with an alternative in which customers would pay the federally sanctioned avoided cost under purpa for large scale transmission interconnected generation. The problem with that comparison is that the purpa avoided cost values aren’t getting new projects developed. As Derek mentioned, California has a program today and for many years where any generator under 20 megawatts in size that’s renewable can sign up for a contract and get that avoided cost. So if that avoided cost, were a fair measure of value and a fair measure of what a developer needs to finance a project and operate it and earn a reasonable profit, we would see a flood of these projects signing up.

Scott Elias (21:52):

Right. We’d be buying them.

Matthew Freedman (21:54):

Right. The programs have been anemic at best. There have been a handful of projects developed under purpa and under a program called the Renewable Energy Market, adjusting Tariff, which is another program that relies on these federally sanctioned avoided costs. So it’s not really a good metric for thinking about the cost effectiveness of the community solar proposal. In addition, the community solar proposal in front of the PUC would also allow for this program to be used to comply with the new solar home building standards in California, which apply to new residential construction. In short, new residential construction has to include solar. So you have two options. One, you put the solar on the roofs of those houses. Two, you provide a measure of alternative compliance. What would alternative compliance look like? It’s a community solar program. That’s pretty much it. So one way to think about the comparison with respect to total costs to the system is is it more expensive to all rate payers to have all the new buildings use all rooftop solar, or would it be less expensive to have some of those customers subscribe to a shared community renewable energy facility? That by the way, also includes energy storage. And when you do that comparison, it is a slam dunk for community solar. I know that CCSA did some calculations in the case just one number. If you took 400 megawatts of new solar demand and you satisfied it with community solar versus rooftop solar, the net present value savings over 25 years to the entire system would be $4 billion.

Scott Elias (23:41):

Wow.

Matthew Freedman (23:41):

Right. And the building industry has said they forecast the need for between 250 and 400 megawatts of new solar per year to satisfy the new solar home building requirement. So we’ve got a huge market here, and this is a way to think about community solar as a huge cost savings. So I think that’s one thing that the proposed decision just really didn’t think about at all. But it’s clear from reading the proposal that was issued by the PUC, that there was a high level decision that they aren’t interested in the community solar program. And the logic is tortured in the decision and the facts are wrong. And the proposal to adopt this alternative approach, which would rely on failed existing programs means that what comes out of this proceeding is really doomed to fail, but it’s even worse. And what’s worse about it is that you’ve asked questions about what does this mean for California?

(24:44):

But the proposed decision includes a lengthy section that basically concludes that the community solar proposal in California, which by the way on this point would look like the community solar proposals in 20 plus other states is preempted as a matter of federal law. This is a very wonky topic, but what’s the consequence of the California Public Utilities Commission adopting a decision that says this kind of program is preempted by federal law? Well, I think it invites challenges to community solar programs across the country. This is really crazy because no state or federal court or federal agency has ever found that these community solar programs are preempted as a matter of federal law. In fact, the federal government has multiple agencies who are dedicated to promoting community solar programs, the US Department of Energy, the US Environmental Protection Agency, the US Department of Health and Human Services, and you’ve got a tax credit that was passed by Congress that specifically applies to these types of programs. So are they unaware of the fact that community solar programs are prohibited as a matter of federal law? Of course not.

Scott Elias (25:54):

Right. No, I think you make an excellent point, and I won’t name names, but I think there’s been conversations around the industry of like, is this an existential threat to our business model? And so as I understand it, the pd Yeah, you’re right. It’s saying effectively, community solar is illegal under federal law and violates purpa. Now, I know we don’t agree with that, but the other day I saw a press release entitled Former FERC Chair Slam BO’S Decision on California Community Solar. So Derek, can you help me unpack this? And just to reiterate, has FERC ever invalidated a community solar program before?

Derek Chernow (26:27):

No. And that’s a really key point. They have not. And former FERC chair, Norman Bay weighed in on this as part of our opening comments that we submitted recently, and we’ll do so again in our reply comments. But he said, one thing is clear, and I’m quoting from Norman Bay. He said, FERC has never invalidated a state community solar program. And as a legal and policy matter, FERC has refrained from asserting jurisdiction over community solar. And he goes on to explain why. And as Matt pointed out, there’s a number of federal programs as Norman Bay had asserted in official comments that were filed, but a number of federal programs that explicitly support community solar and storage explicitly support the Justice 40 goals established by the federal government via community solar and storage. So these programs are operating throughout the state. FERC has specifically decided not to weigh in and leave it to the states alone. So it’s pretty clear that the growth of community solar should continue. Not only should continue, but the federal government is actively supporting that.

Scott Elias (27:39):

Yeah, no, great. And thanks for clarifying that. I mean, I think the other thing, obviously the stakes here are high. This is a really serious matter, but at the end of the day, this is a proposed decision and nothing California is doing can invalidate what New York is doing or what Maryland is doing or what New Jersey is doing because they don’t have any authority there. And so I just want our listeners to know this is a blueprint. This is bad, but this isn’t actually challenging right now, those existing programs across the country. But to that point, this is a proposed decision. For those that are not familiar with the wonky process of dockets, what is a proposed decision? Does this mean California will not have a community solar program? What happens next?

Derek Chernow (28:24):

Matt, you want to take that one as the resident expert on the PUC machinations?

Matthew Freedman (28:29):

Sure. Well, when a proposed decision is issued by an administrative law judge, all parties have a chance to comment. And after the comments have been received, the proposed decision gets modified or updated, and then it goes to the full commission for a vote. There are five commissioners at the PUC, they have to vote for this. At the same time, any one of those commissioners can sponsor an alternate decision, which basically would say, not the proposed decision, let’s do it differently. And I know that parties including turn, have been urging commissioners to issue an alternate decision. So until it’s adopted, it isn’t adopted. However, it’s a bad sign, particularly because the assigned commissioner to this proceeding is the president of the PUC, and she does wield quite a bit of influence, and it suggests some kind of endorsement of this approach by Governor Newsome since the PUC appointees we’re all appointed by the governor and responsive to his concerns. So I think that one of the things that a lot of groups are doing is wanting to put the governor on the spot and say, is this really your intention to kill community solar in California and to have California’s actions essentially become the angel of death for community solar all around the country? I don’t think that the governor’s office is aware of the national implications of this decision, and we’re trying to make them aware of that so they can reconsider.

Scott Elias (30:03):

Yeah. Wow. Angel of death for Community Solar. That would be quite a legacy for the governor. So Derek, talk to me a little bit. It sounds like there’s an opportunity here. Things are not final. What if someone in the industry listening to this or you’re a concerned citizen, what can people do right now to help ensure an alternative decision?

Derek Chernow (30:26):

Yeah, that’s a great question. And as Alexis and Matt have touched on, there’s a broad coalition that are working diligently to ask the PUC and work with the PUC on an alternative decision or rewrite of this proposed decision so it isn’t final, and there’s still a window of opportunity for the state to get it right. And we’re doing everything we can as a coalition to make sure that it does get it right. And California once again retains its leadership mantle in the clean energy space. But there’s a number of things that are taking place. Recently there were a number of CEOs over about three dozen CEOs pen a letter to the governor talking about the investment that is not going to be made in California. If this proposed decision stands, I think there’s a number of groups that are working on advocacy to the PUC.

(31:14):

We have an our sun, our power website with the California page where folks can go learn more and take action and send a note over to the PUC. I know there’s a lot of folks interested from around the country, as Matt alluded to. I think there’s a lot of elected officials and commissioners and energy office officials around the country who are keeping tabs on this, but also are looking to weigh in and remind California that their states are doing well with community solar and it’s time for California to step up their part as well. So there’s a lot of pieces currently taking place right now from advocacy, political pressure, and then of course from the media. And I think what we’ve seen are a lot of folks, again, in this broad support for who’ve come forward in support of the net value billing tariff. And we saw that recently from a farm worker advocacy group come out with an op-ed in the Bakersfield, California and earlier this month talking about how the net value building tariff can really help real people in California see those bill savings that Alexis talked about earlier. So there’s a lot taking place from a lot of different angles to make sure that California gets this right.

Scott Elias (32:27):

Great. That’s been really helpful. Anything else from either Matt or Alexis on your end that you want to sort of chime in with here?

Alexis Sutterman (32:36):

Yeah, I’ll just add, I echo what Derek shared so many avenues to make a public outcry on this and just want to echo that a lot of legislators in the legislature are looking closely at this just given so many supporters of AB 2, 3, 1 16 and all the thought and care that went into that bill to make sure they were clear requirements for a new community solar program. And we are seeing almost all of them not met by this alternative program that the commission is proposing. So there’s definitely a tie into the legislature, as Derek mentioned, the governor and Matt mentioned the governor’s office definitely need some education and needs to hear the public outcry on this. So welcome folks to write letters and make the right calls there. And then of course, for the CPUC voting meetings that take place, those are great opportunities for folks, community members, citizens to share their disappointment, just especially those that are not formal parties to the proceeding because formal parties express through the comments and there’s some rules around that.

(33:43):

But for those who are not at all involved in the formal proceeding and are seeing this now and are disappointed and frustrated, definitely welcome folks to show up there. And I think this is not the end, and we really, really want to make sure that on all sides, people are really hearing the disappointment with the commission. And for environmental justice advocates, we’ve been working on trying to expand solar access for decades. This really feels like a critical moment to make sure we don’t see a decision that actually puts us deeper into environmental injustice and worsens energy, well deepens energy and equity.

Scott Elias (34:27):

Yeah. Thank you. And Derek, thanks for noting that we will definitely make sure that our audience has the link to on our power website and resources on the comments. You all in turn have submitted in this. Matt, anything else you want to close out with to include here?

Matthew Freedman (34:46):

Yeah. California has been struggling with ways to meet its reliability needs on the electric grid in recent years. And there’s been a lot of concern about whether there are adequate resources available to meet our needs in the middle of this decade in the next 2, 3, 4 years. There’s been so much concern about that that a couple of years ago, the legislature and the governor got together and authorized huge expenditures of public funds to have the state itself go subsidize the construction of a bunch of gas plants and lock in very expensive contracts to ensure that the lights stay on well in that framework. What role could community solar play in meeting the state’s near term reliability needs? Community solar projects as proposed by CCSA and supported by us would include a one-to-one ratio of solar capacity to storage capacity with four hours of energy storage. That’s kind of the gold standard for new solar projects that are paired with energy storage.

(35:52):

And that provides the ability of these projects to meet our peak needs in the late afternoon and early evening when the grid is straining in the peak summer months. Right now, projects that are attempting to connect to the transmission grid are facing long delays. There’s a huge overload of the transmission interconnection process. So given the delays that projects are facing at transmission, shouldn’t we be looking at ways to bring on projects cheaply and quickly that connect to the distribution system where there might be easier opportunities to provide these same benefits? And that’s where community Solar could play a really pivotal role, especially with the federal tax credits that are somewhat time limited and a slug of federal money that should be available to help us to bridge that gap. So I think from the perspective of system reliability and meeting the state’s resource planning needs, community solar can play a really important role in the next few years that if this tool is then taken off the table, it makes the challenge that much harder.

Scott Elias (36:54):

Yeah, no, I mean it’s fascinating here. This has been a great conversation. California is usually a leader. It shouldn’t drag the US backward, and there’s still an opportunity it sounds like, for state officials to get this right and hopefully we can get an alternative decision and reverse course. But Jon likes to end by challenging the audience to be fighting for the policies we care about. And I’ll end by reminding you all of the importance of investing in the trade associations like the Coalition for Community Solar Access, see a and countless local groups that put in the work to make your market opportunities a reality. For more information and the resources referenced in the podcast like the proposed decision and CCS a’s response, please refer to our description. There’s also a link to the Our Sign, our Power California campaign. Finally, I want to thank our guests and Colleen Young, our producer, and remind the audience you can always go to clean capital.com to get more episodes of Experts only. Thank you so much for joining us. Keep on fighting the Good Fight. Thank you. Thank

Matthew Freedman (37:51):

You. Keep Hope alive.