Read the Cal NEM 3.0 decision. As someone who has dedicated last 10 years to energy equity and is vice-chair of Low-income oversight board, I have a few initial observations. A thread.....
Bottomline: this proceeding and its somewhat absurd outcome of a solar tax is emblematic of a century-old, inequitable utility governance model. More on that later, but for now, a few reactions:
Of the 20+ intervenors, not a single one represents EJ/low-income residents and yet equity is referenced as both a guiding principle and a reason for adopting a solar-specific fixed charge.
If equity were a major concern, there are 1000s of policy decisions to address well-documented racial+ income disparities, from extending disconnection moratoria to increasing CARE subsidy, to fully deploying ESA budgets, to targeting majority of clean energy incentives to DACs
Check out Cal. Environmental Justice Alliance and partners' statement for what could be done to center equity in solar policy.…
the NEM cost shift argument was developed by ALEC. See Shalanda Baker's book Revolutionary Power for the details.
Cost-effectiveness modeling as the guiding tool for policy-making in the era of extreme inequality and climate change is absurd (at least to me).
This decision explicitly rejects using a societal cost test.
See this LBNL article outlining limitations of the cost tests guiding so many commission decisions, including this one:…
Meanwhile certain costs, like guaranteed utility ROIs, executive compensation, use of federal CARE money, etc. seemingly go unexamined.
I have a law degree, a master’s in energy + resources, 10+ years experience, and it’s still difficult to make sense of the rate structures proposed. How will general Californians considering solar investments fare?
While I support the proposed solar equity fund, here's to hoping an alternative PD comes about on the fundamentals, and that the rhetoric on equity is genuinely realized across ALL commission proceedings and policies.

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