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Urgent Call to Action for California Solar Industry: Ensuring Accuracy in Solar Bill Savings Estimates

SThayer66

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Join the movement to advocate for accurate bill savings estimates for solar customers in California. The CPUC just issued Draft Resolution E-5330 with the its updates to the Inputs and Assumptions used in Bill Savings Estimates, to be Included in California Contractors State License Board Solar Energy System Disclosure Document Provided to Solar Customers.

Critical issues need to be resolved with this resolution requiring immediate attention to protect consumers and promote transparency in the solar energy industry for California.

Summary of Key Points:
  1. Lack of Stakeholder Involvement: The Energy Division failed to follow the Commission's directives by not engaging stakeholders in the process of updating inputs and assumptions for bill savings estimates. This oversight undermines the credibility of the Draft Resolution.
  2. Rate Escalation Factor: The Draft Resolution inaccurately assumes a historical average annual escalation rate of 4 percent, which may mislead consumers. The data used is outdated, and failure to update this rate could result in customers receiving inaccurate information about their bill savings.
  3. Choice of Solar Assessment Tool: The Draft Resolution mandates the use of a specific tool for estimating energy generation, limiting the options available to solar developers/installers. Providing flexibility in the choice of assessment tools is crucial for accurate estimations, especially considering factors like battery storage.
  4. Compliance Deadline: The proposed compliance deadline of January 1, 2025, is deemed inadequate by SEIA. A more reasonable timeline of 12 months from resolution adoption is necessary to allow developers/installers to make technical adjustments, ensure data accuracy, and implement the required changes effectively.
Call to Action: Let's stand together to demand transparency, accuracy, and fairness in the solar energy sector. Contact your local representatives, share this information with fellow solar advocates, and urge the Commission to address the concerns. Use the attached comments from SEIA for background information and support of key points. Together, we can ensure that solar customers receive reliable bill savings estimates and promote a sustainable energy future for California.

Your voice matters in shaping the future of solar energy regulation. Take action today to support accountability and consumer protection in the solar industry. Together, we can make a difference!
 

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California is ground zero for the utility war against rooftop solar, which is very unfortantely, and misguidedly, currently being supported by some local uninions. Personally, I maintain hope that unions will realize worker rights and rooftop solar jobs are in alignment not opposition. Anyways, the 4% rate escalator in the draft resolution is a joke. Everyone knows it is way, way higher. This article from Energy Central just popped up in my inbox saying: "Residential electricity bills in California have increased by as much as 110% in the last decade, according to the public advocate’s arm of the state Public Utilities Commission. In just the past three years, bills for customers of the big three IOUs have seen increases in their bills by 20-50%." Here's the full article:

After pushback, Gavin Newsom cuts much of his electric bill affordability plan. What’s next?

Thanks to SEIA and others who are trying to help fight the good fight...
 
Adjustments to Resolution E-5330, which updates the estimates used in solar energy disclosures, are critical! The resolution mandates the use of PVWatts for solar generation estimates, but more comprehensive tools should be allowed if they include hourly shading and modeling, as this would provide more accurate estimates. Also, the resolution's requirement to optimize bill savings for storage systems lacks clarity. I agree with the recommendation of replacing this with an "Alternate Bill Savings Estimate" field to accommodate varied customer needs, such as those requiring consistent power for critical equipment. The resolution should offer flexibility in presenting savings estimates rather than forcing multiple scenarios.

Regarding the escalation of utility rates, the 4% default rate is SO outdated. Objective, updated data should be used. This is a no brainer!

The resolution's implementation timeline is too rushed and needs public input.

I attached CALSSA's comments in case anyone wants to read them.
 

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Agree with the other comments.

Many changes should be made... Here are my suggestions:
  1. Software Tool Flexibility:
    • Solar Providers should be allowed to use a software tool of their choice for solar-only and solar-plus-storage simulations, as long as it meets certain detailed criteria.
    • The document should not mandate the use of PVWatts for PV simulations, but rather require a tool with similar features.
    • I suggest including specific details in the simulation tool, such as location, system size, module type, orientation, and hourly production calculations.
  2. Battery Operating Modes:
    • Solar Providers should not be limited to presenting only three storage operating modes; they should have the flexibility to include other commercially available modes.
    • The document should allow for an "other" option for battery operating modes to accommodate proprietary models in the market.
  3. Bill Savings Estimates:
    • I propose simplifying bill savings displays into a single field to avoid confusion.
    • The requirement to demonstrate multiple battery scenarios should be removed, and instead, a statement about the uncertainty of bill savings should be included.
    • The document should not require presenting a range of savings as it may lead to customer confusion.
  4. Standardized Inputs and Assumptions:
    • Section 3 should include essential system information like PV system ratings and battery capacity for better comparison between estimates.
    • The document should not specify a fixed lifetime for the PV system but should include warranty information.
    • Formatting changes are suggested for rate schedules to accommodate longer names.
  5. Other Sections:
    • Section 2 should require Section 3 for all payment options, not just for cash purchases.
    • In Section 4, separate PV and battery costs should be removed, and instructions for different payment options should be added.
    • The "Secured by Home Mortgage" field in Section 5 should be removed.
    • Section 7 should clarify the field for PPA payments and include additional details about rates and fees.
  6. Implementation Timeframe:
    • The implementation timeline should be tied to the completion of the final disclosure document to allow for adequate preparation.
Lots of changes needed!
 

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