In spite of finding many problems with its design of two solar programs for disadvantaged communities, the California Public Utilities Commission decided the concept was valuable enough they should be improved and combined into one program (D-24-05-065).

In a May 30 vote, the program opens up to customers of all income levels and expands the geographic boundaries of a disadvantaged community that will encourage more solar projects to serve low-income customer.  The CPUC predicts an increase of roughly 45,000 additional customers up from 23,000 currently enrolled, and 45 additional solar projects to be built up from 23 signed solar contracts. It gave no timeline for this growth.

The two programs, called the Disadvantaged Communities Green Tariff program and the Community Solar Green Tariff program, were designed to allow low-income customers who could not install roof-top solar systems due to roof orientation or other reasons like affordability. The design of the programs and their requirements were described in the fall issue of California Energy News (see “Community Solar Green Tariff Attracts CCAs” in Other Stories on the left).

 While the programs operated by Pacific Gas & Electric was fully subscribed, SCE and SDG&E programs were not due to a lack of solar capacity. PG&E suspended its program because it had customer waiting lists due to a lack of solar project developments that met program requirements to serve them. PG&E also reported project costs exceeded benefits. The few Community Choice Aggregators invited to participate maintained their programs.

SDG&E reported the program was successful until 2018 when most of the customers moved to CCAs service. “This caused rates to spike for its few remaining participating customers leading to customer attrition, SDG&E said. It subsequently suspended its two programs in 2022.

Seven of the eight CCAs administering their programs enrolled customers in the Disadvantaged Green Tariff program but they did not have solar projects to serve them, instead using Renewable Portfolio Standard resources. Five had procured new capacity by October 2023, however.

Disadvantaged Customers Signed up But Solar Did Not

 Both programs provide qualified customers 20% rate discounts from their regular tariffs. In addition, the Community Solar Green Tariff must have a city sponsor and the community solar system must be located within five miles of a designated disadvantaged community. Both CCAs and the utilities are required to procure solar projects dedicated to these customers.

Customers enrolled rapidly and exceeded the required solar resources stemming from favorable Green Tariff rates that became lower than the default rate.  It has been unsuccessful in contracting new resources which would have allowed the utility to enroll new customers.

SCE reported at its peak its Green Tariff program served 1,128 residential and 1,982 non-residential enrolled customers totaling 50 MW of capacity. It is now fully subscribed and suspended to new enrollment.  There were no customers enrolled in SCE’s Communities Green Tariff program at the reporting time in 2022 because there are no solar projects online to serve customers. However, a project was anticipated to come online in August 2023 to deliver power to new customers. Until new capacity develops SCE is maintaining its waitlist. 

PG&E reports its program benefits did not match its costs. It notes in 2021 it spent about $1 million more on solar resource costs than it did to deliver discounts to customers.  Overall program costs were $11.4 million and only 43% of program costs provided bill savings benefits.  The utility reported that the largest portion of costs were for above-market contract payments to solar resources at 55% of the program costs.

Green Access Program Streamlined

The Commission decided that the two programs should be combined, given that the Green Tariff program is more cost effective and easier to implement.  The Communities Green Tariff program had a higher cost per customer and lower enrollment and procurement rates largely due to eligibility requirements, rate volatility, duplication and market confusion, the CPUC said. Therefore, the customers are to be moved to the Green Tariff program, including those wait-listed.   Also, site requirements were expanded.

The decision determined a central marketing website should be created to solve the problems listed above. Applicants will be able to read about each program and learn how to apply. Procurement opportunities will be listed along with statewide enrollment. A consultant will be hired to develop the website to overcome barriers in customer and project developer awareness of the Commission’s renewable energy programs.   Energy storage will be allowed in solicitations.

Reporting Mechanisms Simplified

The decision also eliminates the requirement to report on several renewable statewide renewable accounts in order to reduce time, effort and cost.  Producers will also not have to retire renewable energy credits in connection with that reserve account. Instead, Green Tariff program administrators will conduct the validation and tracking.

The Commission also ordered PG&E and the CCAs to develop an automated billing solution for CCA program participants since they are eligible to remain enrolled for up to 20 years. Apparently, PG&E was using manual data transfers.

Upon recommendations by some of the utilities and CCAs, the Commission agreed to hold solicitations once a year instead of biannually. This will make the schedule more predictable and allow time for developers to prepare and submit offers.

Furthermore, upon recommendations of the interested parties, the Commission ruled that once the new Green Tariff program reaches 500 kW or less, or if “There has been no participation by developers in two consecutive solicitations the utilities may suspend their programs.”  At that time, the Green Tariff program will sunset once all programs are suspended.

The Commission further removed the requirement that customer enrollment be tied to solar power procurement since this restriction may have contributed to the program’s limited performance.

The Commission also increased the customer subscription limit from 2 MW to 40 MW