Environmental organization and others petitioned for writ review of Public Utilities Commission’s adoption of successor to net energy metering (NEM) tariff, which significantly reduced prices utilities paid for customer-generated power, contending it failed to comply with statute setting forth objectives for successor tariff.
The Court of Appeal held that:
- Commission was not required to consider costs and benefits of renewable energy generally when valuing energy generated and exported by consumers;
- Commission’s decision to base price of customer-generated energy on utilities’ marginal cost of energy was reasonably related to statutory goal of equity between customers;
- Petitioners failed to establish benefits of increased resiliency conferred by customer-generated energy accrued to utilities or electrical system rather than to those customers;
- Utilities’ costs under regulatory category “transmission revenue requirements” did not undermine Commission’s estimate of avoided transmission costs;
- Reduction in financial benefit to customers with renewable energy systems did not violate statutory directive to ensure “customer-sited renewable distributed generation continues to grow sustainably”;
- Successor tariff satisfied statutory requirement of including “specific alternatives designed for growth” of customer-generated energy among disadvantaged residential communities; and
- Sufficient evidence supported finding that applying successor tariff to nonresidential customers would serve statutory requirement of balancing costs and benefits to all customers and electrical system.