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FERC Must Reject Petition Endangering Net Metering

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FERC Must Reject Petition Endangering Net Metering Sent via electronic mail and docket submission To: The Federal Energy Regulatory Commission 888 First St NE Washington, DC 20426 Date: June 15, 2020 Re: FERC MUST REJECT PETITION ENDANGERING NET METERING AND URGENTLY- NEEDED JUST TRANSITION TO A CLEAN AND RESILIENT ENERGY FUTURE (DOCKET EL20-42 - PETITION FOR DECLARATORY ORDER) Dear Chairman Chatterjee and Commissioners Glick, McNamee, and Danly: On behalf of our millions of members and supporters nationwide, we, the undersigned 450 organizations—including energy democracy, environmental justice, solar workforce, consumer advocate, and faith organizations—urge the Federal Energy Regulatory Commission (“FERC”) to reject the New England Ratepayers Association’s (“NERA”) April 14, 2020 Petition seeking federal jurisdiction over state net metering programs (“Petition”). The Petition threatens crucial state net metering policies and obstructs the urgently-needed clean and just energy transition to address historical environmental injustices and the climate emergency. The Petition threatens to dismantle net metering policies across the country— endangering the existence and growth of solar development nationwide. Net metering programs have been the cornerstone drivers for community, household, and business investments in distributed solar energy for many years. Net metering policies fairly credit solar customers for the electricity their panels generate. Granting the Petition would jeopardize long-standing state and local policies that support the existing solar systems serving nearly 2.2 million households and 100,000 businesses across 49 states and five territories. Such an outcome is especially egregious in the wake of the COVID-19 emergency, where families cannot afford energy bill hikes amidst mass unemployment and competing costs to survive. Further, dismantling state net metering policies obstructs future growth of distributed solar systems nationwide—and the immense job generation, energy justice, climate benefits, health benefits, and other economic benefits associated with distributed solar systems. Particularly in the wake of the current public health and climate emergencies, stifling these economic and climate resilience-building systems is unacceptable. State net metering policies and distributed solar systems are foundational to achieving the nation’s urgently-needed clean and just energy transition—to address historical environmental injustices, fight the climate emergency, and ensure long-term resilience. Families classified as low-wealth and Black, Brown, Indigenous and other communities of color are disproportionately impacted by the pollution from centralized dirty fossil power and the ravage of climate disasters.1 As we tackle the climate emergency and make the urgently-needed energy system reforms, it is critical that the new energy paradigm not only be powered by clean and renewable energy, but also pioneer electricity structures that build community resilience and distribute wealth, power, and decision-making about energy choices equitably. 2 Solar is vital to that future, delivering benefits of equitable community development, local job generation, customer choice, and the energy security and resilience of communities in the long-term. As millions across the country face the threat of electricity shut-offs due to coronavirus-precipitated job losses, it is more apparent than ever that decentralized solar systems can help families generate their own power and decrease dependence on dirty centralized generation to weather such crises, only sure to rise in the face of growing wealth inequality and increasing climate impacts. 3 Critically, NERA raises several false claims in the Petition regarding the relationship between net metering and families classified as low-wealth as well as communities of color. Claims that costs of solar energy are shifted to “those who cannot afford large houses or businesses” are spurious and misleading, as the majority of studies have found that the benefits of solar net metering outweigh costs for all ratepayers.4 Further, net metering is a critical component of rooftop solar and community solar, tools that increase clean energy access for low- wealth communities, communities of color, and renters. 5 In addition, the Petition demands that FERC itself dictate net metering policy, rather than allowing these important decisions be made by states and localities, who are in the best position to address their communities’ unique needs. As our nation continues to suffer from the novel coronavirus pandemic and we increasingly experience harms of the climate crisis, FERC must support solutions to promote recovery and advance clean and just energy rather than preempting local decision making. We urge the Commission to reject the Petition and enact policies that accelerate the rapid transition to our clean and equitable energy future. 1 NAACP, Environmental and Climate Justice Program, In the Eye of the Storm (2018), https://live-naacp- site.pantheonsite.io/wp-content/uploads/2018/09/NAACP_InTheEyeOfTheStorm.pdf; Environmental Protection Agency, Public Health Benefits per kWh of Energy Efficiency and Renewable Energy in the United States: A Technical Report (2019). 2 See, e.g., Al Weinrub and Denise Fairchild, Energy Democracy: Advancing Equity in Clean Energy Solutions, (2018) available at https://islandpress.org/sites/default/files/9781610918510_excerpt.pdf. 3 See National Renewable Energy Laboratory, Distributed Energy Planning for Climate Resilience (2018), https://www.nrel.gov/docs/fy18osti/71310.pdf; see also See J.Farrell, Community Solar Power: Obstacles and Opportunities, The New Rules Project (2010), https://ilsr.org/wp-content/uploads/files/communitysolarpower2.pdf. 4 Brookings Institute, Rooftop solar: Net metering is a net benefit, May 2016, https://www.brookings.edu/research/rooftop-solar-net-metering-is-a-net-benefit/. 5 See GRID Alternatives and Vote Solar, Low-income Solar Policy Guide: Net Metering/Virtual Net Metering, 2016, https://www.lowincomesolar.org/toolbox/net-metering/; See also Clean Energy States Alliance, Bringing the Benefits of Solar Energy to Low-Income Consumers: A Guide for States & Municipalities, May 2017, https://www.cesa.org/wp-content/uploads/Bringing-the-Benefits-of-Solar-to-Low-Income-Consumers.pdf. Page 2 of 24 450 GROUPS’ LETTER URGING REJECTION OF NERA PETITION June 15, 2020 CONVENING PARTNERS Jean Su & Shiva Patel Nathan Phelps Chandra Farley Energy Justice Program Regulatory Director Just Energy Director Center for Biological Diversity Vote Solar Partnership for Southern Equity Tamara Toles O'Laughlin Sylvia Chi Ted Glick North America Director Policy Director Co-Founder 350.org Asian Pacific Environmental Network Beyond Extreme Energy Timothy DenHerder-Thomas Lynn Benander Denise Fairchild General Manager Executive Director Executive Director Cooperative Energy Futures Co-op Power Emerald Cities Collaborative Emily Wurth Lukas Ross Charlie Jiang Co-Director, Organizing Senior Policy Analyst Climate Campaigner Food & Water Watch Friends of the Earth Greenpeace USA Andie Wyatt John Farrel Basav Sen Policy & Regulatory Manager Co-Director Director Grid Alternatives Institute for Local Self-Reliance Institute for Policy Studies, Climate Policy Project Rev. Michael Malcolm Michael Leon Guerrero Jim Warren Board Member Executive Director Executive Director Interfaith Power & Light, National Labor for Sustainability Network NC WARN Colin Rees Tyson Slocum Johanna Bozuwa Senior Campaigner Director Co-Manager, Energy & Climate Oil Change International Public Citizen The Democracy Collaborative 450 GROUPS’ LETTER URGING REJECTION OF NERA PETITION Page 3 of 24 June 15, 2020 NATIONAL Drew Hudson Bobby Vaughn Jr. Maayan Cohen Founder Investigative Journalist Director of Partnerships & Campaigns 198 Methods A Call to Actions Alliance for Climate Education (ACE) Mike Garrity Emily Cosbar Bill Plotkin Executive Director Market Policy Analyst Director Alliance for the Wild Rockies Ampion, Inc. Animas Valley Institute Harriet Festing Kevin Kamps DeWitt Jones Executive Director Radioactive Waste Specialist Executive Vice President Anthropocene Alliance Beyond Nuclear BlueHub Capital Edward Maibach Marty Newell Raghav Murali Director Chief Operating Officer Director of Policy and General Counsel Center for Climate Change Center for Rural Strategies Center for Sustainable Energy Communication Deb Katz Vick Mohanka Suzanne Hume Executive Director Clean Energy Organizer Founder, Educational Director Citizens Awareness Network Clean Water Action CleanEarth4Kids.org Alice Cherry RL Miller Donald M. Goldberg Co-Founder and Staff Attorney Founder Executive Director Climate Defense Project Climate Hawks Vote Climate Law & Policy Project Laura Berry Mark Stanley Mary Gutierrez Director of Research Director of Operations Executive Director Climate Mobilization Project Demand Progress Earth Action, Inc. 450 GROUPS’ LETTER URGING REJECTION OF NERA PETITION Page 4 of 24 June 15, 2020 Tom Athanasiou Anne McKibbin Jesse Stowell Executive Director Policy Director Vice President of Business Development EcoEquity Elevate Energy Encore Renewable Energy Austin Krause Andrew Taft Grant Smith Solar Integrator & Developer Director of Projects Senior Energy Policy Advisor Entero Energy Entero Energy LLC Environmental Working Group Heather Hochrein Kathleen Doyle Brook Lenker Chief Executive Officer Chief Executive Officer Executive Director EVmatch, Inc. FireFlower Alternative Energy FracTracker Alliance Stephen Schneck Kieran Suckling
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