To: alice.reynolds@cpuc.ca.gov, ora@cpuc.ca.gov, PublicAdvocatesOffice@cpuc.ca.gov
Cc: rishi@rishikumar.com
Subject: No to income based utility rates

Dear President Reynolds and commissioners,

I wanted to share my thoughts on the proposed changes in utility rates based on income (AB 205). I'm really worried that this approach could discourage people from conserving energy because there might be less of an incentive to do so if rates are based on income instead of usage. Just wanted to express my concern!

Please review the petition here - which I have signed.

I have done my part, now CPUC should too: My family and I have been trying to conserve energy by reducing our usage of electricity and gas. We've been adjusting the thermostat during the day and night, wearing warmer clothes, and even installing LED light bulbs and solar panels. But, even with our efforts, our bills have been going up because of PG&E's steep rate hikes over the last three years, particularly for gas.

Utility rates should be based on usage, not income: There are currently 173 investor-owned utilities across the country that charge a set fee to cover a portion of their services. However, none of these utilities determine the fixed charges based on income, and on average, the fee is roughly $10, with the highest being $40. It doesn't quite add up that this new approach would take such a significant jump from $10 to $128. Plus, it's worth noting that this proposed approach by CPUC would be the first of its kind worldwide.

A for-profit organization will now have access to my income information? Apparently, utilities are going to receive ratepayer income details from FTB. However, in my opinion, PG&E shouldn't be collecting or retaining such sensitive information, not now or on an annual basis. I am genuinely shocked that my personal and confidential income data will be shared with a private utility. What happens if their database gets hacked? Who would be accountable for that? This is an enormous violation of privacy and something that the state could be held responsible for.

Shouldn't the CPUC be standing up for the people? I've heard rumors that the investor-owned utilities (IOUs: PG&E, SCE, and SDG&E) have an excessive amount of influence over the CPUC. If this proposal were to be implemented, it could potentially hinder efforts towards electricity conservation since the per kWh rate would be significantly decreased.

This will undermine the future of solar in California: What's even more concerning is that this new proposal is also targeting rooftop solar energy! People who have already invested in solar made their decisions based on a calculated payback period. However, with the fixed fee component and lower per kWh rate, that payback period will be extended, essentially circumventing the 20-year contract between each customer and their utility. On top of that, this proposal will reduce the motivation for potential new customers to invest in and install solar power. It's clear that investor-owned utilities have little interest in promoting rooftop solar energy, as it threatens their monopoly on power generation and transmission. Which brings me to…

…I have to say, I've been extremely disappointed with your previous actions in dismantling California's solar program. As of April 15th, 2023, new solar rooftop installations will receive a significantly smaller credit for each excess kilowatt under the new Net Tariff Billing. The California Solar and Storage Association, the state's largest solar trade organization, reports that this reduction is about 75%. As a result, the payback period for rooftop solar installations will be significantly extended. Even if a ratepayer installs batteries, a paired storage system won't be able to address the substantial seasonal variations in solar output. Frankly, this new tariff is terrible. It was already tried in Nevada and resulted in a significant drop in solar installations, forcing their legislature to eventually reverse the decision. Rooftop solar is a vital component of our energy mix, and CPUC should be advocating for policies that support it, rather than policies that favor the investor-owned utilities.

There are programs in place today: It's worth noting that PG&E currently offers two discount programs, CARE and FERA, which assist eligible customers in paying their energy bills. Millions of customers are already benefiting from these programs. So, what exactly is the problem that we're trying to solve with this new approach? Why is the burden being shifted to us, the ratepayers?

In conclusion: I implore you not to make another mistake with an income-based approach. Instead, let's make responsible decisions that will help us tackle our climate issues, rather than exacerbate them. This approach doesn't seem right for me, nor for the state of California. It certainly isn't the direction that we want to be heading towards as a country.

Thank you for your consideration.

Sincerely,