ExpandedVirtual Net Metering (VNM)San Diego Gas & Electric Company

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Expanded VNM Tariff

SDG&E filed its Expanded VNM Tariff (AL 2286-E) incompliance with CPUC Decision (D.) 11-07-031:

Directs IOUs to modify their NEM tariffs to allow VNM to apply to all residential, commercial and industrial multitenant and multi-meter properties.

Sharing of bill credits can only occur for accounts served by a single SDP.

The expanded VNM concept can apply to any DG technology that receives a full retail rate credit under net energy metering.

Expanded VNM tariffs should “mirror” those filed for VNM in the MASH program.

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VNM-A DeviationsKey differences between Expanded VNM and VNM-A:

VNM-A has been expanded, per D.11-07-031, so that it now applies to all tenants located in an affordable housing development across multiple SDPs. Expanded VNM maintains the single SDP limitation.

Expanded VNM includes an initial set up fee and monthly maintenance fees, as provided for in OP 2 of D11-07-031.

It is not necessary for Expanded VNM customers to participate in or receive incentives from MASH or New Solar Homes Partnership (NHSP). It is also not necessary for an Expanded VNM customer to have received CSI funding.

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Protest Issues & Reply Protests from IREC, Vote Solar and CALSEIA, and DRA

– Virtual Net Metering Fees:• SDG&E proposed a service origination fee based on costs previously approved

under Schedule RES-BCT (Local Government Renewable Energy Self-Generation Bill Credit Transfer).

• Used a scaling approach to take into consideration participation for smaller duplexes with minimal accounts verses larger governmental customers with 50 large accounts.

• Recurring monthly service fees are appropriate for the continued monthly maintenance that will be required for the eligible VNM customers.

– System Allocation Modification:• SDG&E’s 12 month limitation for allocation changes is based on “free” changes

to the allocation designations and is consistent with CPUC approved provisions in both RES-BCT and VNM-A for minimum 12 month effective periods.

• Alternative - charge participants per allocation adjustment, regardless of the anniversary date.

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Protest Issues & Reply cont.

– Credit from vacant or non-participant units:• All SDG&E VNM-A accounts have Revert-to-Owner contracts on file with the

utility – In these instances unused VNM credits will be directed to the Owners account.

• Addresses tenant vacancies without having to create costly programming or unnecessary manual work.

– Definition of Owner:• SDG&E’s VNM-A and Expanded VNM tariffs define Owner as “the Enterprise,

or Entity, that owns a multi-tenant or multi-meter property.”• This language does not limit the applicability of VNM-A or Expanded VNM to

only situations where the owner of the property owns the generation system.

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Protest Issues & Reply cont.– Billing Records:

• SDG&E is not authorized to share benefiting account customer information with the generating account managers. In addition, the generating account already has the ability of obtaining the total kilowatt hours generated through their smart meter data available on line, since they provided the allocations themselves.

• Current provisions allow owners to see aggregate consumption information.

– Solar Tariff Exclusions:• SDG&E’s Schedule DR-SES is intended for individually metered customers with

solar energy systems. • Because many of the tenants do not invest in a solar system, the Commission

has approved the exclusion of DR-SES and DGR rates from participation in Schedule VNM-A. The Commission has also allowed the DGR rate option to be excluded from the tenant’s subaccounts under RES-BCT

• Expanded VNM would be available to non-residential customers.