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Comment for FTC Workshop Examining Competition and Consumer Protection Issues in the Rooftop Solar Business

Policy Positions   
As distributed energy resources (“DER”) are becoming increasingly common, the debate on how customers with such systems should be compensated is intensifying. More states are undertaking initiatives to evaluate their current policies, especially the policies directed at solar distributed generation such as net metering. As the Federal Trade Commission (“Commission”) noted in the announcement notice for Something New Under the Sun Workshop, determining the correct rate for net metering is a complex issue.2 Ideally, customers should pay for the full cost of the services they receive from the grid, including the externalities, and should receive compensation for the full value they contribute to the grid. Further, as distributed generation continues to grow steadily across the country, it is important to implement a framework that can be used consistently in different states and for different DER, not just solar distributed generation. Finally, as resource choices that can balance demand and supply increase, and utility scale renewables become more common, a consistent formulation that could provide a true value comparison among different alternatives is needed. Therefore, we applaud the Commission’s efforts to organize a workshop to explore the issues that dominate the policy debates related to the solar distributed generation.