ventura ventura, January 27, 2022

RE:  Proceeding R.20-08-020 Urge CPUC to Reject the Proposed Decision for NEM 3.0


Ventura County has endured intensifying wildfires and related power outages and is bracing for more. We are near the end of the transmission grid in SCE territory. Energy resilience to impacts of climate change is an urgent unmet need. We are frustrated that clean Distributed Energy Resource (DER) development is not happening at the required pace and scale. There are also many strategies for incentivizing conservation that must be expanded.


As you know from our four year fight against the Puente Power Plant, our communities will not accept any new fossil fuel energy sources, and we are committed to doing our part to reverse global warming. Many vital climate policies require massive scaling of rooftop solar. CARB’s SB100 Joint Agency Report states that to reach its goals, California must add more than triple the 2019 amount of “customer solar” and 244 times the battery storage. Undercutting rooftop solar makes no sense.


Furthermore, ensuring justice and equity requires care in areas that your decision disregards:

  • Defaulting on agreements made with those who bought solar arrays is unjust. A major motivation of these investors is to be part of the solution; such motivation should be neither punished nor discouraged.
  • Our friends and family members are excited to be working in the rooftop solar industry. It would be unconscionable to pull the rug out from under them.
  • There are multiple strategies for financing inclusive programs for accelerating rooftop solar, battery storage, and local microgrids that need to be considered.


We urge immediate attention to these serious needs:

  • Continue expansion of the grid-connected residential photovoltaic (PV) program.
  • Account for the soaring costs of transmission relative to distribution.
  • Account for health, reliability and land use benefits of rooftop solar that are NOT currently included in the Avoided Cost Calculator.
  • Provide appropriate locational benefits/compensation for systems which ease system constraints.
  • Encourage production of “excess” power in combination with battery storage and load shifted or managed EV charging to reduce need for peaker plant use.


The CPUC should be an ally, not an obstacle, in our collective fight for a healthy, sustainable future.




Jan Dietrick, MPH, Policy Team Leader

350 Ventura County Climate Hub (350 VC-CH)


Merrill Berge, Co-Director

Camarillo Sustainable Growth


Kristofer Young, DC, Chair

Climate Reality Project Ventura County (CRP-VC)


Rose Ann Witt, Co-Founder

Conejo Climate Coalition (CCC)


Wayne Morgan

Ventura Climate Coalition (VCC)


Shannon Simpson, Executive Director

Climate First-Replacing Oil and Gas (CFROG)


Faith Grant, Co-Leader

Ventura Citizens’ Climate Lobby

350 Ventura County Calls for Strong Climate Action Plan

Join 350 Ventura County Climate Hub

General Meetings one or two per month, usually on Thursdays 6:30 pm - 8:30 pm Networking until 9 pm.