Here by page 138, I expect everything has already been said. So I've only read about half of it. Likewise the 2021 "Lookback Study" on which the CPUC's discussion is based, as well as the current proposal and other materials.
What strikes me is that CPUC's mandate it to protect consumers from the monopoly utilities. What is being proposed is to increase rates (no decreases proposed for anybody!) for solar owners. We bought solar because it fills our needs cheaper than the utilities do. We and our solar installers and product companies are competing with the utilities. CPUC raising our costs as proposed will benefit the utilities, kill all future solar, and provide no benefit for non-solar customers. This is the exact opposite of the CPUC's mandate.
The proposal describes two problems with NEM: 1) "cost shifting", and 2) the fact that solar peaks mid day while consumption peaks after sunset, the duck curve problem
The loopback study found that it costs the utilities LESS to serve NEM customers that non-NEM customers. The NEM credits are not described as a cost, because they are only offsets debits at other times. But solar customers (NEM or not) need less electricity, so they buy less. The supposed "cost shift" is not a result of NEM per se, but rather of the volumetric pricing structure, where fixed and volume dependent costs are combined into "bundled" cost per kWh. The means that large users contribute more to fixed costs than small users. So, since solar customers use less, they contribute less.
What is strange is that the rate structure is not being considered as part of the solution. It is outside of the scope of the discussion. This is a fatal flaw in the process. Another strange aspect of the discussion is that the volumetric pricing has always created cost shifts. For example, rural distribution costs more per customer than suburban customers. Another case is the vacation home, which pays only monthly minimums until it is occupied. And low income, small houses and apartments use less, and are subsidized by large air-conditioned homes, swimming pools, EV's etc. How does the "cost shift" from solar compare to these other cost shifts? The analysis assumes that everything but solar is fair, so any shift caused by solar is unfair.
As for the offset timing of solar and peak loads, batteries solve this completely. Not only can we store our solar to cover our own consumption during peak times, but our Powerwalls now let us do our exporting during peak periods, reducing the total peak loads even more. This is very important because the so called "fixed costs" of generation and transmission systems are largely determined by the highs peak load they must serve. By reducing the peaks, batteries reduce the costs for everybody. When NEM3 kills off solar, it will also kill off batteries because without solar there is no way to charge a battery during an outage, a main justification for batteries in the first place.
Finally, the purpose of NEM was to facilitate the adoption of renewables, primarily solar. It has succeeded very well, and at no extra cost to the utilities. But the real purpose is to reduce green house gas emissions. Here the Loopback study is completely silent. The term greenhouse gas, climate change, and others do not appear at all. Rooftop solar in California is annually producing as much carbon free energy as the Diablo Canyon Nuclear plant. The carbon reduction benefits are completely ignored.
I think NEM3 is a scam by the utilities to con the CPUC into quashing competition for utilities, and as such is profoundly improper.
I think more should be done to promote batteries and schemes for renters and condo owners to participate in the advantages and cost savings from local solar generation and short term storage. NEM, especially with batteries to smooth the daily load curve, is a clever and efficient way to smooth the seasonal power demand curve, reducing costs for all consumers.
I encourage anyone with an interest in this to follow the links recently posted b others and let your thoughts be heard by the elected who are allowing this to proceed. Also CalSSA has a site with fact sheet, suggestions, petitions, letters to the governor, etc here:
Save California Solar
Sorry for the long rant.
SW