It is a reasonable position to slowly lessen the subsidy as the grid gets cleaner and cleaner, but really we need to continue to healthily subsidize the residential systems installed with at least one battery, and can help with the duck curve problem.As someone on the other side of the country, I am certainly glad this isn't affecting me directly but appreciate seeing CA figure this out as other states will no doubt need to confront some of these issues over time. It seems like some of this came about because the state did not do a good enough job of planning ahead when to sunset/cap some of their incentives and is now in a position where they feel like too many are getting them. However, the solution should not be to change the rules on people who were given promises that induced them to install solar. It seems like the bill text talking abut the advantages customers will still have (lower bills) don't acknowledge the large fixed cost.
I feel like #2 in your list is the piece generally being overlooked in that linked legislation/CPUC finding. There is no doubt NEM is a subsidy, and it does benefit those who are able to install solar, at the expense of ratepayers generally. But that money is intended to support the public good of cleaner energy, and the societal benefits associated with it. While I wouldn't support retroactive changes, it seems like the question the state should be looking at is whether subsidies for residential solar at different levels are an efficient way to support this public good. If the answer is no, then it may make sense to close the programs. But if the answer is yes, then they should continue, with debate held over a fair method for allocating the costs, which could include continuing to assign costs to ratepayers, but could also involve other taxing/subsidy options.
Valuing residential rooftop PV at wholesale rates is way overboard though. Breaking existing NEM 1.0 and 2.0 agreements is crossing a red line.
Something that sounds more fair to me: Under NEM 3.0 you get paid a percentage of the $0.11 /kWh assumed actual value of PV generation each month based on how well you can turn your usage close to 0 during the high demand evenings that month. This would not only reward PV plus ESS, but still reward PV plus efficiency upgrades would get a similar but smaller benefit.
So for instance 3 different customers. I am just throwing some numbers out there for example.
Customer #1 has PV plus ESS and can turn his grid usage to 0 from 4-9 pm 10 of 12 months of the year.
During those 10 months of avoiding draw during peak times, he gains full 0.11 /kWh credit for his daily PV generation
During the 2 months he cannot generate enough, and uses about 50% of what an average home would draw during peak times.
He gets a reduced rate of 0.06/kWh for his excess generation during those months. (moderate subsidy)
Customer #2 has PV only and an eye for efficiency. They avoid car charging and all high use loads at peak hours, and maintain a 50% lower than average grid draw during peak hours for 9 of 12 months. During winter they consume an average amount of power.
They get 0.06/kWh (small subsidy) for PV generation the 9 months when they otherwise are very careful of peak time grid draw.
During those other 3 months, its reduced to 0.04/kWh (No subsidy)
Customer #3 has PV only and does not care about the peak times. They get paid only 0.04/kWh for PV production, as their usage is more typical. (No subsidy)