Docket No.: R.20-08-020

Exhibit No.: Ivy-001

Date: June 18, 2021

Witness: Allie Detrio .

PREPARED OPENING TESTIMONY OF ALLIE DETRIO

ON BEHALF OF IVY ENERGY

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Q: Please state your name and business address.

A: My name is Allie Detrio. I am Policy Advisor for Ivy Energy. The business address is 845 15th Street,

Suite 103, San Diego, California, 92101.

Q: Please summarize your professional and educational background.

A: In my role as Policy Advisor, I advise Ivy Energy on California energy policy issues related to distributed

solar, energy storage, microgrids, and other matters that may impact the multifamily sector. I have 13 years of

work experience in clean energy and sustainability. For the past 6 years, I have been working directly in

California legislative and regulatory affairs on a variety of energy policy issues. I hold a Bachelor of Science in

Sustainability from the Global Institute of Sustainability at Arizona State University, as well as minors in

History, Philosophy, and Economics.

Q: Have you ever testified before this Commission?

A: Yes.

Q: On whose behalf are you testifying?

A: I am testifying on behalf of Ivy Energy. Ivy Energy is a California-based startup that develops software that

optimizes the customer billing experience for multifamily building owners and managers that have a shared

distributed energy resource, such as solar and energy storage. Ivy’s Virtual Grid software eliminates the

complexity of distributing billing across multiple units while providing guaranteed, equitable savings for tenants.

Ivy Energy was a grant recipient of the California Sustainable Energy Entrepreneur Development Initiative

(CalSEED) and was awarded the California Energy Commission’s Visionary of the Year Award in 2020.

Q: What is the purpose of your testimony?

A: The purpose of this opening testimony is to provide information on Virtual Net Metering (VNEM) for

multifamily buildings and responses to Issues 2-6 in the Commission’s Scoping Memo for this rulemaking. Ivy

Energy is intervening in this rulemaking to provide its unique perspective on the multifamily market as a

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provider of billing services and software for multifamily solar adopters. Our top priority is ensuring that renting

households are fairly represented in this proceeding as the Commission considers changes to NEM.

Q: Did you submit data requests to any parties for information that would help inform your testimony?

A: Yes. Ivy Energy submitted a data request to the Joint IOUs requesting all information and workpapers on

VNEM and multifamily buildings.

Q: What information was shared in the response to the data request?

A: The IOUs responded stating they had no workpapers on VNEM. When I made a clarifying request for data

and information on multifamily buildings, including any data validating that VNEM projects were exporting all

energy to the grid, I was directed to the existing language in the Joint IOU’s VNEM tariffs as the basis for their

proposal.

Q: Did any parties serve Ivy Energy with a data request? If so, what information was shared in the

response to the data request?

A: Yes, the Joint IOUs served Ivy Energy with a data request. Ivy Energy responded within the requested

timeframe with the data sets and analysis of multifamily building solar consumption, and our original reports on

the multifamily market segment, which were all referenced in Ivy Energy’s proposal submitted to the

Commission on March 15, 2021.

Q: What is the significance of this data and how does it help inform the Commission’s decision-making

for multifamily VNEM?

A: Our data and analysis conclusively demonstrate that there is significant onsite consumption of solar

generation at multifamily buildings in a VNEM arrangement. The VNEM generation directly serves the load of

the aggregated customers and not all of the generation is exported to the grid. Utilizing the same example

multifamily building with shared solar from the March proposal, Ivy updated the analysis to include new

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months of data in 2021.1

The project PV system to date has provided 52% of the required load for the building. More importantly, only

11% of the total output of the generating facility was exported to the grid when doing interval data analysis. In

some months, such as winter, there was almost no generation exported to the grid. If multifamily solar is paired

with energy storage, what generation is exported to the grid can be smoothed and optimized to support real-time

grid needs.

Q: Can you explain how a multifamily building with solar generation would directly serve the onsite load

before it is exported to the grid?

A: There are three main ways that VNEM systems tie into the grid: load side, supply side and direct to the

building’s transformer interconnections. These pathways allow for solar generation to be consumed onsite

1 See Attachment 1, Figure 1 for underlying data to the graph; Figure 2 is the original data submitted in Ivy Energy’s

Proposal for a Virtual Net Metering Tariff, Appendix A, pg. 14; March 15, 2021

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Building Usage Total (kWh)

TotalLiveSolar TotalSolarExport TotalGridAmount

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before it is exported due to Kirchhoff’s Laws of electrical engineering.2 These laws quantify how current flows

through a circuit and how voltage varies around a loop in a circuit. Kirchhoff’s law essentially states that

current would flow first to wherever there is least resistance. In a VNEM arrangement for multifamily

buildings, the current from the generating facility would first flow to the onsite load because it is less resistant

than exporting directly to the grid.

1) The least common VNEM configuration is a direct to the building’s transformer interconnection. This

connection requires a lengthier permitting process, so we do not see it as often. Per Kirchhoff’s Laws, the solar

generation would be consumed by the building loads connected to that transformer before exporting to the

larger current supplier of the grid. This means that any electricity not served by the building loads would be

exported to the grid.

2) To date, the most common VNEM configuration is a supply side tap system. This connection is made to the

busbar or conductors on the line or utility side of the main service disconnect. Every load on the busbar behind

the main service disconnect has their own meter. Per Kirchhoff’s Laws, the solar generation would be

consumed by all the load meters on the busbar before exporting to the larger current supplier of the grid. This

means that any electricity not served by the busbar loads would be exported to the nearest transformer. At this

point, the solar generation would then serve a second building load (if applicable) connected to the same

transformer before exporting to the grid.

3) The VNEM configuration that we are commonly seeing now that Title 24 building codes are in effect is the

load side tap. The building codes for new construction now require space to be made on the bus bar for solar as

2 Kirchhoff’s Laws; Isaac Physics, a Department for Education project at the University of Cambridge; Accessed June 15,

2021, https://isaacphysics.org/concepts/cp_kirchhoffs_laws

Electrical resistivity and resistor fundamentals; EE Power, Resistor Guide; Accessed June 15, 2021

https://eepower.com/resistor-guide/resistor-fundamentals/electrical-resistivity/#

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a load, rather than tapping in line side. The load side connection is made at the end of the bus bar and allows for

electric loads to be served directly by the onsite loads between the solar generating facility connection and the

service connection. The solar generation would be consumed by all the individual meters as it goes through the

bus bar to the service disconnect. Only when the solar generation is greater than all the individual meter load is

when the remaining current flows to from the service connection to the transformer and electricity is exported to

the grid.

Q: How does this inform electric rate design for multifamily buildings?

A: In order to maintain the integrity of the tariff and capture the full benefits of onsite solar consumption at

multifamily buildings, onsite netting must be retained in the VNEM tariff structure. It is how multifamily

buildings derive and maximize the value of renewable energy installed onsite, as well as enable technologies

like Ivy Energy’s Virtual Grid to equitably allocate energy savings to tenants based on their actual usage of the

solar generation in real time. Ivy Energy strongly opposes the elimination of onsite netting for VNEM and

encourages the Commission to maintain the existing tariff structure for multifamily buildings so that renting

households may continue to receive the same benefits of onsite clean energy that homeowners have received.

Q: What information from the Net Energy Metering 2.0 Lookback Study should inform the successor

and how should the Commission apply those findings in its consideration?

A: As stated in our comments on the Lookback Study, the Commission should note the lack of analysis and

information on VNEM, multifamily buildings, and the customer demographics of this market segment. Since no

data analysis was conducted, Ivy Energy sees no justification for making drastic changes to the VNEM tariff. In

fact, the important public policy goals of equity and environmental justice can be achieved by maintaining the

existing VNEM tariff so that ratepayers who do not own their homes may enjoy the same access and benefits of

clean energy as homeowners. The Lookback Study’s omission of VNEM results in an incomplete analysis of

NEM 2.0 and distorts the findings about low-income solar adoption in California.

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Q: What specific data and information was not included in the Lookback Study that the Commission

should consider as evidence to support your proposal?

A: Over 20 MW of MASH and SOMAH project serving low-income families were left out of the NEM 2.0

Lookback Study, in addition to all general market VNEM projects that are providing the only means of onsite

solar access to renting households.3 A crucial element of the multifamily market that must be considered is the

demographics of residents in multifamily dwellings that may be served by onsite DERs. More than 45% of

Californians rent their homes, representing more than 16 million people, 60% of renters are of non-white

ethnicity, and renters are more likely to have below average incomes, even if they are not officially deemed

“low-income” according to homeowner census and rental population data.4 In California, low-income residents

are more likely to rent than own their homes.5 It is likely that the Lookback Study would have come to a

different conclusion about low-income solar adoption trends in California if VNEM data were included to

capture renting households. The NEM tariff has largely benefitted those that own property. VNEM enables

customers that do not own property to realize the economic and environmental benefits of onsite clean energy.

Those customers should be represented in a comprehensive analysis of the NEM program.

Q: Why is VNEM still needed when the Commission has approved the SOMAH program?

A: First, it is important to note that the SOMAH program utilizes the VNEM tariff structure. To qualify for the

SOMAH program, the property must be designated as “Deed Restricted” housing, of which there are roughly

400,000 units in California. There are more than 16 million renting households in California. SOMAH alone

will not provide an equitable solution to onsite clean energy access for the millions of renting households in

3 Ivy Energy Comments on NEM 2.0 Lookback Study, pg. 3, citation to GRID Alternatives comments on initial NEM 2.0

Lookback Study Analysis 4 Ivy Energy Proposal for Virtual Net Metering Successor Tariff, pg. 6 5 “According to a 2020 study by the Census Bureau, homeownership rates for households above area median incomes

ranged from 78% to 80%, and homeownership rates for households below area median incomes ranged from 48% to 55%

over the past 5 years” https://www.census.gov/housing/hvs/files/currenthvspress.pdf

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California who may not live in eligible deed restricted affordable housing. A robust VNEM tariff must be

maintained so that renters in all multifamily buildings have access to the benefits of net metering.

Q: What other data and information should be shared with the Commission on the multifamily market?

A: It is critically important to understand the people who are benefitting from VNEM – renting households.

There are approximately 16.9 million renters in the state of California.6 In particular, the demographics of the

renting population should give the Commission greater perspective on the multifamily market. The median

household income of California renters is $42,000, compared to $84,000 for California homeowners. More than

57% of Hispanics and Latinos are renters. 43% of Asian Americans are renters. More than 64% of African

Americans are renters. 63% of Native American Indians are renters. Almost 48% of renters in California spend

35% or more of their income on rent, with another 21% of renters spending 25-34% of their income on rent.7

VNEM enables renters to participate and benefit from California’s clean energy transition. Renters are more

likely to be people of color with low and moderate incomes. Renters are receiving tangible cost savings benefits

every time solar is installed at a multifamily building. As the Commission considers how to correct systemic

environmental injustices that have arisen in California, due in large part to the fossil fuel and electric utility

industries, it should keep in mind the demographics of renters in multifamily buildings and design intentional

policies that will allow these historically burdened populations to benefit from clean energy investments. This

can be done by providing a longer runway for solar adoption at multifamily buildings under the existing

program and enabling renters to reap the resulting financial benefits.

Q: Which of the analyzed proposals should the Commission adopt for multifamily VNEM and why?

6 2019 Snapshot of California Renters, Tenants Together: California Statewide Renters Rights Organization

https://www.tenantstogether.org/snapshot-tenants-california 7 Id.

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A: The Commission should adopt the proposals of the Protect Our Communities Foundation and Ivy Energy to

maintain VNEM 2.0 for multifamily buildings and renters until it reaches a comparable adoption level to NEM

2.0 for homeowners. Ivy Energy and Protect Our Communities Foundation proposed the establishment of a

10,000 MW trigger for VNEM 2.0 to transition to the successor tariff.

Ivy Energy and the California Solar & Storage Association proposed some refinements to VNEM that would

increase the benefits to low-income renters and ease administrative burden for both customers and the utilities.8

Ivy Energy’s proposal articulates the dilemma with customers in multifamily buildings on CARE rates.

Allowing low-income customers to keep their CARE discount when the apartment building installs solar and

routing approvals through the property owner/manager with an improved Benefitting Account List

administrative process will provide a tremendous benefit to these customers who have been hardest to reach in

the existing NEM program. Enabling renters who are on CARE to both retain their discount and accrue bill

savings through NEM credits will improve the livelihoods of our most vulnerable Californians. If the

Commission is serious about improving equity in NEM, it should prioritize all renters by improving and

strengthening VNEM for multifamily buildings.

Q: Why should the Commission refrain from making changes to VNEM until the proposed adoption

threshold is triggered?

A: Correcting the imbalance between ratepayers with and without NEM is important, but a blanket approach to

all sub-tariffs may have unintended consequences that adversely impact a class of ratepayers that are equitably

benefitting from NEM 2.0 in line with state social justice policy goals. As discussed in Ivy’s proposal, VNEM

is the only mechanism that enables renters, who are very often low-income and/or people of color, to benefit

from onsite clean energy investments.9 As Protect Our Communities Foundation correctly identified, the chief

8 Ivy Energy Proposal for Virtual Net Metering Successor Tariff, pg. 7-9 9 Ivy Energy Proposal for Virtual Net Metering Successor Tariff, Appendix B, pg. 16. CALSSA Proposal, pg. 15

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inequity in California’s NEM policy is that it inherently favors building and property owners.10 To achieve the

Commission’s equity and environmental justice policy goals, VNEM 2.0 should reach an equal adoption level

to NEM 2.0, and then transition to VNEM 3.0 in the same manner that the general residential market will

transition to NEM 3.0. The Commission must ensure growth of solar adoption in disadvantaged communities

and take meaningful action to correct the inequities in current solar regulations. Any attempt to prematurely

limit or reduce the export compensation (or drastically alter the underlying structure of the VNEM tariff such

that it reduces the DER value proposition) for renters in multifamily buildings is in direct contradiction to that

clear policy goal.

Q: What should the timeline be for implementation?

A: Ivy does not propose a firm timeline for implementation, but rather proposes that the modest changes be

incorporated with any other updates to the IOUs’ billing systems that are directed in the Commission’s final

decision in this rulemaking. Should the Commission adopt Ivy’s proposal, we would aim to collaborate on a

mutually beneficial implementation timeline. It is not Ivy’s intention to unduly burden the utilities.

Q: Assuming the Commission adopted your proposed 10,000 MW trigger for VNEM 2.0, what program

elements or specific features should the Commission include in the VNEM 3.0 tariff?

A: There should be a robust effort to incentivize energy storage at multifamily buildings in a VNEM 3.0

successor tariff. Ivy Energy supports the development of time-varying and dynamic rate structures for

multifamily buildings. These shared DER assets sited on multifamily properties can also be assets to grid

operators and provide grid services. The VNEM 3.0 tariff should also enable resilience at multifamily buildings

so that tenants are able to maintain reliable power in the event of a grid outage. Ivy Energy is keenly interested

in the value stacking opportunities for energy storage, microgrids, and customer demand response that advanced

rate design could enable at multifamily properties.

10 Protect Our Communities Foundation Proposal for Net Metering Successor Tariff, pg. 18-19

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Q: Does the Title 24 Building Code mandating solar on new homes provide a reasonable value

proposition for multifamily customers?

A: No. Title 24 on its own does not provide a reasonable value proposition for customers. While it has been

argued that the building code provides enough market security and stability for DER providers, the reality is

that the building owners and tenants of multifamily properties – the customers – derive value from monetizing

the DER asset. Maintaining a robust VNEM tariff that provides compensation for exports helps to maintain the

value proposition for customers. Without VNEM, property owners will not have a mechanism to recover the

costs of their solar investment other than increasing the cost of housing. It will also disincentivize proper

maintenance of the system by the multifamily building owner if there is no compensation for exports. If the

system is not maintained once built, due to the lack of incentives to maintain it, the tenants will lose the

intended benefits. Eliminating or reducing the VNEM value proposition will simply harm renting households by

increasing their costs, thereby increasing the inequities the Commission is attempting to correct in this

proceeding. Maintaining a robust VNEM tariff is a win-win for tenants, building owners, and regulators that

want to demonstrate their commitment to equity with intentional energy policy.

Q: What are some potential unintended consequences that could occur in the housing market if the

VNEM tariff is drastically altered for the multifamily sector?

A: It was assumed that VNEM would be utilized to help multifamily building owners recoup the cost of their

solar investment when the Title 24 mandates went into effect. If the VNEM tariff is dramatically altered and no

longer provides a viable pathway for multifamily building owners to monetize their mandated DER

investments, the costs of complying with Title 24 will be recovered through a direct increase in the market rate

rental cost with non-equivalent savings on energy cost. This is an inequitable solution that must be avoided.

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Over the next 10 years, it is estimated that 370,000 new apartment units will come online in California with

solar.11 Rental costing analysis decision-making practices utilized by most property management firms include

the use of annual rent comparable studies to determine real time market rates for rental units. Rent comparable

practices can have many variables, but it is common to compare rental pricing by price per square foot, year

built, and date last renovated.12 If there is no avenue for building owners to monetize multifamily solar, such as

through the VNEM tariff, the cost of Title 24 compliance will be folded into market rate rental cost, raising

housing costs and the baseline for the housing market as a whole. With the practice of comparables being

prevalent in California, in this scenario, over time, multifamily buildings built in years past will experience

higher rent adjustments to keep pace with the higher rental costs of new buildings that have mandated solar

under Title 24. This would cause a ripple effect where, over time, even older units without solar would be

valued at a higher cost by virtue of the rent comparable practice compounding year over year. This may easily

be avoided by keeping the full value of VNEM intact for building owners and renters.

Rising housing costs are exacerbating inequities and disproportionately harm renters, who are often low-income

and/or people of color. Maintaining a robust VNEM tariff now that solar is mandated for all new homes is

essential to keeping housing costs affordable over the next decade and beyond. Ignoring the potential damages

to an already volatile rental market would be extremely detrimental to those vulnerable Californians that the

Commission is focused on in this proceeding. In order to maintain a cost-effective Title 24 mandate, and avoid

unintended consequences in the housing market, the integrity of the VNEM tariff must be maintained.

Q: Does this conclude your testimony?

A: Yes. I appreciate the opportunity to submit this testimony on behalf of Ivy Energy.

11 Based on assuming 50,000 new rental units come online annually and 67% have Title 24 residential solar mandates. See

Appendix C of Ivy Energy Proposal for a Virtual Net Metering Tariff, March 15, 2021. 12 Selecting Comparable Properties; National Council of Housing Market Analysts and the National Housing &

Rehabilitation Association https://www.housingonline.com/councils/national-council-housing-market-

analysts/resources/white-papers/selecting-comparable-properties/

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Attachment 1

Analysis of energy usage and solar generation for a multifamily property in San Diego, CA

Figure 1. Updated Data – includes new months of 2021 solar generation and energy usage analysis that were not

available when the initial data was submitted with the proposal

Figure 2. Original Data – table from Ivy Energy Proposal (submitted March 15, 2021)

BillingPeriodID DateStart DateStop TotalLiveSolar TotalSolarCredit TotalGridAmount TotalSolarAmount TotalkWhUsage Total Solar / Load Offset% of Solar Export

165 8/5/2020 7:00 9/15/2020 7:00 22092.19387 1472.71101 23458.73013 23564.90488 47023.63501 0.501128951 6.666205351

208 9/15/2020 7:00 10/15/2020 7:00 13341.19732 3170.380322 11729.61221 16511.57765 28241.18986 0.58466296 23.76383652

216 10/15/2020 7:00 11/15/2020 8:00 7650.32886 805.6500444 5133.241104 8455.978905 13589.22001 0.622256384 10.53092042

229 11/15/2020 8:00 12/15/2020 8:00 4573.049998 0 10937.75993 4573.049998 15510.80993 0.294829865 0

315 12/15/2020 8:00 1/10/2021 8:00 3752.988 651.6909991 5496.940996 4404.678999 9901.619995 0.444844278 17.36459053

636 1/10/2021 8:00 2/10/2021 8:00 4558.211 800.0640002 5854.374971 5358.275 11212.64997 0.477877666 17.5521493

906 2/10/2021 8:00 3/10/2021 8:00 4095.419395 564.6416037 4513.109014 4660.060999 9173.170013 0.50800988 13.78714972

906 2/20/2021 8:00 3/10/2021 8:00 78.16585412 6.105395854 55.60875491 84.27124997 139.8800049 0.602453868 7.810822158

974 3/10/2021 8:00 4/10/2021 7:00 5383.044 747.6469999 4584.50902 6130.691 10715.20002 0.572149002 13.88892604

1110 4/10/2021 7:00 5/10/2021 7:00 5846.904606 1022.74739 4161.147915 6869.651997 11030.79991 0.622770067 17.49211692

1110 4/28/2021 7:00 5/10/2021 7:00 102.9276406 15.91735931 57.09500248 118.845 175.9400024 0.675485952 15.46461107

Totals 9257.555125 80731.98568 156714.1147

% Export 11% % Offset 52%

Date Start Date Stop Total Live

Solar Total Solar

Credit Total Grid Amount Total Solar

Total kWh

Usage

Total Solar / Load Offset

% of Solar

Export

Aug 2020 Sep 2020 22092.19387 1472.71101 23458.73013 23564.90488 37170.117

01 63.40% 6.67%

Sep 2020 Oct 2020 13341.19732 3170.380322 11729.61221 16511.57765 24578.016 67.18% 23.76%

Oct 2020 Nov 2020 7650.32886 805.6500444 5133.241104 8455.978905 13597.945 62.19% 10.53%

Nov 2020 Dec 2020 4573.049998 0 10937.75993 4573.049998 10937.67 41.81% 0.00%

Dec 2020 Jan 2021 3752.988 651.6909991 5496.940996 4404.678999 9901.515 44.48% 17.36%

Jan 2021 Feb 2021 4558.211 800.0640002 5854.374971 5358.275 11212.57 47.79% 17.55%

Avg. 54.47% 12.65%