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“Net energy metering, the gravy train that brought solar companies to Hawaii in droves and led to the nation’s highest grid penetration of rooftop solar, is over!”��

“Low-income ratepayers can now weather the storm of the energy transition with greater economic security.��Energy justice has prevailed!”

Not exactly.��

To be sure, the Public Utility Commission’s Oct. 12 order dealt a blow to the solar industry, but it is not the end of the distributed energy resources story, nor is it the final word on energy justice.��Reading the PUC’s NEM order in its broader context reveals that we have far to go, and many more to bring along the road to a just, 100 percent renewable energy future.

The Phase I order gives the energy industry a brake pedal.��It shifts the burden of innovation off of the utility to the solar industry, but only momentarily.��Phase I was intended to be a placeholder, but not a permanent one.�� More change cometh.

Enter Phase II.��If Phase II delivers on its promise, Hawaii will provide a national model for the renewable energy transition and tackle, head-on, the oft-wielded critique that increased access to rooftop solar hurts the poor.��Although the cost-shift argument has been dissected and critiqued before, the energy justice perspective adds nuance to the existing debate.

The original NEM pricing structure was not perfect.��Under the current utility regulatory model, when the utility sells fewer units of energy due to increased rooftop solar energy generation, the fixed costs of maintaining the grid are redistributed, or shifted, to those who do not participate in the rooftop solar program.

Of course this market imperfection was due for some sort of correction, but targeting NEM as the sole culprit for the “cost-shift” avoids tackling the real issue:��The traditional utility business model must change.��Moreover, in a few key ways, viewing NEM through a purely economic cost-benefit lens limits the justice debate.��

Rooftop solar sparked the energy transition in Hawaii.��It destabilized the utility business model.��This is a good thing for all of us, especially the poor, because this destabilization created competition and forced innovation, both of which should ultimately drive down consumer costs.

This competition also forced an authentic conversation regarding the alternatives to utility-scale energy generation.��Judging from Oahu’s electricity generation map, which illustrates that low-income and rural communities such as Waianae and the North Shore carry the vast majority of the island’s utility scale generation, this conversation is long overdue.

Ironically, the very communities that bear the burden of utility-scale generation are also those regularly singled out by the utility as victims in the “cost-shift” debate; however, the competition created by distributed generation reduces the need for large-scale generation, which is often sited in these same rural and poor communities.��

Finally, rooftop solar introduced decentralization into the energy generation conversation.��Decentralized energy generation, where energy is sited closer to the end user, reduces overall grid vulnerability and increases individual resiliency to major storm events in ways not possible with centralized generation.

New York’s 2012 Super Storm Sandy led the state’s regulators to move quickly to incorporate decentralized solutions into its energy landscape and to convene a group dedicated to exploring the impacts of the energy transition on low-income, vulnerable communities.

Hawaii faces similar threats to its grid infrastructure and to its most vulnerable ratepayers.��Phase II provides an opportunity to explore and resolve these inevitable tensions.

With respect to the state’s broader energy context, the NEM order came on the heels of the Community Solar Tariff released by Hawaiian Electric in early October to little fanfare and even less public scrutiny.

As per the legislative intent of Act 100, community solar, on its best day, is meant to broaden the market for participation in solar.��Other jurisdictions around the country have interpreted community solar legislation broadly to mean increased market participation by low-income ratepayers.

Sadly, as currently drafted, the utility’s tariff actually narrows the pathway for broader participation in community-owned generation and solidifies the utility’s discretionary hold on behind-the-meter generation.��Paradoxically, when the NEM order is read in conjunction with this unappealing Community Solar Tariff, one key market signal is clear to ratepayers:��If you can afford to defect from the grid, you should defect.

This is not energy justice.

In several recent orders, the Public Utilities Commission has indicated a deep concern for justice, and has continued to broaden access to its key dockets, including the power supply improvement plan and the merger.

Despite this broadening, consistently absent in any of these dockets is a strong advocate for low-income ratepayers.��The utility is not positioned to stake claim to this role, nor is the solar industry.

While the office of the Consumer Advocate has broad authority to offer analysis concerning the economic costs and benefits of the energy transition, it is perhaps less well suited to offer input concerning the vulnerabilities inherent in being a low-income ratepayer in the state.

The commission can fill this gap.

Justice is at the heart of our state’s energy transition.��Before deciding the key issues in Phase II of the Distributed Energy Resources docket or even the merger, the PUC can and should act pursuant to its broad authority to convene a diverse group of community-based organizations and advocates for the poor.��This group would actively advise the commission on issues concerning low-income ratepayers and energy justice.

The commission may rely on its own precedent and mandate to convene this group, or look to other jurisdictions for guidance.

Without this type of input, the justice arguments will get lost or worse, co-opted to preserve the status quo.