Western States Build the Foundation of their Energy Future
The quest for a lower cost, more reliable and cleaner grid is motivating states to cooperate.
The operators of the electrical grid in the Western US have had a tough job recently. Region-wide heatwaves, wildfires, natural gas supply constraints, closures of reliable coal power plants and the opening of intermittent new plants have complicated the job of reliably delivering electricity to consumers. A tough job well done though, as the lights stayed on. Now many of these grid operators are facing massive increases in demand, as new policies that electrify transportation and buildings surely are going to require more supply. All this, while already powering seven of the fastest growing state economies in the US.
Grid operators and other stakeholder throughout the region have found a winning strategy to navigate this challenging environment – cooperation.
Earlier this month, the boards that oversee the Western Energy Imbalance Market (WEIM) approved the creation of a new day-ahead power market, known as the Extended Day-Ahead Market (EDAM). I am a Governing Body Member for the WEIM and enthusiastically supported the creation of this market.
The EDAM operates in the day-ahead time frame, a critical period when trying to coordinate reliable electricity supply. It’s a time when many of the challenges that impact supply and demand, such as weather, solar and wind forecasts have come into focus. It’s when the entities responsible for balancing supply and demand in their part of the grid decide which generators to operate, which generators to keep on stand-by and how much energy they need to buy from their neighbors or can offer to neighbors in need, balancing reliability and costs. Modeling estimates that the EDAM will generate an additional $1 billion per year in benefits if fully adopted throughout the West. This comes from further cost optimization of power plant operations, the elimination of certain transmission fees and the sharing of back-up reserves.
EDAM is a remarkable development in a region that has been reluctant to be bound together through regional organizations. The next opportunity, under discussion in state capitals throughout the West, is the establishment of a Regional Transmission Organization (RTO).
In an RTO the participating transmission operators transfer operations of their transmission system to the RTO. The RTO assumes responsibility for short-term reliability. This includes the ability to order power plants to produce more or less to maintain system reliability, sort of like how air traffic controllers ensure safety by monitoring and directing the movement of aircraft on the ground and in the air. RTO also assesses where new transmission investments are needed.
Last year the California legislature directed the California Independent System Operator (CAISO), the state’s existing RTO, to compile studies on the impacts of greater regional cooperation, such as through an RTO. The report will be finalized this week. A draft highlights a range of benefits from an RTO including reduced costs, increased reliability and lower emissions.
The California legislature is now starting to consider legislation that allows the CAISO to expand its existing role as California’s RTO to be a West-wide RTO. A 2015 effort to expand the CAISO’s role failed, but the world is different today.One concern put forward in 2015 by some environmental advocates was that an RTO would increase the profitability of coal power plants in the West and extend their life. This argument looks fanciful in today’s landscape. Coal power plants are closing across the western US. Using data from the US Energy Information Administration, I calculated that 3,000 megawatt of coal generation closed between the end of 2015 and the end of 2021. More significantly, over 60% of the remaining 25,000 megawatts of coal capacity is scheduled to close. Additional closures are being considered by utilities and regulators in resource planning processes. Coal has struggled to compete with wind, solar and natural gas. The creation of an RTO will not change that.
Another concern back in 2015 was an RTO would lead California utilities to preferentially develop clean energy projects outside of California where costs are lower. Hoped-for jobs and other economic development would exit the state. At the time California had much more aggressive renewable energy goals than other states, including a 50% renewable requirement by 2030 adopted that year. The picture in the West is very different today. Not only are California’s goals much higher, 100% carbon free by 2045, but many other states have adopted aggressive renewable goals. Nevada, for example, mirrored California’s goals. Given so many robust policy goals, low costs for wind and solar, and strong federal support, there will be ample project developments in California and everywhere else in the West in the coming decades. An RTO, if anything, is likely to accelerate clean energy development by creating more opportunities to share intermittent clean energy across a larger footprint. Recent research from Luis E. Gonzales, Koichiro Ito and Mar Reguant shows how this can occur through their analysis of market integration in Chile.
In 2015 some California stakeholders were also worried that moving to an RTO in which decision-making is shared across the region could make California vulnerable during stressed market conditions. The state would be unable to take actions to maintain reliability during a crisis because the RTO, overseen by FERC, would give too much deference to other economic interests in the market. Therefore the concern was that California’s costs would rise and reliability could suffer. Other states have shared this concern, but from their own vantage point.Perspectives have changed. Now there’s rapidly growing recognition that greater market cooperation is one of the best solutions available to increase reliability and lower costs, not a threat to these goals. WEIM, EDAM and an RTO increase visibility into the regional generation supply situation. These markets will better prepare the region as a whole, and individual load serving entities, to anticipate and prepare for stressful conditions, and to share resources when unanticipated challenges arise.
Suggested citation: Campbell, Andrew, “Western States Build the Foundation of their Energy Future”, Energy Institute Blog, UC Berkeley, February 27, 2023, https://energyathaas.wordpress.com/2023/02/27/western-states-build-the-foundation-of-their-energy-future/
Andrew G Campbell View All
Andrew Campbell is the Executive Director of the Energy Institute at Haas. Andy has worked in the energy industry for his entire professional career. Prior to coming to the University of California, Andy worked for energy efficiency and demand response company, Tendril, and grid management technology provider, Sentient Energy. He helped both companies navigate the complex energy regulatory environment and tailor their sales and marketing approaches to meet the utility industry’s needs. Previously, he was Senior Energy Advisor to Commissioner Rachelle Chong and Commissioner Nancy Ryan at the California Public Utilities Commission (CPUC). While at the CPUC Andy was the lead advisor in areas including demand response, rate design, grid modernization, and electric vehicles. Andy led successful efforts to develop and adopt policies on Smart Grid investment and data access, regulatory authority over electric vehicle charging, demand response, dynamic pricing for utilities and natural gas quality standards for liquefied natural gas. Andy has also worked in Citigroup’s Global Energy Group and as a reservoir engineer with ExxonMobil. Andy earned a Master in Public Policy from the Kennedy School of Government at Harvard University and bachelors degrees in chemical engineering and economics from Rice University.
To Old Surfer Dude – Thank you for your compliment!
Shutting down utility-owned solar load-serving entities (LSEs) would certainly permit more room for home solar owners to participate in producing clean electricity for California, and allow them to offset the cost of their arrays sooner.
“In a total lack of humility, I have a employed my degree in control systems at Boeing…”
Stating your qualifications doesn’t demonstrate a lack of humility. What’s true is true, and helps other posters better understand your perspective.
“Along with that would be CAISO control of these distributed systems and local electric storage.”
Allowing CAISO control of customer-owned solar raises privacy issues. Because CAISO is only regulated by the Federal Energy Regulatory Commission (FERC), in-state agencies have no ability to audit the company’s books and prevent local influence from compromising its independence and service to the community as a whole.
“Alas, the utilities will fight rooftop solar to their last day in bankruptcy court because their business model is that of profiting on capital improvements.”
Agree, but the business model of profiting on capital improvements is not theirs. It’s a consequence of California’s cost-of-service regulatory model, which permits utilities no profit on the sale of electricity (that’s right – not PG&E, SDG&E, nor SCE make any profit from selling electricity). Instead, utilities’ profit is based on return on equity, or a percentage of all the “stuff” they own. As you note, their incentive is to build as much stuff as possible even if it’s unnecessary (a phenomenon known as the Averch-Johnson Effect).
That includes the same unnecessary solar and wind farms that are helping to curtail your solar output!
How would transmission siting be done under an RTO? It sounds like the CAISO, with its existing rules and processes, would just become the new RTO. The CAISO’s current system is not designed to provide good opportunities for participation and input by regular citizens or small organizations or even local governments. The CPUC’s processes for public participation (while not great either) are better than those of the CAISO, but recent legislation requires the CPUC to be even more deferential to CAISO transmission determinations.
If California is serious about avoiding adverse impacts to disadvantaged communities (such as building transmission lines through them), the siting process needs to provide a means for those communities to be heard. Promises from above that the needs of those communities will be taken into consideration is not enough. Public participation and input needs to be made an integral part of the transmission planning process.
Peter, Thanks for the comment. I agree that meaningful public participation is very important before constructing new infrastructure that has impacts on communities and the environment. Extra efforts should be made to enable public participation for disadvantaged communities.
Concerning transmission siting under an RTO, the final ACR 188 report from NREL that came out this week says that a multistate RTO “would not remove the jurisdiction of California (or any other state) over its retail rates, resource planning, resource siting, transmission siting, renewable energy policies, or emissions reduction policies.” So, then applicable California law regarding how siting is done still applies. I appreciate you applying your extensive experience developing public policy through administrative processes to scrutinize the quality of public participation within the states processes.
Thanks, it is good to know that the RTO process likely would not make CA’s process worse than it is already. Language like you cite is likely necessary from a political standpoint to get states to buy-in to an RTO, but it might be good for the RTO process to try to improve the siting process.
I’m not familiar with the other states’ processes, but CA’s commitment to avoiding impacts on disadvantaged communities (and the environment in general) from the construction of new electric transmission projects is already questionable.
For example, language in the recently passed SB 846 that amends Public Utilities Code section 454.53(f) requires the CPUC to give more deference to the CAISO’s determination of need for a specific transmission project. This undercuts the ability of the CPUC to approve a “no project” alternative which the CPUC (but not the CAISO) is required to consider under CEQA.
I guess we’ll see how it plays out when the rubber meets the road, or more precisely when (and where) the steel starts hitting the dirt.
P.S. It looks like all the hands in the photo are white…
Grid regionalization was backed by Berkshire Hathaway Energy (BHE) when AB 813 (Holden, 2018) was aggressively promoted. Grid regionalization advocates are back with AB 538 (Holden, 2023.) To obtain an idea why such a policy change would be so important to BHE’s profitability, Californians need to revisit one of the most consequential pieces of California environmental legislation, SB 1368 (Perata, 2006) which set a performance standard for out-of-state long-term power supply contracts. This legislation became became PUC §§ 8340 – 8341. The consequence of grid regionalization would be to nullify PUC §§ 8340 – 8341.
The performance standard threshold in PUC §§ 8340 – 8341 is the emissions associated with a modern combined-cycle natural-gas-fired power plant. Coal-fired generation, which makes up a huge fraction of generation of holding company BHE’s subsidiaries in the American West, emits far above this threshold. Thus, it is currently barred for long-term (greater than 5 year supply contracts ) to serve California load. PacifiCorp, a BHE subsidiary is represented in California by Capitol Advisors. One of the opening salvos in the recent campaign was fired by Capitol Advisors and Delaney Hunter on October 13, 2022. “California Lawmakers Poised To Renew Push For Expanded Western Grid.” https://www.panc.org/wp-content/uploads/2022/10/INSIDE-CAL.pdf Quoting from the article, …..The plan called for first adding territory served by the utility PacifiCorp. The envisioned Western RTO would serve California ….
Independent nonprofit Californians for Green Nuclear Power (CGNP) at CGNP dot org was the lone adverse party to the BHE-backed Western Resource Adequacy Program (WRAP) in FERC Docket ER22-2762. Coal-fired generation is portrayed as a reliability asset. Among other issues, CGNP raised concerns regarding BHE market power. By many measures, the BHE subsidiaries in the American West collectively dwarf California’s “big three” investor owned utilities (PG&E, SCE, and SDG&E.) The last time California had a big out-of-state energy firm manipulating California energy markets, the result was the ENRON power crisis. (The most significant cost of that fiasco was the estimated loss of between $300 – $400 billion in productivity.) I believe that if BHE gets their way, the long – term losses to the California economy – and to the environment – will be far greater. As the unfolding energy crisis in Europe during the past twelve months illustrates, political power is connected with the control of energy supplies.
CGNP remains optimistic that genuine environmental stewardship organizations coupled with California organized labor will form a coalition that helps to reject the BHE coal-fired imports hidden within AB 538 (Holden, 2023.)
“Now there’s rapidly growing recognition that greater market cooperation is one of the best solutions available to increase reliability and lower costs, not a threat to these goals.”
And you link to PacifiCorp to support “greater market cooperation”?
Please, Andrew. PacifiCorp, a subsidiary of Berkshire Hathaway Energy, is at this moment building a 345kV high-voltage transmission line, the Gateway South Transmission Project, for the express purpose of transmitting fossil-fired electricity to California (95% of PacifiCorp’s electricity comes from coal- or gas-fired power plants). They are demanding wholesale electricity market rules to be non-discriminatory as to generation sources – that California will be unable to insist on solely carbon-free electricity to meet its reliability needs.
They are demanding WEEC have full control of western states transmission, effectively abolishing state control. For all practical purposes, abolishing CAISO.
For climate change it would be a disaster. We’ve already rejected this nonsense once (AB 13 in 2018), and we can trust PacifiCorp will continue portraying regionalization as a way for states to join together as one big, happy family, sharing renewable electricity as we solve climate change together. Their crusade is, by any other name, a scam.
The post inexplicably misses one of the key developments in regional integration in the West in recent years: the creation of the Western Resource Adequacy Program (WRAP) run by the Western Power Pool (https://www.westernpowerpool.org/). California has not joined the Pool, but most entities in the PNW have. This regional program fills an important gap in the WEIM that does not address adequacy and holds the promise to further support the route to a Western RTO down the road.
Thanks, JP! Agreed that WRAP is a very important piece of the regional cooperation puzzle. It’s recent approval by FERC is a big deal. I actually had a section on WRAP in a draft, but had to cut out it due to space constraints.
Aha! That makes sense, glad the WRAP was under your radar Andrew! Indeed, the FERC tariff approval was critical and I’m excited to see the non-binding phase of the program to take off.
Your assertion that a west-wide RTO would not cost California jobs omits the most critical factor: the Product Content Category requirements of current law (AKA “the Bucket System”). The existing Product Content Category requirements are based on the footprint of the CAISO. They are the overwhelming dominant reason for renewable generation development in California (and near Las Vegas and other places that can directly connect to CAISO facilities). Without them, LSEs would always choose cheaper projects in other states. If the CAISO footprint expands throughout the west, then everywhere would qualify as PCC 1. There would be little reason to develop projects in California where land and permitting is more expensive, while other states have “right to work” laws. California construction workers would lose hundreds of thousands of construction jobs, no matter the clean energy requirements of other states.
WEIM (thank you for serving on the board) and EDAM get most of the benefits of a western RTO without the loss of California jobs.
If the disincentives for rooftop solar were reversed, and since there is ample rooftop space, jobs would be plentiful in California.
Energy storage is the answer to intermittent supply from renewables that will be our climate change required correction future. Weather we pump water behind existing hydro-electric dams, use hydrogen generation or batteries to store the excess solar and wind energy, for later release and distribution, that is the decisions that really need to be addressed today. The battery system, employed by PG&E at Moss Landing, is a good start and helped save the grid back in September of 2022 during the evening crunch, along with thousands of rooftop solar customers who sent their own battery storage electrons to the grid. We need more of both, but NEM 3.0 will curtail any future rooftop solar with battery systems because the utilities will not pay a fair price for the electricity received from the owners of systems build and connected to the grid after April 14, 2023. Residential battery storage cost twice what larger grid tied batteries systems per kilo watt hour of storage and will never get the pay back they need to warrant the installation of Lithium batteries. Only if battery storage prices drop by 50% from the current prices will residential storage become a viable option under NEM 3.0 in the future.
Actually, residential solar+storage is warranted based on PG&E’s rate projections in its 2023 GRC–but it works by customers exiting the grid: https://mcubedecon.com/2022/03/17/are-pges-customers-about-to-walk/ (I got confirmation from a local vendor that the costs used in this analysis are consistent with actual installations.)
I am one of those that will be leaving the grid, though I will use the grid as a very, very expensive backup battery.
“Residential solar + storage…works by customers exiting the grid…”
Good luck with that one. I have yet to find anyone, in California or anywhere else, for whom residential solar + storage alone “works”. The asterisks attached to those claims are many, and always – always – include a natural gas, diesel, or propane generator hiding around the corner to provide backup power.
And you’ll find it isn’t just backup power. Any honest accounting reveals that generator provides the bulk of their home’s energy, increasing their CO2 emissions beyond what they would be if they remained connected to PG&E’s grid.
A New York Times article titled “Frustrated With Utilities, Some Californians Are Leaving the Grid” reveals not a single example of someone whose home is powered exclusively by solar + batteries. The only resident who even claims that distinction is someone whose job it is to sell other fake renewable homes, to other fake environmentalists:
“One of those residents is Alan Savage, a real estate agent in Grass Valley, who bought an off-grid home six years ago and has sold hundreds of such properties. He said he never loses power, unlike PG&E customers. ‘I don’t think I’ll ever go back to being on the grid,’ Mr. Savage said.
“For people like him, it is not enough to take the approach favored by most homeowners with solar panels and batteries. Those homeowners use their systems to supplement the electricity they get from the grid, provide emergency backup power and sell excess energy to the grid.”
Solar + batteries is just another entry in the vast catalog of “renewables” scams, one touted by grifters and con men who have discovered well-intentioned people with well-funded retirement accounts are an easy mark. And I defy you to prove otherwise.
Again, I’ll point out that PG&E and Box Power installed a microgrid near Yosemite that only used a back up propane generator 40 hours last year. This is in a location with significant cloudy weather and cold temperatures during the winter. I also posted earlier an NREL study showing that solar+storage microgrids can supply power in California in the high 99% range. And all of this is before EVs have entered the picture to further extend storage at little incremental cost. I’m willing to live with a fossil generator running 40 hours per year if its zero carbon the other 99+% of the time.
Thanks for confirming “solar + batteries” is a fantasy.
Since trust has now become an issue, we’ll need some assurance PG&E/Box Power’s propane generator was indeed only used 40 hours last year. After all, Box Power is a battery vendor which stands to realize $millions promoting the S+B fantasy. Would it not be reckless to blindly accept the report of an entity with such a blatant conflict of interest? Of course it would. You know that, and I know that.
And such conflicts abound in S+B fantasyland, nonetheless at the National Renewable Energy Laboratory. Though NREL’s stated mission once included “promoting adoption of renewable energy”, evidently some employee realized promotion didn’t pass the reputable-science smell test, and the designation was dropped.
One way or the other: when someone’s career is on the line at an institution dedicated to researching a field of such questionable validity, there is an undeniable conflict. Whether it influences the institution’s output, or not (ask the folks at the National Perpetual Motion Laboratory (NPML)).
“And all of this is before EVs have entered the picture to further extend storage at little incremental cost.”
And all of this is assuming V2G is a whit more viable than R+B – that it will, someday, enter any picture at all.
If nothing else, the renewable “energy transition” is an apt analogue for a house of cards – and a very expensive one, at that.
You cite numerous potential benefits of a regional RTO, and hopefully one will be established in the not-too-distant future. I would point out that the last big effort to have CA join a regional RTO was in 2018 in Assemblymember Chris Holden’s AB 813, which passed in the Assembly but never reached the Senate floor. Gov. Brown generally supported the bill but it was not a priority.
Just as in 2015, there were significant concerns in 2018 about coal, especially given Trump’s commitment to revive the industry. I think all the factors you cited about the decline of industry now are correct, but many opponents of Holden’s bill are no doubt still concerned about the prospect of another Republican president who might use FERC to lean on a regional RTO to do things that are not in CA’s best interest, perhaps not regarding coal but in other ways in certain market conditions. Twenty-two years after the energy crisis, distrust of FERC is still visceral for many people who experienced it.
Finally, you’re right about the concerns about a regional RTO and the loss of California jobs in the energy sector during the previous decade. That still is a big issue, and I think that organized labor will still need to be convinced to support a regional RTO.
The fear of FERC intervention that you identify has some empirical evidence as when FERC intervened to override certain state subsidies for renewables in the interest of “markets” as just one example. That will need to be an ongoing concern
I agree that this larger RTO is needed. My concern is that the energy market created would favor large solar projects over small ones and it would require the construction of more transmission lines.
Large solar projects are the bane of groups like Citizens for Responsible Solar. In order to protect our open space, we need to use existing rooftops. One rooftop comes to mind is that of the rooftop of mega-warehouses.
And the very small, the residential rooftop, should be included in this market. Yes, these electric energy providers must allow the RTO to control their output. And, yes, the software is very complicated. But then, so was Hoover Dam.
One other aspect of this proposed RTO that must be addressed and that is accounting transparency. It would be easy to favor energy from one source over another. Rules would have to be put into place that ensures that the consumers get the lowest cost energy.
“And the very small, the residential rooftop, should be included in this market. Yes, these electric energy providers must allow the RTO to control their output.”
That output is not controlled now, and that is one of the reasons why CAISO still has to curtail significant amounts of utility-scale solar. If a regional RTO started curtailing NEM solar, I suspect that would cause an uproar as that would create huge uncertainty in the return on investment for roof-top solar customers.
I am extensively invested into rooftop solar and curtailment, when needed , would impact me significantly. Yet I understand the need for it.
But, the circuit to which I am connected would have to be a net generator warrant curtailment. Even then, the curtailment would only be to the extent that circuit of its excess.
The real fear of curtailment by the rooftop solar ratepayer is being curtailed in deference to non-renewable resource or a utility owned resource.
If past experience is any indicator, this will happen.
Just because the utilities have forgotten, we must not forget that the utilities are a monopoly for the sole purpose to benefit society and it is guaranteed a profit for providing that service.
Currently, NEM only exists for grandfathered installations and will be completely gone in 20 years.
Old Surfer Dude, you are correct that solar is being curtailed nearly every day in California between 9AM-3PM, but it isn’t in deference to another non-renewable or utility-owned resource, or both. At least not directly.
The California Independent System Operator (CAISO) is forced to curtail solar during those times because solar generates too much electricity – so much, that it threatens system reliability.
Generation to an electricity grid, from all sources combined, must precisely match demand in real time. Either too much or too little, and the grid goes down (within ~3%). That’s a tough balancing act, and though there’s a complex computer system in CAISO headquarters in Folsom, CA, capable of bringing resources online and taking them off automatically, not all resources are fast enough to respond.
For example: if a cloud bank moves over SolarOne, California’s largest solar farm, 500 million watts of power can disappear in a matter of minutes. To keep the grid from going down, CAISO must quickly bring 500 million watts of power from dispatchable resources (ones which aren’t dependent on weather) online to make up for it. Conversely, if supply is already generating 100% of demand for electricity when the cloud bank clears SolarOne, 500 million watts of electricity must quickly be shed, or too much electricity trips breakers (like fuses in your car, or house) to prevent damage to the grid. Either way, the lights go out for millions of customers.
The only dispatchable resources that can ramp up or down fast enough are natural gas-fired power plants. For that reason, gas plants must be kept online 24/7 to be available when output from solar and/or wind wavers. Critics of solar and wind note that because both solar and wind require gas-fired power to be online all the time, they will never be truly 100% emissions-free sources.
A graph at the following link illustrates this phenomenon in detail:
The Failure of California Electricity Policy in One Image
A prime reason why there’s curtailment midday is due to the constant undispatchable output from Diablo Canyon and Palo Verde. Remove that 3600 MW and there’s a lot less. And natural gas plants must remain on line to meet load changes on top of that baseload output. Same problem, different flavor.
“A prime reason why there’s curtailment midday is due to the constant undispatchable output from Diablo Canyon and Palo Verde. Remove that 3600 MW and there’s a lot less.”
An interesting interpretation, but incorrect.
The reason there’s curtailment midday is the overgeneration of inconsistent, undispatchable, intermittent, unpredictable output from California solar, resulting in not only a threat to grid reliability, but additional charges for decremental payments to solar farm owners, as well as paying other states to accept unwanted solar energy (“negative pricing”) – a cost borne by California electricity customers for which they receive nothing of value (other than preventing solar from damaging transmission and potentially causing blackouts).
“And natural gas plants must remain on line to meet load changes on top of that baseload output. Same problem, different flavor.”
A less interesting, but still erroneous interpretation.
Gen 2+ nuclear plants, including Diablo Canyon and Palo Verde, are more than capable of load-following the gentle curves of customer demand. Though they’re incapable of helping erratic wind and solar resources produce reliable output, flexible, small modular reactors (SMRs) will be available by 2030 to help until all wind and solar resources are retired.
You forgot an import discriminator, “overgeneration of inconsistent, undispatchable, intermittent, unpredictable output from California solar” farms. If this solar panels were spread across the empty roofs of California, then the fluctuations described would probably be. Just like a rain prediction of 25% means that over the large area 25% of the area will get rain (as opposed to a 25% probability that the entire area will get rain.)
Rooftop solar, not solar farms.
Oh, and a side benefit of fewer transmission lines for which the ratepayer must foot the bill.
I commend you on your excellent comment!
My take-away from it is that your comment is a strong argument to make solar as distributed as possible. Many, many generation sources would mitigate this single source conundrum. That is, we need as much rooftop solar as is possible, not solar farms.
Along with that would be CAISO control of these distributed systems and local electric storage. Battery storage is key as it can provide energy and shed load quicker than clouds can obscure or dissipate.
Yes, the program is complex, but IMHO, the only serious difficulty is in getting socially beneficial co-operation among energy providers. (In a total lack of humility, I have a employed my degree in control systems at Boeing, am a former SDG&E engineer, have taught computer science at the university level, etc.)
A major benefit from rooftop is that the ratepayer does not pay for these capital improvements while obviating other capital improvements.
Alas, the utilities will fight rooftop solar to their last day in bankruptcy court because their business model is that of profiting on capital improvements.
Again, with most sincerity, I think your comment is great!
Climate Change cranks dismantling the national grid that has served us well for nearly 100 years … the result will be disaster.