2. The Complaint

Everyday Communications Corp. dba Everyday Energy (Complainant or Everyday Energy) is a California-based corporation and B license Contractor (license #949535) that specializes in the design and installation of solar photovoltaic (PV) generating systems. Complainant contracted with Community Housing Works (Community Housing) to install a solar PV system at the Los Robles Apartment Complex (Los Robles). Los Robles, a 76-unit apartment complex, is master-metered and served through a single-phase 240 volt, 400 amp system that serves the common areas and all residential units.

Complainant alleges it requested that the generator be interconnected with San Diego Gas & Electric Company (SDG&E) through a separately-metered interconnection and that the property, which was served through a master meter, be served under SDG&E's virtual net metering tariff schedule, Schedule VNM-A, but that SDG&E refused. Complainant alleges it proposed separate energy metering because the original master-metered, single-phase 240 volt, 400 amp electrical systems cannot support a direct net-metering arrangement without substantial upgrades.

Complainant alleges that Tariff Schedule VNM-A is available to Community Housing as a "Qualified Customer" owning, renting, or leasing in a Multi-Family Affordable Housing Accommodation, where the owner of the complex has installed a solar `eligible customer generator' with the requisite capacity. Complainant alleges that SDG&E's refusal to allow Community Housing to take service under Schedule VNM-A is a violation of Pub. Util. Code § 532 because it constitutes a failure to offer and provide service in accordance with its tariff. Finally, Complainants contend SDG&E's failure to allow Community Housing to take service under Schedule VNM-A violates Decision (D.) 08-10-036, which Complainant argues requires SDG&E to offer virtual net metering arrangements to Multifamily Affordable Solar Housing (MASH) properties that install eligible customer generators to offset common area and tenant loads.

Community Housing is the owner of the Los Robles apartment complex. Los Robles is "low-income residential housing" as defined by Pub. Util. Code § 2852. Electric service to the tenants and common areas of the property is delivered by SDG&E through a single master meter. There are no sub-metered units or areas. Community Housing is the customer-of-record for all electric service to Los Robles.

Complainant contracted with Community Housing to install a 140.5 kilowatt (kW) alternating current (AC) solar PV generator at Los Robles. Community Housing secured a reservation for funding under the Commission's MASH program. Complainant is responsible for installation of the PV generator, associated facilities and equipment at Los Robles. Complainant is responsible for procuring, on Community Housing's behalf, appropriate interconnection and serving arrangements to allow the power produced by the PV generator to be delivered to SDG&E for the purpose of offsetting tenant and common area loads. SDG&E denied Complainant's request to be served under SDG&E's virtual net metering tariff schedule, Schedule VNM-A. Following SDG&E's denial for service under Schedule VNM-A, Complainant modified the electrical system serving the Los Robles apartments at its own expense to allow direct net metering.

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