California Utilities Plan All Out War On Solar, Please Read And Help

[mspohr]

When I looked over NEM 3.0, my impression was (for the most part, anyway) that export rates are market, less non-bypassable charges. Excluding NBC, the import/export hourly differences were probably (maybe ?) explained by demand charges.

I admit, it does seem fair to credit PV exporters with demand savings that accrue from distributed energy but that is way beyond me to talk about in any detail.

Here's a graph on NEM3 that was posted a few days ago:

You can see from this that export prices are much lower than import prices.
Also, it's interesting that export prices don't rise much during peak demand times but import prices do rise a lot.

 

[SageBrush]

Here's a graph on NEM3 that was posted a few days ago

By me, and I remember it well enough. I also noticed the same that you point out now, and questioned whether the differences are demand charge related. That is how it looks to me but I cannot say it is so with any confidence.

 

[mspohr]

By me, and I remember it well enough. I also noticed the same that you point out now, and questioned whether the differences are demand charge related. That is how it looks to me but I cannot say it is so with any confidence.

Looking through the article you posted, there is no mention of demand charges. It's all just lower export rates:
The big thing to know is, on average, NEM 3.0 export rates are around 75% lower than the export rates for NEM 2.0.

 

[SageBrush]

The big thing to know is

That the PUC expects time shifting and (maybe) ESS to be part of a money saving residential package

 

[iPlug]

That the PUC expects time shifting and (maybe) ESS to be part of a money saving residential package

It should be a PUC goal, but as E-TOU-C rates show, there is much too little incentive for time-shifting, including with ESS.

E-TOU-C + NEM 3 means punishment if not self consuming as much PV solar as you can (not an entirely bad idea by itself), but little incentive to time-shift consumption away from peak demand (bad idea) and little incentive to export ESS to grid at peak demand (bad idea).

 

[SageBrush]

It should be a PUC goal, but as E-TOU-C rates show, there is much too little incentive for time-shifting, including with ESS.

E-TOU-C + NEM 3 means punishment if not self consuming as much PV solar as you can (not an entirely bad idea by itself), but little incentive to time-shift consumption away from peak demand (bad idea) and little incentive to export ESS to grid at peak demand (bad idea).

Excluding NBC, I see a 12¢ per kWh arbitrage between import/export for two hours a day for those with ESS alone
If the arbitrage is export - PV, it can be close to 25¢ a kWh for those with both ESS and PV

Is that enough to incentivize PV+ESS for a household clued in to self-consumption ? I really do not know, but I suspect EV as ESS may be in play now, or when the V2G costs come down. I hope so.

 

[iPlug]

Excluding NBC, I see a 12¢ per kWh arbitrage between import/export for two hours a day for those with ESS alone
If the arbitrage is export - PV, it can be close to 25¢ a kWh for those with both ESS and PV

Is that enough to incentivize PV+ESS for a household clued in to self-consumption ? I really do not know, but I suspect EV as ESS may be in play now, or when the V2G costs come down. I hope so.

E-TOU-C above? Maximum arbitrage is 6¢/kWh only for 4 months a year and over 5 evening hours. The other 8 months are 2¢/kWh. Add round trip ESS losses and its gets even sadder.

Understand you are suggesting if one could not self consume all PV solar (in real time), and could put this in ESS then export at peak time, much better arbitrage delta there.

 

[SageBrush]

Understand you are suggesting if one could not self consume all PV solar (in real time), and could put this in ESS then export at peak time, much better arbitrage delta there.

Yep.
BYD is able to sell extra EV pack capacity for $200/kWh retail. If we presume 365 days per years * 10 years and a 20¢ / kWh arbitrage with CA electric utility, the revenue is 365*10*.2 = $730 per kWh. This is far from being a comprehensive accounting, it is just meant to say that the CA PUC may have left open an incentivized residential PV+ pathway that is an actual public benefit.

 

[mspohr]

Yep.
BYD is able to sell extra EV pack capacity for $200/kWh retail. If we presume 365 days per years * 10 years and a 20¢ / kWh arbitrage with CA electric utility, the revenue is 365*10*.2 = $730 per kWh. This is far from being a comprehensive accounting, it is just meant to say that the CA PUC may have left open an incentivized residential PV+ pathway that is an actual public benefit.

Only if you had excess solar to sell.
I'm trying to figure out how this would work for me.
Summer I have excess solar... about 1,000 kWh over 4 months. I guess I could push at 20 cents for 4 months = $200
Winter I have no excess so I'm stuck buying to meet my needs.
Under my current net metering I send about 10,000 kWh excess to the grid during the year (solar generates 14,800 kWh) and get full credit. (Push to grid during the day and pull at night.) So, under current net metering I get full use of my 10,000 kWh at 20 cents ...$2000 which is a lot more than $200

 

[SageBrush]

Only if you had excess solar to sell.
I'm trying to figure out how this would work for me.
Summer I have excess solar... about 1,000 kWh over 4 months. I guess I could push at 20 cents for 4 months = $200
Winter I have no excess so I'm stuck buying to meet my needs.
Under my current net metering I send about 10,000 kWh excess to the grid during the year (solar generates 14,800 kWh) and get full credit. (Push to grid during the day and pull at night.) So, under current net metering I get full use of my 10,000 kWh at 20 cents ...$2000 which is a lot more than $200

PV alone under NEM 3.0 is a tough call without substantial self consumption, no doubt about that.

 

[gene]

Center For Biological Diversity is suing the CPUC NEM3 decision. This is fabulous. I have supported the Center for many, many years. They are very good at getting stuff done. Looking over the filing, they are making some excellent arguments.

 

[cpa]

Center For Biological Diversity is suing the CPUC NEM3 decision. This is fabulous. I have supported the Center for many, many years. They are very good at getting stuff done. Looking over the filing, they are making some excellent arguments.

Gene, it appears to me that the CBD et al. are appealing the decision through the formal appeals process. At this point, it is not a lawsuit. I've done appeals on income tax matters over the years (though I am not a lawyer.) You gotta go through their hoops before you turn it over to the courts.

Generally, the rules are such that the parties affected by perceived improper rulings or decisions must first exhaust their administrative remedies with the appropriate body (here the CPUC.)

My take is that this appeal will stay the implementation date of April while the CPUC lawyers and the lawyers for the IOU pore over their arguments. Then, either the CPUC will reject the appeal or they will come to the table once more with yet another round of biased negotiations. If the appeal is rejected, then if there are no other administrative remedies, the CBD will file suit to have the courts adjudicate the situation. Otherwise, back to the drawing board.

I think this puts the CPUC and the IOUs on notice that we are just going to sit by and let them pick our pockets. The arguments advanced do appear sound to me. But I am not a lawyer, and there may be more than one way to view the cases, statutes, policies, and other materials cited in the appeal.

I have no idea whether this will wind up in court, or whether the CPUC sobers up and recognizes that they have been exposed as lackeys for the IOUs and decides to be more equitable in their decision.

 

[gene]

CPA, thank you for the clarification. In any event, this is very good news, plus the Center is tenacious once they take on an issue. This is why I fiancially support them for years and years. Money donated to them actually is put to very good use.

 

[mspohr]

Center For Biological Diversity is suing the CPUC NEM3 decision. This is fabulous. I have supported the Center for many, many years. They are very good at getting stuff done. Looking over the filing, they are making some excellent arguments.

Just reading the TOC of the document summarizes their excellent arguments.

TABLE OF CONTENTS
Page
I. INTRODUCTION ...............................................................................................................2
II. STANDARD OF REVIEW .................................................................................................3
III. ARGUMENT .......................................................................................................................5
A. The Decision violates the statutory mandate for any successor tariff to
ensure the continued growth of distributed generation in California. .....................5
B. The Decision violates the statutory mandate for any successor tariff to
include specific alternatives designed for growth among residential
customers in disadvantaged communities. ...............................................................9
1. By improperly relying on AB 209 to replace the Equity Fund, the
Commission has not designed an alternative for growth among
residential customers in disadvantaged communities. ...............................10
2. By rejecting a specific low-income cost of solar installation, the
Commission frustrates any mechanism to grow BTM generation in
disadvantaged communities. ......................................................................15
3. By improperly deferring consideration of community solar and
storage, the Decision fails to ensure growth of BTM generation
among residential customers in disadvantaged communities. ...................17
C. The Commission commits legal error by failing to account for the benefits
and costs of BTM generation. ................................................................................19
1. The Commission’s analysis of the benefits of NEM systems fails to
comply with AB 327. .................................................................................19
a. The Commission commits legal error by relying
exclusively on the ACC. ................................................................20
b. The ACC omits several benefits of NEM systems. .......................24
2. The Decision’s analysis of the costs of NEM systems fails to
comply with AB 327. .................................................................................38
a. The Decision commits legal error in conflating the
purported cost shift to non-participants with NEM
participants’ bill savings. ...............................................................39
b. The Decision improperly focuses on costs to non￾participants instead of cost-effectiveness to the electrical
system as a whole...........................................................................42
D. The Decision’s deferral of numerous significant considerations to other
proceedings makes an accurate accounting of the successor tariff
impossible. .............................................................................................................44
E. The Commission commits legal error in making major changes to the
tariff for commercial and industrial customers without record basis. ...................45
IV. CONCLUSION ..................................................................................................................46

 

[cpa]

The gist of the appeal boils down to a simple thesis: The courts are the experts on the law. The CPUC is supposed to interpret and implement the law, tariffs, and other regulations. If it is felt that the CPUC did not follow the law, tariffs, etc., then the courts must intervene to get things right.

Again, IANAL. But if this does wind up as a lawsuit, the courts will not prescribe the remedies. The courts will determine that the CPUC breached the laws, tariffs, and other regulations and sends the case back to the parties to negotiate the new rate system. It is likely that the courts would oversee this process and then sign off once everyone is in agreement.

Probably like the lawsuits faced by LADWP in the 80s-90s with the Owens Lake and Mono Lake situations. The courts sided with the plaintiffs and required the parties to strike an equitable solution that the court signed off on and ordered. (Which of course 25 years later, DWP is still in breach. But that is another show.)

 

[gene]

Appeal seeks to reverse CPUC's flawed rooftop solar decision - Solar Rights Alliance

Three nonprofit organizations have appealed the California Public Utilities Commission (CPUC)’s December 2022 decision to eviscerate the state’s rooftop solar program. The appeal outlines several ways in which the CPUC’s decision violates both the law and their own rules, and argues that the...

solarrights.org

 

[gene]

Why net metering is a good thing.

https://www.biologicaldiversity.org/programs/energy-justice/pdfs/Rooftop-Solar-Justice-Report-March-2023.pdf

 

[nwdiver]

Why net metering is a good thing.

https://www.biologicaldiversity.org/programs/energy-justice/pdfs/Rooftop-Solar-Justice-Report-March-2023.pdf

I agree with the premise but putting 'net metering' on a pedestal is problematic. It's a simple scheme for a complicated situation that's rapidly evolving. Xcel has 'net metering' BUT also charged ~$0.04/kWh produced. Central Valley Electric has 'net metering' BUT also added a ~$4.50/kW demand fee. Otero Electric has 'net metering' BUT also has a $35/mo connection fee.

NET METERING; Four reasons "Net-Metering" is no longer our friend...​

 

[ItsNotAboutTheMoney]

I agree with the premise but putting 'net metering' on a pedestal is problematic. It's a simple scheme for a complicated situation that's rapidly evolving. Xcel has 'net metering' BUT also charged ~$0.04/kWh produced. Central Valley Electric has 'net metering' BUT also added a ~$4.50/kW demand fee. Otero Electric has 'net metering' BUT also has a $35/mo connection fee.

NET METERING; Four reasons "Net-Metering" is no longer our friend...​

Both ways have to go through a distributor who needs to be paid so why would you treat generation have the same value as consumption?

Net metering has always been wrong. Feed-in tariffs are a much better way.

 

[nwdiver]

Both ways have to go through a distributor who needs to be paid so why would you treat generation the same as consumption?

Net metering has always been wrong.

I wouldn't go that far. In the early days when solar penetration was low energy exported at 4pm was always going to be worth more than energy imported at 4am so the aggregate result was that the utility would come out ahead. Roughly speaking it works fine at least up to ~5%. Beyond that it does get vastly more complicated.