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CPUC NEM 3.0 discussion

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absolutely agree, the shift to 4-9PM peak inside of NEM1 and NEM2 has already destroyed payback horizons. the NEM3 thing is just insult to injury.
So true! Our PowerWall helps a lot, covering our consumption from 3 to 12pm to make all our imports off-peak. We were very lucky to get the PW paid for by SGIP Equity Resiliency grant, so the ROI is great! Without the grant, PW is too expensive to justify economically.

On the other hand, the new Export Everything and Grid Charging features add additional leverage to solar under NEM1,2, beyond just avoiding peak period imports. I have not done the math, but perhaps the PW ROI looks better now.

If NEM3 comes to pass, depending on the details we'll all have to re-strategize our solar and storage. For example, perhaps car charging during the day so as not to exporting solar. Or getting a transfer switch to take our solar off-grid and canceling NEM altogether? We'll see.

In the mean time we should all call or write the governor now, so he can stop the NEM3 train wreck!

SW
 
Just saw this post now:



Solar tax is back, grandfathering dropping to 15 again...


Seeems like the current proposal is summarized by this:

Meatwad650 32 points 8 hours ago

So let me get this straight:

  • The first pass at NEM3 comes out. It’s horrific.
  • We all contact people and they realize they ****ed up and pull it.
  • The second pass at NEM3 comes out. It’s less horrific.
  • Right at the deadline the comments come out showing that the utilities want NEM3 to be even more horrific than the first pass.
Isn't this "new" industry response pretty much the same as the original proposal, the one which caused the governor to kibosh the plan?
 
Isn't this "new" industry response pretty much the same as the original proposal, the one which caused the governor to kibosh the plan?

I think some of it is even worst than the original proposal. I don't believe there was a kill of grandfathering for nem1.0/2.0 after a home is sold and 8 years grandfather was definitely not there.

We'll see what they actually vote on or approve, but seems overall worst than the 1st iteration. This has that solar tax too. It's all confusing to me so I'll just wait for smarter folks to break it down.

I think if this passes with these even worst terms, there will be massive job losses and most politicians don't like to kill jobs which stops them from getting elected.
 
So true! Our PowerWall helps a lot, covering our consumption from 3 to 12pm to make all our imports off-peak. We were very lucky to get the PW paid for by SGIP Equity Resiliency grant, so the ROI is great! Without the grant, PW is too expensive to justify economically.

On the other hand, the new Export Everything and Grid Charging features add additional leverage to solar under NEM1,2, beyond just avoiding peak period imports. I have not done the math, but perhaps the PW ROI looks better now.

If NEM3 comes to pass, depending on the details we'll all have to re-strategize our solar and storage. For example, perhaps car charging during the day so as not to exporting solar. Or getting a transfer switch to take our solar off-grid and canceling NEM altogether? We'll see.

In the mean time we should all call or write the governor now, so he can stop the NEM3 train wreck!

SW

yeah i've been using the PW to export solar from 4-9pm (or 4-xPM as there isn't enough solar in the winter to make it till the end of peak, and even in the summer the PWs are tapped by 8-830pm). however, i don't want to enable grid charging due to the whole solar ITC thing. i guess i have to wait 5 years from PTO to turn that on, but i'm sure going to.

on EV w/o powerwalls i was +/- $200 per year at true up. on EV2 i'm at +1500 per year, and with the powerwalls time-shifting i'm probably at +500 per year. the PWs probably won't pay for themselves but i installed them because i was worried about PSPS events. and of course PGE has now segmented the grid enough that i think we probably won't have any more PSPS events!

i did fill out the form from the solar alliance page linked above and separately sent a webform email to the governor.
 
however, i don't want to enable grid charging due to the whole solar ITC thing. i guess i have to wait 5 years from PTO to turn that on, but i'm sure going to.
I did not take the ITC, so that is not a constraint on grid charging for me.

I think I heard that batteries will soon qualify for ITC with or without solar, so I expect the 100% solar charging "rule" to go away. Hopefully someone will file a formal inquiry with IRS soon to document their interpretation of the new rules as they apply to old installations. Since time shifting solar export to peak periods is a key way to facilitate broad expansion of solar capacity, it seems to me that allowing occasional grid charging is completely aligned with the congressional intent of the solar ITC, in spite of the "charged exclusively from solar" phrase.

It would be nice if someone in the industry would approach IRS on this. Elon is probably not the best candidate, but Enphase has an interest in the issue...

In the mean time, far be it from me to give tax advice, especially to people in a situation different from mine, so take this with a grain of silicon:
  • Are we aware of any binding opinion from IRS on the 100% solar interpretation for residential solar?
  • Have we heard of any enforcement actions on this?
  • Tesla Storm Watch would appear to be a violation...
  • It is not clear that IRS could even detect or enforce the current 100%.
  • And, if IRS did enforce it, perhaps the penalty would be a return of the ITC only the non-solar fraction of the charging.
SW
 
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My solar basically turns off at 4pm this time of the year, so yep, a joke
That is what Export Everything" is good for, If they let you do that.... I don't see a regulatory justification for denying that capability, though NEM retail credits are still limited only to exports less than solar production over the month.

Perhaps exporting from 7 PW's, i.e. 35kW, could present problems, but I don't see how: each 200 amp home connection and transformer is good for 48 kW.

SW
 
That is what Export Everything" is good for, If they let you do that.... I don't see a regulatory justification for denying that capability, though NEM retail credits are still limited only to exports less than solar production over the month.

Perhaps exporting from 7 PW's, i.e. 35kW, could present problems, but I don't see how: each 200 amp home connection and transformer is good for 48 kW.

SW
I just have no desire to put the energy into playing the game. I have a zero energy bill. I get back pennies on the dollar for excess I send to PGE. I just like trying to keep my setup KISS. :)
 
I did not take the ITC, so that is not a constraint on grid charging for me.

I think I heard that batteries will soon qualify for ITC with or without solar, so I expect the 100% solar charging "rule" to go away. Hopefully someone will file a formal inquiry with IRS soon to document their interpretation of the new rules as they apply to old installations. Since time shifting solar export to peak periods is a key way to facilitate broad expansion of solar capacity, it seems to me that allowing occasional grid charging is completely aligned with the congressional intent of the solar ITC, in spite of the "charged exclusively from solar" phrase.

It would be nice if someone in the industry would approach IRS on this. Elon is probably not the best candidate, but Enphase has an interest in the issue...

In the mean time, far be it from me to give tax advice, especially to people in a situation different from mine, so take this with a grain of silicon:
  • Are we aware of any binding opinion from IRS on the 100% solar interpretation for residential solar?
  • Have we heard of any enforcement actions on this?
  • Tesla Storm Watch would appear to be a violation...
  • It is not clear that IRS could even detect or enforce the current 100%.
  • And, if IRS did enforce it, perhaps the penalty would be a return of the ITC only the non-solar fraction of the charging.
SW

you are right, in fact i was talking to another solar/PW user at a holiday party and he brought this up - if standalone batteries are going to qualify for the ITC, and obviously they can only grid charge, then what about us early adopters? on the other hand if the point of a standalone battery qualifying for the ITC is related to grid resiliency, maybe all they are allowing you to do is discharge into the grid during a grid emergency.

i *think* the storm watch toggle had/has a disclaimer about "talk to your tax professional", but i might be conflating the grid charging toggle.

i'd think that the IRS would need tesla or other manufacturers to "rat us out" as far as enforcement goes, though the IOU can at least deduce what you are doing if they suddenly see power consumption at night and exporting to the grid during peak, especially during the winter.

as far as grid charging / discharging of the powerwall goes, at least for a solar customer you're only eligible to export what they estimate you generate. so in practical terms the amount of grid charging that makes sense financially is going to be relatively limited - either by low estimated generation during the winter, or your home not self-consuming that much relative to the total solar generated. i don't know how the IOUs will handle standalone batteries, since estimated generation is obviously 0 for those customers.

if i remember right, for commercial owners the IRS does have the concept of < 100% solar charging, and the ITC is prorated. so there's precedent for your last point, at least.
 
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I just have no desire to put the energy into playing the game. I have a zero energy bill. I get back pennies on the dollar for excess I send to PGE. I just like trying to keep my setup KISS. :)
I do understand. But I'm sorry to tell you that your system is not exactly simple. Big, yes, but simple? Still, in your case, more NEM credit would make a larger credit balance for PG&E to zero out at true-up.

In the context of the NEM3 proposal, I think it is important for folks to understand that utilities benefit from customers using batteries, with or without solar. The economics of buying batteries are not great, so I think anything CPUC can do to facilitate residential batteries would help a lot. NEM3 as proposed would stop solar and batteries too by spoiling the ROI.

SW
 
I do understand. But I'm sorry to tell you that your system is not exactly simple. Big, yes, but simple? Still, in your case, more NEM credit would make a larger credit balance for PG&E to zero out at true-up.

In the context of the NEM3 proposal, I think it is important for folks to understand that utilities benefit from customers using batteries, with or without solar. The economics of buying batteries are not great, so I think anything CPUC can do to facilitate residential batteries would help a lot. NEM3 as proposed would stop solar and batteries too by spoiling the ROI.

SW
Getting like 10 cents on the dollar back from PGE, is for me, not worth dealing with battery charging levels.

And I like the comment that one is limited on exports to what PGE has calculated, and seems this is only solar. I have gotten close to the export limit just with my solar. So grid charging batteries and sending back might actually give me a net zero, so if so, why cycle the batteries and deal with the hassles?
 
this probably is not the right place to post, but wasn't sure where it should go
Did this study even see if PG&E had lowered its rates? Not the slightest bit

So utilities and their shareholders are getting rich off of Tesla drivers? Not quite: Since utilities are highly regulated and revenue-capped, they need to return excess profits to their customers in the form of lower rates. (In California and some other states, this is done through a mechanism called "revenue decoupling.")

 
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this probably is not the right place to post, but wasn't sure where it should go
Did this study even see if PG&E had lowered its rates? Not the slightest bit

So utilities and their shareholders are getting rich off of Tesla drivers? Not quite: Since utilities are highly regulated and revenue-capped, they need to return excess profits to their customers in the form of lower rates. (In California and some other states, this is done through a mechanism called "revenue decoupling.")



I dunno man, when California's grid was about to collapse on itself this Summer, my social feeds were bombarded with examples of EV drivers charging around 5pm. So the folks that like to post dumb-azz anti-Biden and anti-Obama memes were snarking about blaming EVs for loading the grid at the worst time causing all of us to suffer greatly.

I doubt this article will convince an anti-EV-person that overall EVs actually help the grid by distributing the volumetric pricing across a lot more off-peak MWh.
 
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I dunno man, when California's grid was about to collapse on itself this Summer, my social feeds were bombarded with examples of EV drivers charging around 5pm. So the folks that like to post dumb-azz anti-Biden and anti-Obama memes were snarking about blaming EVs for loading the grid at the worst time causing all of us to suffer greatly.

I doubt this article will convince an anti-EV-person that overall EVs actually help the grid by distributing the volumetric pricing across a lot more off-peak MWh.
I just don't see PG&E or any other utility reducing rates
 
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Lol this article showed up in my news feed (probably because it has the word "disconnect" in it).


What's weird is the above link references $1.2 Bn of "energy bill relief" for unpaid energy bills, but that above article doesn't explain this $1.2Bn at all lol. According to that article only $219 mm of the $1.2 Bn goes to PG&E customers.

So to learn what is this $1.2 Bn or $219 mm, you have to read this: California Distributed $1.4 Billion in Utility Bill Relief for 2.2 Million Households | California Governor

"We got $1.4 billion out the door to help 2.2 million families with overdue utility bills and we’re sending another $1.4 billion to support those who are still struggling amid rising costs,” said Governor Newsom."

Please tell me if rate payers only got a few hundred million, then where did the rest go?
 
Looks like the second PD was mostly followed, and the vote happens tomorrow on the final version.

Some big wins for residential solar:
No Solar Tax
No retroactive changes to NEM 1 and 2
Also some EDIT: not terrible things for commercial solar that we will all read about, assuming it is all finalized tomorrow as written.
 
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