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CPUC NEM 3.0 discussion

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I agree with what you're saying completely; that every day people invest in things for personal gain.

But playing devil's advocate here for a second, remember that there is a growing-grumble that rich fat-cat EV drivers are not paying their fair share of maintenance of public roadways and infrastructure.

It's the same argument that PG&E uses for the grid, but now you have equity rights groups saying EV drivers are not paying a fair share of excise taxes (state and federal) that help with road maintenance and new construction. Things like Senate Bill 1 are in the ~$0.70 per gallon that "poor petrol powered people pay at the pump."

You can see how quickly the class warfare argument can spread from NEM 3.0 having a fixed kW fee on solar into a property tax on EV's on a per kW basis as well. If the industry (solar and EV) cannot effectively figure out how to contribute to these equity programs, then lawmakers typically come in very aggressive changes like what we're seeing under NEM 3 to force the issue.
I don't have an EV currently, but I will in the 1-3 years and everyone will in 20-30 years. If we are going to fund (partially) road infrastructure through usage fees then EVs must be taxed as well. My preference would be on miles driven versus a flat vehicle fee. If the gas tax is $0.70/gallon and the average MPG is 20 then the EV tax would be $0.035/mile. IMHO, this isn't class warfare just applying the existing taxation model in a similar way.

Now, when we get to flying electric cars that aren't using the road infrastructure that would be very different situation.
 
I don't have an EV currently, but I will in the 1-3 years and everyone will in 20-30 years. If we are going to fund (partially) road infrastructure through usage fees then EVs must be taxed as well. My preference would be on miles driven versus a flat vehicle fee. If the gas tax is $0.70/gallon and the average MPG is 20 then the EV tax would be $0.035/mile. IMHO, this isn't class warfare just applying the existing taxation model in a similar way.

Now, when we get to flying electric cars that aren't using the road infrastructure that would be very different situation.


Yeah, so taking that analogy a bit back to NEM 3.0... how do you see the CPUC coming up with a "fair" way to cover the old transit/fixed-cost fees for the Grid that likely were under-represented in NEM 2.0?

Put that idea in your public comment and send it to the SEIA/CALSSA hah. Those groups have thus far failed to come up with a reasonable appeal for how future solar homeowners will "pay their fair share."

We're in this mess because the solar rights groups have been unable to get through to the CPUC that there is a way to be fair for all without knee-capping the residential solar market in California.

PS, how do you see people paying your $0.035/mile fee to the state/fed? Like could Tesla "meter" your mileage and then bill you periodically to pass that $ back to the government?
 
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I don't have an EV currently, but I will in the 1-3 years and everyone will in 20-30 years. If we are going to fund (partially) road infrastructure through usage fees then EVs must be taxed as well. My preference would be on miles driven versus a flat vehicle fee. If the gas tax is $0.70/gallon and the average MPG is 20 then the EV tax would be $0.035/mile. IMHO, this isn't class warfare just applying the existing taxation model in a similar way.

Now, when we get to flying electric cars that aren't using the road infrastructure that would be very different situation.
CA clearly doesn't use their gas tax on infrastructure. The roads around here have massive potholes that go unfixed for long periods of time.
Who do you think that hurts the most? I have good tires and can afford to have my vehicle's alignment fixed if it needs it. Many vehicles I see taking field workers around on the other hand are one bad jolt away from being on the side of the road.
 
CA clearly doesn't use their gas tax on infrastructure. The roads around here have massive potholes that go unfixed for long periods of time.
Who do you think that hurts the most? I have good tires and can afford to have my vehicle's alignment fixed if it needs it. Many vehicles I see taking field workers around on the other hand are one bad jolt away from being on the side of the road.


Don't worry, politicians and equity groups have already started blaming EV drivers for why poor people have to suffer busted roads with lots of potholes. How much kW is a Model 3 Performance? 336?


I like redhill_qik's idea of a per-mile fee for EVs. The tough part is implementing a way to start collecting that "fair" assessment soon. Instead of waiting until 2026 when some angry lawmaker wants to make a big splash by demanding a 336 x $8 = $2,688 EV property tax since $8 is the magic number pulled out of their azz.
 
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Yeah, so taking that analogy a bit back to NEM 3.0... how do you see the CPUC coming up with a "fair" way to cover the old transit/fixed-cost fees for the Grid that likely were under-represented in NEM 2.0?
As I said earlier, it is either a flat fee for all accounts based on your service type with an allowance for CARES or distribution costs are made NBCs.
PS, how do you see people paying your $0.035/mile fee to the state/fed? Like could Tesla "meter" your mileage and then bill you periodically to pass that $ back to the government?
My understanding is that this is being done in some places. Usually it is a self report that with under reporting "trued-up" when a vehicle changes owners. In California this could also be done as part of the bi-annual smog test with the tester including the mileage which I think may already be noted. Having a car automatically report the miles driven I think would create fear and backlash.

Some people do select insurance plans that require an in vehicle dongle that tracks your usage, so some would be ok with this. Offering a discount for auto-reporting like with the toll tags versus license plate reader with pay-thru-mail would encourage people to do this.
 
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As I said earlier, it is either a flat fee for all accounts based on your service type with an allowance for CARES or distribution costs are made NBCs.

The CPUC did not accept that type of proposal in the early proceedings on NEM 3 (flat fee based on PG&E service size). The $8 per kW per month is a "NBC" that the CPUC thinks is fair after the IOUs educated everybody about the importance of higher NBCs under NEM 3.

I like that EV self reporting idea with a true up at time of sale or disposition. Please write your local rep and propose that! BTW, there is no smog test for EVs heh.

Edit, the dongle-insurance-reporting thing is illegal in California. I asked my insurance agent why I see ads all the time for the "safe drivers save BLAH BLAH" ads, but then I can't participate in California. He said the tracking and data collection through the OBD for insurance purposes is illegal. He doesn't know why all the major carriers advertise those stupid dongles and apps in Nationwide ads that hit the California market.
 
Time to do some quick math:

A Tesla 4.8KW solar array with 2 PW after incentives: $21,000
Production of said solar array over 20 years: 4.8 x 1500 KWh/year/KW x 20 years = 144,000 KWh
Cost per KWh over 20 years : ~$0.15/KWh (yes, I don't take into account the time value of money or any repair that may occur)
Total monthly fees over 20 years: $8 x 4.8 x 20 x 12= $9,216 (and that fee will go up....)
Total fixed per KWh over 20 years: 9,216/144000 = ~$0.06

So, the above system will cost the homeowner $0.21 per KWh. If owner can basically self consume the entire production over 20 years, the saving will be $0.04c per KWh (again quick and dirty, because PG&E will raise prices over time). If owner sends back a third of their production, cost will be: (0.25 - 0.21) x 2/3 - (0.21 - 0.05) x 1/3 = -$0.01 / KWh. So, now total cost per KWh will $0.22/KWh.

Please feel free to play with my math and assumptions above, but it seems to me that solar + batteries is just not worth it under NEM3. Results would be better with a larger array, but clearly the ROI won't be there. Results may not be that much better with pure solar since the ability to consume your own production is much lower. Either way, I don't know why anybody would sign up for NEM3 unless they're forced into it by the solar requirement on new houses. IOUs win.
 
Time to do some quick math:

A Tesla 4.8KW solar array with 2 PW after incentives: $21,000
Production of said solar array over 20 years: 4.8 x 1500 KWh/year/KW x 20 years = 144,000 KWh
Cost per KWh over 20 years : ~$0.15/KWh (yes, I don't take into account the time value of money or any repair that may occur)
Total monthly fees over 20 years: $8 x 4.8 x 20 x 12= $9,216 (and that fee will go up....)
Total fixed per KWh over 20 years: 9,216/144000 = ~$0.06

So, the above system will cost the homeowner $0.21 per KWh. If owner can basically self consume the entire production over 20 years, the saving will be $0.04c per KWh (again quick and dirty, because PG&E will raise prices over time). If owner sends back a third of their production, cost will be: (0.25 - 0.21) x 2/3 - (0.21 - 0.05) x 1/3 = -$0.01 / KWh. So, now total cost per KWh will $0.22/KWh.

Please feel free to play with my math and assumptions above, but it seems to me that solar + batteries is just not worth it under NEM3. Results would be better with a larger array, but clearly the ROI won't be there. Results may not be that much better with pure solar since the ability to consume your own production is much lower. Either way, I don't know why anybody would sign up for NEM3 unless they're forced into it by the solar requirement on new houses. IOUs win.


I think you meant to put a + before the (0.21 - 0.05) x 1/3.

But you've basically hit the nail on the head that having a significant portion of your solar not be self-consumed will destroy the ROI. That is why the IOUs only want systems that are sized to like 50% of annual consumption; that way your 2/3 is more like 3/3.

BTW, on top of the $8/kW/month access fee in NEM 3, I think there are still ~$0.03 per kWh NBC's to cover the things similar to what you saw in NEM 2.

I agree with your general premise though; I don't think a reasonable homeowner is going to get a breakeven. Which is why I can't figure out how the IOU calculator works for systems sized to 100%+. They keep insisting their proposal is still "fair" and would not discourage net-zero emissions. Makes no sense to me.
 
Is that really a common ratio? 1PW per 2.5kW of solar? Obviously more solar per PW is going to yield a lower cost per kWh.


I think his example needs 2 PW's to give some reasonable mechanism to self-consume 2/3 and export 1/3. If the example only had 1 PW, it'd be self consuming more like 1/3 and exporting 2/3. Which likely cannot overcome that $8/month grid benefit charge at all since the ACC rate is peanuts.
 
Somebody smarter than me can do the math of the breakeven point of how much a PW costs vs how much more self consumption it allows.


FWIW, my system is 6.7 kW with 3 Powerwalls. This is about a 40% bigger system than your example.

Based on Tesla's solar production data and PG&E greenbutton data on my exports, I've sent 1/3 of my solar production to the grid. Which should mean I self-consumed 2/3.

I think your math is pretty close (in my experience n = 1 lolz) to the distribution of self-consumption and export for your math assuming a smaller solar and only 2 PWs.

But yeah, I'd like to see what is the calculation for the ROI maximizing number of ESS under the latest NEM 3.0 proposal for a given solar production forecast. I still can't get anything close to the ROI's that the CPUC/IOU are claiming.
 
Time to do some quick math:

A Tesla 4.8KW solar array with 2 PW after incentives: $21,000
Production of said solar array over 20 years: 4.8 x 1500 KWh/year/KW x 20 years = 144,000 KWh
Cost per KWh over 20 years : ~$0.15/KWh (yes, I don't take into account the time value of money or any repair that may occur)
Total monthly fees over 20 years: $8 x 4.8 x 20 x 12= $9,216 (and that fee will go up....)
Total fixed per KWh over 20 years: 9,216/144000 = ~$0.06

So, the above system will cost the homeowner $0.21 per KWh. If owner can basically self consume the entire production over 20 years, the saving will be $0.04c per KWh (again quick and dirty, because PG&E will raise prices over time). If owner sends back a third of their production, cost will be: (0.25 - 0.21) x 2/3 - (0.21 - 0.05) x 1/3 = -$0.01 / KWh. So, now total cost per KWh will $0.22/KWh.

Please feel free to play with my math and assumptions above, but it seems to me that solar + batteries is just not worth it under NEM3. Results would be better with a larger array, but clearly the ROI won't be there. Results may not be that much better with pure solar since the ability to consume your own production is much lower. Either way, I don't know why anybody would sign up for NEM3 unless they're forced into it by the solar requirement on new houses. IOUs win.
Plugging in my situation to your scenario

11 kW PV with 3 PW after incentives: 47,500
Production: 11 x 1500 kWh/year/kW x20 = 330,000 kWh
(BTW, in 2021 my PV system underperformed this calculation by 2k kWh and in 2022 we are still about 1500 kWh under))
Cost per kWh over 20 years: ~$0.14/kWh
Total monthly fees over 20 years: $8x11x20x12 = $21,120
Total fixed per kWh over 20 years: 21,120/330,000 = $0.064
Cost per kWh = $0.204


If ESS is included in the calculation:

11 kW PV with 3 PW after incentives: 47,500
Production: 11 x 1500 kWh/year/kW x20 = 330,000 kWh
Cost per kWh over 20 years: ~$0.14/kWh
Total monthly fees over 20 years: $8x26x20x12 = $49,920
Total fixed per kWh over 20 years: $49,920/330,000 = $0.151
Cost per kWh = $0.291
 
Plugging in my situation to your scenario

11 kW PV with 3 PW after incentives: 47,500
...
Cost per kWh = $0.204


If ESS is included in the calculation:
...
Cost per kWh = $0.291


I cannot imagine a pragmatic scenario where it was the CPUC's intent to charge the $8/kW/month fee for the battery export size on the nameplate.

But at the same time, they didn't put clear language that says the $8/kW would only be applied to the portion of the "system" that was generating energy (eg solar, natural gas, biomass, etc).

I really hope someone who buys a new house with an identical system as your example but under NEM 3.0 does not get hit with the second calculation.
 
Hand slap to the forehead on that one! I guess we turn all of the smog check stations that are no longer needed into mileage check stations with the same two year requirement if you don't have the car auto report.
Please don't suggest that, I could honestly see the government coming up with some similar idea. I can see it now, going to dmv every 2 years so they can check the odometer. :oops:
 
I cannot imagine a pragmatic scenario where it was the CPUC's intent to charge the $8/kW/month fee for the battery export size on the nameplate.

But at the same time, they didn't put clear language that says the $8/kW would only be applied to the portion of the "system" that was generating energy (eg solar, natural gas, biomass, etc).

I really hope someone who buys a new house with an identical system as your example but under NEM 3.0 does not get hit with the second calculation.
Even the first calculation would be crippling to the ROI of the system.

Here's my first full year NEM true up.
1639684551515.png

I'd have to go back and look at every month's statement to confirm, but I'm pretty confident that we never drew from the grid during peak times.
Tesla App says calendar year PV generation was 14,900 kWh. According to this I paid $0.37 / kWh for my net grid draw.
 
since $8 is the magic number pulled out of their azz.
I think Wayne Whitney already posted the math that shows that $8*12 = $96 is quite close to the expected value of exporting all of the generated power from a well-sited 1kW array. In other words, the $8 monthly fee just offsets the possible exported power, assuming the proposed $0.05/kWh is a good average. So I think they want to minimize anybody using the grid as their seasonal storage battery, and so $8/kW isn't at all arbitrary.

In my situation (I removed a gas furnace to install a heat pump, and we have minimal AC consumption in summer) NEM3 would be a clear money loser. As it is under NEM2, I can bank enough solar in May-October to heat the house in the winter at only the cost of NBCs. If I were facing a NEM3 agreement, I'm pretty sure that we would have not installed solar.
 
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