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CPUC NEM 3.0 discussion

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I did the math for heat pump heating at my house and estimate I would need an additional 7-9 MWH of energy to produce the 50 MMBTU that I would need during heating season with a COP of 2-2.5. With PG&E rates it would be almost the same cost as propane, not counting the significant cost to switch from propane furnaces to heat pumps. If I had a bunch of extra solar like H20 it would make sense but I don't.
If I had not had the accident to my house, I never would have changed to heat pumps, way too much money, BUT, sure love the zone and 70 degree temps now
 
I did the math for heat pump heating at my house and estimate I would need an additional 7-9 MWH of energy to produce the 50 MMBTU that I would need during heating season with a COP of 2-2.5. With PG&E rates it would be almost the same cost as propane, not counting the significant cost to switch from propane furnaces to heat pumps. If I had a bunch of extra solar like H20 it would make sense but I don't.
COP of 2-2.5 is pretty awful. Heat pumps are way better than that nowadays.
 
A COP of 3 would still be 5 MWH. What is a good COP for an air source heat pump these days?
In your area, you should be able to find options at three or better, easily. In general, you can convert the more commonly quoted HSPF to COP by dividing by 3.412 SEER, COP and HSPF - GreenBuildingAdvisor

The DOE database lists several heat pumps with HSPFs at 15.2, or a COP of 4.4

Bear in mind that technically the COP for heating is different than the COP for cooling. In general, COP is only computed for heating.
Understanding COP: Coefficient Of Performance Of Heat Pumps
(there is a typo on the maximum possible COP under standard conditions, which should be 14.67)

All the best,

BG
 
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We have a few years old Carrier 20.5 SEER/13.0 HSPF (~COP 3.8) central ducted air-source heat pump. Subsequently later models may do a bit better. Of course all the caveats of matching air handling equipment to get this maximum SEER/HSPF apply...

Mini-splits are available that do COP >4.

Our house is ~2550 sqft, typically set cooling to 77-78°F and for heat to 69°F. Used 1520 kWh to cool the house and 1874 kWh to heat the house for 2021.
 
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Florida has implemented a $25 minimum monthly charge:

This would be an interesting approach for NEM 3. A minimum monthly charge could be set that would have no impact on the majority of non-solar households. On the surface the CPUP could claim it is fair because it is the same for everyone. In reality it would be a regressive "tax" on solar owners whose systems are large enough that they have small or no bills during during some months.

I'm not saying I think it is a good idea, I just think it might be an approach that the CPUC could float as politically correct and still make large solar owners pay more for the grid. The best way is to have a monthly connection fee for everyone.
 
I did the math for heat pump heating at my house and estimate I would need an additional 7-9 MWH of energy to produce the 50 MMBTU that I would need during heating season with a COP of 2-2.5. With PG&E rates it would be almost the same cost as propane, not counting the significant cost to switch from propane furnaces to heat pumps. If I had a bunch of extra solar like H20 it would make sense but I don't.
It is probably in the slightly below break-even range, but I did it in order to lower my personal GHG emissions. And I can always add PV. There are some external benefits outside of cost.
 
Florida has implemented a $25 minimum monthly charge:

This would be an interesting approach for NEM 3. A minimum monthly charge could be set that would have no impact on the majority of non-solar households. On the surface the CPUP could claim it is fair because it is the same for everyone. In reality it would be a regressive "tax" on solar owners whose systems are large enough that they have small or no bills during during some months.

I'm not saying I think it is a good idea, I just think it might be an approach that the CPUC could float as politically correct and still make large solar owners pay more for the grid. The best way is to have a monthly connection fee for everyone.
Increasing the minimum monthly bill makes sense from the current minimums in most of California, IMO. Other utilities like water/sewer service do the same thing - for water service you pay a minimum based on the size of your meter, then additional monthly based on your usage.

This has been proposed as a solution for NEM as well. It also would have the benefit of reducing the incremental cost of electricity, so your cost per kWh would go down. This is important as the push for electrification goes forward which will drive electricity usage higher as more EVs, electric stoves and heat pumps for heating water and buildings are installed.

From a pure cost perspective, it doesn't make sense to replace gas appliances with heat pumps, but from an environmental perspective, it is imperative that we do.

IMO $25 is too high - I think the proposed minimum monthly bill that was mentioned earlier was < $10 / month, which is probably a good place to start.

Similarly, I believe that the way that utility climate credits are implemented are effectively a negative monthly fee. These credits should be refactored in another way so that it doesn't artificially raise the price of electricity by the kWh, but I haven't thought about it enough to come up with a good solution.
 
Increasing the minimum monthly bill makes sense from the current minimums in most of California, IMO. Other utilities like water/sewer service do the same thing - for water service you pay a minimum based on the size of your meter, then additional monthly based on your usage.

...

IMO $25 is too high - I think the proposed minimum monthly bill that was mentioned earlier was < $10 / month, which is probably a good place to start.

I think this is where the pro-solar folks kind of fumbled the ball in the negotiations with the CPUC. The pro-solar crew made a concession similar to yours where they felt some increased minimum monthly cost was reasonable for NEM 3.0 to cover fixed costs. After all, the pro-solar folks thought the cost shift issue became something they had to help remedy. Groups like the Sierra Club, / CALSSA / SEIA wanted to try and meet in the middle/compromise. And that's where they got boned. Being a team player in a negotiation = getting rekt.

The problem is the pro-solar groups don't actually know what is fair. The CPUC wouldn't go on a "hunch" here. The Sierra Club proposed a $14 per month fixed cost fee. And you're saying $25 a month? fuggedaboudit. These are made up numbers according to the IOUs.

The CPUC agreed and demanded proof of what is a fair "grid benefits charge". To determine what is fair, the CPUC turned to the IOU's. I mentioned earlier that G Morien became the "IOU expert" to provide what is a fair interconnect per month NBC for a solar customer to pay. And here's the snippet from the formal Joint IOU submission. Note the fee is per kW DC (not AC!). All of the supporting materials and spreadsheets were uploaded and available for download somewhere, but I'll be damned if I can find that link again.

1654636281775.png


Also, keep in mind the IOUs felt this proposal was LOW. The Joint IOUs added that their proposal didn't account for the "TOU peak" true cost. The IOUs said that the GBC should be higher if the CPUC wanted the solar customer to "pay their fair share" of the peak time grid benefit. In that case, the column on the right in the below slide deck snippet would come into play (again, $ per month per kW DC).

1654636650759.png


The CPUC balked at this, and instead "compromised" at $8 kW per month AC. So a 5 kW AC system was paying $480 per year. And of course, the CPUC thought this was "fair" since it's walking down from the Joint IOU proposal.

I think, had this been the only major concession in the NEM 3.0 proposal, maybe we'd be ok and solar would still make some reasonable economic sense for a residential homeowner. But of course the Joint IOUs also convinced the CPUC that residential solar had cratered the value of solar (ugh). And with this second issue, the CPUC accepted the "avoided cost calculator" rate for energy exports instead of the current TOU/retail NEM,

So here's the rub... this means the NEM 3.0 PD to me makes no economic sense* at all to have the system be able to export solar to the grid. It effectively means no NEM is better than NEM 3.0. Does the CPUC care? Nope.

* I'll @miimura and @Redhill_qik who you know have analyzed their NEM 2.0 bills (still waiting for the TED talk guys)... Take your systems as you know them today (which are combined PV + ESS). But make these assumptions on an annual NEM calc spreadsheet:

1) Slap on the $8 / month / AC monthly fixed cost as an NBC
2) Replace the value of exports with the ACC rate instead of the existing TOU retail rate. Edit: I used PG&E Zone X myself, but you guys can do whatever.
3) For fairness, remove the NEM 2.0 NBC (that $0.026 per kWh thing that made me want to barf in the other thread)
4) Assume the same imported energy cost as today (don't use the +18% to +25% rate increase in the latest GRC).

With these changes... can you make the math work? Every time I run my numbers, I'm better off just making a solar + ESS system with these proposed rules "NEM-less" (simply only use the solar +ESS as a means to reduce on-site loads but never actually net meter with the grid).
 
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Someone from a ratepayer advocacy group or solar industry needs to spend some serious time and effort to play the IOU's game with the CPUC. They need to attack the basis of the Grid Benefits Charge and the Avoided Cost Calculator. I have a suspicion that there are some bad assumptions in there somewhere that are leading to these bad outcomes.
 
Someone from a ratepayer advocacy group or solar industry needs to spend some serious time and effort to play the IOU's game with the CPUC. They need to attack the basis of the Grid Benefits Charge and the Avoided Cost Calculator. I have a suspicion that there are some bad assumptions in there somewhere that are leading to these bad outcomes.

They already have...

The IOUs are using an average solar array size of 5 kW (ignore AC or DC for a minute). So this would be about $50 worth of GBC per month. Since solar is usually for detached homes (VNEM and other congregate solar aggregation has separate fees), the IOUs showed how it costs on average $50 a month to have that detached home grid tied without solar. Pre-solar that home may be paying $100 a month for electricity; of which 50% is generation and 50% is transmission ($50).

The IOUs think it's "fair" to recoup the $50... so they thought the ~$10 per kW per month rate was fair. They still wanted this fee to be "volumetric" (volume based on the size of the solar array) to avoid penalizing smaller systems. A cost-shift-within-a-cost-shift if you will. The IOUs insist up and down that as long as you're grid tied, then you owe ~$50 on average per month. Period. The CPUC thought $40 per month ($8 x 5 kW) was more reasonable, but the CPUC will no longer entertain anything like Dave EV's $25 per month.

The ACC is broken because it doesn't account for the impact of the PPAs* that go into paying for the CAISO's network of generators. The ACC shows the problem... basically solar being generated at noon has almost no contemporaneous value at that time. The ACC shows we have too much solar capacity in California. What the ACC fails to do is actually assign blame.

Of course the IOUs placed the blame on rooftop solar for the problem. And the pro-solar folks have tried to blame the over-production of commercial solar. It was ruled that the NEM 3.0 proceeding isn't here to address how commercial projects are funded and subsidized. So NEM is being asked to address the solar over-production. Sorry CALSSA... the IOUs say you are the problem; and the CPUC agrees residential solar is part of the problem. So, the CPUC's NEM 3 PD will discourage solar-only installs by design.

The CPUC will address the future commercial scale renewables projects by requiring ESS paired with the generation on those projects.


* If you care... here's my take on PPAs:

The IOUs have PPAs that guarantee a certain level of revenue for the generators, so they're able to get their Fitch/Moody's credit ratings really nice on their projects. Gets their borrowing costs really low and almost guarantees them an IRR as long as they don't screw it up. As long as the generators can build the generating facility, the IOU's will take energy from the generator at that locked in rate. This may not be for 100% of the generation, but it's enough to make the project a mostly safe bet as long as it stay son budget. And since PG&E is "too big to fail", the PPAs encourage a lot of companies to get in line and get lots of projects going. Sounds good on paper, until the planning is effed up and there is too much generation.

When PG&E was in their bankruptcy, the FREC tried to actually get authority to unwind some of the crap PPAs, but of course they were overruled.

So ... it's true that PG&E doesn't pass their IOU monopoly ~10% ROE into the rates they charge homeowners to get access to the energy generation. PG&E loves to tell ratepayers that they make zero money on generation. But what they don't mention is how the PPA bidding process is highly incestuous. Ratepayers are subventing the returns of these generating facilities by forcing the IOU to purchase that power at exorbitant rates (that of course are being passed on to ratepayers). The IOUs insist this is the only way to get the independent generators to actually build their projects and make a reliable grid.

Since it's a patchwork of people all wanting to get to the trough, you have generators sunsetting early while you have generators trying to clamor to get online faster. But it's all independent and well run! (subsidized by the PPAs of course). To me, it's just another reason to try and self-generate at the endpoint usage rather than the continued reliance on the centralized power-grab that has too many ways to grift.

 
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If the IOUs get a guaranteed cost plus 10% on their capital projects, shouldn't also be the case that roof top solar should be rewarded to the investors at similar rates? I.e. 10%/yr for the life of the array, 20 years, by which time it is full depreciated and can be removed from service. Subtract from that IOU to solar owner payment the grid related charges.
 
I think this is where the pro-solar folks kind of fumbled the ball in the negotiations with the CPUC. The pro-solar crew made a concession similar to yours where they felt some increased minimum monthly cost was reasonable for NEM 3.0 to cover fixed costs. After all, the pro-solar folks thought the cost shift issue became something they had to help remedy. Groups like the Sierra Club, / CALSSA / SEIA wanted to try and meet in the middle/compromise. And that's where they got boned. Being a team player in a negotiation = getting rekt.

The problem is the pro-solar groups don't actually know what is fair. The CPUC wouldn't go on a "hunch" here. The Sierra Club proposed a $14 per month fixed cost fee. And you're saying $25 a month? fuggedaboudit. These are made up numbers according to the IOUs.

The CPUC agreed and demanded proof of what is a fair "grid benefits charge". To determine what is fair, the CPUC turned to the IOU's. I mentioned earlier that G Morien became the "IOU expert" to provide what is a fair interconnect per month NBC for a solar customer to pay. And here's the snippet from the formal Joint IOU submission. Note the fee is per kW DC (not AC!). All of the supporting materials and spreadsheets were uploaded and available for download somewhere, but I'll be damned if I can find that link again.

View attachment 813861

Also, keep in mind the IOUs felt this proposal was LOW. The Joint IOUs added that their proposal didn't account for the "TOU peak" true cost. The IOUs said that the GBC should be higher if the CPUC wanted the solar customer to "pay their fair share" of the peak time grid benefit. In that case, the column on the right in the below slide deck snippet would come into play (again, $ per month per kW DC).

View attachment 813864

The CPUC balked at this, and instead "compromised" at $8 kW per month AC. So a 5 kW AC system was paying $480 per year. And of course, the CPUC thought this was "fair" since it's walking down from the Joint IOU proposal.

I think, had this been the only major concession in the NEM 3.0 proposal, maybe we'd be ok and solar would still make some reasonable economic sense for a residential homeowner. But of course the Joint IOUs also convinced the CPUC that residential solar had cratered the value of solar (ugh). And with this second issue, the CPUC accepted the "avoided cost calculator" rate for energy exports instead of the current TOU/retail NEM,

So here's the rub... this means the NEM 3.0 PD to me makes no economic sense* at all to have the system be able to export solar to the grid. It effectively means no NEM is better than NEM 3.0. Does the CPUC care? Nope.

* I'll @miimura and @Redhill_qik who you know have analyzed their NEM 2.0 bills (still waiting for the TED talk guys)... Take your systems as you know them today (which are combined PV + ESS). But make these assumptions on an annual NEM calc spreadsheet:

1) Slap on the $8 / month / AC monthly fixed cost as an NBC
2) Replace the value of exports with the ACC rate instead of the existing TOU retail rate. Edit: I used PG&E Zone X myself, but you guys can do whatever.
3) For fairness, remove the NEM 2.0 NBC (that $0.026 per kWh thing that made me want to barf in the other thread)
4) Assume the same imported energy cost as today (don't use the +18% to +25% rate increase in the latest GRC).

With these changes... can you make the math work? Every time I run my numbers, I'm better off just making a solar + ESS system with these proposed rules "NEM-less" (simply only use the solar +ESS as a means to reduce on-site loads but never actually net meter with the grid).
Might want to put the solar +ESS in self consumption to limit grid exports, to be fair.
 
If the IOUs get a guaranteed cost plus 10% on their capital projects, shouldn't also be the case that roof top solar should be rewarded to the investors at similar rates? I.e. 10%/yr for the life of the array, 20 years, by which time it is full depreciated and can be removed from service. Subtract from that IOU to solar owner payment the grid related charges.


Lol I like the way you think, but your proposal is like so far away from the NEM 3.0 PD it's kind of sad to contemplate.

The IOUs argued that SolarCity, Sunrun, and other solar providers usually enter into 20 year PPAs. So, the IOUs fought to bring into scope that a lifecycle for a residential system is thus at least 20 years. Since the whole cost-shift became the main topic to resolve, the argument is that any incremental return (positive ROI) from a rooftop residential solar system is coming from other rate payers. And thus, the positive ROI is the cost shift.

Nowhere in any law/statute/bribery-agreement does it say BGbreeder gets a 10% ROE. So those supporting "NEM reform" believe abnormal ROI for BGbreeder is the same as theft from other ratepayers.

The CPUC eventually arrived at the notion that a reasonable breakeven/payback for a 100% sized solar system in the PG&E and SCE customers (that is, breakeven... not a positive ROI) is 10 to 17 years. But, the smaller solar systems would have a shorter payback, so this was a way to encourage smaller solar systems.
1654708190387.png


Another problem is the Investment that is modelled in this Return On Investment payback model. The CPUC is using a value from the government agency NREL. CALSSA could not understand the NREL's estimate, and they definitely cannot match it in practice. For funsies, go out and try to get a quote for a PV + ESS system at these $ per watt values (before the ITC).

1654708739692.png

1654708813949.png


Maybe @Vines can ask his sales-manager how close these estimates are to reality. Make sure the installer knows you're trying to over-size your ESS by 30% to account for losses during the useful life of the system. You'll get laughed out the door.

CALSSA and SEIA members built their own model and tried to show the CPUC how the breakeven in the NEM 3.0 PD would often hit 20 years (or sometimes never break even at all). They used real ratepayer bills/usage and their actual costs to install as businesses providing rooftop solar. They found 95% of prospective customers would not purchase such a system with the NEM 3.0 PD.


CPUC simply doesn't care. They know what the NEM 3.0 PD would mean to residential solar installs. They want this outcome. The CPUC knows no NEM (put your solar + ESS in self consumption only) is better than their NEM 3.0 PD.
 
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I did NOT suggest anywhere close to $25/month. $25/month is WAY TOO HIGH.


Yeah sorry it was Florida that went with $25 and you said it was too high. Maybe their grid charge is $25 down there. California has a much more corrupt and deadly grid so it's double here lol.

I still think it's stupid the CPUC asked the IOUs to tell them what is a fair grid benefits charge.

But the same CPUC didn't ask CALSSA what is a reasonable retail cost to install residential solar and batteries. I think the NREL is using the initial quote-cost for solar, which is before all the extra costs that creep in like new load centers, lift and shifts, bollards, and fun blade disconnects.
 
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Lol in todays inflation and CPI report…

Energy prices broadly rose 3.9% from a month ago, bringing the annual gain to 34.6%. Within the category, fuel oil posted a 16.9% monthly gain, pushing the 12-month surge to 106.7%.

And when we want to get solar to power our homes and charge our EV’s the IOU’s say we’re the problem. And the CPUC agreed.
 
For you TMC nerds; the comments sought by the NEM 3.0 proceeding are rolling in. This gives you some insight into the ideas that may make their way into the next NEM 3.0 PD.

The ACC rate on exports is basically a shoe-in at this point. The discussions are on the glide path; not on the result. The glide path proposals are all confusing as hell; which as we've learned anything that confuses is worse than having nothing at all lol.

But on the The fixed costs / NBC topic ... the CPUC is exploring a behind-the-meter-meter (har). This will allow NBCs to be assessed on the entire home's gross consumption rather than what is just imported. Plus, the NEM 3.0 NBC would increase to cover more types of costs (see below).

Here's the proposed NBC (at today's rates) that the CalAdvocates are proposing. Instead of paying $0.026 for imported kWh, a homeowner would pay potentially $0.05 on every kWh consumed on the home. So a home that uses 12,000 kWh per year will pay about $50 a month of NBCs. This is this better than just slapping $8 per kWp AC as a flat fee I guess?
1655224542305.png


For those NEM 1.0 people that peel off and land in NEM 3.0, that'd be so annoying lol. They'll have to have a new meter installed with this proposal.



I still think "no NEM" is better than the NEM 3.0 PD or this revised "Behind the meter meter" on Gross Consumption. I dropped in my home's 2021 experience in my model (edit: my hypothetical NEM 3.0 model) ... but I replaced the $8 per month per kWp AC with a $0.05 per gross kWh fixed cost NBC.

Again, I come to the conclusion that I'd rather just have a non-exporting system (no NEM) and simply use the solar+ESS to reduce site loads. I'm still awaiting what @Redhill_qik and @miimura and @wwhitney come up with to tell me what I'm missing. And of course the payback is non-existent in these scenarios. But at least I'm greener? I don't know why I always end up with the conclusion that NEM 3.0 is worse than no-NEM. What am I missing?
 
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For you TMC nerds; the comments sought by the NEM 3.0 proceeding are rolling in. This gives you some insight into the ideas that may make their way into the next NEM 3.0 PD.

The ACC rate on exports is basically a shoe-in at this point. The discussions are on the glide path; not on the result. The glide path proposals are all confusing as hell; which as we've learned anything that confuses is worse than having nothing at all lol.

But on the The fixed costs / NBC topic ... the CPUC is exploring a behind-the-meter-meter (har). This will allow NBCs to be assessed on the entire home's gross consumption rather than what is just imported. Plus, the NEM 3.0 NBC would increase to cover more types of costs (see below).

Here's the proposed NBC (at today's rates) that the CalAdvocates are proposing. Instead of paying $0.026 for imported kWh, a homeowner would pay potentially $0.05 on every kWh consumed on the home. So a home that uses 12,000 kWh per year will pay about $50 a month of NBCs. This is this better than just slapping $8 per kWp AC as a flat fee I guess?
View attachment 816495

For those NEM 1.0 people that peel off and land in NEM 3.0, that'd be so annoying lol. They'll have to have a new meter installed with this proposal.



I still think "no NEM" is better than the NEM 3.0 PD or this revised "Behind the meter meter" on Gross Consumption. I dropped in my home's 2021 experience in my model... but I replaced the $8 per month per kWp AC with a $0.05 per gross kWh fixed cost NBC.

Again, I come to the conclusion that I'd rather just have a non-exporting system (no NEM) and simply use the solar+ESS to reduce site loads. I'm still awaiting what @Redhill_qik and @miimura and @wwhitney come up with to tell me what I'm missing. And of course the payback is non-existent in these scenarios. But at least I'm greener? I don't know why I always end up with the conclusion that NEM 3.0 is worse than no-NEM. What am I missing?
So you are telling me that switching everything to electric, getting batteries and lots of solar to stay off the grid, etc., is going to cost me more with them telling me if I keep my house 70 during the summer, using the solar I produce, they are going to charge me even though I am using zero PGE electricity?