CPUC NEM 3.0 discussion

[holeydonut]

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?

Well, you specifically for the next 14 or so years can live comfortably in retirement. But a semi-clone of yours that were to start an "electrification initiative" under these NEM 3.0 proposals is way worse off than you are now.

You after 14 years will not be a happy camper. But by then hopefully you can install a 1 GWh battery and go off grid with a flotilla of solar on the lake.

 

[Redhill_qik]

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 (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?

Comparing the NEM 3.0 NBCs to the NEM 2.0 NBCs looks like this for PG&E

Tariff Component	Billing Code	NEM 2.0​	NEM 3.0​
New System Generation Charge	NSGC/NSG		0.00299​
Reliability	RMR/RS		0.00012​
Energy Cost Recovery Amount	1DR/ECRA		-0.00429​
Wildfire Hardening	WH		0.00141​
Power Charge Indifference Amount 2022 Vintage	PCIA		0.02554​
Public Purpose Programs	PPP	0.01954​	0.01954​
Nuclear Decommissioning	ND	-0.00013​	-0.00013​
Competition Transition Charge	OCF/CTC	0.00023​	0.00023​
Wildfire Fund	DWR/WF	0.00459​	0.00459​
Total		0.02423​	0.05000​

The biggest impact here is the inclusion of a PCIA component. I guess they want to treat people that add solar the same as if they moved to a CCA. This component has been trending down and should go down by 50% by 2030 and to zero by 2040 as the last of the bad contracts expire. How they would factor in people that have already moved to a CCA is an unknown, but I would expect that this would be your current vintage year which are currently all lower than the 2021-2022 Vintages, but not significantly lower.

I will work on modeling some different scenarios to see how this might all play out, maybe this weekend.

 

[holeydonut]

The biggest impact here is the inclusion of a PCIA component.

Thanks for aggregating the table!

The biggest impact IMO is applying the NBC on every kWh used at the house instead of just the imported amount lol. As h2ofun pointed out, the new policy being proposed effectively punishes someone from adding electric appliances. It also wipes out the mentality that one could add solar to offset the higher energy used to live a more comfortable life.

But yeah the greatest change in the NBC amount is that indifference charge.

 

[h2ofun]

Thanks for aggregating the table!

The biggest impact IMO is applying the NBC on every kWh used at the house instead of just the imported amount lol. As h2ofun pointed out, the new policy being proposed effectively punishes someone from adding electric appliances. It also wipes out the mentality that one could add solar to offset the higher energy used to live a more comfortable life.

But yeah the greatest change in the NBC amount is that indifference charge.

How could they know how much I use in my house? I could just turn off the breakers to the grid

 

[MJ_CA_2019]

How could they know how much I use in my house? I could just turn off the breakers to the grid

Makes you think twice about using any tech considered "Smart" that has an internet connection right?

 

[Redhill_qik]

Thanks for aggregating the table!

The biggest impact IMO is applying the NBC on every kWh used at the house instead of just the imported amount lol. As h2ofun pointed out, the new policy being proposed effectively punishes someone from adding electric appliances. It also wipes out the mentality that one could add solar to offset the higher energy used to live a more comfortable life.

But yeah the change in the NBC amount change is that indifference charge.

Right, metering the entire house usage versus just the imports is a big additional cost. Implementing this will be problematic and will add a significant cost to the installation to be able to support it especially for partial home backup. As people roll off of NEM 2.0 and on to NEM 3.0 would they be required to spend thousands of dollars to add metering? That seems insane.

Note: This is very similar to how the Austin TX implements solar and maybe a number of other utilities as well. Really, this is mostly a way to keep the tax-that-are-not-a-tax revenue flowing, except for the PCIA amount that is a more grey area being IOU costs and stranded customer costs for generation.

 

[RKCRLR]

Right, metering the entire house usage versus just the imports is a big additional cost. Implementing this will be problematic and will add a significant cost to the installation to be able to support it especially for partial home backup. As people roll off of NEM 2.0 and on to NEM 3.0 would they be required to spend thousands of dollars to add metering? That seems insane.

Note: This is very similar to how the Austin TX implements solar and maybe a number of other utilities as well. Really, this is mostly a way to keep the tax-that-are-not-a-tax revenue flowing, except for the PCIA amount that is a more grey area being IOU costs and stranded customer costs for generation.

I agree, how could they enforce requiring current solar owners to pay for installing a meter? I suppose they could assume a certain consumption amount and tell you to install a consumption meter if you disagree with the assumption.

 

[holeydonut]

Right, metering the entire house usage versus just the imports is a big additional cost. Implementing this will be problematic and will add a significant cost to the installation to be able to support it especially for partial home backup. As people roll off of NEM 2.0 and on to NEM 3.0 would they be required to spend thousands of dollars to add metering? That seems insane.

Note: This is very similar to how the Austin TX implements solar and maybe a number of other utilities as well. Really, this is mostly a way to keep the tax-that-are-not-a-tax revenue flowing, except for the PCIA amount that is a more grey area being IOU costs and stranded customer costs for generation.

The more I look at this "NBC on gross consumption" line of questions from the CPUC, the more I think it's just a disingenuous attempt at saying they "tried to find an alternative" to the $8 per month per kW (AC) fixed cost fee. Once they dig into the operational challenges, this proposal of a behind the meter meter will die and they'll default back to $8.

The CPUC seems to think the that $8 per month per kWp (AC) is fair (even if almost every TMC user would disagree). This is ultimately the problem. The CPUC refuses to think "why is the grid so damn expensive?" So, Californians are stuck with the BS IOU-CPUC-Corrupt-spin-cycle since all the CPUC seems to care about is "how do we find someone to pay for this grid?"

I'm a little disheartened that in the latest CALSSA comments, they do not mention at all how the CPUC's NEM 3.0 PD (with their high fixed cost adders and low-value exports) is actually worse than no NEM at all. Correct me if I'm wrong, but my understanding is that right now... if someone installed on-site solar and ESS that was non-exporting, they would not require PTO from PG&E. They would simply see a significant reduction in their annual imports from the grid.

 

[miimura]

I'm a little disheartened that in the latest CALSSA comments, they do not mention at all how the CPUC's NEM 3.0 PD (with their high fixed cost adders and low-value exports) is actually worse than no NEM at all. Correct me if I'm wrong, but my understanding is that right now... if someone installed on-site solar and ESS that was non-exporting, they would not require PTO from PG&E. They would simply see a significant reduction in their annual imports from the grid.

You have to specifically engineer the system so that it is impossible to export in order to avoid utility interconnection (PTO). A system that is interconnected but curtails to avoid export is a different thing and is much easier to accomplish.

IMHO, true non-export or non-PTO systems should not be necessary in California. They only exist in places like Hawaii because there is a legitimate need to avoid excess end-user export in order to maintain grid stability. The CPUC should give customers the option to avoid the $8/kW/mo fee by choosing $0/kWh export credit or choosing a rate schedule that includes $0/kWh export from 8am-3pm.

 

[h2ofun]

You have to specifically engineer the system so that it is impossible to export in order to avoid utility interconnection (PTO). A system that is interconnected but curtails to avoid export is a different thing and is much easier to accomplish.

IMHO, true non-export or non-PTO systems should not be necessary in California. They only exist in places like Hawaii because there is a legitimate need to avoid excess end-user export in order to maintain grid stability. The CPUC should give customers the option to avoid the $8/kW/mo fee by choosing $0/kWh export credit or choosing a rate schedule that includes $0/kWh export from 8am-3pm.

Would totally take away a key reason I spent SO much money on solar, to use PGE battery in summer so I can get back in winter. For folks who do not have an all electric house, one has NO idea how much this is

 

[holeydonut]

The CPUC should give customers the option to avoid the $8/kW/mo fee by choosing $0/kWh export credit or choosing a rate schedule that includes $0/kWh export from 8am-3pm.

At this point, the CPUC is not providing an "out" that resembles your proposal.

So are you saying that right now, if a John Doe (who is not interconnected with solar) in Northern California were to get one of these, and set it to 0 grid export, they'd still need to get a PG&E solar interconnection agreement?

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Transform your businesses and residences into an eco-friendly energy hub using the SolarEdge inverter solution and the SolarEdge energy manager platform.

www.solaredge.com

 

[miimura]

Would totally take away a key reason I spent SO much money on solar, to use PGE battery in summer so I can get back in winter. For folks who do not have an all electric house, one has NO idea how much this is

Yes, that's exactly what PG&E wants. They want to destroy the value of people installing solar to seasonally shift costs. If the State wants people to decarbonize and shift things like heating from fossil fuels to electricity, they need to force the utilities to allow seasonal shifting with workable economics. Otherwise, people just won't do it.

 

[miimura]

At this point, the CPUC is not providing an "out" that resembles your proposal.

So are you saying that right now, if a John Doe (who is not interconnected with solar) in Northern California were to get one of these, and set it to 0 grid export, they'd still need to get a PG&E solar interconnection agreement?

Solar Powering People’s Lives Around the USA | SolarEdge

Transform your businesses and residences into an eco-friendly energy hub using the SolarEdge inverter solution and the SolarEdge energy manager platform.

www.solaredge.com

Yes, that is an inherently interconnected system that requires PTO.

If you want to avoid PTO, you have to have a hard dividing line between loads that are on the grid and loads that are off the grid. Hybrid inverters that have a separate input for battery charging can do this. The hybrid battery inverter can be hooked up so that the battery (and therefore solar) energy cannot flow toward the grid.

 

[dareed1]

You have to specifically engineer the system so that it is impossible to export in order to avoid utility interconnection (PTO). A system that is interconnected but curtails to avoid export is a different thing and is much easier to accomplish.

I think that "impossible to export" is not enough to avoid PTO. Rule 21 D.1 says one needs an interconnection agreement for parallel operation, and parallel operation is defined as "The simultaneous operation of a Generator with power delivered or received by Distribution Provider while Interconnected."
So I think that to avoid PTO one would have to disallow any consumption from the grid while the solar panels are generating power. In Tesla-space, I suppose one could programmatically Go Off Grid whenever the sun is up.

 

[holeydonut]

I think that "impossible to export" is not enough to avoid PTO. Rule 21 D.1 says one needs an interconnection agreement for parallel operation, and parallel operation is defined as "The simultaneous operation of a Generator with power delivered or received by Distribution Provider while Interconnected."
So I think that to avoid PTO one would have to disallow any consumption from the grid while the solar panels are generating power. In Tesla-space, I suppose one could programmatically Go Off Grid whenever the sun is up.

This NEM 3.0 thing just gets worse and worse.

Hypothetical... how would PG&E know if you have a non-exporting SolarEdge inverter? They'd see demand dip, but that's kind of the point of doing a non-exporting system.

Asking for a friend in 15 years.

 

[Onetwothree]

Luckily I just got a new PTO so I think I'm covered for 15 years, but keep your eyes open in 2037 as you'll see my name in the news for suing PG&E to disconnect from the grid entirely. No chance I agree to any of these changes.

 

[miimura]

I think that "impossible to export" is not enough to avoid PTO. Rule 21 D.1 says one needs an interconnection agreement for parallel operation, and parallel operation is defined as "The simultaneous operation of a Generator with power delivered or received by Distribution Provider while Interconnected."
So I think that to avoid PTO one would have to disallow any consumption from the grid while the solar panels are generating power. In Tesla-space, I suppose one could programmatically Go Off Grid whenever the sun is up.

Rule 21 pre-supposes interconnection. The whole point of this discussion is to avoid interconnection. I don't have a reference for authoritative requirements for such a system. If you don't mind the interruption, one way is to just put a switch such that your loads are powered mutually exclusively by either an off-grid inverter or the grid with no connection at all between sources. I suppose if PG&E wanted to be particularly vindictive, they could impose Schedule S standby fees for your electrical service that was not used most of the time. However, DERs are normally exempt from that Schedule.

 

[miimura]

This NEM 3.0 thing just gets worse and worse.

Hypothetical... how would PG&E know if you have a non-exporting SolarEdge inverter? They'd see demand dip, but that's kind of the point of doing a non-exporting system.

Asking for a friend in 15 years.

What you can get away with is a separate discussion from what is required from a legal or regulatory standpoint.

 

[holeydonut]

What you can get away with is a separate discussion from what is required from a legal or regulatory standpoint.

Considering California was at the forefront of green energy adoption in the USA by millions of homeowners... this new NEM 3.0 sucks.

 

[Redhill_qik]

I will work on modeling some different scenarios to see how this might all play out, maybe this weekend.

@holeydonut and @h2ofun would you be willing to share a year of your pre-solar PG&E Green Power CSV hourly data? My own usage is modest in comparison to the amount that both of you consume and I'm not sure that just scaling it up would be valid. Stripping out the header data with your account info would protect your privacy. I would also need some info on your systems to be able to be able to get the PVwatts hourly estimates, num panels, orientation, inclination for each group and a rough geo-location or I could estimate that from your profile info.

If anyone else wants to contribute their data, I would be happy to take it.