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CPUC NEM 3.0 discussion

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@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.
I sent this in with my app, it was off the scale since I was using like 2K per month in the winter since I had like 9 space heater running wide open. This is why I got approved for so much solar. Technically it was below my proven 100% usage for 2 years. Sure is not that now, but it was then
 
So, is retroactively reducing the grandfathering from 20 years to 15 years for existing NEM/NEM2 customers still in the NEM3 proposal?


From what I gather, yes the retroactive change of everyone to 15 years is still in the PD and will go into effect with NEM 3.0.

After the outcry against the original NEM 3.0 PD, the CPUC asked for stakeholders to provide comments about what could change. But, there was no request to re-assess changing of grandfathering to 15 years in the NEM 3.0 PD. Unfortunately for those early solar adopters, there isn't anyone really going to bat for their original 20 years. While the SEIA had initially said changing 20 to 15 could endanger "trust", that argument has kind of fallen away.

Many months ago early in the NEM 3.0 proceeding, I recall seeing comments from Sunrun and the SEIA about how NEM 1.0 and NEM 2.0 solar adopters took out secured loans (or did PPAs) that relied on the 20 year NEM grandfathering. So going from 20 to 15 does financially harm some people, but the CPUC don't care because the IOUs made a compelling argument (bribe?) that 15 years was still very fair.
 
I'm going to say this again, this doesn't have to be that complicated. They need to throw out the old rate structures and have rate structures based on actual costs instead of artificially constructed rate structures if they expect credibility in the future.

Have a fixed residential connection fee for everyone regardless of what other forms of energy conservation or production they have. The connection fee structure should be directly related to what drives the IOU costs (peak power consumption, whatever). An additional fee should be added to the connection fee to subsidize those that would be regressively impacted by a fixed connection fee.

Have energy charges structured so they reflect the actual costs of providing energy during the different periods of the day, weekends, etc. An additional fee based on consumption from the grid should be added to subsidize those regressively impacted by the energy charges.

Have credit for energy sent to grid based on how much it would cost to get the energy from other sources during the time the energy is being provided to the grid.

If this rate structure doesn't provide enough incentive for customers to install renewable energy generators and storage then provide incentives from the general fund (renewable energy benefits everyone) or an additional fee on the energy charges. Any fees for incentives, subsidies, etc., should be listed separately on the bills for transparency.

I don't see how this could be considered unfair.
 
From what I gather, yes the retroactive change of everyone to 15 years is still in the PD and will go into effect with NEM 3.0.

After the outcry against the original NEM 3.0 PD, the CPUC asked for stakeholders to provide comments about what could change. But, there was no request to re-assess changing of grandfathering to 15 years in the NEM 3.0 PD. Unfortunately for those early solar adopters, there isn't anyone really going to bat for their original 20 years. While the SEIA had initially said changing 20 to 15 could endanger "trust", that argument has kind of fallen away.

Many months ago early in the NEM 3.0 proceeding, I recall seeing comments from Sunrun and the SEIA about how NEM 1.0 and NEM 2.0 solar adopters took out secured loans (or did PPAs) that relied on the 20 year NEM grandfathering. So going from 20 to 15 does financially harm some people, but the CPUC don't care because the IOUs made a compelling argument (bribe?) that 15 years was still very fair.
They're using too broad of a brush. In my case I initially installed 4kW of solar in 2009 and another 6kW in 2019. I was verbally told that my 20 year grandfathering would be reset to another 20 years starting in 2019. However, written documents imply that the 20 year grandfathering does not get reset. I had to file a complaint with the CPUC because PG&E kept verbally telling me that it gets reset but they wouldn't send me anything in writing. When PG&E finally sent me an email they admitted the 20 year grandfathering goes from the first installation date. So, for me this would be a double whammy. I would be transitioned to NEM3 in 2024, only 5 years to recover my ROI on the 6kW system.

If they do this this would be the last time I would trust the government for incentives that require me to put a financial outlay up front.
 
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They using too broad of a brush. In my case I initially installed 4kW of solar in 2009 and another 6kW in 2019. I was verbally told that my 20 year grandfathering would be reset to another 20 years starting in 2019. However, written documents imply that the 20 year grandfathering does not get reset. I had to file a complaint with the CPUC because PG&E kept verbally telling me that it gets reset but they wouldn't send me anything in writing. When PG&E finally sent me an email they admitted the 20 year grandfathering goes from the first installation date. So, for me this would be a double whammy. I would be transitioned to NEM3 in 2024, only 6 years to recover my ROI on the 6kW system.

If they do this this would be the last time I would trust the government for incentives that require me to put a financial outlay up front.
When was the first time you trusted government?
 
I dunno what's worse, having PG&E lie to you about the NEM grandfathering "reset" and then subsequently costing you thousands of dollars of value ...

or my experience where a powertrippin' PG&E worker lectured me about how evil solar+ESS was. And then PG&E tried really hard to prevent my install because they are the bullies with monopoly rights to provide power in Northern California.

Either way, ratepayers get hosed because PG&E is enabled to be a-holes and murderers. It's beyond frustrating watching PG&E and SCE kill the one sliver of escape that was presented to homeowners to get away from the mismanaged grid.
 
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Didn't Nevada sue to challenge the 20 to 15 year grandfathering rules? Anyone in NV can comment on the state of things there?

I did see in some searches that they killed NEM completely in like 2017 or something, but changed the law back after all the jobs and projects were killed off and solar no longer made sense and installs started up again.

NEM3.0 will probably kill off the industry if it passes since there is too much risk if the IOUs/CPUC can change things at will. I've heard from my installer that they are trying to do more work in other states since CA is too unstable/unsure what will happen.
 
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Didn't Nevada sue to challenge the 20 to 15 year grandfathering rules? Anyone in NV can comment on the state of things there?

I did see in some searches that they killed NEM completely in like 2017 or something, but changed the law back after all the jobs and projects were killed off and solar no longer made sense and installs started up again.

NEM3.0 will probably kill off the industry if it passes since there is too much risk if the IOUs/CPUC can change things at will. I've heard from my installer that they are trying to do more work in other states since CA is too unstable/unsure what will happen.


Yeah, the Nevada courts found the PUC's change of the original 20 years grandfathering down to 12 violated contract law. Interestingly, it was NV Energy that actually proposed to the Edit: Nevada PUC to allow the grandfathering to remain at 20 years. Those IOUs are sneaky SOBs.


There are a few considerations which I guess are "favorable" if you're an optimist, but I view as more of an obfuscation to screw over their competition.

1) NV Energy never actually submitted a request for grandfathering to retroactively affect prior installs to drop down from 20 to 12 years. Of course they put pressure on the PUC to address the grandfathering, but they never said the words "please retroactively change grandfathering"

2) The Joint IOUs in California did the same thing. They repeatedly told the CPUC that NEM 1.0 and NEM 2.0 systems were already "paid back" after 3 to 7 years. And that the generous 20 year grandfathering under NEM 1, 2 was part of the cost shift problem. But they didn't actually say "please retroactively change grandfathering". The Joint IOUs also put pressure on Gonzales to think of the "cost shift" when she wrote AB1139 (she wanted to change grandfathering from 20 years down to 10 years). But again, the recommendation wasn't made by the IOUs themselves.

So... PG&E, SCE, SDG&E could white knight themselves down the road and "fight on consumers behalf" to get things back to 20 years for existing installs.

Make no mistake, the IOUs are just playing both sides of the issue to fracture the base. Ultimately the losers will remain the residential solar/storage industry and future homeowners having zero reasonable way to get access to a useful solar NEM.

Oh, and the Nevada ruling only affected 33,000 grandfathered NEM customers. California has over 1mm. So yeah, if the NEM 3.0 is signed by the CPUC includes a change to grandfathering... write your local AG and tell them the CPUC just violated contract law.
 
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a powertrippin' PG&E worker lectured me about how evil solar+ESS was
That is a strange position to take. Do you recall his reasoning?

I believe that solar+ESS is the solution to the problem.

First, NEM was created to handle the seasonal variation of solar production, by using summer seasons' higher demand to consume the excess solar.

The utilities argument now is not about that, but rather about the daily cycle of solar production vs load imbalance. Solar (non ESS ones, that is) customers still need full power after sundown. So they still contribute to the total peak power which the utility must deliver, and hence must have generation and transmission capacity to supply that peak. This is a huge portion of their total capital investment, according to their study. This is the argument they made in their "Lookback Study": solar customers need that peak power but don't pay for what it costs.

ESS eliminates that. My Powerwall charges during the morning, and then powers my house from 3 pm till midnight. I use no peak time power at all. In fact, I am now exporting during that period.

So, if solar folks all got batteries, and that market grew to 100% of all customers (it won't), utilities would still provide night and winter power, as well as EV charging, industrial uses, etc. But the peak demand would be around half of what it is now, meaning that utility capital and fuel expenses would be half. As a result, everyones cost for electricity would drop.

Consider this, PG&E is just now turning on a huge Tesla battery system at Moss Landing. 183 megawatts, 730 megawatt hours. That is like around 50,000 Powerwalls. SGIP's $600 million equity resiliency budget bought a similar number of Powerwalls. Why did PG&E do that? Because it saves them $$$. It decreases the amount of generation capacity they need. Transmission too, given that the system is close to the SF & Montery Bay Areas, far from Diablo canyon and lake Shasta.

Anyway, I sincerely wonder how a PG&E worker would explain his distaste for solar + ESS. Unless he actually understands that PG&E profits more when they spend more. And, if they can get CPUC to go along with killing solar, they can spend, spend, spend to supply juice for EV. Just think, tapping directly into the oil companies' vehicle fuel cash flow stream.

EOR. (end of rant). SW
 
That is a strange position to take. Do you recall his reasoning?

I believe that solar+ESS is the solution to the problem.

First, NEM was created to handle the seasonal variation of solar production, by using summer seasons' higher demand to consume the excess solar.

The utilities argument now is not about that, but rather about the daily cycle of solar production vs load imbalance. Solar (non ESS ones, that is) customers still need full power after sundown. So they still contribute to the total peak power which the utility must deliver, and hence must have generation and transmission capacity to supply that peak. This is a huge portion of their total capital investment, according to their study. This is the argument they made in their "Lookback Study": solar customers need that peak power but don't pay for what it costs.

ESS eliminates that. My Powerwall charges during the morning, and then powers my house from 3 pm till midnight. I use no peak time power at all. In fact, I am now exporting during that period.

So, if solar folks all got batteries, and that market grew to 100% of all customers (it won't), utilities would still provide night and winter power, as well as EV charging, industrial uses, etc. But the peak demand would be around half of what it is now, meaning that utility capital and fuel expenses would be half. As a result, everyones cost for electricity would drop.

Consider this, PG&E is just now turning on a huge Tesla battery system at Moss Landing. 183 megawatts, 730 megawatt hours. That is like around 50,000 Powerwalls. SGIP's $600 million equity resiliency budget bought a similar number of Powerwalls. Why did PG&E do that? Because it saves them $$$. It decreases the amount of generation capacity they need. Transmission too, given that the system is close to the SF & Montery Bay Areas, far from Diablo canyon and lake Shasta.
EOR. (end of rant). SW
Most articulate way I’ve seen this (attempt) to be explained. Bravo.
 
That is a strange position to take. Do you recall his reasoning?

I believe that solar+ESS is the solution to the problem.

First, NEM was created to handle the seasonal variation of solar production, by using summer seasons' higher demand to consume the excess solar.

The utilities argument now is not about that, but rather about the daily cycle of solar production vs load imbalance. Solar (non ESS ones, that is) customers still need full power after sundown. So they still contribute to the total peak power which the utility must deliver, and hence must have generation and transmission capacity to supply that peak. This is a huge portion of their total capital investment, according to their study. This is the argument they made in their "Lookback Study": solar customers need that peak power but don't pay for what it costs.

ESS eliminates that. My Powerwall charges during the morning, and then powers my house from 3 pm till midnight. I use no peak time power at all. In fact, I am now exporting during that period.

So, if solar folks all got batteries, and that market grew to 100% of all customers (it won't), utilities would still provide night and winter power, as well as EV charging, industrial uses, etc. But the peak demand would be around half of what it is now, meaning that utility capital and fuel expenses would be half. As a result, everyones cost for electricity would drop.

Consider this, PG&E is just now turning on a huge Tesla battery system at Moss Landing. 183 megawatts, 730 megawatt hours. That is like around 50,000 Powerwalls. SGIP's $600 million equity resiliency budget bought a similar number of Powerwalls. Why did PG&E do that? Because it saves them $$$. It decreases the amount of generation capacity they need. Transmission too, given that the system is close to the SF & Montery Bay Areas, far from Diablo canyon and lake Shasta.

Anyway, I sincerely wonder how a PG&E worker would explain his distaste for solar + ESS. Unless he actually understands that PG&E profits more when they spend more. And, if they can get CPUC to go along with killing solar, they can spend, spend, spend to supply juice for EV. Just think, tapping directly into the oil companies' vehicle fuel cash flow stream.

EOR. (end of rant). SW


Yeah I guess I should have been more specific that he disliked solar + ESS if a homeowner or company like Sunrun does the install. He’s probably a fan of utility scale solar + ESS with PG&E at the epicenter.

Here’s my old thread referencing this lineman.

Anyway so after I struggled for months to get my project approved by PG&E's Diablo planning department, this SOB comes to my house to do the service disconnect so the folks can safely replace my 200A main service panel with a new 200A main service panel. He takes this as an opportunity to absolutely SCREW ME. He disconnects the power... but also threatens the Sunrun crew that if they touch my main service panel, he won't restore my electricity service.

Keep in mind that thread I just linked was dated in mid November. This MOTHER EFFER just disconnected my power and left when it was 35F outside. My house temperature plummeted since I couldn't run my furnaces (the furnace is gas, but the air handler is electric). I had a 1 year old toddler, this was abhorrent behavior by your PoCo. I tried for hours to get PG&E to send someone back to my house, but they insisted there was "nothing they could do".

When the PG&E lineman came back to my house 8 hours later, he was very pleased at what he had done. He said he hoped I learned my lesson that \Sunrun was not a trustworthy company. He said my "home improvement" project of installing solar + ESS did not comply with the rules, and I shouldn't trust companies like Sunrun since they don't follow the rules. He said the only people you should trust to provide power is PG&E. Then went on to rail me about how Sunrun was conning me out of money by selling me batteries since no homeowner needs solar + ESS.

MOTHER EFFER SHUT OFF MY POWER THEN TRIED TO GAS LIGHT ME THAT SUNRUN WAS THE PROBLEM.

So yeah, I didn't like PG&E before. But from here on out I REALLY HATED THESE MF'ers. PG&E sucks beyond belief.

When @SMAlset posted "I was kind of shocked to see you still having trouble getting your solar/pw installed"... it took another 40 days to get the project completed because this PG&E lineman actually succeeded in removing my entire project approval from PG&E's Diablo office and I had to START OVER. PG&E is the worst. They have too much influence and too much corruption.
 
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Yeah I guess I should have been more specific that he disliked solar + ESS if a homeowner or company like Sunrun does the install. He’s probably a fan of utility scale solar + ESS with PG&E at the epicenter.

Here’s my old thread referencing this lineman.
I had some PG&E line folks by my house because they had to replace the transformer. They were all over the Solar Flower, Solar Roof and Powerwalls like a moth to a flame and thought they were the greatest things ever. They talked it up with me on how they worked, what my return was, how it worked in power outages ...

So I guess it depends on who you get and what side of the bed they got out of that morning.
 
I had some PG&E line folks by my house because they had to replace the transformer. They were all over the Solar Flower, Solar Roof and Powerwalls like a moth to a flame and thought they were the greatest things ever. They talked it up with me on how they worked, what my return was, how it worked in power outages ...

So I guess it depends on who you get and what side of the bed they got out of that morning.


Lucky you. I got the guy who has drank the anti-NEM kool-aide and thinks only rich a-holes get solar... and oftentimes they "break the rules to get it". The guy at my house also said solar+ESS took away from his pension, and he wished (edit: I split an infinitive) it = residential solar would go away. So yeah.
 
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Lucky you. I got the guy who has drank the anti-NEM kool-aide and thinks only rich a-holes get solar... and oftentimes they "break the rules to get it". The guy at my house also said solar+ESS took away from his pension, and he wished it would go away. So yeah.
After the initial contact, I’m surprised you didn’t record the subsequent interactions so as to submit it to PGE/news stations.
 
After the initial contact, I’m surprised you didn’t record the subsequent interactions so as to submit it to PGE/news stations.


If he knew he was being recorded, I doubt he would have been so candid about everything. But yeah, he knew his supervisors would get his back (and they did). They said if the QEW (qualified electrical worker) in the field doesn't like what he sees, then he's always 100% right. Sunrun was shady and needs to try again.
 
The guy at my house also said solar+ESS took away from his pension, and he wished (edit: I split an infinitive) it = residential solar would go away.
Oh my, what a nightmare. Odd, though, that thought coming from a guy who works for the company which blew up San Bruno and burned Paradise Ca. to the ground, both cases due to PG&E pros screwing up on simple routine maintenance. That should have been when PG&E and his job went up in smoke, along with his pension.

On the NEM3 thread, I think that the state is slowly coming to grips with the fact that distributed generation and storage means that a monopoly utility is no longer justified. The CCAs are an example of breaking up utilities lock on the market, as are third party generation. Us PW owners are tough competition for PG&E, capable of running off grid for extended periods.

One other thought on NEM3 is I wonder what would happen if all the solar and ESS owners simply shut our systems down, say at noon, statewide. If in fact we are numerous enough to affect non-solar pricing, then a sudden shutdown should stress PG&E severally. The opposite of grid support, an export boycott, if done during a peak stress period, should show how PG&E and it's customers profit from solar. A solar strike, so to speak. A day without solar.

In other news, yesterday I filed my own interconnection request, wherein we add 6 PV panels and 6 micro-inverters to the existing 14 of each. Today I got an email saying that 6 inverters did not have enough capacity to handle 20 panels. The application says there are 20 inverters. My point would be, again, that PG&E people are really not in a good position to criticize customers or other companies.

Sadly, though, PG&E is good at conning the CPUC.

SW