CPUC NEM 3.0 discussion

[holeydonut]

Lets say there two houses. One is a zero energy house without solar and storage and the other is a standard home with solar and storage. And they both consume the same amount of energy from the grid at the same times.

What is the logic in charging the house with solar and storage more than the zero energy house? Why isn't this question being brought into the mix?

Not sure what you mean... the IOUs want the zero energy house to keep paying zero because there is zero happening at the house. But, they want your PV+ESS house to pay way more NBCs than what is currently being paid under NEM 1.0 and NEM 2.0. Because there are occupants of this second home who are using electricity. And, as long as the PV+ESS house remains grid tied, the IOUs say the occupants of the PV+ESS need to pay pay pay pay for the mismanaged grid.

The law allows PG&E and CASIO the right to waste whatever the CPUC allows and to pass those charges/fees as revenue (either revenue to the IOU directly, or revenue to the CASIO operator for generation).

But the law doesn't protect the PV+ESS owner who is grid tied.

 

[Redhill_qik]

Lets say there two houses. One is a zero energy house without solar and storage and the other is a standard home with solar and storage. And they both consume the same amount of energy from the grid at the same times.

What is the logic in charging the house with solar and storage more than the zero energy house? Why isn't this question being brought into the mix?

What exactly is a "zero energy house" one that is vacant or under construction? If this is your definition then it would be a temporary thing with the expectation that it would start consuming and paying "its fair share" at some later time. Going solar is a more permanent change and a change that doesn't fully remove the need for grid power unless you have a massive array and a lot of Powerwalls and even then if your system is down due to a fault you want that grid there to keep you going.

 

[holeydonut]

What exactly is a "zero energy house" one that is vacant or under construction? If this is your definition then it would be a temporary thing with the expectation that it would start consuming and paying "its fair share" at some later time. Going solar is a more permanent change and a change that doesn't fully remove the need for grid power unless you have a massive array and a lot of Powerwalls and even then if your system is down due to a fault you want that grid there to keep you going.

I just think it's BS that a non-exporting PV+ESS system that doesn't have NEM is illegal to install. So using solar generation to offset consumption at the home (without using NEM) is just plain ol' illegal.

The only recourse is to remove all light bulbs, never cook meals, and just stare at the wall like PG&E wants... that's ok and a "fair share" is being paid. FYI, here's an article about a woman who went so far as to go take a piss with a lantern to afford her electricity. New PG&E rate plan takes effect soon in Sonoma

But if I install some solar panels without NEM (and configured the inverter to not grid-export) so I can power my home and presumably cook some meals, I've broken the law. Lames.

 

[RKCRLR]

What exactly is a "zero energy house" one that is vacant or under construction? If this is your definition then it would be a temporary thing with the expectation that it would start consuming and paying "its fair share" at some later time. Going solar is a more permanent change and a change that doesn't fully remove the need for grid power unless you have a massive array and a lot of Powerwalls and even then if your system is down due to a fault you want that grid there to keep you going.

I probably used the wrong terminology. I was thinking of something like this for an energy efficient home:

Efficient Earth-Sheltered Homes

An underground or bermed earth-sheltered house can be weather resistant and energy efficient.

www.energy.gov

My point is it shouldn't matter whether you use less electricity from the grid by efficiency, the climate where you live, how small your house is, or by producing for solar for your own consumption. If they all draw the same amount of electricity from the grid then they all have the same impact on the grid. One shouldn't be penalized by the IOU over the other.

 

[holeydonut]

I probably used the wrong terminology. I was thinking of something like this for an energy efficient home:

Efficient Earth-Sheltered Homes

An underground or bermed earth-sheltered house can be weather resistant and energy efficient.

www.energy.gov

My point is it shouldn't matter whether you use less electricity from the grid by efficiency, the climate where you live, or by producing for solar for your own consumption. If they all draw the same amount of electricity from the grid then they all have the same impact on the grid. One shouldn't be penalized by the IOU over the other.

Oh ok so your zero-energy home is more like a "demands as little energy as possible from the grid but doesn't use solar to achieve this result" home.

You'll enjoy reading Dr. Ahmad Faruqui’s comments - which basically cover the point you're making around the volumetric pricing model and other key topics.

My comments on the CPUC's Proposed Decision on NEM 3.0

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Order Instituting Rulemaking to...

ahmadfaruqui.blogspot.com

The part that addresses what you're saying is:
"The (ed. NEM 3.0) PD is singling out just the cost shift that’s created when solar customers import less power from the grid, ignoring all other cost shifts. If low use is a concern for utilities, it should be addressed by changing the rate design for all customers, not just for solar customers."

Yeah, if someone makes a home consume very little energy (while they reside in it normally), they're not paying their fair share of the grid. Which he likens to a homeowner who slaps on solar and batteries also reducing their demand from the grid. But, in the NEM 3.0 PD, only the homeowner with solar and batteries is being asked to pay more fixed costs, which Faruqui argues is discriminatory.

However, the IOUs and the CPUC have said they aren't stopping the volumetric pricing approach. So by the existing legal definitions... the homeowner who builds a "zero-energy" home is allowed to benefit from a cost shift (and pay less fixed costs). But, the homeowner who adopts solar shall not be conveyed that benefit within the NEM 3.0 proceeding.

The crux of the IOU's argument is that the NEM 3.0 proceeding is; to address NEM (which involves on-site generation). The issues of volumetric pricing or fair-share costs paid by "zero-energy" homes shall be discussed in a different proceeding. IMO, the CPUC has never really addressed Faruqui's points at all... since he's just one dude. He has no lobby/funds to sway ideology or policy.

The guy makes a very compelling argument about NEM 3.0 PD's flaws... it's just too easy for the CPUC to ignore him lol.

 

[RKCRLR]

Oh ok so your zero-energy home is more like a "demands as little energy as possible from the grid but doesn't use solar to achieve this result" home.

You'll enjoy reading Dr. Ahmad Faruqui’s comments - which basically cover the point you're making around the volumetric pricing model and other key topics.

My comments on the CPUC's Proposed Decision on NEM 3.0

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Order Instituting Rulemaking to...

ahmadfaruqui.blogspot.com

The part that addresses what you're saying is:
"The (ed. NEM 3.0) PD is singling out just the cost shift that’s created when solar customers import less power from the grid, ignoring all other cost shifts. If low use is a concern for utilities, it should be addressed by changing the rate design for all customers, not just for solar customers."

Yeah, if someone makes a home consume very little energy (while they reside in it normally), they're not paying their fair share of the grid. Which he likens to a homeowner who slaps on solar and batteries also reducing their demand from the grid. But, in the NEM 3.0 PD, only the homeowner with solar and batteries is being asked to pay more fixed costs, which Faruqui argues is discriminatory.

However, the IOUs and the CPUC have said they aren't stopping the volumetric pricing approach. So by the existing legal definitions... the homeowner who builds a "zero-energy" home is allowed to benefit from a cost shift (and pay less fixed costs). But, the homeowner who adopts solar shall not be conveyed that benefit within the NEM 3.0 proceeding.

The crux of the IOU's argument is that the NEM 3.0 proceeding is; to address NEM (which involves on-site generation). The issues of volumetric pricing or fair-share costs paid by "zero-energy" homes shall be discussed in a different proceeding. IMO, the CPUC has never really addressed Faruqui's points at all... since he's just one dude. He has no lobby/funds to sway ideology or policy.

The guy makes a very compelling argument about NEM 3.0 PD's flaws... it's just too easy for the CPUC to ignore him lol.

I've read it and I agree. All reductions in energy consumption should be penalized the same. It shouldn't matter how you reduced your consumption (other than increased dependence on fossil fuels).

 

[holeydonut]

I've read it and I agree. All reductions in energy consumption should be penalized the same. It shouldn't matter how you reduced your consumption (other than increased dependence on fossil fuels).

Yeah, I think just about everyone on TMC (edit: this energy subforum) would agree with Faruqui.

If someone like @h2ofun (like a version of him interested in electricity-conversion and solar in 2024) simply made a new solar array non-grid exporting, he would still save many MWh of electricity per year even without using the grid for NEM. This should be a good thing, and California should encourage this alternate-water-fun-guy to do what he can to reduce overall grid demand with a clean energy source.

But as it stands, the NEM 3.0 PD would be very punitive. To the extent this alternate-h2ofun would just keep his NG furnace(s), propane tanks, and fireplaces. NEM 3.0 would not encourage solar with batteries at all since the NEM 3.0 PD is effectively punishing residential green energy investment. And that's why NEM 3.0 is regressive to us on TMC.

It's sad the IOUs and all those that rely on their broken business model view NEM 3.0 PD as a boon since it keeps the bizzaro-h2ofun as a hungry ratepayer shoving thousands of dollars per year to PG&E and the CAISO members are there to profit off of the supply the MWh.

 

[getakey]

I've read it and I agree. All reductions in energy consumption should be penalized the same. It shouldn't matter how you reduced your consumption (other than increased dependence on fossil fuels).

I agree, but really what should be penalized is ridiculous high rates, mismanagement, and waste. If this weren't the case, very few of us would need solar

 

[holeydonut]

I agree, but really what should be penalized is ridiculous high rates, mismanagement, and waste. If this weren't the case, very few of us would need solar

You shoulda wrote that in a public comment for the NEM 3.0 proceeding heh.

 

[Sky Blue]

I just think it's BS that a non-exporting PV+ESS system that doesn't have NEM is illegal to install. So using solar generation to offset consumption at the home (without using NEM) is just plain ol' illegal.

But if I install some solar panels without NEM (and configured the inverter to not grid-export) so I can power my home and presumably cook some meals, I've broken the law. Lames.

I have been following this discussion for months but I must have missed the posts that talk about it being illegal to have a non-exporting PV system without entering into a NEM agreement. Can someone refer me to the source of that info? Thanks.

 

[holeydonut]

I have been following this discussion for months but I must have missed the posts that talk about it being illegal to have a non-exporting PV system without entering into a NEM agreement. Can someone refer me to the source of that info? Thanks.

@dareed1 posted about this... and yeah the language is buried deep in the Rule 21 stuff that a parallel generation source is prohibited without express interconnection. And since PV+ESS systems as we know of them today have interconnection through a NEM policy, you're looking at either NEM 2.0 or NEM 3.0 depending on when you connected.

No-NEM would technically be in violation of Rule 21 and no licensed contractor in California could install it. PG&E may not see the energy pushed to the meter, but your existence of only drawing energy at certain off-peak times would be a telltale sign of PV+ESS on the site even without a consumption meter on your house.

Somebody posted that you could get cute where a physical disconnect is thrown (or a relay) whenever the solar is active. So technically it is "not parallel". But I'd imagine this is an easy loophole for PG&E to close up if it became obvious that homeowners were just installing solar and ESS to reduce home consumption without paying their "fair share"

CPUC NEM 3.0 discussion

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...

teslamotorsclub.com

Electric Rule 21: Generating Facility Interconnections

www.cpuc.ca.gov

Edit, I guess they already have some rules in place today to get around a system that connects/disconnects a system for "Momentary Parallel Operation"

 

[RKCRLR]

Costal households in California use significantly less electricity that inland counties that use more air conditioning during the summer and heating in the winter. The costal households are not doing their part to support the grid and need to have a surcharge applied to their bills.

 

[getakey]

I've said this before, about what about using the CCA model for Solar. Solar customers pay the transmission/distro charges both ways (except for PCIA on export) and get credit at the generation rate.

 

[Redhill_qik]

Costal households in California use significantly less electricity that inland counties that use more air conditioning during the summer and heating in the winter. The costal households are not doing their part to support the grid and need to have a surcharge applied to their bills.

View attachment 825106

San Francisco is a bit of an outlier, they are coastal, but I would suspect that the lower annual usage is based on a larger amount of smaller footprint apartments.

 

[getakey]

San Francisco is a bit of an outlier, they are coastal, but I would suspect that the lower annual usage is based on a larger amount of smaller footprint apartments.

but the whole bay area west of the bay is lower usage until you get south of Palo Alto
We were in Belmont (just south of san mateo bridge) and did not have AC. Very few homes in our neighborhood had AC. Our summer electricity usage was trivial

 

[Redhill_qik]

I've said this before, about what about using the CCA model for Solar. Solar customers pay the transmission/distro charges both ways (except for PCIA on export) and get credit at the generation rate.

Can you please clarify what you mean by this, because as a PG&E+CCA customer there is no difference than if I was a pure PG&E customer other than my CCA happens to pay me more than PG&E would as a net generator on the year. Transmission, distribution and PCIA charges are all charges on imports and credits on exports.

 

[Southpasfan]

I've read it and I agree. All reductions in energy consumption should be penalized the same. It shouldn't matter how you reduced your consumption (other than increased dependence on fossil fuels).

Bingo!

Double Bingo at that.

What a pleasure to read this series of posts. Indeed, the problem with NEM 3.0 isn't only that solar now has a proposed penalty which will make it economically unattractive.

No, the problem is that the entire structure, of which NEM 3.0 is one part, has no possible way to deal with anyone, let alone solar customers, figuring out a way to reduce consumption.

That's the discussion which should be happening and really isn't.

Its crazy to penalize any reduction in energy consumption in any way, at all. Full stop.

 

[getakey]

Can you please clarify what you mean by this, because as a PG&E+CCA customer there is no difference than if I was a pure PG&E customer other than my CCA happens to pay me more than PG&E would as a net generator on the year. Transmission, distribution and PCIA charges are all charges on imports and credits on exports.

what I mean is to model the rates Solar customers is after the way they do it for CCAs.
You use PG&E electricity, you pay the rates as it is now. You export, you do not get full retail, you get credited based on PG&E generation rate, but you pay for the transmission/distro charges (except for PCIA) on the exported kWh.

 

[Redhill_qik]

Costal households in California use significantly less electricity that inland counties that use more air conditioning during the summer and heating in the winter. The costal households are not doing their part to support the grid and need to have a surcharge applied to their bills.

View attachment 825106

At one point in time, most (all?) of the tariffs had baseline quantities as a rate component. If you used less than the baseline you got a credit and if you used more than the baseline then you paid more. The baseline depended on your location and it would account for those changes, so the cooler coastal areas, T is the whole coastline from Santa Barbra to Eureka, have lower baselines in the summer hotter inland areas, S (Sacramento), R (Fresno), and W (Bakersfield), have higher baselines.

PG&E Baseline map

https://www.pge.com/nots/rates/PGECZ_90Rev.pdf

I'm on the E-TOU-C that still has the baseline, but other plans like E-TOU-D and EV2A don't have a baseline.

 

[Redhill_qik]

what I mean is to model the rates Solar customers is after the way they do it for CCAs.
You use PG&E electricity, you pay the rates as it is now. You export, you do not get full retail, you get credited based on PG&E generation rate, but you pay for the transmission/distro charges (except for PCIA) on the exported kWh.

I continue to get hung up on "you pay the rates as it is now", because what you describe is not how it works under NEM 2.0 with a CCA.