CPUC NEM 3.0 discussion

[stopcrazypp]

Where is the proposed surcharge for people that offset their usage through conservation and efficiency?

There isn't because they know a lot more people would be against that and it would go against all the policies they have been promoting for decades in terms of getting people to use more efficient appliances and reduce demand. Solar users are just the low hanging fruit they can single out as the boogeyman.

 

[BGbreeder]

The Winter demand in California is far lower than Summer. There is no lack of generation to supply customers that have low generation on Winter days. Hydro from the PNW can easily satisfy that if you want to insist on renewable substitution.

I've never looked into it, but are you sure Standby charges are based on MWh and not MW?

You are right, they are generally peak demand, aka MW, but I have seen MWh. I should have written "MW/MWh". While I agree with you that aggregate demand is lower in the winter, when residential solar customers will have the largest demand, I have not encountered a seasonality to the demand charge, but as we are seeing with the proposed NEM 3.0, utilities can be very creative if it makes them more money.

All the best,

BG

 

[Ampster]

My strategy is to use the additional solar panels and storage behind the meter. It may be a violation of Rule 21 and my NEM agreement but as mentioned above it is a matter of what you can get away with. I will still do enough EV charging so that I will have load on the system. The consequences of violating Rule 21 do not appear to be criminal or even a misdemeanor. I do not even see a reference to fines. Do the IOUs have any enforcement capability.except to cancel service? I doubt that the County building department would care since everything is up to code at time of construction.

 

[yblaser]

My strategy is to use the additional solar panels and storage behind the meter. It may be a violation of Rule 21 and my NEM agreement but as mentioned above it is a matter of what you can get away with. I will still do enough EV charging so that I will have load on the system. The consequences of violating Rule 21 do not appear to be criminal or even a misdemeanor. I do not even see a reference to fines. Do the IOUs have any enforcement capability.except to cancel service? I doubt that the County building department would care since everything is up to code at time of construction.

Certainly it would depend on your locality. If the IOU cuts off your service the county could possibly red tag your home deeming not having electrical service a health hazard. With solar and battery storage you might be able to fight that but it would be onerous. Some jurisdictions require you to have electrical service so I imagine fines could be imposed if you did not or again they could red tag it.

 

[holeydonut]

My strategy is to use the additional solar panels and storage behind the meter. It may be a violation of Rule 21 and my NEM agreement but as mentioned above it is a matter of what you can get away with. I will still do enough EV charging so that I will have load on the system. The consequences of violating Rule 21 do not appear to be criminal or even a misdemeanor. I do not even see a reference to fines. Do the IOUs have any enforcement capability.except to cancel service? I doubt that the County building department would care since everything is up to code at time of construction.

Lol I can't wait to read about some dude in 2042 getting a civil penalty under Rule 21 where PG&E throws a rock through their window. #remindmein20years

 

[holeydonut]

Article about the latest on NEM 3.0. I guess they're anticipating a response from the CPUC in 3 or 4 weeks.

California solar net metering comment period closed, here’s what leaders said

California has finished collecting public comment on NEM 3.0, a policy that is considered anti-rooftop solar, and has provisions that are called “a tax on the sun.”

pv-magazine-usa.com

 

[h2ofun]

Article about the latest on NEM 3.0. I guess they're anticipating a response from the CPUC in 3 or 4 weeks.

California solar net metering comment period closed, here’s what leaders said

California has finished collecting public comment on NEM 3.0, a policy that is considered anti-rooftop solar, and has provisions that are called “a tax on the sun.”

pv-magazine-usa.com

How could they charge for solar I produce and use directly in my house? How would they know what I produced and used in my house? This is nuts

 

[holeydonut]

How could they charge for solar I produce and use directly in my house? How would they know what I produced and used in my house? This is nuts

I feel like h2ofun hasn't been reading this thread lately. It's only 110 pages! Fun fun.

Anyway, the thing you missed was that the CPUC sent out a request for new comments a few weeks ago. Most of the questions in this request were around the market transition credit for the value of the exported solar, but there was one query that reads:

"If the Commission adopts the approach of collecting NBCs on gross consumption from Tariff customers, should the Commission consider collecting from all Tariff customers or only a subset of Tariff customers? For example, should the Commission consider collecting from all nonresidential and residential customers; only residential customers; only non-low-income residential customers; or all residential customers plus non-residential customers on certain rates? Explain your rationale"

I thought this was the CPUC's way to get comments around the idea of removing the $8 per kWp AC per month charge, and instead charge a NBC (of about $0.05 per kWh) on all gross consumption at the home.

But others thought the CPUC was toying with the idea to keep some monthly fixed cost per kWp and then ADD this $0.05 per kWh consumption thing as an incremental NBC.

So for example, assume a NEM 3.0 home adds a 7 kWp AC system that generates 10,000 kWh per year.

In the NEM 3.0 PD, this homeowner would pay 7 kWp x $8 NBC x 12 months = $672 of fixed costs per year fee based on the size of the solar system.

Alternatively, if all 10,000 kWh were used in the home (and as measured with a gross consumption meter), this homeowner could pay $10,000 x $0.05 NBC = $500 extra fixed costs based on the consumption in the home that was offset by solar.

The CPUC and IOU proponents view this gross consumption approach a "fair" way to assess the grid benefits charge. Because (in their words not mine) a home without solar pays the grid benefit costs as a volumetric pricing fee on the gross consumption imported from the grid... so a home with solar should be paying the same grid benefit costs on their gross consumption too even if the solar and ESS reduced grid imports.

TLDR, if you're still in California after your NEM 2.0 grandfathering ends, you might as well move to Nevada as was recommended to me many pages ago.

 

[wwhitney]

The CPUC and IOU proponents view this gross consumption approach a "fair" way to assess the grid benefits charge. Because (in their words not mine) a home without solar pays the grid benefit costs as a volumetric pricing fee on the gross consumption imported from the grid... so a home with solar should be paying the same grid benefit costs on their gross consumption too even if the solar and ESS reduced grid imports.

FWIW, I believe that the city of Austin, TX has been doing something similar for quite a while. They have a "buy all / sell all" PV metering system, where the local POCO buys all solar at one (lower) rate, and all consumption has to be purchased from the POCO at a higher rate.

Definitely takes the Net out of NEM.

Cheers, Wayne

 

[Ampster]

Lol I can't wait to read about some dude in 2042 getting a civil penalty under Rule 21 where PG&E throws a rock through their window. #remindmein20years

Civil Penalty? That is like a parking ticket, correct?

 

[holeydonut]

Civil Penalty? That is like a parking ticket, correct?

A ticket attached to a rock thrown through your window, yes. Or in my case they'll send a lineman to my house and kick me in the nuts.

 

[holeydonut]

FWIW, I believe that the city of Austin, TX has been doing something similar for quite a while. They have a "buy all / sell all" PV metering system, where the local POCO buys all solar at one (lower) rate, and all consumption has to be purchased from the POCO at a higher rate.

Definitely takes the Net out of NEM.

Cheers, Wayne

Looks like they simply call it the "value of solar rate" so they don't attempt to call it NEM.

Value of Solar (VoS) Rates

Any residential or commercial customer with an on-site solar photovoltaic (PV) system (owned or leased) associated with the account and interconnected to the Austin Energy electric distribution system will be billed under the solar rate schedule (pdf).

austinenergy.com

I guess they do require a behind-the-meter-meter... https://austinenergy.com/wcm/connec...ue-of-SolarRider.pdf?MOD=AJPERES&CVID=nPpTUxv

 

[holeydonut]

Details of the Ex Parte meeting between the CPUC and SEIA were published. This gives you an idea of where the tweaks may be in the previous NEM 3.0 PD vs where it may end up after these latest talks. It sounds like Newsom wants the CPUC to give a little ground, so there is a chance you'll see the next NEM 3.0 PD "improve" in some areas based on what the SEIA is pushing for. SEIA and CALSSA have usually been aligned in what they have asked for.

https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M493/K762/493762600.PDF

Unfortunately, the talks are mostly around the market transition credit vs "ACC adder" as a way for a future NEM customer to better get value on their exports as a PV+ESS install vs PV-only.

At the meeting, the representatives of SEIA and Vote Solar reinforced their support for a transition mechanism based on as stepdown of retail rates as proposed in their comments on the Proposed Decision but noted that a properly constructed ACC adder using the correct data inputs could achieve that goal as well. In this regard, the solar representatives talked about use of the ACC Adder instead of a market transition credit as the more appropriate means to achieve a transition from an industry with solar only as a primary product to one in which solar + storage as the primary product. Moreover, in order to achieve an effective transition, the step down of the adder should be capacity based.

And of course SEIA is against a "gross consumption" meter and the legalities of even allowing that.

In addition to the ACC adder, SEIA and Vote Solar representatives spoke to the assessment of nonbypassable charges to behind the meter consumption, mainly focusing on the legal impediments to doing such.

But, this means the NEM 3.0 PD applying a $8 kWp AC per Month fee isn't even up for discussion. Other than the gross consumption NBC, I don't see any evidence that there is an alternative NBC/fixed-cost fee structure being talked about. So it would reason to me that the CPUC would just stick with their NBC language from the PD.

I really wish the SEIA/CPUC would discuss how to calculate whether a future homeowner could actually pull off a hypothetical NEM 3.0 project. I still cannot get my ghetto Excel models to show how a future PV+ESS install makes any economic sense with NEM 3.0. The ACC adder will help the interim installs during the transition period. But once the adder phases out in a few years, solar + ESS would need to be like 1/2 of what we are paying today to make any sense for a normal homeowner to even consider doing. And even then, having PV+ESS "no NEM" (no exports at all) still beats NEM 3.0 on a recurring/monthly basis.

 

[stopcrazypp]

Details of the Ex Parte meeting between the CPUC and SEIA were published. This gives you an idea of where the tweaks may be in the previous NEM 3.0 PD vs where it may end up after these latest talks. It sounds like Newsom wants the CPUC to give a little ground, so there is a chance you'll see the next NEM 3.0 PD "improve" in some areas based on what the SEIA is pushing for. SEIA and CALSSA have usually been aligned in what they have asked for.

https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M493/K762/493762600.PDF

Unfortunately, the talks are mostly around the market transition credit vs "ACC adder" as a way for a future NEM customer to better get value on their exports as a PV+ESS install vs PV-only.



And of course SEIA is against a "gross consumption" meter and the legalities of even allowing that.


But, this means the NEM 3.0 PD applying a $8 kWp AC per Month fee isn't even up for discussion. Other than the gross consumption NBC, I don't see any evidence that there is an alternative NBC/fixed-cost fee structure being talked about. So it would reason to me that the CPUC would just stick with their NBC language from the PD.

I really wish the SEIA/CPUC would discuss how to calculate whether a future homeowner could actually pull off a hypothetical NEM 3.0 project. I still cannot get my ghetto Excel models to show how a future PV+ESS install makes any economic sense with NEM 3.0. The ACC adder will help the interim installs during the transition period. But once the adder phases out in a few years, solar + ESS would need to be like 1/2 of what we are paying today to make any sense for a normal homeowner to even consider doing. And even then, having PV+ESS "no NEM" (no exports at all) still beats NEM 3.0 on a recurring/monthly basis.

Yeah, my gist is the fixed per kW fee isn't even being discussed, when that is the core issue. There is no indication that has been taken off the table. Frankly I don't think the per kWh credits really make that big a difference vs the fixed fee which will be the major killer for those that don't have much electricity demand. It's pretty much a given that regardless of what they work out per kWh, that it would be a pittance vs previous NEM deals, but the per kW fee will always be there even when your array may not be generating much.

 

[ohmman]

I got my install date from Tesla for my solar and battery upgrade (doubling my 9.5kW PV to 19.0kW and increasing to 4 PWs from 2). August 10th so I should be in good shape.

 

[aesculus]

I got my install date from Tesla for my solar and battery upgrade (doubling my 9.5kW PV to 19.0kW and increasing to 4 PWs from 2). August 10th so I should be in good shape.

Wow. You are pushing into @h2ofun territory.

 

[holeydonut]

I got my install date from Tesla for my solar and battery upgrade (doubling my 9.5kW PV to 19.0kW and increasing to 4 PWs from 2). August 10th so I should be in good shape.

Nice, are you going to get the resiliency SGIP? I feel like it's a no brainer to get as much solar as you can fit on a house under NEM 2.0. Ample batteries plus on prem non-renewables generation complete a system that results in the least amount of dependency on that wacky grid.

 

[Xepa777]

I’m a total noob forgive me questions. I feel like a ice vehicle owner trying to learn about EV for the first time hahahha.

1) if I only get solar panels and not power walls, does NEM 2 vs 3 matter to me?

2) Does NEM 2 vs 3 matter in making my power wall economical? Last I heard power walls aren’t economical and only matter if you care about other factors like power outages or stabilizing your eceltricity bill (I get that economic argument, but my counter point is I can just own more tesla shares).

3) does the virtual power plant program in California do anything for roi calculation on power walls? Or naw not a projected material number. I get “it depends on frequently of outages and your location” but give me a range estimate lol. I live in Bay Area peninsula.

If the payback period is like under 5 years then I’m good with solar. Sounds like that’s the case if I order it in august with a cash back credit card. Sounds like power wall that’s not gonna happen. Thoughts?

 

[h2ofun]

I’m a total noob forgive me questions. I feel like a ice vehicle owner trying to learn about EV for the first time hahahha.

1) if I only get solar panels and not power walls, does NEM 2 vs 3 matter to me?

2) Does NEM 2 vs 3 matter in making my power wall economical? Last I heard power walls aren’t economical and only matter if you care about other factors like power outages or stabilizing your eceltricity bill (I get that economic argument, but my counter point is I can just own more tesla shares).

3) does the virtual power plant program in California do anything for roi calculation on power walls? Or naw not a projected material number. I get “it depends on frequently of outages and your location” but give me a range estimate lol. I live in Bay Area peninsula.

If the payback period is like under 5 years then I’m good with solar. Sounds like that’s the case if I order it in august with a cash back credit card. Sounds like power wall that’s not gonna happen. Thoughts?

NEM3 is totally about solar panels

 

[sunwarriors]

I’m a total noob forgive me questions. I feel like a ice vehicle owner trying to learn about EV for the first time hahahha.

1) if I only get solar panels and not power walls, does NEM 2 vs 3 matter to me?

2) Does NEM 2 vs 3 matter in making my power wall economical? Last I heard power walls aren’t economical and only matter if you care about other factors like power outages or stabilizing your eceltricity bill (I get that economic argument, but my counter point is I can just own more tesla shares).

3) does the virtual power plant program in California do anything for roi calculation on power walls? Or naw not a projected material number. I get “it depends on frequently of outages and your location” but give me a range estimate lol. I live in Bay Area peninsula.

If the payback period is like under 5 years then I’m good with solar. Sounds like that’s the case if I order it in august with a cash back credit card. Sounds like power wall that’s not gonna happen. Thoughts?

ROI on batteries is usually not good, but a lot of that also depends on your usage. When I was doing calcs when I started my research, if you use a ton of power during on-peak and have a wide gap between peak rates and off peak rates, then batteries can have some ROI, but I just say don't expect any now. It does give you a lot of flexibility if laws change, IOUs get crazy/greedy, etc...I WFH too so my use has changed a lot.

In San Diego, this can be as wide as $0.102 vs. $0.639 (on EV-TOU-5 plan). To make ROI work, say you use 75%+ of your energy during peak rates. If you're forced to pay 6x the energy when you need it from the IOU and have no batteries, batteries can be ROI positive since you can drain your own batteries instead of paying the IOU 6x. Off-Peak (when sun is out) is at $0.391 so you sell when it's worth less as well.

Just do the math and see what you value more ($$ or having energy storage). Our power here is rock solid (for now) so it's not even for power outages. I honestly think this will change though with climate issues all over the world.

Also, NEM 2.0 good, NEM 3.0 bad.