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CPUC NEM 3.0 discussion

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Thanks. Yes looking through those documents Gross Consumption seems to be always defined as total energy consumed from the grid + self consumed energy. So indeed they are trying to pull a fast one here.
Seems like even the bill's authors were confused about the term:

"...the bill's authors and the Governor realized their mistake and have agreed to a set of formal actions clarifying that "gross consumption" in SB 846 only applies to the energy you buy from the utility. Not the solar energy you make and consume at home. The bill itself will not change. But the actions agreed to by the bill's authors carry enough legal weight to satisfy our concern."
 
Received an email update:

I am happy to report that the authors of SB 846 have agreed to clarify in writing that the bill will not impose a Solar Tax on the solar energy you produce and consume at home. This means you no longer need to call or email your Senator or Assemblymember!

In other words, you helped defeat the Solar Tax. Again.
This is the third time in the last year we have had to fight to stop a fast-moving Solar Tax proposal. In all three cases, your emails and calls made the difference.

Today, the public flooded state lawmakers with thousands and thousands of calls and emails. The message went through loud and clear.

Here are the details:

  • The problem with SB 846 was that it would have taxed all "gross consumption" to pay for keeping the Diablo Canyon nuclear power plant open. Section 9.l of the bill.
  • Earlier this year, the CPUC made it clear that they considered "gross consumption" to include both the energy you buy from the utility (fair) AND the energy you produce and consume at home (no way).
  • If the bill had passed without clarification, the CPUC would have implemented it according to their interpretation, and set the stage for the CPUC to impose not just a Diablo Canyon Solar Tax, but a slew of other Solar Taxes that could be as much as $600 / year for an average solar user.
But thanks to you, the bill's authors and the Governor realized their mistake and have agreed to a set of formal actions clarifying that "gross consumption" in SB 846 only applies to the energy you buy from the utility. Not the solar energy you make and consume at home. The bill itself will not change. But the actions agreed to by the bill's authors carry enough legal weight to satisfy our concern.

To be crystal clear, we have not defeated the Solar Tax once and for all. We have defeated this one proposal today. We still do not know what the CPUC will reveal in their revised proposal, which we expect on or before September 29th.

I would hope that the CPUC saw the depth and breadth of public opposition today and responds the same way their colleagues in the Legislature did. But we may need to do more organizing in the weeks and months to come to finally protect you and your neighbors from unnecessary and backwards-moving solar taxes. I hope you are up for it, because I think your voice is actually making a difference!

Thank you for your efforts today. This isn't the end, but every time we speak together in favor of everyone's right to make solar energy without unreasonable interference, our movement gets stronger.

– Dave Rosenfeld, Executive Director

P.S. You may have noticed that our website crashed a few times today. With more than 16,000 people trying to take action at one time, the flood of grassroots even exceeded our own capacity! Lesson learned, and we have upgraded our capacity to match our growing movement. Thank you for your patience and understanding.
 
Seems like even the bill's authors were confused about the term:

"...the bill's authors and the Governor realized their mistake and have agreed to a set of formal actions clarifying that "gross consumption" in SB 846 only applies to the energy you buy from the utility. Not the solar energy you make and consume at home. The bill itself will not change. But the actions agreed to by the bill's authors carry enough legal weight to satisfy our concern."
So an innocent mistake by a bill author that didn't know what specific word usage meant or a deliberate attempt by the real author from an IOU trying to slip the camel's nose under the tent?

Full disclosure, I also that it might just apply to grid imports at first, but after 15 minutes looking through the usage on cpuc.ca.gov it was obviously something more.
 
I mean, I'm not sure that is a total victory, since isn't part of the whole NEM battle the "price" of grid imports?

Or, to put it another way, I don't think it ended up as a charge on "NET" GRID IMPORTS. It could be gross imports.

I'm not even in IOU territory and I find this whole thing disgusting.
 
I mean, I'm not sure that is a total victory, since isn't part of the whole NEM battle the "price" of grid imports?

Or, to put it another way, I don't think it ended up as a charge on "NET" GRID IMPORTS. It could be gross imports.

I'm not even in IOU territory and I find this whole thing disgusting.
Part of NEM3.0 is the offsetting of grid imports vs grid exports, but the larger issue from the earlier proposal was the Grid Participation Charge (GPC) which would have leveed a monthly fee of $8 per kW that the system was AC-rated for at PTO. If a GPC is needed to fund the grid then it should be present for both solar and non-solar customers.
 
Part of NEM3.0 is the offsetting of grid imports vs grid exports, but the larger issue from the earlier proposal was the Grid Participation Charge (GPC) which would have leveed a monthly fee of $8 per kW that the system was AC-rated for at PTO. If a GPC is needed to fund the grid then it should be present for both solar and non-solar customers.
I agree. The grid is the grid for everyone, and we all need to support it.

The process of getting from a progressive grid fee ($/kWh consumed) to a site fee ($/meter/mo or $/account/mo), which is certainly regressive, I think is going to be a long, and political process.

Much as I enjoy sausage, I don't enjoy the process of watching it get made...
 
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I agree. The grid is the grid for everyone, and we all need to support it.

The process of getting from a progressive grid fee ($/kWh consumed) to a site fee ($/meter/mo or $/account/mo), which is certainly regressive, I think is going to be a long, and political process.

Much as I enjoy sausage, I don't enjoy the process of watching it get made...
To address impact on low income families they can use the same structure they have already that provides bill credits. Either way it will still be politically unpopular, given no one wants to pay extra fees (they only do this to solar users because we are a smaller group). The grid cost was never the issue the IOUs really wanted to address however, the real motivation is to prevent home solar from competing with utility installed solar. Home solar just also serves conveniently as a scape goat for problems with the grid.
 
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I agree. The grid is the grid for everyone, and we all need to support it.

The process of getting from a progressive grid fee ($/kWh consumed) to a site fee ($/meter/mo or $/account/mo), which is certainly regressive, I think is going to be a long, and political process.

Much as I enjoy sausage, I don't enjoy the process of watching it get made...
Hawaii just has a minimum bill if you have solar-- $26. That is really a pretty fair way of doing it IMO, and the price is reasonable.
 
Hawaii just has a minimum bill if you have solar-- $26. That is really a pretty fair way of doing it IMO, and the price is reasonable.
I think Florida does it this way also. And it should be a minimum bill for every user no matter how you reduce energy usage from the grid. And if some people still need subsidizing to pay the minimum monthly bill it should come from the general fund or other methods, not a fee on your utility bill.
 
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I don't know what to make from Dodd's statement. Is this just a CYA deflection or does he not understand that the CPUC has defined Gross Consumption to mean all electricity used by the customer both from the grid and from solar.
Tuesday afternoon the measure’s author, Sen. Bill Dodd, D-Napa, said in a statement that claims the bill would lead to a solar tax were ludicrous and false. Once disagreements had been smoothed over with environmental groups, he said in another statement: “I’m glad the solar industry came to their senses and recognized what the bill is intended to do.”

Read more at: https://www.sacbee.com/news/california/article265088989.html#storylink=cpy
 
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I don't know what to make from Dodd's statement. Is this just a CYA deflection or does he not understand that the CPUC has defined Gross Consumption to mean all electricity used by the customer both from the grid and from solar.

Regardless of deflection/CYA, I'm just glad the CALSSA and solar advocates caught this semantic issue and sought to address it before the legislation went through.

Personally, I think it's BS that the dozens of lawyers, policymakers, and advocates read "gross consumption" and didn't bother to ask for that term to be clarified in the policy language until now. Any first year who barely passed the LSAT would even be keen to the risk that "gross consumption" isn't common knowledge and should be defined.

I've done enough deals to know key omissions that sneak past all these high-powered-smart-as-hell experts is done with malice and completely intentional. Lucky for those being sneaky; intention is very hard to prove. But such tactics are the most common way sneaky SOBs try to game the system and get things in their favor.

BTW, if you want to read more fun stuff today, take a look at the NEM 2 lookback study to remind yourself why NEM 3.0 is going to be a swift kick in the face of the residential solar industry. Basically the CPUC's thinktank believe NEM 2.0 was a grand error, and NEM 3.0 will fix those errors. NEM 3.0 isn't meant to be some gradual evolution; it is meant to repair many years of "bad NEM 2.0" policy.

 
I don't know what to make from Dodd's statement. Is this just a CYA deflection or does he not understand that the CPUC has defined Gross Consumption to mean all electricity used by the customer both from the grid and from solar.
I'm convinced many of our legislators don't understand the details of the bills they introduce and approve. He was probably just putting in what PG&/CPUC was telling him to. But I'm sure PG&E & CPUC understood what gross consumption meant. This just shows the ignorance of our legislators.
 
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I'm not opposed to a minimum "meter" bill - but IMO it should be the same for all customers, not just solar customers. And the minimum likely should be lower than $26 in most cases.
Given everything that has been discussed above, I suspect that in California it would be much more than $26; let's do the math. If a typical bill is $200 and the non-generation portion is 70%, that would be a meter fee more like $140/month, and my guess would be more like $180+, to cover costs for low income groups. I'm not trying to be inflammatory, nor am I saying that I think they are reasonable, just recognizing what the grid costs are here in California.
(Bill estimate from Cost of Electricity in California | EnergySage)

All the best,

BG
 
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Man, I've spoken with 6 solar shops. None of them will touch an existing install to add new panels. My Enphase 3C Envoy has open spots for 2 more home runs, and my wiring can support the extra current from 12 more panels and IQ7+ micros.

But these "certified Enphase installers" all say Enphase doesn't make modular equipment. So if I want more solar with IQ7+, I need a second Envoy. They said once I provisioned my Envoy for the 23 panels currently connected to it... that's it. No more current can be aggregated at the Envoy. Like whut.

I dunno about ya'll but I think PG&E may have won this one. I can't charge my EV from solar; need to charge the EV from PG&E's super awesome grid.
 
Given everything that has been discussed above, I suspect that in California it would be much more than $26; let's do the math. If a typical bill is $200 and the non-generation portion is 70%, that would be a meter fee more like $140/month, and my guess would be more like $180+, to cover costs for low income groups. I'm not trying to be inflammatory, nor am I saying that I think they are reasonable, just recognizing what the grid costs are here in California.
(Bill estimate from Cost of Electricity in California | EnergySage)

All the best,

BG
I was curious and went to look at PG&E's earnings report for the last quarter. Unfortunately it isn't broken out between residential and commercial customers, so for a worst case analysis I am using the 4.8 million residential accounts + 0.6M commercial accounts number that they publish and lump them together as 5.4M accounts. Commercial numbers should be larger than residential, so this is a worst case for just us residential people.
  • Electric Revenue - $3,690M = $227.78/month/account
  • Cost of Electricity -$780M = $48.15/month/account
  • Operating & Maintenance $2,291 = $141.42/month/account
In the case of the operating and maintenance portion it isn't split between electric and natural gas, so you can't assign it all to electric.
  • Natural Gas Revenue = $1,428M = 27.9% of Total revenue
  • Cost of Natural Gas = $359M = 31.5% of cost of electric + NG
So taking a swag I will say that the operating and maintenance is split 70% electric to 30% natural gas. This would take the electric portion from $141.42/month/account down to $98.99/month/account. How much of that should be a fixed fee? I think maybe 50%, so that would be $49.50/month. Realistically this should maybe be 25-30% lower with commercial accounts paying a significantly more than a single residential account.