CPUC NEM 3.0 discussion

[holeydonut]

It seems like the whole point of the $8/kW fee is for the IOUs to try to recover lost "revenue" due to generation and usage behind the meter. I don't think they're going to make it easy to have a non exporting grid tied system.

Yeah, I'm a pessimist and assume by the time this all shakes out, if a non-exporting residential solar (or with batteries) system is grid-tied at all, it will have a $8/month/kWh charge.

Like imagine there is a clone of wwhitney that works for PG&E. He's reading all this stuff and thinking about how wwhitney is going to get around the rules. But since evil-Wayne has the pen on the NEM 3.0 PTO form, he can put in language to keep good-Wayne from doing clever ideas.

evil-Wayne has a pension that needs to be funded and paid by PG&E. good-Wayne only gets compensated with upvotes provided TMC users.

 

[h2ofun]

Yeah, I'm a pessimist and assume by the time this all shakes out, if a non-exporting residential solar (or with batteries) system is grid-tied at all, it will have a $8/month/kWh charge.

Like imagine there is a clone of wwhitney that works for PG&E. He's reading all this stuff and thinking about how wwhitney is going to get around the rules. But since evil-Wayne has the pen on the NEM 3.0 PTO form, he can put in language to keep good-Wayne from doing clever ideas.

evil-Wayne has a pension that needs to be funded and paid by PG&E. good-Wayne only gets compensated with upvotes provided TMC users.

The question is can one do a non export with PGE today? Would PGE even need to be involved?

 

[holeydonut]

The question is can one do a non export with PGE today? Would PGE even need to be involved?

Yes, today per PG&E's mammoth Rule 21 compliance doc, a non-exporting PV+ESS system would still need to be PTO'd with PG&E if the non-exporting system is still tied to a common system served by PG&E.

But today, your gas generator has a safety switch to disconnect the house from the grid before the generator can power it. So your gas generator doesn't fall into this rulemaking on PG&E tariffs and interconnect. Unfortunately, I can't really tell a PV+ESS that was also hard-disconnected before feeding the house/micro-grid could bypass all this PG&E mumbo jumbo as well.

And of course today there is no magical grid benefits charge. So it's not clear to anyone yet whether PG&E would have a non-exporting "envelope option" be exempt from the fee in the future. I still think PG&E employs may evil-wwhitney's who will probably find a way to ensure good-wwhitney pays some $$$.

PS, I don't think everyone working for PG&E to be evil; just enough to make me not like PG&E as a whole

https://www.pge.com/tariffs/assets/pdf/tariffbook/ELEC_RULES_21.pdf

 

[wwhitney]

But today, your gas generator has a safety switch to disconnect the house from the grid before the generator can power it. So your gas generator doesn't fall into this rulemaking on PG&E tariffs and interconnect. Unfortunately, I can't really tell (if) a PV+ESS that was also hard-disconnected before feeding the house/micro-grid could bypass all this PG&E mumbo jumbo as well.

From my brief review, I feel 80% confident that it would. First, it's exactly analogous to the ATS/generator situation. And second, it would not meet the definition of Parallel Operation in Rule 21.

Cheers, Wayne

 

[holeydonut]

From my brief review, I feel 80% confident that it would. First, it's exactly analogous to the ATS/generator situation. And second, it would not meet the definition of Parallel Operation in Rule 21.

Cheers, Wayne

Do you think in the future we'll need the energy gateway (or smart meter or whatever) to actually open the relay when the PV and ESS are sending energy to the home?

Like right now, my solar is generating to run my house and charge my batteries. But, the relay is still closed to the extent that PG&E's grid is exposed (slightly) to my home's microgrid. Technically any little blip of the PCS software or the CT measurement could cause energy to sneak over to PG&E's side of the meter. This also means when I have to draw energy from PG&E after 11pm, the flow is there without any change to the relay.

I feel like for your ATS/non-export situation to work in the future, the home PV+ESS system would need to actually open the relay or truly disconnect a future system from the grid in order to sneak around the Rule 21 stuff. Much like your gas generator where there's probably a physical plate that opens your main disconnect breaker before the generator can power on. Problem is at night if the batteries are depleted, grid energy has to go to the house, through a closed relay.

I'm thinking an evil-clone-version of wwhitney will modify the language in some weird way. Like maybe say that any home which relies on grid access on at least 100 days in a year cycle will be required to seek interconnection for on-site generation. And, to me, my current interconnection form requires storage to be included in on-site generation inverter size

Since PG&E would now have an interconnection agreement and a known quantity of solar+ESS "size" at the property, there could be fees even with a non-export agreement.

I'm really not happy with this evil-clone-wwhitney that my brain has concocted. evil-Wayne is too smart for his own good.

 

[wwhitney]

I feel like for your ATS/non-export situation to work in the future, the home PV+ESS system would need to actually open the relay or truly disconnect a future system from the grid in order to sneak around the Rule 21 stuff.

Right, my understanding is you'd either (a) need a non-export interconnection agreement or (b) disconnect from the grid when your inverters are running. With the as-previously-mentioned cost in (b) of having enough inverter power to run all your loads.

In this context it's worth mentioning again the pilot program the PUC approved to allow (residential ?) non-export installations up to 30 kW (presumably combined PV + ESS) without prior approval, just notification to the IOU. I post the link earlier in the thread.

Cheers, Wayne

 

[h2ofun]

From my brief review, I feel 80% confident that it would. First, it's exactly analogous to the ATS/generator situation. And second, it would not meet the definition of Parallel Operation in Rule 21.

Cheers, Wayne

I do not want something like my generator which only goes on when the grid is down. I just want non export. So if my batteries are full, and the house is maxed out, then I want the inverters to be turned off so no more solar until house or batteries need

 

[RKCRLR]

Or a potential "win-win" for existing solar generators would be for the utility to waive the $8/kW connection fees in return for the utility getting to keep the exported electricity. Or perhaps a break even approach where the connect fees don't exceed the compensation for exports. But that would probably still kill future installations.

 

[miimura]

Or a potential "win-win" for existing solar generators would be for the utility to waive the $8/kW connection fees in return for the utility getting to keep the exported electricity. Or perhaps a break even approach where the connect fees don't exceed the compensation for exports. But that would probably still kill future installations.

I like your thinking, but they want that money from everyone. The solar system size relative to your usage varies a lot and your "grid contribution" would vary a lot on this basis.

Personally, the biggest problem I have with the flat $/kW fee is that people with solar systems that are small relative to their usage are paying this fee AND they're still buying a lot of kWh from the utility which already has grid support included. I think there should be a $/kW based Minimum Charge to replace the existing minimums and reduce the export credit. Crediting only the Generation portion of the unbundled rates might be an easy target. That would also make it easy for the CCA customer case - they only get credit for whatever their CCA gives them.

 

[holeydonut]

Or a potential "win-win" for existing solar generators would be for the utility to waive the $8/kW connection fees in return for the utility getting to keep the exported electricity. Or perhaps a break even approach where the connect fees don't exceed the compensation for exports. But that would probably still kill future installations.

The ACC calculator already estimates that by 2030 your noon time solar is worth $0.025. So PG&E will not be paying you for your exported energy and they’ll charge you $8/kW/month.

That’s a “win-win” for them right? Oh wait… that’s a lose-lose

 

[getakey]

If you only use 330kWH/mo why do you have solar? Also, if you only use 330kWH how will your minimum bill be $100 with solar?


Hence, we find a grid benefits charge in combination with the retail rate will
provide improved accuracy, in the case of net energy metering customers. The
addition of the grid benefits charge will lead to just and reasonable rates for all
customers, decreasing the cost shift currently created by the inaccuracies related
to the two-way street of imports and exports. Further, we agree that net energy
metering customers cause costs even when not directly importing energy from
the grid. As NRDC described, net energy metering customers intermittently
reduce usage depending upon the performance of the solar system. Thus, the
grid must be always prepared for the intermittent decrease and increase of
usage.

You should really read the proposed decision.

the same could be said for Utility Solar and Wind

 

[brian.c]

Or a potential "win-win" for existing solar generators would be for the utility to waive the $8/kW connection fees in return for the utility getting to keep the exported electricity. Or perhaps a break even approach where the connect fees don't exceed the compensation for exports. But that would probably still kill future installations.

I did the calculations on that, and the fee is much more than the exported energy, at least for me. My fee would be about $1200 a year, my export at .05 is worth 300. So I would be all for, give them the exported and remove the fees... This would basically just remove NEM completely... But they know, people will buy more batteries, and they will get less and less exported. We would end up only needing to buy in Dec/Jan... Their investors are not gonna like that. To me, its clear this is a money grab. If they just wanted to even things out, they could have removed NEM like other states. I wonder what other states have for grid fees? Since PG&E kind of bakes it into the rates, seems like they should first look at changing that. I would be interesting what the grid fee would be, if they split it equally among all customers. Right now the minimum charge is $10, which seems like someone who uses very little energy is not "paying their fair share of the grid".

 

[helloSF]

I wonder how many people quit paying on those leases and loans when they realize their monthly lease/loan payment + PG&E fees cost more than no solar at all. I know when I looked at the leases, you did not save that much over your normal PG&E bill. But you were generating green energy, and saving a few bucks.

I think its pretty clear though, CPUC and the IOUs could care less about the average family. They care about making profits, making their investors happy.In a normal business we could go elsewhere, but they have a monopoly and we have no choice. We can't even disconnect if we thought we could be 100% off grid. The way this is structured, you can not even lower your usage to lower costs. This bill will only hurt middle and low income families, does anyone think millionaires are too concerned about a few thousand a year? The amount we lose will hurt us financially, it will be noticeable, it will force us to cut spending elsewhere.

On another note to those who might think this is a good idea, once they get approval to raise fees on certain groups of people, based on their perceived costs, be prepared to be targeted in the future. Live in the mountains or out in the country, I can see them tacking on a $200 monthly fee to bury the lines etc. I mean its only fair if we are worried about cost shifting... Why should I have to pay more for your choices on where to live?

The IOU's in the CPUC proceeding have claimed that that Solar Customers are bypassing fixed charges and they see that as an inequity and a disparity that needs to be addressed. The "Fairness" argument is simple; the CPUC cannot allow "wealthy" home and landowners the right to bypass their proportionate share of grid operating expenses. The $8 kw/mo proposed charge is a clunky way to address the perceived inequity. A more rational approach would to charge all a grid access charge and create a rate structure that incentivizes the adoption of solar+storage that reduces total distribution system expense.

The IOU's prioritize profits above all else including safety. If you read through the recent GRCs for each of the IOU's you will see that rates under each IOU will be increasing wildly over the next 5 years for all customer classes. The rate increases are a byproduct of the increased capital investment authorized by the CPUC. Under-grounding power lines is extremely expensive; earlier this year PG&E announced its intention to underground about 10k mi of its above-ground electric distribution power lines in areas at high risk of wildfire. At $4M per mile, what do you think this will do to rates?

 

[sunwarriors]

The IOU's in the CPUC proceeding have claimed that that Solar Customers are bypassing fixed charges and they see that as an inequity and a disparity that needs to be addressed. The "Fairness" argument is simple; the CPUC cannot allow "wealthy" home and landowners the right to bypass their proportionate share of grid operating expenses. The $8 kw/mo proposed charge is a clunky way to address the perceived inequity. A more rational approach would to charge all a grid access charge and[FONT=-apple-system, BlinkMacSystemFont, Segoe UI, Roboto, Helvetica, Arial, sans-serif, Apple Color Emoji, Segoe UI Emoji, Segoe UI Symbol] create a rate structure that incentivizes the adoption of solar+storage that reduces total distribution system expense.[/FONT]

The IOU's prioritize profits above all else including safety. If you read through the recent GRCs for each of the IOU's you will see that rates under each IOU will be increasing wildly over the next 5 years for all customer classes. The rate increases are a byproduct of the increased capital investment authorized by the CPUC. Under-grounding power lines is extremely expensive; earlier this year PG&E announced its intention to underground about 10k mi of its above-ground electric distribution power lines in areas at high risk of wildfire. At $4M per mile, what do you think this will do to rates?

Do solar owners cost the IOUs more to support/run the grid?

I still like the idea of everyone paying a flat fee to support the grid, NON-solar owners included at the same charge maybe tied to panel amp service like someone else mentioned. There is no reason to carve out and penalize solar owners when again, non-solar users are using the grid just as much/more. The whole rich argument is just to deflect blame on the IOUs for their poor mismanagement/investments and instead, fund bonuses instead.

With so few installs having batteries too, anyone who had solar under NEM1.0 and now, has to charge their EV regularly is probably not zeroing out their usage honestly, especially if they don't have a L2 charger and just runs it after work.

The 5c export just makes it not worthwhile to export as it doesn't zero out your existing $8 charge anyways so similar to other states, they might as well just eliminate NEM flat out, but we see every state that has done that cause the death of solar in their state and they backtrack later so removing NEM usually leads to less solar investment.

Unlike Hawaii, it doesn't sound like CA IOUs have as much issues absorbing the solar generation (someone mentioned they push it to AZ and I think I've read articles saying they give the energy away free). They probably just need to buy a lot more storage to sell back later. Investing in underground lines just seems like what a normal business should be doing and something everyone needs to pay for (not only solar folks).

 

[RKCRLR]

The IOU's in the CPUC proceeding have claimed that that Solar Customers are bypassing fixed charges and they see that as an inequity and a disparity that needs to be addressed. The "Fairness" argument is simple; the CPUC cannot allow "wealthy" home and landowners the right to bypass their proportionate share of grid operating expenses. The $8 kw/mo proposed charge is a clunky way to address the perceived inequity. A more rational approach would to charge all a grid access charge and create a rate structure that incentivizes the adoption of solar+storage that reduces total distribution system expense.

The same argument of bypassing fixed charges could be applied to anyone that took steps to use less electricity than average.

How about people that replaced incandescent lights with LED lights, added more insulation to their houses, replaced inefficient appliances with efficient ones, etc.? And what if you just decided to be more conservative? Aren't they bypassing fixed charges?

And what about smaller homes and apartments? And houses in moderate climates? They use less electricity so are bypassing fixed charges.

 

[h2ofun]

The same argument of bypassing fixed charges could be applied to anyone that took steps to use less electricity than average.

How about people that replaced incandescent lights with LED lights, added more insulation to their houses, replaced inefficient appliances with efficient ones, etc.? And what if you just decided to be more conservative? Aren't they bypassing fixed charges?

And what about smaller homes and apartments? And houses in moderate climates? They use less electricity so are bypassing fixed charges.

do not use facts and logic

 

[helloSF]

Do solar owners cost the IOUs more to support/run the grid?

I still like the idea of everyone paying a flat fee to support the grid, NON-solar owners included at the same charge maybe tied to panel amp service like someone else mentioned. There is no reason to carve out and penalize solar owners when again, non-solar users are using the grid just as much/more. The whole rich argument is just to deflect blame on the IOUs for their poor mismanagement/investments and instead, fund bonuses instead.

With so few installs having batteries too, anyone who had solar under NEM1.0 and now, has to charge their EV regularly is probably not zeroing out their usage honestly, especially if they don't have a L2 charger and just runs it after work.

The 5c export just makes it not worthwhile to export as it doesn't zero out your existing $8 charge anyways so similar to other states, they might as well just eliminate NEM flat out, but we see every state that has done that cause the death of solar in their state and they backtrack later so removing NEM usually leads to less solar investment.

Unlike Hawaii, it doesn't sound like CA IOUs have as much issues absorbing the solar generation (someone mentioned they push it to AZ and I think I've read articles saying they give the energy away free). They probably just need to buy a lot more storage to sell back later. Investing in underground lines just seems like what a normal business should be doing and something everyone needs to pay for (not only solar folks).

Anyone (solar/non solar) who lives in a Wildland Urban Interface (WUI) will ultimately cost more to serve because of the expense involved in hardening the distribution system and rising utility insurance rates. Addressing wildfire risk means that IOU's will decrease system reliability through public power power shut off (PSPS) events while at the same time saddle all Californians with even higher utility rates.

Ultimately, if California is to maintain energy access for middle and low-income residents, utilities must spend less....and certain remote customers will likely have to spend more for grid access/reliability.

 

[getakey]

Do solar owners cost the IOUs more to support/run the grid?

I still like the idea of everyone paying a flat fee to support the grid, NON-solar owners included at the same charge maybe tied to panel amp service like someone else mentioned. There is no reason to carve out and penalize solar owners when again, non-solar users are using the grid just as much/more. The whole rich argument is just to deflect blame on the IOUs for their poor mismanagement/investments and instead, fund bonuses instead.

With so few installs having batteries too, anyone who had solar under NEM1.0 and now, has to charge their EV regularly is probably not zeroing out their usage honestly, especially if they don't have a L2 charger and just runs it after work.

The 5c export just makes it not worthwhile to export as it doesn't zero out your existing $8 charge anyways so similar to other states, they might as well just eliminate NEM flat out, but we see every state that has done that cause the death of solar in their state and they backtrack later so removing NEM usually leads to less solar investment.

Unlike Hawaii, it doesn't sound like CA IOUs have as much issues absorbing the solar generation (someone mentioned they push it to AZ and I think I've read articles saying they give the energy away free). They probably just need to buy a lot more storage to sell back later. Investing in underground lines just seems like what a normal business should be doing and something everyone needs to pay for (not only solar folks).

Totally agree. I wonder how this will impact CCAs

 

[brian.c]

The same argument of bypassing fixed charges could be applied to anyone that took steps to use less electricity than average.

How about people that replaced incandescent lights with LED lights, added more insulation to their houses, replaced inefficient appliances with efficient ones, etc.? And what if you just decided to be more conservative? Aren't they bypassing fixed charges?

And what about smaller homes and apartments? And houses in moderate climates? They use less electricity so are bypassing fixed charges.

The fees and export costs will be more than what I paid on average before going solar. One big reason going solar was to be able to use more energy. Of course, this was 10 years ago, but if I were to go back to what I did in the past, there would not be that big a difference, other than me being miserable and hot in the summer. If I remove the EV, and A/C, my usage at .30p/kw is less than my fee+exports. This is based on usage of about 8000kwh per year, which is probably higher than what I would use if I do not run A/C or charge EV. Usage before the EV averaged between 10-11k kwh per year. I remember years back (around the time I was installing solar) talking with my neighbor, his bill was 3x what mine was. So I guess even before solar I was not paying my fair share.

 

[Zorg]

BTW, based on what I read, I think that the $8 per month fee is only for SCE. PGE is $6.7 or so.