h2ofun
Active Member
I believe it does, both solar and batteriesI've posted this a few times but people don't seem to interpret the language in the CPUC proposal the same as me.
Technically I can see an interpretation where the ESS also contribute to the kW in a "system". So, maybe a 10 kWp AC solar system with 2x Powerwall 2's (10 kW total for the two) would be a 20 kW system.
Consider my NEM2-MT interconnect agreement. It clearly lists my total system size as 6.7 kW of solar + 15.0 kW 3x PW2 = 21.7 kW total "facility". I would expect a NEM 3.0 person with a system identical as mine to pay PG&E 21.7 x $8.00 per month if this bogus proposal passes.
I asked Sunrun to submit my PTO application as a 6.7 kW system so PG&E wouldn't bump my total system size over 20 kW; which would require a higher tier of insurance coverage naming PG&E as an insured. PG&E countered immediately saying ESS is part of a system size and I need to update the form.
Edit: @h2ofun, does your PTO agreement list your system size as 32 kW or 57 kw (including 5x Powerwalls)?
I think we need to be ultra careful with how the CPUC and the IOUs ultimately enforce this. Unless someone expressly adds language to define what is a "residential customer's system", you should include the ESS in the size because the IOUs have set precedent that they interpret system size this way.
Quote from the CPUC propsal:
I am still wanting 100% clarity. What does the 15 years nem2 get? No 8 buck fee? Still get residential rate when sending back?