CPUC NEM 3.0 discussion

[skepticcyclist]

Sorry if I'm being obtuse, but you mean even the proposed PV fees? I'm talking about for new customers or upgrading customers. I'm on NEM 2.0 right now and will have my grandfather period, I'm just thinking about if I wanted to double the size of my array after the change and it would push me into NEM 3.0. If I go non-export, shouldn't I just pay like a non-PV consumer?

Even 2.0 customers have basic fees they pay while being grid connected (this varies by utility provider and type of plan.) For me I currently pay about $15/month in fees alone, even if I do not use a single watt of power from the grid. I am also required to be connected to the grid.

 

[ohmman]

Even 2.0 customers have basic fees they pay while being grid connected (this varies by utility provider and type of plan.) For me I currently pay about $15/month in fees alone, even if I do not use a single watt of power from the grid. I am also required to be connected to the grid.

Yes, I’m aware. I must be having a tough time being clear. I’m saying this:

If you have a no export agreement, meaning you no longer export to the grid and don’t have a NEM arrangement as a result, then you can connect with “standard” non-NEM service and avoid any NEM 3.0 fees. So you can have self-generation+ESS with supplemental grid connectivity when it’s needed (winter).

If I were to be in a position where the alternative was to pay $8/kW/month of installed capacity and have monthly true-ups vs annual true-ups, this is what I would likely do. It satisfies the requirement of grid connectivity but allows as much PV as I’d like to install at home. I’d just curtail when overproducing, and plan properly to charge my EVs and batteries versus getting paid wholesale rates that are being arbitraged to my neighbors.

 

[Zorg]

Yes, I’m aware. I must be having a tough time being clear. I’m saying this:

If you have a no export agreement, meaning you no longer export to the grid and don’t have a NEM arrangement as a result, then you can connect with “standard” non-NEM service and avoid any NEM 3.0 fees. So you can have self-generation+ESS with supplemental grid connectivity when it’s needed (winter).

If I were to be in a position where the alternative was to pay $8/kW/month of installed capacity and have monthly true-ups vs annual true-ups, this is what I would likely do. It satisfies the requirement of grid connectivity but allows as much PV as I’d like to install at home. I’d just curtail when overproducing, and plan properly to charge my EVs and batteries versus getting paid wholesale rates that are being arbitraged to my neighbors.

But if your PV is grid tied, don't you need a PTO from the utility before turning it on? Can you get a PTO without a NEM agreement?

 

[miimura]

But if your PV is grid tied, don't you need a PTO from the utility before turning it on? Can you get a PTO without a NEM agreement?

In this kind of setup where you don't feed the grid, you either use solar charge controllers to put the solar straight into a battery or you AC couple grid-tie inverters to an off-grid battery inverter. In order to avoid PTO and NEM agreement, you would need to separate your loads on your solar micro-grid from the actual grid. Rule 21 talks about parallel operation. That is what you need to avoid. This means that you have to have large inverters that can completely power your loads without any grid support. Of course, you can still use the grid as backup if your batteries and solar fall short.

 

[ohmman]

In this kind of setup where you don't feed the grid, you either use solar charge controllers to put the solar straight into a battery or you AC couple grid-tie inverters to an off-grid battery inverter. In order to avoid PTO and NEM agreement, you would need to separate your loads on your solar micro-grid from the actual grid. Rule 21 talks about parallel operation. That is what you need to avoid. This means that you have to have large inverters that can completely power your loads without any grid support. Of course, you can still use the grid as backup if your batteries and solar fall short.

Per the non-export agreement, one of these conditions will satisfy the requirement. Adding something to stop power from flowing backwards to the grid is really all that's necessary from my reading. That said, I understand that to provide consistency of power in the home when blending sources, there are internal needs that are more complex.

Non-export interconnection is available to all types of generator technologies and sizes where one of the following is true:

1. A reverse-power protection device will be installed.
2. An under-power protection device will be installed.
3. The generating facility interconnection equipment has been certified as non-islanding, and the incidental export of power will be limited by the design of the interconnection.
4. The gross nameplate rating of the generating facility will not exceed 50 percent of the minimum electrical load of the host customer's facility over the previous 12 months.
5. The generating facility completely offsets the facility load by being both (a) optimally sized to meet its peak demand with load following functionality on the generator controls, and (b) ensuring conditional (inadvertent) export of electric power from the generation facility to the distribution provider's distribution or transmission system, occurring no more frequently than twice in any 24-hour period. Also, the exports are greater than two seconds, but no more than 60 seconds. If this option is selected, option 1 or 2, above, will also be required.

 

[h2ofun]

Per the non-export agreement, one of these conditions will satisfy the requirement. Adding something to stop power from flowing backwards to the grid is really all that's necessary from my reading. That said, I understand that to provide consistency of power in the home when blending sources, there are internal needs that are more complex.

If this passes, I assume someone will come up with a solution, hoping Tesla

 

[Sky Blue]

Yes, I’m aware. I must be having a tough time being clear. I’m saying this:

If you have a no export agreement, meaning you no longer export to the grid and don’t have a NEM arrangement as a result, then you can connect with “standard” non-NEM service and avoid any NEM 3.0 fees. So you can have self-generation+ESS with supplemental grid connectivity when it’s needed (winter).

If I were to be in a position where the alternative was to pay $8/kW/month of installed capacity and have monthly true-ups vs annual true-ups, this is what I would likely do. It satisfies the requirement of grid connectivity but allows as much PV as I’d like to install at home. I’d just curtail when overproducing, and plan properly to charge my EVs and batteries versus getting paid wholesale rates that are being arbitraged to my neighbors.

Ohmman, what you are writing is perfectly clear and I agree with you. In fact, if the CPUC adopts NEM 3, that's what I plan to do when my NEM contract expires in two years. I'll put an export limiter on my inverter to stop sending my surplus PV output to PG&E. Instead, I'll add batteries to my system and charge them with my surplus PV production. I'll select a new rate plan, probably E-1, to replace my expired NEM contract. No more $8/kW/installed capacity/month NEM 3 charge. Since my PV array and batteries will provide most of the electricity I need my PG&E bills won't amount to much more than the $10/month cover charge that everyone pays. And with my battery backup I won't lose power every time PG&E sets fire to a nearby forest.

 

[Redhill_qik]

Ohmman, what you are writing is perfectly clear and I agree with you. In fact, if the CPUC adopts NEM 3, that's what I plan to do when my NEM contract expires in two years. I'll put an export limiter on my inverter to stop sending my surplus PV output to PG&E. Instead, I'll add batteries to my system and charge them with my surplus PV production. I'll select a new rate plan, probably E-1, to replace my expired NEM contract. No more $8/kW/installed capacity/month NEM 3 charge. Since my PV array and batteries will provide most of the electricity I need my PG&E bills won't amount to much more than the $10/month cover charge that everyone pays. And with my battery backup I won't lose power every time PG&E sets fire to a nearby forest.Is t

What analysis have you done that shows that going non-export would be a lower cost for you versus NEM 3.0 or are you planning on doing this out of spite?

The analysis will be different for every home based on their usage and system, but in my case switching to non-export and paying full price on all of the imports would worse than paying the $8/kW/month. Specifically, for 2021 my imports would have cost $820.12, but with my 7.6kW system (assuming invertor limit versus raw panels) it would cost me $668.80.

I'm a net exporter and I have my Powerwalls configured to only power the house during Peak. Changing to self powered mode would lower the amount of my imports and may it get it below the solar penalty fee, but I would also end up with the PV cycling during the day as the Powerwalls filled to 100%, took over the house load disabling the PV system until they discharged to xx% and the PV was reenabled to power the house and charge the PWs again. So, I don't know how much this would reduce the imports overall.

There is also the one-time cost to install the export prevention equipment that would need to be factored in. No idea how much that would be.

 

[EVDRVN]

If this passes, I assume someone will come up with a solution, hoping Tesla

I do, we all cut solar for a day or week during peak loads and watch how fast they reverse this. The actual power now lies with the solar customers pardon the pun. 12,000 MW worth.

 

[miimura]

Per the non-export agreement, one of these conditions will satisfy the requirement. Adding something to stop power from flowing backwards to the grid is really all that's necessary from my reading. That said, I understand that to provide consistency of power in the home when blending sources, there are internal needs that are more complex.

I don't think "non-export" will be sufficient to avoid the $8/kW/mo fee. A solar inverter with a limiter device is still grid tied and operating in parallel with the grid. I think you will have to go further and completely decouple the solar in order to avoid the Interconnection agreement altogether. I should really sketch out what I mean with a single line diagram.

 

[sunwarriors]

What analysis have you done that shows that going non-export would be a lower cost for you versus NEM 3.0 or are you planning on doing this out of spite?

The analysis will be different for every home based on their usage and system, but in my case switching to non-export and paying full price on all of the imports would worse than paying the $8/kW/month. Specifically, for 2021 my imports would have cost $820.12, but with my 7.6kW system (assuming invertor limit versus raw panels) it would cost me $668.80.

I'm a net exporter and I have my Powerwalls configured to only power the house during Peak. Changing to self powered mode would lower the amount of my imports and may it get it below the solar penalty fee, but I would also end up with the PV cycling during the day as the Powerwalls filled to 100%, took over the house load disabling the PV system until they discharged to xx% and the PV was reenabled to power the house and charge the PWs again. So, I don't know how much this would reduce the imports overall.

There is also the one-time cost to install the export prevention equipment that would need to be factored in. No idea how much that would be.

It's too early to know what will happen, but assuming someone is on NEM3.0 and someone correct me if I am wrong, but I think the annual true up is eliminated in NEM3.0.

That means you can't bank credits anymore in the summer and use them during the winter. In that scenario, you are at $10-$16/month in the summer, but most folks are paying a hundred or a couple in the winter months. For 4-5 months of low winter solar, your electric bills maybe $500-$1000 from that alone. Add in that $8/kW and you are now at $1.3k-$1.7k?

Ideally, if you can go no export, try to see if you can charge your powerwalls from the grid now with some EV plan. SDG&E has one at $0.09/kWh (but $16/month minimum). Sun/no sun/no export, charge up batteries cheap overnight, use from 4-9pm. I assume grid charging isn't allowed if you got a tax credit, but people will prob do their own math and remove bad placed panels (north/ne), run numbers to see if repaying the credit is worth it to allow you to charge PWs from the grid.

 

[miimura]

By the time I get kicked out of NEM1, I will have passed the 5 years required renewable charging from the tax credit.

 

[sunwarriors]

By the time I get kicked out of NEM1, I will have passed the 5 years required renewable charging from the tax credit.

Is 5 years what's needed for batteries to only charge from the grid?

 

[miimura]

Is 5 years what's needed for batteries to only charge from the grid?

The terms of the tax credit require batteries to be charged 100% from on-site renewable energy for 5 years to qualify for the solar tax credit.

 

[holeydonut]

The terms of the tax credit require batteries to be charged 100% from on-site renewable energy for 5 years to qualify for the solar tax credit.

I hope after that, Tesla makes it so Powerwalls can be used for TOU shifting with grid energy assuming there are clouds or wildfire ash or something keeping solar from being an effective generator. I guess PG&E could charge $8 per kW per month for this benefit... so maybe it's not worth it.

 

[Merrill]

So still trying to determine when my 15 year grandfather clause kicks in, when I got my powerwalls installed they kicked me off of E1 and NEM1 to TOUC and NEM2. I’m wondering if that will be the start of the 15 years.

 

[gene]

So still trying to determine when my 15 year grandfather clause kicks in, when I got my powerwalls installed they kicked me off of E1 and NEM1 to TOUC and NEM2. I’m wondering if that will be the start of the 15 years.

I believe that when you acquired NEM2 is when your grandfather clause would begin.

 

[gene]

"The survey’s results spell doom for the California residential solar industry: 95.4% of respondents said they would no longer buy solar under a decision that lowers payments and adds a grid access charge. "

Survey says 95% of shoppers would not buy solar under NEM 3.0

Andy Sendy of SolarReviews explained to <b>pv magazine</b> why he believes the proposed decision would kill the California solar industry, and to offer a possible alternative.

pv-magazine-usa.com

 

[skepticcyclist]

"The survey’s results spell doom for the California residential solar industry: 95.4% of respondents said they would no longer buy solar under a decision that lowers payments and adds a grid access charge. "

Survey says 95% of shoppers would not buy solar under NEM 3.0

Andy Sendy of SolarReviews explained to <b>pv magazine</b> why he believes the proposed decision would kill the California solar industry, and to offer a possible alternative.

pv-magazine-usa.com

That is exactly what the utility providers want.

 

[sunwarriors]

"The survey’s results spell doom for the California residential solar industry: 95.4% of respondents said they would no longer buy solar under a decision that lowers payments and adds a grid access charge. "

Survey says 95% of shoppers would not buy solar under NEM 3.0

Andy Sendy of SolarReviews explained to <b>pv magazine</b> why he believes the proposed decision would kill the California solar industry, and to offer a possible alternative.

pv-magazine-usa.com

Hah, I was just about to post this. I think batteries have a horrible ROI though (I calculate/assume $0), but perhaps some middle ground will be pay some export during peak times so during the summer when massive AC use, energy is needed, folks can still export at a reduced step-rate (what a lot of pre-NEM3.0 proposals had) and maybe little/no credit during 12-4pm or something.

The $8/kW has to go since that's a non-starter and hurts anyone with worst roof/sun space.

Another point:
"He said that if the grid access charge is meant to pay for the cost-shift created by NEM 1.0 and 2.0 customers, it will struggle to generate revenue if nobody wants to buy solar anymore."

No one does solar meaning no one will pay this $8/kW anyways as mentioned. A fee for ALL customers to be connected to the grid seems to be the most fair and people can do solar/not do solar based on their own energy use, finances, etc...I have talked to neighbors who are certainly wealthy enough to do solar, but don't because their bills are ~$100/month. Spend $20k-$40k to install solar and still pay $100/month after install on NEM3.0? What's the point?

They mention SGIP in the article which is a horrid experience to use/go through. I'd much rather they just make it some straight additional tax credit so "I" manage it vs. some government entity with no support/response/delays/slow/help at all.