CPUC NEM 3.0 discussion

[holeydonut]

I'm not fully on board with that question, but it is difficult to conclude otherwise based on the scatter shot of information that is being made available. I found a CAISO Peak Load History document and most of the days in late August or early September and from 15:00-18:00 (3:00pm-6:00pm). Solar generation is declining during these times, but still contributing to the grid.

I think you answered your own question... the E3 study and avoided cost calculator conducted in preparation of NEM 3.0 determined that residential rooftop solar (without batteries) offered little to no benefit to peak "demand."

We've learned that CAISO simply sees a reduction of "demand" as rooftop solar suppresses endpoint energy draw. But the E3 data was supposed to look at all demand, even an estimate to what was happening behind the meter of a solar customer. This allowed them to calculate the "avoided cost" of energy generation at a given time of day.

Anyway, regardless of what "demand" definition you go with... the IOUs say a solar-only customer taxes the grid just as much as a non-solar home during peak. And, the conclusion that we've heard countless times from the IOUs is that a solar-only NEM 1.0 or 2.0 customer is unfairly "NEM-ing" during peak, which means they aren't paying for this peak time grid fair share even if they are importing at a higher TOU rate.

What is dumbs about the now-delayed NEM 3.0 PD is that a solar customer with ESS is still paying the same fixed costs as a customer without ESS. But every study has found a solar+ESS self-gen home benefits the grid, especially during peak.

Here's the ACC rate per MWh projected for 2030. When the data estimates the peak hours for PG&E's biggest zone, (periods 18-20 6pm to 9pm), the costs are highest because there is little to no solar. And to the point you made, they need to invest a ton of grid/transmission to support the forecast surge in demand during those 3 hours.

 

[Southpasfan]

This is a preview of things to come in many industries.

For decades we, the public, have been told to conserve and attempt to use less energy, and for that matter, produce less waste or pollute less in all sorts of ways.

The only thing that ever works is when a technology emerges, and the wide adoption of that technology changes the situation.

All of the BS "conserve power" or, for that matter, more energy efficient homes or whatever, has had some effect, but from the perspective of the utilities has not put that much of a dent in their business.

Along comes solar, and now ESS, with 2022 pricing and efficiency, and we are talking REAL, NOT NOMINAL, reduction in energy use.

The utilities, who have to pay for "The Grid" somehow, can't handle it. So they come up with another BS argument, that the rich rooftop solar people are sticking it to the poor non solar people.

There is no way to pay for the grid through volumetric pricing and at the same time adopt rooftop solar to reduce consumption, even with ESS.

Since we need rooftop solar and ESS, the funding of the grid through business as usual has to change.

 

[Redhill_qik]

What is dumbs about the now-delayed NEM 3.0 PD is that a solar customer with ESS is still paying the same fixed costs as a customer without ESS. But every study has found a solar+ESS self-gen home benefits the grid, especially during peak.

Here's the ACC rate per MWh projected for 2030. When the data estimates the peak hours for PG&E's biggest zone, (periods 18-20 6pm to 9pm), the costs are highest because there is little to no solar. And to the point you made, they need to invest a ton of grid/transmission to support the forecast surge in demand during those 3 hours.

I keep a running spreadsheet with all of my Green Power button data and my own usage looks like this pre-Solar+ESS and post-Solar+ESS.

Hour​	2019 Pre-Solar+ESS Average kWh​	2021 Post-Solar+ESS Average kWh​	2019 Pre-Solar+ESS Max kWh​	2021 Post-Solar+ESS Max kWh​
15:00​	0.86​	-2.30​	4.40​	3.62​
16:00​	1.08​	-2.43​	5.59​	0.66​
17:00​	1.38​	-1.54​	5.90​	1.01​
18:00​	1.51​	-0.75​	5.49​	1.15​
19:00​	1.47​	-0.12​	5.67​	2.98​
20:00​	1.25​	0.19​	4.86​	2.55​
21:00​	1.58​	1.09​	5.26​	3.69​

My Powerwalls are covering my Peak time from 16:00-20:59, but there were some occasional algorithm glitches and I still have a problem with the CTs correctly measuring a circuit that isn't backed up and is used for Christmas lights which is why I the max numbers are high. Still a lot lower than pre-Solar+ESS.

 

[holeydonut]

I keep a running spreadsheet with all of my Green Power button data and my own usage looks like this pre-Solar+ESS and post-Solar+ESS.

Hour​	2019 Pre-Solar+ESS Average kWh​	2021 Post-Solar+ESS Average kWh​	2019 Pre-Solar+ESS Max kWh​	2021 Post-Solar+ESS Max kWh​
15:00​	0.86​	-2.30​	4.40​	3.62​
16:00​	1.08​	-2.43​	5.59​	0.66​
17:00​	1.38​	-1.54​	5.90​	1.01​
18:00​	1.51​	-0.75​	5.49​	1.15​
19:00​	1.47​	-0.12​	5.67​	2.98​
20:00​	1.25​	0.19​	4.86​	2.55​
21:00​	1.58​	1.09​	5.26​	3.69​

My Powerwalls are covering my Peak time from 16:00-20:59, but there were some occasional algorithm glitches and I still have a problem with the CTs correctly measuring a circuit that isn't backed up and is used for Christmas lights which is why I the max numbers are high. Still a lot lower than pre-Solar+ESS.

If you're feeling extra rich this summer from having robbed lots of poor people in July/Aug... set your ESS reserve to 100% to stop the batteries from exporting during peak.

It'll make your system act like a solar-only installation. The IOUs contend your 19:00 and 20:00 number in this "no ESS configuration" will look more like the 5.67 and 4.86 respectively even though you have some solar.

 

[Redhill_qik]

If you're feeling extra rich this summer from having robbed lots of poor people in July/Aug... set your ESS reserve to 100% to stop the batteries from exporting during peak.

It'll make your system act like a solar-only installation. The IOUs contend your 19:00 and 20:00 number in this "no ESS configuration" will look more like the 5.67 and 4.86 respectively even though you have some solar.

I actually do plan on adjusting my Peak behavior starting in April, if the PW TOU pricing controls will let me get it right. My CCA SVCE is changing from excess generation being paid out at retail TOU rates to paying out at 200% of the PG&E wholesale Net Surplus Compensation rates for net kWh on an annual basis. This changes my incentive from wanting to export as much as possible during Peak to just wanting to export as much as possible while achieving a PG&E energy charge at true-up close to $0.00 (I was -$986.34 which then reset to $0.00). This means that I want to continue using the solar generation for house loads during Peak to lower then amount of Powerwall discharge that needs to be recharged from solar the next at the 90% efficient rate.

Now, I just need to figure out how to set the buy/sell values to achieve the goal of prioritizing solar to house and then Powerwall to house during Peak. I did not participate in the Tesla Virtual Power Plant Beta program, but I would definitely consider it now if the export compensation was over $0.75 kWh.

 

[Redhill_qik]

It seems that PG&E may be concerned about their NEM 3.0 positions as they are running a survey titled "Solar Reform Brand Impact".

 

[hayhayday]

The E-Elec rate potentially seems very similar to EV2, slightly lower but with a $15 fee, initially seems like it would have been $25 but cpuc prefers fixed fee.
E-ELEC Rate Component Price
Monthly Fixed Charge $15
Summer Peak (4 pm – 9 pm) $0.43340/kWh
Summer Part-Peak (3 – 4pm, 9 pm – 12 am) $0.27152/kWh
Summer Off-Peak (12 am – 3 pm) $0.21484/kWh
Winter Peak (4 pm – 9 pm) $0.24032/kWh
Winter Part-Peak (3 – 4pm, 9 pm – 12 am) $0.21823/kWh
Winter Off-Peak (12 am – 3 pm) $0.20437/kWh

Seems like peak rate differential on the other tou c\d will may continue to increase and baseline quantity will further be reduced so solar value is already being reduced with these adjustment. If nem customer eventually moved to e-elec rate, between the nbc and $15 fixed fee would likely be $25-30 total even if net producer which will be harder as peak continues to increase.

Step 1 Change Period (May 2023 – April 2024): Schedule
E-TOU-C summer and winter POPP differentials shall
be set as follows:
o Summer: A total differential of $0.08344 per kWh
(consisting of a $0.06344 generation rate
differential and a $0.02000 distribution rate
differential)
o Winter: A total differential of $0.02835 (consisting
of a $0.02503 generation rate differential and a
$0.00332 distribution rate differential)

• Step 2 Change Period (May 2024 – April 2025): Schedule
E-TOU-C summer and winter POPP differentials shall
be set as follows:
o Summer: A total differential of $0.10300 per kWh
(consisting of a $0.08300 generation rate
differential and a $0.02000 distribution rate
differential)
o Winter: A total differential of $0.03000 (consisting
of a $0.02668 generation rate differential and a
$0.00332 distribution rate differential)

Step 3 Change Period (May 2025 – April 2026): Schedule
E-TOU-C summer and winter POPP differentials shall
be set as follows:
o Summer: A total differential of $0.12300 per kWh
(consisting of a $0.10300 generation rate
differential and a $0.02000 distribution rate
differential)
o Winter: A total differential of $0.03000 (consisting
of a $0.02668 generation rate differential and a
$0.00332 distribution rate differential)


Individually-Metered customers, figures in kWh per day:
Basic Electric All-Electric
Baseline Territory Summer Winter Summer Winter
P 13.5 11.0 15.2 26.0
Q 9.8 11.0 8.5 26.0
R 17.7 10.4 19.9 26.7
S 15.0 10.2 17.8 23.7
T 6.5 7.5 7.1 12.9
V 7.1 8.1 10.4 19.1
W 19.2 9.8 22.4 19.0
X 9.8 9.7 8.5 14.6
Y 10.5 11.1 12.0 24.0
Z 5.9 7.8 6.7 15.7

https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M415/K874/415874503.PDF start ~page 98

 

[gene]

A closer look at the CPUC board members who approve SDG&E rate hikes

Commissioners appointed by the governor, vote on rate increases proposed every three years.

www.cbs8.com

 

[getakey]

this is a load of crap

Debunking Myths Surrounding California's Net Metering Reform

Setting the record straight to allow for a fair judgement on the merits of the proposed net-metering decision in California.

www.nrdc.org

 

[ohmman]

this is a load of crap

Debunking Myths Surrounding California's Net Metering Reform

Setting the record straight to allow for a fair judgement on the merits of the proposed net-metering decision in California.

www.nrdc.org

This may have been posted upthread, but this piece goes into the NRDC's relationship with CPUC and the utilities.

How an Environmental Group Aligned with Monopoly Utilities to Squash Rooftop Solar

A half-century old nonprofit organization is flaunting its laurels to obscure its support of anti-climate, pro-utility legislation. Blind esteem for this organization is actively derailing clean energy legislation and climate policies. So why would an organization dedicated to protecting the...

www.hammondclimatesolutions.com

 

[h2ofun]

this is a load of crap

Debunking Myths Surrounding California's Net Metering Reform

Setting the record straight to allow for a fair judgement on the merits of the proposed net-metering decision in California.

www.nrdc.org

wow, what junk

 

[holeydonut]

this is a load of crap

Debunking Myths Surrounding California's Net Metering Reform

Setting the record straight to allow for a fair judgement on the merits of the proposed net-metering decision in California.

www.nrdc.org

Just in case someone actually wants to know why that NRDC article is crap. The irony of their stupid approach of labeling arguments "myths" then coming up with their absurdly stupid logic is hilarious. They fight what they say is a myth with their own myths.


For their first "myth" about the benefits of solar production, they say "If the same solar panel was placed on the grid side of the customer’s meter ... it would be paid at least five times less".
We've already seen this interpretation is total trash since the utilities are locked into PPAs to pay for solar energy from utility scale generators. While the spot price of a marginal amount of solar may be "5 times less", they incorrectly extrapolate that the "price" of all residential rooftop solar generation should be valued at 5 times less. The utilities are paying high rates for the solar they obtain at noon from utility scale solar generators. This is because they're contractually obligated to do so. These guaranteed purchase agreements subsidize the profits of those utility scale solar generators.


For their next "myth" about grid infrastructure costs being reduced by NEM 2.0, they say that NEM 2.0 policies still require high grid distribution and transmission investment.
The NRDC is so out of touch they actually type out "A recent study by Vibrant Clean Energy (VCE) showed that distributed solar and storage might be able to significantly reduce grid infrastructure costs." So Solar + Storage reduce grid investment? The NRDC conveniently excludes the idea that Solar + Storage is possible under NEM 2.0. The NRDC makes it so the reader has to infer that NEM 2.0 doesn't allow solar and storage to validate their claim that NEM 2.0 doesn't help the grid. And taken a step further, why would the NRDC be in favor of the NEM 3.0 PD that actively punishes a Solar + Storage customer with the same fixed costs fee as a Solar-Only customer?


The next "myth" about increasing the utility's profits. The NRDC says that utility profits are unaffected.
I know the public at large is stupid, but it's unfortunate this simple twist of words from the IOUs is so effective. This stupid "profit" statement permeates every conversation about the IOUs. Every time I've spoken with an IOU employee, they say this. Even Gavin Newsom says it in pressers. They always say the CPUC sets the utility's profits and PG&E doesn't get more or less profit regardless who has solar or not. This phrasing is misleading for most people. These groups should be saying the CPUC sets the rate of return or profit margin.

If the NRDC or the IOUs wanted to be truthful about this, they would say that the CPUC sets the return rate or profit rate the utilities get to make on their investment and cost structure. The utilities are allowed to generate an amount of revenue based on a forecast of their expected costs. If the costs go up, then the CPUC will authorize a level of revenue that can generate the target return or profit rate. That means, if the IOUs spend more money, their absolute total dollars of return will increase since they make guaranteed money on every dollar they spend (or waste).

When a residential solar customer spends money on infrastructure investment instead of PG&E, then PG&E cannot get a return on those dollars since the IOU wasn't the ones who spent. When a residential solar customer spends money on infrastructure investment instead of a utility scale solar generator, PG&E cannot get a return on those dollars since the per MWh cost of that solar does not land on PG&E's income statement.

Not a Myth: Every Californian rate payer will benefit if the IOUs reduce total costs. But the IOUs spend a lot of money to try and convince some rate payers that other rate payers are the problem... and this results in more total profit dollars for the IOUs.


The next "myth" about giving the utilities what they asked for.
Wow. Talk about playing a semantics card again. The NRDC response makes it sound like the myth is that the PD gives the IOUs "everything" they asked for. While the PD isn't an exact copy-paste of the Joint IOU submission, it is surely damn close. The PD gives the IOUs almost everything, and even has the outrageous per month fixed costs for all Solar + ESS customers that only the IOUs wanted.

For example, the NRDC response says the CPUC PD gives a payback period of 10 years instead of the 21 years the IOUs asked for. Except to get this 10 year payback, the CPUC accepted the IOU's estimate of costs used in the 10 year calculation. Nobody who installs residential solar and ESS understands where the CPUC's numbers come from. Nobody can get solar (before or after incentives) at the levels the CPUC thinks is resulting in a 10 year payback.


The next "myth" that the value of NEM 1.0 and NEM 2.0 customers is unaffected by the PD.
I guess having 20 years grandfathering dropped to 15 years is "keeping the deal." If you're ever buying a car or house from a NRDC employee, you better watch out. They don't seem to like honoring contracts/commitments. Moving the goalposts seems like something they'll do without blinking.


I could keep going on and on... but I'm tired. Hopefully someone else here will also cite why this NRDC article is total trash. Unfortunately their interpretations seem to be what the IOUs are paying a ton of money to influence the public. And the IOUs have a lot of money to spend.

 

[stopcrazypp]

This may have been posted upthread, but this piece goes into the NRDC's relationship with CPUC and the utilities.

How an Environmental Group Aligned with Monopoly Utilities to Squash Rooftop Solar

A half-century old nonprofit organization is flaunting its laurels to obscure its support of anti-climate, pro-utility legislation. Blind esteem for this organization is actively derailing clean energy legislation and climate policies. So why would an organization dedicated to protecting the...

www.hammondclimatesolutions.com

Yes I posted this upthread. Outside of other influences, it makes zero sense for an environmental group to back the utility position (they stand out like a sore thumb in doing so, which is why I looked it up) and that article provides a good summary of what happened to NRDC.

 

[Merrill]

It looks like the NRDC is infiltrated by pro utility lawyers and executives which has changed what the really stand for. They should change their name to reflect who they really are.

 

[sunwarriors]

A closer look at the CPUC board members who approve SDG&E rate hikes

Commissioners appointed by the governor, vote on rate increases proposed every three years.

www.cbs8.com

Another example of where having the CPUC manage us down here in San Diego (and Los Angeles) is a total rip off. None of those member's rates are even here so for all they care, they can make rates $2.00/kWh. Sempra also donated to Newsom's campaign. I have a pretty good idea of who I'm sure to not vote for Govenor later this year.

I still point back to the need to localized management of the utilities more. The CPUC is a failure and has no accountability to the general population. They also seem to make inflated salaries doing what?

 

[wwu123]

If they are still on a tiered tariff like E-1 (pure tiered) or E-6 (TOU and tiered) then they would be getting increasing higher costs (penalties) with increased usage. These tiered tariffs are going away at the of year as everyone is getting moved to pure TOU plans.

Edit: Actually E-TOU-C (I'm on this) is also tiered and the difference is the same E-6 (0.08206 higher when you go above the baseline of ~10.5kWh/day)

I don't think E-1 is actually sunsetting, folks can opt-out of the TOU move before or after, including switching back to E-1 if they like.

While E-1 is a tiered rate plan, it has actually flattened out over the past decade, from four tiers down to current three. It's interesting reading the latest PD on rates (dfferent doc from the PD regarding NEM 3.0) posted by @hayhayday though, interesting tidbits about E-1 and E-6:
- PG&E's long-term plan essentially makes E-1 flat, but they have to make the transition more gradually in this set of rate changes. If it does eventually become flat, the only rate differences across the year AFAIK would be the flat winter rate vs flat summer rate.
-As E-1 becomes flatter, the baseline quantity would increasingly become irrelevant (i.e. difference between baseline Tier-1 rates and Tier-2 rate shrinks). Yet they are shrinking the baseline quantities nonetheless. They were limited generally to reducing them by 5% max this round, so apparently they had wanted to shrink them even further. Since the baseline is becoming more irrelevant, I think the long-term purpose of reducing it is mainly to squeeze those customers on a medical baseline program.
-Even though E-6 is sunsetting for everyone in less than a year, they still had to muck with it. Not just increasing the rates as typical, but flattening the TOU spreads as well - which reduces the arbitrage for solar customers in this last remaining year.
-As E-1 flattens, E-TOU-C really will remain the only tiered rate among current plans. While the tier spread is $0.08 as @Redhill_qik mentions, interestingly this is the one they propose to increase the TOU spreads, since the TOU periods are ones that solar customers can't easily arbitrage. Currently it's almost flat, rather than TOU, for 8 months of the year. They were limited to making it more gradual, so for example the winter spread will go from about $0.02 to $0.04 and then $0.06, over a few years.

They have to maintain one or two tiered rates, at the least for medical baselines to make any sense. E-1 and E-TOU-C are currently them, but I do feel E-TOU-C will be replaced in a few years by a -E or -F that just screws everyone in every way possible.

 

[holeydonut]

I don't think E-1 is actually sunsetting, folks can opt-out of the TOU move before or after, including switching back to E-1 if they like.

Yes, but E-1 (PG&E) is rapidly becoming super-high-cost for people not on CARE or FERA. The baseline allowance rates for E-1 effective January 1, 2022 is up 33% since January 1, 2019. The 101% to 400% Tier 2 is also up about 29% in the same 3 year span. The proposed changes to E-1 that PG&E asked for last July were very high (again, for non-CARE)... so tiered may actually be worse than TOU for many homeowners. Homeowners who have AC will probably get nuked on E-TOU-C, but folks in condos with gas appliances may benefit.

Part of the reason PG&E has said the transition from E-1 to E-TOU-C is "neutral" to the rate payers bill is because they jacked up E-1 rates by quite a bit.

And to beat my PG&E-sucks-horse to a more bloody pulp than it already is... PG&E will blame the homeowners themselves for their astronomical bills (or blame wealthy solar fat-cats).

If the homeowner stays on E-1, PG&E will say the homeowner should check out E-TOU-C.

If the homeowner switches to E-TOU-C, then PG&E will tell the homeowner solar customers are being subsidized; and the homeowner themselves they did a poor job shifting demand out of peak time.

 

[charlesj]

Just in case someone actually wants to know why that NRDC article is crap. The irony of their stupid approach of labeling arguments "myths" then coming up with their absurdly stupid logic is hilarious. They fight what they say is a myth with their own myths.


....

Like an anti-missile missile. Their anti-myth myth.

 

[charlesj]

... They also seem to make inflated salaries doing what?

That is simple, screwing the public. Only one rep is on that board to look after consumer's interests.

 

[gene]

Here is why NRDC does what they do:

1. Lineage: After he co-founded NRDC, John Bryson served on the CPUC and then became CEO of Edison International, which of course founded the Edison International Institute (EEI), which has led the attacks on rooftop solar over the years. Ralph Cavanaugh cut his teeth under Bryson, and is widely understood to be aligned with his philosophy. Another take on this

This close relationship with utilities has persisted over the subsequent years. NRDC has issued at least four joint statements with Edison Electric Institute since 2002 regarding all manner of clean energy policy, which NRDC makes no effort to hide.

2. Attacking rooftop solar. In the 2014 agreement with EEI, for example, NRDC made a deal with the utility industry in which the utilities stop fighting the existence of energy efficiency and rooftop solar in exchange for NRDC's support for designing these programs so the utilities can maintain their profit margins.

In other words: on the eve of EEI's massive, multi-state attack on net metering, NRDC's Ralph Cavanaugh went to a conference of utility regulators to single-handedly and unilaterally negotiate a deal with the titans of the utility sector that explicitly gave EEI cover for their war on rooftop solar. (here, here, here and here)
The close coordination didn't stop there, it crept into states across the country. NRDC jointly filed with the utilities during the California NEM2 proceeding in 2016. Filing jointly as intervenors in a rate case is an extraordinary level of cooperation.

3. Protecting utilities from liability: In their 2018 agreement with EEI, NRDC's Cavanaugh cuts another deal with utility executives to shield them from liability from wildfires and other collateral damage of their negligence. You see NRDC's utility-centric, customer-be-dammed approach come into full focus, where utility "solvency" and "cost recovery" are the primary concerns.

This quickly created real-world consequences in the policy arena. From the LA Times in 2019 as lawmakers were debating shielding PG&E from California's liability rules:
"Cavanagh thinks state legislators should change the law so that PG&E and other utilities aren’t held liable for fires sparked by their infrastructure unless they’re found to be negligent.
“Our utility liability rules are unworkable. They menace every utility in California, and they need to be fixed,” he said. “This is not just about PG&E, and it’s a mistake to treat it as such.”
Here's the tell: NRDC called utility accountability the "menace", rather than the company that committed numerous crimes of negligence that caused tremendous death and destruction. NRDC's position on that issue was not a mainstream position but rather the position of an organization hopelessly intertwined with "utility-first" philosophy, regardless of the public interest.

4. Enron: Going back to the 90s, most have forgotten that NRDC was a key lobbyist for the CA deregulation bill that precipitated the Enron crisis. NRDC's Cavanaugh provided green window dressing for the bill, quoted extensively across the news media calling the bill as the "smart green future", giving cover to the Legislature to pass the bill at the last minute of the session, even as nearly every other energy, environmental and public interest group was opposed. Here's an in-depth from 1997 from the Bay Guardian about how NRDC was key to getting votes for the bill.