You may be right. It's confusing language. You would think they would state the general terms then add the exceptions vs the other way around.
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CPUC solar decision?
- Thread starter h2ofun
- Start date
But the IOUs can change the rules at any time, in the middle of the game. Even if your usage does not change and you've done all the calculations, they can continue to make rates cheaper during peak solar hours relative to peak usage or at night, and then discontinue whatever rate plan you did the calculations for and force you onto a new one. Unless of course you get an agreement in writing that they won't change the rate plan for the duration of the payback period, but I have yet to hear of anyone getting that. There's no way I'm going to play a game where my opponent does not even agree to set rules before the game starts that don't change until it ends.
A new rate with "highly differentiated time-of-use rates" is supposed to be created as part of this, the current EV2-A plan is listed as also acceptable. If I optimistically assume the new rate plan will remain at about $0.18 like ev2-a assuming it can be self consumed or stored in batteries 1 KW solar that generates an averageish 1200 kwh per year would be worth ~$120 year(0.18x1200 = $216 - 8x12 solar fee = $120). The solar fee represents about $0.07 per kwh generated compares to few cents that could be paid for exports making large systems a losing proposition. At $2 per watt even with an increase to 30% itc would result in ~ 12 year breakeven. Seems like best way would be a small enough solar system that nothing would ever be exported with largeish battery that charges from grid to avoid highly differentiated time-of-use rates. Hopefully this encourages tesla to enable grid charging as it can be on other solutions.
YES, so I tell a buyer that guess what, I have these cool black things on my roof which you get to pay 240 bucks a month just to look at them.
I suppose in 15 years from installation date you could do that. I am beating at that time you will chose to keep the panels and pay the monthly capacity payment because that will be way less than the energy payment you will get if you do not have solar.....
I've never seen PG&E use the DC rating for any of their system sizing. I would be surprised if they used anything except the AC inverter rating.
Where you could get hosed is if PG&E finds a way to include the battery export kW within the monthly fee. In some contexts (like in the NEM2-MT PTO form), the total interconnected system size is the sum of the ESS and PV at peak. Even if your batteries never export to the Grid and your solar rarely produces peak AC output, they don't care and size things as if you just unloaded on the grid all the time.
Can you imagine what you'd have to do if they tacked on an additional 25 kW "system size" including your 5x Powerwalls?
After 36 years in the utility business before recently retiring, I would advise folks to just wait a bit. This is a PROPOSED decision, and now there is a commenting period, and you can be sure with these issues that there will be a TON of comments about many aspects of the proposed decision. The CPUC will then take those comments, reason through them and compare/contrast them with each other (pro/con) and then roll them into a compromised final decision and vote on that after the first of the year.
This process is like a negotiation. The PD is the first salvo fired and then the comments come back that usually end up restoring some sense of reasonableness to the proceeding. For me, the biggest issue I see is going from $0 to $8 per installed kW for a grid management fee (seems way excessive). I'm sure the comments will hit on that pretty heavily...
This process is like a negotiation. The PD is the first salvo fired and then the comments come back that usually end up restoring some sense of reasonableness to the proceeding. For me, the biggest issue I see is going from $0 to $8 per installed kW for a grid management fee (seems way excessive). I'm sure the comments will hit on that pretty heavily...
I want to believe you, but the CPUC didn't do this one-side-negotiation tactic with NEM 2.0. Negotiations are all about leverage; and the CPUC has inexplicably handed maximum leverage to the joint IOU's.
SEIA, CALSSA, and dozens of solar advocates have made cases about how the joint IOU's request to de-couple credits from retail rates; a huge step up of NBC/grid-fees; and reduction of grandfathering would torpedo the industry and reduce trust with consumers that Solar is a smart move.
It would have made more sense for the CPUC to pick a middle-ground proposal and require the parties to argue why some of these sliders should move left or right. Instead, the CPUC hands a base case of putting 100% of the burden back on the SEIA, CALSSA, and the Public to make a new plea to move the sliders away from the IOU's position. This is such a bogus approach because PG&E is equipped with mammoth resources, influence, and "facilitation" funneling money to the business interests of the CPUC members.
What new information can CALSSA produce to influence changing the $8 to $4? Like do the CALSSA members need to go protest on 880 or write letters to Gavin? Elon sending a Tweet would have a better chance of moving the needle now. The fee should have started at $3 per month and PG&E provide evidence why they need it to be $6.
It's not a viable option in my opinion so I haven't bothered to find the specific regulations. I am going by what my POCO says:
Interconnect safely
Interconnection is governed by both federal and state regulations for safety and reliability. All solar and renewable generators must connect to our grid. You must complete our Interconnection Application.from Overview for Beginners
If you are motivated, I am sure you can contact your POCO to get more specifics.
In any case, I imagine the worse case is that the POCO cuts you off and assess some significant fines. So, perhaps an off-grid solar system rather than grid-tied system is the way to go and just use a transfer switch to power your home from the off-grid system whenever you want without interconnection legally.
It is true that some proceedings get changed more than others in the transition from a proposed to final decision. It really seems to depend on how the CPUC feels about certain hot-button issues associated with each proceeding. I've seen some pretty massive change in some proceedings when going from PD to FD, though, so it does give me some hope. I have 41 solar panels on my roof and no battery, so I'm definitely following this proceeding very closely.
This is just my experience as a utility witness in several CPUC proceedings (so you can take it with a grain of salt), but I think the most valuable way to influence the decision is for groups that have been recognized as parties in the proceeding make very persuasive arguments in their comments about the changes they would like to see to the proposed decision. I personally haven't seen change in this context come about from demonstrations, taking over a freeway, etc. The PD has the Commission's thought process about the issues, and that is what needs to be studied and argued against. While the Governor does appoint CPUC members, I don't think he makes phone calls to change decisions that come from an Administrative Law Judge after considering all the evidence (I could be wrong, of course, but I haven't seen an abrupt about-face like that). The PD has all of their logic built in and that is what needs to be argued.
Oh, and by the way, I do think there should be some sort of Grid Management charge to help pay for the grid that everyone uses, but I think it should be less than $8/kW/month. And even if that logic fails, they should start it lower and step it up over time so people can get acclimated to it.
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I agree, writing Gavin and protests won't work. I'm being sarcastic about those options. Elon Tweeting is less sarcastic though... Elon has tweeted already that the CPUC proposal is "insane" but he could do more tweeting.
I think the CPUC has already received the "persuasive arguments" you think will sway the CPUC now. CALSSA, SEIA, and other parties that actually think residential solar is a good thing have submitted their cases and proposals. The CPUC has apparently decided to just ignore those arguments in their latest proposal. The $8 per kW fee is nuts; and the gradual step-down that the CPUC proposes is nowhere near what CALSSA requested as a gradual easing that won't disrupt the industry. SDG&E customers don't even get a step-down in the latest from the CPUC.
Even recently there were a slew of exparte meetings between industry and IOU with the CPUC. They presented some new findings and interpretations of the data around the "cost-shift" and "avoided cost". Again, the CPUC evidently just ignored those arguments. The CPUC's preceding pages have been flooded with homeowners saying the IOU's interpretation would harm their rooftop solar purchase decision and make residential solar untenable for an average (not low-income) person to rationalize.
I don't see some random Jane Doe posting on the CPUC public forum with some magical perspective that is going to move the decision making. The CPUC doesn't read this stuff and addresses none of it. The only thing the PUC would care about is if Jane Doe were to somehow kick down some bucks and lobby like the Commercial interests do. VNEM and commercial interests are somehow avoiding the same fees/rates as the residential cohort. Anyone surprised by this?
All PG&E cares about is making that guaranteed return on energy investments. When you or I make private energy investments, PG&E doesn't get their guaranteed return. Every single decision they make centers around why it's better for PG&E to invest and skim that margin. The CPUC through their network of connections and business ties also skim. This IOU model with PUC oversight is straight up busted.
Edit: Grammar since I was angrily typing on my phone.
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There should be an option for zero export systems that would be exempt from the per kW fees as the would be no grid participation.
nwdiver
Well-Known Member
Why not pay for the grid based on how much you use the grid? If you have two homes each with 10kW of solar but one uses the grid ~10x more than the other should not the home that uses demand response and/or storage pay a lower 'grid management' fee?
$/kW fees are lazy and idiotic. Period.
Everything I have seen from Interconnection uses "CEC AC Rating". This is calculated as the panels' PTC rating in Watts times the CEC-AC Efficiency of the inverter. These figures can be found for all approved equipment in a spreadsheet published by the CEC.
I looked into this because this is the calculation used to determine if your repair or upgrade will kick you out of NEM 1, which I am on.
Not sure if the industry will ever get to this point, but I think the grid management fee should be based on some sort of average kW max per month (import or export) - maybe over two or four 15 minute meter intervals to average out anomalies. That would be a true indicator of how much the home is relying on the grid. If a homeowner can manage a lower kW meter read average by charging storage batteries or cars from solar and/or consuming their solar with AC, etc., then they should pay less of a grid fee. But if they're running AC at 9pm and charging cars with no storage battery and the house hits a peak of 15 kW, then the grid management fee should reflect that...All of that is easier said than done, though, and would be a tidal change in how billing is done for residential customers (lots of education required with a lot of call center questions - "Why is my grid management fee based on 24 kW", etc.).
I recall this being discussed in some ex parte comms many months ago between the CPUC and PG&E. What you (and others in this thread are proposing) is basically to tie the fixed-cost fee to real life experience of using the Grid. Because "pay for use" makes sense and is fair in most people's minds.
But pay for use is exactly what PG&E and the joint IOU's want to avoid. They contend rich people would just pay to not use, which means the poor are still stuck paying the fixed costs.
Like take the example where PG&E simply charges a fixed transmission fee for each kWh sent to the Grid and later retrieved from the Grid under NEM.
So for this example, consider my modest solar system of 6.7 kW (AC) rating. In my August 2021 billing cycle, my house sent about 500 kWh solar production to the grid, and I took about 500 kWh from the grid after midnight since I configured my Powerwalls to only discharge during peak and shoulder times.
PG&E sees the 500 kWh x2 since that's the info that come in from my black and white PG&E bill (and matches their greenbutton).
So a logical person could say I "used" the grid for 1,000 kWh. And if NEM 3.0's fee were in effect, my fee would be 6.7 x $8 = $53.60 for the month.
With this baseline, the wacky $8 per kW fee in the latest language amounts to $0.0536 per kWh for that 1,000 I "used" the grid. I think $0.0536 per kWh is wacky high, but at least having it tied to my actual use of the grid makes sense.
Unfortunately, PG&E argued that I have an escape to avoid paying this $0.0536. If I add another battery or V2H EV in the future, then PG&E doesn't get any money since no energy goes through their meter. Instead it goes into my car or battery. But PG&E needs that money.
So they argued the CPUC had to put a fixed charge on the size of the system regardless how much that system actually used the Grid. This was the easiest way PG&E could see $$$ in all instances. PG&E argued that in absence of a fixed fee, they wanted to to put a generation meter to see what was happening behind the main PG&E meter. That way PG&E could charge directly for the actual kWh solar production. This particular idea with a second meter would be costly and difficult to implement. So the CPUC went with their "lazy" approach as @nwdiver calls it that satisfies PG&E's desire to get paid no matter what.
Edit: Randy, sorry I just realized I've been being kind of singling out your posts about this topic lately. I don't mean to be harassing you to contradict everything you're saying. I think you're actually taking a reasonable and level headed response to all this. So please, do not take my comments here on TMC as a means that I dislike what you're saying. I just dislike PG&E... a lot...
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