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File for PTO before installation?

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sorka

Well-Known Member
Feb 28, 2015
11,685
9,662
Merced, CA
Lots of family and friends asking me in the last couple of weeks if it's too late to get under NEM 2.0 and my answer them has been yes unless they can get a system installed, inspected, and then submit an error free interconnection agreement application prior to April 14th.

But then this article claims that as part of the NEM 3.0 ruling, NEM 2.0 can be applied for WITHOUT a complete installation and that you have 3 years from the application to install, inspect, and get PTO and remain under NEM 2.0.

I can't imagine this is actually true and I can't find any reference to this anywhere else. So is the article just complete BS?

 
You can apply for NEM before you install solar. You can upload documents like wiring plan, final permits afterwards. As long as you initiate the NEM application and get a prelim approval, you will be locked in to the NEM2.0. Source: me, self installed, pulled all the permits, and submitted NEM myself.
 
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My neighbor quoted the same thing from their installer. They want to add on, but not right away. The installer said they would file all the paperwork and then they had 3 years to install
The installers I have talked to just need to get the interconnect agreement signed by PGE before what April 12th, then they have time to do all the rest of the stuff
 
Just hope your design doesn't materially change between the date the PTO application goes in vs when put the solar+ESS in. In my case, I originally had a NEM2-PS application in 2019 since my target solar + ESS was below 30kW and the ESS was only 10kW.

But then during the implementation phase, PG&E blocked me from getting 2x Powerwalls on a partial home backup because they deemed it to be unsafe. When I was able to get a 3rd Powerwall under SGIP, PG&E forced a cancellation of my NEM2-PS and instead used NEM2-MT since 3x Powerwalls exceed the 10kW paired storage cap.

My feeling is if you're only doing solar, this probably is a safe way to go. But with ESS being so unpredictable, I feel this could put your system at risk. Maybe you can get solar-only in first... then add ESS later to ensure your solar stays under NEM 2.0. My understanding is that adding paired storage to a NEM 2.0 solar system does not force you into NEM 3.0.

Here's a snippet of PG&E PTO form 79-1193-02. I don't even know if 2x Powerwalls technically falls under 10 kW any more since the max potential export of Powerwall 2's has gone up lol.

1677626223058.png
 
Just hope your design doesn't materially change between the date the PTO application goes in vs when put the solar+ESS in. In my case, I originally had a NEM2-PS application in 2019 since my target solar + ESS was below 30kW and the ESS was only 10kW.

But then during the implementation phase, PG&E blocked me from getting 2x Powerwalls on a partial home backup because they deemed it to be unsafe. When I was able to get a 3rd Powerwall under SGIP, PG&E forced a cancellation of my NEM2-PS and instead used NEM2-MT since 3x Powerwalls exceed the 10kW paired storage cap.

My feeling is if you're only doing solar, this probably is a safe way to go. But with ESS being so unpredictable, I feel this could put your system at risk. Maybe you can get solar-only in first... then add ESS later to ensure your solar stays under NEM 2.0. My understanding is that adding paired storage to a NEM 2.0 solar system does not force you into NEM 3.0.

Here's a snippet of PG&E PTO form 79-1193-02. I don't even know if 2x Powerwalls technically falls under 10 kW any more since the max potential export of Powerwall 2's has gone up lol.

View attachment 912371

I believe the 10kW ESS limit is rendered moot if it’s “Energy Storage with Power Control System Certification”…which I believe the Powerwalls fall under.
 
My brother in law ordered solar/powerwalls with Tesla at the end of February. They guaranteed, in writing, that they would file the application prior to the mid April deadline. That deadline came and went without submitting the application to PG&E.

I feel really bad because I recommended Tesla to him when he was getting ready to shop around to see if any installers would file the application prior to the deadline. He wasn't in a huge rush to get it done. He was happy to wait a year or more. He was also willing to have it installed immediately. His time scale was very flexible. He just wanted to get in under NEM 2.0. After the deadline, it no longer pencils out for him on ROI and he now feels he dodged a bullet with the new PUC/IOU scam to add $128 fixed / month to his PG&E bill which will basically gut NEM 2.0 bypassing our grandfathering for 20 years.
 
My brother in law ordered solar/powerwalls with Tesla at the end of February. They guaranteed, in writing, that they would file the application prior to the mid April deadline. That deadline came and went without submitting the application to PG&E.

I feel really bad because I recommended Tesla to him when he was getting ready to shop around to see if any installers would file the application prior to the deadline. He wasn't in a huge rush to get it done. He was happy to wait a year or more. He was also willing to have it installed immediately. His time scale was very flexible. He just wanted to get in under NEM 2.0. After the deadline, it no longer pencils out for him on ROI and he now feels he dodged a bullet with the new PUC/IOU scam to add $128 fixed / month to his PG&E bill which will basically gut NEM 2.0 bypassing our grandfathering for 20 years.
You’re referring to the CA Bill (now law?) that required the CPUC to shift some of the cost to an income-based tariff by some deadline in the future?

My understanding is that was a first proposal and there’s a couple years ahead before this gets all settled out. Lots of ways things can go.

It does suck that your brother-in-law started in Feb and they couldn’t get the NEM2.0 paperwork filed in time. Seems like Tesla go most people through. Sometimes you had to follow up with them a bit.
 
That’s a bummer. I signed up to add some more panels end of Jan under the same guarantee and my project sailed right through.

 
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My brother in law ordered solar/powerwalls with Tesla at the end of February. They guaranteed, in writing, that they would file the application prior to the mid April deadline. That deadline came and went without submitting the application to PG&E.

I feel really bad because I recommended Tesla to him when he was getting ready to shop around to see if any installers would file the application prior to the deadline. He wasn't in a huge rush to get it done. He was happy to wait a year or more. He was also willing to have it installed immediately. His time scale was very flexible. He just wanted to get in under NEM 2.0. After the deadline, it no longer pencils out for him on ROI and he now feels he dodged a bullet with the new PUC/IOU scam to add $128 fixed / month to his PG&E bill which will basically gut NEM 2.0 bypassing our grandfathering for 20 years.

I haven't been following it closely, but you're actually the first person I've seen state they or someone they knew missed NEM2.0 deadlines.

I'm sure there are more and maybe I'm not looking, but from all the successful reports, it didn't seem like this was something very hard for installers to do and Tesla seems to be doing it well too. I wonder if their sales rep just messed up and left the company, simply didn't care, etc...I haven't read mass failures to qualify though.

As for the fixed monthly cost that's written in law, I think it's stated it'll take effect in 2024 and there are 4 competing proposals. Of course, the IOU one is the highest monthly cost (I think up to like $128 in San Diego? The lowest was like $5 or $8 bucks, forget exactly). I'm sure as it gets closer to implementation, we will see more noise/lawsuits or changes/rewrites to the law.
 
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I haven't been following it closely, but you're actually the first person I've seen state they or someone they knew missed NEM2.0 deadlines.

I'm sure there are more and maybe I'm not looking, but from all the successful reports, it didn't seem like this was something very hard for installers to do and Tesla seems to be doing it well too. I wonder if their sales rep just messed up and left the company, simply didn't care, etc...I haven't read mass failures to qualify though.

As for the fixed monthly cost that's written in law, I think it's stated it'll take effect in 2024 and there are 4 competing proposals. Of course, the IOU one is the highest monthly cost (I think up to like $128 in San Diego? The lowest was like $5 or $8 bucks, forget exactly). I'm sure as it gets closer to implementation, we will see more noise/lawsuits or changes/rewrites to the law.
Thanks for clearing that up for me. As far as I know, no circuits excluded. I'm only going by what I was told verbally. That was one wall would handle the house (except AC) for most of the day. I only went with two wall in hopes of handling the AC too. I later found it wouldn't. I'm wondering how valuable NEM2 is with 2 walls. I'll just wait and see. Estimated install was July. We'll see how that goes. Thanks again.