Thanks for posting that, I just didn't have the time to dig into the explanation. Your explanation was pretty accurate, but I would call the no-go zone a sphere not a square. It is much easier to cross near the gas meter area now as well.
Of course, PGE giveth and taketh in equal measure. Not only did they eliminate the like for like swaps within the exclusion zone they changed the rules around AC disconnects.
More Disconnects and equipment will be needed going forward, since no longer can the PGE required disconnect turn of customer loads or be in a sensible location between the TEG and the Service panel. This also means that no longer can a customer run their home in backup mode if PGE turns off the generation AC disconnect.
I honestly think this rule will not pass muster as soon as someone wants to sue PGE over it. We are waiting for them to start a fight over it with one of our really rich customers, and then they can turn the lawyers loose so we are not caught in the middle.
I feel like since main service panels are typically chest-high and the gas regulator is down near the ankles, it'd be tough for an existing MSP to be within that 36" radius. Hopefully you aren't seeing instances where things would have been like-for-like in the old rules but suddenly you're stuck with a lift and shift now.
The whole thing about PG&E requiring disconnects to turn off generation and backup sources is such BS. I agree with you that seems like an overreach on their part. I can't imagine PG&E having any normal/good explanation for having to be able to turn off someone's backup ESS.