I believe the PCS listing was only done for Gateway 2. I don't think the original Backup Gateway in the gray box can do that level of limiting, just the normal power flow control based on the CT measurements.
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PG&E Customers with 3 or more PWs: Interconnection NEM2, NEM2-MT, or NEM2-PS
- Thread starter holeydonut
- Start date
DISCLAIMER: I am not a lawyer...
I had similar feelings (WTF??!!!) when reading section 8 of interconnection agreement about liability insurance requriement.
But, I would take section 8 in this as PG&E doing CYA moves only IF someone purposely jerry-rigged available output from PW storage by non-REG to discharge back to grid for profit during peak times. With section 8.3 waiving the insurance requirement for "soley" REGF use, which you admit is 99.999% time of your (and our) intended use, I am personally less concerned about the insurance requirement. And I assume why not much discussed about the insurance requirement by installers/users. I assume the use of Storm Watch, which is allowed by PG&E and facilitated by Tesla, is an exception to this that is just not explicitly covered in contract and again not intended for return output to the grid.
Rest of your questions...have no personal knowledge and would like to know, and had
assumed Tesla paid interconnect fees.
Just my take on things...
I have the backup gateway and was able to avoid the NGOM additional meter (PG&E) after the UL listing was approved.
I was following this thread of comments:
During the review of my interconnection agreement (late 2019, early 2020) I was told that I'd need a NGOM to monitor my solar generation because the backup gateway didn't have the UL to prove that it wouldn't export to the grid. I told my installer to wait because I didn't want the additional meter and the associated rework. After the UL was approved (June 2020 is when I found out) then PG&E dropped the NGOM requirement and gave me PTO. Is that not exactly what the UL was? Power Control System with export controls?
If i'm off in unrelated land my apologies.
I understand your situation and what you're saying. There is a specific new Power Control System feature in the Gateway 2 that allows the batteries to fill in power to avoid overloading the grid connection. I'm saying that the certification that allowed the elimination of the NGOM and the PCS certification are separate, especially considering that the NGOM elimination applies to Backup Gateway 1 and Gateway 2, while the PCS feature is only available on Gateway 2. However, I'm a bit out of my depth and I may be wrong. Someone like @Vines would know better.
Yeah, that whole MT form is just idiotic for a normal homeowner installation of Tesla ESS and PV. It seems geared toward some large parcel with multiple generation sources and crude batteries that don't have built-in power control systems.
I get it... PG&E is worried about a 200 A backfeed damaging a transformer at an inopportune time. Plus PG&E doesn't want some bad apple cleverly gaming of the TOU rates and NEM credits with timing of grid export.
The frustrating part of this is that I don't think a Tesla Powerwall 2 and Gateway 2 can grid export stored battery energy even if I tried. I can't find a single example of someone figuring that out, but PG&E is making all new installs (potentially) pay $800+ in tariffs and likely higher monthly NBC's just because PG&E is worried we'll actually do it.
I've told PG&E repeatedly during phone calls and in-person visits that the reason I put PV + ESS on my house is to use their grid as little as possible. I couldn't fit enough panels and storage to go 100% off grid. But I want to take as little power from them as possible and I'm not pushing anything from my batteries back to them. I couldn't push stored ESS energy to them even if I tried.
They always respond with "But you could figure out a hack or the Tesla software can fail. So PG&E has to make sure the homeowner governed from harming PG&E."
As others have pointed out; where was this mentality from PG&E when their gas lines were blowing up homes and setting homes on fire?
Do you have any data that says NBC's will be higher? Not hearing that from all the folks already on the MT plan
All I have is this table about NEM from a few years ago:
When I asked them (since it says "ask") what the Rule 21 NBC's were for NEMMT PG&E and Sunrun said ¯\_(ツ)_/¯
I think it's also not a good comparison to take the older (haha, 2 years ago is old) examples from TMC compared to a new installation in 2021. It seems when they finally brought NEMMT online for some people who used to be on NEM1 and NEM2, there were no extra fees assessed since those people were effectively grandfathered.
But if you or I sign up today, I can't tell (primarily because I've never seen a NEM bill) if there would be higher one-time tariffs or higher recurring monthly NBCs under NEMMT vs NEMPS or NEM2.
Honestly, the fact that I can't even get an answer about whether there is a $800 up front tariff for me is just stupid. It's like they're pushing policies without any clue what is the impact. But they can do this since they're the monopoly and the CPUC is toothless.
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We have an 8.16 kW solar system (340W panels, 24) and 3 PWs (40.5 kW ESS). The system includes the Gateway2, SolarEdge SE7600H-US inverter, and we requested and received approval from PG&E for the removal of the NGOM that was going to be installed per our plans (request made after having reading Haytae's thread on the NGOM not being required any longer due to Tesla's certification approval). We were previously on an EV2A rate plan. I'll also mention, and not sure if relevant, that our area has a generation aggregate (Silicon Valley Clean Energy) which specifies how our energy is sent back and credited at what rate to us which does differ from what it would be under PG&E from what I understand. We have two differing true-ups, April for SVCE and I believe November for PG&E (PTO approved at end of October).
Here's info from our Interconnection Agreement (NEM2MT).
2.5.1 -- PV 7.616 kW; Storage/Batteries (NEM eligible only) 15.000 Inverter kW
2.5.3 -- Total Gross Nameplate Rating of the Generating Facility: 22.616 kW
2.6.1 -- PV 7.558 kW; Storage/Batteries (NEM eligible only) 15.000 Inverter kW
2.6.3 -- Total Net Nameplate Rating of the Generating Facility: 22.558 kW
2.7.1 -- PV 7.616 kW; Storage/Batteries (NEM eligible only) 15.000 Inverter kW
2.7.3 -- Total Maximum level of power that may be exported by the Generating Facility: 22.616
Box checked for: does not meet the requirements for cogeneration as such term is used in Section 216.6 of the PUC code.
2.10 -- Requirements....PV are met; other technology are met
2.11 -- Customer-Generator's otherwise-applicable-rate schedule as of the execution of this agreement is: EV2A
Appendix A -- Description of the Generating Facility and Single-Line Diagram (description includes language about non-export, inadvertent export and continuous export seconds and range of export. Diagram to included point of interconnection, location and type of protection equipment and identifying disconnect switches)
Appendix B -- Rules "2" and "21"
Appendix I -- box checked: "Producer's storage device(s) will not cause the Host Load to exceed its normal peak demand....
Given our system, hopefully our agreement specifics might help answer some questions. This was prepared on Form 79-1069-02, Advice 5667-E, October 2019.
Here's info from our Interconnection Agreement (NEM2MT).
2.5.1 -- PV 7.616 kW; Storage/Batteries (NEM eligible only) 15.000 Inverter kW
2.5.3 -- Total Gross Nameplate Rating of the Generating Facility: 22.616 kW
2.6.1 -- PV 7.558 kW; Storage/Batteries (NEM eligible only) 15.000 Inverter kW
2.6.3 -- Total Net Nameplate Rating of the Generating Facility: 22.558 kW
2.7.1 -- PV 7.616 kW; Storage/Batteries (NEM eligible only) 15.000 Inverter kW
2.7.3 -- Total Maximum level of power that may be exported by the Generating Facility: 22.616
Box checked for: does not meet the requirements for cogeneration as such term is used in Section 216.6 of the PUC code.
2.10 -- Requirements....PV are met; other technology are met
2.11 -- Customer-Generator's otherwise-applicable-rate schedule as of the execution of this agreement is: EV2A
Appendix A -- Description of the Generating Facility and Single-Line Diagram (description includes language about non-export, inadvertent export and continuous export seconds and range of export. Diagram to included point of interconnection, location and type of protection equipment and identifying disconnect switches)
Appendix B -- Rules "2" and "21"
Appendix I -- box checked: "Producer's storage device(s) will not cause the Host Load to exceed its normal peak demand....
Given our system, hopefully our agreement specifics might help answer some questions. This was prepared on Form 79-1069-02, Advice 5667-E, October 2019.
Thanks! I’m guessing you just ignored the section asking PG&E to be named on your homeowners insurance? It’s good they let you check the second box in the appendix I to allow non-peak grid charging.
What are your monthly bill NBC’s?
The $800 is described here and is a pure interconnection fee. (Normally it is $145).
Net Energy Metering Multiple Tariff (NEMMT)
Best case for me and H2ofun is there isn’t actually a $800 fee at this time.
The NGOM was another ~$1,400 estimate fee because PG&E would have to install the meter.
Lots of typing really late at night. The form was prepared for my husband’s sig. As for the insurance part I assume similar to what members here I think in Florida posted they had as a requirement/obligation to provide to their utility. Seem to recall some Million dollar or such numbers being thrown out from members and discussion on the thread about cost of such extra insurance protection. Understandable that if you are “attaching” equipment to their system which they are not installing and is not theirs that they’d want some level of coverage should it be faulty.
Thanks for the info, I didn't realize there were other PoCo's out there that have similar requests; especially around insurance.
I've pinged my insurance agent to see what the incremental cost is for the $1,000,000 coverage I'll need on my 22 kW gross system.
I've pinged my insurance agent to see what the incremental cost is for the $1,000,000 coverage I'll need on my 22 kW gross system.
Had a few minutes and found the thread Florida members posted on it.
Florida solar utility liability insurance requirements
Ugh, I just got lawyered... apparently back in May 2020 I actually signed a preliminary set of documents with Sunrun. In the package was a NEMMT agreement. But back then I was a dummy dumbs (I didn't even have a TMC account!), and I didn't understand the scope of what I was signing.
While I didn't get the "FULL" NEMMT contract at that time, technically I did sign one of the pages stating I would conform with Rule 21 which includes the language around insurance and includes the clause around no-grid-charging or exporting without PG&E's approval.
Ugh I hate lawyers.
While I didn't get the "FULL" NEMMT contract at that time, technically I did sign one of the pages stating I would conform with Rule 21 which includes the language around insurance and includes the clause around no-grid-charging or exporting without PG&E's approval.
Ugh I hate lawyers.
Bummer, I expect that to be the same for mine, but it doesn't hurt to ask.
I wonder if PG&E would get all butthurt about stormwatch charging the batteries if you had checked no grid charging? Surely they don't intend that people don't charge up batteries before a storm?
The version of the NEMMT form that I signed almost a year ago didn't include the section 2.7 or Appendix I. I'm still not sure why Sunrun even had the "you agree to Rule 21" page in there.
I miss the old days when I thought this would be an easy project. That was 44 weeks ago and I still don't have PTO
PG&E is all over the place. But it's clear someone over there thinks Tesla Powerwalls are bad for business. And Powerwalls are evil because they can export in full force to the grid during peak times and could blow up transformers.
Does this section exist in your NEMMT agreement? Section 8.1 is the insurance requirements
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