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PG&E Customers with 3 or more PWs: Interconnection NEM2, NEM2-MT, or NEM2-PS

miimura

Well-Known Member
Aug 21, 2013
6,273
5,906
Los Altos, CA
There are a lot of things that are capable of potentially unsafe activity if used incorrectly. I think it's weird PG&E is worried about the edge case of the PW's spazzing out and becoming massive export systems. IMO the UL listing for the PW's being a Power Control System with export controls ought to sufficient.
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.
 

SVDNN

Member
Sep 23, 2018
50
23
SF Bay Area
Thanks Wayne.

For reference, I pasted the image of table 11.2 from the PDF you cited below.

It seems like any reasonable PV + Tesla Powerwall installation is going to fall under this new NEM2-MT instead of NEM2-PS. Even though there's a thin window to get a NEM2-PS to work, it may require that NGOM compliance or non-export relay installed. And I feel like PG&E isn't ready quite yet to grant blanket exemptions for Tesla Powerwalls for this PS-compliance.

So, assuming I do have to use NEM2-MT (boooo), I haven't been able to get any explanations from Sunrun or PG&E regarding:
1) Whether there is a $800 interconnection fee today
2) Who pays this the interconnection fee if it is $800 instead of $145
3) Whether there are any other one-time tariffs or fees
4) What the impact is to the recurring NBC's on each monthly statement or NEM true-up for people on Mt vs PS
5) Whether I'm supposed to disclose the Powerwalls under the NEM2-MT form section 2.7 as "exporting equipment"
6) Whether I'm allowed to check the second box under Appendix I in the NEM2-MT form
7) Whether I really need to add PG&E to my homeowners insurance

The other stupid thing about the table below is that it's for systems that are not "100% REGF Charged" a Renewable Electrical Generation Facility = (REGF). So 99.999% of the time my Powerwalls will be REGF and only take power from my solar. In the 0.0001% of the time that a Stormwatch comes in, then yeah, it'll take power from the grid.




View attachment 635918

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...



Screen Shot 2021-02-12 at 5.55.52 PM.png
 

MJ_CA_2019

Member
Aug 19, 2020
141
34
Central CA
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.
I have the backup gateway and was able to avoid the NGOM additional meter (PG&E) after the UL listing was approved.
 

MJ_CA_2019

Member
Aug 19, 2020
141
34
Central CA
Is this really the same issue? I'm not sure that it is.

I was following this thread of comments:
upload_2021-2-12_23-41-1.png


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.
 

miimura

Well-Known Member
Aug 21, 2013
6,273
5,906
Los Altos, CA
I was following this thread of comments:View attachment 636324

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.
 
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holeydonut

Supporting Member
Jun 27, 2020
1,540
902
East Bay NorCal
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...



View attachment 636271


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?
 

h2ofun

Active Member
Aug 11, 2020
2,490
426
auburn, ca
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
 

holeydonut

Supporting Member
Jun 27, 2020
1,540
902
East Bay NorCal
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:
upload_2021-2-13_15-31-34.png



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.
 
Last edited:

SMAlset

Well-Known Member
Mar 4, 2017
9,072
9,787
SF Bay Area
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.
 
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SMAlset

Well-Known Member
Mar 4, 2017
9,072
9,787
SF Bay Area
I don't believe I'm aware of what fees Tesla paid on our behalf with PG&E. I might be wrong but wasn't there like an $800 fee associated with the NGOM if it was installed?
 

holeydonut

Supporting Member
Jun 27, 2020
1,540
902
East Bay NorCal
I don't believe I'm aware of what fees Tesla paid on our behalf with PG&E. I might be wrong but wasn't there like an $800 fee associated with the NGOM if it was installed?


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.
 

SMAlset

Well-Known Member
Mar 4, 2017
9,072
9,787
SF Bay Area
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.
 
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holeydonut

Supporting Member
Jun 27, 2020
1,540
902
East Bay NorCal
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.
 

h2ofun

Active Member
Aug 11, 2020
2,490
426
auburn, ca
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.
what kind of policy is that coverage?
 

SMAlset

Well-Known Member
Mar 4, 2017
9,072
9,787
SF Bay Area

holeydonut

Supporting Member
Jun 27, 2020
1,540
902
East Bay NorCal
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.
 

Vines

Active Member
Jul 20, 2018
1,876
2,205
Silicon Valley, CA
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.

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?
 

holeydonut

Supporting Member
Jun 27, 2020
1,540
902
East Bay NorCal
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.
 

MJ_CA_2019

Member
Aug 19, 2020
141
34
Central CA
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.

Does this section exist in your NEMMT agreement? Section 8.1 is the insurance requirements

upload_2021-2-18_21-8-8.png
 
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