Does this section exist in your NEMMT agreement? Section 8.1 is the insurance requirements
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Yeah the most recent NEM2-MT agreement (the full one that I have yet to sign) has that 8.3 clause. But that 8.3 clause directly contradicts what I need to put on Appendix I.
One could have a ESS that derives 100% of its energy from renewable sources. If so, by the definition of the PDF that @wwhitney linked earlier, such system is a "REGF" (Renewable Electrical Generation Facility). If it is REGF, that means it cannot be grid-charged. So under Appendix I of the NEM2-MT agreement the first box must be checked to never allow grid charging under the agreement. And you're right, a homeowner need to add extra insurance under 8.1; they just need to put PG&E as a named insured under 8.2 with their standard homeowners policy.
But if the ESS can be Stormwatch enabled to take energy from the grid in an emergency, it is not REGF. Because now it can be grid charged. In this case, second check box should be used under Appendix I. But that also means 8.1 must be hoored and extra insurance added. 8.2 would still require PG&E to be named insured.
I think a reasonable interpretation is "Stormwatch" isn't a normal event. But nowhere in the docs does PG&E give a homeowner an escape clause for emergency charging.
The worst part of all of this is that all these documents punish Tesla Powerwalls because PG&E treats them as having the ability to grid-export whenever the homeowner wants. And that simply just makes this whole mess garbage.