PG&E discontinuing EV-A rate

[ohmman]

From an arbitrage standpoint, I estimate that the annual savings is about the same for Powerwalls on EV-A vs. EV2-A. The rate differential on EV2-A is Off-Peak Generation to Peak Consumption, whereas the EV-A differential is Part-Peak Generation to Peak Consumption. The problem is that your surplus solar after the batteries are already filled will be worth less on EV2-A Monday thru Friday.

It's tough to calculate, but I agree (as I mentioned above) that the differential is greater - you're arbitraging off-peak to peak in EV2-A versus part-peak to peak in EV-A. That helps a lot with the DC-AC and charge-discharge efficiency penalties. I've often wondered what the real arbitrage benefit looks like once those and vampire drain are incorporated into the math. Also, there's a lifecycle cost to each discharge/charge cycle on the battery. Theoretically with EV2-A, discharge depth won't be as great because part-peak and peak are delayed by an hour over EV-A.

 

[astrorob]

For residential storage ITC, you must charge 100% from solar. The reduction in the credit between 75% and 100% only applies to commercial storage ITC applications.

It would be very difficult to convince an installer, Tesla or otherwise, to set up your Powerwall system without solar so that you charge from the grid when there is solar on-site. From an arbitrage standpoint, I estimate that the annual savings is about the same for Powerwalls on EV-A vs. EV2-A. The rate differential on EV2-A is Off-Peak Generation to Peak Consumption, whereas the EV-A differential is Part-Peak Generation to Peak Consumption. The problem is that your surplus solar after the batteries are already filled will be worth less on EV2-A Monday thru Friday.

tesla's page about powerwall2 and the california self-generation credit implies that the schedule for charging the powerwalls is user configurable and it's up to you to configure it properly to claim the ca credit... but you are saying that the configuration is static and set by the installer... is tesla's page really in error?

Powerwall Time-Based Control | Tesla Support

in other words if you set up for time based control and cost-savings, it should charge overnight. are you saying that they will restrict this mode if they think you have claimed the ITC?

again, my question is not so much if i can claim the ITC at all, but rather if i can operate for a year in non-solar mode, and then in the 2nd year go to 100% solar (forever from that point) and then claim the ITC in that year. by non-solar mode i don't mean that the PW is not connected to the solar at all, but instead is configured in software to charge overnight.

 

[miimura]

tesla's page about powerwall2 and the california self-generation credit implies that the schedule for charging the powerwalls is user configurable and it's up to you to configure it properly to claim the ca credit... but you are saying that the configuration is static and set by the installer... is tesla's page really in error?

Powerwall Time-Based Control | Tesla Support

in other words if you set up for time based control and cost-savings, it should charge overnight. are you saying that they will restrict this mode if they think you have claimed the ITC?

again, my question is not so much if i can claim the ITC at all, but rather if i can operate for a year in non-solar mode, and then in the 2nd year go to 100% solar (forever from that point) and then claim the ITC in that year.

You are misunderstanding where the different configuration levels are. When the system is installed there is a binary configuration - does the system pair with solar or is it standalone without solar. In the USA, that fundamental choice determines whether the system charges from the grid or charges only from solar. After that, all the configuration in the app works the same way, as shown on that Tesla support page. However, the charging behavior will be different depending on the solar/no-solar choice during commissioning. So, my statement about convincing the installer refers only to that solar/no-solar step in commissioning.

I am not a tax expert, so I don't know whether you can defer taking the ITC until you start using it in a compliant manner. I suspect not, mostly because you did not incur the expense in the tax year that you would be trying to take the credit. As with many tax issues, it's all good until you get audited. Then you find out what is actually acceptable or not.

The SGIP has its own requirements. Basically, if you take their rebate, they are requiring you to cycle the Powerwall to reduce the Peak consumption on the grid. IIRC, you must configure the system to make the equivalent of at least one full discharge per week. So, you cannot just leave it in Backup mode after taking that rebate.

 

[ohmman]

I am not a tax expert, so I don't know whether you can defer taking the ITC until you start using it in a compliant manner. I suspect not, mostly because you did not incur the expense in the tax year that you would be trying to take the credit. As with many tax issues, it's all good until you get audited. Then you find out what is actually acceptable or not.

I'm also not a tax expert (@cpa is, so I'll tag him in) but this aligns with what I'd expect as well. They likely need to be installed in concert with one another.

 

[astrorob]

You are misunderstanding where the different configuration levels are. When the system is installed there is a binary configuration - does the system pair with solar or is it standalone without solar. In the USA, that fundamental choice determines whether the system charges from the grid or charges only from solar. After that, all the configuration in the app works the same way, as shown on that Tesla support page. However, the charging behavior will be different depending on the solar/no-solar choice during commissioning. So, my statement about convincing the installer refers only to that solar/no-solar step in commissioning.

i mean, that's fine; i am not a tesla installer nor do i have access to their technical documentation. the tesla website implies (and later says) that the end user can change the mode, so that's what i was going off of. the website does not seem to make any distinction between solar and non-solar except to say that the "balanced mode" is only available when paired with solar.

I am not a tax expert, so I don't know whether you can defer taking the ITC until you start using it in a compliant manner. I suspect not, mostly because you did not incur the expense in the tax year that you would be trying to take the credit. As with many tax issues, it's all good until you get audited. Then you find out what is actually acceptable or not.

right - my tax guy doesn't know so i wondered if anyone here had faced this problem. there does seem to be a lot of wiggle room in when you can claim the credit - this IRS guidance is focused on how *early* you can claim the credit, since the sunsetting portion of the ITC is predicated on when construction is have said to have begun:

Commence Construction Guidance | SEIA

anyway i agree that the mismatch between tax years could be a problem. and i'm not sure this would necessarily trigger an audit - when i bought my leaf back in 2011 i claimed the EV tax credit and simply got a letter in the mail that the tax credit was denied and that i had to send them further proof of purchase. when i talked to the inspector on the phone, he said that congress had explicitly told them to crack down on that particular credit as people were trying to claim VINs belonging to ford pickup trucks, etc. i sent the guy my sales contract and they approved the credit. i suppose the worst that happens here is the same - other than that my taxes are very simple so there's not a lot for them to comb over - i'm not depreciating anything for instance.

The SGIP has its own requirements. Basically, if you take their rebate, they are requiring you to cycle the Powerwall to reduce the Peak consumption on the grid. IIRC, you must configure the system to make the equivalent of at least one full discharge per week. So, you cannot just leave it in Backup mode after taking that rebate.

right, i was only mentioning that because that's the first page that talks about how the charge/discharge behavior is user configurable, at least in some capacity.

I'm also not a tax expert (@cpa is, so I'll tag him in) but this aligns with what I'd expect as well. They likely need to be installed in concert with one another.

this would be a powerwall installation after solar's already been installed. i think that's still eligible for the various credits.

 

[ohmman]

this would be a powerwall installation after solar's already been installed. i think that's still eligible for the various credits.

Gotcha. I did the same - installed my PWs after solar was installed. But I never applied for the ITC. I suppose that means that technically Tesla could unlock grid charging for me.

 

[greendublin]

No.

I'm in a similar situation: my original NEM1 date was in 2003, I switched to EV-A a year ago. Due to a roof leak I decided to get a new PV system which was just installed. Then I got the letter saying I will be moved to EV-2A. I called the PG&E Solar Hotline today, the rep had to ask two levels up but the answer was no, they will use the original NEM1 PTO date even if tell them I removed my old PV, go off NEM for a billing cycle, and then reapply with the new PV under NEM2. You can see the grandfathering dates at this link under the section titled WHEN WILL NEM CUSTOMERS BE TRANSITIONED TO THE NEW EV RATE?

Explore EV Fundamentals

@MikeW There seems to be a discrepancy on grandfathering for PG&E customers who switched from NEM1 to NEM2. I am in the same boat as you. However, @TallCoolOne, who has a similar situation with NEM1 and NEM2, got his rate grandfathered (the posts are earlier in the thread). I don't see anything in the Regulation that states what happens to grandfathering for PG&E customers that switched from NEM1 to NEM2. I believe it is a gray area and various customer support reps are making a decision based on their own.

 

[cpa]

I'm also not a tax expert (@cpa is, so I'll tag him in) but this aligns with what I'd expect as well. They likely need to be installed in concert with one another.

I'd have to know more electronic engineering detail and the policies and regulations of the organization that consents to this arrangement.

The rule that cash basis taxpayers can only take a deduction or credit in the year of expenditure is generally true. But, like most things taxing, there are exceptions. Here is a real-life example from my "Forensic Files!"

Client purchased a series of machines consisting of several different components from two different European manufacturers. A local third company assembled and installed these components. The total costs were around $3.5 million. These costs were paid in full in 2017. The equipment was ready to use, but product was not available to begin testing and calibrating the equipment until 2018. We showed the $3.5 million as construction in progress on the balance sheet on the 2017 returns. We placed this equipment in service in March 2018 when product started running, calibrations made, and small repairs were performed. Depreciation was taken in 2018.

Even though this client is an accrual basis taxpayer, the same tax rule applied. The equipment was not fit to be placed into service until testing and calibrating had been completed in order to claim depreciation.

I would suspect that the order of magnitude of the equipment in question is not very significant. Even upon audit, satisfactory, credible, and competent representation from a utility, electrician, and other uninterested third parties would be all that would be necessary to support a taxpayer's position. It is not worth the Service's time to hire outside engineers and others to rebut the taxpayer's position for a $10-$20,000 tax credit.

 

[ohmman]

I'm toying around with a spreadsheet to estimate the difference in arbitrage opportunity between EV-A and EV2-A. My current assumptions are that the Powerwall roundtrip efficiency is 92.5% (based on the data sheet), that losses between the installation and the meter "net out" when comparing to selling to the meter, and that there is no marginal cost to the additional charge/discharge cycles (more on that shortly).

With EV-A, PWs are charged during part-peak in the morning, which makes the arbitrage spread smaller. With EV2-A, the PWs are charge during off-peak in the morning, giving a wider spread. Assuming the efficiency numbers above, the arbitrage opportunity per kWh between the two are:

Summer EV-A: 0.22214
Summer EV2-A: 0.29934
Winter EV-A: 0.12836
Winter EV2-A: 0.17223

While EV2-A is much more favorable with this metric, one has to remember that most of us aren't storing all off-peak or part-peak power to our Powerwalls. I'm generally done topping up my batteries prior to noon, at which time I begin exporting to the grid at part-peak on EV-A. I will only be exporting at off-peak rates on EV2-A. I have to come up with reasonable time-of-year estimates for Powerwall consumption so that I can better model this, and I'm open to any ideas people have. But I think it's pretty clear that this minor difference in arbitrage rates isn't going to make up for the significant difference in grid export pricing. Part-peak on EV-A is 0.28917, and off-peak on EV2-A is 0.16234, which represents a 44% decrease in export revenue when I'm not storing energy.

I still haven't spoken with PG&E about the unlikely potential for grandfathering into EV-A for a while longer. Assuming I cannot do so, I really do think I'll be changing consumption behavior at the house to utilize my solar and not allow PG&E to pay me peanuts while selling it to my neighbors at theoretically higher rates.

 

[cpa]

Ohmman, we do not know what is going to happen once PG&E is negotiating with creditors, the State of California, and other interested parties in bankruptcy court. There has been a hue and cry from the lawyers representing us ratepayers that we need a seat at the table. To date, the bankruptcy judge has not ruled on this motion. However, the last time PG&E was in bankruptcy in the early 00s, the court told us ratepayers to pound sand. The tariffs that had been in place were torn up, and new tariffs took their place. (At least this is my fuzzy recollection.)

Bankruptcy courts (Article II courts) wield a lot of power, and in those instances where they are prohibited by statute to make decisions, their opinions are weighed heavily by the district courts (Article III courts) who can make these decisions. If we ratepayers do not get to negotiate with the courts in bankruptcy, past may be prologue, and who really know what tariffs will emerge and what they will cost?

Your exercise seems like a worthy one. I just hope you do not have to tear up your calculations and start anew if we get a nasty curve ball thrown to us when PG&E emerges from bankruptcy late next year.

 

[ohmman]

Well, as it turns out, I have some decent news from PG&E. The wording says that for the purposes of grandfathering, PG&E is to use the earliest PTO on the current tariff. Because installing Powerwalls in May of 2018 required them moving me to NEM2 (NEM-PS), that PTO is the earliest on my current tariff and will be used for grandfather purposes.

More importantly, I was told that for most residences with similar storage (one to two Powerwalls), EV2-A is not an eligible rate anyway, and those on EV-A will not be moved. I asked if this was across the board for storage, and he said it was not, but that it would pretty widely apply. He suggested that those with storage on the EV-A rate plan should call ASAP to clarify. I called the PG&E number provided by @miimura (877-743-4112).

@MikeW, I see you're a long time member but an infrequent poster so I'm not sure if you are frequently lurking. If so, I wonder if the bolded text in my original paragraph would apply to you since you've been moved to NEM2 already. Perhaps because you moved after the rate plan was approved it does not apply. And you didn't mention storage, so I'm not sure if you have that protection or not.

I definitely suggest that those with storage give PG&E a call. I'm good until November 2023..

 

[miimura]

When calculating arbitrage remember that EV-A has weekend schedule that has no Part-Peak and shorter Peak hours. If forced to EV2, I will set the Powerwalls so all the Part-Peak and Peak are set as Peak in the app, at least during the Summer when I have sufficient generation. During the Winter I don't have enough, so will fall back to just offsetting Peak.

Thanks for the heads up about Powerwall customers and EV2 migration. I really need to call them now.

 

[SoundDaTrumpet]

I'm toying around with a spreadsheet to estimate the difference in arbitrage opportunity between EV-A and EV2-A. My current assumptions are that the Powerwall roundtrip efficiency is 92.5% (based on the data sheet), that losses between the installation and the meter "net out" when comparing to selling to the meter, and that there is no marginal cost to the additional charge/discharge cycles (more on that shortly).

With EV-A, PWs are charged during part-peak in the morning, which makes the arbitrage spread smaller. With EV2-A, the PWs are charge during off-peak in the morning, giving a wider spread. Assuming the efficiency numbers above, the arbitrage opportunity per kWh between the two are:

Summer EV-A: 0.22214
Summer EV2-A: 0.29934
Winter EV-A: 0.12836
Winter EV2-A: 0.17223

While EV2-A is much more favorable with this metric, one has to remember that most of us aren't storing all off-peak or part-peak power to our Powerwalls. I'm generally done topping up my batteries prior to noon, at which time I begin exporting to the grid at part-peak on EV-A. I will only be exporting at off-peak rates on EV2-A. I have to come up with reasonable time-of-year estimates for Powerwall consumption so that I can better model this, and I'm open to any ideas people have. But I think it's pretty clear that this minor difference in arbitrage rates isn't going to make up for the significant difference in grid export pricing. Part-peak on EV-A is 0.28917, and off-peak on EV2-A is 0.16234, which represents a 44% decrease in export revenue when I'm not storing energy.

I still haven't spoken with PG&E about the unlikely potential for grandfathering into EV-A for a while longer. Assuming I cannot do so, I really do think I'll be changing consumption behavior at the house to utilize my solar and not allow PG&E to pay me peanuts while selling it to my neighbors at theoretically higher rates.

I took the effort to build a spreadsheet to do the comparison. To qualify my spreadsheet, I was able to match the rate tool provided by PG&E within 0.5% at the time. This validation was only possible because I did not commission the system yet. The rate tool works well ONLY as a standard solar user. It will be a challenge to validate a homemade spreadsheet as a sanity check. For this, I will keep old data to test tweaks to my spreadsheet.

After commissioning of the Powerwall, I cannot make sense of the bills AND the rate tool estimator does not work anymore. This said, I have revealed that EV2-A is just plain terrible for the simple reason is that under EV2-A, surplus generation is sold to PG&E at off-peak prices (dimes). Under EV-A, surplus was bought by PG&E for much more (quarters). After EV-A sunsets/expires for me, all rate schedule cost the same according to PG&E. I have not yet modeled other non-EV TOU rates schedules nor E-1.

One thing for certain. When my 5 year commitment to satisfy SGIP requirements (state incentive) passes, I will be switching back to E-1 flat rate for another 20 years. I am certain PG&E will think of a way to force me to use Powerwalls: (a) Entice via a high compensation demand response program, or (b) Edict to eliminate the grandfathering by the Governor.

 

[ohmman]

Furthermore, to firm up my analysis: my energy use behaviors will not change as a result of EV2-A. I am currently charging my EV at midnight which is off-peak for both EV2-A and EV-A. The Time Based Control I have setup follows the EV2-A rate schedule already (except from 3-4pm).

While this is entirely true from a cost perspective, from an overall efficiency standpoint you're probably better off charging your EV from your own solar pre-3pm. It's likely that doesn't work for your schedule or convenience, but it reduces nighttime load on the grid, which is when it is supplied with a higher GHG mix, and there are less transmission losses keeping it all under the roof.

For me, it was just the frustration that PG&E would be buying for dimes and selling to my neighbors on different rate plans at potentially higher rates. While I enjoy arbitraging their rates, I (perhaps unjustly) cannot stand the idea of PG&E arbitraging my solar..

 

[astrorob]

wow - so if i read you right, even though EV2-A is not somehow 'compatible' with storage, they would allow you to stay on EV-A instead of forcing you on to E-TOU-A? if that's the case i absolutely need to add storage in order to avoid the $800-$1000 increase in my yearly bill that E-TOU-A would represent.

my NEM1 PTO was nov 2015, so i guess that gives me a year to get some PW2s installed... however, so far i am having no luck getting any local installer's attention. if i were to go with tesla direct, as i understand it, i wouldn't be able to claim the SGIP rebate since they seem to be fully subscribed.

 

[GenSao]

wow - so if i read you right, even though EV2-A is not somehow 'compatible' with storage, they would allow you to stay on EV-A instead of forcing you on to E-TOU-A? if that's the case i absolutely need to add storage in order to avoid the $800-$1000 increase in my yearly bill that E-TOU-A would represent.

my NEM1 PTO was nov 2015, so i guess that gives me a year to get some PW2s installed... however, so far i am having no luck getting any local installer's attention. if i were to go with tesla direct, as i understand it, i wouldn't be able to claim the SGIP rebate since they seem to be fully subscribed.

@astrorob ,

Depending how things play out, Tesla may still be an option early next year as SGIP is extended. Although Tesla is fully subscribed, how additional funds for wait-listed Step 5 and future allocations are distributed have not been determined yet.

They are in the process on updating SGIP moving forward. I anticipate new funds will not be available till (likely) the later of the following dates:

• April 1, 2020: Effective date of California PUC Decision D.19 08 001 and related changes for SGIP.
• July 1, 2020: the new fiscal year when money is available.

Funds may be available sooner depending on how/when they relocate the unspent funds. Keep an eye out for the final process.

 

[JPP]

Well, as it turns out, I have some decent news from PG&E. The wording says that for the purposes of grandfathering, PG&E is to use the earliest PTO on the current tariff. Because installing Powerwalls in May of 2018 required them moving me to NEM2 (NEM-PS), that PTO is the earliest on my current tariff and will be used for grandfather purposes.

More importantly, I was told that for most residences with similar storage (one to two Powerwalls), EV2-A is not an eligible rate anyway, and those on EV-A will not be moved. I asked if this was across the board for storage, and he said it was not, but that it would pretty widely apply. He suggested that those with storage on the EV-A rate plan should call ASAP to clarify. I called the PG&E number provided by @miimura (877-743-4112).

@MikeW, I see you're a long time member but an infrequent poster so I'm not sure if you are frequently lurking. If so, I wonder if the bolded text in my original paragraph would apply to you since you've been moved to NEM2 already. Perhaps because you moved after the rate plan was approved it does not apply. And you didn't mention storage, so I'm not sure if you have that protection or not.

I definitely suggest that those with storage give PG&E a call. I'm good until November 2023..

Nuts--my solar PTO was in 2013. I am to be rolled off of EV-A in November. My 2 Powerwalls will not likely be installed until end December. I for sure am not choosing the new EV2-A plan as it is by far the most expensive for me. I was just going to pick the old TOU plan rather than the E-1 flat rate (...roughly the same $$ hit for me) and maybe with the Powerwalls it will work out OK. Really a no-win with PG&E...they continue to move the target and punish solar customers.

 

[wwhitney]

Well, as it turns out, I have some decent news from PG&E. The wording says that for the purposes of grandfathering, PG&E is to use the earliest PTO on the current tariff. Because installing Powerwalls in May of 2018 required them moving me to NEM2 (NEM-PS), that PTO is the earliest on my current tariff and will be used for grandfather purposes.

Were you on NEM1 prior to your Powerwall PTO, and did you add any solar when you added the Powerwall? If "yes, no" then you could have stayed on NEM1, which is my situation. I have solar under NEM from 2012 (so NEM1), and last year I added Powerwalls and stayed on NEM1, via NEM-MT instead of plain NEM. [One reason I handled my own interconnection for the Powerwalls with PG&E was that when I asked Tesla last year about whether adding Powerwalls would force me to switch to NEM2, they were clueless.]

Based on your post, I called up the PG&E Solar Customer Service, and the answer I got was that the phrase "current tariff" refers to NEM1 versus NEM2, and not plain NEM versus NEM-MT (or NEM-PS, something I'm not familiar with but you mentioned, presumably NEM Paired Storage).

So if you were on NEM1 prior to the Powerwalls, and NEM2 now, at least the answers we got from PG&E are consistent. That raises the question, would it be worth voluntarily switching from NEM1 to NEM2 in order to extend eligibility for EV-A? Probably too late to do now anyway.

Cheers, Wayne

 

[wwhitney]

That raises the question, would it be worth voluntarily switching from NEM1 to NEM2 in order to extend eligibility for EV-A? Probably too late to do now anyway.

The EV tariff from PG&E is available here: https://www.pge.com/tariffs/assets/pdf/tariffbook/ELEC_SCHEDS_EV (Sch).pdf I excerpted the relevant section below. The last sentence suggests this would be possible. I haven't had time to unpack the whole paragraph or look up the CPUC references.

Cheers, Wayne

Pursuant to D.17-01-006, as revised by D. 17-02-017 and D. 17-10-018, for grandfathered service, certain solar customers will be allowed to continue service on Rate A of this schedule. Specifically, solar customers that interconnected by December 16, 2016, and elected service under Schedule EV prior to July 31, 2017, are allowed to retain service under this schedule for five years after issuance of the permission to operate, but no later than July 31, 2022. In addition, pursuant to D. 16-01-044, net energy metering customers that interconnected after December 15, 2016 and elected service on Rate Option A of this rate schedule may also continue service on this rate schedule for a period of 5 years from the date the customer commenced service on the NEM 2.0 rate, but no later than November 30, 2025. Existing EV-A customers seeking to commence service on NEM2.0 rate and continue service on EV-A for up to 5 years must submit an interconnection application by November 30, 2019.

 

[KSilver2000]

Nuts--my solar PTO was in 2013. I am to be rolled off of EV-A in November. My 2 Powerwalls will not likely be installed until end December. I for sure am not choosing the new EV2-A plan as it is by far the most expensive for me. I was just going to pick the old TOU plan rather than the E-1 flat rate (...roughly the same $$ hit for me) and maybe with the Powerwalls it will work out OK. Really a no-win with PG&E...they continue to move the target and punish solar customers.

Not just PG&E. They’re actually late to the party rolling out EV2 as other utilities around the country already shifted their times with new EV/TOU rates awhile back.