PGE: Do I lose granfathered NEM if I add batteries?

[NorCalSlrUser]

E.g, is it a whole new interconnect agreement?

I was thinking about adding batteries later, if prices go down but if it means losing NEM2.0, and also no ITC credit, maybe it is better to add them this year. I do not need them for backup, only for future protection in case PGE keeps changing the TOU rates and periods, e.g. if they add rates where the evening rates are much higher than daytime, then you pretty much need batteries. And you need NEM to carry summer overproduction to winter.

 

[Ampster]

There is no succesor to NEM 2.O so you would not lose NEM. Do you mean the ITC that you already took or the possible ITC on batteries? If you take SGIP funds there maybe some additional constraints in a new or modified NEM agreement. Others who have SGIP funded installs have suggested they are not significant constraints.
My own hybrid battery system is behind the meter without SGIP constraints so it does not affect my NEM agreement. It just required a building permit, not PG&E approval.

 

[wwhitney]

If the correct forms are filed, adding storage does not affect your NEM 1.0 vs NEM 2.0 status.

My own hybrid battery system is behind the meter without SGIP constraints so it does not affect my NEM agreement. It just required a building permit, not PG&E approval.

I'm doubtful that's true, did PG&E itself tell you that you didn't need to switched to NEM Paired Storage?

Cheers, Wayne

 

[Ampster]

I'm doubtful that's true, did PG&E itself tell you that you didn't need to switched to NEM Paired Storage?

The important assumption is that my system is "behind the meter". A lineman told me that they considered it the same as a generator and as long as it had an interlock they did not care. The building department in my county also confirmed that assumption.
It is possible that cities with municipal utilites have building codes that overlap with their own city owned utility. I have done some research and asked on several forums. So far no one has pointed out where, in any code in California, an Investor Owned Utility has any jurisdiction over what I do behind the meter. I am open to other opinions based on documentation.

I agree many people make the assumption that the power companies are all powerful. Indeed, I am required by the code to have a hookup if one is provided and pay minimum charges for that service. However, I am not required to purchase power. FWIW, I am a retired financial executive with a background in risk management and construction and not a prepper.

 

[h2ofun]

The important assumptiin is that my system is behind the meter. A lineman told me that they considered it the same as a generator and as long as it had an interlock they did not care. The building department in my county also confirmed that.
It is possible that cities with municipal utilites have building codes that overlap with their own city owned utility. I have done some research and asked on several forums. So far no one has pointed out where in any code in California an Investor Owned Utility has any jurisdiction over what I do behind the meter. I am open to other opinions based on documentatiin.

what they do not know cannot hurt them?

 

[Ampster]

what they do not know cannot hurt them?

They know and my point is they do not have jurisdiction.
Since you raised the question, does PG&E know that you have a means of backup and are applying for a taxpayer funded ER SGIP program that is redundant with the backup that you already have? Is there somewhere in that application that you certify that you have no other means to power your well or your medical device?
If the application does not ask that question, it is my opinion that it should ask that question. It all depends on where you are standing.

 

[h2ofun]

They know and my point is they do not have jurisdiction.
Since you raised the question, does PG&E know that you have a means of backup and are applying for a taxpayer funded ER SGIP program that is redundant with the backup that you already have? Is there somewhere in that application that you certify that you have no other means to power your well or your medical device?
If the application does not ask that question, it is my opinion that it should ask that question. It all depends on where you are standing.

The main part of the SGIP program is to not use energy from the grid, especially at peak times. This is why one has to cycle the batteries 52 times a year, for 5 years. I could have zero power outages and still have to meet this requirement. If this were not the case folks would not be forced onto ev2-a tou plans.

 

[jjrandorin]

E.g, is it a whole new interconnect agreement?

I was thinking about adding batteries later, if prices go down but if it means losing NEM2.0, and also no ITC credit, maybe it is better to add them this year. I do not need them for backup, only for future protection in case PGE keeps changing the TOU rates and periods, e.g. if they add rates where the evening rates are much higher than daytime, then you pretty much need batteries. And you need NEM to carry summer overproduction to winter.

OP, it is a new interconnect agreement, but as was pointed out, adding storage to an existing PV system does not impact ones NEM agreement (at least not at this time it doesnt).

I had PV installed in 2015, and did not add powerwalls (storage) until Jan of 2020. I am still on NEM 1.0. The new interconnect agreement has some verbiage there or a checkbox or something but I am saying that from memory.

So, while adding storage does require a new interconnect agreement, it doesnt trigger a change in your NEM agreement. All this stuff is always "at this time" though, so no telling what it will look like whenever they get around to changing to NEM 3.0 or whatever it ends up being.

 

[h2ofun]

OP, it is a new interconnect agreement, but as was pointed out, adding storage to an existing PV system does not impact ones NEM agreement (at least not at this time it doesnt).

I had PV installed in 2015, and did not add powerwalls (storag) until Jan of 2020. I am still on NEM 1.0. The new interconnect agreement has some verbiage there or a checkbox or something but I am saying that from memory.

So, while adding storage does require a new interconnect agreement, it doesnt trigger a change in your NEM agreement. All this stuff is always "at this time" though, so no telling what it will look like whenever they get around to changing to NEM 3.0 or whatever it ends up being.

I believe the goals is to define and roll out NEW 3.0, and if and any changes to NEM 1 and or NEM2 by the end of this year.

 

[wwhitney]

The important assumption is that my system is "behind the meter".

I'm fairly sure that if you have a battery based grid-tie inverter connected to your premises wiring system, and hence to the grid, that requires an Interconnection Agreement with your power company under CPUC's Rule 21. Even if your inverter is configured to be Non-Exporting, you still need a Non-Export Interconnection Agreement.

https://www.cpuc.ca.gov/Rule21/#:~:text=Electric Rule 21 is a,to a utility's distribution system.

A backup engine generator is to be installed via a transfer switch so that it is never directly connected to the grid; your premises wiring system is disconnected from the grid before the generator may energize it. This usage apparently does not require involving the utility.

In contrast a grid-tie inverter is operating in parallel to the grid and providing energy output to your premises while it is connected to the grid. So even if no energy is being exported, the grid-tie inverter is connected to the grid, and you need an Interconnection Agreement. At the very least, the power company needs to be able to confirm that your grid-tied inverter generator will be non-export.

Now if you have a battery based inverter that can operate in standalone mode, and it is behind a transfer switch so it never generates power while connected to the grid, then I agree that is like the backup engine generator case and doesn't require involving the utility.

Cheers, Wayne

 

[Ampster]

The main part of the SGIP program is to not use energy from the grid, especially at peak times

Yes, I have no issue with that. I actually had an approved application in Step One for two Powerwalls. I gave up my deposit because I thought I could get the same benefit more cost effectively by doing it myself.
My comment was directed at the purpose of the ER program to carve out funds for peoole who deserved some "equity". I am sure there are different opinions about what the intention was, at the time that the carve out was approved.

 

[astrorob]

my tesla rep characterized the PGE powerwall paperwork for the new interconnection agreement as pretty much just "registering" the powerwall with PGE. it's the actual electrical construction/wiring that needs a permit and corresponding inspection. so i'm not sure the act of filing that paperwork is "asking permission" from PGE. note that as others have mentioned above there is a NEM2.0 version of this paperwork and a NEM1.0 version of the paperwork and if you are on NEM1 and file the NEM2 form i assume you're now on NEM2, which i assume is universally a bad thing for the homeowner.

at any rate he also said that if PGE has rules, like the dreaded 3-ft rule, then it falls to the city inspection to enforce it. in that sense you need PGE's 'permission' to install and operate a powerwall but it's sort of up to the discretion/whim of the city inspector.

 

[Ampster]

Now if you have a battery based inverter that can operate in standalone mode, and it is behind a transfer switch so it never generates power while connected to the grid, then I agree that is like the backup engine generator case and doesn't require involving the utility.

That is my interpretation as well. My hybrid inverter is Rule 21 compliant and does sync with the grid so that loads can be shifted to the grid if brief surges exceed the inverter capacity. Whether that is considered "connected" I am sure can be argued. Rule 21 has a lot to say about inverter standards.
There is some wording in most interconnection agreements about the "system" that does attempt to be more inclusive. That puts my agument more at risk for the practical reason that it puts me in a contractual disagreement with PG&E and my NEM agreement would be at risk. I have no intention to test my argument, since that could cause me to lose any benefits of NEM 2.O.

 

[h2ofun]

That is my interpretation as well. My hybrid inverter is Rule 21 compliant and does sync with the grid so that loads can be shifted to the grid if brief surges exceed the inverter capacity. Whether that is considered "connected" I am sure can be argued. Rule 21 is more about inverter standards.
There is some wording in most interconnection agreements about the "system" that does attempt to be more inclusive. I have no intention to test that since that is a contractual arrangement that could cause me to lose any benefits of NEM 2.O.

what would you lose in NEM 2.0?

 

[Ampster]

what would you lose in NEM 2.0?

That is a good question. First off, my apologies to the OP, I hope your question was answered and that you have a better sense that you could install a Powerwall with little risk. I also believe it would be a good hedge against futher erosion of the benefits of solar.
As to the question about what I would lose if I did not have NEM? I have two EVs and am on EVA. I would lose the ability to store solar at two or three times the rate that I can charge my EVs at. It is not a rate issue, but the fundemental ability under NEM to use the grid as a battery to charge my EVs conveniently.

I currently have enough battery capacity to run my home by not using the grid.

 

[h2ofun]

That is a good question. First off, my apologies to the OP, I hope your question was answered and that you have a better sense that you could install a Powerwall with little risk. I also believe it would be a good hedge against futher erosion of the benefits of solar.
As to the question about what I would lose if I did not have NEM? I have two EVs and am on EVA. I would lose the ability to store solar at two or three times the rate that I can charge my EVs at. It is not a rate issue, but the fundemental ability under NEM to use the grid as a battery to charge my EVs conveniently.

I currently have enough battery capacity to run my home by not using the grid.

I am confused. NEM 2 just says you have to be on a TOU plan. Solar, tou-c or d. For EV or batteries, its ev2-a, which you are already one. So, still confused on what you would lose.

 

[NorCalSlrUser]

OP here. Just to clarify - I recently got Solar (PTO last Thursday!) so I am on NEM 2.0.

I decided not to get the battery and to use the grid as the battery since it lets you store in summer and use in winter. and pay the NBCs.
Currently this suits me fine since TOU-C and TOU-D have very small difference between peak and of peak. So I'd rather have that than the batteries, but of course everything is as of now.

Thanks, jjrandorin, I guess I should watch if that provision of storage not impacting NEM is being eliminated, though that may be hard to know.

 

[Ampster]

@h2ofun said,
"NEM 2 just says you have to be on a TOU plan......... still confused on what you would lose."
Earlier I tried to answer your question,

I would lose the ability to store solar at two or three times the rate that I can charge my EVs at.

I am already on a TOU plan. NEM says I will be credited for generation at retail. No NEM would mean no credit for generation. @NorCalSlrUser seems to understand the concept. For the benefit of other readers it is easier to separate NEM from rates. They are separate issues.

 

[jjrandorin]

OP here. Just to clarify - I recently got Solar (PTO last Thursday!) so I am on NEM 2.0.

I decided not to get the battery and to use the grid as the battery since it lets you store in summer and use in winter. and pay the NBCs.
Currently this suits me fine since TOU-C and TOU-D have very small difference between peak and of peak. So I'd rather have that than the batteries, but of course everything is as of now.

Thanks, jjrandorin, I guess I should watch if that provision of storage not impacting NEM is being eliminated, though that may be hard to know.

There is a pretty good chance that if you check in here periodically, changes will likely end up being posted here by someone impacted by them.

 

[h2ofun]

@h2ofun said,
"NEM 2 just says you have to be on a TOU plan......... still confused on what you would lose."


I am already on a TOU plan. NEM says I will be credited for generation at retail. No NEM would mean no credit for generation. For the benefit of other readers it is easier to separate NEM from rates. They are separate issues.

Again, do no understand. Seems impossible to lose NEM. Everyone is either on TOU, or most will be within the next 2 year. So is anyone current that has solar or batteries not on NEM? Confused still