Powerwall 2: SGIP/Incentives

[abasile]

Just talked to my local SGIP administrator and he acknowledged that other installers are essentially gouging consumers when compared to Tesla's costs. When asked if I could be a self installer he said they are actively looking in to those and for at least the Powerwalls as it's known that Tesla won't sell to a homeowner directly for a self install they would not be approved.

He understands what everyone is trying to do, i.e. get a Powerwall installed for a reasonable price and get the SGIP rebate but if Tesla isn't going to apply for the rebate for you it's highly likely you won't get it if you have them install your system which they would know not just because Tesla won't sell to you directly to install but also because of the documentation you have to provide they can see that Tesla installed it.

It appears that this all hinges on the definition of a "Developer" which is given as follows in the SGIP Handbook. I've highlighted and italicized what seems to be the most relevant text:

4.1.5 Developer
A Developer is the corporate entity that holds the contract for purchase and installation of the system, and/or alternative System Ownership Agreement (such as a Power Purchase Agreement) with the host customer and handles the project’s development activities. The Developer must fully disclose their participation in developing the project and/or ownership in the project, or that of a combination of affiliated installers/developers. The customer contract will be verified at Proof of Project Milestone to confirm the Developer’s representations. When applicable, the Developer cap will apply to any combination of affiliated developers under the same majority ownership.

My observations and thoughts are:

1. It's clear from elsewhere in the SGIP documentation that a homeowner can be a "developer", at least in some situations.

2. A "System Ownership Agreement" with the host customer is trivial if the developer is the host customer.

3. The sticking point may be "handles the project's development activities". I'm not a lawyer, but it seems to me that this should be interpreted in favor of homeowners regardless of which company performs the physical installation. I would consider a homeowner who performs the following to be engaged in "development activities" at the highest level of the project:

(A) Research available battery technologies, assess site electrical usage and generation, and determine to install a battery system.

(B) Become familiar with available government incentives and local utility policies.

(C) Contact potential installers, solicit bids, and initiate a contract with an installer.

(D) Provide site details to the installer and decide on installation specifics such as location, number of Powerwalls, and backed up circuits.

(E) Monitor the installation for satisfactory performance and aesthetics.

(F) Plan to comply with government policies governing system use (i.e., charging only from renewable generation if applicable).

It would be great to see SGIP issue clear, written, unified guidance on this topic. The rule of law should be our guide, not the inclinations of one particular administrator.

 

[Kren]

Just talked to my local SGIP administrator and he acknowledged that other installers are essentially gouging consumers when compared to Tesla's costs. When asked if I could be a self installer he said they are actively looking in to those and for at least the Powerwalls as it's known that Tesla won't sell to a homeowner directly for a self install they would not be approved.

He understands what everyone is trying to do, i.e. get a Powerwall installed for a reasonable price and get the SGIP rebate but if Tesla isn't going to apply for the rebate for you it's highly likely you won't get it if you have them install your system which they would know not just because Tesla won't sell to you directly to install but also because of the documentation you have to provide they can see that Tesla installed it.

In the end I think I'm just going to pass on this. It's sad really but the 20% developer cap is really screwing everyone. Doesn't essentially help that the only somewhat more reasonable installer I found has a contract that puts all the risk on you and provides no guarantee that they will even install a Powerwall within a reasonable or heck even an unreasonable time frame without you losing your deposit if say they still haven't installed it in 3 years.

It seems like you were considering doing the install yourself? Are you wanting to actually install the battery yourself doing all the electrical and etc? That is not what we (most of the homeowner self-submitters) are doing. That's is not how we are filling out our application. I am applying as a "Developer". According to SGIP handbook, a developer can be a homeowner how is taking charge of the process of their installation. I am hiring Tesla as my installer, I am purchasing a Tesla battery. I am submitting the Rebate paperwork. Some of the homeowner submitters, are really taking over the process, like SoundDeTrumpet(I will use this person as an example because they seem to be the most thorough and accurate homeowner self-submitter on this forum), researching, submitting white papers and technical reports. But SoundDeTrumpet is not physically installing the system. Some of the homeowners, like myself, are not as thorough. Submitting the application doesn't really have anything to do with Tesla except that you have to list them as the installer and the manufacturer of the battery. You also have to supply all the technical information, most of which is on the internet. It could all change, but I don't think the SGIP notifies Tesla, at this point, who is applying for the rebate. A person could theoretically get in the queue for Tesla to install and submit step 3 rebate and also, get in the queue for self-submitting their own rebate in step 2 and see which one gets confirmed first. You should just apply as a developers and fill out the application. At this point you have nothing to loose but your time. All the SGIP folks can do is say no. I won't tell Tesla if you don't. The only problem I see is after you get confirmed as a homeowner, have Tesla do the install (telling them not to apply for a rebate for you), will Tesla then help you get the last few documents needed to get the rebate?

 

[Kren]

It appears that this all hinges on the definition of a "Developer" which is given as follows in the SGIP Handbook. I've highlighted and italicized what seems to be the most relevant text:



My observations and thoughts are:

1. It's clear from elsewhere in the SGIP documentation that a homeowner can be a "developer", at least in some situations.

2. A "System Ownership Agreement" with the host customer is trivial if the developer is the host customer.

3. The sticking point may be "handles the project's development activities". I'm not a lawyer, but it seems to me that this should be interpreted in favor of homeowners regardless of which company performs the physical installation. I would consider a homeowner who performs the following to be engaged in "development activities" at the highest level of the project:

(A) Research available battery technologies, assess site electrical usage and generation, and determine to install a battery system.

(B) Become familiar with available government incentives and local utility policies.

(C) Contact potential installers, solicit bids, and initiate a contract with an installer.

(D) Provide site details to the installer and decide on installation specifics such as location, number of Powerwalls, and backed up circuits.

(E) Monitor the installation for satisfactory performance and aesthetics.

(F) Plan to comply with government policies governing system use (i.e., charging only from renewable generation if applicable).

It would be great to see SGIP issue clear, written, unified guidance on this topic. The rule of law should be our guide, not the inclinations of one particular administrator.

Yes, exactly. And at this point, SGIP also seems to agree and is the reason why we are getting approval as Developer.

 

[Kren]

I guess they are constantly looking at the program to help ensure the funds are being used as effectively as possible but he gave no indication they were looking specifically to raise the 20% cap or abolish it.

An interesting article from 2015 talks about an incentive failure because of most of the money going to one firm, Bloom Energy. I guess they are trying to avoid this. California’s SGIP, or How Not to Structure an Energy Incentive

 

[Kren]

I emailed the SGIP rep and he said there are no plans to raise the developer cap at this point. However, he said that PG&E is more than halfway through their Step 2 budget in only 4 months, so he thinks Step 3 for PG&E will open next Spring.

Yeah, but after Tesla reached their 20% cap, it seems like budget funds dispersal for Step 2 slowed significantly. Once Swell energy reaches their 20% cap it will slow even more. At the current rate, it looks like it will be years before any utility get's to step 3. I starting keeping track end of July and it looks like the funds are just trickling out. They need to find away to start moving things along faster. There are probably millions in funds that would be used up or freed up overnight if they would just start confirming or cancelling funds for all the people who applied and are waiting.

 

[DeJa]

It seems like you were considering doing the install yourself? Are you wanting to actually install the battery yourself doing all the electrical and etc? That is not what we (most of the homeowner self-submitters) are doing. That's is not how we are filling out our application. I am applying as a "Developer". According to SGIP handbook, a developer can be a homeowner how is taking charge of the process of their installation. I am hiring Tesla as my installer, I am purchasing a Tesla battery. I am submitting the Rebate paperwork. Some of the homeowner submitters, are really taking over the process, like SoundDeTrumpet(I will use this person as an example because they seem to be the most thorough and accurate homeowner self-submitter on this forum), researching, submitting white papers and technical reports. But SoundDeTrumpet is not physically installing the system. Some of the homeowners, like myself, are not as thorough. Submitting the application doesn't really have anything to do with Tesla except that you have to list them as the installer and the manufacturer of the battery. You also have to supply all the technical information, most of which is on the internet. It could all change, but I don't think the SGIP notifies Tesla, at this point, who is applying for the rebate. A person could theoretically get in the queue for Tesla to install and submit step 3 rebate and also, get in the queue for self-submitting their own rebate in step 2 and see which one gets confirmed first. You should just apply as a developers and fill out the application. At this point you have nothing to loose but your time. All the SGIP folks can do is say no. I won't tell Tesla if you don't. The only problem I see is after you get confirmed as a homeowner, have Tesla do the install (telling them not to apply for a rebate for you), will Tesla then help you get the last few documents needed to get the rebate?

Heck no! I was asking if I could register as a Developer and then Tesla could install it and I could submit the rebates as the Developer and get it. I was thinking about doing exactly what you suggested which is exactly as I asked the SGIP administrator. His explicit response was that it likely won't be approved.

The crux seems to be "A Developer is the corporate entity that holds the contract for purchase and installation of the system, ". You don't hold the contract for the installation of the system or really the purchase either I suppose. Anyone can get approved as a Developer. You can go out on your own and buy your own batteries (although not from Tesla) and do the install yourself and submit the rebate, etc. but that isn't what is happening when you have Tesla install a Powerwall for you. They know it, the documentation you have to submit proves it.

I'm not saying it will or it won't but maybe it's worth a call to your local SGIP office (mine was CSE) to ask them explicitly if they have a policy on this if getting the SGIP rebate is a deciding factor for you. I wish you all the best of luck

 

[Az_Rael]

An interesting article from 2015 talks about an incentive failure because of most of the money going to one firm, Bloom Energy. I guess they are trying to avoid this. California’s SGIP, or How Not to Structure an Energy Incentive

This article implies the companies themselves are getting the funds. Is there a separate rebate for the developer in addition to the rebate we get?

Otherwise, if the only one getting the rebate is the homeowner (on the small residential side), who cares if most of us get the rebate via Tesla as our installer? The money is still going to individual power customers.

 

[abasile]

The crux seems to be "A Developer is the corporate entity that holds the contract for purchase and installation of the system ..."

But the "Developer" and the "Installer" need not be the same entity. There's an important "and/or" which follows.

Anyhow, I'm now especially interested in what our SGIP options might be. I cancelled our PW2 order with a third party installer when they communicated that it would not work for them to support a "whole house backup" with a single PW2 (which was written in my contract) due to Tesla policies on 40A and 50A circuits. We would have been fine with the third party installer and a single PW2, but we're not fine with not being able to back up an electric induction range and a 50A subpanel.

Therefore, if we're going to have a battery system at all, it needs to consist of two PW2s. This would be costly (more than $18K) with the third party installer and would require them to drop our SGIP Step 1 application and re-apply under the current Step, and we're not going for that. Tesla gave us a firm price of $13,656.75 total for two PW2s, which is great except for the SGIP uncertainty.

Also, in relation to the possibility of adding a second PW2 to our original order, I confirmed the following in section 2.6.1 of the SGIP Handbook:

If the step to which a project is assigned has closed, modifications to the project will not result in additional incentive funding.

 

[SoundDaTrumpet]

Heck no! I was asking if I could register as a Developer and then Tesla could install it and I could submit the rebates as the Developer and get it. I was thinking about doing exactly what you suggested which is exactly as I asked the SGIP administrator. His explicit response was that it likely won't be approved.

The crux seems to be "A Developer is the corporate entity that holds the contract for purchase and installation of the system, ". You don't hold the contract for the installation of the system or really the purchase either I suppose. Anyone can get approved as a Developer. You can go out on your own and buy your own batteries (although not from Tesla) and do the install yourself and submit the rebate, etc. but that isn't what is happening when you have Tesla install a Powerwall for you. They know it, the documentation you have to submit proves it.

I'm not saying it will or it won't but maybe it's worth a call to your local SGIP office (mine was CSE) to ask them explicitly if they have a policy on this if getting the SGIP rebate is a deciding factor for you. I wish you all the best of luck

Talking to the SGIP administrator, he was supposed to add "(or homeowner)" and address the ambiguity of "AND" at the next SGIP Handbook revision. Business dictionary says holder of the contract is the owner or the one who pays for services/product. I wonder when the definition section will be updated. I hope he did not forget of this revision to the handbook.

The SGIP administrator at PG&E did not see it the same way as SGIP administrator for the above definition. PG&E interprets definition of "holder of the contract" incorrectly.

The SGIP handbook has to change. PG&E SGIP is on the side of caution unless it's clearly written in the handbook. Imagine SGIP administrator as the legislature, and Utility (PG&E) SGIP as the executive branch to execute the handbook. PG&E having trouble interpreting and executing.

What is agreed between both parties is that Homeowner Developers need to have skin in the game, not just simply handing over $500 and few signatures. It is said that Tesla can't help complete applications for self-install/homeowner developers. Assuredly I have 100% backing from SGIP administrator, but weak backing from SGIP PG&E. Let me know if anything above has changed.

 

[SoundDaTrumpet]

It appears that this all hinges on the definition of a "Developer" which is given as follows in the SGIP Handbook. I've highlighted and italicized what seems to be the most relevant text:



My observations and thoughts are:

1. It's clear from elsewhere in the SGIP documentation that a homeowner can be a "developer", at least in some situations.

2. A "System Ownership Agreement" with the host customer is trivial if the developer is the host customer.

3. The sticking point may be "handles the project's development activities". I'm not a lawyer, but it seems to me that this should be interpreted in favor of homeowners regardless of which company performs the physical installation. I would consider a homeowner who performs the following to be engaged in "development activities" at the highest level of the project:

(A) Research available battery technologies, assess site electrical usage and generation, and determine to install a battery system.

(B) Become familiar with available government incentives and local utility policies.

(C) Contact potential installers, solicit bids, and initiate a contract with an installer.

(D) Provide site details to the installer and decide on installation specifics such as location, number of Powerwalls, and backed up circuits.

(E) Monitor the installation for satisfactory performance and aesthetics.

(F) Plan to comply with government policies governing system use (i.e., charging only from renewable generation if applicable).

It would be great to see SGIP issue clear, written, unified guidance on this topic. The rule of law should be our guide, not the inclinations of one particular administrator.

Wow, your outline above is exactly what is included in my Preliminary Monitoring Plan I submitted with my application. I hope my application (or another homeowner developer using Tesla as installer) gets approved soon.

 

[abasile]

Wow, your outline above is exactly what is included in my Preliminary Monitoring Plan I submitted with my application.

Cool! I promise - I came up with that outline independently. Good to have multiple minds chewing on this.

I hope my application (or another homeowner developer using Tesla as installer) gets approved soon.

I agree! This won't help as many people as simply raising the developer cap would, but in principle it makes sense that the minority of homeowners who are willing to actively engage themselves in the whole process should be able to qualify for SGIP rebates by acting as "Developers". Personally, when it comes to any sort of property improvement, I tend to be pretty hands-on regardless of who is being paid to do the work.

 

[Kren]

This article implies the companies themselves are getting the funds. Is there a separate rebate for the developer in addition to the rebate we get?

Otherwise, if the only one getting the rebate is the homeowner (on the small residential side), who cares if most of us get the rebate via Tesla as our installer? The money is still going to individual power customers.

yes, I agree with you. But I think this article shows why they started this Developer's cap...even though it doesn't really apply in this situation. I wonder if SGIP realize that this is a different situation and therefore the developer's cap is not really needed.

 

[Kren]

Talking to the SGIP administrator, he was supposed to add "(or homeowner)" and address the ambiguity of "AND" at the next SGIP Handbook revision. Business dictionary says holder of the contract is the owner or the one who pays for services/product. I wonder when the definition section will be updated. I hope he did not forget of this revision to the handbook.

The SGIP administrator at PG&E did not see it the same way as SGIP administrator for the above definition. PG&E interprets definition of "holder of the contract" incorrectly.

The SGIP handbook has to change. PG&E SGIP is on the side of caution unless it's clearly written in the handbook. Imagine SGIP administrator as the legislature, and Utility (PG&E) SGIP as the executive branch to execute the handbook. PG&E having trouble interpreting and executing.

What is agreed between both parties is that Homeowner Developers need to have skin in the game, not just simply handing over $500 and few signatures. It is said that Tesla can't help complete applications for self-install/homeowner developers. Assuredly I have 100% backing from SGIP administrator, but weak backing from SGIP PG&E. Let me know if anything above has changed.

Yes, same here. SGIp is encouraging me on. But I have not contacted my utility, SCE, yet. I am in contact with another homeowner self-submitter who seems to have a good relationship with the SGIP SCE. So I am just following their lead, trying not to upset the boat. One thing aboaut PG&E SGIP, they really seem to be getting things moving. They got a lot of rebates confirmed so that's good.

 

[Ulmo]

I just got this document too, and we are having difficulty with it. Although I understand it, the account holder does not, and doesn't want to take the time to interpret it. I have been assigned the task to summarize it or ask for a summary.

Why would we have insurance requirements to protect PG&E when PG&E doesn't take responsibility for their own murderous and tree killing actions? Above-ground power lines must be outlawed in California, with implementation of such ban started in any area with trees or brush (for instance, it does little good to implement the ban first in downtown San Francisco, downtown Oakland, or downtown LA), to avoid fire.

I have to ask how many PowerWalls were burnt in the California fires in the last two weeks, and how many of them will cause or materially enhance fires during their lifetime.

 

[commasign]

Maybe some movement on Phase 3 (I have 4 Powerwalls, PG&E). Tesla sent me a docusign just now for the rebate application. For my $26,000 project the numbers work out to $18,500 rebate. Fingers crossed that it all works out.

 

[bkp_duke]

Maybe some movement on Phase 3 (I have 4 Powerwalls, PG&E). Tesla sent me a docusign just now for the rebate application. For my $26,000 project the numbers work out to $18,500 rebate. Fingers crossed that it all works out.

I am pretty sure that the SGIP rebate is capped at 2 Powerwalls.

 

[SoundDaTrumpet]

I am pretty sure that the SGIP rebate is capped at 2 Powerwalls.

It would suggest that commasign is applying for the "Large Scale Storage" for >10kW systems. Large Scale Storage have a different set of discharging requirements.

 

[bkp_duke]

It would suggest that commasign is applying for the "Large Scale Storage" for >10kW systems. Large Scale Storage have a different set of discharging requirements.

Interesting. Tesla didn't even offer me this option. I have a 12kw PV system.

Going to have to look into this now. Thanks.

 

[zanary]

It would suggest that commasign is applying for the "Large Scale Storage" for >10kW systems. Large Scale Storage have a different set of discharging requirements.

I thought the Powerwall 2 as a individual product does not quality for Large Scale. The Powerpack does.

I'm curious if SGIP will catch this and reject, but if they don't that's awesome news for everyone getting more than 2 Powerwall.

 

[bkp_duke]

OK, called up Tesla/SolarCity to get some clarification on this.

According to the concierge I spoke with, the 2 PW limit for SGIP rebates was lifted the beginning of October. I've asked for further clarification on this point, and to get a quote for 3 or 4 PWs if that is the case (up from my current order of 2). According to the rep, this would still fall under the Small Residential Storage category.

Thoughts? Rep wrong? (he did go back to the "Incentives Team" to clarify twice)