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Powerwall 2: SGIP/Incentives

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Pretty sure that the statement about all 5 steps of Tesla's developer cap being reserved can only apply to the Small Residential Storage category (1 or 2 Powerwalls, anyone can qualify). Tesla hasn't yet hit its developer cap in Step 2 (the current step) of the Large Scale Storage category (3 or more Powerwalls, some qualification criteria must be met).

Cheers, Wayne
 
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Reading the thread it seems like anyone other than Tesla is jacking up the prices. Hopefully they will change their minds about allocating it per installer.
We need to make a request to the CPUC to get them to modify this, possibly to remove the developer cap after each step has been open for 30 days. I had hoped to do this earlier this month, but ended up getting busy with other stuff. Also, Tesla recently called me with an update on my project and told me that they will be applying for Step 3 on my behalf, which is great for me but doesn’t do anything for those who find themselves hit by Tesla’s developer cap limit. Ideally, someone who is more personally affected than I am should be the one to petition the CPUC. I would still be happy to help where I can.
 
FWIW, last month I read through some of the CPUC paper trail on the design of the 2017 SGIP. The possibility that the developer cap could cause the program to stall did come up, as did the idea of modifying the developer cap after a certain period of time in a given step. The impression I got was that modification in the case of a stall would certainly be possible. I think removal after 30 days might be a step too far, maybe something more like a doubling after 90 days, then another doubling after another 90 days if required.

Cheers, Wayne
 
Tesla called me to say that PG&E is declaring Tesla as developer and PG&E plans to cancel my reservation. Considering I have a "confirmed reservation" email from PG&E saying I am approved and allowed to begin installation, the idea that PG&E can change their mind at any moment makes this project too risky. As an insult, PG&E contacted my sub-contractor Tesla directly before contacting me is a big strike against PG&E. I am not planning to contest this and plan to back out installing a Powerwall. Makes no sense for me anymore to install considering power outages are rare in the PG&E region. My take away is do not attempt to apply as a homeowner developer and use Tesla as installer if you live in the PG&E region.
 
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Tesla called me to say that PG&E is declaring Tesla as developer and PG&E plans to cancel my reservation. Considering I have a "confirmed reservation" email from PG&E saying I am approved and allowed to begin installation, the idea that PG&E can change their mind at any moment makes this project too risky. As an insult, PG&E contacted my sub-contractor Tesla directly before contacting me is a big strike against PG&E. I am not planning to contest this and plan to back out installing a Powerwall. Makes no sense for me anymore to install considering power outages are rare in the PG&E region. My take away is do not attempt to apply as a homeowner developer and use Tesla as installer if you live in the PG&E region.

I think you should open a CPUC complaint against PG&E for this. It's not hard to do.
 
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I got some interesting information from CSE about cancelling self-developer applications. Unfortunately, I am not at liberty to post the message, but to paraphrase the key points:

- Tesla doesn't allow their customers to take on all of the required developer activities.
- CSE has cancelled reservations for homeowner self-developers. (It's not clear to me what criteria makes homeowners ineligible to be developers. Perhaps the first point?)
- It's an issue that is apparently big enough that it will be discussed at this workshop: Self-Generation Incentive Program (SGIP) Quarterly Workshop | CSE

I'm not sure what to make of this.Though I'm inclined to attend that workshop, now.
 
I got some interesting information from CSE about cancelling self-developer applications. Unfortunately, I am not at liberty to post the message, but to paraphrase the key points:

- Tesla doesn't allow their customers to take on all of the required developer activities.
- CSE has cancelled reservations for homeowner self-developers. (It's not clear to me what criteria makes homeowners ineligible to be developers. Perhaps the first point?)
- It's an issue that is apparently big enough that it will be discussed at this workshop: Self-Generation Incentive Program (SGIP) Quarterly Workshop | CSE

I'm not sure what to make of this.Though I'm inclined to attend that workshop, now.
Yes, I believe that is the same reason PG&E is cancelling their homeowners. Homeowner's can take on some of the development activities but I guess SGIP CSE&PGE don't think it is enough for homeowners to self-submit their rebates. Homeowners need to get their voices heard somehow through a petition or other signature campaign.
 
FWIW, this issue came up with PG&E and until recently they were going to cancel homeowner developers using Tesla as the installer. However, as of this week they have changed their tune, and I finally got my developer key today. I was warned, however, that at the time of the submittal of the ICF the Program Administrator is going to review the division of development duties and potentially decide that the homeowner was not, in fact, the developer.

Cheers, Wayne
 
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Yes, I believe that is the same reason PG&E is cancelling their homeowners. Homeowner's can take on some of the development activities but I guess SGIP CSE&PGE don't think it is enough for homeowners to self-submit their rebates. Homeowners need to get their voices heard somehow through a petition or other signature campaign.

The SGIP handbook, under the definition of developer, says:

For applications received in Step 3 and later, a Developer is, if not individual homeowners applying for SGIP incentives for systems located on their own property, the corporate entity registered and in good
standing with the Secretary of State of California that handles a substantial amount of the project’s development activities.

That implies to me that handling "a substantial amount of the project’s development activities" is only a requirement if the developer is not the homeowner.
 
- It's an issue that is apparently big enough that it will be discussed at this workshop: Self-Generation Incentive Program (SGIP) Quarterly Workshop | CSE
Considering SGIP spelled out "homeowner developers" explicitly in the handbook update, and they actually have a 13 point criteria for qualifying as a "developer", I don't understand why CSE is getting surprised by this.

They also shouldn't be surprised when they created the 20% cap, and there's only really one installer out there that isn't charging a premium. Shouldn't take an economics class to explain 0.20 * X = 1.00, and what X needs to be -- or change the cap to scale to the market.

For instance, no homeowner is going to install a near equivalently-sized Sonnen Eco when it costs ~$8K more after rebates than one PowerWall 2 -- that's worth another PW2! So then it boils down to the best-value priced PW2 installer ... For most, there is only one choice.
 
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Considering SGIP spelled out "homeowner developers" explicitly in the handbook update, and they actually have a 13 point criteria for qualifying as a "developer", I don't understand why CSE is getting surprised by this.

But as I pointed out above, the SGIP handbook only seems to apply the requirement of "a substantial amount of the project’s development activities" to developers that aren't the homeowner.

Also, not sure why you think CSE is getting surprised.
 
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I was warned, however, that at the time of the submittal of the ICF the Program Administrator is going to review the division of development duties and potentially decide that the homeowner was not, in fact, the developer.
The following language in the SGIP Handbook (4.1.5, page 35) suggests that the Developer status on an application can only be reassigned before the confirmed reservation is issued:

If a reassignment of Developer status for a given project occurs after an SGIP application is submitted but before a confirmed reservation is issued, and leads to a participant retroactively exceeding its developer cap for a given incentive Step, a sufficient number of reservation requests for that participant shall be cancelled to bring the participant under its developer cap.

So assuming all parties actually have performed the functions they said they would in the reservation request, I don't see how PG&E thinks it can cancel an application at the ICF stage. [The order is reservation request -> reservation confirmation -> project is completed -> incentive claim form.]

Cheers, Wayne
 
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there's only really one installer out there that isn't charging a premium.
To be fair, there's one installer out there who's willing to sell at a loss. If this were international trade, it could easily be called "dumping".

I'm not saying that all of the delta between Tesla and other installers is due to Tesla selling at a loss. But a lot of it is.

Cheers, Wayne
 
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