Someone asked me about my experience trying to be my own developer here in PG&E territory in Step 2. So here's a brief recap:
I ordered 1 Powerwall on July 10, 2017, so I missed participating with Tesla in SGIP Step 1 or Step 2. After some time waiting (in vain) for SGIP Step 3 to open, I confirmed my order on September 6. I subsequently changed my Tesla order to 2 Powerwalls, signing a new contract on February 5, 2018.
Since as of October SGIP Step 3 hadn't open in PG&E land (and still hasn't!) I started looking into being my own developer. I submitted my Developer Application on October 26, but I didn't get my developer key until January 24. Then I submitted my SGIP application February 6, after I got the updated contract from Tesla.
PG&E cancelled my application on February 21, claiming that when Tesla is the installer on a project, they are also the developer. The basis for this seems to have been what Tesla told them, and they did not seem to look very closely at the supporting materials I submitted. Once I got PG&E to look at the supporting materials, they agreed that I handling everal of the development activities Tesla said they normally do, and my application was reinstated on March 6. It is now in RRF Technical Review (what is the next status change I should expect?)
A few take-away points if you are interested in pursuing this yourself in PG&E territory:
1) Rules for the SGIP are set by the CPUC but carried out by the several utilities. The Program Administrators try to coordinate their implementation of the program, but there will still be some variation across utilities.
2) The developer definition was revised for Steps 3 and beyond, although I was able to qualify under the original Step 1 and Step 2 definition. The idea that the phrase "corporate entity" in the original definition rules out individuals (homeowners, sole proprietors, or partnerships) seems to have been dropped in light of the CPUC's subsequent guidance. Please also note that the "exclusive list of a project’s development activities" in the SGIP Handbook applies to both the original and revised definitions of developer: you can see by looking at the definition of Developer in the appendix that the list is not part of the definition.
3) PG&E seems to be operating under the presumption that when Tesla is the installer on a project, they will be the developer, but this is rebuttable. It probably requires taking on some duties that Tesla normally handles. The activities I handled, in order of increasing difficulty in my opinion:
A) Apply for your own interconnection agreement with PG&E via egi-pge.com. In case anyone is interested, I have some pointers from PG&E on how to fill out their online forms for the case of adding batteries to an existing NEM 1.0 solar installation. Note that while PG&E may try to bill you an interconnection fee for the application, there is no fee for changes to NEM 1.0, unless you are adding enough additional solar panels to no longer qualify for NEM 1.0. So in that case you will need to get PG&E to withdraw the invoice to get your interconnection application to proceed.
B) Submit your own SGIP application. A lot has been said about this already in this thread. I did elect to skip the Proposed Monitoring Plan, as while I have solar I am electing not to seek the ITC and not to agree to charge the Powerwalls only from my solar.
C) Design the installation yourself. Principally this would mean coming up with a one-line diagram showing all your panels and feeder sizes, where the Backup Gateway will be connected, and where the Powerwalls will be connected. Some attention to the physical details of the installation should be paid. Tesla Engineering will want to do their own design, but you can do your own design and try to point Tesla in a certain direction. Ultimately you need a design that Tesla is willing to install.
D) Do some of the installation work yourself, with a permit from the building department. In California homeowners are allowed to do this. I went ahead and installed 3 new electrical panels, dividing my circuits between a future backed up panel (critical loads) and a non-backuped panel (noncritical loads). I also put in separate small panels for terminating my AC solar circuit and for connecting the batteries. Per the SGIP, you need a licensed contractor to install the power storage system itself, e.g. Tesla.
Cheers, Wayne
