powerwall install, NEM2 vs NEM1 & rate EV

[astrorob]

Hi all,

tesla energy has sent me the paperwork to apply for the interconnection of my powerwalls ahead of installation next month.

before signing, i wanted to check the wisdom of the group one last time - from reading threads here, it seems that PGE will grandfather rate EV customers for 5 years from the latest interconnection agreement. my original NEM1 interconnection agreement was just over 4 years ago, so i'm hoping that by interconnecting the PW2s under NEM2 that i will qualify for 5 more years of grandfathering.

obviously if this is not true and i'm still forced to move to EV2 or TOU-A next november *and* i end up with the NEM2 non-bypassible charges i'm going to be sad. so i just wanted to see if everyone agrees that the switch to NEM2.0 should come with another 5 years of EV. i have heard here of people who somehow stayed on NEM1 even when interconnecting the PW2 so if that is actually an option (and the grandfathering won't work) i should push to stay on NEM1.

thanks

 

[patrick40363]

You should be remaining on NEM 1. Powerwalls don't bump you off your current EV rate unless you are increasing your solar system size.

 

[Ampster]

Just to be clear how the rates work within the tariffs. My understanding is we are indeed grandfathered on that tarriff, but the CPUC does allow them increases in the kWhr rates. The structure of the tarriff is what is grandfathered. I am not clear if the actual time periods are grandfathered or not. I don't recall shifts on the EV-A tariff, but I have not kept a log since mine went into effect in late 2017.

 

[astrorob]

You should be remaining on NEM 1. Powerwalls don't bump you off your current EV rate unless you are increasing your solar system size.

i'm not worried about being bumped off of EVA due to the powerwall. i'm asking if, as posited in other threads, we are reasonably sure that PGE considers the new interconnection agreement for the powerwalls under NEM2.0 as the date from which i would be grandfathered in to EVA. that is, my EVA grandfathering would be extended to december of 2024.

otherwise, since my NEM1.0 interconnection agreement was in november of 2015, in november of 2020 i will be forced to switch off of EVA if this doesn't work.

to be clear i think i understand that if i were to increase the size of my system, then i'd definitely be forced into establishing a new agreement under NEM2.0 (and likely for sure be able to grandfather on EVA for 5 more years.) i'm really asking if the powerwall PTO under NEM2.0 would trigger this grandfathering in the absence of any changs to my PV installation.

 

[astrorob]

Just to be clear how the rates work within the tariffs. My understanding is we are indeed grandfathered on that tarriff, but the CPUC does allow them increases in the kWhr rates. The structure of the tarriff is what is grandfathered. I am not clear if the actual time periods are grandfathered or not. I don't recall shifts on the EV-A tariff, but I have not kept a log since mine went into effect in late 2017.

understood, it's not the dollar rates that i'm concerned about, it's the time periods. by my analysis EV2 would be a disaster for me, increasing my yearly spend from around $200 to around $1200 under NEM1.0. TOU-A is also bad - $800 per year.

i think if the CPUC allowed PGE to change the rates *and* the time periods for a given rate, then the different rates would be a distinction without a difference - they could change one rate at any time to be exactly equivalent to another.

 

[Lloyd]

With the powerwall, the difference between the rates in my case is near ZERO. My powerwalls supply 95% of my power during peak periods on either rate. It's just a matter of programming the peak rates into the powerwall. The off peak rate went up also, so there is the difference.

 

[patrick40363]

Call PGE and ask them.

 

[astrorob]

Call PGE and ask them.

i'm doing that, thanks. i am pretty paranoid and worry a little bit that they look into my account and then say "oh hey, you need to be off of EV immediately" or something like that.

anyway what the guy is telling me is that:

1. NEM2.0 is compulsory when interconnecting the powerwall
2. interconnecting the powerwall would cause them to push me onto EV2 *now*
3. if i file the paperwork by nov 30, i am eligible to be switched back onto EV and then grandfathered until 2024

i don't know if the nov 30 date is tied to my account (probably because my true-up is in november), and it sounds like there might be another form i have to file which is a petition to be put back on EV.

HOWEVER,

he then talked to a supervisor and said that they are always going to take the earliest interconnection date for the EV grandfathering, and essentially there's nothing that can be done to change that. this is only a little suspicious because he was reading out loud from some document that described being moved from EV to EV2 and back again after some kind of petition. i don't know what kind of customer that would apply to; maybe a non-solar customer but i was talking to the solar customer service department.

i guess we're back having conflicting information on this, as i think we've heard both stories from PGE reps in multiple threads here. however, if PGE has been vacillating on this then i suppose the newest info supersedes older info.

 

[miimura]

With the powerwall, the difference between the rates in my case is near ZERO. My powerwalls supply 95% of my power during peak periods on either rate. It's just a matter of programming the peak rates into the powerwall. The off peak rate went up also, so there is the difference.

For customers with solar and Powerwalls who still use significantly more kWh than they generate, the problem is the change from EV-A Part-Peak to EV2-A Off-Peak during generating hours from 7am to 3pm. After the Powerwall(s) are filled, the generation goes to the grid. That generation earns Off-Peak NEM credits of ~16c/kWh instead of Part-Peak of 22-29c/kWh. As you point out, EV charging overnight also increased from <14c/kWh to >16c/kWh.

 

[miimura]

i'm doing that, thanks. i am pretty paranoid and worry a little bit that they look into my account and then say "oh hey, you need to be off of EV immediately" or something like that.

anyway what the guy is telling me is that:

1. NEM2.0 is compulsory when interconnecting the powerwall
2. interconnecting the powerwall would cause them to push me onto EV2 *now*
3. if i file the paperwork by nov 30, i am eligible to be switched back onto EV and then grandfathered until 2024

i don't know if the nov 30 date is tied to my account (probably because my true-up is in november), and it sounds like there might be another form i have to file which is a petition to be put back on EV.

HOWEVER,

he then talked to a supervisor and said that they are always going to take the earliest interconnection date for the EV grandfathering, and essentially there's nothing that can be done to change that. this is only a little suspicious because he was reading out loud from some document that described being moved from EV to EV2 and back again after some kind of petition. i don't know what kind of customer that would apply to; maybe a non-solar customer but i was talking to the solar customer service department.

i guess we're back having conflicting information on this, as i think we've heard both stories from PGE reps in multiple threads here. however, if PGE has been vacillating on this then i suppose the newest info supersedes older info.

The November 30th date is in the Tariffs for the Grandfathering conditions and has nothing to do with your true-up.

This transition is very messy. They should have generated specific letters for each customer telling them the date that they will definitively be moved to the new rate. The blanket letters are not actionable by the customer and are just a CYA thing for PG&E. This is especially important for Powerwall customers because we can change behavior significantly by just changing the schedules in the app.

 

[bmah]

For customers with solar and Powerwalls who still use significantly more kWh than they generate, the problem is the change from EV-A Part-Peak to EV2-A Off-Peak during generating hours from 7am to 3pm. After the Powerwall(s) are filled, the generation goes to the grid. That generation earns Off-Peak NEM credits of ~16c/kWh instead of Part-Peak of 22-29c/kWh. As you point out, EV charging overnight also increased from <14c/kWh to >16c/kWh.

Hmmm. I use more kWh than I generate, but usually my Powerwalls are able to soak up the solar production during off-peak and partial-peak. There's not a lot (if any) to backfeed to the grid during those times. (EV-A, NEM1, Cost Savings mode with 40% reserve)

Maybe I just have a lot of battery capacity compared to daily solar production (3 Powerwalls vs. 5.88kW solar). It might play out differently during the summer months.

If someone has a lot of solar production compared to their batteries, then in that case, I could see them exporting to the grid during partial-peak (on EV-A) or non-peak (EV2-A).

Bruce.

 

[miimura]

I also have a small solar system compared to battery capacity - 4.32kW solar and 2 PWs. However, during the summer months I don't use that much energy during Peak because I don't have A/C. Therefore, I generate way more than my Peak usage, hence the loss of credits for the surplus Summer generation. I am barely dollar negative during the best generating months on EV-A. I'm sure that when I am pushed into EV2-A I will not have any dollar negative months any more.

 

[astrorob]

The November 30th date is in the Tariffs for the Grandfathering conditions and has nothing to do with your true-up.

ok thanks. i did some googling and it seems this guy was reading from the very latest rev of the schedule EV document, since some of the things he was mumbling were verbatim from this paragraph:

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

based on this:

https://www.pge.com/tariffs/assets/pdf/adviceletter/ELEC_5476-E.pdf

which says,

PG&E submitted AL 5039-E on March 30, 2017 to comply with Ordering Paragraph 5 of D.17-01-006 (revised by D.17-02-017). It proposed changes to the applicability provisions of PG&E’s various TOU rate schedules, proposed new definitions related to TOU to Electric Rule 1, and first clarified that TOU Period Grandfathering commences from the date of the first Permission to Operate (PTO).3 Additional changes were made to the advice letter via substitute sheets on July 3, 2017.

footnote 3 says:

3 “For the purposes of TOU Period Grandfathering, Permission to Operate (PTO) refers to the original permission to operate date as issued by PG&E for the Eligible System. Any subsequent requests to modify that previously approved system do not restart the Transition Mitigation Period once the new PTO is issued nor can any changes alter its original TOU grandfathering eligibility.” (AL 5039-E/5039-E-A, Appendix 1, E. Eligible System).

so based on that, i guess the supervisor today was telling the truth... the rep kept apologizing that "all this stuff is new" and "while that's not an excuse", "sometimes we're not up on all this powerwall stuff." that might account for why other reps have hung up the phone after giving the customer the impression that they would reset the clock with a powerwall interconnection. if they never bumped it up to someone who knew, that would explain it.

the last line of the first quoted paragraph does however say:

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

the question is, as a current NEM1.0 customer, can i "commence service" on NEM2.0, or are they talking about people who did not have solar but were on EVA and are now trying to become NEM customers for the first time? maybe this is where the original idea came from - that since you have to file a new interconnection agreement for powerwalls, and ostensibly that will be under NEM2.0, that a broad reading of that sentence would allow you to grandfather as long as you filed by nov 20, 2019.

 

[miimura]

the question is, as a current NEM1.0 customer, can i "commence service" on NEM2.0, or are they talking about people who did not have solar but were on EVA and are now trying to become NEM customers for the first time? maybe this is where the original idea came from - that since you have to file a new interconnection agreement for powerwalls, and ostensibly that will be under NEM2.0, that a broad reading of that sentence would allow you to grandfather as long as you filed by nov 20, 2019.

I believe you would have to add new solar (greater than the larger of 1.0kW CEC-AC or 10% of exsiting size) and submit a new interconnection application for that installation by Nov 30th, to qualify for the extended grandfathering. This would push you into NEM 2.0 from NEM 1.0.

 

[astrorob]

right - in fact, after posting that i kept reading https://www.pge.com/tariffs/assets/pdf/adviceletter/ELEC_5476-E.pdf and there's a whole discussion about that after the paragraph that i posted. they go into detail about how the grandfathering rule was sufficiently vague that some customers may have gone out and added capacity to their system in order to extend their grandfathering period even though PGE did not read the decision that way.

Advice 5476-E ends with PGE telling the CPUC that they can resolve this one way or another, however, i have no idea how to find the CPUC response.

this:

https://cpucadviceletters.org/search/?page=1&q=5476-E&source=&submit=

doesn't tell me a whole lot.

anyway, more solar capacity is not happening in the next few days. so that leaves me with the question,

how can i connect my powerwalls but stay on NEM1.0?

or is this impossible?

 

[wwhitney]

It is absolutely possible to connect powerwalls and stay on NEM 1.0. I did it by submitting my own interconnection agreement. So Tesla just has to submit the correct interconnection agreement on your behalf. If they've sent you one that would switch you to NEM 2.0, don't sign it, and tell them to send you the correct one.

Cheers, Wayne

 

[wwhitney]

tell them to send you the correct one.

FWIW, the interconnection form I ended up signing and submitting in July, 2018 was PG&E Form 79-1193, titled "Electric Sample Form No. 79-1193 Agreement and Customer Authorization Net Energy Metering Interconnection for Solar and/or Wind Electric Generating Facilities of 30 Kilowatts or Less Paired with Energy Storage of 10 Kilowatts or Less"

Cheers, Wayne

 

[astrorob]

Thank you, Wayne. that is very helpful. i didn't sign anything; the only problem is now i've made work for them - i asked them to submit me under nem2.0 since i thought that would get me the grandfathering.

the forms they sent me are marked as 79-1193-02, so it sounds like a revision of your form. hopefully yours still exists!

to top it off when i emailed my project manager in response to PGE telling me to pound sand, i found that she has gone on vacation until december 3rd. so i guess nothing will happen for a while. it might delay my PTO but the install is scheduled for mid-december so i think it should be fine if i manage to get new paperwork in early december.

 

[Sherlo]

I believe you would have to add new solar (greater than the larger of 1.0kW CEC-AC or 10% of exsiting size) and submit a new interconnection application for that installation by Nov 30th, to qualify for the extended grandfathering. This would push you into NEM 2.0 from NEM 1.0.

Yes, this is precisely what I was told when I asked in my case. Just added PWs to existing solar and inquired as to whether I could go NEM2 and get grandfathered for 5 years from the new PTO date. After speaking with a supervisor, the answer was nope. They use my earlier PTO from 2014 solar.

So stayed on NEM1 and waiting for the switch from EVA to EV2A this month.

 

[astrorob]

thanks for another confirmation re: staying on NEM1 - the rep i talked to today tried to tell me that i would have to switch to NEM2 no matter what... and that didn't sound right.