California PG&E NEM 2.0 deadline - plan submitted or operating?

[BMEP]

Long time reader, first time poster.

Hoping there is somebody here that understands the maze that is PG&E in regards to the NEM 2.0 deadline. I'm planning a new DIY installation and really trying to be under NEM 2.0

I'm trying to understand what's actually required to make the deadline. Some of PG&E's published info says the interconnection agreement has to (only) be submitted by the 4/13 deadline.

However, the link below (intended for solar installers/business) says "Include a copy of the final building permit/inspection certificate that clearly indicates that final inspection for the solar or renewable installation has been performed." which means to me, county permit finaled - a/k/a installation is completely finished.

This is the difference between NEM2 or 3 for me because I can get the application submitted by 4/13, but no way I can get the project done/permit finaled by then.

Interconnections

Learn about interconnecting independent power sources to PG&E's electric system.

www.pge.com

Any help/insight is greatly appreciated!

Rob

 

[zanydroid]

Long time reader, first time poster.

Hoping there is somebody here that understands the maze that is PG&E in regards to the NEM 2.0 deadline. I'm planning a new DIY installation and really trying to be under NEM 2.0

I'm trying to understand what's actually required to make the deadline. Some of PG&E's published info says the interconnection agreement has to (only) be submitted by the 4/13 deadline.

However, the link below (intended for solar installers/business) says "Include a copy of the final building permit/inspection certificate that clearly indicates that final inspection for the solar or renewable installation has been performed." which means to me, county permit finaled - a/k/a installation is completely finished.

This is the difference between NEM2 or 3 for me because I can get the application submitted by 4/13, but no way I can get the project done/permit finaled by then.

Interconnections

Learn about interconnecting independent power sources to PG&E's electric system.

www.pge.com

Any help/insight is greatly appreciated!

Rob

The solar installer lobby’s marketing material says interconnection application, processed to a sufficient point by PG&E or whomever, is all that’s needed. I am proceeding on my own project on this basis.

I’ve looked over the "NEM3" final decision and PG&E form twice and it does not include a section for it. It does require equipment selection and system size to be locked. And I believe it will need to pass a basic engineering validation at POCO wrt compatibility with grid (I assume backfeed capacity they’re willing to absorb from your area).

Also it’s not really worth fretting about. Either you get in or you don’t. You only lose time in filling out the design parameters and the interconnection application fee. You can’t possibly get the plans reviewed and all inspections in by 4/13.

 

[zanydroid]

These are the docs I’ve been keeping an eye on. I also have a copy of my interconnection application from a previous turnkey install I paid for (current project is DIY) and that is consistent with what I’ve said

https://www.pge.com/tariffs/assets/pdf/tariffbook/ELEC_FORMS_79-1151A-02.pdf

https://www.pge.com/tariffs/assets/pdf/tariffbook/ELEC_FORMS_79-1151B-02.pdf

Standard NEM Process & Requirements

Solar, wind and hybrid renewable energy projects of less than 30 kilowatts (kW) require a Standard Net Energy Metering (NEM) Interconnection Agreement with PG&E. Our team is here to help ensure your project has a successful, safe and reliable interconnection to the grid.

www.pge.com

 

[BMEP]

Thanks for the info zanydroid - I'll read the docs you linked to.

Also it’s not really worth fretting about. Either you get in or you don’t.

One consideration I have is the type of batteries to buy. I'm targeting 25kWh-ish of storage. My thinking has been that with NEM2, batteries would be backup-only so I'd buy lower cost (probably AGM) batteries since they wouldn't be cycled daily.

It seems like the low buy rates of NEM3 would reward daily use of battery capacity so I'd want something with better cycle-life like LiFePO4. I think that'll eventually pay for itself, but it will be a sizable up-front cost compared to AGM.

 

[zanydroid]

One consideration I have is the type of batteries to buy. I'm targeting 25kWh-ish of storage. My thinking has been that with NEM2, batteries would be backup-only so I'd buy lower cost (probably AGM) batteries since they wouldn't be cycled daily.

I'm not sure if AGM are still allowed in California since the adoption of the IBC clause to require listed ESS OR salvaged EV cells if allowed by your AHJ. I know in the past there was an allowance for AGM.

It seems like the low buy rates of NEM3 would reward daily use of battery capacity so I'd want something with better cycle-life like LiFePO4. I think that'll eventually pay for itself, but it will be a sizable up-front cost compared to AGM.

Yes NEM3 is designed to force you to immediately fulfill your need via adding storage and make storage pay for itself since there is a spread of 0.22-0.32 in Norcal (peak and off peak range IIRC) (probably 0.22 - 0.45 or something in SoCal) for each kWh of usage you can shift from export to local consumption with your batteries.

The way to go here is either go NEM2 or defer solar until ESS becomes cheaper. Note this analysis doesn't take into account the shape of the transition glideslope. Since a solar system would have higher years if the glideslope is relative to calendar year rather than year in service. Since I don't plan on doing any solar with NEM3 I do not know the inputs necessary to sort this out, nor am I incentivized to be so diligent. The input details should be in the final decision doc.

Note also that a bootleg time-shifting ESS is rather detectable by the POCO with simple algorithms during the time when the sun is low/gone. And this constitutes a massive fraction of the peak TOU hours.

 

[BMEP]

I'm not sure if AGM are still allowed in California since the adoption of the IBC clause to require listed ESS OR salvaged EV cells if allowed by your AHJ. I know in the past there was an allowance for AGM.

Thanks for that! I hadn't even considered that list... and as you said, I don't see any AGM on that list. I guess I'll see if the county would accept AGM batteries - I wonder if PG&E's engineering review would get to that detail level?

You make some very good points. Maybe my decision (if AGM is not allowed) is more about the size of a CEC-listed ESS... smaller for NEM2, larger for 3.

 

[Ampster]

I don't see any AGM on that list. I guess I'll see if the county would accept AGM batteries

As far as I know, Lead Acid is an exception to the NEC 2020 rule that batteries be UL approved. No fire risk with AGMs.

 

[zanydroid]

PG&E goes down to the detail of panels and inverter. I don’t plan to use ESS so I haven’t paid attention to those rows in the form.

https://up.codes/viewer/california/ca-residential-code-2022/chapter/3/building-planning#R328

The IBC section as adopted says ESS, and when I click through to the definition of ESS I don’t see an exception for AGM. I agree AGM is safer, don’t know why there is a carve out for more dangerous stuff like EV cells but not for AGM. I would recommend talking to the AHJ about a variance possibility. I’m not sure how such negotiations are best handled.

 

[thewilliam]

Anybody have a feel for upgrades to a system say a year from now? If you have an existing NEM 2 agreement then want to add either battery or solar capacity after the April deadline will the process force you to NEM 3 (NBT?)?

I haven't thoroughly read the NEM 3.0 documentation yet. I just started an install process, PG&E Ca central coast, panels/inverters no battery, and hope to get in by the April deadline.

 

[Ampster]

The way I understand it, you need to get your application into PG&E by the April deadline. You then have perhaps several years to complete the other steps in your installation. Search for other threads on this topic to confirm. This is discussed extensively discussed on several threads. Also l read the CPUC ruling to confirm.
I also understand that you can later add batteries without bumping you into NEM 3.0 and you may also be able to increase the size of your system by 1,000 Watts without bumping you into NEM 3.0.

 

[thewilliam]

For the NEM 2.0 deadline I found this in the final decision.

12.
Implementation of the changes adopted in the previous ordering paragraphs of this decision shall occur in the following steps:
(a)
Step 0: NEM 2.0 Sunset Period begins with adoption of this decision. Customers submitting a completed interconnection application prior to the end of the Sunset Period will be considered applicable for the current NEM 2.0 tariff.

And later in Step 4

The interconnection application date for residential customers is defined as the submission date of an application that is free of major deficiencies and includes a complete application, a signed contract, a single-line diagram, a complete California Contractors State License Board Solar Energy System Disclosure Document, a signed California Solar Consumer Protection Guide, and an oversizing attestation (if applicable).

 

[agarg]

Long time reader, first time poster.

Hoping there is somebody here that understands the maze that is PG&E in regards to the NEM 2.0 deadline. I'm planning a new DIY installation and really trying to be under NEM 2.0

I'm trying to understand what's actually required to make the deadline. Some of PG&E's published info says the interconnection agreement has to (only) be submitted by the 4/13 deadline.

However, the link below (intended for solar installers/business) says "Include a copy of the final building permit/inspection certificate that clearly indicates that final inspection for the solar or renewable installation has been performed." which means to me, county permit finaled - a/k/a installation is completely finished.

This is the difference between NEM2 or 3 for me because I can get the application submitted by 4/13, but no way I can get the project done/permit finaled by then.

Interconnections

Learn about interconnecting independent power sources to PG&E's electric system.

www.pge.com

Any help/insight is greatly appreciated!

Rob

Hi Rob: I am in the process of completing my design for the Solar PV. I thought I did with AP Systems but it turned out they dont want DIY, and so I am looking at alternatives. However that is digression. I also tried to fill my interconnection Single line so that I can be grandfathered into NEM 2.0. Just before log in, there is a clear line that says:

"Final inspection clearance must be submitted before 04/15/2026 to retain NEM2 eligibility."

I suspect that this is not in line what CPUC had voted for and so there is a risk that we may not NEM 2 if we don't finish and get a "Final Inspection Clearance". There is enough literature that suggest that installation is not mandatory before 4/13/2023 but I am not sure.

Also, the PGE application is complicated and full of acronyms and I would love to find a free lance who can help me finish the applications at least now so that I at least have a chance that it would count for NEM 2 even if install was a few weeks after April 13th.

Would love to connect with you.

Anil

 

[agarg]

I'm not sure if AGM are still allowed in California since the adoption of the IBC clause to require listed ESS OR salvaged EV cells if allowed by your AHJ. I know in the past there was an allowance for AGM.


Yes NEM3 is designed to force you to immediately fulfill your need via adding storage and make storage pay for itself since there is a spread of 0.22-0.32 in Norcal (peak and off peak range IIRC) (probably 0.22 - 0.45 or something in SoCal) for each kWh of usage you can shift from export to local consumption with your batteries.

The way to go here is either go NEM2 or defer solar until ESS becomes cheaper. Note this analysis doesn't take into account the shape of the transition glideslope. Since a solar system would have higher years if the glideslope is relative to calendar year rather than year in service. Since I don't plan on doing any solar with NEM3 I do not know the inputs necessary to sort this out, nor am I incentivized to be so diligent. The input details should be in the final decision doc.

Note also that a bootleg time-shifting ESS is rather detectable by the POCO with simple algorithms during the time when the sun is low/gone. And this constitutes a massive fraction of the peak TOU hours.

AGM is not allowed, I am sure.
I have read that on some California Gov site.

Anil

 

[zanydroid]

Hi Rob: I am in the process of completing my design for the Solar PV. I thought I did with AP Systems but it turned out they dont want DIY, and so I am looking at alternatives. However that is digression. I also tried to fill my interconnection Single line so that I can be grandfathered into NEM 2.0. Just before log in, there is a clear line that says:

"Final inspection clearance must be submitted before 04/15/2026 to retain NEM2 eligibility."

I suspect that this is not in line what CPUC had voted for and so there is a risk that we may not NEM 2 if we don't finish and get a "Final Inspection Clearance". There is enough literature that suggest that installation is not mandatory before 4/13/2023 but I am not sure.

Also, the PGE application is complicated and full of acronyms and I would love to find a free lance who can help me finish the applications at least now so that I at least have a chance that it would count for NEM 2 even if install was a few weeks after April 13th.

Would love to connect with you.

Anil

Re: the deadlines, I recommend following this person on Reddit:

https://www.reddit.com/r/solar/comments/11bwpfz

There's a post for help with a California interconnection application, and people suggested posting the project on Greenlancer.

Here: https://diysolarforum.com/threads/help-needed-with-sce-interconnection.55283/

Also the PG&E application has a web app, that helps a bit because it forces you to paint inside the lines and auto completes stuff. But there is still a fair amount of jargon in it.

 

[Ampster]

AGM is not allowed, I am sure.

It is allowed under NEC 2020 but I do not know if that has been adopted in all Counties or Cities in California and whether the IBC contradicts that exception.

 

[BMEP]

@agarg - that line about "final inspection" and the one I referenced in my original post is what has me wondering.

@zanydroid - great info again - thanks!

@Ampster - I believe CA is currently using NEC2017, not sure that matters

One other problem I have is this is new construction and I STILL don't have PG&E service installed yet. I applied on 6/4/22 and I'm still waiting. They even had a construction date and they didn't show. They scheduled another date next week (3/7) but with the rain/snow we've had, I bet they don't show again. The new business rep I'm working with already sort laid the groundwork, "Well, depending on the storm, we stand a good chance of making the 3/7 date" - well, the (most recent) storm was worse than planned.

I asked if this kind of delay was normal and got what now seems to be the default excuse for any problem. COVID, supply chain, labor, etc etc etc. I get that a lot of this is real, but 9 months to get new service? I'm connecting to an existing pole that's 80 feet away.

Bottom line for my solar plans, I haven't yet figured out a way to use the online application because it wants my account number, which does not yet exist.

 

[BMEP]

I just found something interesting... After posting above, I wondered if I could just create an account before my service is active. While going through that process, I ran across this on the "sign-in" page for new construction. Note the line, "Final inspection clearance must be submitted before 04/15/2026 to retain NEM2 eligibility.". So there you go - has to be operating by 2026, which is what I've seen people post in various places (3 years).

 

[zanydroid]

I believe CA is currently using NEC2017, not sure that matters

NEC 2020 was adopted on Jan 1, 2023

You should not need service to do an application. But I guess the online one might not work?

 

[agarg]

One other problem I have is this is new construction and I STILL don't have PG&E service installed yet. I applied on 6/4/22 and I'm still waiting. They even had a construction date and they didn't show. They scheduled another date next week (3/7) but with the rain/snow we've had, I bet they don't show again. The new business rep I'm working with already sort laid the groundwork, "Well, depending on the storm, we stand a good chance of making the 3/7 date" - well, the (most recent) storm was worse than planned.

* PG&E will make an exception for new construction projects unable to submit a completed application by the sunset date. If the load application is submitted by the NEM2 Sunset date, the project will be eligible for NEM2, provided the site is energized under the same Service Point Notification. This refers to the “Project Number” or “Notification Number”. To retain this eligibility, final electrical clearance must be granted by 04/15/2026.

 

[agarg]

The solar installer lobby’s marketing material says interconnection application, processed to a sufficient point by PG&E or whomever, is all that’s needed. I am proceeding on my own project on this basis.

I read the CPUC ruling in December and the interpretation in the news was that if you get the application in, and do not change it materially, and ESS addition will not count as material change, then the NEM 2 will be allowed and we have 12 months to complete. I think, PGE is going to stick with its own interpretation and they make that clear by posting a requirement for inspection very clear.

I think CPUC may be asked to step in and clarify their intent post 4/13/2023 and there is an element of risk because CPUC may side with PGE.