California Members: NEM3.0 impact on NEM1/2 customers and what to do?

[fafrd]

Hi, I didn't even think about this procedural step...

I always assumed, that when my 2015 solar install, expires in 2035, PGE will just automatically apply NEM3 to my bill. As the end user, there is nothing to do on my part. Can you pls help clarify my understanding if it is wrong? My assumption here is, I will still continue to have one PGE bill, which will reflect a combined total of kWh generation of both the arrays. They will both be treated as a NEM2 for the next 20 years.

In essence, I assumed, in the scenario which I am suggesting in my original post, If I get into NEM 2.0 now before the dateline, by adding a new Tesla solar system, and my existing old 2015 solar array system gets converted "at the same time" from NEM1 to NEM2 due to the addition of that new Tesla solar when it goes "online". My new PGE bill will reflect NEM2 for the next 20 years with both the combined old 2015 and new 2023 solar arrays, right?

Sorry if I didn't understand your reply earlier.

No, you won’t get a full 20 years from the date of the new array addition. You will get a total of 20 years of grandfathering from your first NEM 1.0 PTO date…

Pretty sure the only way to get a new 20-year grandfather period is to decommission and disinstall your NEM 1.0 array and start out as a new NEM 2.0 customer without history…

 

[mxp]

Do you have Non Bypassable Charges? On my NEM 2.0 bill they are about $0.025/kWh and show as a separate lie item. That would be one clue.

So far, I found this article to have the best explanation/illustration for NEM 2.0 NBCs https://aurorasolar.com/blog/the-ultimate-guide-to-nem-2-0-part-1-non-bypassable-charges/

 

[HuntersCrackpipe]

No, you won’t get a full 20 years from the date of the new array addition. You will get a total of 20 years of grandfathering from your first NEM 1.0 PTO date…

Pretty sure the only way to get a new 20-year grandfather period is to decommission and disinstall your NEM 1.0 array and start out as a new NEM 2.0 customer without history…

Bought a house last year and PG&E told me I had to remove the NEM 1.0 (2007) system installed by the builder completely and install a new system in order to be NEM 2 for 20 years otherwise it would be considered an "upgrade" to an existing facility and the PTO for NEM 2 would just continue from the original date, so expire in 2027. I had it removed (panels, racking, wiring, inverter, everything) and had a new system installed. I called PG&E and told them the old system was removed, they ended NEM. I emailed them photos of before and after showing the old panels removed and everything new installed over where the old components were and asked if the system would be considered a NEW facility for 20 years of NEM 2 and this is what they emailed back:

Thank you for your email. Technically this project category would still fall under “Upgrade Existing Generating Facility” since there was an Existing system detected by PG&E records (Even if that equipment is now removed and no longer in use). Currently the application has that system as been marked as decommissioned and removed. The NEM status for this application was changed to NEM 2 instead of NEM 1 because the system size increased from 2.600 kW to 11.000 kW. Any Increase greater than 1 kW or 10% the original system size (Whichever is the greater of the two) requires a user’s application to be switched over to NEM 2. The NEM 2 grandfathering start period will be the date that this application is issued PTO. Please note that the NEM 2 sunset date is 4/14/23, and a new NEM Billing Tariff will be released (NEM 3). Please let us know if you have any further questions.

So they acknowledge there was a system, it was removed and no longer in use, was decommissioned and removed, but then say they transitioned the account from NEM 1 to NEM 2 because the system size exceeded NEM 1 original size limitations. I even called and had them remove the system from the account and they terminated NEM during the application review process for the new system, but this is still somehow an upgrade to a system that no longer exists on the home or in their system? How can you upgrade something that does not exist? if the system was removed physically and in PG&E's system and NEM was terminated then any new PTO issued for the account would have to by definition be for a new system, with a new 20 year period under whatever NEM provisions exist at the time of issuance. They say they switched it from NEM 1 to NEM 2, how is that if you terminated NEM 1 when you removed the old system? My daily energy use actually stopped showing excess solar energy production for 4 days on their site so they must have actually stopped NEM rather than just switch it. When you submit the interconnection application you are required to include the old system in the single line diagram showing how the system was upgraded, so pray tell how a single line diagram absent any old system components is considered an upgrade? Unless I interpreted the email wrong, there's no way in hell PG&E is going to allow you to remove an old system (rare anyone ever does this) and install a new one and start over. Everything from that email appears to suggest they just considered it an upgrade and will run out the original PTO from 2007 (for a system that no PTO exist for) but this statement made me wonder more

The NEM 2 grandfathering start period will be the date that this application is issued PTO

Does this mean the remainder of the original NEM PTO period now under NEM 2 "starts" when they grant PTO to the new system or does this mean the entire 20 year period begins when they grant PTO? I may have to contact the NEM ombudsman's office on this one.

 

[solar8484]

Bought a house last year and PG&E told me I had to remove the NEM 1.0 (2007) system installed by the builder completely and install a new system in order to be NEM 2 for 20 years otherwise it would be considered an "upgrade" to an existing facility and the PTO for NEM 2 would just continue from the original date, so expire in 2027. I had it removed (panels, racking, wiring, inverter, everything) and had a new system installed. I called PG&E and told them the old system was removed, they ended NEM. I emailed them photos of before and after showing the old panels removed and everything new installed over where the old components were and asked if the system would be considered a NEW facility for 20 years of NEM 2 and this is what they emailed back:



So they acknowledge there was a system, it was removed and no longer in use, was decommissioned and removed, but then say they transitioned the account from NEM 1 to NEM 2 because the system size exceeded NEM 1 original size limitations. I even called and had them remove the system from the account and they terminated NEM during the application review process for the new system, but this is still somehow an upgrade to a system that no longer exists on the home or in their system? How can you upgrade something that does not exist? if the system was removed physically and in PG&E's system and NEM was terminated then any new PTO issued for the account would have to by definition be for a new system, with a new 20 year period under whatever NEM provisions exist at the time of issuance. They say they switched it from NEM 1 to NEM 2, how is that if you terminated NEM 1 when you removed the old system? My daily energy use actually stopped showing excess solar energy production for 4 days on their site so they must have actually stopped NEM rather than just switch it. When you submit the interconnection application you are required to include the old system in the single line diagram showing how the system was upgraded, so pray tell how a single line diagram absent any old system components is considered an upgrade? Unless I interpreted the email wrong, there's no way in hell PG&E is going to allow you to remove an old system (rare anyone ever does this) and install a new one and start over. Everything from that email appears to suggest they just considered it an upgrade and will run out the original PTO from 2007 (for a system that no PTO exist for) but this statement made me wonder more


Does this mean the remainder of the original NEM PTO period now under NEM 2 "starts" when they grant PTO to the new system or does this mean the entire 20 year period begins when they grant PTO? I may have to contact the NEM ombudsman's office on this one.

The operative word you missed are "generating facility" (i.e. you house). You are upgrading a generating facility which is not necessarily an existing solar system.

 

[HuntersCrackpipe]

The operative word you missed are "generating facility" (i.e. you house). You are upgrading a generating facility which is not necessarily an existing solar system.

A house doesn't generate electricity, a solar system does. A power plant is a facility, a solar system is a photovoltaic generating facility. Under that logic the 2007 system could be removed in 2010 for whatever reason (reroof etc), never reinstalled, and subsequently removed from PG&E's system reverting back to regular billing from NEM billing. In 2023 said homeowner decided to install a new system, but because a system existed from 2007-2010, this new system will now only remain under NEM 2 until 2027 because the system that used to exist was granted permission to operate in 2007. PTO goes with the system, the permission to operate is granted to the system not to the house...you operate the system at the house. Your implication is that the address itself is what is granted PTO, therefore a person who buys that same house in 2023 gets told by PG&E that 4 homeowners ago they had a solar system that no longer exists but because it did exist, any system you install only has 4 years of NEM 2 left.

That makes no sense, that's like buying a 2020 Camry with a 5 year warranty (old system), scrapping it and buying a 2023 Camry (new system) and being told you only have 2 years of warranty left because the warranty goes with you, a new car doesn't mean new warranty. You can keep the 2020 Camry (old system) and make whatever modifications you want to it, but the warranty will not extend beyond 5 years because...IT IS THE SAME CAR

 

[solar8484]

A house doesn't generate electricity, a solar system does. A power plant is a facility, a solar system is a photovoltaic generating facility. Under that logic the 2007 system could be removed in 2010 for whatever reason (reroof etc), never reinstalled, and subsequently removed from PG&E's system reverting back to regular billing from NEM billing. In 2023 said homeowner decided to install a new system, but because a system existed from 2007-2010, this new system will now only remain under NEM 2 until 2027 because the system that used to exist was granted permission to operate in 2007. PTO goes with the system, the permission to operate is granted to the system not to the house...you operate the system at the house. Your implication is that the address itself is what is granted PTO, therefore a person who buys that same house in 2023 gets told by PG&E that 4 homeowners ago they had a solar system that no longer exists but because it did exist, any system you install only has 4 years of NEM 2 left.

That makes no sense, that's like buying a 2020 Camry with a 5 year warranty (old system), scrapping it and buying a 2023 Camry (new system) and being told you only have 2 years of warranty left because the warranty goes with you, a new car doesn't mean new warranty. You can keep the 2020 Camry (old system) and make whatever modifications you want to it, but the warranty will not extend beyond 5 years because...IT IS THE SAME CAR

Not any house but your house which had an active solar system until it was removed just recently then replaced by a larger solar system. If the original system was removed years ago with acknowledgement from PG&E then you would have a better case to convince them it's not a generating facility upgrade.

 

[HuntersCrackpipe]

Not any house but your house which had an active solar system until it was removed just recently then replaced by a larger solar system. If the original system was removed years ago with acknowledgement from PG&E then you would have a better case to convince them it's not a generating facility upgrade.

Solar system = power generating facility. This can be ground mounted, on a roof, up your ass, they don't care. The physical structure to which it is connected is not a facility.

 

[solar8484]

Solar system = power generating facility. This can be ground mounted, on a roof, up your ass, they don't care. The physical structure to which it is connected is not a facility.

Not the physical structure but the address of the house that is tied to the PG&E account. Your frustration is understandable but it's unlikely you will convince PG&E to see things your way.

 

[fafrd]

Not the physical structure but the address of the house that is tied to the PG&E account. Your frustration is understandable but it's unlikely you will convince PG&E to see things your way.

Seems like this should not impact legacy NEM 1/2 customers, but since I just found some information on the new E-ELEC rate plan PG&E is planning to move all NEM 3.0 customers to by yearend, I thought I would share:

PG&E Electric Rates in 2024: How to Lower Your Essential Electricity Costs

PG&E electric rates are some of the highest in California and more than double the national average. Here's how to lower your electricity costs.

www.solar.com

10kWh of export off-peak needed to offset each kWh of import during peak hours and each kWh of summertime consumption from 8-9pm will cost you over 18kWh of off-peak export credit.

As we’ve been saying since the Final Decision was issued a little over a year ago, NEM 3.0 customers will need to size their arrays for 150% of annual consumption (which is allowed under NEM 3.0) and will need a hybrid inverter + battery sized to at least offset overnight consumption.

This will translate to more than enough solar production to offset all daily consumption except for December and January for those that don’t rely on electrical heating.

Those +50% kWhs of credit during summer months will be worth ~5% or ~18 days worth of wintertime consumption when solar power will likely only cover ~1/2 of consumption or 31 days of December + January.

So you won’t quite break-even on an annual basis but since there is a minimum monthly bill you’ll probably be close enough for jazz (no additional payment due at true-up).

Those with electrical heating that consume much more electrical power over winter months are going have trouble making NEM3.0 pencil out unless they can convince their utility to allow them to install a larger array (2 times annual consumption or larger).

And I suspect that how the NEM 3.0 rules and this new E-ELEC rate plan will impact NEM 1.0 customers whose grandfather period has ended will be the subject of greatly increased discussion a year from now…