Thoughts on Solar

The Ides of March came and went, and with it access to NEM 2.0!

We - and pretty much every one else in the California solar industry - experienced a mad, last-minute crush as we tried to get as many applications submitted with time to respond to the inevitable kickback from SCE before the final clock strike on April 14th. 

Our oldest filing with the status, “Application Submitted” goes back to February 21st.  That means  18 business days have elapsed since we submitted that application and it has yet to be looked at by anyone at SCE!  Ironically, this isn’t even an application for PV, it is simply a storage addition.  But yeah, things have been busy - that application was number 403,122.  The final application that we submitted on the 15th was number 433,008 - a total of 29,886 applications in 15 business days - that’s crazy!

So now what?  Well, for the next 28 days we wait to see what excuse SCE will find to reject our applications, because we know that they will! Once they do, we will respond before the final re-submission deadline so that all of our submissions end up approved.

As to everyone else in SCE territory, we’re sorry you missed out on the great gold rush of ‘23.  Know, however, that we have the modeling tools needed to accurately estimate your savings under the byzantine formula that is NEM 3.0.  And to all you folks in PWP territory, the good news is that nothing has changed for you!

Onward!

Some people are simply shameless, and it appears that the powers-that-be at SCE are among them. We just got this charming missive from the division at SCE that is responsible for processing Interconnection Applications:

Subject: Extended NEM Application Processing Timelines

Hello Contractors and Installers,

We are currently experiencing a high volume of new NEM applications. As a result, processing timelines are taking longer than expected. Please note, Interconnection Requests (IRs) may exceed our average processing timelines. Although most applications will be reviewed within 10 business days, some may take up to 20 business days to review.

To help mitigate this volume, we strongly recommend that you submit your application and the required documents in complete form, including all signatures and attachments. Ensuring that your applications are submitted in complete form helps us to minimize the number of touchpoints and reduce the application queue.

We request your cooperation and understanding as we work diligently in decreasing the application volume. Please refer to PowerClerk for the latest status of your application. If you have any additional questions, please send an email to Customer.Generation@sce.com.

Sincerely,

Eduyng Castano
Senior Manager of Customer Generation Programs
Southern California Edison

To deem this outrageous is to be way too kind. Gee, I wonder why there is a high volume of applications? Could it be because the bottom is dropping out of solar economics in SCE territory after the April 14th deadline? Who could have predicted that - apart from pretty much everyone who is paying attention. And how is it that SCE can unilaterally change the requirement for them to process applications? Doesn’t the CPUC have something to say about this?

The existing standard of 10 business days - two weeks on the calendar - was already a joke, but now they are saying that “some” applications could take 20 business days - nearly a month! Oh and to add insult to injury, they also raised the application fee - you know, the money that is supposed to cover application processing - by 25%! Must be nice to be able to jack the price that you are charging, while simultaneously reducing the service provided. Aren’t monopolies swell?

This is getting real folks. In an earlier post - find it here - we stated that we couldn’t guarantee NEM 2.0 for applications submitted after March 31st. But given this revision - and zero clarity on which applications might hit that 20-day limit, we need to push things up. RUN ON SUN WILL NOT GUARANTEE NEM 2.0 FOR ANY APPLICATION SUBMITTED AFTER MARCH 15! (The Ides of March indeed!)

This is a terrible way to run a business, but we have no control over the arbitrary nonsense coming from SCE. Please plan accordingly!

It is sometimes said that deadlines focus the mind.  Well, if you are in SCE territory, there is a deadline looming that you need to keep in mind if you are thinking of going solar in the next three years!

The deadline imposed by the CPUC upon SCE customers to get into solar under the existing, far more lucrative NEM 2.0 rules is coming fast.  Here are the key takeaways:

• You must have a complete application in to SCE - and accepted by them - before April 15th!
• SCE loves to reject applications at least once - if that happens to you, so that it isn’t approved before the 15th, you are out of luck!
• YOU DO NOT NEED TO COMPLETE THE PROJECT BY THE DEADLINE!!!  YOU ONLY NEED TO HAVE A COMPLETE APPLICATION BY THEN.
• Projects can be completed anytime within three years of submission!

I know people don’t think this way, but if adding solar is on your “to-do” list but realistically not for a year or two, YOU NEED TO GET YOUR APPLICATION ON FILE NOW!  It’s crazy, and it isn’t how we want to do business, but these are the cards we’ve been dealt.

One last point - this only applies to SCE, PG&E, and SDG&E customers.  If your utility isn’t one of those three, your fine, this does not affect you at all.

TL;DR: NEM 3.0 will drastically lower payback rates in SCE territory
Act before April 14th to lock-in the better rates of the current rules!

(NB: If you are NOT an SCE customer, you can ignore this entirely as it won’t affect you at all!)

In December, the California Public Utilities Commission (CPUC) unanimously approved the Net Energy Metering (NEM) 3.0 proposed decision, making it the law in the territories serviced by the three Investor-Owned Utilities (IOUs) - PG&E, SDG&E, and SCE.  While the final rules aren’t as bad as they started out to be (more on that below), they are still a disaster for the industry.  Here’s our take…

NEM Today…

NEM is the policy that allows solar power system owners to be compensated for the energy that they export to the grid.  Typically, because energy use at home is lower during the day, while your solar system is producing its greatest amount of energy, that energy goes back onto the grid, where the utility then sells it to your neighbor, just as if they had generated it themselves.  But the utility didn’t need to incur any cost to generate that energy, so it is only fair and right that the customer who had invested in that solar power system should be compensated for the excess they provide to the grid.

NEM has had two distinct iterations in IOU territory.  The original form of NEM was full retail compensation - that is, the utility customer was credited one-for-one for the energy that they export.  Since that is the same amount that the utility gets to charge the neighbor receiving that energy, the transaction is essentially a push for the utility.  While that is still the case with the municipal utilities like PWP and LADWP, it is no longer the case with the IOUs in general and SCE in particular.

Back in 2017, the CPUC rolled out NEM 2.0 - and while it was a disappointing departure from full-retail NEM, it wasn’t as bad as the IOUs wanted.  Instead, the changes added a one-time interconnection fee ($75 in SCE territory), required solar customers to be placed on Time-of-Use rates (as opposed to the more economically beneficial tiered rates), and introduced the concept of Non-Bypassable Charges which reduced the value of exported energy by a little over two cents per kWh.  (You can read my post explaining NEM 2.0 here.)  Existing NEM customers were “grandfathered” in for twenty years, thereby guaranteeing that they would retain the value of their investment.

However, that wasn’t the end of the IOU’s war against rooftop solar.  It was understood that there would be a subsequent rulemaking - NEM 3.0 - and the IOUs vowed to bring solar to heel when that rulemaking rolled around.  Indeed, solar managed to thrive in the years since NEM 2.0 went into effect, with California installing more than 1.5 million solar systems by last September.  

I have written at length about the NEM 3.0 Proposed Decision that was released in December 2021, and the solar industry’s efforts to fight it off (as in here, here, here, here, here, here, and here)!  There was good reason for our sense of urgency and our advocacy: the PD was a disaster!  It would have threatened the grandfathering of existing NEM customers, it would have imposed an outrageous tax on new solar systems, and it would have drastically cut the compensation rate for energy exported back to the grid.  If approved as proposed, it would have decimated the solar industry in IOU territories.  Fighting back was our only option.

First - the Good News…

Our unprecedented advocacy had positive results.  The initial PD was withdrawn, and we bought 11 months of delay allowing thousands of additional solar systems to be installed under NEM 2.0.  The rules as adopted leave alone the grandfathering for NEM 1.0 and 2.0 systems which will remain under their rules for 20 years.  Most importantly, we killed the solar tax that would have added a monthly charge of $6/kW on all new systems!

We made a lot of noise and we defeated some of the worst provisions of the original PD - kudos to all who wrote, and spoke, and marched, and called - it made a difference.

And Now, the Bad News…

But as important as those results are, we took a major hit when it comes to the export value of solar energy sent back to the grid - on average, roughly a 75% haircut - and the change happens overnight!  Instead of providing a “glide slope” of reduced export rates over, say, a five-year phase-in period, the drastically reduced export rates land as of April 14.  This will create a “gold rush” to get applications in before the rules change - more on that below.

Not only did the CPUC drastically lower the export rate, they made the means of calculating it completely Byzantine in its complexity, making modeling of export savings more complicated by orders of magnitude.  Under existing NEM 2.0 rules, your compensation was tied to when the energy was exported (since all solar customers were put on a Time-of-Use rate).  That meant you could be getting compensated under one of six export values: essentially high, medium, and low periods for both Summer and Winter seasons. 

By contrast, the new system uses one value for every hour of the year - 8,760 discrete values!  Seriously?

In an effort to provide some clarity out of that chaos, our friends at CALSSA boiled that down into this heatmap that averages those values down to “just” 576 values (12 months times 24 hours, times two categories - weekday and weekend).  Here’s the weekday version (click for larger):

The color coding here is a simple gradient going from red for the lowest values to green for the highest.  There is one thing here that is really curious - see those two green numbers?  If you are exporting energy to the grid between six and seven p.m. during September, SCE is going to pay you nearly $3 for that energy!  Of course, there is very little solar output at those hours, but a properly programmed storage system can time its release of energy to coincide with those peak hours.

Clearly, solar power systems that also include storage will fair better under the NEM 3.0 rules than will solar only systems.  Which is great for those who can afford the extra expense of adding storage, but is awful for everyone else.

In addition to the vastly lowered export rates, all solar customers will be forced onto the TOU-D-Prime rate.  That rate structure imposes a monthly fixed charge of $14.  (Compare that to the 3.1¢/day rate imposed on the tiered, Domestic rate that SCE customers were historically paying.)

The On-Peak rates are eye-popping!  If you are using energy during that 4-9 p.m. window in the summer you will be paying 54¢/kWh!  While that peak is crazy high, the  differential between On-Peak and Off-Peak is enormous: 30.7¢/kWh.  Again, if you have storage and can shift energy from mid-day production peaks for use after 4 p.m., you can leverage that difference.

Of course this reliance on storage to make NEM 3.0 less painful is in discord to the IOU’s professed concern for the inequities of solar - i.e., that it is only for the rich. Making the payback period for solar longer for everyone simply makes it less affordable by working-class people.  Needing to add storage on top of that, really pushes these systems toward the rich, and away from the middle class.  But then, this was never about concerns over lower income customers, this was always about protecting SCE’s profits.

Going Forward

Ok, so we are stuck with a bad decision that goes into effect April 14.  In order to qualify for NEM 2.0, the interconnection agreement must be submitted no later than April 13, and must be “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).“  The ruling doesn’t define what a “major deficiency” is, and up until now, it has been SCE’s sole discretion as to whether an application was complete and valid.  We have seen applications kicked for the most minor of issues, and if you submit near the deadline, and SCE kicks the application and you now miss the deadline, the value of your project will have changed drastically for the worst.

I’m not sure what other companies will do, but this is our intention: WE WILL NOT GUARANTEE SYSTEM SAVINGS FOR ANY APPLICATION SIGNED AFTER MARCH 31!

We can be certain that there will be problems as we get closer to the deadline, so the above rule will be hard and fast, and our contracts will reflect that reality.  So, a word to the wise: if you are thinking about going solar in SCE territory this year - act NOW!  You do not need to complete the project this year to qualify - you just need the application in and complete.  You have up to three years to actually complete the project!

It’s gonna be a crazy first quarter - the joys of riding on the solar coaster!  Get in touch now so that we can get the process completed in a timely manner.

Short and sweet: We need you to call Governor Newsom on June 21st!

Here’s the message from our friends at CALSSA:

1. Call between 9 a.m. and 5 p.m.Do not call earlier or later as you likely will not be able to get through. If for some reason you are unable to leave either a recorded message or a message with a live person and it is between 9 and 5, simply keep calling again until you do! 
   
   
2. The number to call is 916-445-2841. After you dial, a recording will ask you to press 1 to continue in English or 2 for Spanish. After you press the appropriate number, you will then need to press “6″ to speak to a representative.
   
   
3. The phone may ring many times, but eventually you shouldreach a representative for the Governor. When you do, simply deliver your message (sample script below). If no one picks up, you may be instructed to record a message, which is also totally fine.
   
   

   Sample script: “My name is __, I live in ___ and I [own a solar system/work in the solar industry]. I am opposed to a solar tax of any kind, and any other change that makes solar less affordable for working and middle class people. California should make rooftop solar more affordable for everyday people, not less. I expect Governor Newsom to take a clear public stance on this matter and show the leadership that this state deserves. Thank you.” [Feel free to use your own words!] 
   



4. After you are done speaking with someone or recording a message, please go here to let us know what happened. This is very important as we’re keeping tabs on how many phone calls we’ve generated.
   
   
5. Finally, after you have reported back to us on your call, make sure to email your colleagues or share on social media what you’ve done and ask them to do the same! There’s template language you can use below.

Thanks for your help - together we are going to win this thing!