That seems reasonable. I’m sure it goes without explaining why you can’t absolve yourself from costs associated with infrastructure.
In the end they will be stimulating customers to cut the cord and go full battery, not at today’s values, but soon that will be an economical option for some people.
As best as I can tell, this decision doesn’t eliminate compensation to customers for avoided delivery costs. The controversy seems to be over how to value the utilities’ avoided delivery costs and also whether customers that export more power than they import in a year can get a payment instead of just a credit-carryover to the next year.
(The file auto-downloads from CPUC site as docx file).
Here’s the part that I think is the crux of the controversy (CALSSA and SEIA are solar advocacy groups):
>In its initial protest, CALSSA states that PG&E and SDG&E propose to limit delivery-related retail export compensation credits to offsetting delivery-related charges and to limit generation-related credits to offsetting generation-related charges. For example, the value of avoided procurement costs in the ACC, and thus in the retail export compensation rate, would only be able to offset the customer’s generation charges. CALSSA asserts that D.22-12-056 requires separate data columns for delivery-related and energy-related portions of the retail export compensation rate only to accommodate unbundled customers. CALSSA concludes that since bundled customers receive both types of credits from the utility, there is no need to apply them independently. CALSSA argues that if bill credit value exists disproportionately in either the energy or delivery side, customers responding to the price signal may not be able to use all of the credits if they exceed charges only on the energy or delivery side. In its protests of PG&E’s and SDG&E’s ALs, SEIA does not object to applying delivery- and energy-related portions of the retail export compensation rate separately, other than at the annual true-up. SEIA proposes that, to fully compensate a customer for all the costs it helped PG&E and SDG&E avoid, the utilities should calculate whether a customer is a “net producer” based on whether the combined retail export compensation rate credits for generation avoided costs and delivery avoided costs (excluding the ACC Plus credit) are larger than the combined generation and delivery charges during the relevant period
>
>In their replies, PG&E and SDG&E explained that the applicability of bill credits only to their respective bill components is a carryover from NEM 1.0 and NEM 2.0 practices, and that this is appropriate because D.22-12-056 did not direct a change to the practice. Further, PG&E asserts that this is necessary to maintain competitive neutrality amongst Load Serving Entities (LSE), because unbundled NBT customers would face an incentive to opt back to bundled service, as non-utility LSEs could not reduce delivery charge obligations. Finally, PG&E asserts, this would represent an asymmetric procurement obligation on the utilities by effectively requiring the utility to credit energy from oversized systems well beyond the actual consumption of the customer. SDG&E also raises competitive neutrality and asymmetric obligation issues.
>
>In its protest to the supplemental ALs, CALSSA continues to advocate against limiting the applicability of bill credits only to their respective bill components. CALSSA asserts that treating retail export compensation rate components separately for bundled customers would be inconsistent with NEM because NEM retail export compensation is based on rates. CALSSA also asserts that community choice aggregators (CCA) could take steps to maintain competitive neutrality, proposing that CCAs could allow credits in excess of charges to result in payments to the customer.
>
>PG&E asserts in its reply to CALSSA’s supplemental protest that the Commission has no authority to require CCAs to provide such a structure, that CALSSA’s suggested approach would lead to asymmetric procurement obligations and undermine competitive neutrality, and that the suggested payments would not be equivalent to the non-bifurcated credits requested by CALSSA. PG&E also asserts that its proposed approach correctly implements the intent of the decision, and that NBT credits are not so different from NEM credits that this treatment should not carry over. SCE does not address this topic in its reply. In its reply to CALSSA’s supplemental protest, SDG&E asserts that CALSSA’s proposed treatment would not maintain competitive neutrality with other LSEs and would likely result in NBT customers choosing the utility as their commodity provider. SDG&E argues that any credits for NBT provided by another LSE would only offset the commodity charges from that LSE, not the delivery portion of the unbundled customer’s bill, while for a bundled customer, the generation credits would offset the delivery side of the bill as well. SDG&E also cites the D.22-12-056 statement that the division of the retail export credit between delivery and commodity is reasonable and considers competitive neutrality amongst LSEs as support for SDG&E’s interpretation that the Commission intended for the retail export credits to maintain competitive neutrality.
There’s also a mention later in the decision that the question of how/whether battery owners can/will get separately compensated under demand response/VPP is a separate question that should be resolved in proceedings about those programs.
3 comments
That seems reasonable. I’m sure it goes without explaining why you can’t absolve yourself from costs associated with infrastructure.
In the end they will be stimulating customers to cut the cord and go full battery, not at today’s values, but soon that will be an economical option for some people.
As best as I can tell, this decision doesn’t eliminate compensation to customers for avoided delivery costs. The controversy seems to be over how to value the utilities’ avoided delivery costs and also whether customers that export more power than they import in a year can get a payment instead of just a credit-carryover to the next year.
[Here’s the full text of the CPUC decision](https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M520/K653/520653275.docx)
(The file auto-downloads from CPUC site as docx file).
Here’s the part that I think is the crux of the controversy (CALSSA and SEIA are solar advocacy groups):
>In its initial protest, CALSSA states that PG&E and SDG&E propose to limit delivery-related retail export compensation credits to offsetting delivery-related charges and to limit generation-related credits to offsetting generation-related charges. For example, the value of avoided procurement costs in the ACC, and thus in the retail export compensation rate, would only be able to offset the customer’s generation charges. CALSSA asserts that D.22-12-056 requires separate data columns for delivery-related and energy-related portions of the retail export compensation rate only to accommodate unbundled customers. CALSSA concludes that since bundled customers receive both types of credits from the utility, there is no need to apply them independently. CALSSA argues that if bill credit value exists disproportionately in either the energy or delivery side, customers responding to the price signal may not be able to use all of the credits if they exceed charges only on the energy or delivery side. In its protests of PG&E’s and SDG&E’s ALs, SEIA does not object to applying delivery- and energy-related portions of the retail export compensation rate separately, other than at the annual true-up. SEIA proposes that, to fully compensate a customer for all the costs it helped PG&E and SDG&E avoid, the utilities should calculate whether a customer is a “net producer” based on whether the combined retail export compensation rate credits for generation avoided costs and delivery avoided costs (excluding the ACC Plus credit) are larger than the combined generation and delivery charges during the relevant period
>
>In their replies, PG&E and SDG&E explained that the applicability of bill credits only to their respective bill components is a carryover from NEM 1.0 and NEM 2.0 practices, and that this is appropriate because D.22-12-056 did not direct a change to the practice. Further, PG&E asserts that this is necessary to maintain competitive neutrality amongst Load Serving Entities (LSE), because unbundled NBT customers would face an incentive to opt back to bundled service, as non-utility LSEs could not reduce delivery charge obligations. Finally, PG&E asserts, this would represent an asymmetric procurement obligation on the utilities by effectively requiring the utility to credit energy from oversized systems well beyond the actual consumption of the customer. SDG&E also raises competitive neutrality and asymmetric obligation issues.
>
>In its protest to the supplemental ALs, CALSSA continues to advocate against limiting the applicability of bill credits only to their respective bill components. CALSSA asserts that treating retail export compensation rate components separately for bundled customers would be inconsistent with NEM because NEM retail export compensation is based on rates. CALSSA also asserts that community choice aggregators (CCA) could take steps to maintain competitive neutrality, proposing that CCAs could allow credits in excess of charges to result in payments to the customer.
>
>PG&E asserts in its reply to CALSSA’s supplemental protest that the Commission has no authority to require CCAs to provide such a structure, that CALSSA’s suggested approach would lead to asymmetric procurement obligations and undermine competitive neutrality, and that the suggested payments would not be equivalent to the non-bifurcated credits requested by CALSSA. PG&E also asserts that its proposed approach correctly implements the intent of the decision, and that NBT credits are not so different from NEM credits that this treatment should not carry over. SCE does not address this topic in its reply. In its reply to CALSSA’s supplemental protest, SDG&E asserts that CALSSA’s proposed treatment would not maintain competitive neutrality with other LSEs and would likely result in NBT customers choosing the utility as their commodity provider. SDG&E argues that any credits for NBT provided by another LSE would only offset the commodity charges from that LSE, not the delivery portion of the unbundled customer’s bill, while for a bundled customer, the generation credits would offset the delivery side of the bill as well. SDG&E also cites the D.22-12-056 statement that the division of the retail export credit between delivery and commodity is reasonable and considers competitive neutrality amongst LSEs as support for SDG&E’s interpretation that the Commission intended for the retail export credits to maintain competitive neutrality.
There’s also a mention later in the decision that the question of how/whether battery owners can/will get separately compensated under demand response/VPP is a separate question that should be resolved in proceedings about those programs.