SDG&E DR-SESG "grandfathered" TOU plans

[NateHornblower]

I didn't want to bump an old thread (https://www.solarpaneltalk.com/forum...ge3#post367249) but wanted to revisit the topic.

After the Jan 1, 2022 rate increase, the grandfathered DR-SES plan has no more off peak rates. They're all the same no matter what time of day.

Screen Shot 2022-05-04 at 6.41.12 PM.png
I am still on this plan. I am not sure what I was "Grandfathered" info if the rates can be manipulated like this. They aren't the same as the DR-SES TOU plan.

Screen Shot 2022-05-04 at 6.42.19 PM.png

I mistakenly thought I was grandfathered into the rate times - my peak would be 11a-6p during summer, etc. and that rate would be the same rate charged/credited for the non grandfathered plans. It's clear the times can't be changed, but the rates can be anything. If CPUC sets rates, woudln't "off peak" and "semi peak" and "peak" be the same across all plans? Clearly the answer is no. What did I misunderstand? I've been charging my car at $.53/kwh at 3am since January.

The tariff (https://tariff.sdge.com/tm2/pdf/ELEC...EDS_DR-SES.pdf) mentions (bolding mine):

TOU Period Grandfathering Term (Residential): Upon SDG&E’s implementation of updated TOU periods adopted in D.17-08-030, TOU Grandfathering Eligible Customer Generators will continue to be billed under prior existing TOU periods and resulting rates for the remainder of their applicable TOU Grandfathering Term, which begins upon issuance of a permission to operate customer’s on-site solar system and continues for 5 years. In no event shall the duration a customer’s grandfathering term extend beyond July 31, 2022. Upon expiration of a customer’s TOU period Grandfathering Term, the customer will be billed using his otherwise applicable TOU periods and associated rates beginning with the customer’s the next billing cycle.

Is this rate effectively dead for August billing period and beyond?

What's the best rate play here?

Thanks for any insight.

[J.P.M.]

There are no guarantees in life or POCO rates. The CPUC regulates rates and that includes rate times as well as for how long grandfathering goes on and the particulars of the political climate.

Anyway, given special condition 14 on sheet 5 of sch DR-SES, cal P.U.C. sheet 35716-E, your grandfathering will end on 07/31/2022.

Looks to me that for those on grandfathered DR-SES, until 07/31/2022, the buy and sell rates are the same regardless of time of use or generation.
Maybe that's a mercy farewell kiss off of grandfathered rates by the POCO.
If you're an NEM 1.0 user, go back to tiered rates. If you're not, find a rate with low nite rates and turn into a night owl.

FWIW, I'm still on tiered rates, Sch DR, have been on that rate since I moved to CA in 1995 and through my PTO date of 10/13/2013 right up to the present. Unless the POCOs have their way and get the CPUC to rescind 20 year NEM mandate or completely abolish tiered rates, that's where I plan to stay unless something better comes along or tiered rates go away.

[organic farmer]

If you live in a state that allows the POCOS to pay you for power you put onto their girds, be thankful.

Not an option in my state.

Yes, we can 'net-meter' at a higher cost and there is no hope of ever being paid for it.

[NateHornblower]

There are no guarantees in life or POCO rates. The CPUC regulates rates and that includes rate times as well as for how long grandfathering goes on and the particulars of the political climate.

Anyway, given special condition 14 on sheet 5 of sch DR-SES, cal P.U.C. sheet 35716-E, your grandfathering will end on 12/31/2022.

Looks to me that for those on grandfathered DR-SES, until 07/31/2022, the buy and sell rates are the same regardless of time of use or generation.
Maybe that's a mercy farewell kiss off of grandfathered rates by the POCO.
If you're an NEM 1.0 user, go back to tiered rates. If you're not, find a rate with low nite rates and turn into a night owl.

FWIW, I'm still on tiered rates, Sch DR, have been on that rate since I moved to CA in 1995 and through my PTO date of 10/13/2013 right up to the present. Unless the POCOs have their way and get the CPUC to rescind 20 year NEM mandate or completely abolish tiered rates, that's where I plan to stay unless something better comes along or tiered rates go away.

Hello again. I remember you from years back.

What exactly am I grandfathered in as a NEM 2.0 participant? I thought I knew but apparently do not. I get the CPUC sets rates, but am not clear on how rates are set in that a "grandfathered" plan pays a different rate than non grandfathered DR-SES TOU, or that the time period differential can be zero. Curious if you (or anyone) has any insight into this. It seems arbitrary but since it is regulated, it cannot be.

These changes say, "We must grandfather you into old TOU time definitions (peak being 11a-6, semi 6a-11a and 6p-10p, and off peak being 10p-6a) for a period of time, but we're changing the rate per kw/h to effectively nullify the old TOU plan" by nearly doubling the off peak rate. Seems to be in conflict with the spirit of the grandfathering requirement.

EDIT:

https://www.energytoolbase.com/newsroom/blog/grandfathering-protections-for-solar-customers

According to the above, that time periods are all that's grandfathered. Not surprising SDG&E gave grandfathered TOU the big middle finger with this rate adjustment.

[J.P.M.]

Hello again. I remember you from years back.

What exactly am I grandfathered in as a NEM 2.0 participant? I thought I knew but apparently do not. I get the CPUC sets rates, but am not clear on how rates are set in that a "grandfathered" plan pays a different rate than non grandfathered DR-SES TOU, or that the time period differential can be zero. Curious if you (or anyone) has any insight into this. It seems arbitrary but since it is regulated, it cannot be.

These changes say, "We must grandfather you into old TOU time definitions (peak being 11a-6, semi 6a-11a and 6p-10p, and off peak being 10p-6a) for a period of time, but we're changing the rate per kw/h to effectively nullify the old TOU plan" by nearly doubling the off peak rate. Seems to be in conflict with the spirit of the grandfathering requirement.

EDIT:

https://www.energytoolbase.com/newsroom/blog/grandfathering-protections-for-solar-customers

According to the above, that time periods are all that's grandfathered. Not surprising SDG&E gave grandfathered TOU the big middle finger with this rate adjustment.

What can I add other than to repeat what I've already written ?

Looks to me like you'll be getting full retail for generation based on DR-SES grandfathered schedule and almost a single rate/hr. +/- a few cents/kWh until 07/31/2022. Until that date grandfathered DR - SES customers seem to have what's pretty close to hourly flat rates.
After that, you'll probably be switched over to standard DR-SES which (I'm guessing here) is your "otherwise applicable rate".

Or, you can switch to any other allowable residential rate of your choice. But, note that it seems to me that being an NEM 2.0 customer, tiered rates are not an option for you - but I might be mistaken on that if I misread SDG & E's cryptic language,

That grandfathered rates had a limited life of 5 years from PTO including a not to exceed date was clear from the beginning.

Read the source stuff from the CPUC and SDG & E rather than some other things that are not authoritative.

[slinthicum]

Interesting how SDG&E rates vary. I have an EV and I'm on the EV02 rate shown below. For summer when compared with the DR-SES TOU rate shown above, I'm about 3 cents higher for on-peak and off-peak rates, but 6 cents cheaper for super off-peak. I focus on EV charging from 12a.m. to 6a.m. daily, scheduling the dishwasher for the same time frame. We've shifted laundry to weekends until 2:00p.m. to take advantage of those extended super off-peak hours. With a January true-up date, we utilize our electric fireplace as an auxiliary heating source to eliminate solar overproduction and as a consequence reduce our natural gas bill.

These summer on-peak rates are going to come as a shock for a lot of people......

ev02.jpg

[Ampster]

Theoretically, TOU rates were designed to change people's consumption patterns. Based on predicted loads for the summer we still have a steep neck of the duck curve.

[J.P.M.]

From the FWIW desk:

I noticed something hiding in plain sight when I was snooping around several years ago looking for the theoretical array orientation that resulted in a pretty good probability of producing the most total annual generation revenue per installed STC kW (but not necessarily the highest average value per array kWh per installed STC kW) for a residential SDG & E customer in the inland region using Miramar TMY weather data and SAM: The number of "on peak rate", really draconian summer hours rate (non grandfathered) is 765 out of 8,760 hours in a year or ~ 8.73 % of the year. Seems to me that small %age might allow some time shifting and/or conservation opportunities. Such orientation info might be one more tool for those building with lower electric bills in mind, or for ground mounts.

That the peak summer hour rate is so high while the relatively small size of the total peak time may be two indications or backup to the idea or opinion that the duck curve will be hard to flatten by rate increases alone.