Letter from SDG&E Regarding new TOU time period

[NateHornblower]

I received this letter today and figured I'd pass it along. From my initial read, it seems that one can stay on tiered rates, but they do not say for how long. I've had a few conversations with SDG&E on the phone and get differing answers - anything from through 2018 to sometime in 2019 - when those on tiered would be forced to a TOU plan. Of course, I can't find anything in writing. The letter states that one can switched to the current TOU plan for 5 years, but must do so by November 31. Previous phone conversations stated if grandfathered, one can switch to an old TOU plan within 5 years from PTO. This seems to have been incorrect.

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To support the statewide commitment to clean, reliable electricity, California's residential customers will join business customers in moving to time of use pricing plans. These plans encourage people to save electricity when it matters most because prices are higher when demand for electricity peaks, and lower during off-peak hours.

As we increase our use of electricity from renewable sources, the peak time for energy used from the power grid has shifted to later in the day when the sun goes down and renewable energy production drops. To align with this change in demand, beginning December 1, the on-peak hours - when electricity demand is at its highest - are changing from 11 am-6 pm to 4 pm-9 pm.

Know your options
Customers like you with private wind or solar systems have a choice to remain on your current pricing plan or move to a time of use plan. Here are your options:

• You can simply choose to remain on your current standard tiered pricing plan. No action is required at this time to stay on a tiered plan.
• You can switch to a time of use pricing plan now. If you chose this option, you will keep the current time of use peak period for up to five years from your Permission to Operate date. To make this change, your decision is needed by November 30, 2017.

To change to a time of use pricing plan, simply log in to My Account at sdqe.com/MyAccount, scroll down to "Featured Services" and select

[sensij]

These are the same grandfathering terms that have been discussed here a few times. I can find some other threads to link, if you would like.

There is no set end date for tiered plan availability. I would guess at least 5 years, but it is just a guess. *New* installations can continue to elect the tiered plan until March, but after that, all new PV installations will be TOU.

[J.P.M.]

Tiered tariffs and schedules will be around for awhile. Although I think SDG & E is quite deceptive about it, and some, maybe most or all PV users may be forced off tiered rates at some point. Folks on NEM 1.0 will, at some point, need to make a positive election to remain on tiered rates. Otherwise, they will default to T.O.U. All that says nothing about want happens, for example, if the CPUC allows the 3 big CA POCOs to either get rid of tiered rates entirely, or, perhaps more likely, close the tiered rate schedules to new customers and eventually letting them die out.

At this time, my understanding is, at least for NEM 1.0 users, the tiered rates are possible, BUT, at some future point those users will be advised that they will need to positively affirm their desire and intent to remain on tiered rates. Lacking such positive election, SGD & E will switch those users to T.O.U.

Such election may or may not apply to NEM 2.0 users on tiered rates. Overall, more lack of clarity and direction from the POCO.

[NateHornblower]

I agree with J.P.M. in that SDG&E is purposefully being vague. For instance, can I stay on tiered rates and move to TOU in 2018 under the current (not new) peak times? Can I move back to tiered? If so, is that for 5 years?

Sure, I can call SDG&E but I don't get consistent answers and verbal statements are worthless anyway. There's nothing in writing clarifying the scenarios for both 1.0 and 2.0 participants.

[sensij]

4-9 pm peak is your only TOU option after Dec 1, if you aren't in a plan with the better hours by then.

The election to the tiered plan needs to be made within 120 days of Dec 1 for NEM-ST customers.

That much is clear. Forget any idea that suggests you can swap to an otherwise unavailable tariff after the deadlines. You won't be able to.

[J.P.M.]

4-9 pm peak is your only TOU option after Dec 1, if you aren't in a plan with the better hours by then.

The election to the tiered plan needs to be made within 120 days of Dec 1 for NEM-ST customers.

That much is clear. Forget any idea that suggests you can swap to an otherwise unavailable tariff after the deadlines. You won't be able to.

If a user is an NEM - ST customer (NEM - 2.0) tiered rates are going away, probably in 2019 or so.

NEM 1.0 cust. will, at this time anyway, have a tiered rate available to them with no published time limit for how long the tiered rate will be available, at least at this time.

But again, and to reiterate, NEM 1.0 users will need to make the positive election if they wish to stay on tiered rates. SDG & E has told me (several times, but not in writing) that they (SDG & E) will send notices to all tiered rate NEM 1.0 users notifying those users that they must positively choose to stay on tiered rates or positively elect to move to another rate or, if no response to SDG & E's notification, be switched to DR - SES. Those who don't make that positive election will be switched to the default schedule which, at this time, is DR - SES.

NEM - ST tariff customers will at some go to tiered rates, like it or not.

SDG & E wants all residential customers on T.O.U. Part of AB -327 was that NEM 1.0 users were locked in for 20 yrs. I believe that "lock" includes some form of tiered rates must remain available to those users if they choose to stay on tiered rates. But, I suppose that could change at just about any time.

After all, one of the AB-327 mandates was to make things clearer and easier for users to understand, and we all see how well that mandate has been adhered to, so I guess that's changed/gone by the boards already.

[sensij]

If a user is an NEM - ST customer (NEM - 2.0) tiered rates are going away, probably in 2019 or so.

I continue to disagree with this interpretation. The NEM-ST tariff states:

Eligible customer-generators who complete their interconnection application for service under this schedule within a period of 120 days after SDG&E's 2016 General Rate Case Phase 2 ("GRC P2") proceeding (A.15-04-012) TOU rates become effective shall be permitted to ... 2) take service under existing TOU rates or tiered rates in effect at the time their interconnection application was completed for a period of time up to five years from the date they take service.

I've seen no written basis for concluding that NEM-ST customers will lose access to the tiered plans before their 5 years are up.

[NateHornblower]

I've seen no written basis for concluding that NEM-ST customers will lose access to the tiered plans before their 5 years are up.

Thus, the point that SDG&E is being vague on purpose. This is up to interpretation. My interpretation is tiered rates are going away for all residential customers sometime in 2018 or 2019. NEM 1.0 customers that did not switch to the current TOU plan by 7/13/17 can no longer utilize that option. Their choice is tiered or the new TOU plan. Eventually, it appears NEM 1.0 will move to TOU regardless, but I haven't dug too deep into it because I'm NEM-ST (2.0).

Ugh, I had a long post prepared and it disappeared when I submitted the post. The long and short of it is being NEM-ST, it's clear I have to move to TOU before EOM to be able to utilize legacy TOU for 5 years post PTO. What isn't clear is - during that period, can I move to TOU-EV(2), back to tiered, and back to legacy TOU within this period if I so desired?

[sensij]

Thus, the point that SDG&E is being vague on purpose. This is up to interpretation. My interpretation is tiered rates are going away for all residential customers sometime in 2018 or 2019. NEM 1.0 customers that did not switch to the current TOU plan by 7/13/17 can no longer utilize that option. Their choice is tiered or the new TOU plan. Eventually, it appears NEM 1.0 will move to TOU regardless, but I haven't dug too deep into it because I'm NEM-ST (2.0).

Ugh, I had a long post prepared and it disappeared when I submitted the post. The long and short of it is being NEM-ST, it's clear I have to move to TOU before EOM to be able to utilize legacy TOU for 5 years post PTO. What isn't clear is - during that period, can I move to TOU-EV(2), back to tiered, and back to legacy TOU within this period if I so desired?

No. You can't switch back and forth. If you give up a plan that you grandfathered into, you can't go back.

No, tiered rates aren't going away anytime soon. The CPUC has agreed to require the *default* rate plans to become TOU in 2019, but the ability to opt-in to tiered plans will still exist for non-solar and NEM 1.0 customers. That is what I think J.P.M. means when he talks about the need for a postive election of the tiered tariff.

[J.P.M.]

No. You can't switch back and forth. If you give up a plan that you grandfathered into, you can't go back.

No, tiered rates aren't going away anytime soon. The CPUC has agreed to require the *default* rate plans to become TOU in 2019, but the ability to opt-in to tiered plans will still exist for non-solar and NEM 1.0 customers. That is what I think J.P.M. means when he talks about the need for a postive election of the tiered tariff.

I think this is a mess. And, I put most of the blame on the POCO for it.

We can all say "I think this means that...", or quote/reprint stuff from SDG & E, a lot of it vague and perhaps or even likely contradictory to something else SDG & E has published somewhere else, with most all of it being undated.

So, rather than waste time and any possible remaining good will arguing about what looks to me to be purposely vague statements and direction from SDG & E that puts all positions on the same shaky ground, until I get better information from SDG & E, in writing, presented in a way that's reasonably complete and unambiguous, and that I can understand, I'll keep my fingers still and mouth shut about how, and when, and in what ways rates and customer tariff and billing options and requirements are, or are not., going to change.

I don't mind a good and spirited exchange of opinions, but all this is, in my opinion anyway, going nowhere near a productive result, mostly from a lack of clear direction and explanations by the POCO.

[lessthanjoey]

4-9 pm peak is your only TOU option after Dec 1, if you aren't in a plan with the better hours by then.

The election to the tiered plan needs to be made within 120 days of Dec 1 for NEM-ST customers.

That much is clear. Forget any idea that suggests you can swap to an otherwise unavailable tariff after the deadlines. You won't be able to.

This isn't quite true. SDG&E have confirmed to me that EV-TOU2 plan is exempt from the TOU time changes for now. In other words "they have no current plans to change EV-TOU2 peak/off-peak times".

I'm under no disillusion that they won't just turn around soon and change their mind on this, there's no guarantee, but it's not changing in the near future the was DR-SES is changing.

Edit: As sensij points out below, apparently having no current plans didn't last very long! My statement above is now *incorrect*.

[sensij]

This isn't quite true. SDG&E have confirmed to me that EV-TOU2 plan is exempt from the TOU time changes for now. In other words "they have no current plans to change EV-TOU2 peak/off-peak times".

I'm under no disillusion that they won't just turn around soon and change their mind on this, there's no guarantee, but it's not changing in the near future the was DR-SES is changing.

You should probably Google advice letter 3130-E. PDF page 48. EV-TOU-2 hours are changing too.

Edit: OK, I'm at a computer now, here is the link.

[sensij]

I think this is a mess. And, I put most of the blame on the POCO for it.

I think this is less of a mess than some are making it out to be, but have no desire to burn goodwill over it either. My statements in this thread will remain un-edited as the future unfolds. I encourage anyone who is on the fence to take the grandfathering deadlines seriously.

[lessthanjoey]

You should probably Google advice letter 3130-E. PDF page 48. EV-TOU-2 hours are changing too.

Edit: OK, I'm at a computer now, here is the link.

Thank you for this! I had called ~ 2 months ago, looks like they changed their minds 2 weeks ago "officially".

Edit: also looks like they've played around with the hours and gone full-on annoying. The page linked below *used to* say that the new peak hours were 3-9pm, but it looks like now they're taking advantage of CPUC telling them they could have 4-9pm (and it matches 3130-E). They've also picked-up noon-2pm as "super off-peak" in winter. Amazing!

https://www.sdge.com/clean-energy/time-use-period-grandfathering-net-energy-metering-customers

[questioner]

These are the same grandfathering terms that have been discussed here a few times. I can find some other threads to link, if you would like.

There is no set end date for tiered plan availability. I would guess at least 5 years, but it is just a guess. *New* installations can continue to elect the tiered plan until March, but after that, all new PV installations will be TOU.

We got this letter too. We have a 10KW ground mount system. producing about -1600 kwh/ $600/mo in summer. we haven't moved into the home yet but want to cover house and 1800 SF shop with A/C. We have an friend who works at SDGE in the dept that helps customers with solar. She advised us to take the DRSES now. she said we will be able to stay on tiered billing (if we chose) until 2021, then you WILL NOT have tiered billing you WILL BE time-of-use with On-Peak from 4-9pm. If you pick a TOU rate after 12/1/17

do you agree we should switch from tiered to TOU?