Why Is My Pg&e True-up So High

Business customers:

To comply with California Public Utilities Commission (CPUC) requirements to better aligns electricity price signals with grid needs, PG&E will transition Non-Residential customers to TOU rate plans with higher prices during evening peak hours (4-9 pm), a shift from the daytime peak hours (typically 12-6 pm) under current “legacy” rates.

The (CPUC) also issued requirements1 that allow Non-Residential customers with approved solar systems who have met certain interconnection-related milestones to remain on Time-of-Use (TOU) rates with “legacy” TOU periods for up to ten years. The 10-year legacy period starts from the first solar approval date (the date on which the customer received permission to operate from PG&E) but will not extend beyond 2027, which is the end of the transition mitigation period.2

As described in PG&E’s advice letter 5188-E (PDF), to be eligible for “Solar Legacy TOU Periods” the customer must meet all of the following requirements:

  1. Submit an interconnection application for solar by the applicable deadline:
    • Public Agencies – by December 31, 2017
    • All Other Non-Residential Customers – by January 31, 2017
  2. Receive Permission to Operate (PTO) from PG&E
    • Customers who submitted an interconnection application by the applicable deadline but have not yet received PTO by the time of mandatory TOU defaults will be transitioned to an applicable rate with revised TOU periods along with all other Non-Residential customers. However, once PTO is issued, customers will be returned to their applicable TOU rate with legacy TOU periods.
    • The mandatory TOU defaults will occur in March 2021 for Commercial/Industrial and Agricultural customers.
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For eligible “benefiting” accounts (electric meters):

In the case of interconnection applications for a solar program that included one or more “benefiting” account(s), the benefiting electric meters that were approved with the solar system are also eligible for Solar Legacy TOU Periods for as long as they are in the same “arrangement” specified in the original approved interconnection application.

The Net Energy Metering (NEM) and other tariff programs that have benefiting accounts/meters and are eligible for this provision are: Net Energy Metering Aggregation (NEMA/NEM2A), the Virtual NEM programs (NEMV/NEM2V), Virtual NEM for Multifamily Affordable Housing with Solar Generation (NEMVMASH and NEM2VMSH), and Local Government Renewable Energy Self-Generation Bill Credit Transfer (RES-BCT).

Maintaining eligibility

Customers who are eligible will maintain their eligibility as long as all of the following statements are true:

  1. The approved solar system remains operational at its current location. Solar Legacy TOU Period Eligibility is location and customer-specific.
  2. The eligible service agreement ID remains with the customer of record who was in place at the time of interconnection.
  3. The eligible service agreement ID is on an applicable non-residential rate with legacy TOU periods.
  4. In the case of a benefiting account/meter, the eligible service agreement ID is in the original, approved arrangement. Benefiting accounts added or removed from the arrangement after the original Permission to Operate (PTO) date are not eligible for Solar Legacy TOU Periods.

Notification of status

Customers with one or more electric service agreement ID(s) eligible for Solar Legacy TOU Periods will be notified of their status along with their Legacy TOU Period Expiration Date via bill messages and letters in advance of the mandatory default transition dates for all other Non-Residential customers. As described in PG&E’s advice letter 5039-E-A (PDF), Commercial and Industrial customers will be transitioned to the new TOU rate periods annually in November and Agricultural customers will be transitioned annually in March, after their Solar Legacy TOU Period Expiration date. Reminder: all Solar Legacy TOU Period Eligibility will end in 2027.

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Staying on legacy TOU rate periods

Eligible service agreement ID(s) will remain on the current legacy TOU rate periods until their solar legacy TOU period expiration date, at which point they will transition to the new rates.

In general, legacy TOU rate periods with daytime peak hours that coincide better with solar production provide greater bill savings for customers with solar technologies. However, a particular customers’ consumption patterns, as well as the underlying rate prices, will determine which rate is best for a given customer.

Before your Solar Legacy TOU Period Eligibility nears expiration, PG&E will provide you with additional information on your rate transition.

More information

For more information about Solar Legacy TOU Period eligibility, review PG&E’s Electric Rule 1 (PDF) in the section titled “Behind-the-meter solar TOU period grandfathering.” To speak with a representative, contact the Solar Customer Service Center at 1-877-743-4112.

  1. CPUC Decisions (D.) 17-01-006 (PDF) and D. 17-10-018 (PDF).
  2. For a limited set of customers, the 10-year legacy TOU period eligibility may start at the PTO for capacity added to an existing system. This would apply to customers who applied for interconnection between January 23, 2017 and January 31, 2017 for non-Public Agency customers and between January 23, 2017 and December 31, 2017 for Public Agency customers per CPUC Resolution E 5053.
  3. “Public Agencies” are defined as public schools, colleges and universities; federal, state, county and city government agencies; municipal utilities; public water and/or sanitation agencies; and joint powers authorities.

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