Energy, Inc. (Sunverge), OutBack Power Technologies (OutBack), and Charles Hewitt filed comments. On November 8, 2013, Outback, SDG&E, CALSEIA, SolarCity, CESA, SCE, PG&E, ORA, IREC, Sunverge, and Charles Hewitt filed reply comments. On January 6, 2014, Commissioner Michael Peevey issued a subsequent ACR to solicit additional input into safety considerations for the interconnection of energy storage systems. On January 8, 2014 SCE, ORA, SDG&E, Charles Hewitt, Elke Brazel, CESA, IREC and SolarCity filed comments in response to the January 6, 2014 ACR. NEM Eligibility The October 17, 2013 ACR explained that storage devices paired with NEM-eligible generation facilities that meet the Guidebook requirements may exempt from interconnection application fees, supplemental review fees, costs for distribution upgrades, and standby charges as additions or enhancements to NEM-eligible systems under the current NEM tariff. These exemptions would apply to any storage device connected behind the same billing meter as the NEM generating system because this configuration meets the conditions of the "directly connected energy storage" category as described in the Guidebook. However, in order to preserve the integrity of NEM, or in other words, in order to ensure that NEM credits can only be generated by eligible renewable electric generation, the ACR proposed that qualifying systems meet certain configuration and metering requirements. To achieve this goal, the ACR suggested that the metering requirements in the NEM Multiple Tariff (NEM-MT) serve as the standard to ensure that only NEM-eligible generation receives NEM credit. Under the NEM-MT provision, the customer-generator must 1) install a non-export relay on the non-NEM generator(s); 2) install Net Generation Output
Energy, Inc. (Sunverge), OutBack Power Technologies (OutBack), and Charles Hewitt filed comments. On November 8, 2013, Outback, SDG&E, CALSEIA, SolarCity, CESA, SCE, PG&E, ORA, IREC, Sunverge, and Charles Hewitt filed reply comments. On January 6, 2014, Commissioner Michael Peevey issued a subsequent ACR to solicit additional input into safety considerations for the interconnection of energy storage systems. On January 8, 2014 SCE, ORA, SDG&E, Charles Hewitt, Elke Brazel, CESA, IREC and SolarCity filed comments in response to the January 6, 2014 ACR. NEM Eligibility The October 17, 2013 ACR explained that storage devices paired with NEM-eligible generation facilities that meet the Guidebook requirements may exempt from interconnection application fees, supplemental review fees, costs for distribution upgrades, and standby charges as additions or enhancements to NEM-eligible systems under the current NEM tariff. These exemptions would apply to any storage device connected behind the same billing meter as the NEM generating system because this configuration meets the conditions of the "directly connected energy storage" category as described in the Guidebook. However, in order to preserve the integrity of NEM, or in other words, in order to ensure that NEM credits can only be generated by eligible renewable electric generation, the ACR proposed that qualifying systems meet certain configuration and metering requirements. To achieve this goal, the ACR suggested that the metering requirements in the NEM Multiple Tariff (NEM-MT) serve as the standard to ensure that only NEM-eligible generation receives NEM credit. Under the NEM-MT provision, the customer-generator must 1) install a non-export relay on the non-NEM generator(s); 2) install Net Generation Output
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