December 31: New "TOU 1.0" Deadline for Public Agencies

Interconnection applications must be submitted by December 31*, and they should be prepared by an independent advisor.

The California Public Utilities Commission (CPUC) has issued a new decision that expands eligibility to public agencies for grandfathering existing Time of Use (TOU) periods in PG&E, SCE, and SDG&E territories. Any public agency planning a solar PV project should immediately begin work to submit their project interconnection applications before the new December 31* deadline to qualify for TOU grandfathering.

*A previous version of this article incorrectly listed December 25 as the deadline, due to lack of clarity around the final date of the decision.


To recap, California’s three major public utilities are shifting their summer “peak” energy cost periods from mid-afternoon to early evening, in what some are calling TOU 2.0. Solar PV systems generate most of their power and bill savings during summer afternoons. By shifting the summer peak period to early evening after solar PV has stopped producing power, the energy cost savings generated by solar PV are reduced. Sage has modeled a loss of value from the proposed TOU period changes as much as 30% for a typical 1 MW high school PV system. (Read more about the TOU changes here.)

In a January 19, 2017 rulemaking, the CPUC created terms and conditions for customers to be eligible for ten years of grandfathering on current TOU periods. It stated that customers had to submit an initial interconnection application by January 31, 2017, and complete installation by July 31, 2017 for non-school customers and December 31, 2017 for schools.

What's New

The new TOU decision issued by the CPUC on October 26, 2017, eliminates the construction deadline and opens up a new interconnection application period until December 31, 2017, which is 60 days from the date of the decision. You have until Christmas to submit a completed interconnection application for any projects your agency is considering. Under this new decision, you can install an eligible system at any time and receive TOU period grandfathering through July 31, 2027 for most public agencies, and through December 31, 2027, for schools.

Take Action

An independent energy advisor can correctly size the systems at your facilities and prepare and submit the interconnection applications. While solar vendors may offer to submit interconnection applications for you, we recommend using an independent advisor to avoid biasing a future competitive procurement process for design and installation of the PV systems. It’s critical to preserve an open, transparent and competitive procurement process to deliver the best value energy project for your organization.

Sage is the independent energy advisor trusted by more than 80 California school districts and public agencies. We can expedite your interconnection application process using conservative assumptions to ensure that your organization ends up with the best possible solar project.

Give us a call to get started.