SolarDaily Exclusive: One Small Contractor Forces CPUC to Blink on 150% Storage Rule

SolarDaily Exclusive: One Small Contractor Forces CPUC to Blink on 150% Storage Rule
by Clarence Oxford
Los Angeles CA (SPX) Aug 20, 2025
On August 13 at exactly 4:38 p.m., Southern California Edison (SCE) pressed send on an email that landed like a hammer blow across California's solar industry. The subject was clinical: "Suspension of the Paired Storage 150% Rule is Expiring August 15, 2025." The reality was far harsher: in 48 hours, contractors would once again be shackled by an outdated CPUC regulation that limited storage capacity to 150% of paired solar.

The reaction was swift - but not from a major trade group or utility coalition. Instead, it came from one small solar company in Torrance, CA: ABC Solar Incorporated.

The Rule in Question

The Paired Storage 150% Rule, adopted in 2014, restricts the maximum AC output of storage systems paired with rooftop solar to no more than 150% of the solar array's CEC-AC rating. Originally justified as a guardrail against export "gaming," it has long since outlived its purpose. Under today's Net Billing Tariff (NEM 3.0), oversizing batteries yields no export advantage. Instead, larger batteries are used for resilience, outage protection, and self-consumption - exactly the capabilities California customers want in an era of wildfires, heat waves, and grid instability.

From 2020 until now, the rule had been suspended under CPUC Decision D.20-06-017, allowing flexibility in system design. The 4:38 p.m. email announced the party was over.

The Little Guy Fights Back

Enter Bradley L. Bartz, president of ABC Solar. With 25 years in the industry, Bartz has built a reputation for battling Edison on interconnections and calling out CPUC's pro-utility bias. That night, he filed a formal extension request under Rule 8.3 of General Order 96-B.

Unlike CALSSA's broad petition filed in June, which seeks to permanently revise or eliminate the rule, Bartz's filing was laser-focused: stop the August 16 reinstatement before it stranded projects.

Here is the request, in full, submitted by ABC Solar:

The Original Extension Request

Dear Executive Director Peterson:

Pursuant to Rule 8.3 of General Order 96-B, ABC Solar Incorporated respectfully requests a 90-day extension of the compliance deadline for the reinstatement of the Paired Storage 150% Rule under Decision (D.) 20-06-017.
As presently scheduled, the temporary suspension of the 150% Rule will expire on August 15, 2025, with interconnection applications submitted on or after August 16, 2025 required to comply with the limit that the aggregate output capacity of paired storage not exceed 150% of the CEC-AC rating of the renewable generating facility. We request that this effective date be extended to November 15, 2025.

Background
In August 2020, pursuant to D.20-06-017, the CPUC suspended the 150% sizing limit for paired storage to encourage adoption and flexibility during the early Net Billing Tariff (NBT) transition. The rule suspension allowed customers to size storage systems for resiliency, peak shaving, and self-consumption without being bound to the PV array size. This approach has supported deployment of storage for wildfire resiliency, outage mitigation, and electrification.
The upcoming reinstatement coincides with multiple market stresses, including the loss of the 30% Federal Investment Tax Credit for solar and storage recently eliminated under new federal policy. This creates a significant financial barrier for California customers and contractors.

Justification for Extension
Avoiding Project Stranding - Many customers currently in the design, permitting, and procurement process would be forced to cancel or redesign systems if the rule is reinstated abruptly.
Customer Harm Prevention - The combined effect of the federal ITC elimination and a sudden rule change would result in higher costs, reduced system capability, and in some cases total project abandonment.
No Material Grid Risk - Under NEM 3.0 export rates, there is no incentive to oversize batteries for export gaming. Larger batteries are used for self-supply and resiliency, supporting grid stability.
Administrative Readiness - A short extension allows utilities, installers, and permitting offices to update forms, portals, and public materials, avoiding customer confusion and inconsistent application processing.

Request
For these reasons, ABC Solar Incorporated respectfully requests that the CPUC extend the effective date for reinstatement of the Paired Storage 150% Rule from August 16, 2025 to November 15, 2025.
This extension will reduce customer harm, allow for orderly transition, and preserve progress in California's clean energy and resiliency goals during a challenging policy environment.
We appreciate your consideration and are available to provide supporting data, project impact case studies, or to participate in any related workshops.

Sincerely yours,

Bradley L. Bartz
ABC Solar Incorporated

The Blink

On August 15 at 2:59 p.m., Edison sent out a second email. This time, the tone was different:

"A request to extend the suspension...was approved by the CPUC. As a result, the suspension of the Paired Storage 150% rule is in place until further notice."

The August 16 deadline was dead. Projects could proceed. Contractors breathed a sigh of relief.

Why the CPUC Folded

This wasn't just about one filing. The CPUC is under heavy pressure. On August 7, the California Supreme Court ordered a re-review of CPUC's rooftop solar net metering cuts, signaling deep concern that the Commission has leaned too far toward investor-owned utilities at the expense of ratepayers.

Approving ABC Solar's extension request was damage control. It prevented stranded projects and helped the Commission avoid reinforcing the perception that it serves utilities first and Californians last.

Independent vs. Association

It's true: CALSSA's June petition will determine the rule's long-term fate, likely replacing the cap with a compromise on grid upgrades and export limits. But let's be clear - CALSSA's filing didn't stop the August 16 cutoff.

That credit goes to one small contractor filing late at night: ABC Solar.

The Bigger Lesson

Policy fights in California often feel like David vs. Goliath. But this week, David won. The CPUC blinked, not because of industry giants, but because one contractor stood up and refused to let utilities dictate the terms of resilience.

As Bartz puts it: "This time, the little guy won."