A viral r/bayarea post calling PG&E's energy comparison emails "useless" points to a real structural problem: a CPUC rule caps rooftop solar at 110% of prior-year usage, leaving solar customers unable to act on whatever gap the benchmarking report shows.

A Bay Area solar customer posted a PG&E energy comparison email to r/bayarea this week, called it "useless," and drew 271 upvotes. The complaint, from user turtlepsp: PG&E's neighbor-benchmarking reports compare household usage against a local average that doesn't account for solar generation — leading the poster to speculate the utility is measuring them against "empty investment homes." PG&E has not publicly detailed its comparison methodology, and neither has the CPUC.

There is a regulatory constraint underneath the frustration. The California Public Utilities Commission caps rooftop solar installations at no more than 110% of a customer's prior-year electricity usage, under CPUC Decision 16-01-044 — a rule carried into the NEM 3.0 framework that took effect April 2023. A homeowner who adds an EV or a heat pump cannot simply upsize their array to close the gap the benchmarking report implies they should close.

Solar advocates have pushed back on the cap for years. In a February 2024 letter to the CPUC published by the Public Interest Network, Environment California executive director Laura Deehan warned that combined rate cuts and size limits had "caused a crisis within the rooftop solar market."

PG&E co-authored the joint utility proposal — with SCE and SDG&E — that shaped NEM 3.0's billing structure and grid-charge framework. The utility spent $5.04 million on lobbying in 2023 and made $2.1 million in separate contributions to California politicians and campaigns, per OpenSecrets.

What remains unresolved: how PG&E constructs its benchmarking pool, and whether the CPUC has plans to revisit the 110% cap.