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COM/MP1/sid Mailed 5/29/2007

Decision 07-05-047 May 24, 2007


Order Instituting Rulemaking Regarding Policies, Procedures and Rules for California Solar Initiative, the Self-Generation Incentive Program and Other Distributed Generation Issues.

Rulemaking 06-03-004

(Filed March 2, 2006)


This decision establishes a process for approval of interim marketing and outreach plans for the California Solar Initiative (CSI). The interim process will remain in place until such time as the Commission provides more complete guidance to the CSI program administrators regarding CSI marketing and outreach activities at a later date in Phase II of this rulemaking.


In opening this rulemaking on the CSI, the Commission stated its intent to develop marketing and outreach protocols for CSI so that funds are used wisely to inform potential solar customers and developers of program opportunities. Given the myriad issues to confront in establishing the CSI, the Commission planned from the outset of this proceeding to address marketing and outreach issues after preliminary, or Phase I issues, were resolved. The Phase II schedule for this proceeding indicates marketing and outreach plans will be addressed following examination of research, development and demonstration (RD&D) and low income/affordable housing incentive issues.1

Currently, the CSI program administrators2 have no Commission-established budget for marketing and outreach activities, although the Commission has set a cap of 10% of total CSI funds on administrative activities, which includes marketing and outreach. (See Decision (D.) 06-08-028, mimeo. at 97.) Furthermore, the Commission directed the program administrators to spend no more than 5% of their budgeted CSI funds reserved for administration until marketing, outreach, and program evaluation issues were addressed in Phase II. (Id.)

Although the CSI program began on January 1, 2007 and program administrators are now accepting applications for solar incentives from residential and non-residential customers of PG&E, SCE, and San Diego Gas & Electric Company (SDG&E), the program administrators have no guidance from the Commission on CSI marketing and outreach activities. Given that the program is underway, there is an immediate need for the program administrators to perform some level of marketing and outreach functions now, in advance of more thorough guidance on marketing and outreach from the Commission later this year. Any marketing and outreach the program administrators perform in advance of interim or final Commission guidance is at risk for disallowance.

On April 3, 2007, the assigned Commissioner issued a ruling soliciting comments on a process for approval of interim marketing and outreach plans. The ruling set forth a proposed process whereby program administrators would submit interim marketing plans within 10 days of this order to the Energy Division through an Advice Letter process. The ruling specified a budget of no more than $500,000 annually for each program administrator and listed components of interim marketing plans including bill inserts and installer training sessions.

Comments and/or reply comments on the ruling were filed by Americans for Solar Power (ASPv), the Consumer Federation of California (CFC), the Green Power Institute, PG&E, SDG&E, SDREO, and SCE.

The comments generally support the concept of approval of interim marketing plans by the Energy Division in advance of more complete consideration of this issue by the Commission later this year, although parties seek clarification on elements of the interim marketing plans, the total budget, reporting requirements, and timing of filings. We will address the specific comments in the next section.

Only one party, CFC, opposes the need for interim marketing plans. CFC maintains the Commission does not have authority to begin CSI until January 2008, thus interim marketing in 2007 is unnecessary. Further, CFC maintains that any marketing should be statewide rather than individual campaigns by each program administrator. We disagree with CFC's main assertion that the Commission does not have authority to implement CSI in 2007. Indeed, the program is well underway and applications for solar incentives are received daily by program administrators. Therefore, we find it necessary to approve interim marketing plans despite CFC's comments. We will consider CFC's suggestion for statewide rather than individual marketing efforts when we give greater attention to this issue later in Phase II.

1 See "Assigned Commissioner's Ruling Revising Schedule for Phase Two," February 5, 2007.

2 The CSI program administrators are Pacific Gas and Electric Company (PG&E), the San Diego Regional Energy Office (SDREO), and Southern California Edison Company (SCE). On May 3, 2007, SDREO changed its name to the California Center for Sustainable Energy (CCSE). To avoid confusion, this decision will continue to refer to CCSE by its former name, SDREO.

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