3. Overview of Staff Proposal

On July 15, 2009, the Administrative Law Judge (ALJ) issued a ruling requesting comments on a proposal by the Commission's Energy Division staff for an SWH incentive program as envisioned by AB 1470.3 The program would fund gas-displacing SWH systems on new and existing homes and businesses, and electric-displacing systems on existing homes and businesses. The Staff Proposal finds that an SWH incentive program can be cost-effective for ratepayers and in the public interest. Based on this finding, staff proposes establishing the CSI Thermal Program, which would provide incentives to both natural gas-displacing and electric-displacing SWH systems. Funding for the CSI Thermal Program would be derived from the $250 million authorized in AB 1470 to fund gas-displacing systems, and the $100.8 million for solar thermal incentives set forth in Section 2851(b).

Staff envisions the CSI Thermal Program would begin on January 1, 2010 and run for eight years, until December 31, 2017. This timeframe is in keeping with AB 1470, which focuses on promoting SWH installations by 2017 and contains a sunset provision repealing the statute on August 1, 2018. (Section 2867.4.)

A workshop to allow interested parties to ask questions about the proposal and generate ideas for further consideration was held on August 3, 2009.

Comments on the Staff Proposal were filed by the Association of California Community and Energy Services (ACCES), CCSE, the California Solar Energy Industries Association (CALSEIA), the Commission's Division of Ratepayer Advocates (DRA), Ecoplexus, Inc., Environment California Research and Policy Center (Environment California), PG&E, SCE, S.O.L.I.D. USA, Inc. dba SOLID Energy (SOLID), Sopogy, Inc., The Utility Reform Network (TURN), and jointly by SDG&E and Southern California Gas Company (SoCalGas).

Reply comments were filed by ACCES, CCSE, CALSEIA, DRA, PG&E, SCE, SOLID, TURN, and jointly by SDG&E/SoCalGas.

In addition to the comments by parties listed above, several interested persons submitted letters to staff and the ALJ on the Staff Proposal, including the American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE), and the Solar Rating and Certification Corporation (SRCC). These letters were reviewed and placed in the correspondence file of this proceeding.

The Staff Proposal and parties' comments on specific issues within the proposal are discussed by issue in the sections that follow.

3 "Administrative Law Judge's Ruling Noticing Workshop and Requesting Comment on Staff Proposal for Solar Water Heating Program," R.08-03-008, July 15, 2009 (Staff Proposal).

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