The Staff Proposal recommends that the CSI Thermal Program Administrators use a public process to develop a CSI Thermal Program Handbook within 30 days of the Commission adopting the program. Ultimately, staff suggests the CSI Thermal Program Handbook would become a section within the general market CSI Handbook, and future modification to it would be submitted to the Energy Division via Advice Letter. Further, staff proposes the PAs host quarterly meetings with stakeholders to entertain CSI Thermal Program modification suggestions.
Staff proposes that the CSI Thermal Program begin accepting applications for incentives on January 1, 2010. In addition, staff suggests that in order to prevent a stall in activity in the SWH market after release of the Staff Proposal in mid-2009, where potential customers might forestall installation decisions in the hopes of qualifying for an incentive in 2010, any qualifying SWH systems installed after the July 15, 2009 release of the Staff Proposal should be eligible to apply for incentives.
CALSEIA and Environment California strongly support a program launch date no later than January 1, 2010 and agree with the Staff Proposal to make rebates retroactive to the release of the Staff Proposal on July 15, 2009. Several parties, namely CALSEIA, SOLID, and PG&E suggest a phased approach, wherein the Commission would first implement incentives for either natural gas- or electric-displacing solar water heating, and follow afterward with other program elements such as combined systems. SOLID suggests segmented start dates of January 1, 2010 for residential SWH incentives and April 1, 2010 for commercial/industrial SWH incentives. PG&E proposes phased deadlines for the PAs to submit marketing and outreach plans, handbook amendments, and SWH applications for residential and commercial customers.
CCSE contends that the 30 days envisioned by the Staff Proposal for the development of the CSI Thermal Handbook is insufficient. CCSE recommends a minimum of 60 days for Handbook development. SCE recommends that the program implementation be postponed to six months after the Commission's final decision on the program, or approximately June 1, 2010.
We acknowledge there are many parties who want an immediate start to this program. Ideally, we would have liked to see the CSI Thermal Program begin accepting applications on January 1, 2010. At the same time, we realize there are a number of administrative and implementation issues that the PAs need time to resolve, such as drafting of the Program Handbook with appropriate siting, installation, system sizing and energy efficiency guidelines and an incentive calculator. We have directed Energy Division to hold workshops on these issues, to aid the PAs in development of the Program Handbook. Thus, we agree with CCSE that 30 days may be insufficient for Program Handbook development.
Therefore, we will adopt a phased approach, as suggested by several parties. We do not agree with SCE to delay implementation six months. We conclude that a phased approach is reasonable, particularly because we are using the same PAs from the general market CSI program who can apply the lessons learned in implementing that program to speed implementation of CSI Thermal.
Rather, we will give the PAs until April 1, 2010 to jointly submit the CSI Thermal Program Handbook by advice letter to Energy Division. The PAs are directed to use the CSI Thermal Program Handbook outline set forth in Appendix A as the basis for developing the handbook, which should be a subset, or chapter within, the general market CSI Handbook. To facilitate development of the handbook and the incentive calculation tool, Energy Division shall hold workshops, as described in this decision, within 60 days of this order.
We adopt a phased implementation of this program as follows:
· Within 60 days from the effective date of this decision, Energy Division shall hold workshops to assist the PAs in developing siting, installation, freeze protection and system sizing requirements to guard against oversizing of systems, appropriate energy efficiency improvements that meet the criteria specified in this decision, and an incentive calculation tool.
· By April 1, 2010, the PAs shall complete development of the on-line incentive calculation tool and provide it to Energy Division for review prior to program implementation.
· By April, 2010, the PAs shall complete drafting of the single-family residential customer portion of the CSI Thermal Program Handbook, which shall be a subset of the general market CSI Handbook, containing program rules and specifications applicable to residential customers, and submit it through an Advice Letter, with the goal of accepting applications from single-family residential customers on May 1, 2010.
· By April 1, 2010, each PA shall submit a separate Advice Letter that includes: a) a detailed estimate of its program budget for the first year of program implementation, indicating direct and indirect expenses, labor and non-labor, for incentives, administration, market facilitation, and measurement and evaluation; and b) its proposed market facilitation strategic plan and detailed budget for the first two years of program implementation.
· By May 1, 2010, the PAs shall complete drafting of the commercial/multifamily portion of the CSI Thermal Program Handbook, which shall be a subset of the general market CSI Handbook, and submit it as an Advice Letter, with the goal of accepting applications from these customers on June 1, 2010.
· Within 180 days from the effective date of this decision, Energy Division shall hold a workshop on the issue of the eligibility of non-solar water heating solar thermal technologies that displace gas usage and meet all other program requirements. The workshop should address how to estimate these technologies thermal displacement for incentive calculation purposes and whether performance-based incentives might be appropriate for these technologies. Following the workshop, Energy Division should provide a workshop report to the service list of this proceeding, or its successor proceeding, and the Administrative Law Judge.
· Within 90 days of this decision, PG&E, SCE, SDG&E and SoCalGas shall each file an advice letter to amend their preliminary statements and establish a memorandum account to track actual annual expenditures for the gas-displacing CSI Thermal program, beginning on the effective date of this decision through December 31, 2017.
· On an ongoing basis, in response to program experience and evaluation, or when a Commission decision or statutory change requires handbook updates, the PAs shall submit CSI Thermal Program Handbook changes through the advice letter process.
Although applications will not be accepted until May 2010 for single-family residential customers and June 1, 2010 for commercial customers, we hope to reduce any potential disruption in the SWH market by adopting staff's proposal to allow systems installed after the July 15, 2009 release of the Staff Proposal to be eligible for incentives if they meet all program eligibility requirements set forth in this decision. CALSEIA requests clarification that a system installed in 2009 could qualify if it meets all program eligibility criteria and obtained a building permit after July 15, 2009. We agree with this clarification and will adopt it.
CCSE notes the potential overlap of its SWH pilot with eligibility for incentives under a statewide program as early as July 15, 2009. CCSE proposes the Commission allow customers who apply for incentives from the SWH Pilot Program between July 15, 2009 and December 31, 2009 to receive any higher incentive offered by the CSI Thermal Program when incentives become available after January 2010. We agree with this approach and will adopt it.