3. Pacificorp's Proposed Program

Based on the success of the Commission's CSI Program, and in response to requests from its customers, Pacificorp proposes a solar incentive program to provide rebate payments to customers that install solar photovoltaic systems on their premises. Pacificorp's application recommends a total program budget of $8.168 million to fund up-front solar incentives for residential, commercial, industrial and irrigation customers that would be based on expected performance of the solar energy system. Incentives would start at $2.80 per watt and decline in seven steps to $1.80 per watt. Incentives would decline based on capacity limits in each step, with a total program capacity of 3.3 megawatts (MW). Pacificorp issued a request for proposals (RFP) for a program administrator, and subsequently contracted with the California Center for Sustainable Energy (CCSE) to administer the program.

In response to Pacificorp's application, DRA offers several suggestions it contends will ensure Pacificorp's customers benefit from the Commission's experience with the CSI Program. DRA suggests the Commission require the Pacificorp solar program to be consistent with the CSI and with the California Energy Commission (CEC) guidelines for ratepayer funded solar incentive programs in California, per Public Resources Code Section 25784. DRA recommends the Commission review detailed program requirements, such as program eligibility, the application process, metering requirements, and program evaluation before approving Pacificorp's proposed program, and DRA suggests further consideration of low income program and energy efficiency requirements, performance-based incentives, and incentive levels.

Ongoing discussions between the parties led to Pacificorp and DRA filing a Joint Stipulation on August 2, where they described their numerous areas of agreement on program design and a shorter, four-year program duration. They also describe three critical areas of disagreement, namely the starting incentive rate, the rate of incentive decline, and the total program budget.

In a late-filed response, the Siskiyou Parties oppose the changes to the original application contained in Pacificorp's supplemental filing and the Joint Stipulation with DRA. Specifically, the Siskiyou Parties oppose reductions in incentive levels and reductions in the program budget and duration because these changes could reduce the potential benefits of the program to local residents by discouraging solar development in the county and decreasing green job opportunities. The Siskiyou Parties urge the Commission to approve the Pacificorp application as originally filed, along with a condition that the program be transitioned to administration by a qualified local entity.

DRA opposes the Siskiyou Parties' recommendations because DRA seeks to limit the burden on ratepayers who will fund the program. DRA maintains that its stipulation with Pacificorp seeks to balance the goals of encouraging a solar program in the Pacificorp territory, while reducing the costs to ratepayers of implementing the program.