9. Comments on Proposed Decision

The proposed decision of the Commissioner in this matter was mailed to the parties in accordance with Section 311 of the Public Utilities Code and comments were allowed under Rule 14.3 of the Commission's Rules of Practice and Procedure. Comments on the proposed decision were filed by CCSE, Everyday Energy, IREC, Grid Alternatives, PG&E, SCE, SDG&E, the Solar Alliance, SolarCity, Recolte, and the Vote Solar Initiative. Reply comments were filed by CCSE, Grid Alternatives, PG&E, Recolte, SCE, SDG&E, and the Solar Alliance. In addition, the ALJ received letters from Del Mesa Carmel, Eden Housing, Skyline Solar, Inc. (Skyline Solar), and Sustainable Napa County. These letters were placed in the correspondence file of this proceeding. Minor corrections and clarifications in response to comments are incorporated throughout the decision. Where comments reargued earlier positions, they were ignored. A few comments merit discussion.

The utilities oppose expansion of the RES-BCT tariff beyond local governments, arguing that an expansion shifts costs to other bundled customers. We agree that further study of the underlying costs of any RES-BCT expansion deserve further scrutiny and we direct Energy Division to review this issue further.

PG&E and SDG&E requests that biogas and fuel cell projects not be eligible for VNM as these projects only qualify for a generation credit under net energy metering. We agree and have made this change.

PG&E requests additional time to perform the AMI feasibility study discussed in Section 5.4 and Ordering Paragraph 8. This request is reasonable and this change has been made. In addition, PG&E requests that Track 1A MASH incentives be reduced to $1.90 per watt to enable the PAs to fund more MASH applications. PG&E contends this lower incentive is supported by Navigant's recent study of the CSI low-income incentive programs.⁴² We find this change reasonable and will adopt it.

Skyline Solar requests that systems under 10 kW that employ tracking technology be allowed to receive PBI payments. We agree with this exemption and incorporate it into the decision.

⁴² See Navigant's "California Solar Initiative Low-Income Solar Program Evaluation Market Assessment Report," at 10. The report can be viewed at: http://www.cpuc.ca.gov/NR/rdonlyres/EB601615-61B3-43B2-B034-EEC95AF46708/0/CSISASHandMASHMarketAssessmentReport.pdf.