7. Comments on Proposed Decision

The proposed decision in this matter was mailed to the parties in accordance with § 311 of the Public Utilities Code and comments were allowed under Rule 14.3 of the Commission's Rules of Practice and Procedure. Comments were filed on October 31, 2011 by Clean Coalition and SCE, and reply comments were filed on November 7, 2011 by Clean Coalition, SCE, SunEdison LLC, and Silverado Power LLC. To the extent warranted, revisions have been incorporated into this decision to reflect the substance of these comments.

One issue raised by SCE in its opening comments is addressed here. SCE's opening comments on the proposed decision suggest an alternative CREST pricing mechanisms and claim that the current pricing mechanism is unlawful. These SCE comments are outside the scope of the issues addressed in this decision, which is narrowly focused on urgently needed CREST program changes what will facilitate project financing and qualify developers for expiring federal cash grants. The changes we adopt here to address these concerns are based on more current contract language approved by the Commission and used in current renewable programs, and are therefore appropriate updates to a program that is over three years old. SCE improperly seeks to collaterally attack Commission decisions regarding CREST pricing that are not at issue here. Consequently, we give no weight to SCE's comments on these issues.

In contrast, we find SCE's opening comments on the interconnection agreements raised by the Clean Coalition to be helpful, and we have modified the proposed decision to address them here.