Parties' Comments

Responses to the petition were filed by the California Solar Energy Industries Association (CALSEIA), the Commission's Division or Ratepayer Advocates (DRA), and jointly by Southern California Edison Company, Pacific Gas and Electric Company, Southern California Gas Company, and the California Center for Sustainable Energy (collectively, the CSI Thermal Program Administrators, or PAs).

DRA and CALSEIA support the petition. DRA agrees with EchoFirst that there is no valid public policy reason to confer monopoly status on SRCC, which could have the unintended consequence of slowing down market acceptance of SWH systems. DRA maintains that a competitive market for certification services has worked well in other industries, such as the photovoltaic industry, and can provide timelier certification of qualifying projects. CALSEIA supports the petition and emphasizes that all SWH systems should be certified to a single standard, which is critical for estimating system performance and assigning incentive values through the CSI Thermal Program. CALSEIA urges that the Petition should not preclude continued certification by SRCC.

The CSI Thermal PAs support the Petition to allow SWH systems certified by IAPMO to be eligible for CSI Thermal incentives given the evidence submitted by EchoFirst regarding IAPMO as a certifying body accredited by ANSI. The CSI Thermal PAs do not agree, however, with the portion of EchoFirst's petition that would allow any NRTL or ANSI-accredited laboratory to certify SWH systems, unless the entity is specifically approved by the Commission. Thus, the CSI Thermal PAs would limit modification of D.10-01-022 at this time and only allow the addition of IAPMO as a certifying entity. EchoFirst does not object to the CSI Thermal PAs' suggestion that further Commission review and approval should be required before allowing additional NRTL or ANSI accredited laboratories, beyond IAPMO, to certify SWH systems.

In addition, the CSI Thermal PAs allege that various administrative, technical, and programmatic changes are necessary if IAPMO is accepted as a certifying entity. The PAs request 90 calendar days for implementation of program changes if the Petition is granted. EchoFirst counters that a maximum of 30 days should be sufficient to implement certification by IAPMO, contending that the CSI Thermal PAs need only upload basic certification data comprising 16 data fields if IAPMO becomes a certifying entity.