Discussion

Upon review of the petition, we find that EchoFirst has provided adequate evidence that IAPMO is ANSI-accredited to certify solar energy products to the SRCC standards required by Section 2864 for the CSI Thermal Program. (EchoFirst Petition, Attachment 2, Exhibits B and C.) EchoFirst provided the Commission's Energy Division Staff, under a nondisclosure agreement, with access to a report by a consultant for Arizona Public Service who reviewed detailed computer modeling results comparing IAPMO product listings with the OG-300 standard. Based upon the support provided in the petition and review by Energy Division Staff, we are satisfied that IAPMO is qualified to certify SWH systems to SRCC standards.

The SRCC OG-100 and OG-300 ratings are the basis on which the CSI Thermal Program pays incentives. Therefore, we should clarify that when SWH systems have SRCC ratings from two or more certifying entities (also known as "listing agencies"), the CSI Thermal Program will accept only the lowest of the ratings, to eliminate motivation for solar equipment manufacturers to "shop around" for the highest rating.

At the same time, we agree with the CSI Thermal PAs that we should not accept certification by any NRTL or ANSI-accredited listing agency without some level of additional review. We will grant EchoFirst's petition only in part. We will allow IAPMO to be considered a qualified entity to certify equipment to SRCC standards, as required by Section 2864, but we will not extend this approval to all NRTL or ANSI-accredited laboratories. Rather, we will establish a process for the CSI Thermal PAs to consider acceptance of SRCC certification by additional ANSI-accredited listing agencies.

Specifically, CSI Thermal program participants who want acceptance of SRCC certifications rendered by entities other than SRCC and IAPMO may submit a letter to the CSI Thermal PAs requesting the CSI Thermal Program accepts these additional certifying entities. Entities seeking acceptance of the SRCC certifications they perform must be accredited by ANSI as listing agencies. The CSI Thermal PAs may require that these entities provide detailed computer modeling results and system design schematics to allow the CSI Thermal PAs to compare product listings and certification practices with SRCC OG-300 and OG-100 standards. The PAs may also require these entities to provide a publicly-available detailed list of data fields in a standard format such as the "Comma-Separated-Value" format. The Commission's Energy Division shall specify the format for such data in consultation with the CSI Thermal PAs.

The CSI Thermal PAs shall charge the entity seeking certification for any costs to review such requests, after first receiving approval from the Energy Division Director for the pass-through of these costs. We will require the CSI Thermal PAs to notify Energy Division if they accept SRCC certifications performed by additional entities, and the PAs should keep the CSI Thermal Handbook and any applicable websites updated.

While a request by letter to the CSI Thermal PAs is sufficient to seek acceptance of new listing agencies, we will require the CSI Thermal PAs to file a Tier 2 advice letter for Commission approval should they want to suspend accepting certifications from entities other than SRCC. The CSI Thermal PAs may seek such suspension should they find the SRCC ratings from entities other than SRCC differ significantly from those provided by SRCC. We find this reasonable given a statement made by the author of AB 1470, Assemblymember Huffman, in his letter to President Peevey:

It's also important to note that regardless of the entity certifying a solar water heating unit, all certification entities should produce the same test results when testing a solar water heater for eligibility against the SRCC OG-300 or OG-100 standard. (EchoFirst Petition, Attachment 2, Exhibit A; emphasis in original.)

As Huffman points out, there should not be much difference between the SRCC and other entities' test results. While a small degree of variability is expected, if differences are significant, the CSI Thermal PAs may seek Commission approval to suspend accepting certifications by IAPMO or other ANSI-accredited listing agencies. The CSI Thermal PAs may also seek Commission approval to suspend certifications if the PAs determine that the certifying entity has not provided necessary information to administer CSI Thermal incentives, including but not limited to system diagrams to inspect OG-300 systems and performance data necessary for incentive calculations, or the certifications are in any other way deficient.

Finally, we agree with EchoFirst that a maximum of 30 days should be sufficient to implement acceptance of SRCC certification by IAPMO. We will direct the CSI Thermal PAs to accept IAPMO certification to SRCC standards within 30 days of the effective date of this decision, dependent upon IAPMO providing all required documentation and data inputs to the PAs in a timely manner. We will give the ALJ flexibility to modify the compliance dates in this order.

In summary, we conclude we should modify the last sentence of the first paragraph on page 27 of D.10-01-022 to state (new text is underlined):

Therefore, we will authorize SWH incentives only for SWH systems that have been certified to SRCC standards by SRCC, by the International Association of Plumbing and Mechanical Officials (IAPMO), or by other entities approved by the CSI Thermal PAs that are accredited by the American National Standards Institute (ANSI). When SWH systems have SRCC ratings from two or more certifying entities, the CSI Thermal Program will accept only the lowest rating.

Further, it is necessary to modify Appendix A of D.10-01-022. The first bullet point under the heading "Eligibility" on page 4 of Appendix A should be modified as follows (new text is underlined):

· Energy output displacement standards. Residential SWH systems shall have Solar Rating and Certification Corporation (SRCC) OG-300 SWH system certification and solar collectors used in multifamily residential commercial or industrial water heating shall have SRCC OG-100 SWH system certification. SRCC certification may be rendered by SRCC or the International Association of Plumbing and Mechanical Officials, or any American National Standards Institute accredited listing agency, if approved by the CSI Thermal PAs. When SWH systems have SRCC ratings from two or more certifying entities, the CSI Thermal Program will accept only the lowest rating.