Comments on Proposed Decision

The proposed decision in this matter was mailed to the parties in accordance with Section 311 and comments were allowed under Rule 14.3 of the Commission's Rules of Practice and Procedure. Comments were filed by CALSEIA and jointly by the CSI Thermal PAs, namely PG&E, SCE, SoCalGas and CCSE. Reply comments were filed by EchoFirst. Where the comments suggested minor adjustments or clarifications to the decision, these changes have been incorporated. Where comments introduced new arguments or facts, they were not considered.

The CSI Thermal PAs ask for three modifications to the decision. First, they request 60 days to implement the decision, and additional time beyond 60 days if IAPMO does not provide necessary documentation in a timely manner. We will leave the implementation deadline at 30 days, but provide flexibility to the ALJ to amend deadlines if warranted. Second, they request that the

Commission require IAPMO and any future certifying entities to publicly publish eligible systems data in a standard "comma-separated-value" (CSV) format. We agree that publishing of the information in a standard format is important and have added this clarification. We will not specify the CSV data format in this decision, but direct Energy Division to specify the data format in coordination with the CSI Thermal PAs. Finally, the CSI Thermal PAs suggest the Commission assign a third party to serve as the approving body for entities requesting to certify solar thermal systems. We decline to make this modification at this time because we have no record regarding which third party entities might be qualified or available to perform this work, and developing this information will delay the decision. It is more reasonable to give the CSI Thermal PAs the ability to hire a contractor to perform this work, when and if it should be needed, and then pass the cost of any contractor through to entities seeking approval as certifying entities.

CALSEIA comments that the terms "NRTL" and "ANSI-accredited laboratory" are used inaccurately in the decision. These entities are correctly known as "Listing Agencies" and informally described as "certification bodies." According to CALSEIA, entities operating SWH system testing laboratories do not offer product certification services. IAPMO is an ANSI-accredited Listing Agency, but is not operating as an NRTL or an ANSI-accredited laboratory. The decision has been revised accordingly to add the term "listing agency" and remove references to NRTLs as listing agencies.