Assignment of Proceeding

Michael R. Peevey is the assigned Commissioner and Dorothy J. Duda is the assigned Administrative Law Judge in this proceeding.

Findings of Fact

1. Section 2864 requires SWH systems to have SRCC OG-300 or OG-100 certification to receive rebate funding.

2. D.10-01-022 states that the Commission will only authorize SWH incentives for systems that have SRCC certification.

3. Commission Staff and the CSI Thermal PAs have interpreted Section 2864 and D.10-01-022 to mean that only SRCC may certify equipment to the OG-300 and OG-100 standards.

4. The U.S. EPA, the Salt River Project Agricultural Improvement and Power District, and the Arizona Corporation Commission recognize IAPMO certification of SWHs to the SRCC OG-300 standard.

5. EchoFirst did not file its petition within one year of D.10-01-022 because it did not realize the Commission would not accept SRCC certification performed by entities other than SRCC until April 2011.

Conclusions of Law

1. It is reasonable to distinguish the SRCC standards from the certification entities that apply those standards.

2. IAPMO is qualified to certify SWH systems to SRCC standards.

3. The Commission should modify D.10-01-022 to accept certification performed by IAPMO or any ANSI-accredited listing agency, if approved by the CSI Thermal PAs.

4. The CSI Thermal PAs may require entities seeking certification eligibility to provide detailed computer modeling results, system design schematics and a publicly-available list of data fields in a standard format, as specified by Energy Division.

5. When SWH systems have SRCC ratings from two or more certifying entities, the CSI Thermal Program should accept only the lowest rating.

6. The CSI Thermal PAs shall charge the entity seeking acceptance of SRCC certifications for any costs to review such requests, after first receiving approval from the Energy Division Director for the pass-through of these costs.

7. The Commission should allow the CSI Thermal PAs to file a Tier 2 advice letter to suspend accepting certifications from a particular listing agency other than SRCC if the ratings differ significantly from those provided by SRCC, if information necessary to administer the CSI Thermal Program is not provided, or if the PAs find the certifications are in any other way deficient.

8. A maximum of 30 days should be sufficient to implement acceptance of SRCC certification by IAPMO, assuming IAPMO provides all required documentation and data inputs to the PAs in a timely manner.

9. EchoFirst's petition should be considered although it was filed more than a year after the Commission issued D.10-01-022.

ORDER

IT IS ORDERED that:

1. The petition of EchoFirst filed on July 18, 2011 is granted in part.

2. Decision 10-01-022, which established the California Solar Initiative Thermal Program to provide solar water heating incentives, is modified as set forth in Appendix A.

3. Within 30 days of the effective date of this decision, the California Solar Initiative Thermal Program Administrators (namely Pacific Gas and Electric Company, Southern California Edison Company, Southern California Gas Company, and the California Center for Sustainable Energy) shall accept Solar Rating and Certification Corporation certification performed by the International Association of Plumbing and Mechanical Officials.

4. The California Solar Initiative Thermal Program Administrators (CSI Thermal PAs, namely Pacific Gas and Electric Company, Southern California Edison Company, Southern California Gas Company, and the California Center for Sustainable Energy) may consider requests from program participants to accept Solar Rating and Certification Corporation certifications performed by an American National Standards Institute accredited listing agency.

5. The California Solar Initiative Thermal Program Administrators (namely Pacific Gas and Electric Company, Southern California Edison Company, Southern California Gas Company, and the California Center for Sustainable Energy) shall pass-through costs incurred to review requests for acceptance of Solar Rating and Certification Corporation certification onto the entity seeking such acceptance, after first obtaining review and approval from the Energy Division Director.

6. The California Solar Initiative (CSI) Thermal Program Administrators (namely Pacific Gas and Electric Company, Southern California Edison Company, Southern California Gas Company, and the California Center for Sustainable Energy) may file a Tier 2 advice letter to suspend accepting certifications from a particular listing agency other than the Solar Rating and Certification Corporation (SRCC) if the ratings differ significantly from those provided by SRCC, if information necessary to administer the CSI Thermal Program is not provided, or if the certifications are in any other way deficient.

7. The Administrative Law Judge may modify the compliance dates set forth in this order for good cause and as needed to ensure effective program implementation.

8. This proceeding remains open for consideration of additional issue as set forth in the Scoping Memo Ruling dated November 9, 2010.

This order is effective today.

Dated November 10, 2011, at San Francisco, California.

Appendix A

Modifications to Decision 10-01-022

1) The last sentence of the first paragraph on p. 27 of D.10-01-022 is modified to state (new text is underlined):

2) The first bullet point under the heading "Eligibility" on page 4 of Appendix A is modified as follows (new text is underlined):

(End of Appendix A)

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