Parties' Comments

Dr. Barkovich, CALSEIA, CCSE, and PG&E support the Staff Proposal. CALSEIA asserts that it is unfair for the CSI Thermal Program to exclude electric ratepayers who may use propane to heat water. CALSEIA asserts that expansion of the program to include propane-displacing systems should decrease fossil fuel combustion and help reduce greenhouse gas emissions, in keeping with California policy goals set forth in Assembly Bill (AB) 32. CALSEIA agrees with the Staff recommendation to allow customers who install SWH to use propane as a backup fuel source.

Dr. Barkovich notes in her comments that in the area of California where she resides, propane prices are tied to the price of oil and are two and half times the costs for propane listed in the Staff Proposal. She estimates that the annual cost of heating water with propane is almost $700 per year, much higher than the cost of heating water with electricity. Thus, if oil prices remain high, it would be cost-effective for her to switch to electric water heating, which runs counter to state policy preferences to reduce electricity consumption.

SCE opposes the Staff Proposal, arguing the Commission has no jurisdiction over propane gas suppliers and the Legislature has only authorized incentives for natural gas and electric-displacing SWH systems. SCE contends that providing incentives to propane-displacing SWH systems does not advance the CSI Thermal Program objectives to reduce or delay electric transmission and distribution system upgrades and reduce peak electricity demand. According to SCE, the CSI Thermal budget should be used solely to offset electricity consumption because it is the most expensive energy resource.