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 Dr. Barkovich, SCE, and jointly by CCSE and PG&E. Reply comments were filed by CALSEIA. Where the comments suggested minor adjustments or clarifications to the decision, these changes have been incorporated. Where comments reargued or presented new arguments or facts, they were not considered.

A few comments merit discussion. SCE asks the Commission to clarify whether SWH systems that displace propane count toward CSI megawatt goals. SCE cites D.10-01-022 where the Commission stated that CSI Thermal incentives to electric-displacing SWH systems should count against Step 10 of the general market CSI program. The decision has been modified to clarify that incentives to propane-displacing systems should count against Step 10 of the general market CSI program, identical to treatment of electric-displacing incentives in D.10-01-022. It is unclear from SCE's comments how incentives provided to propane-displacing systems would be translated into progress toward CSI MW goals. The Commission's Energy Division should explore with the CSI PAs how to report progress toward CSI MW goals for the funds used for SWH systems.

CCSE and PG&E ask for an additional 30 days beyond approval of their Tier 2 advice letter to fully implement the changes ordered in this decision. This request is reasonable and is adopted.