Responses to Ruling

The responses generally support the concept of a reduction in solar incentives to $2.50/watt, but they disagree with critical elements of implementing the reduction. For example, several commentors request that the Commission not apply the incentive reduction to any project that had already submitted an application as of the date of the ruling. They ask that all applications received up to the date of the ruling, which total 91 MW in capacity, receive the higher $2.80/watt incentive. Others request the Commission provide 30 day or more advance notice of incentive reductions. Several parties explain they assumed the trigger mechanism adopted in D.06-01-024 applied only to the CSI beginning in 2007 and not to the SGIP program in 2006. Others suggest that a trigger mechanism should not be applied statewide, but should apply by utility service territory. Thus, if one utility had fewer applications and had not reserved its allocation of CSI funds, it should continue to pay a higher incentive level.

Comments from solar industry participants generally urge the Commission to not reduce solar incentives for applications already submitted. ASPv and PV Now recommend that the 50 MW trigger should be based not on applications received, but on "confirmed reservations," which means that applicants have submitted proof of project advancement including completed interconnection forms and signed customer contracts for their projects.

Almost all commentors asked for better communication from program administrators, i.e., the utilities and SDREO, to program participants concerning the applications received. They suggest that the Commission should direct program administrators to provide web-based information concerning the MW level of incentives applied for and reserved on a more frequent basis (i.e., daily or weekly). This would provide customers and solar installers advance notice of incentive applications and reservations, sufficient to indicate when applications are approaching another MW-based reduction threshold.