VII. Energy Efficiency

In D.06-01-024, the Commission required an energy efficiency audit for existing buildings as a condition of receiving CSI incentives, and directed staff to consider requiring energy efficiency improvements in existing buildings as a condition of solar incentive payments. In April 2006, the Energy Division's Staff Proposal recommended the Commission adhere to its earlier audit requirements and not require CSI incentive recipients to make energy efficiency improvements at this time. Staff suggested assessing experience with this approach and resulting energy efficiency improvements before requiring energy efficiency improvements in future years. In response, parties filed comments in May 2006 on whether the Commission should require efficiency improvements and the details of how energy audits should be handled as a precondition of receiving solar incentives.

Before the Commission could decide the issue of whether to require energy efficiency improvements, SB 1 was signed adding Section 2851(a)(2)(c)(3), which provides that:

By January 1, 2008, the commission, in consultation with the State Energy Resources Conservation and Development Commission, shall require reasonable and cost-effective energy efficiency improvements in existing buildings as a condition of providing incentives for eligible solar energy systems, with appropriate exemptions or limitations to accommodate the limited financial resources of low-income residential housing.

Given the language in SB 1 linking incentive payments to the requirement to make energy efficiency improvements, the Commission will need to work closely with the CEC to reflect these energy efficiency requirements in the CSI program as of January 2008. In the meantime, this decision clarifies the interim energy efficiency audit and efficiency standard requirements as a condition of receiving solar incentives in 2007, until reasonable and cost-effective energy efficiency improvements and exemptions for low-income residential housing are identified in consultation with the CEC, in compliance with SB 1.

Interim Audit Requirements

In April 2006, the Staff Proposal recommended maintaining the audit requirement for existing structures, with the clarification that an audit should both establish an efficiency baseline and educate the applicant regarding the economic benefits of efficiency improvements. Staff recommended simplifying the audit requirement by exempting any existing home or building already certified as energy efficient as demonstrated by the U.S. Green Building Council's Leadership in Energy & Environmental Design (LEED) designation or U.S. Department of Energy/U.S. Environmental Protection Agency "Energy Star" certification, as well as those having had an acceptable energy audit report during the past three years. In comments in May 2006, parties agreed with Staff's recommendations to allow exemptions from audits for structures recently certified as energy efficient.

Therefore, we find that applicants shall obtain energy efficiency audits for existing structures. These may be provided by any of the variety of methods offered by ratepayer-supported utility efficiency programs or from a non-utility provider. If a customer obtains an audit from a non-utility provider, this will be at the customer's expense. We adopt Staff's recommendations to exempt applicants from the audit requirement under any of the following circumstances:

We find this interim audit requirement reasonably links efficiency and solar investments together, a view supported by virtually unanimous party comments.

Interim Audit Protocols, Documentation, and Certification

Next, we address what constitutes acceptable energy audit protocols, auditor certification, and documentation requirements. In April 2006, the Staff Proposal recommended that acceptable energy audits include online, telephone, or onsite audits offered through utility programs, and in the event such programs cannot accommodate all customers seeking solar incentives, non-utility audits as well. Staff asked parties to comment regarding what audit protocol and auditor certification should be accepted for non-utility audits. Further, Staff indicated that to ensure customer awareness of applicable energy-related improvements before making a decision on a solar facility, customers should be required to submit a copy of the audit results as part of the solar incentive application.

In comments in May 2006, SCE, SDG&E/SoCalGas and Division of Ratepayer Advocates indicate that the existing utility on-line and telephone audit protocols should be the standard for any non-utility providers. PG&E advocates that the audit should look at those measures now required by Title 24 standards, which typically apply to new construction or major building renovations. SCE further states that non-utility audit providers should be registered with the Commission. ASPv, presumably expecting non-utility audits would be used at additional expense to customers, recommended that additional solar rebates be given to cover such audit expenses, citing the example of a New Jersey program that does so.

In the case of residential audits, we accept the recommendation of several of the utilities to use the existing audit protocols for on-line or telephone audits. For non-residential structures, we are not sure if these simplified approaches are warranted, or if a more customized, site-specific approach is necessary. We also appreciate the recommendation from SDG&E/SoCalGas and SCE that non-utility audit providers should be subject to both a standard audit protocol, as well as certification they have appropriate training and knowledge. Thus, we direct the CSI Handbook development group to work with the program administrators to establish an appropriate non-residential energy audit protocol, and acceptable auditor/provider certification standards. The protocol should achieve a quality of audit commensurate with the utility programs. We do not adopt the suggestion that the Commission take the step of registering auditors. We expect there are existing state or national certification programs such as those used for Title 24 compliance, or from recognized educational institutions and professional and trade organizations that might be found suitable.

With regard to documentation requirements, we expect the application for existing structures to include a copy of findings from acceptable audit protocols, or evidence of meeting one of the exemption cases. For new construction, we believe Title 24 compliance documents are generally accepted proof of satisfying state building efficiency standards. We direct the CSI Handbook development group to identify acceptable compliance documentation and to include the recommended approach in the CSI program handbook.

Previous PageTop Of PageNext PageGo To First Page