4. Performance Requirements
Staff recommends that to qualify for incentives, an installation must meet a minimum performance requirement, which is .95 of the Design Factor used to calculate up-front incentive payments, known as Estimated Performance Based Buydown (EPBB) incentives, in the mainstream CSI program. The Design Factor is a reflection of a proposed system's tilt, orientation, shading, equipment efficiency, and other factors compared to an optimally-installed system.17 Staff proposes this requirement to ensure that systems are properly designed to achieve maximum benefit to the low-income homeowner and ensure program funds are used efficiently.
Grid Alternatives fears this requirement will prevent participation by homeowners in less sunny parts of the state. Grid Alternatives contends that many houses that are good candidates for solar would be eliminated from the program because they have an orientation or roof pitch slightly less then optimal. Therefore, it recommends dropping the geographic correction built into the Design Factor formula to avoid penalizing applicants based on geography. SCE opposes Grid Alternatives' suggestion to drop the geographic portion of the Design Factor formula, arguing that limited program dollars should not be spent on geographic regions that will not yield optimal system performance.
We will adopt the Staff Proposal to require a minimum performance requirement equal to .95 of the EPBB Design Factor. The overall CSI program intent is to reward high-performing systems and avoid poor installations that would disadvantage the consumer. If we require that systems meet a Design Factor of .95, this provides better assurance of high performing installations for low-income homeowners. In addition, we will remove the geographic correction from the EPBB calculation for low-income applicants, as suggested by Grid Alternatives. We will allow a well-designed system anywhere in the state that meets a Design Factor of .95 to qualify for low-income incentives without the geographic correction required for mainstream CSI applicants. In our view, if an applicant meets the eligibility criteria in Section 2852 and the other Design Factor criteria, we do not want to prevent them from receiving incentives solely based on their geographic location in the state.
Regarding other program requirements that are addressed in the mainstream CSI Program Handbook (including but not limited to warranty, insurance, metering, and interconnection), we will apply all the same program requirements to low-income applicants as to mainstream applicants, unless the Program Manager can justify to Energy Division staff why a particular requirement should be modified. If the Program Manager seeks a change in a CSI Program Handbook requirement, it should send a letter to the Director of Energy Division, with a copy to the service list of this proceeding, asking for the change. Energy Division shall resolve any requests directly with the Program Manager, unless the change requires modification of a Commission order. In that event, the party seeking the change must file a petition for modification of the relevant Commission order.18
17 See D.06-08-028, p. 44, for further explanation of the Design Factor.
18 See Rule 16.4 of the Commission's Rules of Practice and Procedure.
