6. Energy Efficiency
With regards to energy efficiency requirements, Section 2851(a)(3) directs the Commission, in consultation with the CEC, to require "reasonable and cost-effective energy efficiency improvements" as a condition of receiving solar incentives, although it allows "appropriate exemptions or limitations to accommodate the limited financial resources of low-income residential housing." The CEC is currently considering what energy efficiency improvements should be required as a condition of receiving solar incentives through the mainstream CSI program. In the interim, the Commission requires mainstream CSI applicants to complete an energy efficiency audit.
For the low-income solar program, Staff recommends all low-income solar incentive applicants complete an energy efficiency audit as part of their application. As in the mainstream CSI program, the applicant may obtain an audit through the variety of free methods offered by utility efficiency programs or from a non-utility provider at the customer's expense. Staff also recommends that if the household is eligible for LIEE and is not enrolled, it must enroll within one year of receiving a solar rebate. Based on audit results, the Program Manager would determine which energy efficiency measures must be undertaken and the appropriate size of the system eligible for incentives. If an applicant is eligible for LIEE, measures will be undertaken through that program. If a household is not eligible for LIEE, the applicant will be required to pay for low-cost energy efficiency measures. The Program Manager will work with the applicant to determine what energy efficiency measures are feasible and affordable. Staff recommends that the Program Manager require implementation of all identified energy efficiency measures that have up to a two-year payback. The maximum system size that can receive incentives would be based on an estimate of the household's annual load assuming all weatherization and energy efficiency measures with a two-year payback or less are undertaken.
Several parties, namely Grid Alternatives, A WISH, SDG&E, SCE, PG&E, SoCal Forum, and CSD, comment that applicants should be required to enroll in LIEE and install energy efficiency measures before they receive any solar incentives.
6.1. Discussion
Given that Section 2851(a)(3) allows exemptions from otherwise applicable energy efficiency requirements for low-income housing, we find that Staff's recommendations are generally reasonable and appropriate given the limited financial resources of low-income homeowners. An audit requirement should assist customers and the Program Manager to compare the costs of a solar installation against the estimated savings from energy efficiency improvements, and allow the Program Manager to determine the size of system that should receive incentives. The audit should prevent low-income incentive dollars from being used to fund oversized systems serving energy inefficient households. As PG&E noted, "right-sizing" PV systems means the limited budget for low-income solar incentives can reach as many qualifying customers as possible.
Therefore, we adopt the following energy efficiency requirements for the low-income solar program:
· Applicants must enroll in LIEE, if eligible, and have all feasible LIEE measure installed prior to receiving a solar incentive.20
· Applicants must include an energy efficiency audit with their incentive application. The audit can be performed through LIEE, if applicant is eligible, or under the same requirements for audits in the mainstream CSI program.
· The Program Manager will review the audit along with the application to determine the maximum system size that can receive an incentive through the low-income incentive program.21 The maximum system size that can receive low-income solar incentives should be based on customer usage, adjusted based on an estimate of energy savings resulting from either:
o installation of all feasible LIEE measures (for those applicants who qualify), or
o for applicants who do not qualify for LIEE, installation of all feasible measures that would be covered if they were LIEE eligible. While installation is not required, the Program Manager should assist the applicant to obtain financing for potential installation of energy efficiency measures identified by the applicant's audit along with the solar energy system.
The Program Manager should coordinate with utility LIEE programs wherever possible to identify qualifying low-income homeowners and ensure qualifying households receive LIEE benefits along with solar incentives. We direct our Energy Division to explore methods to expedite LIEE measure installation for low-income solar incentive applicants, to avoid LIEE installation delays from deterring low-income solar applicants.
20 If the LIEE program has an installation backlog, solar applicants must be on the waiting list for installation.
21 For example, if an audit determines energy efficiency improvements, funded through either LIEE or applicant's resources, could reduce the low-income applicant's consumption and that a 1.5 kW solar system would be adequate to serve the applicant's efficient load, the maximum system size that could receive an incentive would be 1.5 kW.
