8. Miscellaneous Comments

8.1. Transfer of Ownership/Occupant Turnover

The Staff Proposal asked parties to comment on how the Commission could address the risk that owner turnover of single-family low-income homes could result in a non-low-income owner of the solar installation funded through this program.

Upon further review, we find it unnecessary to address this issue because if a home meets the definition of low-income residential housing in Section 2852, i.e., financed with low-income housing tax credit, bonds, or government loans or grants, and subject to deed restrictions, the property by definition will be occupied by a low-income resident. Furthermore, the mainstream CSI Program Handbook requires a system owner to notify the Program Administrator in writing a minimum of 60 days prior to any change in either the site location of the PV system or ownership of the PV system during the 10-year warranty period. These notification requirements shall apply to all CSI incentive recipients, whether through the mainstream CSI program or the low-income program.

8.2. Time of Use (TOU) Pricing Requirements

Section 2851(a)(4) requires TOU pricing for all ratepayers with a solar energy system. However, Section 2851 was modified in June 2007 by AB 171422 to allow the Commission to delay implementation of TOU pricing requirements until the effective date of new TOU tariffs in the utilities' next general rate cases.

A WISH and SDG&E express concern that TOU requirements for low-income solar customers could have unintended consequences and actually increase energy costs. A WISH maintains that low-income populations will be disproportionately affected by TOU rates because they are often on fixed incomes, disabled, or home with children.23 Given the delay in implementation of TOU requirements provided by AB 1714, we do not need to address these comments at this time. Instead, as the Commission develops new TOU tariffs, it should ensure TOU impacts on low-income solar customers are considered.

8.3. Marketing and Outreach

Greenlining advocates a "solar literacy" campaign as part of the low-income solar incentive program. A WISH and SoCal Forum agree the program needs a strong education component. We agree that good solar education for all customer types, regardless of income level, is an important element of CSI. The Staff Proposal envisioned the Program Manager developing a narrowly targeted marketing and outreach program for this program, collaborating with housing agencies to find and attract eligible homeowners. We adopt the marketing and outreach recommendations in the Staff Proposal, which we set forth in Appendix A. At the same time, we reiterate our plans as part of our overall CSI program implementation to adopt a general CSI marketing and outreach plan targeted at all ratepayers, to which low-income homeowners will be exposed. Thus, we adopt a targeted marketing plan within the low-income solar program because we will address broader marketing and outreach through the mainstream CSI program, thus preserving the maximum low-income program dollars for incentives to deploy solar installations.

When the Energy Division issues the RFP for a Program Manager, it should explicitly request bidders for Program Manager to outline their plans for solar marketing and outreach. As outlined in Appendix A, any outreach program should include education on the benefits of solar technology, energy efficiency, solar financing and tax credits, and proper system maintenance. The outreach program should include a component geared to populations that are not proficient in English and persons with disabilities.

Grid Alternatives suggests the low-income incentive program should be directly coordinated with existing energy efficiency programs and utilities should share lists of past and current LIEE clients or distribute solar information in their program materials to current LIEE clients. We agree that the low-income CSI Program Manager should obtain a listing of homeowners enrolled in LIEE from each utility. Since the utilities routinely provide lists of potential LIEE participants to their LIEE contractors, there is precedent for the utilities to provide information on low-income populations to non-utility entities as long as appropriate privacy safeguards are followed.24

8.4. Consumer Protection

SCE notes that low-income populations include seniors and those on welfare who need protection from third parties seeking self-profit. SCE recommends the Commission consider protections against program and customer abuse, fraudulent behavior, and improper or flawed installations. SCE specifically suggests prohibiting third-party ownership of low-income solar installations and providing incentives only to low-income homeowners. SDG&E and DRA agree with SCE that the program should not provide incentives to third parties for solar systems on low-income homes.

We agree with SCE that it would be wise to exclude third-party ownership arrangements as part of the low-income single family incentive program until we have further experience with solar incentives to low-income homeowners or more information concerning third-party ownership arrangements for low-income homeowners. We are concerned with ensuring that any third-party ownership arrangements provide long-term benefits to low-income homeowners. In the absence of information concerning adequate protections for the homeowner, we direct that the Program Manager may only pay low-income solar incentives to a qualifying low-income homeowner who is also the system owner. We will consider modifying this order to allow third-party ownership arrangements for low-income customers if we are presented with a proposal that adequately protects and benefits low-income homeowners in third-party ownership arrangements.

8.5. Maximum System Size

DRA suggests the Commission allow an increase in maximum system size for systems funded through the low-income incentive program. DRA reasons that allowing systems up to 125% of the mainstream CSI size limit will allow surplus production that will more likely zero out the participants' annual electric bill. Many parties oppose DRA's suggestions. Grid Alternatives argues DRA's idea may cause low-income customers to install and pay for larger systems than they actually need and creates a disincentive for energy efficiency. PG&E maintains deliberate over-sizing could make customers ineligible for net metering and could exhaust the limited low-income incentive budget with fewer systems installed. We agree with PG&E and Grid Alternatives that providing rebates to over-sized low-income systems could have negative consequences and we will not adopt this suggestion.

8.6. Program Phase-In

The Staff proposal recommended commencing the program in only a few areas of each utility territory, then serving more areas over time. SCE states that a phase-in period would be unnecessary if SCE were to administer the program, because SCE has the existing infrastructure to implement the program throughout its service territory. We will not dictate an outcome on this issue, although we have set aggressive program milestones to be reached by the end of 2010. Interested respondents to the RFP for Program Manager should address their program implementation plan, either phase-in or statewide, in their bid responses. Nevertheless, we reiterate that we intend for this program to be offered to all qualifying low-income homeowners in the territories of PG&E, SCE, and SDG&E.

22 Statutes of 2007, Chapter 11.

23 We understand that SCE and PG&E currently offer optional TOU tariffs for low-income consumers who take service on CARE tariffs. SDG&E is developing a similar TOU tariff for CARE customers.

24 See D.00-07-020 where the Commission found that LIEE customer information could be provided to contractors, subject to confidentiality agreements between the utility and the contractor. (D.00-07-020, 2000 Cal. PUC LEXIS *166.)

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