Comments on Proposed Decision

The proposed decision of Commissioner Peevey in this matter was mailed to the parties in accordance with Section 311 of the Public Utilities Code and Rule 14.2(a) of the Commission's Rules of Practice and Procedure.

The following parties filed comments (by July 16, 2007) or reply comments (by July 23, 2007): California Center for Sustainable Energy (formerly known as San Diego Regional Energy Office), Fat Spaniel Technologies, Inc., San Diego Gas & Electric, and Joint Parties. Based on the comments, we make the following modifications to the proposed decision. We also make minor modifications to improve the discussion or correct typographical errors.

Assignment of Proceeding

President Michael R. Peevey is the assigned Commissioner and Dorothy J. Duda is the assigned Administrative Law Judge for this portion of this proceeding.

Findings of Fact

1. The petition to modify calls into question the cost data on which the Commission based its decision to require all customers with systems of greater than 10 kW to install meters with +/- 2% accuracy for participants.

2. The petition to modify demonstrates that the cost of meeting the metering communication and reporting requirements for most systems participating in the CSI under the EPBB will likely exceed the cost caps adopted in D.06-08-028.

Conclusions of Law

1. It is reasonable to reduce metering requirements for EPBB incentives, which are paid on an upfront, lump sum basis, while maintaining and enhancing metering accuracy requirements for participants in the PBI Program, where incentive payments are based on metered system output.

2. D.06-08-028 should be modified to allow EPBB program participants to use meters that are accurate to within +/- 5% of actual system output.

3. D.06-08-028 should be modified to remove the cost cap for metering, communications, and reporting services for all systems receiving incentives under the PBI.

4. Conforming changes should be made to the California Solar Handbook.

5. The duplicative petition filed by PV Powered Inc., should be summarily denied.

ORDER

IT IS ORDERED that:

1. Decision (D.) 06-08-028 is modified as follows: (new text is shown in underline and deleted text in strikethrough).

a. Revised Table 9 - Modified CSI Metering and Monitoring Rules




Incentive Type




System Size



Minimum Meter Accuracy

Performance Communication and Reporting Requirement




Cost Cap

EPBB

< 10 kW

+/- 5%

Yes

    1%

EPBB

10 kW to 30 kW

+/- 5%

Yes

    1%

EPBB

30 kW and greater

+/- 5%

Yes

    .5%

         

PBI

< 10 kW

+/- 2%

Yes

No Cost Cap

PBI

10 kW to 30 kW

+/- 2%

Yes

No Cost Cap

PBI

30 kW and greater

+/- 2%

Yes

No Cost Cap

b. Conclusion of Law 41 - Meters with accuracy within +/- 5% of actual system output 2% for systems, 10 kW and larger will not add a significant cost burden to systems receiving CSI incentives under the Expected Performance Based Buydown (EPBB). CSI participants.

c. Conclusion of Law 42 - All systems paid incentives through under the CSI should install a solar production meter with either 2% or 5% accuracy depending on system size accurate to within 5% of actual system output for systems paid incentives under the EPBB, and accurate to within 2% for systems paid under the Performance Based Incentive (PBI), at the customer's expense, and that includes some form of communications and reporting capability.

d. Ordering Paragraph 16 All solar projects that receive an incentive through the CSI program shall install at a minimum a separate solar production meter accurate to within +/- 5% for systems under 10 kW receiving CSI incentives under the Expected Performance Based Buydown (EPBB) and accurate to within
+/-
2% for systems 10 kW and larger receiving incentives under the PBI, as set forth in Table 9 of this order. Inverter-integrated Internal meters certified as accurate to within +/- 5% are acceptable for all EPBB projects under 10 kW. All solar production meters shall be equipped with communication reporting capability, as set forth in Section V. For systems receiving incentives under the EPBB Systems 100 kW and larger must have reporting capabilities before receiving PBI payments, and systems below 100 kW shall have reporting capabilities as soon as protocols are established through the CSI Handbook process. the total cost of a customer's metering, communication, and reporting system for the first five years of solar production shall be less than 1% of total installed costs for systems up to 30 kW, and less than 0.5% for larger systems.

2. Conforming changes consistent with this decision shall also be incorporated into the California Solar Initiative (CSI) Handbook.

3. Within six months of the date of this decision, the metering subcommittee reporting to the program administrators shall investigate and develop a plan to ensure the accuracy level of +/- 5% meters used to report output from systems receiving CSI incentives under the EPBB program.

4. In coordination with the metering subcommittee and with direction from the Energy Division, the Program Administrators shall develop a research plan to assess the metering, monitoring and reporting market and will retain an independent third-party to conduct this study.

5. The Pacific Gas and Electric Company, Southern California Edison Company, and San Diego Gas & Electric Company and its program administrator, the California Center for Sustainable Energy, formerly known as the San Diego Regional Energy Office, shall cooperate in implementing these changes.

6. All changes adopted herein will apply to all open applications on the effective date of this decision. That is, any CSI application that has not received an incentive payment as of the effective date of this decision will be subject to the changes adopted in this decision.

7. The petition to modify filed by PV Powered Inc. is summarily denied.

This order is effective today.

Dated July 26, 2007, at San Francisco, California.

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