Comments on Petition
Comments on the petition were filed on April 24, 2008 by the City and County of San Francisco (CCSF), Community Environmental Council (the Council), the Commission's Division of Ratepayer Advocates (DRA), PG&E, SCE, and jointly by SDG&E/SoCalGas.
CCSF and the Council support the petition, with CCSF stating that San Francisco has different solar insulation, climactic, economic and housing stock conditions than the San Diego area, and expanding the pilot statewide could provide an early database of information to ensure sound program design under AB 1470. The Council claims expanding the pilot beyond San Diego could "jump start" solar water heating in California.
The utilities and DRA oppose the petition on several grounds. SCE and SDG&E/SoCalGas contend the request is premature because both D.06-01-024 and the ruling approving the pilot's implementation allude to statewide expansion only after review of pilot program results, with at least 12 months of information. They maintain that absent such a review, the request is premature. SCE argues the pilot's performance to date has been below its goals, indicating the pilot should be cancelled. PG&E alleges the pilot cannot be extended beyond San Diego because Section 2867.2 does not allow use of CSI funds for solar water heating to displace gas usage except for the pilot program in San Diego.5 Instead, PG&E suggests the Commission take the current pilot program results and use them to move directly to development of a program under AB 1470.
SCE and PG&E both request that if the Commission grants the petition and expands the pilot, despite their objections, it should allow SCE and PG&E, who currently administer CSI in their territories, to administer the expanded pilot in their territories as well. SCE opposes any additional funding for the pilot, or increase in residential incentives.
Several parties-namely DRA, PG&E, and SDG&E/SoCalGas-recommend coordination between programs offering solar water heating incentives and the Commission's energy efficiency and demand response programs.
On May 1, 2008, Petitioners replied to these comments, stating that the statutory constraint raised by PG&E is a legitimate concern that will need Commission interpretation. In addition, they reiterate their reasons why an expanded pilot could provide data to inform a statewide solar water heating program under AB 1470.
5 Section 2867.2 states:
"Except for the Solar Water Heating Pilot Program in San Diego, solar water heating technologies shall not be eligible for California Solar Initiative (CSI) funds, pursuant to Section 2851, unless they also displace electricity, in which case only the electricity displacing portion of the technology may be eligible under the CSI program, as determined by the Commission."
