9. Program Evaluation and Milestones

As part of its evaluation plan, Staff proposed program milestones, reporting requirements, and evaluation criteria. The proposed milestones center around implementation of the MASH program within four months from the date of the Commission order approving the program, a goal of 50 completed affordable housing solar installations funded by MASH by 2012, and outreach to the target affordable housing community by 2010. For reporting, Staff proposes both ongoing reporting by Program Administrators, where Program Administrators would submit quarterly progress reports to the Energy Division, and biennial evaluations where Energy Division would select an independent evaluator through a Request for Proposal (RFP) process. Staff proposes evaluation criteria for both quarterly reports from the Program Administrators to Energy Division, and for the evaluation performed by an independent evaluator. Finally, Staff proposes that the Program Administrators be required to integrate data from the MASH program into the general market CSI database, and make the data available to Energy Division and the public as appropriate.

There were few comments on this area of the Staff Proposal. SCE supports the Staff Proposal for evaluation and milestones, while PG&E recommends a time frame longer than four months for program implementation.

We will adopt a modified version of the Staff recommendations for Program Evaluation, as set forth in Appendix A of this order. First, with regard to program milestones, we will adopt the four-month implementation timeline proposed by Staff, with the exception that more time may be needed for full implementation of VNM. We have chosen the general market CSI Program Administrators to run the MASH program based on our understanding that they would be able to implement this program quickly, building on their existing administrative infrastructure. In our view, the Program Administrators should be able to provide applications for Track 1 incentives to the public and create a statewide application for Track 2 incentive proposals, within four months of this order. As more time may be needed for full implementation of VNM, we do not include it in the four-month expectation.

Second, we adopt Staff's reporting and evaluation recommendations, which include regular progress reports and biennial independent evaluations. The Program Administrators shall submit semi-annual progress reports to the Director of Energy Division, as set forth in Appendix A. Third, we adopt the evaluation criteria and process in the Staff Proposal. Energy Division will select an independent evaluator every two years to review the program as set forth in Appendix A. The Energy Division will select the evaluator through an RFP process and will direct one of the utilities to enter into contract with the evaluator. A co-funding agreement between the utilities shall address an arrangement between the contracting utility and the other utilities to pay for this evaluation from each utility's CSI MASH program funds.

In addition to the evaluation factors set forth in Appendix A, the evaluation should compare program participation levels within Track 1A and 1B and Track 2 to assess whether the incentive levels and budget allocations are appropriate for each incentive track.

With regard to program data, we will require the Program Administrators to add all projects that apply for Track 1 incentives to the public CSI database. Program administrators shall separately monitor and track data regarding Track 2 projects.

Finally, we will require the Program Administrators to submit to an annual audit of program expenditures. The purpose of this audit is to ensure program funds are paid to legitimate and verified installations of solar energy systems on qualifying affordable housing properties, as defined in § 2852, and that administrative funds, including VNM implementation expenses, are spent in a reasonable and appropriate manner. Energy Division should ensure that each Program Administrator submits to an audit annually, which it forwards to the Energy Division Director on an annual basis beginning one year after the first MASH applications are available.