12. Comments on Proposed Decision

The proposed decision of Commissioner Michael R. Peevey in this matter was mailed to the parties in accordance with § 311 of the Public Utilities Code and comments were allowed under Rule 14.3 of the Commission's Rules of Practice and Procedure. Comments were filed on September 29, 2008 by A WISH, CCSE, LISC/NHA, PG&E, SCE, and SDG&E. Reply comments were filed on October 6, 2008 by CCSE, Ecoplexus, the Interstate Renewable Energy Council (IREC), PG&E, SCE, and SDG&E. Where the comments suggested minor adjustments or clarifications to the decision, these clarifications and adjustments have been incorporated throughout. Where comments reargued earlier positions or present new arguments or facts, they were not considered.

A few comments merit discussion. A WISH expresses concern that MASH incentive recipients might be required to take service on TOU tariffs. The decision has been revised to reflect the fact that recent legislation modified the Pub. Util. Code with regard to TOU tariffs for solar incentive recipients. Thus, A WISH's concerns are now moot.

The utilities and CCSE raise several concerns with regard to cost recovery to implement VNM. PG&E and SCE request a larger administrative budget to cover these costs. CCSE suggests that if the Commission considers making VNM available to all multitenant properties, not just affordable housing, the cost of developing VNM should be borne by the entire CSI program and not limited to the MASH program. The decision has been revised to allow cost recovery for VNM implementation expenses through the general market CSI administrative budget.

PG&E and SDG&E raise several concerns with what they consider implementation complexities of VNM. Based on PG&E's comments, the decision has been revised to clarify that a building owner/manager will bear the costs for any additional meter necessary for VNM. The other questions raised by PG&E and SDG&E, including but not limited to issues surrounding the annual net metering true-ups, unoccupied units, and VNM credits to non-low income building tenants, are all questions that we delegate to Energy Division to resolve in its review of the utilities' advice letter filings for VNM.

LISC/NHA request the Commission modify the definition of "direct tenant benefits" to include expanded services that a building owner could offer to building residents, such as community service referrals, financial literacy training, and after school programs. We will not adopt an expanded definition at this time because we prefer tenant benefits funded through MASH to be focused on reducing a consumer's electricity bill or reducing energy usage, in keeping with our stated MASH program goals. In addition, LISC/NHA request MASH program implementation by January 1, 2009. We find that the timelines set in this decision for program implementation are reasonable and we will not shorten them.

Previous PageTop Of PageNext PageGo To First Page