3. Staff Proposal for Low-Income Solar Water Heating (SWH) Incentives
As mentioned above, the July 15, 2009 Staff Proposal for a CSI Thermal SWH incentive program contained recommendations regarding SWH incentives for low-income residential housing and proposed to allocate $20 million for incentives to natural gas-displacing SWH systems on eligible low-income single-family properties.4 The Staff Proposal recommended paying eligible low-income applicants 200% of the otherwise applicable SWH incentive level.
The Staff Proposal did not recommend offering incentives to low-income applicants for electric-displacing SWH systems due to the relatively low installation rate of electric water heating in California. The Staff Proposal noted that the CSI program already funds two low-income programs for solar photovoltaic (PV) systems, the Multifamily Affordable Solar Housing (MASH) and the Single-Family Affordable Solar Homes (SASH). Similarly, the Staff Proposal did not recommend providing low-income SWH incentives to multifamily properties, noting that 30% of residents in multifamily dwellings do not pay for water heating separately from rent. Staff reasoned it would be difficult to meet the statutory requirement of Section 2866(d), which requires that low-income residents benefit from SWH systems "through reduced or lowered energy costs."
With regard to program administration, the Staff Proposal recommended that the CSI Thermal Program Administrators (PAs)5 administer the low-income SWH incentives, with the proposed $20 million in funding split among the three PAs with gas customers (i.e., all PAs except SCE) in the same proportion as the CSI Thermal program. Further, the Staff Proposal recommended that the program be available for low-income customers that participate in LIEE and meet all other income and housing eligibility guidelines for the SASH program.
Comments on the portion of the Staff Proposal pertaining to recommendations for low-income SWH incentives were filed by the Association of California Community and Energy Services (ACCES), CCSE, California Solar Energy Industries Association (CALSEIA), Ecoplexus Inc. (Ecoplexus), Environment California Research and Policy Center (Environment California), PG&E, The Utility Reform Network (TURN), S.O.L.I.D. USA, Inc. (SOLID), and jointly by SDG&E and SoCalGas (SDG&E/SoCalGas). Reply comments were filed by ACCES, SDG&E/SoCalGas, and TURN.
In addition to the parties who filed comments, two interested organizations submitted letters to staff and the Administrative Law Judge (ALJ) on the Staff Proposal with regard to low-income incentives, namely Bridge Housing Corporation and Libre Energy, Inc. These letters were reviewed and placed in the correspondence file of this proceeding.
4 See Staff Proposal, July 15, 2009, Section 4.12 at 55.
5 The CSI Thermal PAs are Pacific Gas and Electric Company (PG&E), Southern California Edison Company (SCE), Southern California Gas Company (SoCalGas) and California Center for Sustainable Energy (CCSE).
