7. Fuel Displacement Type

Several parties, namely ACCES, CALSEIA, Environment California, and SDG&E/SoCalGas, recommended that the Commission allow low-income single-family customers with electric-displacing SWH systems to apply for CSI Thermal incentives. CCSE opposes the idea.

We decline to adopt this recommendation because we do not find it appropriate for funds collected from natural gas ratepayers to be used to fund incentives for electricity-displacement. Moreover, it is not appropriate to use funds from the electric-displacing budget of CSI Thermal, which derive from the CSI General Market budget, for low-income SWH incentives as the CSI General Market budget is currently almost depleted. In addition, low-income electric ratepayers can take advantage of solar PV incentives through the existing CSI SASH and MASH programs.