3. Petition to Modify Metering and Monitoring Requirements
On March 5, 2007, the Joint Solar Parties,1 Pacific Gas and Electric Company (PG&E), San Diego Regional Energy Office (now known as the California Center for Sustainable Energy (CCSE)), and SMA America (hereinafter, collectively, the "Petitioners") filed a petition for modification of D.06-08-028 seeking changes to meter accuracy requirements and elimination of the requirement for independent performance monitoring. In D.07-07-028, the Commission addressed the meter accuracy portion of the petition and eliminated the cost cap for customers that receive PBI. In today's decision, we address the remaining portion of the petition regarding independent performance monitoring.
The Petitioners request that the Commission no longer require that solar system performance monitoring and reporting under the CSI program be provided by an independent entity, unaffiliated with solar manufacturers or installers. They argue the current independence requirement severely limits competition because there are only three PMRS vendors. Furthermore, they contend that it is unclear if these vendors qualify as unaffiliated with incentive recipients, solar manufacturers or installers. They note that the current PMRS vendors may rely on solar vendors, installers, and integrators to sell their products and services, calling into question their independence.
The Petitioners argue that the Commission should allow any PMRS vendor listed with the California Energy Commission (CEC), including those affiliated with solar manufacturers and vendors, installers, and integrators, to provide PMRS services. They claim the quality of data monitored and reported by non-independent PMRS providers can be verified through the CSI program's Measurement and Evaluation process. They also argue that the independence requirement is limiting choice for PMRS providers, and as a result is keeping PMRS costs artificially high. Thus, they claim the independence requirement does not adequately protect solar customers.
Responses to the petition were filed jointly by Fat Spaniel Technologies (FST) and Energy Recommerce Inc. (Energy Recommerce),2 Southern California Edison Company (SCE), the Consumer Federation of California (CFC), KACO Solar Inc. (KACO), and PVI Solutions, Inc.
PVI Solutions, Inc. and KACO support the proposed modification, claiming it will allow greater competition among PMRS providers and innovation through integration of PMRS with solar installations. They concur with Petitioners that random sampling of PMRS providers should ensure the provision of quality data.
CFC, SCE, and FST/Energy Recommerce oppose the proposed modification, claiming that Petitioners have not adequately supported why the independence requirement should be relaxed, and that relaxing independence to achieve more PMRS providers will reduce consumer protection and increase costs.
Specifically, FST/Energy Recommerce contend that the integrity of performance data is of utmost importance. They argue that performance-based solar incentives, which pay solar customers based on production, create an incentive for system owners to report artificially high production data to receive larger PBI payments. In addition, inverter manufacturers, PV panel manufacturers and solar installers have a significant incentive to overstate system efficiency. For this reason, FST/Energy Recommerce claim that an independent PMRS requirement preserves the integrity of program data at the lowest possible cost. FST/Energy Recommerce urge the Commission to take extra precautions to ensure that financial incentives correspond to the energy actually produced.
Further, they claim that independent monitoring and reporting is becoming the standard for renewable energy credit (REC) trading. These parties argue that if the Commission were to eliminate the independence requirement, this could undermine confidence in the value of California solar RECs. Finally, FST/Energy Recommerce argue the Commission does not need to relax the independence requirement because there is no shortage of entities interested in providing PMRS services. They claim seven independent entities are interested in being PMRS providers, rather than the three entities suggested by Petitioners.
In response, Petitioners reiterate that the independence criterion unintentionally restricts market entry and limits innovation and customer choice in PMRS. They also note that innovative technological approaches for PMRS are allowed under the CEC's New Solar Home Partnership. They claim that certification standards for PMRS providers and CSI program measurement and evaluation can better ensure accuracy in system performance. Regarding REC requirements, Petitioners comment that since the REC program is voluntary, CSI incentive recipients should not be required to meet an independent PMRS requirement that may or may not be required for a future REC program.
1 The Joint Solar Parties are PV Now (now known as the Solar Alliance), California Solar Energy Industries Association, and the Vote Solar Initiative.
2 The FST/Energy Recommerce response was also supported by: Bridgeover, Inc., Connected Energy Corp., Draker Solar Design, LLC, DRI Energy Inc., Heliotronics, Inc., Independent Energy Solutions, Inc., Old Country Roofing, Solar Wave Energy, Inc., Solectria Renewables LLC, and Southern California Solar dba Solar Electric Systems.
