4. Performance Data Provider (PDP) Proposal and Comments

On September 4, 2007, the Administrative Law Judge (ALJ) issued a ruling requesting further comments from parties on the petition for modification of the metering independence requirement. The ruling noted that since the petition for modification was filed, the metering subgroup of the CSI Handbook development process had continued to discuss PMRS requirements. Energy Division staff who monitors the work of the metering subgroup informed the ALJ of a proposal for replacing the independence requirements in D.06-08-028 with a detailed set of instructions for how to qualify as a third party PDP who provides data from PBI customer meters to CSI Program Administrators. The concept behind the PDP proposal is the creation of detailed standards and protocols for collecting and reporting solar production data from solar system owners to CSI Program Administrators for purposes of calculating performance incentive payments. These PDP standards and protocols would replace the current requirement that only independent entities not affiliated with solar manufacturers or installers can provide PMRS.

The ruling asked parties a set of questions about the PDP proposal, which was attached to the ruling. The ruling asked parties whether it was appropriate to remove the independence requirements previously adopted and instead apply a qualification process for PDPs. The ruling also asked whether the PDP qualification process should apply solely to the transmission of solar data to a Program Administrator for purposes of a PBI payment, or whether it should also apply to PMRS for reporting to customers on their system data.

The following parties provided comments on the PDP proposal: CCSE, Enphase Energy Inc. (Enphase, formerly PVI Solutions), FST/Energy Recommerce, KACO, PG&E, SCE, and jointly by the Solar Alliance, California Solar Energy Industries Association (CALSEIA), and Recurrent Energy, Inc. (collectively the Joint Solar Parties II).

Several commentors, namely PG&E, the Joint Solar Parties II, Enphase, KACO, support removal of the independence requirement and replacement with the PDP qualification process. They contend an independence requirement is unnecessary given the PDP proposal, which provides a superior model for data integrity. Moreover, they maintain that qualification of PDPs will allow the PMRS market to develop on its own by allowing customers to choose their PMRS provider from a larger pool of qualified entities. PG&E notes the PDP proposal is firmly based on Commission-approved rules for meter data management within the Direct Access program and is superior to the Commission's independence requirement which failed to define "affiliation" with sufficient specificity in the PMRS and solar metering context.

CCSE supports the PDP proposal, but only for data to Program Administrators for PBI payment purposes. CCSE maintains the PDP proposal is not intended to replace independence requirements for PMRS providers who supply system data to system owners. In that regard, CCSE suggests a three-fold approach to ensure accuracy and integrity of solar system performance data involving random inspections of metering systems, random audits of PMRS data, and verification of a sample of sites through the CSI measurement and evaluation process.

FST/Energy Recommerce and SCE oppose the PDP proposal. FST/Energy Recommerce maintain the PDP proposal is not an adequate substitute for an independence requirement because it allows monitoring by parties with an inherent bias toward the results. They contend the surest way to maintain data quality and integrity and avoid vendor self-interest and inflated claims for PBI payments is through independent PMRS services, not provided by solar owners, installers, manufacturers or integrators who are inherently biased. They allege PMRS should be independently "provided," even if it is sold bundled with a solar system.

FST/Energy Recommerce claim the PDP proposal is incomplete and unclear in numerous areas such as validation rules, audit procedures, data format, non-performance safeguards, and appeal procedures. They express concern that the PDP qualification process allows Program Administrators the power to assess PMRS providers' qualifications without an appropriate appeals process.

SCE alleges the PDP proposal does not provide sufficient detail on topics such as information technology, audits and penalties, and it ignores the utilities' Advanced Meter Infrastructure (AMI) rollouts. In lieu of the PDP proposal, SCE contends the Commission should delegate PMRS for PBI payment purposes to the Program Administrator to either perform themselves or contract with an entity for the services. Further, SCE suggests the Commission require all solar installations that receive CSI incentives to install an additional meter socket so that the Program Administrator can determine the best meter for that customer's needs. The Commission should adopt minimum PMRS standards and require the meter to provide a display of basic performance information. PG&E, the Joint Solar Parties II, and FST/Energy Recommerce oppose SCE's proposal, contending the idea will increase program administration costs and allow SCE to monopolize the meter data management market. These parties see no reason to allow SCE to mandate a utility specific approach.