6. Comments on Proposed Decision

The proposed decision of Commissioner Peevey in this matter was mailed to the parties in accordance with Pub. Util. Code § 311 and Rule 14.3 of the Commission's Rules of Practice and Procedure. Comments were filed by CCSE, Enphase, FST/Energy Recommerce, the Joint Solar Parties, PG&E, and SCE. Reply comments were filed by FST/Energy Recommerce, the Joint Solar Parties, and SCE.

Several parties ask for more time than the decision allows to develop and refine the PDP protocols in a workshop process. We make no adjustments to the decision because it already provides flexibility for the ALJ to amend the schedule for PDP development through the workshop process, if needed.

Another frequent comment was that Appendix A to the decision with interim PDP data transfer rules does not adequately reflect the process the program administrators are currently using. PG&E and CCSE provide a suggested revised appendix with their actual process, and FST/Energy Recommerce provide further edits to the appendix. SCE urges that we not adopt any interim PDP rules until after a workshop. We have modified Appendix A to reflect the modifications noted by the parties. We decline the suggestion to allow the program administrators flexibility to modify the interim PDP rules. The parties should instead use their time to refine final PDP protocols and rules through the workshop process, thereby lessening the time the interim rules are in effect. We will use the workshop for discussion of final PDP rules, and not further modification of these interim ones. However, we will allow the program administrators to propose minor, non-substantive revisions to the contact information or data submission timing in these interim rules. This change has been incorporated into the decision.

FST/Energy Recommerce comment that D.07-07-028 ordered the CSI program administrators to retain a consultant to conduct a metering, monitoring and reporting market assessment to inform future decisions on metering accuracy, monitoring and reporting, and system eligibility. The Joint Solar Parties respond that this report was intended to provide clarity about meter costs and levels of accuracy, and is not aimed at informing the issue of whether PMRS providers should be independent. We agree with the Joint Solar Parties that we do not need the results of the study commissioned in D.07-07-028 to modify our prior order and remove the independence requirement in this order.

Other minor modifications to the order suggested by parties in their comments have been incorporated throughout the decision.