California Solar Initiative

In comments to President Peevey's ruling, three themes emerge:

· Ratepayers may receive more benefit from programs already determined to be cost effective, such as energy efficiency, other distributed generation technologies, or utility-scale renewables.

· Under conditions where incentives are long-term, predictable, and assured, solar energy will become a low-cost option, and the industry self-sustaining.

· The CPUC should determine the costs and benefits of solar attributes to inform incentive policies.

We propose six program elements which consider these themes, capitalize on successful elements of the CEC, CPUC, German, and Japanese solar programs, and provide alternatives to improve identified weaknesses.

1. Consolidate solar incentive programs.

2. Adopt a declining incentive schedule.

3. Establish an energy efficiency eligibility requirement.

4. Provide higher incentives for affordable housing, and for buildings that exceed minimum efficiency standards.

5. Adopt performance-based incentives.

6. Develop a predictable automatic trigger-mechanism to minimize short-term funding gaps, ensure long-term funding availability, and optimize ratepayer funds spent on solar installations.