4. Other Issues

4.1 Corporate Parent Limits

Powerlight contends that projects located on county fairgrounds should be subject to the annual 1 MW corporate/government parent cap per utility service territory. Powerlight states that the fairgrounds are not independent entities, but are overseen by California's State and County Fairgrounds, the Division of Fairs and Expositions, and the California Construction Authority.

Western Fairs and Vote Solar argue that each county fair is a unique, separate, and self-funded entity similar to a school district. Each has its own board of directors, and different legal structures. Most are District Agricultural Associations. Some are non-profits, and others are county organizations. None are state agencies. Moreover, Vote Solar states that average project costs for these solar installations are $4.64 per watt, which is considerably lower than the average SGIP rebate.

DES and JPIDG seek to expand MW eligibility under the parent cap. Capstone questions why the Commission restricts the entities most likely to install DG: a statewide network of grocery stores and other retail chains. We agree that putting caps on funding for government and corporate parents hinder the goal of increasing DG capacity to reduce peak demand, and may inflate project costs to artificially high levels. We do not rule today whether or not county fairgrounds are subject to a cap. Rather, we remove the 1 MW per service territory parent cap that limits funding for the university system, other state and federal agencies, corporations, and other entities formerly subject to the cap. We clarify that the SGIP will not pay incentives for capacity over 1 MW per location through the life of the program.

4.2 Reservation Requests

CALSEIA suspects that certain project developers submit incentive reservation requests for "phantom" projects, in order to reserve funds for undeveloped future projects. CALSEIA states that these practices allow developers to tie up substantial funding that could be reserved for legitimate projects.

Under current program rules, an applicant must provide proof-of-project documentation within 90 days of receiving a conditional reservation request. A program administrator may grant an extension based on project circumstances.

CALSEIA recommends the Commission adopt additional mechanisms to deter phantom projects, such as requiring a nominal fee when an application is submitted, refundable upon project completion. We are not opposed to such a mechanism, provided it does not place an undue financial burden on smaller projects. We delegate to the Working Group the task of developing appropriate procedural or financial mechanisms to deter inappropriate reservation requests.