XV. Program Administration

The SGIP is currently administered by PG&E, SCE, SoCalGas and SDREO. SDREO is a private nonprofit corporation that has administered a variety of other energy programs in the San Diego area, including energy efficiency programs funded through this Commission's decisions. Among the activities required of program administrators are the following:

· Coordinate with energy efficiency programs to assure each customer maximizes energy efficiency improvements prior to installing a solar system;

· Verify system installations;

· Make payments for installed systems;

· Provide information, application forms, program instructions on websites and in more traditional formats;

· Provide the Commission with monthly status reports on the program's progress;

· Conduct annual program evaluations;

· Conduct education and outreach, coordinating with existing marketing efforts, such as Flex Your Power and energy efficiency marketing;

· Manage a website that provides information about funding levels, number and types of systems funded and the number of applications in progress and on a waiting list;

The staff also recommends the Commission select third parties to administer the residential retrofit portion of the CSI, while initially retaining the existing SGIP program administrators as administrators for the commercial and industrial portion of the CSI.

The utilities favor their administration of the solar program, under the supervision of the Commission, citing utility experience with SGIP and the infrastructure they already have in place. The utilities observe that they are well-suited to act as a single point of contact to coordinate the CSI with other utility-administered programs such as energy efficiency, demand response, net metering, and interconnection. They clarify that while they may have opposed specific elements of SB 1, they are not opposed to continuation of a well-constructed solar incentive program.

Vote Solar strongly opposes utility administration, observing that utility opposition to SB 1 suggests the conflict of interest they have with regard to distributed solar projects. Vote Solar also commends the CEC's administration of the ERP program and, if administration is to stay with the utilities, Vote Solar recommends the CEC oversee the programs because its decision-making has been more responsive than this Commission's.

ASPv, PV Now, and Environment California recommend the Commission assign administrative tasks to an independent non-profit entity such as SDREO rather than to the utilities, citing conflict of interest concerns similar to those voiced by Vote Solar. PV Now emphasizes the need for flexible Commission oversight which allows for program changes in response to market conditions and broader input from stakeholders.

SDREO suggests the Commission differentiate among solar program activities which could be categorized as implementation, and those activities more closely related to administrative functions. SDREO lists administrative functions which broadly include policy research and oversight, portfolio management of programs, monitoring and evaluation, fiscal responsibility, and dispute resolution. Program implementers perform day-to-day program activities related to direct program delivery based on contracted agreements. SDREO supports a single agency as the high-level administrator, and regional implementers to deliver the program.

Discussion. The residential retrofit portion of the CSI program is one that is well-suited to third party administration. It is an area where, in the past, the administration has been done by the CEC and not the utilities. Thus, a new administrative structure will need to be developed in any case. We expect to explore, over the next year, a pilot approach using third-party administration initially only for the residential retrofit portion of the program.

For the commercial and industrial sector, we find it prudent to continue the status quo with existing program administrators, including SDREO.

To facilitate implementation of one statewide solar program, we will encourage web-based administrative options to facilitate quick and transparent transactions for applications and other activities. A single interactive database would allow applicants, evaluators and administrators to readily access statewide project information and makes non-confidential project data publicly available.

In addition, we will not engage the SGIP Working Group for the purpose of developing rules or policies for the CSI. Instead, we expect our staff to convene regular and public meetings of the utilities, program administrator(s) and any parties interested in articulating and solving administrative or implementation problems and identifying program opportunities. This group shall work together to develop a program manual using the SGIP manual as a foundation and that reflects the provisions of this order and other orders that address relevant issues.