6. Administration

The Staff Proposal recommends that the Program Administrators of the general market CSI program, namely PG&E, SCE, and CCSE, serve as Program Administrators for the MASH program because they have the expertise to work successfully with affordable housing developers and building owners. Staff proposes separate administration from the LISF program because participants in the two programs will be very different, with the LISF program focused on homeowners and the MASH program focused on affordable housing owners and property managers. Staff reasons that the multifamily affordable housing sector has characteristics that make it similar to the commercial and nonprofit sectors in the general market CSI program. Staff also reasons that using the existing CSI program managers will expedite program implementation.

The current CSI Program Administrators agree that they should administer the MASH program, for the reasons stated in the Staff Proposal. Global Green supports this idea as well, but only for Track 1 incentives. For Track 2 incentives, Global Green suggests the Commission select a single statewide entity to administer these incentives funds as a pool. In the alternative, if the Commission rejects this idea, Global Green suggests a statewide advisory committee for Track 2 incentives that would work with the Program Administrators to develop a common application, review proposals, and conduct outreach.

CARE recommends the Commission consider integrating MASH with existing affordable housing efforts, and using local housing authorities to administer MASH. SCE and Global Green oppose this suggestion, noting there is no evidence that local housing authorities either want to or have the resources to accept this administrative commitment.

We agree with the Staff Proposal that the multifamily affordable housing sector has similarities to the commercial and nonprofit sectors served by the general market CSI program. These sectors all involve building owners seeking to lower operating costs for their businesses or nonprofit endeavors with solar installations, in contrast to the LISF program aimed at low-income homeowners. Although we have chosen to administer LISF through a single statewide administrator, we did so based on the specific financing and outreach needs of a program targeted at low-income homeowners. The outreach and administrative work we expect with the MASH program, aimed at the owners of affordable housing, will differ significantly from the LISF program. Therefore, we will require the existing CSI Program Administrators to undertake administration of the MASH program in their territories. We agree with staff this will expedite program implementation because the Program Administrators can incorporate the MASH incentive program into their existing administrative structures. Nevertheless, we will still require the Program Administrators to coordinate with the Program Manager for LISF to ensure consistency in marketing and outreach activities, where applicable, and take advantage of any synergies that may exist in Program Administration.

We reject CARE's suggestion to use local housing authorities to administer MASH because this approach would require further exploration to determine interest by local housing agencies and consider other legal questions. This would cause unnecessary program delay.

At the same time, although we will use the existing CSI Program Administrators to administer this program, we agree with Global Green's suggestion to obtain the expertise of the affordable housing sector in administering this program. Although we will not adopt Global Green's idea of separate administration for Track 2, we will require the Program Administrators to conduct marketing, outreach, and education services for both Track 1 and Track 2 of the MASH program in cooperation with or under contract with entities with experience in affordable housing. In addition, A WISH asks us to incorporate "green job" creation into this program. We agree, and therefore, we direct the Program Administrators to work with community stakeholders to develop training strategies for reaching disadvantaged communities, in order to incorporate green job creation into the MASH program.

Because marketing and outreach for the MASH program will likely require coordination with the general market CSI program, we will require the approval process and timeline for MASH marketing and outreach plans to mirror that of the general market CSI program. In keeping with general market CSI requirements, as set forth on an interim basis in D.07-05-047, the Program Administrators should submit MASH marketing and outreach budgets and plans along with general CSI marketing plans, although MASH information should be separately stated in the plan. The MASH marketing plan should contain a description of the proposed budget and plans for marketing and outreach services and green job creation strategies, including the entities the Program Administrator expects to contract with and for what services.