1 csi staff proposal workshop energy division california public utilities commission november 17,...
TRANSCRIPT
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CSI Staff Proposal Workshop
Energy DivisionCalifornia Public Utilities Commission
November 17, 2010
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CSI Staff Proposal• Purpose: To recommend CSI Program
modifications to improve its ability to achieve its goals
• July 26, 2010: ALJ ruling setting a PHC and requesting statements on the CSI Staff Proposal
• August 12, 2010: PHC held to discuss CSI Staff Proposal
• Where we are now:– November 9, 2010: Scoping Memo issued,
which sets high priority issues to be considered in 2011.
• Comments due December 6, 2010• Reply comments due December 20, 2010
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Workshop Purpose
– To answer any questions on a subset of issues in the CSI Staff Proposal
– To solicit verbal feedback from parties on recommendations, including hearing alternative recommendations
– To help ensure that parties are well-informed on issues prior to writing comments
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Areas of Focus• This workshop will cover some, but not all, of the CSI Staff Proposal recommendations• Issues will not be covered in the same order as presented in the proposal
– Recommendations are grouped by related subject area• Recommendations covered in today’s workshop:
Recommendation Staff Proposal Section
Service Delivery Point as the Boundary of Eligibility for VNM Service
2.2
Expansion of VNM to all Customers 2.3
Expansion of VNM to all Affordable Housing Customers 2.4
Create Bill Credit Transfer (BCT) Tariff Option for All Multitenant buildings and Modify CSI Sized to Load Restrictions
2.5
SASH Design Factor Requirement 6.3
SASH Inspections 6.4
Two year Occupancy Requirement for Eligibility for MASH 6.7
Increasing Incentives Available for Sold Out MASH Track 1 6.6
Goal of Long-Term M&O Plan 5.2
Annual M&O Plans 5.3
Authorized M&O Activities 5.5
CSI Required Messaging and Branding 5.6
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Service Delivery Point as the Boundary of Eligibility for VNM Service
(Section 2.2)Issue: The current VNM tariffs limit the transfer of kWh credits to
customer accounts behind a single service delivery point.– In MASH/VNM decision (D.08-10-036), the CPUC did not
provide a clear definition of an affordable housing property.– Many affordable housing residences with multiple service
delivery points are precluded from providing VNM credits to all residents.
Recommendations:• The CPUC should determine the “service delivery point” is
not the proper boundary for MASH VNM projects.• The CPUC should clarify its intent is to encompass an entire
affordable housing development, and order VNM tariffs to be modified accordingly.
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Expansion of VNM to all Multitenant and Affordable Housing Customers
(Sections 2.3 and 2.4)Issue: Per D.08-10-036, VNM is limited to the MASH
Program.
Recommendations: • VNM should be expanded to all multitenant
customers.• If VNM is not expanded to all multitenant
customers, then it should be expanded to all qualified low-income customers.– Parties are encouraged to answer questions on VNM
expansion in the CSI Staff Proposal (pp.14-15).
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Create BCT Tariff Option for all Multitenant Buildings and Modify CSI Sized to Load Restrictions
(Section 2.5)Issues:• RES-BCT Tariff allows customers to transfer bill credits to multiple
accounts in a utility service area.– This tariff is only open to local governments, but could benefit
multitenant properties.• The CSI Program limits PV system be sized to cover the total load of
a single customer account, which is problematic for a host site with multiple accounts.
Recommendations:• RES-BCT should be allowed for all multitenant buildings.• The CSI Program should provide rebates up to the total load of host
site.– However, the total system size should be able to exceed the rebated
capacity.– Individual multitenant units should only receive a CSI rebate for the
portion of their solar system that serves onsite load.
SASH Design Factor Requirement(Section 6.3)
Issue: The SASH Program only provides incentives to projects that have a modified design factor of 0.95 or better without the geographic correction.– Only 56% of EPBB General Market projects
have a design factor of 0.95 or better.
Recommendation: • Change the SASH minimum design factor
requirement to 0.85.
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SASH Inspections(Section 6.4)
Issue: SASH decision (D.07-11-045) required that 100% of SASH systems be inspected.– System inspections are costly.– Given that SASH projects routinely pass inspections, is it
necessary to continue to the to inspect 100%?
Recommendation:• Require only 14% of SASH projects receive
inspections, similar to the General Market Program.
• The inspector, not the SASH Program Manager, will randomly select which projects will be inspected.
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Two-Year Occupancy Requirement for Eligibility in MASH
(Section 6.7)
Issue: Only projects that are occupied for at least two years are eligible for MASH Program incentives.
Recommendation:
• The CPUC should eliminate the two year occupancy requirement.
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Increasing Incentives Available for Sold Out MASH Track 1 Incentives
(Section 6.6)
Issue: MASH Track 1 incentives are sold out in all CSI territories– The CSI PA’s have established waiting lists for Track 1 projects
Recommendations:• The CPUC should eliminate all future MASH Track 2
incentives and allocate the funding towards Track 1.• The CPUC should consider reallocating some SASH funding
to the MASH Program.• The CPUC should lower the MASH Track 1 incentives to
$1.00/w (for Track 1A) and $1.20/w (for Track 1B).• The CPUC should allow MASH-eligible projects to receive
government/nonprofit incentives under the General Market Program.
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Goal of Long-Term M&O Plan(Section 5.2)
Issue: The Interim M&O decision did not establish an overall goal for the M&O strategy.
Recommendation: • The CPUC should direct the CSI PAs to conduct M&O
activities that meet the CSI goals. • The CPUC should order the review of annual M&O
(according to a defined process) plans to be measured against the plans’ ability to accomplish these objectives.
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Annual M&O Plans(Section 5.3)
Issue:• Annual M&O plans are submitted to Energy Division via business letters.
– Such filing method does not confer same transparency-- i.e. public review, protest, comment, resolution and approval– as the formal Advice Letter process.
• CSI PAs have submitted their plans at different times each year, causing delays in approval.
• CSI PAs submit plans for General Market program separately from those for the MASH program.
Recommendation: • CSI PAs should file Annual M&O plans via Advice Letter, concurrently with
MASH and CSI-Thermal M&O plans.• The M&O Plan filings should be presented for discussion at the Quarterly
CSI Program Forum and/or at a separate Commission workshop. • The M&O Plans should include the following:
– CSI PA M&O activities– M&O budget status to date– Details of statewide M&O strategy– Information on how to integrate with other Go Solar California program
components
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Authorized M&O Activities(Section 5.5)
Issue: • Interim M&O Activities limited to basic activities, primarily focused on facilitating
customer participation and instructing installers on how to fill out CSI applications.
• CSI Program has not developed an integrated, statewide consumer marketing campaign, and this represents a significant missed opportunity for the program.
Recommendation:• The CSI Program should issue a competitive request for proposals to
conduct a statewide consumer education campaign and activities, jointly funded by the Program Administrators.
– The Program Administrators should target spending at least 25 percent of the budget on statewide efforts.
• The M&O plans should draw from a list of suggested activities that advance CSI program goals.
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CSI Required Messaging and Branding(Section 5.6)Issue:
• The Go Solar California website, logo, and brand have been developed as a single statewide consumer education site.
• The CSI M&O program requires that all program materials include the Go Solar California logo, as well as maintain a consistent look and feel of the Go Solar California website .
• The CSI program seeks opportunities to integrate M&O information with other customer programs such as energy efficiency and demand response.
Recommendation:• The CPUC should require that the CSI PAs maintain the Go Solar California brand as
the statewide brand for solar M&O.
• All materials paid for by the CSI Program will be made available through an appropriate part of the Go Solar California web site.
– No CSI M&O materials should reside exclusively on the Program Administrators own solar web sites.
• The CSI PAs should be required to coordinate the Go Solar California brand with the new statewide energy efficiency brand and consumer education portal.
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Next Steps
• Scoping Memo comments are due December 6, 2010– Reply comments are due December 20, 2010 Goal: To
issue a Proposed Decision on “High Priority” items in Q1 2011
• “Medium” priority issues– Goal: To issue a Proposed Decision in Q2/Q3 2011– Workshop and comment schedule TBD
• “Low” priority issues– Goal: To issue a Proposed Decision by Q4 2011/Q1 2012– Workshop and comment schedule TBD
