DRAFT

PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

Agenda Id:

18539ENERGY DIVISION RESOLUTION E-5086 July 16, 2020

R E S O L U T I O N

Resolution E-5086. Approving with modification Pacific Gas and Electric’s (PG&E) Advice Letter (AL) 4219-G/5765-E and partially approving PG&E AL 4226-G/5778-E.

PROPOSED OUTCOME:- Approves, with modification, Pacific Gas and Electric

Company’s (PG&E’s) Advice Letter (AL) 4219-G/5765-E.- Approves, in part, PG&E’s AL 4226-G/5778-E.

SAFETY CONSIDERATIONS:- The California Public Utilities Commission previously

established safety parameters related to the Self Generation Incentive Program (SGIP). As a result, there are not any expected incremental safety implications associated with approval of this Resolution.

ESTIMATED COST:- PG&E has asserted that it will not require any funding

beyond what was previously approved in Decision 19-09-027 and Decision 20-01-021 to undertake the activities requested in the advice letters discussed in this Resolution. This Resolution has no additional impact on rates.

By PG&E AL 4219-G/5765-E filed on February 20, 2020 and PG&E AL 4226-G/5778-E filed on March 6, 2020.

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Resolution E-5086 DRAFT July 16, 2020PG&E AL 4219-G/5765-E, PG&E AL 4226-G/5778-E/NHWSUMMARY

This Resolution approves, with modification, Pacific Gas and Electric Company’s (PG&E’s) Advice Letter (AL) 4219-G/5765-E which provided PG&E’s Self-Generation Incentive Plan (SGIP) Residential Equity Resiliency Marketing Plan and Implementation Strategy. This Resolution also approves, in part, PG&E’s AL 4226-G/5778-E which requests approval to establish a SGIP Financial Assistance Pilot to Support Customer Resiliency. The California Public Utilities Commission (CPUC) rejects, without prejudice, PG&E’s proposal under its Financial Assistance Pilot to implement a revolving loan fund using on-bill finance for non-residential customers. If it so chooses, PG&E may revise this component of its proposal and submit a more detailed version through a new, separate Tier two advice letter for review by the Energy Division.

BACKGROUND

The Self-Generation Incentive Program (SGIP) was established by the California Public Utilities Commission (CPUC) in 2001 through Decision (D.)01-03-073 in response to Assembly Bill (AB) 970 (Ducheny, Stats. 2000, Ch. 329). AB 970 directed the Commission to provide incentives for distributed generation resources to reduce peak energy demand. Since 2001, the Legislature has refined and extended the SGIP several times, including expanding the program to include energy storage technologies.1

On September 18, 2019, the CPUC issued Decision (D.)19-09-027, Decision Establishing a Self-Generation Incentive Program Equity Resiliency Budget, Modifying Existing Equity Budget Incentives, Approving Carry-Over Of Accumulated Unspent Funds, And Approving $10 Million To Support The San Joaquin Valley Disadvantaged Community Pilot Projects (Equity Resiliency Decision). One of the most significant outcomes of this decision was the creation of a new equity resiliency budget for customers residing in Tier 2 and

1 SGIP incentives are available to any retail electric or gas distribution class of customer of Pacific Gas and Electric Company (PG&E), Southern California Edison Company (SCE), Southern California Gas Company (SoCalGas), and San Diego Gas & Electric (SDG&E). PG&E, SCE, and SoCalGas administer SGIP in their respective service territories. The Center for Sustainable Energy (CSE) administers SGIP for SDG&E. Thus, the four SGIP Program Administrators (PAs) are PG&E, SCE, SoCalGas, and CSE.

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Resolution E-5086 DRAFT July 16, 2020PG&E AL 4219-G/5765-E, PG&E AL 4226-G/5778-E/NHWTier 3 High Fire Threat Districts (HFTDs). The Decision describes how a new, higher energy storage incentive level would be available to non-residential customers who provide certain critical services or infrastructure to vulnerable communities and to residential customers who are eligible for the equity budget, on medical baseline, have notified their utility of a serious illness or condition that could become life threatening if electricity is disconnected, or have participated in one of the CPUC’s income-qualified solar programs.2

In addition to establishing several new budget categories within SGIP, the Equity Resiliency Decision modifies the equity budget incentive level to increase participation. Specifically, the Equity Resiliency Decision increases the equity budget incentive from $0.50 per watt hour (Wh) to $0.85 per Wh and establishes a new $1.00 per Wh incentive for all customers eligible for the equity resiliency budget. D.19-09-027 explains the rationale for these incentive levels as follows:

“At $0.85/Wh, [a median 13.2 kWh, two-hour residential storage system] would receive $11,200, or 83 percent of its total eligible cost, and at $1.00/Wh, the total incentive would equal $13,200 or 98% of the system’s total eligible cost. . . . the risk of setting the incentive levels too low for the new equity resiliency budget and the equity budget, leading again to no or very low participation in these budgets, outweigh the risk that developers will inflate costs. . . .Our top priority is to ensure access to the benefits provided by the SGIP to qualifying equity budget and vulnerable customers in Tier 3 and Tier 2 HFTDs as soon as possible.”3

The Equity Resiliency Decision also acknowledges that it will likely take more than a higher incentive level to increase uptake by equity customers. The decision notes that these customers may be less familiar with energy storage technologies and that in turn, it maybe be more difficult for project developers to identify these customers. As such, the Equity Resiliency Decision establishes the first ever carveout for SGIP ME&O funding within the SGIP Program Administrators’ (PAs) administrative funds and directs the PAs to develop a ME&O plan describing how they will use this funding to promote SGIP equity incentives alongside incentives available under 2 Decision 19-09-027 (D.19-09-027) at 24-25.3 Id. at 36-38.

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Resolution E-5086 DRAFT July 16, 2020PG&E AL 4219-G/5765-E, PG&E AL 4226-G/5778-E/NHWthe CPUC’s low-income solar programs. These include the Single-family Affordable Solar Homes (SASH), Disadvantaged Communities Single-family Solar Homes (DAC-SASH), Multi-family Affordable Solar Housing (MASH), and Solar on Multifamily Affordable Housing (SOMAH) programs. Ordering Paragraph (OP) 7(e) of the Equity Resiliency Decision directs the SGIP PAs to:

“develop a customized equity budget Marketing Education and Outreach (ME&O) Plan (Plan) in consultation with disability rights advocates and other key stakeholders as described in this decision that: co-promotes equity budget incentives with the [CPUC’s income-qualified solar] programs; prioritizes outreach methods to rapidly inform customers with critical resiliency needs about the availability of SGIP incentives and how they can identify and apply for storage systems that are appropriate for resiliency; and, addresses other guidance provided in this decision.”4

On December 17, 2019 the SGIP PAs submitted a preliminary statewide ME&O plan through their joint advice letter, PG&E AL 4191-G/5714-E, SCE AL 4127-E, SoCalGas AL 5555-G, and CSE AL 106-E (PG&E AL 4191-G/5714-E at al.). On January 14, 2020 the PAs conducted an ME&O workshop with stakeholders to discuss their intended outreach approaches and solicit feedback. The Energy Division approved PG&E AL 4191-G/5714-E at al. on February 26, 2020.

On January 27, 2020, the CPUC issued Decision (D.)20-01-021 Self-Generation Incentive Program Revisions Pursuant to Senate Bill 700 and Other Program Changes (SB 700 Decision) which authorizes ratepayer collections of $166 million annually for the years 2020 to 2024 to fund SGIP consistent with the authorization established by Senate Bill 700 (Wiener, 2018). In this decision, the CPUC bolstered the new equity resiliency budget by increasing funding and expanding the eligibility criteria to include customers who have experienced at least two discrete Public Safety Power Shutoff (PSPS)5 events in 4 Id. at OP 7.5 California Public Utilities Code Sections 451 and 399.2(a) give electric utilities authority to shut off electric power in order to protect public safety, referred to as PSPS events. This authority allows a utility to proactively de-energize electric facilities in locations where weather conditions present

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Resolution E-5086 DRAFT July 16, 2020PG&E AL 4219-G/5765-E, PG&E AL 4226-G/5778-E/NHWaddition to meeting the other equity criteria. The new program rules established that residential and non-residential customers can be either located in a Tier 2 or Tier 3 HFTD or have experienced at least two PSPS events in order to qualify for equity resiliency incentives. The SB 700 Decision also added additional types of facilities to the list that qualify as critical infrastructure for non-residential equity resiliency eligibility. Further, the Decision included customers who rely on electric pump wells for water supplies to the group of residential customers eligible for equity resiliency incentives. In total, between the Equity Resiliency Decision and the SB 700 Decision, the CPUC has allocated over $612 million for the equity resiliency budget and new funding of over $24 million for the equity residential budget.

Several parties commented on the SB 700 proposed decision providing input on how the CPUC intends for SGIP ME&O funding to be allocated and utilized given SB 700’s authorization to extend administration of SGIP to January 1, 2026. Thus, the SB 700 final Decision clarified that, “each SGIP PA shall allocate approximately 10 percent of their adopted annual administrative allocations to the customized ME&O Plan required in D.19-09-027 and should update the ME&O Plan on an annual basis.”6

The SB 700 Decision also articulates the CPUC’s vision when creating the first ME&O carve out within SGIP: “We clarify here that the Commission’s intent in D.19-09-027 is for SGIP PAs to develop a ME&O plan that extends well beyond an IOU-led mass marketing approach. D.19-09-027 outlines requirements and expectations for development of a customized ME&O Plan for the equity resiliency and equity budgets that will necessarily result in a targeted and community-based approach.”7

SGIP Joint Statewide Marketing, Education and Outreach Plan

extremely high risk of wildfires caused by blowing trees, branches, etc. contacting electric infrastructure. During a PSPS event, customers in the de-energized area have no electricity. Resolution ESRB-8 (July 12, 2018) at 4 requires that a utility initiate a PSPS event only when all other options have been exhausted. http://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M218/K186/218186823.PDF 6 D.20-01-021 at 77.7 Id.

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Resolution E-5086 DRAFT July 16, 2020PG&E AL 4219-G/5765-E, PG&E AL 4226-G/5778-E/NHWOn February 18, 2020, the SGIP PAs’ submitted a revised, statewide ME&O plan through their joint advice letter, PG&E AL 4218-G/5764-E, SCE AL 4167-E, SoCal Gas AL 5589-G, and CSE AL 109-E (PG&E AL 4218-G/5764-E at al.). This filing incorporated stakeholder feedback received at the January ME&O workshop and built on the guidance provide in the SB 700 Decision. Recognizing the need for a more customized approach, the February 18, 2020 joint advice letter asserted, “each PA will be submitting their own tailored and territory-specific ME&O Plan . . . that will target the customers with the most need for SGIP incentives. These plans will build upon the statewide ME&O Plan . . . and will detail the activities to be executed by each administrator and outreach partner organization(s). This will allow more flexibility, adaptability and enable more opportunities to work with stakeholders to ensure equitable penetration throughout the entirety of the PA’s territories.”8 The Energy Division approved PG&E AL 4218-G/5764-E at al., containing the statewide Marketing Education and Outreach (ME&O), plan on April 9, 2020 citing the “PAs’ commitment to submitting territory-specific ME&O plans ‘in the coming weeks’.”9

PG&E’s Territory-Specific Marketing, Education and Outreach Plan

On February 20, 2020, PG&E submitted AL 4219-G/5765-E, with its territory-specific, SGIP Residential Equity Resiliency Marketing Plan and Implementation Strategy. Although unclear from the AL title, PG&E’s plan also discusses outreach to non-residential customers who are eligible for the equity resiliency budget. PG&E notes that it developed its ME&O plan in consultation with East Bay Community Energy (EBCE), Medical Disability Rights Advocacy Group, Rebuild NorthBay, and Rebuild Paradise.10

8 PG&E AL 4218-G/5764-E at al: Proposed Revisions to the Self-Generation Incentive Program Handbook to Further Incorporate Requirements Pursuant to Decision 19-09-027 (February 18, 2020) at 9. 9 Energy Division Non-Standard Disposition Letter on PG&E AL 4218-G/-A/5764-E/-A, SCE AL 4167-E/-A, SoCalGas AL 5589-G/-A, and CSE AL 109-E/-A, Proposed Revisions to the Self-Generation Incentive Program Handbook to Further Incorporate Requirements Pursuant to Decision D.19-09-027 (April 9, 2020) at 6.10 PG&E Advice Letter 4219-G/5765-E: Self-Generation Incentive Plan (SGIP) Residential Equity Resiliency Marketing Plan and Implementation Strategy (February 20, 2020).

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Resolution E-5086 DRAFT July 16, 2020PG&E AL 4219-G/5765-E, PG&E AL 4226-G/5778-E/NHWIn its SGIP ME&O plan, PG&E identifies four key barriers to customer adoption of energy storage and specifically, utilization of the incentives available through the equity resiliency budget. These include upfront funding challenges, trust in program legitimacy, lack of case managers, limited installer inventory and hard-to-reach rural customers. In terms of the barrier posed by upfront funding, PG&E proposed its financial assistance pilot through a subsequent advice letter which is also disposed of in this Resolution. PG&E states that it will also coordinate financing opportunities available through various CCAs resiliency programs. In order to overcome the second barrier and enable customers to trust that the incentives available through SGIP are legitimate, PG&E states that it will use its existing in-house communication channels such as ongoing PSPS and wildfire education efforts, as well as partner with community-based organizations (CBO) and local outreach partners. PG&E acknowledges that the lack of SGIP case managers may require individualized assistance to help customers understand and complete the SGIP process. PG&E intends to support this type of assistance by working with CBOs and other trusted, local groups who regularly interface with customers. Finally, PG&E intends to communicate regularly with installers and include them in the outreach effort to ensure there is sufficient contactor support for customers interested in applying to SGIP, that outreach to rural areas occurs regularly, and that any issues related to equipment backlogs can be quickly mitigated.

Specifically on the topic of outreach partners, PG&E’s ME&O AL states that in addition to utilizing its existing relationship with 39 CBOs and 38 community outreach contractors working on the Energy Savings Assistance Program (ESA) and enrolling customers onto medical baseline rates, PG&E will also engage over 200 organizations focused on Access and Functional Needs (AFN) customers and Voluntary Organizations Active in Disaster (VOAD), particularly those focused on the American Disabilities Act (ADA).11 In addition, PG&E states that it will share informational materials on SGIP, its “Program Toolkit”, with partners to leverage ongoing marketing conducted for SASH, DAC-SASH, SOMAH, and the CCAs’ resiliency programs. PG&E will also explore opportunities to include information on SGIP in materials being distributed by county, local, and tribal governments. Finally, PG&E states that it will bolster the efforts of CBOs by providing them with an enrollment fee if they support customers

(PG&E AL 4219-G/5765-E) at 2.11 PG&E AL 4219-G/5765-E) at 6.

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Resolution E-5086 DRAFT July 16, 2020PG&E AL 4219-G/5765-E, PG&E AL 4226-G/5778-E/NHWeligible for the equity resiliency budget through the application process.

PG&E’s ME&O plan provides a total proposed budget of $615,000, of which it plans to direct $150,000 to the enrollment fee for CBOs. The AL does not provide a narrative on PG&E’s proposed ME&O budget, only a budget table.12 The AL also includes an Appendix A which summarizes the topics discussed at the January 2020 SGIP ME&O workshop and explains how PG&E has integrated this feedback into its ME&O plan.

PG&E’s Proposed SGIP Financial Assistance Pilot

On March 6, 2020, PG&E filed AL 4226-G/5778-E in which it requests to create a financial assistance pilot within SGIP. PG&E proposed the pilot on its own motion to “further support vulnerable customers ahead of 2020 PSPS events”13 and, as subsequently clarified, “to support the outreach efforts, led by Community Based Organizations as outlined in the PG&E Self-Generation Incentive Plan (SGIP) Residential Equity Resiliency Marketing Plan and Implementation Strategy.”14 The advice letter states that PG&E intends for its pilot to occur in 2020 although it could be continued if funding remains and Energy Division agrees. As proposed, the pilot would have two separate and distinct components.

The first component of PG&E’s proposed financial assistant pilot seeks to support vulnerable residential customers and the energy storage providers working with them by providing 50% of the SGIP incentive upfront and the other 50% after project completion and inspection. This approach is a departure from the established SGIP process which awards incentives only after project completion and inspection. PG&E asserts that accelerating half of the SGIP rebate so that it is awarded closer to the start of the project will both alleviate the financial burden on residential customers and cash flow issues 12 Id. at 8.13 PG&E Advice Letter 4226-G/5778-E: Request for Self-Generation Incentive Program Financial Assistance Pilot to Support Customer Resiliency (March 6, 2020). (PG&E AL 4226-G/5778-E) at 2.14 Pacific Gas and Electric Company’s Reply to the Responses from California Solar & Storage Association (CALSSA), SUNRUN and GRID Alternatives (GRID) to Advice 4226-G/5778-E – SGIP Financial Assistance Pilot to Support Customer Resiliency (April 2, 2020). (PG&E Reply to Responses on PG&E AL 4226-G/5778-E).

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Resolution E-5086 DRAFT July 16, 2020PG&E AL 4219-G/5765-E, PG&E AL 4226-G/5778-E/NHWfaced by project developers. As described by PG&E, developers can only take on a certain number of projects before recouping costs and contractors are typically only paid in full after the customer receives the SGIP incentive. PG&E states that it will develop a participation agreement to be signed by contractors to ensure that any advances paid for projects that are ultimately not completed are returned to the program and that projects provided up-front financing are installed within a certain timeframe. In addition, PG&E asserts that it will “vet all participating contractors, including their licensing and insurance, as well as through third party resources such as the Better Business Bureau.”15

The second component of the pilot would authorize PG&E to set aside $15 million for a revolving loan fund which the utility would make available to non-residential, critical infrastructure customers who are seeking to install energy storage or renewable generation projects for resiliency. PG&E acknowledges that upfront costs can also be a barrier for these customers and thus it seeks to provide upfront funding through no-interest loans to accelerate enhanced resiliency for critical infrastructure. PG&E explains that these non-residential customers would pay back the loan based on the on-bill financing (OBF) model that exists within PG&E’s energy efficiency programs.16As principal returns to the revolving loan fund, PG&E can support additional projects with new loans. By making a no-interest loan available, PG&E hopes to accelerate non-residential SGIP projects while also motivating customers to complete energy efficiency projects through similar but separate loans at the same time as SGIP projects.

15 PG&E AL 4226-G/5778-E at 2.16 In D.09-09-047 and later modified in D.19-03-001, the Commission approved an OBF program as part of the energy efficiency funding for all four of the major energy utilities. The OBF program offers eligible non‐residential customers a way to pay for energy efficiency upgrades without incurring up‐front costs. Under the program, a utility provides eligible customers with unsecured loans covering the energy efficiency equipment and installation costs (net of rebates and other incentives) with no interest. Customers then repay the loans through charges added to their regular utility bills. https://www.cpuc.ca.gov/egyefficiency/ andhttps://www.pge.com/en_US/small-medium-business/save-energy-and-money/energy-efficiency-financing.page?cid=ps_EEF_Business_20200121_google_google_ALL_Financing&dclid=&gclid=CjwKCAjw5vz2BRAtEiwAbcVIL_7IXsuM29xzDE1RAp_bQYmcghk-ogjo5d_OTZRac3uARUq9g2lpJxoCHCgQAvD_BwE

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Resolution E-5086 DRAFT July 16, 2020PG&E AL 4219-G/5765-E, PG&E AL 4226-G/5778-E/NHWNOTICE

Notice of PG&E AL 4219-G/5765-E and PG&E AL 4226-G/5778-E were made by publication in the Commission’s Daily Calendar. PG&E states it mailed and distributed a copy of each in accordance with Section 4 of General Order 96-B.

PROTESTS AND RESPONSES

On March 11, 2020 Sonoma Clean Power Authority (SCP), Marin Clean Energy (MCE), and GRID Alternatives (GRID) each filed a timely protest to PG&E’s ME&O Plan (PG&E AL 4219-G/5765-E).

On March 26, 2020 Sunrun Inc. (Sunrun), GRID, and the California Solar & Storage Association (CALSSA) each filed a timely response to PG&E’s Financial Assistance Pilot (PG&E AL 4226-G/5778-E).

On March 18, 2020 PG&E replied to the protests of its ME&O Plan (PG&E AL 4219-G/5765-E) that were filed by SCP, MCE, and GRID.

On April 2, 2020, PG&E replied to the responses on its Financial Assistance Pilot (PG&E AL 4226-G/5778-E) that were submitted by Sunrun, GRID, and CALSSA.

The following provides a summary of the major issues raised in the protests and responses, and PG&E’s reply to each. For clarity, each AL is discussed separately with the protests/responses followed immediately by PG&E’s reply. We first discuss the protests of PG&E’s ME&O Plan (AL 4219-G/5765-E) and PG&E’s reply to these protests. Second, we turn to the responses to PG&E’s Financial Assistance Pilot (AL 4226-G/5778-E) and PG&E’s reply to these responses.

Protests on PG&E’s ME&O Plan (PG&E AL 4219-G/5765-E)

Sonoma ProtestIn its protest, Sonoma Clean Power Authority (SCP) calls for the CPUC to reject PG&E’s ME&O plan. SCP states that it appreciates the stakeholder workshop held by the SGIP PAs in January but that “it does not appear that PG&E is incorporating that feedback, nor adhering to the Commission’s Decision."17 In particular, SCP states that the SGIP ME&O plan submitted by PG&E provides “scant information on coordination with local government partners, and other important stakeholders, such as low-income solar [program 17 Id. at 4.

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Resolution E-5086 DRAFT July 16, 2020PG&E AL 4219-G/5765-E, PG&E AL 4226-G/5778-E/NHWadministrators] PAs. The plan vaguely alludes to coordination with [community choice aggregators] CCAs on a handful of residential outreach concepts, but provides no concrete commitments or plans."18

To remedy this, SCP asks the CPUC to direct PG&E to both redevelop its ME&O plan in coordination with CCAs and low-income solar PAs and allocate a specific line of funding in its ME&O budget to these entities. SCP requests that it be allocated 10% of PG&E’s 2020-2024 ME&O funds.

SCP further requests that the CPUC approve its ME&O plan that it provides as Appendix A to its protest and bolsters with letters of support in Appendix B. SCP emphasizes its prior experience working with vulnerable customers and coordinating with local entities as justification for approval of its ME&O plan. SCP asserts it is uniquely motivated to make its customers aware of SGIP as they have experienced "315,000 PSPS-account events in 2019. In addition, in recent years Sonoma suffered 3 emergencies as declared by the Governor: the Wine Country Fires, the 2019 flooding in Sonoma County, and the Kincaid fire."19

MCE ProtestMCE makes the same three requests of the CPUC as SCP in regard to PG&E’s ME&O plan. In short, both CCAs request that the CPUC: 1) reject PG&E’s ME&O plan and direct it to revise it in coordination with CCAs and low-income solar PAs; 2) approve their provided ME&O plan; and 3) direct PG&E to include an SGIP ME&O budget line specifically for CCAs and low-income solar PAs. Also similar to SCP, MCE provides a proposed SGIP ME&O plan as Appendix A to its protest and letters of support as Appendix B.

As evidence of its eagerness to collaborate and lack of reciprocation from PG&E, MCE asserts that it reached out to PG&E staff after the January ME&O workshop but never receive a response. In addition, MCE raises alarm that PG&E’s ME&O plan has excluded portions of the statewide SGIP PA ME&O plan that discusses collaborating with local governments, low-income solar PAs, and CCAs. This leads MCE to find that "[i]t is clear from the lack of communication and the proposed changes in PG&E’s Equity Marketing Plan that PG&E 18 Id.19 Protest of Sonoma Clean Power Authority to Pacific Gas and Electric Company Advice Letter 4219-G/5765-E, Self-Generation Incentive Plan (SGIP) Residential Equity Resiliency Marketing Plan and Implementation Strategy (March 11, 2020) (SCP Protest) at 3.

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Resolution E-5086 DRAFT July 16, 2020PG&E AL 4219-G/5765-E, PG&E AL 4226-G/5778-E/NHWneither has the intent to truly collaborate with CCAs and low-income solar PAs on SGIP Equity ME&O, nor will do so in the future without a clear directive from the Commission."20 MCE emphasizes its dedication to advancing the resiliency of its customers and notes that it has already committed resources and launched an RFP for behind the meter energy storage solutions in order to kick-off these efforts in Q2 2020. MCE asserts that it "has been actively engaging with its local government and Office of Emergency Services (“OES”) partners to identify the facilities that were critical in maintaining community support during the 2019 PSPS events. To date, MCE has identified more than 60 critical facilities across its service area that are prime candidates for SGIP incentives."21 MCE requests that the CPUC direct PG&E to allocate $55,000 annually to MCE's SGIP ME&O efforts.

GRID ProtestThe protest filed by GRID points out that PG&E’s ME&O plan fails to address equity customers since it does not target residential customers who would qualify as being low-income and having experienced at least 2 discrete PSPS events or living in a Tier 2 or Tier 3 HFTD. GRID asserts that PG&E should revise its prioritization of targeted customers to first focus on low-income, medically vulnerable customers followed by low-income and medically vulnerable customers who have solar or are currently participating in the CPUC’s low-income solar programs. Similar to MCE, GRID states that it has reached out to staff at PG&E but has been unable to discuss SGIP outreach with staff. GRID expresses concern that it “is unclear if PG&E has reached out to equity-focused CBOs and CCAs to help mitigate the health and safety impacts of PSPS events on low-income customers.”22

GRID clarifies that ultimately the reason it felt compelled to protest PG&E’s ME&O plan rather than simply submit a response was that “PG&E leaves out key third-party partners, and leaves ambiguous the

20 Protest of Marin Clean Energy to Pacific Gas and Electric Company Advice Letter 4219-G/5765-E, Self-Generation Incentive Plan (SGIP) Residential Equity Resiliency Marketing Plan and Implementation Strategy (March 11, 2020) (MCE Protest) at 7.21 Id. at 8. 22 Protest of GRID Alternatives to the Pacific Gas and Electric Company Self-Generation Incentive Program (SGIP) Residential Equity Resiliency Marketing Plan and Implementation Strategy (March 11, 2020) (GRID Protest) at 3.

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Resolution E-5086 DRAFT July 16, 2020PG&E AL 4219-G/5765-E, PG&E AL 4226-G/5778-E/NHWactual amount of funding that these third-party partners can receive."23 In particular, GRID underscores that by only providing a budget table and no associated narrative, there is no way to discern how many CBOs PG&E intends to have participate in the enrollment fee proposal nor the duration over which funding would be provided to CBOs. GRID also requests clarity on whether the enrollment fee and the referral fee discussed in PG&E's ME&O plan are the same or if they represent distinct concepts. GRID states that PG&E must clarify its CBO funding and recommends that "an annual 50% ($213,669) carve-out of PG&E’s annual budget for five years"24 be provided to low-income solar PAs, CBOs, and CCAs and that, "[o]f this portion, the low-income solar PAs should receive $106,834 per year."25

PG&E’s Reply to Protests on its ME&O Plan (PG&E AL 4219-G/5765-E)

In its response to SCP's, MCE's, and GRID's protests of its ME&O Plan, PG&E states that it appreciates this dialogue and “strongly emphasizes its commitment to continue working with local government, community-based organizations (CBOs), low-income solar program administrators and Community Choice Aggregators (CCAs) to ensure success of SGIP marketing and overall program goals."26 PG&E asserts that the SGIP Program Toolkit that it will develop through its ME&O budget, "is intended to provide all stakeholders access to SGIP messaging that can be used within stakeholder channels."27 Thus the reply emphasizes that one of PG&E's key outreach tactics is to make programmatic information available for others to voluntarily disseminate.

In response to GRID’s protest in particular, PG&E asserts that it does plan to engage low-income customers and never intended to exclude such customers. PG&E emphasizes that its existing CBO network is well positioned to reach these customers given their experience

23 Id. at 4.24 Id. at 5.25 Id.26 Reply of Pacific Gas and Electric Company (PG&E) to Protests of Sonoma Clean Power (SCP), Marin Clean Energy (MCE) and Grid Alternatives (GRID) to PG&E Advice Letter 4219-G/5765-E, “Self-Generation Incentive Program (SGIP) Residential Equity Resiliency Marketing Plan and Implementation Strategy” (ME&O Plan) (March 18, 2020) (PG&E Reply to Protests of AL 4219-G/5765-E) at 4.27 Id.

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Resolution E-5086 DRAFT July 16, 2020PG&E AL 4219-G/5765-E, PG&E AL 4226-G/5778-E/NHWworking on the ESA and California Alternate Rates for Energy (CARE) programs which specifically target low-income and vulnerable populations. The response also asserts that PG&E will work with vulnerable customers who have solar and will provide information on the benefits of pairing solar with energy storage for those who do not yet have solar. PG&E’s response provides high level clarification on how the proposed enrollment fee component of its ME&O plan will function. PG&E specifically clarifies that the $150,000 it has allocated for this activity is solely to be used by its existing CBO network. According to PG&E, CBOs will obtain a payment only once a vulnerable customer successfully submits an SGIP application.

PG&E’s response also acknowledges the requests for funding included by SCP, MCE, and GRID in their protests. PG&E states that it “supports budget requests at the discretion of the Commission”28 (emphasis in original) and provides data on the percent of various categories of vulnerable categories by county that have experienced multiple PSPS events “for the Commission to consider when assessing appropriate budget requests.”29

Responses on PG&E Financial Assistance Pilot (PG&E AL 4226-G/5778-E)

Sunrun ResponseSunrun Inc. (Sunrun) states its strong support for PG&E’s financial assistance pilot in its response to PG&E AL 4226-G/5778-E. In particular, Sunrun emphasizes that COVID-19 and the associated statewide shelter-in-place order that was instituted subsequent to PG&E’s AL filing has created unprecedented challenges for energy storage project developers that makes PG&E’s pilot even more crucial. Sunrun asserts, “Given the extraordinary circumstances, accelerated access to capital is critical for storage developers to participate in SGIP at this time.”30 As such, Sunrun requests that PG&E’s financial assistance pilot be expanded to also include residential equity customers so that it is not restricted to only customers living in wildfire areas. Sunrun also encourages PG&E to consider extending its financial assistance proposal to all residential SGIP customers in the future.

28 Id. at 5. 29 Id.30 Sunrun Inc.’s Response to Pacific Gas and Electric Company’s Advice Letter 4226-G/5778-E (March 26, 2020). (Sunrun Response). at 2.

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Resolution E-5086 DRAFT July 16, 2020PG&E AL 4219-G/5765-E, PG&E AL 4226-G/5778-E/NHWSeparately, Sunrun flags concerns that PG&E’s stated plans for vetting participating contractors could cause delays in implementing the pilot and allowing contractors to participate. Sunrun instead recommends that all project developers on the SGIP approved developer list be eligible to participate in the pilot. The response notes that, PG&E can “utilize existing enforcement measures in SGIP to prevent gaming, such as imposing infractions, suspensions, or expulsions for contractors who do not comply with the rules.”31

GRID Alternatives’ ResponseIn its response to PG&E’s financial assistance advice letter, GRID commends PG&E for taking initiative to address access to capital issues faced by equity customers. GRID requests, however, that PG&E’s pilot go further by making 100% of the SGIP incentive available specifically to SASH and DAC-SASH customers. As justification for this request, GRID underscores that the Equity Resiliency Decision (D.19-09-027) streamlined the eligibility of these customers as they are to “automatically qualify for the equity budget.”32 Similar to Sunrun, GRID points to the dramatic economic impacts resulting from COVID-19 which make access to capital all the more critical. GRID asserts that, “At this time, providing 50% of the incentive upfront requiring low-income customers or low-income solar PAs to carry or pay 50% of the total project costs until completion of the project will result in little or no DAC-SASH and SASH paired solar + storage projects.”33 GRID asserts that providing 100% of the SGIP incentive upfront to SASH and DAC-SASH projects is appropriate because the CPUC already has a high degree of oversight over these programs since it oversees GRID as the statewide SASH and DAC-SASH program administrator. As a final justification for increasing upfront funding, GRID points to the SGIP application statistics since the implementation of the COVID-19 shelter in place order as demonstrating a dramatic decline in uptake in the equity and equity resiliency budgets.

Like Sunrun, GRID’s response highlights concerns about PG&E’s plan for vetting contractors who will be allowed to participate in the financial assistance pilot. In contrast to Sunrun, however, GRID wants to ensure that contractors who are new to SGIP be able to participate 31 Id. 32 D.19-09-027 at 15. See also Attachment A at 5.33 Response of GRID Alternatives to the Pacific Gas and Electric Company Request for Self-Generation Incentive Program Financial Assistance Pilot to Support Customer Resiliency (March 26, 2020).(GRID Response) at 3.

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Resolution E-5086 DRAFT July 16, 2020PG&E AL 4219-G/5765-E, PG&E AL 4226-G/5778-E/NHWin the financial assistance pilot. GRID notes that the Equity Resiliency Decision implemented revisions to the equity budget in response to the previously low uptake and that this underscores the need for the pilot to include new contractors who are familiar with and ready to effectively serve equity communities. In particular, GRID itself is eager participate in the pilot and in its response, it encourages PG&E to coordinate with GRID as the administrator of the SASH and DAC-SASH programs.

CALSSA ResponseThe California Solar & Storage Association (CALSSA) strongly supports PG&E’s financial assistance pilot and provides four suggestions to improve it – three for the residential component and one for the non-residential component. First, CALSSA seeks clarity on whether only a specific subset of equity resiliency-eligible residential customers will be allowed to participate in the financial assistance pilot since PG&E only mentions medical baseline and income-qualified customers in their AL. In particular, CALSSA seeks to confirm whether customers who have voluntarily notified their utility of a serious medical condition that would be life threatening without electricity as well as customers who rely on electric well pumps will be allowed to make use of the pilot. Secondly, CALSSA suggests that PG&E should consider providing a higher percentage of the incentive upfront, even if not the full 100%, to cover more of the project costs. Finally, CALSSA states that PG&E should clarify at what stage of the SGIP application process the upfront payment would be received.

CALSSA also seeks clarity on the non-residential component of PG&E’s pilot. CALSSA’s reply points out inconsistencies in PG&E’s discussion of the group of customers it is targeting, as PG&E mentions both non-residential customers eligible for the equity resiliency decision and non-residential critical infrastructure customers more broadly. CALSSA urges PG&E to make on-bill financing available to both non-residential customers applying to the equity resiliency budget and to those using the resiliency adder, in other words that “all critical facilities be allowed to access to these loans."34

34 Response to PG&E AL 4226-G/5778-E SGIP Financial Assistance CALSSA (March 26, 2020). (CALSSA Response) at 2.

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Resolution E-5086 DRAFT July 16, 2020PG&E AL 4219-G/5765-E, PG&E AL 4226-G/5778-E/NHWPG&E’s Reply to Responses on PG&E AL 4226-G/5778-E

As stated earlier, in its reply to Sunrun’s, GRID’s, and CALSSA’s responses PG&E explains that it has proposed a financial assistance pilot to further support its ME&O plan. Thus, PG&E clarifies that the customers intended to be served by the pilot are the same audience targeted by its ME&O plan, i.e. customers eligible for the equity resiliency budget. Therefore, as restated in a footnote in its reply, PG&E’s intended beneficiaries of the residential component of the pilot are first and foremost residential customers who have experienced at least two PSPS events and are on medical baseline or have informed PG&E of a condition that would be life threatening without electricity. The footnote in the reply goes on to state that the secondary audience for PG&E’s upfront payment are residential equity resiliency customers on medical baseline who have adopted rooftop solar but who do not have energy storage systems. In the non-residential space, PG&E states that it intends to target governmental, non-profit, and small business entities eligible for equity resiliency incentives who are located in disadvantaged or low-income communities. With those clarifications, PG&E requests that the CPUC approve its financial assistance pilot as originally filed. PG&E notes that it welcomes future revisions or additions to the pilot and that it is open to discussing additional efforts to support the energy storage industry in light of COVID-19 impacts.

DISCUSSION

As in the prior section, we will first discuss Pacific Gas and Electric’s (PG&E’s) Marketing Education and Outreach (ME&O) Plan submitted through Advice Letter (AL) 4219-G/5765-E, followed by PG&E’s Financial Assistance Pilot proposed in AL 4226-G/5778-E.

PG&E’s ME&O Plan

SCP, MCE, and GRID each ask the CPUC to reject PG&E’s ME&O plan because of the lack of coordination with, and allocation of funding to, CCAs and low-income solar PAs. We are concerned by the experiences described by both MCE and GRID in which they reached out to PG&E staff to discuss SGIP and never heard back. While we acknowledge that the number of changes made to SGIP, associated regulatory filings, and degree of new programmatic implementation details has created an unprecedented workload for the SGIP PAs, it is essential that PG&E collaborate with these entities. As stated in their

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Resolution E-5086 DRAFT July 16, 2020PG&E AL 4219-G/5765-E, PG&E AL 4226-G/5778-E/NHWprotests, SCP, MCE, and GRID are each highly motivated to support vulnerable customers in accessing SGIP and each entity has valuable prior experience working with these customers and helping them enroll in beneficial programs. Now that several months have passed since PG&E’s AL filing and particularly since the new SGIP budget categories have been incorporated into the SGIP application database and the bulk of regulatory filings have been completed, PG&E should have greater bandwidth to engage with CCAs and low-income solar PAs. We expect PG&E to open up these lines of communication immediately, if they have not already done so.

The protests ask the CPUC to direct PG&E to redraft their ME&O plan in coordination with CCAs and low-income solar PAs. While we find PG&E’s ME&O plan would have benefited from additional detail on its intended outreach implementation processes, we must balance efforts to refine and perfect this plan with the need for PG&E to quickly commence outreach efforts given that the 2020 wildfire season has now already begun. Instead of directing PG&E to refile its ME&O plan, we look to PG&E’s Program Toolkit as an opportunity for PG&E to collaborate with CCAs and low-income solar PAs to better inform this customer-facing educational resource. We direct PG&E to engage with these entities on development of the toolkit and make the final version publicly available for download on its website within 30 days of adoption of this resolution.

In terms of content of PG&E’s ME&O plan, we agree with GRID’s suggestion that PG&E should prioritize low-income, medically vulnerable customers first as medical baseline customers are likely to be particularly vulnerable and those who are low-income face the greatest need for assistance when adopting energy storage. We direct PG&E to prioritize SGIP outreach to customers who have experienced two or more discrete PSPS events or who live in Tier 2 or 3 HFTDs and who are enrolled in both medical baseline and the CARE or Family Energy Rate Assistance (FERA) programs as a proxy for customers who are low-income. In order to expedite outreach to vulnerable customers as early as possible in the 2020 wildfire season, we approve PG&E’s ME&O plan with this change.

While we find it is necessary to approve PG&E’s SGIP ME&O plan for 2020, we note that the SB 700 Decision states that the SGIP PAs “should work to update the ME&O Plan on an annual basis.”35 Given this suggestion and the degree of controversy surrounding PG&E’s 35 D.20-01-021 at 26.

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Resolution E-5086 DRAFT July 16, 2020PG&E AL 4219-G/5765-E, PG&E AL 4226-G/5778-E/NHWinitial SGIP ME&O plan, we direct PG&E to submit a revised SGIP ME&O plan for 2021 within one week into the new year, i.e. by January 11, 2021. We further direct PG&E to collaborate directly with the CCAs and low-income solar PAs in the development of its 2021 SGIP ME&O plan. This timeline also allows PG&E to coordinate its SGIP ME&O plan to align with forthcoming clean energy coordination goals in the ESA and CARE proceeding, A.19-11-003.

This leads us to the most significant issue raised in the protests, the request for the CPUC to allocate part of PG&E’s ME&O budget to SCP, MCE, and GRID. We appreciate the dedication of SCP, MCE, and GRID to ensuring the customers they serve are aware of and can access the SGIP incentives for vulnerable customers and critical facilities. In particular, we acknowledge the time and effort that SCP and MCE put into drafting ME&O plans for targeting vulnerable customers in their service territories to educate and inform them about the opportunities available through SGIP. We also note SCP’s proposal to make upfront funding available to customers seeking to install storage systems less than 30 kilowatts (kW). This proposal goes beyond the financial assistance pilot proposed by PG&E that is discussed in this Resolution as SCP will make funding available in an amount equal to the expected SGIP incentive.36 We note that this program is now already being utilized by residential customers in SCP’s service territory.37

To determine whether to allocate ME&O funding to CCAs and low-income solar PAs, it is first important to determine the appropriate total funding level for PG&E’s ME&O budget. The SB 700 Decision “clarifies that PG&E and SCE shall estimate an annual administrative allocation for [the customized ME&O Plan] as approximately one-fifth of their accumulated unused funds”.38 PG&E requested $650,000 for SGIP ME&O but as previously noted, it is unclear whether this amount is just for 2020 or covers the next five years of the program. In contrast, GRID calculates that PG&E’s annual ME&O funding should be $427,339.39 Ordering Paragraph 7(c) of the Equity Resiliency Decision directed the SGIP PAs to submit SGIP accounting data as of December 31, 2019 via a Tier 1 AL. Thus, we use the compliance filing made by PG&E on January 31, 2020 through AL 36 SCP Protest at A-12.37 Sonoma Clean Power SGIP Assistance webpage. Accessed 6/7/20. https://sonomacleanpower.org/programs/sgipassistance38 D.20-01-021 at 77.39 GRID Protest at 4.

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Resolution E-5086 DRAFT July 16, 2020PG&E AL 4219-G/5765-E, PG&E AL 4226-G/5778-E/NHW4211-G/5747-E as the basis for calculating the maximum allowable amount for PG&E’s ME&O budget. That advice letter states that PG&E had $24,885,964 for administrative funding at the end of 2019.40 Thus, PG&E should have $497,719 annually available for SGIP ME&O funding through 2024.41 This is fairly close to GRID’s estimated budget but significantly lower that PG&E’s requested budget. We find that it is reasonable for PG&E to accelerate ME&O funding by potentially spending more than one-fifth of the total amount in 2020 since costs of outreach efforts will likely be frontloaded in the first year and we are eager to see uptake in the equity resiliency budget as soon as possible.

Next we turn to the funding requested by the protestants. SCP requested ten percent of PG&E’s ME&O budget for 2020 through 2024. Although SCP did not include a value for this figure, based on our analysis above, we calculate that this would be approximately $49,772 annually. This is similar to MCE’s requested SGIP ME&O funding level of $55,000 annually. GRID asserts that 50 percent of PG&E’s ME&O funds ($213,669) should be directed to CCAs, CBOs, and low-income solar PAs and that the PAs should specifically receive $106,834 annually “because the low-income solar PAs cover the entire service of PG&E,17 in contrast to the regional territories served by CCAs and other CBOs.”42

To determine whether to allocate funding to the CCAs and/or low-income solar PAs, we look to what the discussion of this issue in prior SGIP decisions. In comments on the SB 700 Decision in particular, parties (including both MCE and GRID) requested that they be allocated a portion of the PAs’ ME&O funding. While the SB 700 Decision found that it “would be difficult if not impossible for the SGIP PAs to accomplish this targeted and community-based approach without partnering with and appropriately funding interested local governments, CCAs and/or low-income solar PAs”43, it elected to “not direct specific funding carve-outs for ME&O Plan implementation partners as recommended by MCE, GRID and the City of San Jose.”44 We also note a similar statement in the Equity Resiliency Decision 40 Pacific Gas and Electric Tier 1 Compliance Advice Letter to Submit the Final Self Generation Incentive Program Accounting Data as of December 31, 2019 per Decision 19-09-027 (January 31, 2020) at 2.41 $24,885,964.00 * 10% = $2,488,596.40 / 5 = $497,719.2842 GRID Protest at 5-6.43 D.20-01-021 at 77.44 Id.

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Resolution E-5086 DRAFT July 16, 2020PG&E AL 4219-G/5765-E, PG&E AL 4226-G/5778-E/NHWwhich concluded, “We do not approve GRID’s suggestion of a specific allocation of equity budget ME&O funds to specific entities, as the funds should be dispersed as determine necessary via competitive contracts.”45 It is based on this precedent that we deny the CCAs’ request for ME&O funding. We agree that any funding should be competitively awarded and in particular, we refrain from allocating PG&E’s ME&O funding such that it is only available to a subset of customers in its service territory.

We have already seen significant demand for incentives available to vulnerable customers and communities through the equity resiliency budget as PG&E’s portion of funds allocated under the Equity Resiliency Decision ended up in a waitlist within the first few months. Thus, we are eager to cast as wide a net as possible to ensure the equity resiliency funds made available through the SB 700 Decision go to the most vulnerable customers with the greatest need, regardless of location.

Based on a similar rationale, we also reject GRID’s request that the CPUC allocate ME&O funding to it. While GRID correctly underscores its broader reach as it works throughout PG&E’s service territory, we are cognizant of the statement in PG&E’s advice letter that, “the disability rights advocates have expressed concerns of adding a barrier to adoption by focusing on having both solar and battery storage adopted. Adhering to the goal of gaining SGIP adoption as quickly as possible to impact wildfire season, and offer fair and equal territory coverage, PAs are choosing to incorporate rooftop solar in targeting but are not solely focusing on rooftop solar + battery storage."46 In addition, PG&E’s states in reply to GRID’s protest that “solar adoption among highly vulnerable customers is low and, given the timing to wildfire season, market penetration to this audience will be further limited.”47 We are eager to see a strong SGIP collaboration emerge between PG&E and GRID but we do not find it appropriate to direct SGIP ME&O funding to GRID at this time.

The guidance in the Equity Resiliency Decision to make funding available through competitive contracts leads us to the discussion of PG&E’s enrollment fee (capitation) which PG&E appears to use synonymously with referral fee. We support this competitive outreach 45 D.19-09-027 at 96.46 PG&E AL 4219-G/5765-E at 15.47 PG&E Reply to Protests at 6.

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Resolution E-5086 DRAFT July 16, 2020PG&E AL 4219-G/5765-E, PG&E AL 4226-G/5778-E/NHWapproach as it awards funding based on successful customer recruitment into SGIP. To clarify this concept, we instead adopt the term, “Customer Recruitment Incentive”. PG&E’s discussion of its proposed enrollment fee clarifies that it will be earned only if an eligible vulnerable customer successfully submits an SGIP application. However, PG&E fails to both define vulnerable customers and to state what the value of the enrollment fee will be. For this program component, we hereby define a vulnerable customer as any residential customer who is eligible for the equity resiliency budget. Thus, we establish a $300 Customer Recruitment Incentive on a per customer basis once PG&E validates the customer’s eligibility through their SGIP application. In order to account for economies of scale in the customer recruitment process, once an entity has successfully recruited 30 customers to apply to the equity resiliency budget (receiving a total of $9,000 in ME&O funding), the $300 Customer Recruitment Incentive will then be paid out based on the entity referring increments of five customers who successfully apply to the SGIP equity resiliency budget. No single entity may receive more than $100,000 worth of SGIP Customer Recruitment Incentives.

PG&E states that it intends to only make the enrollment fee funding available to its existing CBO network but it fails to state a rationale for doing so. We find no reason to restrict the customer recruitment incentive to only the CBOs that PG&E has previously worked with. In particular, we find that PG&E should make the customer recruitment incentive available to the 200 additional organizations working on access and functional needs that it discusses in its ME&O plan. We also find that that PG&E should make its customer recruitment incentive available to both CCAs and low-income solar PAs. In order to address this larger group of entities that will be eligible, we direct PG&E to replace its $150,000 CBO enrollment fee with a $300,000 Customer Recruitment Incentive. This will result in a total 2020 ME&O budget for PG&E of $765,000.

PG&E’s Financial Assistance Plan

The majority of issues and questions raised in the three responses to PG&E’s SGIP financial assistance advice letter focus on how the pilot will impact residential customers, and in particular, how it could be revised to further benefit them. Thus, we discuss the residential component of PG&E’s proposed financial assistance pilot first. Both Sunrun and GRID appear to recommend expanding PG&E’s pilot to include residential equity customers since GRID’s response seems to

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Resolution E-5086 DRAFT July 16, 2020PG&E AL 4219-G/5765-E, PG&E AL 4226-G/5778-E/NHWrequest upfront funding for all SASH and DAC-SASH projects, regardless of whether customers live in Tier 2 or 3 HFTDs or have experienced at least two discrete PSPS events. PG&E’s AL 4226-G/5778-E makes it clear that PG&E intends to accelerate incentive payments to contractors specifically working with residential customers who are eligible for the equity resiliency budget (ERB). In addition, while PG&E’s AL states that it will work with residential customers who qualify “[i]n accordance with definitions established in D.19-09-027 and D.20-01-021”48, PG&E’s reply more narrowly describes the targeted market as primarily resiliency customers on medical baseline or with a serious condition that could be life-threatening without electricity who have experienced at least two PSPS events, and secondly, eligible medical baseline customers with solar.49

While we agree that enabling customers with medical issues to enhance their resiliency prior to the wildfire season should a top priority, PG&E’s financial assistance pilot should address issues of access to capital faced by customers beyond only those who are medically vulnerable. We note that one of the primary recommendations resulting from the California Energy Commission’s Low-Income Barriers Study was to “continue developing a series of energy upgrade financing pilot programs to evaluate a variety of models to improve access and participation of low-income customers.”50 PG&E’s financial assistance pilot provides an excellent opportunity to help low-income customers overcome access to capital and creditworthiness issues that could otherwise prevent them from benefiting from the residential equity and equity resiliency budgets. For this reason, we direct PG&E to make the accelerated SGIP incentive payment available to contractors working with any residential customer who is eligible for the residential SGIP equity budget (including those in Tier 2 or 3 HFTDs or who have experienced at least two discrete PSPS events), in addition to residential resiliency customers who are on medical baseline or have notified PG&E of a 48 PG&E AL 4226-G/5778-E at 2.49 PG&E Reply to Responses on PG&E AL 4226-G/5778-E at 1. 50 Scavo, Jordan, Suzanne Korosec, Esteban Guerrero, Bill Pennington, and Pamela Doughman. 2016. Low-Income Barriers Study, Part A: Overcoming Barriers to Energy Efficiency and Renewables for Low-income customers and Small Business Contracting Opportunities in Disadvantaged Communities. California Energy Commission. Publication Number: CEC-300-2016-009-CMF. at 7. https://efiling.energy.ca.gov/getdocument.aspx?tn=214830

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Resolution E-5086 DRAFT July 16, 2020PG&E AL 4219-G/5765-E, PG&E AL 4226-G/5778-E/NHWserious illness or condition that could be life-threatening if electricity is disconnected.

Next we turn to GRID’s request that SASH and DAC-SASH customers be eligible to receive 100% of the incentive upfront. This suggestion is somewhat echoed in CALSSA’s request that an amount greater than 50% of the SGIP incentive be made available to customers upfront. We find that PG&E’s proposal to provide 50% of the SGIP incentive upfront once a customer has an incentive officially reserved in the program is appropriate. The proposed construct balances the need to address issues of upfront capital with the need to incentivize contractors to expeditiously complete project installation prior to future PSPS events. It also helps mitigate risk that contractors might submit so-called “phantom projects” that never proceed to fruition. If any such projects are submitted, the proposed 50/50 incentive split limits the amount of funding PG&E will have tied up while it works to recoup these funds from contractors. On this point, we direct PG&E to ensure the participant agreement enables it to recoup funding from contractors who receive upfront funding but do not complete an associated project within 12 months from the date the upfront funding was received.51 PG&E may also elect to shorten the project completion deadline if it so choses but this must be clearly stated in the participant agreement. GRID does, however, raise an important point that low-income customers should not be asked to bear the remaining project costs until the project is completed as this would pose a burden that would likely continue to limit participation. As stated in its ME&O plan AL, PG&E had proposed that the pilot “will be to offer 50% of the eligible incentive as an advance incentive payment to the contractor in exchange for no upfront cost to the customer. "52 (Emphasis added) Thus, we direct PG&E, through the participant agreement to require contractors to legally affirm that they will not charge a residential SGIP host customer any out of pocket costs. If the cost of a given project is greater than the SGIP incentive it receives, participating contractors may only recoup such costs from customers

51 We set the deadline for projects to be completed as 12 months from the date the upfront funding was received based on the existing SGIP rules that Incentive Claim Form (ICF) documents must be received within 12 months of the Confirmed Reservation date. Given that the purpose of the pilot is to expedite these projects, we do not allow for any extensions. SGIP Handbook at 15, Figure 2.2-2. https://www.selfgenca.com/documents/handbook/2020 52 PG&E AL 4219-G/5765-E at 3.

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Resolution E-5086 DRAFT July 16, 2020PG&E AL 4219-G/5765-E, PG&E AL 4226-G/5778-E/NHWafter the project is completed and the SGIP incentive has been paid. PG&E must ensure that the participant agreement includes the following statement, borrowing from the Equity Resiliency Decision and the SGIP Program Handbook, “Vendors/developers shall not sell a residential storage system that receives incentives for a total price (before incentives) that is greater than the price they sell a comparable system that does not receive incentives.”53 We further direct PG&E to bar any contractor who is found to overcharge or prematurely charge customers to be permanently barred from further participation in the financial assistance pilot.

Both Sunrun and GRID seek clarity on which contractors will be allowed to participate in PG&E’s financial assistance pilot. While we recognize the urgency expressed by Sunrun to expedite contractor participation in the pilot and the associated access to capital, we are persuaded by GRID’s statement on the importance of allowing participation by new contractors. A key rationale for increasing the equity budget incentive and creating the equity resiliency budget was to better enable SGIP to reach new groups of customers who have been historically underserved by the program. Thus, we are eager to see both existing SGIP contractors and new entrants work with customers eligible for the equity and equity resiliency budgets. We find PG&E’s proposal to check participating contractors’ licenses, verify that participating contractors have a sufficient level of insurance, and confer with the Better Business Bureau on the status of participating contractors to be a sufficiently robust vetting process. To expedite access to the pilot and address Sunrun’s concerns about unnecessary delay, we direct PG&E to make a determination on a contractor’s ability to participate in the pilot within 15 days of receiving a complete application. We also echo Sunrun in noting that PG&E should “utilize existing enforcement measures in SGIP to prevent gaming, such as imposing infractions, suspensions, or expulsions for contractors who do not comply with the rules.”54

The last issue raised in regard to the residential portion of PG&E’s financial assistance pilot is CALSSA’s request that PG&E clarify at what stage of the application process PG&E will pay the upfront portion of the incentive to pilot participants. PG&E does not clarify its planned process in its response. As described above, we have interpreted the proposal to be that PG&E will pay out half the value of

53 Equity Resiliency Decision at 38.54 Sunrun Response at 2.

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Resolution E-5086 DRAFT July 16, 2020PG&E AL 4219-G/5765-E, PG&E AL 4226-G/5778-E/NHWthe incentive as soon as the residential customer’s incentive is officially reserved in SGIP, i.e. when a confirmed reservation letter is issued. We direct PG&E to implement its pilot in this fashion.

Finally, there is clearly an interest in potentially revising the pilot in the future which both underscores the need for robust data collection and reporting. For example, Sunrun requests that PG&E consider extending the pilot to all SGIP residential customers in the future and PG&E states that it looks forward to working with stakeholders and the Energy Division to determine how to enhance the pilot in the future. In its reply, PG&E acknowledges that, "The Pilot will be closely tracked by PG&E and evaluated by PG&E and the Energy Division."55 To support Energy Division’s ability to evaluate the pilot, after the first advance is paid, we direct PG&E to file a report on the first of every month with Energy Division that provides the following information on each residential SGIP equity or equity resiliency project participating in the pilot:

- Eligibility pathway used by host customer and the budget they

applied to;- Value of incentive paid;- Entity/contractor that the incentive was paid to;- The total project cost as submitted by the developer or contractor;- Date of upfront payment; and,- Date of project completion (once available).

The report shall also detail the number of cancelled pilot projects and the amount of time until the advance was repaid in full. In addition, on a quarterly basis, starting at the end of Q3 2020, PG&E shall report to the service list for the SGIP proceeding, R.20-05-012, the following, aggregated information:

- Number of projects receiving advances;- Total value of advances paid;- List of participating contractors; and,- Number of cancelled pilot projects.

In summary, we support PG&E’s residential component of its financial assistance pilot, as there is increasing urgency of enabling as many residential customers as possible to install energy storage prior to the 55 PG&E Reply to Responses on PG&E AL 4226-G/5778-E at 2.

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Resolution E-5086 DRAFT July 16, 2020PG&E AL 4219-G/5765-E, PG&E AL 4226-G/5778-E/NHWcommencement of wildfires and PSPS events. We look forward to evaluating the pilot with PG&E in early 2021 to determine whether it should be renewed prior to the 2021 wildfire season. Next we turn to the non-residential component of PG&E’s financial assistance pilot.

As noted earlier, the responses to PG&E’s financial assistance pilot focused almost exclusively on the residential portion of PG&E’s pilot with the exception of CALSSA’s request that PG&E clarify which non-residential customers would be able to participate in the revolving loan fund through on-bill financing (OBF). This demonstrates a greater interest in and presumably a greater need for upfront capital by residential customers as compared to non-residential customers. This need can also be gleaned from GRID’s use of the SGIP equity resiliency application statistics as of late March to demonstrate a perceived waning interest in the equity resiliency budget. In reality, when GRID pulled this data, the equity and equity resiliency budgets were only open to residential customers. When the equity and equity resiliency budgets opened to non-residential customers in mid-May, demand exceeded the initial $100 million available within the first week in most SGIP service territories. Simply put, it appears that there are fewer barriers for non-residential customers to participate in the equity and equity resiliency budgets than there are for residential customers.

It is in this context that we evaluate the non-residential component of PG&E’s financial assistance pilot. We first turn to the question raised by CALSSA about which non-residential customers will be allowed to participate. While PG&E’s reply states that it only intends to make the pilot available to non-residential customers who are eligible for the equity resiliency budget, it remains unclear whether it intends for non-residential, critical infrastructure customers applying to the SGIP renewable generation technology budget to be eligible. Notably, PG&E fails to provide any rationale for why it would chose to not extend the pilot to non-residential customers eligible for the resiliency adder for renewable generation technologies. As stated in the SB 700 Decision:

“Renewable generation technologies can provide critical resiliency services to non-residential customers serving their communities during PSPS events. Providing a significant incentive adder for renewable generation projects for customers with critical resiliency needs supports such customers’ ability to weather PSPS events

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Resolution E-5086 DRAFT July 16, 2020PG&E AL 4219-G/5765-E, PG&E AL 4226-G/5778-E/NHW

and reflects the Commission’s desire to prioritize use of SGIP incentives by customers facing wildfire related outages."56

Given that the CPUC’s rationale for creating the resiliency adder for renewable generation projects closely aligns with PG&E’s state goal to “to help to mitigate against the impacts of future PSPS events"57, we feel that it should have been explicitly and clearly included in the pilot. If PG&E did intend to exclude this group, it needed to have provided a justification for why it found this was necessary.

In addition to an articulated rationale on why only certain non-residential customers with critical resiliency needs are eligible for its pilot, we find that other critical details on PG&E’s revolving loan fund through OBF are lacking. In particular, PG&E fails to clarify what portion of the non-residential equity resiliency incentive it will make available upfront and how this will impact the current SGIP incentive payment structure for non-residential projects under which 50 percent of the incentive is paid post installation for non-residential projects and the other 50 percent is paid over the five years after installation based on meeting established metrics for performance based incentives (PBI). Through subsequent discussion with PG&E, Energy Division understands that PG&E plans to make 50 percent of the value of the incentive available upfront which would then be paid back through OBF. Then, PG&E’s SGIP would still pay 50% of the incentive post-installation. PG&E would aim to align the OBF payments to correlate with the five year PBI period so that the customer would be incentivized to meet performance metrics in order to more efficiently pay off the no-interest loan.

While we support PG&E’s innovation here, there are still critical details that need to be more fully vetted through the advice letter process. For this reason, we reject without prejudice the non-residential component of PG&E’s financial assistance pilot. We encourage PG&E to revise its non-residential financial assistance proposal with additional detail and added clarity on customer eligibility and resubmit this as an additional pilot through a separate advice letter filing. Given the volume of applications submitted to the non-residential equity budget and by non-residential customers to the equity resiliency budget, we feel there is less risk that denying the

56 SB 700 Decision at 51.57 PG&E Reply to Responses on PG&E AL 4226-G/5778-E at 2.

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Resolution E-5086 DRAFT July 16, 2020PG&E AL 4219-G/5765-E, PG&E AL 4226-G/5778-E/NHWnon-residential component of PG&E’s advice letter will delay participation of non-residential customers in SGIP.

COMMENTS

Public Utilities Code Section 311(g)(1) provides that this resolution must be served on all parties and subject to at least 30 days public review. Please note that comments are due 20 days from the mailing date of this resolution. Section 311(g)(2) provides that this 30-day review period and 20-day comment period may be reduced or waived upon the stipulation of all parties in the proceeding. The 30-day review and 20-day comment period for the draft of this resolution was neither waived nor reduced.

FINDINGS AND CONCLUSIONS

1. Assembly Bill (AB) 970 (Ducheny, Stats. 2000, Ch. 329) directed the California Public Utilities Commission (CPUC) to provide incentives for distributed generation resources to reduce peak energy demand.

2. The Self-Generation Incentive Program (SGIP) was established by the CPUC in 2001 in Decision (D.) 01-03-073 in response to AB 970.

3. Since 2001, the California State Legislature has refined and extended SGIP several times, including expanding the program to include energy storage technologies.

4. SGIP is jointly administered by Pacific Gas and Electric Company (PG&E), Southern California Edison Company (SCE), Southern California Gas Company (SoCalGas), and the Center for Sustainable Energy (CSE) on behalf of San Diego Gas & Electric Company (SDG&E), jointly the SGIP Program Administrators (PAs).

5. On September 18, 2019, the CPUC issued Decision (D.)19-09-027 Decision Establishing a Self-Generation Incentive Program Equity Resiliency Budget, Modifying Existing Equity Budget Incentives, Approving Carry-Over Of Accumulated Unspent Funds, And Approving $10 Million To Support The San Joaquin Valley Disadvantaged Community Pilot Projects (Equity Resiliency Decision).

6. The Equity Resiliency Decision created a new equity resiliency budget with a $1.00 per watt hour (Wh) incentive for customers residing in Tier 2 and Tier 3 High Fire Threat Districts (HFTDs) who are either non-residential customers that provide certain

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Resolution E-5086 DRAFT July 16, 2020PG&E AL 4219-G/5765-E, PG&E AL 4226-G/5778-E/NHW

critical services or infrastructure to vulnerable communities or residential customers who are eligible for the SGIP equity budget, on medical baseline, have notified their utility of a serious illness or condition that could become life threatening if electricity is disconnected, or have participated in one of the CPUC’s low-income solar programs.

7. The Equity Resiliency Decision modified the SGIP equity budget incentive level from $0.50 per Wh to $0.85 per Wh to increase participation.

8. The Equity Resiliency Decision established the first ever carveout for SGIP Marketing Education and Outreach (ME&O) funding within the SGIP PAs’ administrative funds and directed the PAs to develop a ME&O plan describing how they will use this funding to promote SGIP equity incentives alongside incentives available under the CPUC’s low-income solar programs.

9. On December 17, 2019, the SGIP PAs filed a preliminary statewide ME&O plan through a joint advice letter (AL), PG&E AL 4191-G/5714-E at al. The Energy Division subsequently approved this AL on February 26, 2020.

10. On January 14, 2020 the SGIP PAs conducted an ME&O workshop with stakeholders to discuss the PAs’ intended outreach approaches and solicit stakeholder feedback.

11. On January 27, 2020, the CPUC issued Decision (D.)20-01-021 Self-Generation Incentive Program Revisions Pursuant to Senate Bill 700 and Other Program Changes (SB 700 Decision) which authorizes ratepayer collections of $166 million annually for the years 2020 to 2024 to fund SGIP consistent with the authorization established by Senate Bill 700 (Wiener, 2018).

12. The SB 700 Decision increased funding for the equity resiliency budget and expanded its eligibility criteria to include customers who have experience at least two discrete Public Safety Power Shutoff (PSPS) events in addition to meeting the other equity criteria.

13. The SB 700 Decision added additional types of facilities to the list that qualify as critical infrastructure for non-residential equity resiliency eligibility and included customers who rely on electric well pumps in the group of residential customers eligible for equity resiliency incentives.

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Resolution E-5086 DRAFT July 16, 2020PG&E AL 4219-G/5765-E, PG&E AL 4226-G/5778-E/NHW14. Through the Equity Resiliency Decision and the SB 700 Decision,

the CPUC allocated over $612 million for the equity resiliency budget and new funding of over $24 million to the equity residential budget.

15. The SB 700 Decision directed each SGIP PA to allocate approximately 10 percent of their adopted annual administrative allocations to the customized ME&O plan required in the Equity Resiliency Decision.

16. On February 18, 2020, the SGIP PAs submitted a revised, statewide ME&O plan through a joint AL, PG&E AL 4218-G/5764-E at al. The Energy Division subsequently approved this AL on April 9, 2020.

17. On February 20, 2020, PG&E submitted AL 4219-G/5765-E, with its territory-specific SGIP Residential Equity Resiliency Marketing Plan and Implementation Strategy.

18. On March 6, 2020, PG&E filed AL 4226-G/5778-E in which it requested to create a financial assistance pilot within SGIP.

19. On March 11, 2020, Sonoma Clean Power Authority (SCP), Marin Clean Energy (MCE), and GRID Alternatives (GRID) each filed a timely protest to PG&E’s ME&O Plan filed through PG&E AL 4219-G/5765-E.

20. On March 18, 2020 PG&E replied to the protests of its ME&O Plan (PG&E AL 4219-G/5765-E) that were filed by SCP, MCE, and GRID.

21. On March 26, 2020 Sunrun Inc. (Sunrun), GRID, and the California Solar & Storage Association (CALSSA) each filed a timely response to PG&E’s Financial Assistance Pilot, PG&E AL 4226-G/5778-E.

22. On April 2, 2020, PG&E replied to the responses on its Financial Assistance Pilot (PG&E AL 4226-G/5778-E), that were submitted by Sunrun, GRI), and CALSSA.

23. The California wildfire season annually commences in approximately late May and typically extends through October.

24. In order to expedite outreach to vulnerable customers as early as possible in the 2020 wildfire season, it is necessary to expedite approval of PG&E’s 2020 SGIP ME&O Plan.

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Resolution E-5086 DRAFT July 16, 2020PG&E AL 4219-G/5765-E, PG&E AL 4226-G/5778-E/NHW25. PG&E proposed a ME&O budget of $615,000.

26. In its SGIP ME&O Plan, PG&E proposed to create a program toolkit that can be used by community based organizations (CBOs) to educate customers about SGIP.

27. It is appropriate for PG&E to work with SCP, MCE, GRID, and any other Community Choice Aggregators (CCAs) or low-income solar program administrators (PAs) that express interest to develop and refine PG&E’s SGIP program toolkit.

28. It is appropriate for PG&E to prioritize SGIP outreach to customers who have experienced two or more discrete PSPS events or who live in Tier 2 or Tier 3 HFTDs and who are enrolled in both medical baseline and the California Alternative Rates for Energy (CARE) or Family Energy Rate Assistance (FERA) programs as a proxy for customers who are low-income.

29. PG&E proposed $150,000 in its ME&O budget for a CBO enrollment fee.

30. It is appropriate to add $150,000 toward the PG&E’s CBO enrollment fee, bringing it to $300,000 for 2020 and to rename this component the SGIP Customer Recruitment Incentive.

31. The SB 700 Decision directed that the SGIP ME&O Plan to be updated on an annual basis.

32. It is reasonable for PG&E to submit a revised SGIP ME&O plan for 2021, developed in consultation with interested stakeholders including CCAs and low-income solar PAs by January 11, 2020.

33. It is appropriate for PG&E’s SGIP Customer Recruitment Incentive to be available to CBOs, organizations that work with individuals with access and functional needs, CCAs, and low-income solar PAs. The SGIP Customer Recruitment Incentive will be provided once an eligible residential customer that is referred to SGIP by the entity applies for the equity resiliency budget and PG&E validates the customer’s eligibility through their SGIP application. The value of this incentive will be is $300 per customer for the first 30 verified customers and the $300 for every additional group of five verified customers.

34. No single entity participating in the SGIP Customer Recruitment Incentive component may receive more than $100,000 worth of SGIP Customer Recruitment Incentives.

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Resolution E-5086 DRAFT July 16, 2020PG&E AL 4219-G/5765-E, PG&E AL 4226-G/5778-E/NHW35. PG&E provided limited details on the non-residential component

of its financial assistance pilot.36. It is reasonable to reject the non-residential portion of PG&E’s

financial assistance pilot without prejudice.37. The Equity Resiliency Decision required the SGIP PAs to include

the following statement in the SGIP Handbook, “Vendors/developers shall not sell a residential storage system that receives incentives for a total price (before incentives) that is greater than the price they sell a comparable system that does not receive incentives.” It is reasonable for PG&E to include this same phrase in its SGIP financial assistance participant agreement.

38. It is appropriate for PG&E to permanently bar any contractor who is found to have charged a residential SGIP host customer participating in the pilot any out of project costs prior to project completion and receipt of the full SGIP incentive and any contractor who is found to have overcharged customers from participating in the financial assistance pilot.

39. It is reasonable for PG&E to check a contractor’s license, verify that they have a sufficient level of insurance, and confer with the Better Business Bureau on the status of the contractor prior to allowing a contractor to participate in PG&E’s financial assistance pilot.

40. It is reasonable for PG&E to make a determination on a contractor’s ability to participate in the pilot within 15 days of receiving a complete application.

41. Enforcement measures, including imposing infractions, suspensions, or expulsions already exist in SGIP. It is reasonable for PG&E to use these measures to take action against any contractors who do not comply with the rules of PG&E’s residential financial assistance pilot.

42. It is reasonable for PG&E’s SGIP incentive budget to provide the upfront half of the incentive to residential financial assistance pilot participants when a confirmed reservation letter is issued.

43. Regular reporting on outcomes of PG&E’s residential financial assistance pilot is necessary for future evaluation and potential reforms to the pilot.

44. It is reasonable for PG&E on the first of every month, commencing the first month after it issues its first upfront payment to a residential equity or equity resiliency project, to submit to the

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Resolution E-5086 DRAFT July 16, 2020PG&E AL 4219-G/5765-E, PG&E AL 4226-G/5778-E/NHW

Energy Division a report on the progress and outcomes of its residential financial assistance pilot.

45. It is reasonable for PG&E on a quarterly basis, starting at the end of the third quarter of 2020, to serve a report to the service list for the SGIP proceeding, R.20-05-012, with aggregated information on the progress and outcomes of its residential financial assistance pilot

THEREFORE IT IS ORDERED THAT:

1. Pacific Gas and Electric Company’s Advice Letters are approved with the modifications set forth below and otherwise specified herein.

2. Pacific Gas and Electric Company shall solicit feedback from Sonoma Clean Power Authority, Marin Clean Energy, other Community Choice Aggregators (CCAs), GRID Alternatives, and low-income solar program administrators that express interest in the development of its Self-Generation Incentive Program (SGIP) Program Toolkit.

3. Pacific Gas and Electric Company shall make the final version of its Self-Generation Incentive Program (SGIP) Program Toolkit publicly available for download on its website within 30 days of adoption of this Resolution.

4. Pacific Gas and Electric Company shall prioritize SGIP outreach to customers who have experienced two or more discrete Public Safety Power Shutoff (PSPS) events or who live in Tiers 2 or 3 High Fire Threat Districts (HFTDs) and who are enrolled in both medical baseline and the California Alternative Rates for Energy (CARE) or Family Energy Rate Assistance (FERA) programs.

5. Pacific Gas and Electric Company shall submit a revised Self-Generation Incentive Program (SGIP) Marketing Education and Outreach (ME&O) plan for 2021, developed in consultation with Choice Aggregators (CCAs) and low-income solar program administrators (PA), via a Tier 2 advice letter by January 11, 2021.

6. Pacific Gas and Electric Company’s (PG&E) 2020 Marketing Education and Outreach (ME&O) budget is approved with the addition of $150,000 toward the PG&E’s community based organization (CBO) enrollment fee which shall be called the Self-Generation Incentive Program (SGIP) Customer Recruitment Incentive. PG&E shall allocate a total of $300,000 to its SGIP

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Resolution E-5086 DRAFT July 16, 2020PG&E AL 4219-G/5765-E, PG&E AL 4226-G/5778-E/NHW

Customer Recruitment Incentive that will be available to CBOs in its existing network, as well as organizations that work with individuals with access and functional needs, community choice aggregators (CCAs), and low-income solar program administrators (PAs).

7. Pacific Gas and Electric Company’s (PG&E) Self-Generation Incentive Program (SGIP) Customer Recruitment Incentive shall be available to entities once an eligible residential customer that they referred to SGIP applies for the equity resiliency budget and PG&E validates the customer’s eligibility through their SGIP application. The value of this incentive is $300 per customer for the first 30 verified customers.

8. To account for economies of scale in the customer recruitment process, once an entity has been awarded Self-Generation Incentive Program (SGIP) Customer Recruitment Incentives for 30 customers, the entity will then receive the $300 customer recruitment incentive based on each group of five customers it refers to SGIP who successfully apply to the equity resiliency budget. No single entity may receive more than $100,000 worth of SGIP Customer Recruitment Incentives.

9. The non-residential component of Pacific Gas and Electric Company’s (PG&E) Financial Assistance Pilot proposed in PG&E AL 4226-G/5778-E is rejected without prejudice.

10. Pacific Gas and Electric Company (PG&E) shall make its residential financial assistance pilot available to all residential customers who are eligible for the SGIP equity budget in addition to residential customers who are eligible for the equity resiliency budget by nature of their enrollment on Medical baseline or having voluntarily notified PG&E of a medical condition that would be life-threatening without electricity.

11. Pacific Gas and Electric Company will ensure that its Self-Generation Incentive Program (SGIP) financial assistance participant agreement enables the utility to recoup funding from contractors who receive upfront funding but do not complete the associated project within a maximum of 12 months from the date the upfront funding was received.

12. Pacific Gas and Electric Company, through its Self-Generation Incentive Program (SGIP) financial assistance participant agreement, shall require contractors to legally affirm that they will not charge the residential SGIP host customer any out of pocket costs prior to the SGIP incentive being paid.

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Resolution E-5086 DRAFT July 16, 2020PG&E AL 4219-G/5765-E, PG&E AL 4226-G/5778-E/NHW13. Pacific Gas and Electric Company shall ensure that its Self-

Generation Incentive Program (SGIP) financial assistance participant agreement includes the following: “Vendors/developers shall not sell a residential storage system that receives incentives for a total price (before incentives) that is greater than the price they sell a comparable system that does not receive incentives.”

14. Pacific Gas and Electric Company shall permanently bar from participating in the financial assistance pilot, any contractor who is found to have charged a residential host customer participating in the pilot any out-of-project costs prior to project completion and receipt of the full Self-Generation Incentive Program (SGIP) incentive, as well as any contractor who is found to have overcharged customers.

15. Pacific Gas and Electric Company (PG&E) shall check a contractor’s license, verify that they have a sufficient level of insurance, and confer with the Better Business Bureau on the status of the contractor prior to allowing a contractor to participate in PG&E’s financial assistance pilot.

16. Pacific Gas and Electric Company shall make a determination on a contractor’s ability to participate in the pilot within 15 days of receiving a complete application.

17. Pacific Gas and Electric Company shall utilize existing Self-Generation Incentive Program (SGIP) enforcement measures, including imposing infractions, suspensions, or expulsions for contractors who do not comply with the rules of the financial assistance pilot.

18. Pacific Gas and Electric Company’s Self-Generation Incentive Program (SGIP) incentive budget shall provide the upfront half of the incentive to residential financial assistance pilot participants when a confirmed reservation letter is issued.

19. On the first of every month, commencing the first month after Pacific Gas and Electric Company (PG&E) issues its first upfront payment to a residential equity or equity resiliency project, PG&E shall submit to the Energy Division a report that details the number of cancelled pilot projects and how long it took for the associated advances to be repaid in full and provides the following information on each participating pilot: the eligibility pathway used by the host customer and the budget they applied to; the value of the incentive paid; the name of the entity/contractor that the incentive was paid to; the total project cost as submitted by the developer/contractor;

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Resolution E-5086 DRAFT July 16, 2020PG&E AL 4219-G/5765-E, PG&E AL 4226-G/5778-E/NHW

the date of upfront payment; and, the date of project completion (once available).

20. On a quarterly basis, starting at the end of the third quarter of 2020, Pacific Gas and Electric Company shall serve a report to the service list for the Self-Generation Incentive Program (SGIP) proceeding, R.20-05-012, aggregated information on the number of projects receiving advances, the total value of advances paid, the list of participating contractors, and the number of cancelled projects.

This Resolution is effective today.

I certify that the foregoing resolution was duly introduced, passed and adopted at a conference of the Public Utilities Commission of the State of California held on July 16, 2020; the following Commissioners voting favorably thereon:

_____________________ALICE STEBBINS

Executive Director

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