BILL ANALYSIS Ó 1
SENATE ENERGY, UTILITIES AND COMMUNICATIONS COMMITTEE
ALEX PADILLA, CHAIR
AB 415 - Garcia Hearing Date:
June 18, 2013 A
As Amended: April 24, 2013 FISCAL B
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DESCRIPTION
Current law states that to be eligible for gas customer-funded
incentive rebate, solar water heaters and solar collectors must
at minimum have an SRCC OG-300 or SRCC OG-100 certification,
respectively. The building using the system must be connected to
a natural gas utility's distribution system within the state.
The system must also be warrantied for 10 years, and have a
device to measure system performance and energy generated or
displaced. (PUC §2864)
This bill modifies the eligibility criteria to require that the
solar water heating systems must be certified by an accredited
listing agency according to pre-established standards from Solar
Rating & Certification Corporation (SRCC), International
Organization on Standardization (ISO) or American Society of
Heating, Refrigerating, and Air-Conditioning Engineers (ASHRAE).
The bill also permits the adoption of future standards for the
CSI-Thermal program.
BACKGROUND
The Solar Water Heating and Efficiency Act of 2007 (AB 1470)
directed the California Public Utilities Commission (CPUC) to
establish a program to promote the installation of 200,000 solar
water heating systems in homes and businesses by 2017. The
program is funded through a surcharge on gas customers and is
limited to $250 million in funding over the 10 years of the
program. The surcharge funds rebates for installing solar water
heating systems, but those systems must first be certified that
they meet certain performance requirements. The act originally
called for certification through the SRCC. The California Solar
Initiative (CSI) Thermal program administrators are Pacific Gas
& Electric, Southern California Edison, Southern California Gas,
and the California Center for Sustainable Energy.
The SRCC is a non-profit organization providing performance
standards and certifications for solar thermal products.
Certification of solar water heating collectors and systems
involves evaluating and comparing the equipment to established
standards. The SRCC OG-100 and OG-300 standards included
provisions addressing the internal administration of the
certification program. Therefore, any entity that acted in
accordance with those standards and certified a product would
have that certification accepted by the CSI Thermal program
administrators. The SRCC standards have recently been updated,
and the OG-100 and OG-300 standards are obsolete.
The new SRCC Standard 300 and Standard 100 define standards
including system design, reliability and durability, safety,
operation and servicing, installation, and documentation for
solar water heating systems, and solar collectors, respectively.
The new standards do not include provisions of administering the
certification. This effectively establishes the SRCC as the only
entity qualified to issue a certification. Other organizations
that produce standards or certify equipment for solar collectors
are the ISO and the ASHRAE.
In response to a petition by EchoFirst, Inc., the CPUC found
that the International Association of Plumbing and Mechanical
Officials (IAPMO) is qualified to certify solar water heating
systems according to SRCC standards.<1> In the same decision,
the CPUC established a process by which other entities that are
accredited by the American National Standards Institute could
also be approved to certify solar water heating equipment. Other
CSI Thermal program participants who want acceptance of SRCC
certifications rendered by entities other than SRCC and IAPMO
may submit a letter to the CSI Thermal program administrators
requesting that the entities be accepted.
COMMENTS
1. Author's Intent . The author intends to enable an open
and competitive market for certification services by
updating statute to be consistent with current policies at
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<1> CPUC D.11-11-004
the CPUC.
2. Comparison to Similar Programs . The US Environmental
Protection Agency administers the Energy Star program that
certifies energy efficient products. In order to earn the
label, Energy Star products must be third party certified
based on testing in EPA-recognized laboratories. In
addition to up-front testing, a percentage of all Energy
Star products are subject to "off-the-shelf" verification
testing each year. The goal of this testing is to ensure
that changes or variations in the manufacturing process do
not undermine a product's qualification with Energy Star
requirements.
This bill proposes that the certification of solar water
heating collectors and systems follow a similar process.
The certification is performed by independent third party
laboratories that test the products and compare them to
published standards. The bill ensures that the laboratories
are qualified to perform the testing by specifying that
they should be accredited listing agencies. The bill does
not specify the agency that performs the accreditation of
the testing laboratories. However, this is specified in the
CPUC decision as the American National Standards Institute.
3. Future Considerations . The standards specified in the
bill may not cover new equipment that is developed in the
future. This bill also allows for future standards to be
adopted as long as those standards are developed by an
accredited entity.
4. Codified Standards . Given that the initial problem
specified by the author is that the standards specified in
the code section became obsolete and established an
effective monopoly after being revised, it may be a prudent
solution to strike mention of specific standards in the
code section. In order to avoid a similar situation in the
future, the code could simply provide the CPUC the
authority to ratify a set of standards and the authority to
adopt new standards as is appropriate for the success of
the CSI Thermal program.
The author may wish to consider amendments that strike the
specified standards and maintain the requirement that the
solar water heating systems be certified by an accredited
listing agency in accordance with standards developed by an
accredited standard developer and adopted by the
commission.
ASSEMBLY VOTES
Assembly Floor (74-0)
Assembly Appropriations Committee (17-0)
Assembly Utilities and Commerce Committee
(14-0)
Assembly Rules Committee (11-0)
POSITIONS
Sponsor:
California Solar Energy Industries Association
Support:
Aquatherm Industries, Inc.
Aztec Solar Inc.
International Association of Plumbing and Mechanical Officials
Solar Energy Industries Association
Oppose:
None on file.
Kyle Hiner
AB 415 Analysis
Hearing Date: June 18, 2013