BILL ANALYSIS Ó 1
SENATE ENERGY, UTILITIES AND COMMUNICATIONS COMMITTEE
ALEX PADILLA, CHAIR
SB 37 - De León Hearing Date:
April 30, 2013 S
As Amended: April 9, 2013 FISCAL B
3
7
DESCRIPTION
Current law requires California's electric utilities to first
meet their energy needs through cost effective energy efficiency
measures before renewable and conventional generation.
Current decisions of the California Public Utilities Commission
(CPUC) require investor-owned utilities (IOUs) to administer
energy efficiency programs in multi-year portfolios designed to
meet pre-established energy savings goals and funded by
ratepayer charges, currently at about $1 billion per year.
This bill authorizes the CPUC to require IOUs to develop and
implement residential on-bill repayment (OBR) programs for
eligible energy efficiency, renewable energy, distributed
generation, energy storage, or demand response improvements
under which a customer pays down a loan from a third-party
lender with payments that are listed as a separate line item on
the customer's utility bill.
This bill requires an OBR obligation to "run with the meter,"
meaning that any subsequent owner or tenant of a property is
required to assume the obligation to make remaining OBR payments
on the loan as a condition of getting electric or gas service at
that location.
Current law and CPUC decisions establish an escalating series of
procedures for a utility to follow when a residential customer
fails to pay charges for utility service, including customer
notice, payment options, site visits, and culminating with
service disconnection.
Current law prohibits utilities from disconnecting residential
service for nonpayment of debt owed to a third party.
This bill would make a residential customer who fails to make an
OBR payment subject to service disconnection as an exception to
the prohibition on terminating service for nonpayment of
third-party debt.
Current law requires the CPUC to respond to customer complaints
about utility service, including billing issues, and to resolve
complaints informally or through formal hearing procedures.
This bill prohibits the CPUC, and the utility, from providing a
forum for any customer dispute regarding a customer's obligation
to make an OBR payment, including any customer complaint that
the OBR improvement did not reduce the monthly utility bill as
promised.
This bill requires "bill neutrality" for OBR programs so that a
utility customer's annual OBR repayment charges are less than or
equal to the projected annual electric and gas savings arising
from the energy improvements financed with an OBR loan.
This bill authorizes the CPUC to limit the application of the
bill neutrality requirement after two years, except that OBR
obligations for lower income households and tenants shall always
be bill neutral.
This bill requires the CPUC to establish a method to determine
bill neutrality for each utility customer's OBR project, and
authorizes the CPUC to include changes in an owner's "expected
operating and maintenance costs" in calculating bill neutrality.
This bill authorizes a multi-unit property owner to finance an
eligible energy improvement through an OBR loan with each tenant
allocated a portion of the monthly payment, which the tenant is
obligated to pay as a condition of getting utility service.
This bill requires every owner of real property subject to an
OBR obligation to deliver to a prospective tenant, prior to
signing a lease or rental agreement, a notice of any OBR
obligation under a standard notice and disclosure form but
provides that a lease shall not be invalidated because of
failure to provide the notice.
This bill requires every seller of real property subject to an
OBR repayment obligation to deliver to the buyer a notice of
that OBR obligation under a standard notice and disclosure form
and provides that, once that form is delivered, the seller is
not required to provide the buyer any additional information
about the OBR obligation.
This bill requires an OBR lender to record a notice of OBR
obligation, including that it survives changes in ownership,
with the county recorder's office where an affected property is
located.
This bill authorizes the IOUs to recover actual costs of
establishing and administering the OBR program and requires the
CPUC to approve a utility's request for recovery of actual costs
for all judgments, settlements, costs, and expenses, including
attorney's fees, and other liabilities in connection with
federal lending, credit, and debt collection and servicing laws.
This bill requires the CPUC, to the extent feasible and
cost-effective, to develop a loan-loss reserve or loan guarantee
program as part of an OBR program for residential energy
efficiency improvements to be directed to "residential customers
who experience disproportionate bill impacts from summer cooling
and other demands on the electrical system that cause excessive
usage and potentially significant bill impacts." If these
customers fail to make an OBR payment, the loan reserve would
pay the lender rather than the customer getting service
disconnected.
This bill requires the CPUC to ensure that any OBR program
include consumer protections for residential customers,
including protections to prevent increases in the expected
number of service terminations.
This bill would require the CPUC to establish other OBR program
requirements including eligibility criteria for types of
improvements and projects, the establishment of energy and cost
savings evaluation standards and requirements, prepayment
options, and project inspection services or requirements.
BACKGROUND
Billions for Energy Efficiency Programs - Energy efficiency is
California's top strategy for reducing energy use and meeting
the state's energy needs. Energy efficiency is at the top of the
"loading order," and California's utilities are required to
first meet their energy needs through cost-effective energy
efficiency measures before renewable and conventional
generation. According to a December 2012 LAO report, California
has invested at least $9.5 billion in ratepayer and taxpayer
funds for energy efficiency programs that provide financial
incentives and rebates for installing energy efficient
appliances, lighting, windows, HVAC systems and other
technologies or measures, including:
$1 billion per year from IOU ratepayers for programs
approved by the CPUC through 2014, with $220 million for
financing and expansion of the "Energy Upgrade
California" program offering residential energy
efficiency incentives and rebates up to $4,500 per
customer.
$25 million in ratepayer funds for a "Clean Energy
Upgrade Financing" program required by ABx1 14 (Skinner,
2011) to finance energy efficiency retrofits with loans
administered by the California Alternative Energy and
Advanced Transportation Financing Authority (CAEATFA)
within the State Treasurer's Office.
$300 million per year from IOU ratepayers for free
energy efficiency and weatherization services for IOU
low-income customers approved by the CPUC.
$30 million per year in federal funding for free
weatherization services for low-income residents
administered by the California Department of Community
Services and Development (CDCS).
$185 million in one-time funding for free
weatherization services for low-income residents from the
American Recovery and Reinvestment Act of 2009 (ARRA)
administered by CDCS.
$280 million in one-time ARRA funds for energy
efficiency programs administered or coordinated by the
California Energy Commission (CEC), including Energy
Upgrade California and several pilot programs designed to
develop best practices for energy efficiency retrofits of
California's buildings constructed prior to adoption of
Title 24 energy efficiency building standards. These
pilots are intended to help CEC develop a comprehensive
energy efficiency strategy for this old building stock,
as required by AB 758 (Skinner, 2009).
On Bill Repayment - OBR allows repayment of a third-party loan
with a monthly payment on a utility bill. It can be an
affordable and attractive option for residential customers to
invest in energy efficiency measures if the loan repayment
period is long enough so that monthly payments are offset by the
energy savings from the measure. For example, a homeowner with a
monthly utility bill of $175 may borrow $7,200 for duct sealing,
a programmable thermostat, new windows, and a new refrigerator,
which together are projected to cut $70 from the monthly utility
bill. With a 15-year loan at 5 percent interest, the monthly
loan payment would be $57. The homeowner's total monthly payment
would be $162 ($105 for utility service plus $57 OBR payment),
for a monthly savings of $13. Lenders are likely to provide more
favorable loan terms when repayment is part of a utility bill
subject to utility collection procedures and the threat of
service disconnection for nonpayment.
CPUC Pilots on OBR - To comply with AB 758's requirement to
investigate energy efficiency financing options to retrofit old
housing stock, the CPUC hired a consultant, which released a
report in July 2011 called "Energy Efficiency Financing in
California - Needs and Gaps - Preliminary Assessment and
Recommendations." The report concluded that a $4 billion annual
investment in energy efficiency is needed to meet California's
aggressive energy goals, and it identified on-bill collection of
loan payments as one of many options for energy efficiency
financing but recognized legal and regulatory barriers to its
implementation.
In its November 2012 decision approving $1.9 billion in
ratepayer funds for IOU energy efficiency programs for
2013-2014, the CPUC approved $220 million for financing to
increase customer adoption of energy efficiency measures,
including non-residential OBR, and a multi-family housing OBR
pilot. It declined to require residential OBR at this time and
instead required IOUs to collect data on performance of other
programs and build a database of California loan payment history
from all sources of energy project loans, in order to inform a
future decision on residential OBR. It also required
modification and expansion of Energy Upgrade California to
further leverage the hundreds of millions in ARRA energy
efficiency funds that expired last year.
The CPUC previously identified many reasons for not requiring
OBR for single-family residential customers prior to conducting
pilot programs:
It is unclear how much of an advantage OBR provides
to ensure customer payment of energy efficiency loans
based solely on the likelihood that customers pay their
utility bills, which would provide lenders sufficient
security to offer low interest rates.
Lack of legal authority to allow utilities to
initiate collection actions and disconnect for
non-payment of portions of the utility bill not related
to provision of utility services, citing Public Utilities
Code Sections 779.2 and 771, which prohibit disconnect
for third-party debt.
Lenders' desire to analyze long-term utility payment
histories in order to assign a credit risk would require
utilities to make customer payment information available.
It is uncertain whether OBR can or should require
"bill neutrality" so that the monthly loan payment does
not exceed the amount of energy savings from the measure
financed.
It is not clear that OBR, on its own, will be able
to make significantly more financing or better rates and
terms available than home equity loans.
COMMENTS
1. Bill Failed Passage and CPUC Raises Concerns . The
author presented this bill to the committee on April 16,
but it failed passage. Since then, the CPUC adopted an
official "Support if Amended" position, raising 19 separate
legal concerns and proposed amendments. The CPUC raises
significant issues with the bill's "bill neutrality"
requirement, pointing out how many factors affect whether
bill neutrality will actually be achieved over the life of
a loan, especially for tenants. The CPUC also states the
following about the loan loss reserve provisions:
"The new section seems to propose to remove disconnect
provisions and instead require the CPUC to offer a loan
loss reserve to guarantee residential loans. This would
undercut the purpose of the bill, put ratepayer funds at
risk, and remove the incentive to repay the loan."
2. Author's Purpose . According to the author, this bill
would provide Californians access to low-cost loans for
energy efficiency and clean energy projects that can be
repaid through monthly utility bills, thereby creating
energy savings and generating jobs. The author states that
OBR is necessary because existing clean energy financing
programs are "funded by insufficient ratepayer or taxpayer
moneys" and reach only a small number of Californians due
to restrictions in income level, credit score, project
size, or property and technology specific eligibility
criteria.
3. Does OBR "Not Rely on Public Funding" ? The legislative
findings of this bill declare that the OBR program it
requires the CPUC to establish "does not rely on public
funding." Although the intent is that OBR will attract
private capital for residential energy improvement loans,
this bill also requires funding in an unspecified, but
likely substantial, amount for a loan loss reserve to
guarantee that lenders are paid if customers who
"experience disproportionate bill impacts from summer
cooling" fall behind on OBR payments. In addition, before a
single OBR loan can be made, this bill requires the CPUC
to, among other things, establish the requirements of an
OBR program each IOU will be required to develop, specify
which energy improvements are eligible and ensure that they
will achieve greenhouse gas reductions, establish a
methodology to calculate bill neutrality of individual OBR
projects (likely to be a highly complex and contentious
proceeding, according to stakeholders), adopt rules for
collection of unpaid OBR obligations on closed service
accounts, and establish the loan loss reserve program. The
$1.9 billion in ratepayer funds already approved for the
2013-14 IOU energy efficiency program years does not
include these costs for residential OBR or any loan loss
reserve program.
This bill also expressly authorizes IOUs to collect from
ratepayers their costs to develop and implement OBR
programs, as well as the costs of all judgments,
litigation, attorney's fees, and other liabilities related
to their role as bill collectors for the lenders. Moreover,
the bill prohibits the CPUC and IOUs from handling customer
complaints about any aspect of an OBR obligation. Assuming
the CPUC would not leave customers without a place to lodge
a complaint, it likely will contract out a customer service
function, as is being considered for the CPUC's OBR pilot.
The bill also requires energy and cost savings calculations
(necessary for the bill neutrality requirement) and project
inspection services for each customer's OBR project, but
does not specify how those will be funded.
Thus, absent any indication of another funding source, it
appears that all of these OBR program costs would be paid
with ratepayer funds in an unknown amount on top of the
nearly $1 billion a year in ratepayer funds already
collected for IOU energy efficiency programs.
4. Pilots vs. Potentially Premature Prescription . This bill
contains a lengthy list of prescriptions for implementing
OBR, reaching conclusions on complex issues that the CPUC
has concluded are best addressed through pilot programs it
has undertaken. It seeks to fill a perceived void in
availability of energy efficiency financing, but is it not
clear if it incorporates lessons learned from low customer
participation in existing loan programs, including CEC
pilots specifically aimed at developing best practices for
financing energy efficiency retrofits. The CPUC has
concluded that, in order to proceed with residential OBR,
legislation is necessary to make OBR an exception to the
statutory prohibition on service disconnection for
nonpayment of third-party debt (Public Utilities Code
Sections 777.1(e) and 779.2). But is it necessary to
prescribe detailed program elements and undertake extensive
start-up costs before learning from pilot programs?
Will this bill conflict with elements of the CPUC's
residential OBR pilot already in the planning stages? Why
not follow the CPUC's approach of continue non-residential
OBR and pilot programs, focus on continuing ARRA funded
programs, and build a database of California loan payment
history from all current sources of energy project loans
that can inform a future decision on how to implement
residential OBR? The author and committee may wish to
consider amending the bill by striking its provisions and
instead amend Public Utilities Code Sections 777.1(e) and
779.2 to authorize the CPUC to conduct residential OBR
pilot programs and report the results, including the number
of service disconnections, to the Legislature.
5. OBR Is Exception to Prohibition on Residential Service
Disconnection . This bill seeks to eliminate the legal
barrier to residential OBR - current law prohibiting
termination of residential utility service for nonpayment
of debt owed to a third party. This bill makes OBR an
exception to this prohibition and expressly allows
utilities to treat underpayment of OBR obligations as
failure to pay for utility service. Thus, any customer who
falls behind in the monthly OBR payments would be subject
to the same escalating procedures required by CPUC rules
for nonpayment of a utility bill, including customer
notice, payment options, and eventually service
disconnection. This would be the case regardless of whether
that customer originated the OBR obligation, received the
required OBR disclosure or not (the bill provides no
enforcement of seller or landlord disclosure obligations),
and irrespective of whether the OBR obligation was "bill
neutral" (nothing in the bill relieves a customer of the
OBR obligation if the improvement turns out not to be bill
neutral over the term of the loan).
6. Will Utility Service Disconnections Increase With OBR ?
Just over a year ago the CPUC updated its service
disconnection procedures for PG&E and Southern California
Edison, with special requirements for disabled and other
vulnerable populations, with the goal of reducing
disconnections, particularly as Californians still struggle
to come out of the economic recession. Some parties, such
as the Division of Ratepayer Advocates (DRA), oppose this
bill and express concern that residential OBR "will have
the unintended consequence of putting customers, in
particular middle- and low-income customers, at greater
risk for incurring disconnections." DRA points out that
low-income customers experience disconnection at a rate
three times higher than the average disconnection rate.
The Utility Reform Network (TURN) also states that it has
had "concerns that ratepayers could be disconnected for
failure to pay third-party financing on the bill. . . when
the work was poorly done and/or did not provide the
promised energy reductions," although TURN states that a
loan loss reserve program obviates this concern.
Similarly, the California Association of Realtors expresses
concern that OBR "not create a liability trap for unwary
homeowners" but believes the bill neutrality requirement
will help prevent this: "We think it is particularly
important that actual savings, versus those projected by
providers, be verified. Our members have reported
complaints that projected savings have not been realized in
practice. . . . California has an unfortunate history of
abusive home improvement schemes targeting unsophisticated
homeowners with unsustainable obligations - requiring bill
neutrality will guard against unscrupulous contractors
taking advantage of homeowners."
7. Loan Loss Reserve: Protecting Consumers or the Bank ?
TURN and other supporters of this bill state that the loan
guarantee program required by the bill will protect
customers from the risk of losing service. Although the
language is unclear, it appears the intent is that
specified customers with an OBR obligation will have unpaid
OBR payments made from a loan reserve fund rather than face
disconnect for nonpayment. The bill requires the CPUC to
develop a loan-loss reserve or loan guarantee program as
part of OBR "to the extent feasible and cost effective" and
requires the loan program to be directed to "residential
customers who experience disproportionate bill impacts from
summer cooling and other demands on the electrical system
that cause excessive usage and potentially significant bill
impacts." Who is included in this definition and how big is
this universe of customers? Are low-income customers
included or given any priority for access to loan
guarantees instead of facing service disconnection? What if
the CPUC determines a loan loss reserve is not feasible or
cost effective?
Other than potential protection from a loan guarantee
program the CPUC may establish if feasible and
cost-effective, nothing in the bill removes any customer or
group of customers from the threat of disconnect for
nonpayment of an OBR obligation. Indeed, this security that
OBR loans will be subject to utility collection procedures
and potential loss of service is precisely what lenders say
enables them to offer customers low interest rates and
attractive loan terms in an OBR program. What is the
incentive for customers to make OBR payments if they do not
face the threat of disconnect? Will these customers
eligible for loan protection face higher interest rates on
OBR loans?
The utilities express concern that a loan loss reserve
program shifts costs that should appropriately be assumed
by banks and lending institutions to utility ratepayers. "A
loan loss reserve is not protection of the consumer; it is
protection of the bank," states Sempra. According to
Edison, the loan loss reserve has "the direct effect of
increasing rates to all ratepayers for the sole purpose of
protecting the financial lending entity when they make bad
loans. This action will burden ratepayers and utilities
with costs and risks that should be borne by the financial
institutions that are in the business of lending capital."
8. Bill Neutrality Required, But No Recourse if Bills Not
Neutral . This bill requires "bill neutrality" for OBR
programs so that a utility customer's annual OBR repayment
charges are less than or equal to the projected annual
electric and gas energy savings arising from the energy
improvements financed with an OBR loan. This promise of
utility bill reduction (or at least neutrality) from the
improvement is what makes the investment and monthly loan
payments worthwhile to the customer. Bill neutrality is
always required for tenants and "lower income households"
and for all OBR obligations incurred in the first two years
of an OBR program. Just as the OBR obligation "runs with
the meter," the bill neutrality requirement also continues
with each subsequent property owner or tenant. But the bill
fails to define any recourse for a customer when bill
neutrality is not realized. In fact, the bill prohibits the
CPUC and the utilities from providing a forum for customer
disputes on bill neutrality or any other OBR-related issue.
The customer, meanwhile, faces service disconnection for
refusal to pay.
9. Bill Neutrality Methodology Controversial . The lack of
customer recourse related to the bill neutrality guarantee
could be problematic given the many variables that can
affect energy use over the lifetime of an OBR loan. These
include the behavior of the customer utilizing the new
equipment (whether a customer elects to enjoy more heat or
cooling once monthly bills go down), climate zone, quality
of contractor installation, changes in numbers of occupants
at a residence, new appliances or equipment added to a
household, and fluctuating energy costs. A change in owner
or tenant of a property introduces more uncertainty into
the bill neutrality calculation.
This bill requires the CPUC to establish a methodology to
calculate bill neutrality that can be applied to each
individual customer project financed with OBR, which
stakeholders and CPUC staff indicate will be complex and
contentious. Just as the CPUC has struggled for more than a
decade with its methodology for evaluation, measurement and
verification (EM&V) of savings from IOU energy efficiency
programs at the portfolio level, the methodology for
calculating projected and actual energy savings at the
individual residential customer level will likely be
fraught with uncertainty. The CPUC authorizes 4 percent of
the IOU energy efficiency budgets - about $40 million per
year - for EM&V. What will be the cost of EM&V at the
individual customer level for OBR projects, and who will
pay?
The only specific direction in the bill on this issue is
authorizing the CPUC to include changes in an owner's
"expected operating and maintenance costs" in calculating
bill neutrality. This appears to open the door for
including non-energy savings to offset bill increases from
the OBR payment, such as the avoided cost of repairs on a
new HVAC compared to an old one. What is the policy
justification for this provision, and will other non-energy
savings be included in the calculation of bill neutrality?
10. How Do Tenants Participate in OBR ? The author states
that this bill will remedy the problem of the "split
incentive" that currently keeps multi-family housing from
participating in existing energy efficiency programs -
renters have no incentive to invest in improvements to
properties they don't own, and landlords have little
incentive to invest in clean energy measures when tenants
pay utilities and thus stand to benefit.
The language of the bill in unclear, however, exactly how
tenants will participate in OBR and how that participation
differs for rental housing with master-meters where tenants
do not get individual utility bills, compared with housing
where each rental unit gets a bill directly from the
utility. The bill refers to a property owner authorizing an
OBR project that a tenant is responsible to pay for
"directly or indirectly through the provisions of the
applicable lease." Many support letters state that "SB 37
would allow landlords to initiate energy efficiency
projects that will be financed by the utility bills of
tenants who will benefit from the projects."
Does the bill neutrality requirement apply to a tenant in a
master-metered property where the owner undertakes an OBR
obligation? Can a tenant in a master-metered property be
subject to service disconnection for nonpayment of an OBR
obligation that exists indirectly through the provisions of
a lease? For tenants in individual metered properties, how
does an OBR obligation undertaken by the landlord get
allocated to each rental unit, how is the bill neutrality
requirement applied to each tenant, and is the bill
neutrality requirement and allocation of the OBR obligation
recalculated each time a new renter assumes occupancy of
the unit? Who pays for an unpaid OBR obligation of a prior
tenant?
11. Does This Bill Protect Consumers ? This bill requires the
CPUC to ensure that OBR programs include consumer
protections for residential customers, including
protections to prevent increases in the expected number of
service terminations, such as targeted use of a commission
approved loan loss reserve in lieu of service termination,
and bill neutrality at all times for lower income
households and tenants. However, the following provisions
of the bill have potentially harmful effects for consumers:
No recourse or enforcement of the bill neutrality
requirement, even though the threat of service
disconnection for nonpayment of an OBR obligation
continues through the life of the loan and passes from
one owner or tenant to the next regardless of differing
energy use or other variables.
Authority for the CPUC to eliminate the bill
neutrality requirement after two years (except for lower
income households and tenants) if it determines bill
neutrality has unnecessarily limited the types of
projects that may be financed with OBR.
Prohibition on CPUC and utilities handling customer
disputes about OBR issues, even though the OBR payment
appears as a line item on the utility bill (and no
provision for any alternative customer complaint forum or
process).
No enforcement of landlord obligation to provide
tenants notice of an OBR obligation; instead, a provision
stating that failure of a landlord to provide notice does
not invalidate a lease.
No enforcement of a seller obligation to provide a
buyer of an OBR obligation; instead, a provision stating
that a seller or real estate agent is not required to
provide a buyer any additional information beyond a
standard disclosure form.
No requirement that disclosures to buyers and
tenants include information on bill neutrality of the OBR
project.
1. Renewable Energy/Demand Response/Distributed Generation .
The bill requires OBR programs for not only energy
efficiency, but also renewable energy, distributed
generation, energy storage, and demand response
investments. It is unclear how OBR for renewable generation
and distributed generation would overlap with existing
programs supporting these investments, such as the Self
Generation Investment Program, the New Solar Homes
Partnership, and the California Solar Initiative. Moreover
there are no parameters for the program specified including
performance requirements, evaluation of need (note that
customers now have options to install solar with no
up-front investment), or consideration of whether the cost
of the generator must have a pay-back less than the cost of
utility service, among other issues. Additionally, demand
response programs that have been designed to date are
generally a behavior and ratebased application calling on
the customer to reduced demand (aka turn off the lights) at
specified times. Consequently, that is no equipment
required of the customer to participate.
2. Ratepayer Impact . Although OBR financing would be from
third-party lenders, it appears that the cost of other OBR
program requirements, including a potentially substantial
loan loss reserve fund, would be paid by ratepayers through
the energy efficiency surcharge that already funds about $1
billion per year for energy efficiency programs and also
through individual IOU rate increases for each IOU's
litigation and liability costs.
3. Double Referral . Should this bill be approved by the
committee, it will be re-referred to the Senate Committee
on Judiciary for its consideration on May 2nd.
POSITIONS
Sponsor:
Environmental Defense Fund
Support:
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|Abundant Power |Groom Energy Solutions |
|American Lung Association |International Council of |
|Asian Pacific Environmental |Shopping Centers |
|Network |Matadors Community Credit |
|Beutler Corporation |Union |
|Blue Earth |MaxLite |
|BOMA California |Metrus Energy |
|CalCEF |Mission Valley Bank |
|California Apartment Association |Natural Resources Defense |
|California Business Properties |Council |
|Association |Nularis, Inc. |
|California Environmental Justice |Planning and Conservation |
|Alliance |League |
|California Housing Partnership |Renewable Funding |
|Corporation |SCIenergy |
|Carbon Lighthouse |Shorenstein Properties |
|Clean Fund |Sierra Club California |
|Clean Power Campaign |Small Business California |
|Coalition for Clean Air |SolarCity |
|DBL Investors |Solar Energy Industries |
|Efficiency First California |Association |
|Energi Insurance Services, Inc. |The Greenlining Institute |
|Enlighted Inc. |The Utility Reform Network |
|Environmental Health Coalition |The Vote Solar Initiative |
|Facility Solutions Group |Tioga Energy |
|Global Green USA Green Campus |USGBC California |
|Partners | |
| | |
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Support, if amended
California Public Utilities Commission
Concerns:
California Association of Realtors
Oppose:
Division of Ratepayer Advocates
Pacific Gas and Electric Company, unless amended
San Diego Gas and Electric Company, unless amended
Sempra Energy Utilities, unless amended
Southern California Edison
Southern California Gas Company, unless amended
Jacqueline Kinney
SB 37 Analysis
Hearing Date: April 30, 2013