Parties and TASC (separately) argue that a warranty requirement could discourage innovation in product offerings. IREC and ORA suggest that equipment warranties are sufficiently common in the solar market now that it would be unnecessary, and potentially create an administrative burden, to impose a separate warranty requirement. Because warranties have been required both CSI and SGIP, it is reasonable and not burdensome to require a minimum 10-year warranty or service agreement to ensure proper maintenance and continued system performance. A warranty will help to protect against defects and undue degradation of electrical generation output caused by faulty manufacture or installation, and to cover any expenses generated from repair and replacement of the system that are not otherwise covered by the manufacturer. Parties express a range of views on whether additional safety requirements are needed for interconnection and other issues that are not strictly customersited equipment. CMUA, SCE, and SDG&E make a number of proposals for safety standards, including requirements for projects larger than 1 MW; and continuation of safety requirements in the existing NEM program. SDG&E urges that the possibility of technology-specific requirements should be expressly considered. Joint Solar Parties question whether any separate or additional safety standards are necessary, and that in any event the Commission's ability to impose safety standards on entities that are not regulated utilities is limited. On these issues, the Commission's and IOUs' normal processes, particularly those related to interconnection, should suffice to maintain an
Parties and TASC (separately) argue that a warranty requirement could discourage innovation in product offerings. IREC and ORA suggest that equipment warranties are sufficiently common in the solar market now that it would be unnecessary, and potentially create an administrative burden, to impose a separate warranty requirement. Because warranties have been required both CSI and SGIP, it is reasonable and not burdensome to require a minimum 10-year warranty or service agreement to ensure proper maintenance and continued system performance. A warranty will help to protect against defects and undue degradation of electrical generation output caused by faulty manufacture or installation, and to cover any expenses generated from repair and replacement of the system that are not otherwise covered by the manufacturer. Parties express a range of views on whether additional safety requirements are needed for interconnection and other issues that are not strictly customersited equipment. CMUA, SCE, and SDG&E make a number of proposals for safety standards, including requirements for projects larger than 1 MW; and continuation of safety requirements in the existing NEM program. SDG&E urges that the possibility of technology-specific requirements should be expressly considered. Joint Solar Parties question whether any separate or additional safety standards are necessary, and that in any event the Commission's ability to impose safety standards on entities that are not regulated utilities is limited. On these issues, the Commission's and IOUs' normal processes, particularly those related to interconnection, should suffice to maintain an
157960987.docx