Table 5: D.1606055 Incentive Structure for NonResidential Energy Storage ($/Wh) Slow Adoption Fast Adoption No With ITC Pct of No With ITC Pct of ITC ITC NonITC ITC ITC NonITC Step 1 0.50 0.36 72% 0.50 0.36 72% Step 2 0.45 0.31 69% 0.40 0.26 65% Level Step 3 0.40 0.26 65% 0.30 0.16 53% Step 4 0.35 0.21 60% 0.20 0.06 30% Step 5 0.30 0.16 53% 0.10 0% Incentive Step 1 n/a n/a n/a n/a Step 2 10% 14% 20% 28% in Level Step 3 11% 16% 25% 38% Decline Step 4 13% 19% 33% 63% Pct Step 5 14% 24% 50% 100% Incentive We find that CalSEIA’s explanation of the current incentive structure for nonresidential energy storage demonstrates a flaw in the current methodology. To address the problem, CalSEIA recommends that the nonITC/ITC incentive adjustment methodology for each step be based on the percentage difference at Step 1, i.e., 72%. Five parties filed responses to the Petition. CESA, SolarCity and CSE support the changes recommended by the Petition. The Joint IOUs oppose the Petition. ORA supports the Petition but recommends a different solution. The Joint IOUs’ opposition to the Petition centers on their concerns that granting CalSEIA’s Petition would contravene the Commission’s determination in D.1606055 that the value of the ITC is $0.14/Wh for all projects at all incentive levels. D.1606055 did not make such a finding. In D.1606055, we determined the
Table 5: D.1606055 Incentive Structure for NonResidential Energy Storage ($/Wh) Slow Adoption Fast Adoption No ITC With ITC ITC Pct of NonITC No ITC With ITC ITC Pct of NonITC Incentive Level Step 1 Step 2 Step 3 Step 4 Step 5 0.50 0.45 0.40 0.35 0.30 0.36 0.31 0.26 0.21 0.16 72% 69% 65% 60% 53% 0.50 0.40 0.30 0.20 0.10 0.36 0.26 0.16 0.06 72% 65% 53% 30% 0% Pct Decline in Incentive Level Step 1 Step 2 Step 3 Step 4 Step 5 n/a 10% 11% 13% 14% n/a 14% 16% 19% 24% n/a 20% 25% 33% 50% n/a 28% 38% 63% 100% We find that CalSEIA’s explanation of the current incentive structure for nonresidential energy storage demonstrates a flaw in the current methodology. To address the problem, CalSEIA recommends that the nonITC/ITC incentive adjustment methodology for each step be based on the percentage difference at Step 1, i.e., 72%. Five parties filed responses to the Petition. CESA, SolarCity and CSE support the changes recommended by the Petition. The Joint IOUs oppose the Petition. ORA supports the Petition but recommends a different solution. The Joint IOUs’ opposition to the Petition centers on their concerns that granting CalSEIA’s Petition would contravene the Commission’s determination in D.1606055 that the value of the ITC is $0.14/Wh for all projects at all incentive levels. D.1606055 did not make such a finding. In D.1606055, we determined the
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