attachment-0002 - New Jersey`s Clean Energy Program

REIP Funding Cycle 3
Application Selection
and
Approval Process Options
REC Meeting 7/13/10
Stakeholder Comments
on the Lottery Proposal
“Applications limited to 10 per installer per day…on the day the applications exceed
remaining funds, the applications received that day would be selected by a lottery” …MSEIA
“If you want to get really good applications you should guarantee each contractor two or
three applications. This keeps the small businessman in the game”….Quantum Solar
“Conceptually we have no problem with a lottery method, but don’t see the need for a new
administrative procedure when setting rebates at a reasonable level will ensure that
oversubscription does not occur” ….Trinity Solar
“By creating a lottery system, you create a situation where no one really knows whether they
receive a grant or what that grant will be”….Astrum Solar
“Any lottery utilized needs to cap the number of rebate approvals from any one company so
that a few large companies do not receive all of the rebates”….Seabright Solar
“Concern over the proposed lottery system….solar for the lucky”….Solar Connections
Application
Selection
– Several options were considered
– Installer concerns about fairness and
certainty
– After reviewing the pros and cons of
these methods, two options emerged.
1. Daily Application Caps
2. Hybrid Cap-Lottery
How Option #1
Could be Deployed
Daily Application Caps
– Similar to process approved for HPw/ES.
– Each installer is limited to a small number of
applications (3 to 5?) per day.
– On a daily basis, all applications are treated equally
regardless of submittal method and time of day.
– Lottery used for the final day that budget limit is
reached to distribute equitably.
– Submittal period will remain open until the value of
rebates requested exceeds the available budget.
Daily Application Caps
PROS
CONS
Ensures that all installers will have at
least some projects approved in FC3
if they submit complete applications
within the first few days.
Installers are not able to drop off high
volumes of applications, therefore
higher mailing costs and time for
installers.
Potential to keep submittal period
open for longer period than some
other options.
Budget oversight and notification
requires approximately two days so
installers may submit applications that
will not be funded.
Installers have more control over
which applications will be selected.
Need to ensure that only the daily limit
of applications is submitted each day
by each installer.
High volume installers are not able to
dominate funds by “camping out”.
Administratively burdensome, need to
watch for “gaming”.
How Option #2
Could be Deployed
Hybrid Cap-Lottery
– Open from September 1st through 10th.
– Selections are in two phases: cap phase & lottery
phase
– Installers will need to identify 3 top priority projects
which will be selected during the cap phase. If not
identified, staff will select.
– Each installer and it’s affiliates will be treated as one
entity.
– Public & non-profits automatically directed to the cap
phase but limited to 10% of budget during cap phase.
– During cap phase, each participating entity is
reasonably assured that up to 3 of their applications
will receive approval, provided the application is
complete and valid.
How Option #2
Could be Deployed
Hybrid Cap-Lottery (continued)
– Applications with “installer TBD” (except publics) or “self
installs” will be automatically included in the lottery
phase.
– Remaining applications are then assigned a random
sequencing number for use in the lottery phase.
– Remaining applications will be awarded in the sequence
number order until the remaining funds are gone.
– If rebate funds remain available after lottery phase, then
the submittal period will re-open with a daily cap of 3
applications per day with a lottery used for last day of
funding availability.
Hybrid Cap-Lottery
PROS
CONS
Ensures that all installers will have at least Only a few applications per installer are
a few projects (up to 3) approved in FC3 if reasonably assured to be funded.
they submit complete applications.
High volume installers not able to
dominate all the funds by being first in
line.
Budget oversight and notification
requires approximately two days so
installers may submit applications that
will not be funded.
Allowing seven business days will help
spread out the volume of applications
received per day and eliminate panic.
Administratively burdensome, need to
watch for “gaming”
Avoid long lines on first day of FC3 and
confusion on time each application was
received via mail, hand deliver or FedEx.
Can drop off high volumes of applications.
Recommended Option:
Hybrid Cap-Lottery
– Combines the best features of all options.
– Recommend approving up to 3* complete applications
in cap phase for each installer before the lottery phase.
• Why three?
– New installers need three installations in NJCEP program to become a
Trade Ally Partner and to be considered QA eligible
– In FC2, 59% of installers submitted 3 or fewer applications
– In FC2, 79% of the installers submitted 6 or fewer
– In FC2 this would have left a significant budget (~75%) for the lottery
– Would spread funds among all installers.
– All installers that submit complete applications will
have some approvals.
– A fair and neutral process will result.
* “up to 3” is subject to the application volume and the available funding
Application Selection Process
Hybrid Cap-Lottery Method
Applications
Receipt
Priority Application
Selection,
Number Identifier &
Random Sequencing
Approvals
• US Mail, FedEx, UPS, or hand-delivery is accepted
• Applications will be accepted from September 1-10 (7 business days)
• Cutoff on Sept 10 @ 4pm based on application receipt, not postmark
• Time of day of receipt is not needed (except on 9/10/10)
Application Selection Process
Hybrid Cap-Lottery Method
Applications
Receipt
Priority Application
Selection, Number
Identifier & Random
Sequencing
Approvals
• Cap Phase: Three priority applications identified by the installer (we
recommend a separate envelope with “Cap Phase” written on the outside) will
be pulled from rest of applications. Also, all public and non-profit applications
(up to 3 per entity) are added to the cap phase. Although all of these should
be eligible for approval in this phase, these will be entered into a separate
random number generator process to determine application approval order.
• Lottery Phase: Remaining applications, plus all “Installer TBD” (except
publics) and “Self Installs”, will be entered in a spreadsheet and assigned a
sequencing number using a random number generator.
Online Random Number
Generator Example
Application
# Identifier
Random
Generator
Number
1
0011
2
0067
3
0003
4
0451
5
0046
6
0152
7
0405
8
0858
Application Selection Process
Hybrid Cap-Lottery Method
Applications
Receipt
Priority Application
Selection, Number
Identifier & Random
Sequencing
Approvals
• Cap Phase: Up to three per installer (or 3 per public/non-profit entity)
priority applications with be reviewed in order of random sequence for
completeness and approved first.
• Lottery Phase: If funds are still available, remaining applications
reviewed in order of random sequence for completeness and approved
until funds are gone.
• Incomplete applications returned to applicant. When funding is
consumed all remaining applications returned to applicants.