MEMBERS-ONLY FACT SHEET
SGIP RSSE Total Eligible Project Cost

April 14, 2026

On February 20, 2026, the CPUC released an Assigned Commissioner’s Ruling regarding documentation developers must provide for the Total Eligible Project Costs (TEPC) of Residential Solar & Storage Equity (RSSE) projects. This Ruling was subsequently updated on March 13, 2026, and took effect immediately. The Rulings solicited comments that the CPUC is still considering, making this fact sheet subject to potential future change. While the Rulings provide instructions on TEPC documentation, there remains substantial ambiguity regarding what documentation will be considered acceptable. CALSSA has done its best to obtain more clarity from the CPUC and Program Administrators in these areas, but developers may find that PAs request further documentation beyond what is included in our guidance.

Maximum SGIP Incentive
The Ruling uses $30,020 as an example of the maximum SGIP incentive for a typical RSSE project consisting of a 5 kW PV system and a 13.2 kWh battery. That figure reflects the maximum incentive for a project of that size: $15,500 for 5 kW of solar at $3.10/W and $14,520 for 13.2 kWh of storage at $1,100/kWh. For projects with different system sizes, the maximum SGIP incentive would be different, because it is based on the size of the storage system and the CEC-AC rating of the solar system.

The Rulings divide RSSE projects into three categories for ICF-stage TEPC verification: (1) projects with a TEPC at or below 90% of the maximum SGIP incentive for the system’s size, (2) projects with TEPC above 90% and at or below 100% of the maximum SGIP incentive for the system’s size, and (3) projects with TEPC above 100% of the maximum SGIP incentive for the system’s size.

Projects with TEPC at or below 90% of the maximum SGIP incentive
These projects are given no additional TEPC verification requirements.

Projects with TEPC above 90% and at or below 100% of the maximum SGIP incentive
The Ruling states that developers must submit “receipts for the system equipment.” This must be documentation from an external vendor. If the documentation is for a larger equipment order beyond the individual project, developers should include a cover sheet with an explanation of how the equipment cost was derived.

The Ruling also says developers must submit “labor contracts, or similar documents.” Similar documents can include, “a document describing the salary range of the employee and the hours worked on the project.” This means that in lieu of pay stubs, a company may submit a document on their letterhead listing the various employees (after removing names) working on the SGIP project along with their pay rate or salary range and the hours worked on the project.

Projects with TEPC above 100% of the maximum SGIP incentive
Developers are required to submit everything they would for projects between 90% and 100% of the maximum SGIP incentive, plus “any other invoices or documentation needed to validate each cost category reported at ICF to justify the full TEPC.” Those additional cost categories include the following:

• Engineering & Design

• Permitting

• Interconnection

• Warranty/Maintenance

• Metering/Monitoring

• Sales Tax

• Other Eligible Costs 

Some portion of these cost categories may, where applicable, be supported through the salary-range document. Developers may put “N/A” for individual categories as well.

The developer must also complete, sign, and date a Supplemental Cost Verification Form and deliver it to the host customer. The system owner company must also sign the form if it is a separate entity. The host customer does not sign the form. The document can be found here. The form asks for a narrative explaining why the TEPC exceeds 100% of the maximum SGIP incentive and for information on customer costs, including any upfront or post-installation costs, monthly PPA or lease payments, total estimated PPA or lease payments, and average PPA $/kWh.

While there has been no explicit guidance regarding an acceptable narrative in this document, CALSSA has been told by at least one PA that they are looking for some kind of written explanation. At least one developer had their Supplemental Cost Verification Form rejected by the PAs when they did not include a written explanation and instead directed the customer to look at a separate cost breakdown document.

Baseline Costs
The Ruling allows developers with multiple RSSE projects who choose not to submit these forms with every ICF to instead submit a “baseline TEPC” for all their RSSE projects. The Ruling states:

Through this pathway, the developer could provide receipts or documentation to support the average project cost for each cost category reported at ICF. Documentation may include total financing costs for cost of capital, a bulk invoice for system equipment that can be averaged on a per module basis, and estimated hours worked and salary for the typical project.

Through the baseline approach, developers still need to provide the same type of documentation they would provide for an individual project at the ICF stage, including, if applicable, a salary range document. However, for projects in which the TEPC does not exceed the baseline and the line items are materially consistent with it, developers would not need to provide additional documentation to justify their costs. If a project’s TEPC at ICF does exceed the baseline, the developer must provide additional documentation justifying the exceedance, such as receipts if relevant or a written explanation of increased labor costs due to a job’s complexity. Equipment documentation for the baseline approach should cover more than just a single project. While it is not explicitly stated in the Ruling when the baseline document may be submitted, CPUC staff have indicated it may be done anytime a project is in “RRF Reserved” status.

Order for Reviewing Projects
The Ruling requires projects to be grouped and reviewed in the following order of priority:

A. Projects with a TEPC of less than 100% of the maximum SGIP incentive, and those above 100% of the maximum SGIP incentive that applied before February 20, 2026.

B. Projects with a TEPC above 100% of the maximum SGIP incentive, with customer out-of-pocket customer costs below $3,000, that are not in Group A, as well as all multifamily projects not in Group A.

C. Projects with a TEPC above 100% of the maximum SGIP incentive that do not meet any of the criteria in Group B.

Auditing
Projects in Group C will be randomly sampled for auditing. Projects in Groups A and B may also be flagged for auditing, particularly where PAs or the Commission identify unusually high TEPCs or customer out-of-pocket costs. Projects flagged for auditing may have 30% or more of the SGIP incentive held until the audit is complete. Additionally, if a PA determines that a TEPC has not been sufficiently validated, the ruling requires the PA to reduce the TEPC, which may also reduce the SGIP incentive, and the PA may issue a warning directing the developer to reduce TEPC reported on other projects as appro