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Investigation Claims: SWWH028 Application Date Validation vs Installation Date Guidance

Feedback2026Claim Spec

BAYREN reports that CEDARS validation is blocking Q4 2025 claims because Claim.ApplicationDate falls outside the effective dates of the selected MeasDetailID.


This conflicts with prior guidance to determine the measure package version based on Claim.InstallationDate rather than Claim.ApplicationDate.


Upload QC Summary: https://cedars-2.cpuc.ca.gov/claims/upload-summary/646/

Example Failure

Claim example: BAY-2025-MF-012119-SWWH028-06

  • Application Date: 07-Nov-2024

  • MeasDetailID effective dates: 01-Jan-2025 to 31-Jul-2025

Result: Application Date is outside the allowed range.

Current Behavior

  • MeasDetailID values and start and end dates are sourced from eTRM.

  • CEDARS validates against Application Date.

  • Validation is working as designed.

Issue

  • Policy guidance suggests versioning may be based on Installation Date.

  • System validation enforces Application Date.

  • BAYREN’s workaround is to revert to Application Date versioning.
    If unresolved, all 2025 claims may need revision before annual reporting.

Key Questions

  1. Should SWWH028 using A.O.Smith CAHP-120 Heat Pump Water Heater (other than Multi-Family) eligibility be based on Installation Date instead of Application Date?

  2. Is this measure-specific or a broader rule change?

  3. Should CEDARS override eTRM dates, or must eTRM be updated?

  4. What are the impacts of changing validation logic?

Select the module in CEDARS
Posted by cedars team ·
Status: No Fix Required6 comments

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Comments6

  • wwright@frontierenergy.com

    •

    Aug 28

    BayREN will conform to the guidance for measure package versioning set forth in the 5/15/2024 Documentation Requirements for SB1414, Title-24 and Permitting Compliance document that states use of "The earlier of Installation Date or Application Date for non-HVAC equipment." This ticket can be closed out. Thank you for the assistance.

    • cedars team

      Team•

      Aug 31

      Thanks for updating us. Closing the ticket.

  • Amy Reardon

    •

    Apr 2

    Hi all, it wounds like everyone agrees with this solution, including the ex ante team, so let’s let BayREN know. Per Corina’s comment, we expect them to follow through by providing (1) claim an application date that is inside the MP date range, and (2) describe their activity in excruciating detail in the Comments field of the Measure table. This would include name of ED person who approved the exception and the actual application date — so it remains documented for evaluation purposes.

    We can mention it at the beginning of the PCG during announcements.

  • Roopa Reddy

    Team•

    Mar 27

    @cedars team @Jake Richardson (PG&E)

    DATE rules implemented pursuant to CPUC guidance (https://cedars.cpuc.ca.gov/deer-resources/deemed-measure-packages/guidance/file/3114/download/) are intended to apply consistently across all eTRM deemed measure packages. PG&E appreciates the Commission’s comment and the consideration of an exception for a specific measure package (re: 3/26/2026 email response). To preserve consistency in rule application and system implementation, PG&E recommends an alternative approach whereby, if the CPUC authorizes an exception to these rules, then BayREN aligns the claim application date with the installation date. In this case, BayREN should maintain documentation with these claims on the exception.  This approach achieves the intended objective, avoids the need for code changes, and remains fully consistent with the rules as currently written. Thank you.

    • Jake Richardson (PG&E)

      Team•

      Mar 27

      @Amy.reardon@cpuc.ca.gov just tagging you here too since you may not get notified otherwise.

    • corina.jump

      •

      Apr 2

      Agreed. Since ED approved this exception then the easiest way for BAYREN to claim the measure is for them to (1) claim an application date that is inside the MP date range, and (2) describe their activity in excruciating detail in the Comments field of the Measure table. This would include name of ED person who approved the exception and the actual application date — so it remains documented for evaluation purposes.