Questions from California Energy Commission

[Copied verbatim from email messages; Numbering added for clarity]

1. In draft rule, what California state programs are included in the baseline forecast?

1A. Did they use EE information from all utilities which submitted a Form 861, or a subset. 

On the rules –

2. Will the final targets still be based on the AEO forecast used in the draft rule, or will there be an 

update?

3. In its compliance plan, will California be allowed to use its own demand forecast and counting 

conventions as long as they are part of a public process (i.e. the Integrated energy Policy 

Report)? Rationale: California does not use the AEO or EGRID in its planning, procurement, and 

evaluation. We have a fully integrated process, so that we know which program is counted where, what 

the assumptions are and the sources of the data. If we have to use AEO/EGRID, then we will need to do 

our planning using our own process and then convert it into federal numbers.

4. Could they more clearly explain how the draft rule proposes that incremental savings from 

programs and actions initiated between 2012 and 2020 are to be counted? Are they to be treated as 

committed and included in the [updated] baseline forecast? 

5. Per our discussion, here are three quotes from the EPA rule preamble . We don’t 

understand what the EPA question is:

a. The first and third one refers to “recognize”. What does recognized mean?

b. The second one refers to under what conditions would savings be allowed to “count”. 

What does count mean? Is it in the setting of the rate-based goal, in the compliance 

plan? Something else?

EPA: EPA proposes that emission reductions that existing state requirements, programs and 

measures achieve during a plan performance period as a result of actions taken after a specified 

date may be recognized in determining emission performance under a state plan. While 

proposing that the ”specified date” would be the date of proposal of these emission guidelines, 

the EPA also requests comment on the following alternatives: the start date of the initial plan 

performance period, the date of promulgation of the emission guidelines, the end date of the base 

period for the EPA’s BSER-based goals analysis (e.g., the beginning of 2013 for blocks 1-3 and 

beginning of 2017 for block 4, end-use energy efficiency), the end of 2005, or another date (p. 

476). For this option, EPA is seeking comment on the point in time after which such actions 

should be able to qualify for use during a plan performance period, considering the method used 

to set state goals (p. 476). EPA requests comment on whether there is a rational basis for 

choosing a date that predates the base period from which the EPA used historical data to derive 

state goals... EPA generally requests comment on the appropriate date to select under this option 

(p. 477).”
EPA: “The agency requests comment on whether pre-2020 implementation of new requirements 

would be practical for states. The agency generally requests comment on this approach, 

including the conditions that should apply to pre-2020 emission reductions that would count 

toward the state goal (479).”

EPA: “EPA proposes that emission reductions that existing state requirements, programs and 

measures achieve during a plan performance period as a result of actions taken after a specified 

date may be recognized in determining emission performance under a state plan. While 

proposing that the ”specified date” would be the date of proposal of these emission guidelines, 

the EPA also requests comment on the following alternatives:

 - the start date of the initial plan performance period, 

 - the date of promulgation of the emission guidelines, 

- the end date of the base period for the EPA’s BSER-based goals analysis (e.g., the 

beginning of 2013 for blocks 1-3 and beginning of 2017 for block 4, end-use energy

efficiency), 

- the end of 2005, or another date (p. 476).