Table 2. Summary of Working Group Participation Organization Type Number Attending Kickoff Attended Final Meeting Attended more than 50% of Meetings Advocacy 2 1 1 Industry organizations 2 4 3 Program Administrators 17 12 13 Implementer 24 15 13 Commission & Contractors 9 8 7 The working group held seven weekly meetings after the public kickoff on October 12, 2016. A summary of each working group activity and the corresponding topic is provided in Table 3. Table 3: Working Group Meetings and Topics Date Event Topic 10/12/16 Public Meeting, all day Introduce Working objectives and recruit participants 10/20/16 Webinar Review Working Group process, schedule 10/25/16 Webinar Installation category definitions 11/1/16 Webinar Measure level assignments 11/8/16 Webinar Program influence models 11/15/16 Webinar Preponderance of evidence models 11/17/16 Sub-group conference call Deemed Preponderance of Evidence standards 11/22/16 Webinar Preponderance of evidence details
discounted replacement cost existing equipment Suboptimal Y Replace Replace Discounted future replacement cost Suboptimal or Original? Code Suboptimal Y Replace Repair Discounted repairs over EUL of installed equip Suboptimal or Original efficiency? Original Efficiency Suboptimal efficiency Y Repair to Orig eff. Repair to Orig eff. Zero – full cost is incremental ?? No Savings maintenance?? Suboptimal efficiency Y Repair to > original efficiency Repair to Orig eff. Zero – full cost is incremental ?? No Savings maintenance??
Suboptimal efficiency N Repair to Orig eff. Repair to Orig eff. Zero – full cost is incremental Suboptimal? No Savings maintenance?? Suboptimal efficiency Repair to > original efficiency Repair to Orig eff. Zero – full cost is incremental suboptimal to more than original efficiency? Or suboptimal to original? No Savings maintenance?? Suboptimal efficiency Y Replace Repair to Orig eff. Discounted future repair – * Suboptimal efficiency or Original efficiency Original Efficiency *if using original efficiency in first period – add cost of repair to original
We do not object to the assertion that a payback period longer than the expected useful life of a measure is indicative of important non-energy and non-program influencing factors. However, this singular address of an important issue falls short of a comprehensive treatment of appropriate screening criteria for program influence. Further, we assert that under an assumption of rational and fully informed decision-making, any payback (before incentives) that is shorter than the remaining useful life of the existing equipment indicates it is economically favorable to replace the equipment without need for incentives. Thus, for cases where rational decision making applies, incentives that do not financially induce existing equipment to cross a remaining useful life payback threshold also indicate no influence. We are familiar with the perspective of some program implementers, that customers have numerous competing high yield opportunities for capital investment and/or that business uncertainty implies a higher discount rate for future costs and benefits than those we apply in our models. However, under no circumstance should ratepayer incentives be applied where the simple payback period is less than 12 months before incentives. We adopt the ”no influence” criteria proposed with the addition of a minimum payback period, to balance the maximum payback period proposed in the table. The following is an excerpt from Section 4 of the guidance document, describing the meaning of “direct-to-default”: “Direct-to-default” that the evidence is strongly suggestive of one of the three outcomes and the burden of proof to justify another outcome is high. It is not definitive and does not guarantee an outcome but effectively reduces the rigor for additional requirements necessary to support the default baseline. This guide identifies seven such technology-program type-market combinations: Evidence Default Baseline C/I energy management systems that don’t fit in the “add-on” category C/I/Ag refrigeration
Alteration Type Savings Customer Class / Add On / BRO Efficient Equipment (ER/NR) No Existing Condition All Code Existing Buildings Upstream/ midstream All Code NMEC, RCT, exp. design Existing Calculated Existing Direct-to-Decision/ Direct-to-Default POE** Deemed Existing Deemed POE projects including industrial and agricultural processes SEM* programs NMEC All Existing Other programs All Existing POE** *Strategic Energy Management programs are currently under development in a collaborative effort of Commission staff and Program Administrators. **”Incentive Tiered POE” will apply here only following Commission approval of Tier 1 and Tier 2 preponderance of evidence requirements. These requirements are not adopted in this Resolution but assigned to the Track 2 Working Group, per ordering paragraph 25. Measure Level List The working group developed a measure level list, but some working group members are concerned that the measure descriptions are too broad in some cases. Also, we do not adopt the working group recommendation to classify lighting as eligible for existing conditions baseline for all downstream program types. For these reasons, we cannot adopt the measure level list. Public Utilities Code section 311(g)(1) provides that this resolution must be served on all parties and subject to at least 30-days public review and comment prior to a vote of the Commission. Section 311(g)(2) provides that this 30-day