ALJ/JF2/VUK/jt2 Date of Issuance 6/5/2018 Decision 1805041 May 31, 2018 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF Application of Southern California Edison Company (U338E) for Approval of Energy Efficiency Rolling Portfolio Business Plan. Application 1701013 And Related Matters. Application 1701014 Application 1701015 Application 1701016 Application 1701017 DECISION ADDRESSING ENERGY EFFICIENCY BUSINESS PLANS
3CREN, the County of Los Angeles on behalf of SoCalREN, LGSEC, MCE, PG&E, SCE, SDG&E, and SoCalGas. Also on May 15, 2017, SCE filed an errata to its business plan exhibits and workpapers. Also on May 15, 2017, PG&E on behalf of the business plan proponents and TURN, served a motion on the service list requesting an extension to respond to specific questions included in the Scoping Memo, mostly related to budget issues. The motions requested leave to file and serve these responses by June 12, 2017. This motion was granted by ALJ email ruling on May 15, 2017. On May 26, 2017, Commission staff held a workshop on the proposed sectorlevel metrics. Additional informal meetings on the sectorlevel metrics proposals occurred in June 2017 arranged through the California Energy Efficiency Coordinating Committee (CAEECC) stakeholder process envisioned in D.1510028. On June 9, 2017, the ALJs issued a ruling modifying the remaining procedural schedule. On June 12, 2017, supplemental budget information was filed by the following PAs or prospective PAs: ABAG on behalf of BayREN, the County of Ventura on behalf of 3CREN, the County of Los Angeles on behalf of SoCalREN LGSEC, MCE, PG&E, SCE, SDG&E, and SoCalGas. On June 16, 2017, Commission staff held a workshop on third party solicitation issues. On June 22, 2017, comments on all of the supplemental information, responses to Attachment B questions in the Scoping Memo, and other key issues identified by parties were filed by the following 19 parties: ABAG on behalf of BayREN, California Efficiency and Demand Management Council (Efficiency Council); California Energy Efficiency Alliance (CEA), CEE, the City and County
On October 3, 2017, SCE filed, on behalf of PG&E, SDG&E and itself, a response to SoCalGas’s motion. Also on October 3, 2017, the assigned ALJ granted SoCalGas’s motion to strike portions of GreenFan’s and Verified’s comments. On October 13, 2017, the following parties filed final reply comments on the business plan applications: NAESCO; City and County of San Francisco; MCE; CodeCycle; CEE; GreenFan and Verified; San Joaquin Valley Clean Energy Organization; Demand Council; PG&E; San Joaquin Valley Clean Energy Organization, Association of Monterey Bay Area Governments, High Sierra Energy Foundation, County of San Luis Obispo, Redwood Energy Authority; County of Ventura; SoCalGas; California Community Choice Association; SCE; SoCalREN; SBUA; TURN; ORA; SDG&E; LGSEC; ABAG. Also on October 13, 2017, SoCalGas filed a motion to strike portions of ORA’s final opening comments, pertaining to SoCalGas’s codes and standards advocacy activities. On October 27, 2017, ORA filed a response to SoCalGas’s motion to strike portions of ORA’s final opening comments. On November 13, 2017, the assigned ALJ issued a ruling denying SoCalGas’s motion to file an amended business plan, and directing SoCalGas to instead seek approval for its proposed 2018 budget through the ABAL process. Also on November 13, 2017, the Commission issued a proposed decision to adopt the framework for third party solicitations. On November 14, 2017, the assigned ALJ issued a ruling denying SoCalGas’s motion to strike portions of ORA’s final opening comments. On January 11, 2018, following a round of opening and reply comments on the proposed decision, the Commission adopted D.1801004, which established a
Table 2. 2018 Energy Efficiency Portfolio CostEffectiveness Scenarios (without Codes and Standards) – 2018 Annual Budget Advice Letter Supplements PA Scenario 1/ baseline Scenario 2 Scenario 3 PG&E 1.01 1.27 1.26 Eliminate all nonresource programs and resource programs with a TRC less than 0.55. Increase the NTG values to 0.85 for all measures with a NTG less than 0.85. SCE 1.13 1.25 1.25 Eliminate lowest impact programs. CFLs/A lamp LEDs remain. Eliminate lowest impact programs. CFLs/A lamp LEDs removed. SDG&E 1.09 1.16 1.37 Eliminate all resource programs < 1.0 Eliminate all nonresource programs MCE 0.69 NA [none] Business plan BayREN 0.23 0.27 0.32 Shift funds from Res Single Family to C&S, Commercial P4P/Financing Target older Single Family homes for deeper savings; CodeCycle for NonRes Lighting SoCalREN 0.44 0.55 0.72 Discontinue non costeffective programs and shift funds from Single Family to Multifamily Multifamily program with tiered incentives The extent to which the various scenarios reflect or are consistent with the PAs’ business plans is obviously not uniform, but generally indicative of future challenges, i.e., the types of tradeoffs the PAs may have to face, in achieving or improving costeffectiveness. Given the noncosteffective or marginally costeffective forecasts reflected in the PAs’ business plans – albeit reflective of
Offerings Codes & Standards Advocacy Building Codes Combined Codes & Stds Advocacy PG&E Appliance Standards Lighting Lighting Innovation Combined Lighting SCE Primary Lighting Lighting Market Transformation Emerging Tech Tech Development Combined (then split by fuel) Gas SoCalGas Tech Assessments Electric SCE Tech Introduction Workforce Education & Training K12 Connections No Change PG&E Institutional Partnerships University of California Combined SCE California State University State of California Combined DGS/DoC PG&E Department of Corrections Foodservice Point of Sale Program SoCalGas Midstream Commercial Water Heating SoCalGas Table 4. Lead Program Administrator for Statewide Downstream Pilot Programs Program Lead IOU HVAC Quality Installation/Quality Maintenance (QI/QM) SDG&E Water/Wastewater Pumping Program SCE Career and Workforce Readiness PG&E
REN PAs’ portfolios Forecasted budget must not exceed the annual budget in the approved business plan, or (if applicable) the revised annual budget in the PA’s September 4, 2018 ABAL, for the program year for which the ABAL requests budget authority, plus any unspent funds from previous years in the business plan period, by more than 20 percent; and PA claim requiring staff verification: Forecasted energy savings goals must meet or exceed the annual energy savings targets included in the PA’s business plan. Verification shall include review of: prior year actual energy savings, sectorlevel metrics, and analysis of provided program/portfolio information so an energy efficiency expert would reasonably conclude the forecast will be achieved. Standard of review for staff disposition of the ABALs does not include review of program administrators' decisions on reducing, cancelling, expanding or adding individual programs or program areas. Review Process for “Ramp” or Transition Period We consider the first few years of this business plan period (20182022) as ramp years in the context of third party solicitations, setting up the statewide administration framework, and affording the PAs an opportunity to improve portfolio costeffectiveness. The Commission can call for a resubmitted ABAL from any PA as a result of a decision in the policy track (R.1311005 or its successor), new data based on evaluation results or PA savings claims, or for any other reason. If a PA’s ABAL submitted for program year 2019 (September 4, 2018) through program year 2022 (September 1, 2021) meets the ABAL review criteria, staff will approve that PA’s ABAL. If a PA’s ABAL submitted for program year 2019 (September 4, 2018) through program year 2022 (September 1, 2021) fails the ABAL review criteria, then staff will reject that PA’s ABAL and direct the PA to
It is reasonable to require the PAs to include updated budget information, including the supplemental budget filings, starting with their September 3, 2019 ABALs. We should require the IOUs’ ABALs to include forecasted portfolio TRCs that meet or exceed 1.25, except for program years 2019 – 2022 (ramp years), during which the IOUs’ ABALs should include forecasted portfolio TRCs that meet or exceed 1.0. An additional process, for IOUs whose ABALs include forecasted portfolio TRCs that meet or exceed 1.0 but do not meet or exceed 1.25 during the program years 2019-2022 (ramp years), is necessary to provide for continuity and align PAs’ interests with our overall objectives of meeting or exceeding energy savings goals, costeffectively, and within budget. Recommendations for major modifications to costeffectiveness policy should not be addressed in this proceeding. Recommendations for major modifications to costeffectiveness policy should cite to specific evaluation studies and/or program data supporting such recommendations, in R.1311005 or its successor. The program administrators should ensure their accounting and reporting policies and practices can accommodate any requirements the Commission may adopt in Rulemaking 1311005 or its successor proceeding. We should consider third party models that minimize administrative costs. We should enable third parties to choose whether to use utility account representatives. The IOUs should track the number and proportion of third parties that forego the option of using utility account representatives. The utilities should include this information in their annual reports.
Activity in advocating for building codes (T24) tied to adoption in CA Number of measures supported by CASE studies in rulemaking cycle (current work) Number of measures adopted by CEC in rulemaking cycle (indicator of past work) Metrics Activity in advocating for appliance, lighting and equipment standards tied to adoption in CA Number of T20 measures supported by CASE studies in rulemaking cycle (current work) Number of measures adopted by CEC in current year Metrics Activity in advocating for codes and standards tied to adoption at the federal level Number of federal standards adopted for which a utility advocated (IOUs to list advocated activities) Percent of federal standards adopted for which a utility advocated (# IOU supported/ # DOE adopted) Metrics Local government participation and success in adoption of reach codes The number of local government Reach Codes implemented (this is a joint IOU and REN effort) Metric