Rolling Portfolio. TURN offered, “One approach could be to authorize EE funding for 2015 as an extension of the 2013-2014 portfolio cycle, and additionally authorize the continuation of that same funding beyond 2015 unless or until superseded by a Commission decision approving the Rolling Portfolio funding.” In D.14-10-046, the Commission authorized this approach. The Commission also modified the Proposed Decision, consistent with TURN’s recommendation, to clarify that existing unspent, uncommitted funds from pre-2013 program cycles be used to offset the revenue requirement to be collected in rates each year, to the extent that any such funds are available. per TURN's suggestion to include the following language: "IOUs are to collect in rates the annual authorized budget levels for the program administrators in their service territory at the 2015 level, less carry-forward of unspent funds from prior portfolio cycles, until the earlier of 2025 or when the Commission issues a superseding decision on funding."). Compare with PD, Ordering Paragraph 20. TURN Cmts on Ph1 PD, 10/6/14, pp. 3-4; TURN Rep Cmts on Ph1 PD, 10/13/14, p. 5 D.14-10-046: 2015 Programs [Code: Ph1-2015] 1. Home Upgrade TURN recommended that the Commission not take further action on the Energy Upgrade California - Home Upgrade Program (EUC-HUP) for 2015, other than to authorize the program administrator’s planned activities through 2015. The Commission agreed that “this is not the time for another redesign of residential Home Upgrade programs.” TURN also recommended that the Commission adopt PG&E’s 1. Home Upgrade D.14-10-046, p. 94 (HUP design) TURN Cmts on 2015 Filings, 4/2/14, pp. 5-6 (avoid major changes to EUC-HUP) D.14-10-046, p. 100 (concluding that "the concept of removing project-related, non-efficiency related costs … from the total cost calculation has merit" because including these costs "creates a misleading picture of a measure's and project's while rejecting the specific proposal as lacking in "empirical support for the [25% cost reduction] value", and instead encouraging a working Verified
proposed 25% downward adjustment to EUC-HUP project incremental measure costs in 2015 as an interim measure until a more precise approach could be developed in Phase III, and avoid unnecessarily perpetuating the known inaccuracies in the existing method throughout 2015. The Commission found merit in this concept, while rejecting the specific proposal as lacking empirical support. 2. Lighting TURN argued that PG&E and SDG&E had not demonstrated that the Statewide Lighting Program, which was created in D.12-11-015 to consolidate residential and non-residential lighting programs to support market transformation across customer sectors, should be merged with other programs in 2015. The Commission agreed and directed PG&E, SDG&E, and SCE to separately account for statewide lighting programs in their compliance filings. TURN also recommended that the Commission modify the Phase 1 PD to clarify the guidance related to the role of CFLs in 2015 and to better align that guidance with The Commission agreed that the PD should be clarified, although the Commission rejected TURN’s proposed clarification. group to make new proposal in Phase III) TURN Cmts on 2015 Filings, 4/2/14, pp. 6-8 (removing related project costs from TRC calculation) 2. Lighting D.14-10-046, p. 106, fn. 92 TURN Rep Cmts on Ph1 PD, 10/13/14, p. 4 (separate statewide program) D.14-10-046, pp. 114-115 TURN Cmts on Ph1 PD, pp. 4-7 (clarification re CFLs)
forward evidence supporting the longevity claim.” D.15-10-028: Rolling Portfolio Framework [Ph2-RC, Ph2-RC-CoordCmte, Ph2-RC-Funding, Ph2-RC-PR, Ph2-RC-StakeProc, and TURN’s efforts that resulted in a substantial contribution to D.15-10-028 began before the Commission opened this proceeding. TURN, along with the Natural Resource Defense Counsel (NRDC), convened a broad group EE stakeholders in search of common ground. This group consisted of nearly thirty parties, including program administrators, consumer advocates, local government representatives, environmental organizations, efficiency companies and and other key stakeholders. These discussions resulted in 2 letters to then-assigned Commission Ferron, presenting recommendations from this diverse collective of stakeholders for the scope of the forthcoming EE rulemaking. The first letter, dated July 30, 2013, outlined the groups’ priorities for EE policy to be considered in the new EE rulemaking. These priorities included transitioning to a new regulatory framework that would (a) provide Letters sent by the Coalition to Commissioner Ferron on dated July 30, 2013 and Sept. 18, 2013 (attached to this Claim at Attachment 5) R.13-11-005, p. 10 (encouraging parties to present a joint proposal for a rolling portfolio structure in Phase II) See Notice of Ex Parte Communication, filed 12/18/14 by NRDC (providing notice of the letter sent that day by NRDC on behalf of itself, TURN, and 16 other parties, to Commissioner Peterman and ALJ Edmister, proposing that 5 specific issue areas be included in the Scope of Phase II of Attachment B to the Notice is the 12/18/14 Letter, which references the two earlier letters sent by TURN, NRDC, and the coalition on July 30 and September 18, 2013. Assigned Commissioner’s and Administrative Law Judge’s Joint Ruling Re Phase II Prehearing Conference Statements, 1/13/15, p. 3. D.16-02-023, pp. 3-5 (granting intervenor compensation to NRDC for substantial contributions to D.15-10-028, including NRDC’s work with TURN prior to the commencement of R.13-11-005, and work with the coalition to influence the scope and develop the joint proposal for a rolling Verified
consistency in the market for consumers and other market actors, (b) maximize efficiency and expanded opportunities to capture efficiency potential, (c) rely on energy efficiency in planning, and (d) improve upon the existing evaluation, measurement and verification process. The second letter, dated September 18, 2013, presented the groups’ recommendations that the forthcoming OIR include clear steps for developing a record to support transitioning to a rolling portfolio approach. The Commission issued its Order Initiating Rulemaking 13-11-005 shortly thereafter, which encouraged parties to collaborate through informal stakeholder forums to submit a joint proposal or party proposals for a “Rolling Portfolio” filing and review process in Phase II of the proceeding. The coalition convened by TURN and NRDC commenced work on developing a joint proposal for transitioning to a rolling portfolio system to present in Phase II. This work was conducted through six subgroups, a steering committee called the “Coordinating Committee,” the “Funding Authorization” subgroup, the “Technical” subgroup, the “Portfolio Refresh” subgroup, the “Stakeholder Engagement” subgroup, and the “Reporting” portfolio) TURN PHC Statement, Jan. 26, 2015, pp. 4-5 (advocating the inclusion in Phase II the adoption of a new “rolling portfolio” framework for portfolio planning, review, and management); p. 10 (explaining that the summary of the joint proposal under development by the coalition was attached to NRDC’s PHC Statement) Administrative Law Judge’s Ruling Regarding Comments on Phase II Workshop 1, issued (workshop presentations developed by the coalition, including TURN, were attached to this ruling) TURN Cmts on Phase II Workshop 1, 4/6/15 TURN Cmts on Staff’s Rolling Portfolio Whitepaper, 5/26/15 effective
Ruling Regarding High Opportunity Energy Efficiency Programs or Projects (HOPPs Ruling). TURN contributed to the outcomes in the HOPPs Ruling. For instance, TURN recommended that the Commission amend Staff’s proposed baseline adjustment for HOPPs for “replace on burnout” equipment to clarify that “repair eligible” equipment will be treated differently than equipment that cannot be repaired. The Commission responded by inviting PAs to make a case in their HOPPs proposal that a given piece of equipment has a history of being repaired rather than replaced. TURN also opposed Staff’s proposed baseline adjustment for “routine maintenance” undertaken as part of Retrocommissioning HOPPs, so that all savings flowing directly from the intervention – including routine maintenance that has been neglected but is required for for participation in the EE program – would be counted. While the Commission did not adopt TURN’s precise approach, the Commission agreed that routine maintenance should be counted with certain qualifications in order to facilitate to objective of AB 802 to make maintenance happen that should be happening but isn’t. High Opportunity Program, June 2, 2016 (discussing TURN’s response) (attached to this request as Attachment 6) TURN Cmts on Phase II Workshop 3, 4/13/15, pp. 17-21 (outlining concepts for residential and commercial pilot programs) CPUC Disposition approving Advice Letter 4948/4948-A, SCG’s Commercial High Opportunity Projects and Programs (HOPPs)- Commercial Restaurant Retrofit (CRR) Program (discussing TURN’s response) (attached to this request as Attachment 7) supported
optimize program activities into the most and cost-effective possible configurations,” rather than replicating the existing program configuration in the new statewide administration scheme. Furthermore, the Commission agreed with TURN and others that statewide administrators should have the discretion to determine whether to contract with a single statewide implementer, who might in turn hire subcontractors, or to contract directly with multiple implementers offering local or regional specialties or expertise in the market(s) to be targeted. The Commission also dismissed IOU concerns that the new approach to statewide programs would erode their ability to target EE to address capacity or reliability needs, reminding them that the activities subject to the new statewide program requirements are for the most part distinct from the types of customer-facing, downstream activities that could be strategically deployed to target reliability needs, as TURN had suggested. Finally, the Commission agreed with TURN and others that the cost sharing mechanism for statewide programs should be trued-up annually, and based on actual program participation. Workshop 3, 4/13/15, p. 8 TURN Cmts on Phase IIB/IIIA PD, 8/8/16, pp. 3-6
personnel, they should explain why this continues to be necessary.” D.17-09-025: EE Goals for 2018 and Beyond [Ph3-P&G] 1. Potentials Scenario TURN recommended that the Commission use the Navigant scenario called “mTRC (GHG Adder #1) Reference” to set EE goals for 2018-2030. That scenario estimates economic potential using the TRC, as modified to include a GHG adder based on CARB’s price ceiling TURN argued against using a PAC-based scenario as long as the Commission measures portfolio using the TRC and PAC, because the resulting goals would include uneconomic savings from the TRC perspective. TURN further noted that the TRC appropriately recognizes that the PA and program participants are jointly investing in EE, and thus serves as a meaningful consumer protection in EE policy. The Commission in agreed with TURN (and others) that the EE goals for 2018 and beyond should be based on this scenario. TURN additionally argued that 1. Potentials Scenario D.17-09-025, p pp. 19-20 (adopting a scenario with a GHG adder now) pp. 20-21 (basing the GHG adder on the CARB APCR Price) p. 21 (adopting a TRC scenario, not a PAC-based scenario, in part due to the asymmetry problem cited by TURN and others) TURN Cmts Responding to the ALJ’s Ruling Inviting Comments on Draft Potential and Goals Study for 2018 and Beyond [Phase III], 7/7/17, pp. 3-5 (GHG adder using CARB’s Cap-and-Trade price ceiling) pp. 6-7 (TRC not scenario); pp. 8-9 (adopt a GHG adder even without a resolution of the pending issue in 2. Cumulative Savings Goals D.17-09-025, pp. 26-27. TURN Cmts Responding to the ALJ’s Ruling Inviting Comments on Draft Potential and Goals Study for 2018 and Beyond [Phase III], 7/7/17, pp. 11-12. Verified