therefore reversed our opinion on this topic, and have included support for an IE structure, as specified further in the text of the decision. Numerous parties also disagreed with the proposed decision’s requirement for a mid-process Tier 2 advice letter filing at the RFA short list and RFP design stage, including the IOUs, NRDC, the Council, ORA, and CLEAResult. We have removed this requirement, and have instead substituted the requirement for an IE structure, as well as the filing of Tier 2 advice letters for contracts or batches of contracts, after award, that are valued at $5 million or more and/or with terms of longer than three years, for Commission review. Several parties commented that the 60 percent requirement for third party designed and implemented programs should not be moved back to 2022 from 2020, including the Council, CLEAResult, NAESCO, ORA, and NRDC. We will not modify this requirement, in part because some of the delay has been caused by the Commission’s process itself, and in part out of an abundance of caution and a desire to see this process be successful, if on a slightly slower timeframe. The comments of several parties, including ORA and the IOUs, included requests for clarification about whether the third party solicitation process can begin before the business plans are addressed by the Commission. The answer is no. This decision enables the IOUs to begin solicitations for IEs, and to prepare the standard contract terms and conditions, as discussed in this decision, but does not yet authorize the launch of RFAs, until such time as the programs are addressed by the Commission in a decision on the business plan filings. CEE’s comments, while supporting other aspects of the decision or concurring with others’ comments already discussed above, focus primarily on the need for further requirements for diverse contracting and workforce quality standards. Their comments were also generally supported by NRDC. As a
risks of third party solicitation failure, ensure a level playing field for all participants, and reflect commercial viability. There is a great deal of experience and evidence gleaned over the past several portfolio cycles, as well as studies, in support of requiring certain workforce standards to ensure quality measure installations and energy savings. The Legislature has encouraged increased reliance on payforperformance program structures to encourage placing risk for the energy savings delivered on the parties most able to deliver those savings. Maintaining uptodate third party solicitation schedules and making them widely accessible will help ensure success of the third party solicitations. Providing a semiannual forum for stakeholder discussion about the progress of the third party solicitations will help improve the quality of the solicitation process. Design of this round of strategic energy management programs and staff proposed programs involving limited integration of energy efficiency and demand response programs do not meet the criteria for third party programs required in D.1608019 and addressed by the solicitations covered in this decision. Allowing for extensions of existing third party contracts will help prevent any gaps in program coverage while new third party solicitations are underway and new third party programs ramp up. Requiring regular annual reporting of utility third party contracts in place will provide additional transparency and oversight of the third party solicitation process. Maintenance of updated implementation plans associated with third party programs will encourage program success and transparency, consistent with the terms of D.1510028.
Arlis Reynolds THE CADMUS GROUP, INC. 4 VENTURE IRVINE CA 92618 (949) 428-6264 Arlis.Reynolds@CadmusGroup.com Sepideh Shahinfard THE CADMUS GROUP, INC. 1901 HARRISON ST., NO. 1100 OAKLAND CA 94612 (510) 768-8386 Sepideh.Shahinfard@CadmusGroup.com Ken Williams Director - Caifornia Client Solutions THE FRANKLIN ENERGY GROUP 18865 VISTA PORTOLA TRABUCO CANYON CA 92579 (949) 290-3110 kwilliams@franklinenergy.com Carmen Henrikson Associate V.P., Strategy TRC SOLUTIONS 436 14TH STREET, SUITE 1020 OAKLAND CA 94612 (415) 235-5562 Chenrikson@trcsolutions.com Craig Tyler TYLER & ASSOCIATES EMAIL ONLY EMAIL ONLY CA 00000 (510) 841-8038 craigtyler@comcast.net Eric Eberhardt Associate Director Energy Services UNIVERSITY OF CALIF. OFFICE OF THE PRES. EMAIL ONLY EMAIL ONLY CA 00000 (510) 987-9392 eric.eberhardt@ucop.edu Kristin Heinemeier Western Cooling Efficiency Center UNIVERSITY OF CALIFORNIA - DAVIS 215 SAGE ST., SUITE 100 DAVIS CA 95616 (530) 754-7667 kheinemeier@ucdavis.edu Andrew G. Campbell Exec. Dir., Energy Institute At Haas UNIVERSITY OF CALIFORNIA, BERKELEY UNIVERSITY OF CALIFORNIA, BERKELEY 324 GIANNINI HALL BERKELEY CA 94720 (415) 515-4655 acampbell@berkeley.edu Carol Yin YINSIGHT, INC EMAIL ONLY EMAIL ONLY CA 00000 (478) 227-6594 cyin@yinsight.net (End of Appendix A)