4. The Joint Energy Division /Utility EM&V
Plan (Joint Plan)

The Joint Plan is included as Attachment 1 to this decision.5 ED and the IOUs agreed that we needed to develop a more collaborative and transparent working relationship as an important step towards improving the EM&V process. IOU and ED staff agree to work together on shared EM&V projects, and to follow mutually agreed upon standards for transparency, respect, and communication while working on separate EM&V projects. ED and the IOUs believe that this more collaborative process will result in greater cost‐efficiencies, more reliable results, broader stakeholder buy-in, and fewer disputed issues.

ED and the IOUs agree that the optimal approach to EM&V for 2010-2012 is to define an EM&V planning framework and retain flexibility to fund EM&V projects as needs arise, rather than to adopt from the outset a detailed plan covering the full scope of EM&V needs over a three year period. ED and the IOUs state that they will plan and implement EM&V projects with the goal of achieving the highest benefit for the EM&V expenditure, while minimizing interference with the programs and utility customers. To that end, EM&V projects will be designed to avoid duplication of effort, consolidated across all activities in a streamlined manner, and planned to comply with the Commission's schedule requirements.

The Joint Plan and its proposed budget allocations represent ED and the IOUs' current best judgment on the appropriate allocation of the authorized EM&V budget to EM&V projects needed to accomplish technically credible, quality work products that will comply with the Commission's requirements and goals stated in D.09‐09‐047. The Joint Plan presents a 2010 through 2012 EM&V Budget, with an estimated allocation of funding authorized by D.09-09-047 EM&V Projects. The estimated budget is shown on page 19 of the Joint Plan, also in Attachment 1 of this decision.

DRA generally supports the Joint Plan as long as ED's recommendations on other EM&V issues are incorporated into the EM&V framework (DRA's specific comments on issues other than the Joint Plan are discussed in sections below). DRA believes the Joint Plan needs improvement in the areas of transparency, and should include more opportunities for stakeholder input.

TURN supports generally the overall direction for EM&V set forth in the Joint Plan. TURN supports the Joint Plan's emphasis on a flexible and phased approach for the 2010-2012 portfolio period. TURN agrees with the Joint Plan's requirements that all IOU Phase 1 (immediately implementable) EM&V projects should be done in collaboration with ED to reduce the risk of such studies not being done in a timely manner.

There is no opposition to the Joint Plan. The Joint Plan presents a reasonable set of procedures to guide ED and the IOUs in formulating and carrying out EM&V studies. However, the Joint Plan does not address all outstanding issues. We will adopt the Joint Plan as presented in Attachment 1, subject to the discussion on remaining issues addressed herein.

In approving the EM&V plan, we wish to clarify that we intend for our staff to coordinate with other pertinent state agencies wherever such coordination enhances the state's overall energy policy goals. For example, we intend for the EM&V function to be supportive and responsive to the state's energy loading order policies and climate policy goals. We specifically direct our staff to coordinate with the CEC on the implementation of the energy consumptions surveys described in the EM&V plan as "EM&V Project Number 12," since the CEC has historically managed.

In the following sections we address additional issues which were not resolved as part of the Joint Plan. The determinations made here are informed by the ED Recommendations put forth in the November 20 ALJ ruling, and party comments that followed.6 We address these issues by topic, rather than by specific question as framed in the ruling.

5 As sponsors (along with ED) of the Joint Plan, there was no need for the IOUs to provide comments on this document.

6 To the extent that there are differences between the ED Straw Proposal and the combination of ED's positions in the Joint Plan and its recommended resolution of outstanding EM&V issues, we consider the latter views to supersede the Straw Proposal.

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