7. Customer Participation in EM&V as a
Condition of EM&V Funding

Question 10 of the November 20 Ruling asked: "Should the IOUs modify program eligibility rules to require very large customized program participants to participate in evaluations if selected in a sample, as a condition for receiving energy efficiency funding?"

ED has found that many large project participants have refused to participate in evaluations. ED believes it is reasonable to require participants who receive a large sum of energy efficiency funding and services to participate in evaluations, if needed. This participation would include on-site measurement and verification, as well as surveys of key participant personnel. ED proposes to review past projects with the IOUs to determine the energy efficiency incentive threshold above which participation in evaluations would be obligatory.

ED pledges to reduce the burden of participating in evaluations by coordinating with the IOU implementation and inspection process. ED recommends that the Commission require the IOUs to cooperate with ED in this regard.

SCE sees this as a program issue, not an EM&V issue. SCE asserts that the IOUs already require such customers who receive energy efficiency program funds to sign a statement acknowledging that they may be required to participate in evaluation studies. If this issue needs to be considered further, SCE would defer this issue to R.09-11-014. PG&E and SDG&E/SoCalGas agree with SCE that large customized program participants are already subject to evaluation requirements, but PG&E notes that this obligation is limited to calculated savings programs (as opposed to deemed savings programs).¹⁹ SDG&E/SoCalGas recommend that ED and the IOUs improve coordination in this area to ensure better customer participation in the evaluation process. DRA agrees that streamlining the EM&V process and accommodating customer needs is important.

This issue appears to be one of enforcement of existing obligations. While all customers receiving energy efficiency program funds are obligated to submit to evaluation studies, some customers apparently refuse to do so. This may be because, as SDG&E/SoCalGas point out, customers may find the studies to be redundant, to require too much effort, or to be intrusive. Nevertheless, we emphasize to both IOUs and customers that our energy efficiency program relies on accurate information about programs and we expect all participants to adhere to evaluation requirements.

We find no specific policy that needs to be changed here; the current requirements simply need to be enforced. We encourage the efforts of ED (including its EM&V consultants) and the IOUs to work with customers to both ensure necessary and required cooperation and to limit the burden on customers.

¹⁹ "Calculated savings programs" refers to programs that offer rebates for custom projects (typically for large commercial and industrial customers), for which the rebate and ex-ante energy savings are calculated for each individual project. "Deemed savings programs" refers to programs that offer predetermined rebates and assume a predetermined energy savings for a range of conditions (i.e. climate, building type, etc.) for a predetermined set of energy efficiency products and services. Ex-ante deemed rebates and savings assumptions are not adjusted for each individual project.