3. Positions of the Parties
The Chapter was made available for comment through an Assigned Commissioner Ruling on June 25, 2010. Comments and reply comments were submitted by various parties, including the major IOUs, TURN, and NRDC, on July 16 and July 23, respectively. In response to these comments, various changes were made to the Chapter. The parties suggested various small corrections and alterations to the text and many parties made comments about specific details of program implementation. However, the Plan is a broad blueprint setting forth an overall vision and strategies for achieving the vision. The specifics of strategy implementation will be developed in the forthcoming Action Plan process. Accordingly, party comments that address specific details of program design and implementation to meet the Chapter's goals will be addressed in the Action Plan process.
For its part, PG&E suggests language referencing Property Assessed Clean Energy (PACE) bonds and Assembly Bill (AB) 811 be removed given the recently announced position of the Federal Housing Finance Agency (FHFA).2 While FHFA's position has created significant uncertainty, the issue is far from resolved. A number of jurisdictions, including the State of California, are challenging the FHFA's policies and federal legislation has been introduced. We decline to remove the language on PACE and AB 811 type financial incentives at this time. These and other financing solutions are a critical factor in maximizing lighting energy savings opportunities and making best practice solutions affordable, and immediate action is necessary to take advantage of PACE financing opportunities when and if the financing is available.
SCE and PG&E both raised concerns about the cost-effectiveness of specific lighting programs and requested changes to specify that only cost-effective solutions will be pursued. However, Commission policy on this issue is clear - as long as the portfolio of programs is cost-effective, a single program does not have to be cost-effective. It can be expected that programs specifically designed to advance new technologies and achieve market transformation may not be cost-effective, particularly in the initial years of implementation.
For its part, TURN commented that milestones are needed to ensure a timely and satisfactory shift from compact fluorescent lights (CFLs) to other advanced lighting technologies.
2 PG&E notes "federal support has been withdrawn from AB 811 and PACE programs," and proposes that "until these options are federally supported with proper financial backing, we use this time to design evaluation methodologies that take advantage of creative mechanisms that either have, or can secure, the proper backing."
