4. Discussion
The broad, collaborative market-transformation activities envisioned by the Plan require new approaches. As noted in D.07-10-032, the Plan requires a pronounced commitment from business and government leaders, as well as a process to collaboratively engage the expertise of market sector professionals and the leadership of key stakeholders.3 To this end, the Plan was also designed to be a living document that includes ongoing opportunities for stakeholders to discuss progress toward objectives and implementation milestones, findings from market assessments or program evaluations, changes in the marketplace, and possible improvements.4 As stated in D.08-09-040, the Plan does not identify a process to track progress towards the defined end points; therefore, a key priority for the first Plan update is to include identified timeframes, defined end points, and processes to track progress.5
In D.09-09-047, a few key themes emerged. One was the importance of laying out action strategies that extend beyond utility programs. Another went to the need for the Commission to take a public leadership position in championing this broad perspective both in a planning document and its subsequent implementation.6 D.09-09-047 directed the Energy Division to issue a Strategic Action Plan Progress Report by June 2011, to enable the Commission and the energy efficiency community in California to track the progress of Plan implementation. This report will assess each of the major sectors' key actions, coordinated tasks, and timelines necessary to achieve the goals of the Plan. As part of its review process, Energy Division provides quarterly updates starting in June 2010 on California's progress toward the Plan's 2009-2011 near-term milestones.7
To address all of these issues and create the necessary structure to track progress and implement the Plan, Energy Division - in coordination with utilities, state agencies, a variety of entities in buildings and industry, and a wide range of trade groups and nonprofit organizations - is creating action plans for the Plan sectors. These action plans are designed to: (a) identify the key actions required to achieve Plan milestones; (b) secure leaders (hereafter, "champions") to achieve these actions; (c) track and report on progress; and (d) feed into the development of the Strategic Action Plan Progress Report in June 2011. The action plans are being designed to achieve milestones identified in the Plan by working with Plan champions. In the near-term, the Commission will serve as a central organizational point for Plan champions, via the energy efficiency web portal, offline facilitation of the champions network, and tracking progress towards milestones. Each quarter, updates on actions and progress indicators, as feasible, will be shared via a website.8
PG&E requests that parties be allowed to file written comments on the action plan. To clarify, stakeholder involvement and input is essential to the development of the action plans, because the plans will map the wide range of actions underway or needed from a variety of market players and stakeholders to advance the goals and strategies presented in the Strategic Plan, including in parts of the state not served by IOUs. We will actively solicit stakeholder input and the numerous opportunities for participation in the process will include the opportunity to comment. However, action plans are not part of the formal EE proceeding because they will not set new rules or policies or mandate actions by the IOUs or be adopted by the Commission.
As noted above, the Plan contains brief sections on residential lighting in Chapter 2, and commercial lighting in Chapter 3.9 In order to avoid redundancy and potential conflict between the existing lighting strategies and goals, and the new strategies and goals in the Chapter, it is necessary to delete the existing lighting sections in Chapters 2 and 3 of the Plan, with two exceptions. In particular, strategies 4-4 of the Residential Chapter and 3-3 of the Commercial Chapter are identical and call for the coordinated phase-out of utility incentives for the purchase of CFLs. The phase-out is important primarily because savings from one-time IOU CFL purchases decay over time and, as noted by TURN, phasing out CFL subsidies makes room for other, more effective, high-efficiency lighting products.10 These strategies should not be deleted as they are the only lighting strategies from the existing Plan that are not addressed in the Chapter. Indeed, because these strategies also reflect the Commission's position on CFLs, that due to new state and federal lighting standards, "utility programs promoting CFLs will provide reduced incremental benefit," the Chapter adds a fifth strategy to the "policy for transformation goal" - a coordinated phase-out of IOU incentives for the purchase of CFLs for both residential and commercial applications.
In their comments on the draft decision, SCE and SDG&E seek clarification that the CFL lighting strategies apply to basic CFLs, not specialty CFLs. PG&E agrees. This clarification is consistent with D.09-09-047, which states "The Strategic Plan articulates a number of strategies to advance high performance residential lighting, including a coordinated phase out of utilities incentives for basic CFLs." Therefore, we adopt the proposed change.
Several parties argue that the Chapter should specifically tie the phase-out of basic CFL incentives to the effective date of state and federal lighting standards. We decline to make these changes. As discussed in past decisions, we recognize a number of market and technological changes affect our current and future approach to lighting programs including CFL incentives and that standards are not the sole driving force to shape our policies or goals in this area.11 Indeed, the very purpose of the Strategic Plan and this Chapter is to consider all of the factors and engage a variety of actors who will impact the broad vision and blueprint for transforming the lighting market.
3 D.07-10-032 at 27.
4 D.07-10-032 at 23.
5 D.08-09-040 at 15.
6 D.09-09-047 at 16.
7 D.09-09-047 at 269.
8 The website that will be used is: www.Engage360.com.
9 D.09-09-047 at 22-24 and 41-42, respectively.
10 D.09-09-047, at 136-139.
11 Id. "We agree with DRA, TURN and NRDC that, in concert, the federal stimulus funding, impending standards, and other market forces warrant an adapted response to capturing further lighting potential. The need to achieve major incremental efficiency gains is too urgent and the costs too great to continue to sink ratepayer money into outdated programs. California utilities should continue leading the effort to push the frontier of efficiency opportunity and program execution."
