5. Statewide Reporting Requirements
In D.09-09-047 at 7, the Commission directed the utilities to develop and implement twelve statewide programs during the 2010-2012 program cycle, specifically directing the IOUs:
... to ensure utility offerings are coordinated (i.e., the same) across a number of areas, including: a) program name, b) incentive levels offered, c) same or very similar delivery mechanisms, d) same or very similar marketing materials, e) regular inter-utility coordination, f) on-going review and adoption of best practices and feed-back from program evaluations across the utilities, and g) intra-utility coordinated actions with state, local and federal agencies and other key actors.
Joint IOUs contend they have worked in close coordination to develop nearly identical programs to provide the same customer experience to customers across the State and are currently developing a more formalized structure to maintain consistency across utilities throughout the program cycle. However, due to regional, customer, and/or utility differences, Joint IOUs claim to have encountered situations in which limited variations between programs are necessary or beneficial to address specific needs. For example, the Direct Install Program is currently offered to customers with demand of 100 kW or less. While this limitation is necessary for SDG&E, due to the smaller size customers they serve, Joint IOUs assert that it may be beneficial for SCE and PG&E to expand this program (e.g., to customers with demand up to 200 kW) to more successfully address this market in their service territories.
Rather than constrain the utilities' ability to successfully address a viable market in an effort to maintain statewide uniformity, Joint IOUs request that the Commission allow for reasonable and appropriate variations within statewide programs to best address unique IOU needs. As such, Joint IOUs request modifications to D.09-09-047 to state that requirements a-g (listed above) shall be "the same or very similar" for any statewide program. Currently, out of seven required elements, only delivery mechanisms and marketing materials may differ at all among IOUs for any statewide program. Under the IOU proposal, each IOU could vary each of the seven elements slightly for any statewide program.
Further, Joint IOUs recommend that these variations be reported through the Commission's Energy Efficiency Groupware Application (EEGA) reporting system within statewide programs throughout the course of the program cycle. This process will allow the utilities the needed flexibility to make appropriate real time adjustments to programs based on actual program experience during the cycle, but would also ensure transparency and accountability to maintaining an acceptable level of statewide uniformity. Specifically, any utility that deviates from the statewide program would be required to report any exceptions, including a rationale, through regular quarterly reporting, consistent with past reporting procedures. All variations, with justification, would be included in an appendix to the program implementation plan to ensure an up-to-date record of the program plans.
To ensure appropriate limitations to program variations, Joint IOUs request that the Commission should also explicitly require that: (1) any variation of incentives that is greater/less than 50% of the agreed upon statewide incentive level would require immediate Energy Division notification; and (2) any program modification that would require changes to the structure of the program logic model would require immediate Energy Division notification, to ensure coordination with evaluation, measurement, and verification processes.
DRA/TURN oppose these modifications. They contend that with these modifications, any utility could abandon the Commission's policy approach seeking statewide uniformity, so long as it notifies Energy Division that it is so doing. DRA/TURN urge the Commission to reject this request to reverse the progress that has been made in developing consistent statewide programs, and instead require the utilities to offer consistent program offerings across the state.
We will adopt certain of the modifications sought by the Joint IOUs in this area. It is reasonable to allow small variations to statewide programs to fit the needs of different IOU territories, as long as these variations are generally consistent with the intent and design of the statewide programs. This approach was already recognized in part in D.09-09-047, which allowed certain elements of statewide programs to be "very similar" instead of exactly the same; extension of this concept to other aspects of statewide programs is consistent with the intent of D.09-09-047 and constitutes a reasonable modification to that decision. In particular, we continue to want to ensure that third-party implementers can easily work among and between different utilities across California without concern over differences in utility programs. Therefore, we will modify D.09-09-047 to add a new Ordering Paragraph to state:
Pacific Gas and Electric Company, Southern California Edison Company,
San Diego Gas & Electric Company, and Southern California Gas Company shall ensure statewide utility energy efficiency offerings are coordinated (i.e., very similar or the same) across a number of areas, including: a) program name, b) incentive levels offered, c) delivery mechanisms, d) marketing materials, e) regular inter-utility coordination, f) on-going review and adoption of best practices and feed-back from program evaluations across the utilities, and g) intra-utility coordinated actions with state, local and federal agencies and other key actors.
We find that the other specific language changes proposed by the Joint IOUs are too far-reaching, as their proposal would provide essentially unlimited flexibility to modify current statewide programs - including incentive levels - with no oversight beyond notification to Energy Division.9 This approach would undermine the foundational concept of having statewide programs. Further, Joint IOUs provide no specific justifications for deviations in incentive levels or changes to program logic models. The utilities continue to have the ability to file advice letters to seek further programmatic changes.
9 We have no concern about the IOU proposal to report variations in statewide programs in the EEGA reporting system.
