6. Sponsorship Costs

D.09-09-047 sets administrative, direct implementation, and marketing budget caps and targets, and defines some of the activities that should fall under each of these three categories.¹⁰ After the issuance of the decision, Joint IOUs state that they worked with Energy Division to better define and categorize all allowable costs. Through this process, Energy Division provided guidance on several specific costs. Energy Division recommended that the utilities exclude any costs related to sponsorship of conferences as allowable energy efficiency conference costs, but would allow membership-based issue-specific trade organizations that include entry into conferences as a component of membership benefits.

Consistent with Energy Division's recommendation, Joint IOUs request that D.09-09-047 be modified to expand the definition of allowable administrative costs to include costs for energy efficiency program-specific sponsored events or activities, including costs such as conference entry fees for membership-based, issue-specific trade organizations with membership benefits, energy efficiency program recognition, promotions, and staff travel costs to participate in these energy efficiency conferences. Joint IOUs request that such administrative costs for energy efficiency programs be allowed to be funded by energy efficiency funds.

We will adopt the modifications sought by Joint IOUs in this area (with minor edits for clarity) by adding a new Ordering Paragraph to D.09-09-047. No party opposes these modifications. We adopted strict limits on administrative costs in D.09-09-047 in order to ensure the maximum amount of ratepayer funding for energy efficiency programs, as opposed to overhead. The utility-proposed modifications are reasonable and consistent with the intent of D.09-09-047, as they narrowly expand the category of allowable administrative costs to allow utility staff to promote utility energy efficiency programs to targeted audiences.

¹⁰ See D.09-09-047 at 6, 49-51, 57, 63, 73, 238-239, 192, and OP 13.