· Provide missing technical resources that will get more projects implemented;

· Include more public agencies in project implementation;

· Leverage existing local government partnerships to implement these resources; and

· Provide centralized, regional program management and administration by local governments.173

The bridge pilot would test a modification of the process to enable regional networks to independently (emphasis added) prepare and submit program implementation plans directly ....After [the Commission] reviews and approves sponsored PIPs the [Commission] would then direct the IOUs to contract directly with the [local governments] as identified in the PIP to implement programs.180

· Leverage additional state and federal resources so that energy efficiency programs are offered at lower costs to ratepayers;

· Address the water/energy nexus;

· Develop and deploy new and existing technologies;

· Address workforce training issues; and

· Address hard-to-reach customer segments such as low to moderate residential households and small to medium sized businesses.

166 CCSF, LGSEC, Beutler Corporation, DRA, PG&E, and SDG&E.

167 Commission Staff is preparing an evaluation of non-residential programs, including local government partnerships. This evaluation is anticipated to be completed in July 2012.

168 Described in SCE Advice Letter 2445-E-A.

169 PG&E Comments on Programmatic Guidance Ruling at 10.

170 SDG&E Comments on Programmatic Guidance Ruling at 5.

171 Phase IV Scoping Memo, at 5-6, 8.

172 LGSEC Comments on Programmatic Guidance Ruling at 4.

173 Ibid. at 4.

174 Ibid. at 7-8.

175 CCSF Comments on Programmatic Guidance Ruling at 2.

176 DRA Reply Comments on Programmatic Guidance Ruling at 2-3.

177 TURN Reply Comments on Programmatic Guidance Ruling at 2.

178 SCE Reply Comments on Programmatic Guidance Ruling at 3.

179 For example, see "Comprehensiveness in California's Small Business Retrofit Programs Within Local Government Partnerships." May 2009, at 14.

180 LGSEC Comments on Programmatic Guidance Ruling at 4.

181 The menu is contained in SCE Advice Letter 2445-E-A.

182 In its opening comments, SCE asserts that the Proposed Decision wrongly encourages local governments to submit proposals to administer regional pilot partnership programs for the 2013-2014 program cycle. According to SCE, "[i]n 2005, the CPUC thoroughly examined the proposal for non-utility administration of EE programs, and in D.05-01-055 concluded that it requires statutory authority to do so, because the public interest in the EE programs dictates that the CPUC must select an administrator over which it exercises jurisdiction." (SCE Opening Comments at 3.) SCE's argument suffers three significant flaws. First, it is premature. Rather than authorize programs, the Proposed Decision only requests proposals. Second, as fully detailed by LGSEC (see LGSEC reply comments at 3-5), SCE's argument misinterprets the relevant law. Finally, contrary to SCE's assumptions, rather than calling for an independent administrator, the proposal set forth in the Proposed Decision provides for utility oversight of the non-utility administrator.

183 D.05-01-055 at 94.

184 D.07-10-032 at 74.

185 CCSE, DRA, Greenlining, SDG&E/SoCalGas, LGSEC, NAESCO, NRDC, OPower, PG&E, SCE, South San Joaquin Irrigation District (SSJID), and TURN.

186 NAESCO Comments, November 7, 2011 at 7.

187 NRDC Comments, November 8, 2011 at 9.

188 OPOWER Comments, November 8, 2011 at 5.

189 SDG&E/SoCalGas Comments, November 8, 2011 at 7.

190 PG&E's November 8, 2011 comments included a helpful summary of how past third-party program solicitations worked: "Each third party implementer was chosen as part of a Statewide Competitive Solicitation process which included oversight and input by the Peer Review Group (PRG). Third-party implementers are selected based on their ability to penetrate a target market segment given their specific industry sector and/or technology knowledge. These third-party implementers and government partners are measured by the same cost-effectiveness parameters used to measure utility performance. However, additional parameters such as their ability to reach different customer segments are also considered."

191 PRG Report on the 2009-2011 Energy Efficiency Applications of SCE, SoCalGas, SDG&E and PG&E. September 12, 2008.

192 NRDC Comments, November 8, 2011 at 10.

193 The Third-Party Procurement Table and associated purchase orders should include both third-party procurement supporting the IOU's 20% target and "core" programs.

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