4. Protests

In response to the pilot program applications, the Inland Empire Utilities Agency (Inland Empire) filed comments, while the DRA and TURN filed protests. DRA and TURN offered detailed objections to aspects of each of the proposed pilot offerings.

Inland Empire argued that the goal of the pilot program is not to ensure energy savings, but to determine if energy savings can be realized through future investments. For this reason, Inland Empire pleaded for a broad perspective on the pilot programs.

DRA agreed that water conservation is an important concern for California and supports the goal of developing and expanding best practices and existing programs to realize the substantial incremental benefits of joint water and energy resources and infrastructure management. However, DRA pointed out that the purpose of the energy efficiency program is to conserve energy, not water. DRA discussed that the utilities' primary obligation in overseeing energy efficiency programs is to fund programs that will directly benefit their ratepayers, as well as to displace the procurement of more costly and emission-intensive fossil fuels. For this reason, the Commission has prioritized energy efficiency first in the loading order.

DRA asserted that for the purpose of this pilot exercise, the energy efficiency program can only be responsible for conserving water that saves energy within respective energy utility territories to benefit ratepayers who support the energy efficiency programs, and that the energy utilities should not use the outcome of this pilot to favor non-utility programs over those that directly benefit their own ratepayers. DRA argued that a useful and appropriate pilot program should produce data that provides for a meaningful comparison of energy-embedded water conservation programs to traditional energy efficiency programs to determine if there is a place for water conservation in the overall energy efficiency strategy.

TURN protested the applications, offering the following three arguments. First, TURN argued that each application lacks essential information, without which the Commission can neither assess potential ratepayer benefits from the pilots nor evaluate whether the pilots will help answer fundamental questions about water-embedded energy as a demand side resource for energy utilities. Second, TURN claimed that the applications do not appear to satisfy the Commission's directive regarding low-income customers. Finally, TURN states that the applications conflict with existing Commission energy efficiency policies. TURN additionally objected to PG&E's proposed funding mechanism.