3. Positions of Parties

In their Bridge Funding Request, the Utilities propose to:

1. Fund all "successful" 2006-2008 energy efficiency program operations (as listed in Attachment A of the Bridge Funding Request) until the Commission acts upon their applications.

2. Undertake 2009-2011 program planning activities during the bridge period.

3. Conduct evaluation, measurement and verification (EM&V) related to 2009-2011 planning and activities.

4. Record program planning activities and EM&V expenditures incurred from January 1, 2009 to the effective date of a final decision on the Utilities' applications in the currently authorized energy efficiency balancing accounts.

5. Allow the annual revenue requirement at the levels shown for each Utility in Attachment C of the Bridge Funding Request to be included in rates effective January 1, 2009, through existing authorized mechanisms for energy efficiency.

6. Count the energy and demand savings achieved through the bridge period toward the 2009 energy efficiency goals adopted by the Commission.

The Natural Resources Defense Council (NRDC) supports bridge funding to maintain continuity in providing energy efficiency services to customers across California. NRDC and City and County of San Francisco (CCSF) recommend that the Commission clarify the end date for local government partnership (LGP) bridge funding, so that LGP programs can be eligible for continued bridge funding beyond the three month transition period requested by the Utilities to avoid disruption of these programs. Silicon Valley Leadership Group (SVLG), National Association of Energy Services Companies (NAESCO), and Quantum Energy Services & Technologies (QuEST) also support the Utilities' Bridge Funding Request.

The Commission's Division of Ratepayer Advocates and The Utility Reform Network (DRA/TURN), filing jointly, oppose aspects of the Utilities' Bridge Funding Request. They argue that the Commission should set bridge funding levels using a single formula calculating the monthly average for the 2006-2008 period, thereby rejecting the different calculations and adders proposed by the utilities. DRA/TURN propose to use the monthly average budgets from the 2006-2008 program period for each month of bridge funding, which would result in monthly budgets of $54.7 million instead of $85.5 million requested in total by the Utilities. DRA/TURN also take issue with the Utilities' request to fund all "successful" 2006-2008 programs in the bridge funding period, because the Utilities have not provided a definition of what constitutes a successful program.

Women's Energy Matters (WEM) finds it inappropriate that the Utilities' Bridge Funding Request is proportionate to the monthly average of 2009-2011 funds instead of the monthly average of their 2006-2008 funds, as the Utilities would use higher funding levels for new third party programs instead of only continuing existing programs. WEM believes using the Utilities' proposed funding level would prejudge the final decision on 2009-2011 programs. However, WEM supports allowing local governments and existing third parties to begin new procedures and program designs. WEM also recommends a maximum of one-year bridge funding. The California Water League (CWL) proposes allowing new programs as well as rollover programs to be approved and to commence and distribute funding.