5. Energy Efficiency Education Should Result in Measure Installation
5.1. Introduction
We strongly support energy efficiency education that happens at the same time as installation of energy efficiency measures. However, we deny funding for energy efficiency education that occurs on its own and does not result in prompt LIEE measure installation. The IOUs' responses to data requests the ALJ issued during the proceeding42 indicate that they are complying with this principle, with the exception of SCE.
This approach to LIEE budgets does not mean that LIEE-eligible customers will not receive energy efficiency education. The single statewide ME&O program we discuss later in this decision will deliver comprehensive energy efficiency education to all customers, including low income customers. Further, the IOUs and their contractors deliver substantial energy education as part of the assessment process they use to bring customers into the LIEE program, and this will not change. However, we question the efficacy of balkanized education efforts by individual IOUs, especially if they lead to no actual measure installation or concomitant energy savings.
5.2. IOUs' Education Proposals and Parties' Positions
SCE states that in 2009, every treated household will receive an in-home education kit that includes three CFLs to be installed by the customer. (We disallow such CFL giveaways in our section on Lighting.) According to SCE, the kits will contain a step-by-step guide to taking immediate action to save energy, money and the environment, as well as thermometers and other simple tools that the customers can use to take measurements and make adjustments to their refrigerator, freezer, hot water heater and HVAC system.
No measures will be installed as part of this program because "installation fees will not be paid to contractors for CFLs delivered through the in-home education kit." SCE also proposes door-to-door canvassing structured to provide energy education and awareness to low income customers who might otherwise not be treated through LIEE due to ineligibility for LIEE measures.43 SCE further proposes handing out the education kits at community events.
PG&E proposes to treat 300,000 homes during 2009-11, and each home will receive in-home energy education. PG&E increased the number of homes treated (and thus receiving education) in order to meet the Commission's programmatic initiative of treating 25% of estimated eligible PG&E customers through 2011. PG&E currently provides (and will continue to provide in 2009-11) energy education/assessment to all customers treated through the LIEE program. Increased numbers of customers treated results in increased numbers of energy education sessions. In-home energy education is provided to LIEE participants during the initial visit at the same time the participant's home is assessed to determine what measures can be installed. Each of these assessed and educated homes will receive energy efficiency measures, either immediately or through appointments.
For SDG&E, the difference in in-home energy education provided in 2008 as compared to 2009 is reflective of the number of treated homes proposed for each year. SDG&E proposed treating 10,440 homes in 2008 and is proposing to treat 20,000 homes each year for 2009 through 2011. SDG&E's in home education budget will increase by over 700% over the prior budget cycle, but we find that its customized approach is tied directly to measure installation.
SDG&E will carry out a customized energy assessment and audit in each home. As we note in discussing our Whole Neighborhood Approach, we require all IOUs to implement this approach. As a result of the audits, SDG&E will offer each customer energy savings tips specific to that home based on the assessment and audit results. SDG&E states that it expects that the majority of education sessions will result in installation of energy efficiency measures. Where an opportunity to install measures through the LIEE program guidelines exist, those measures will typically be installed within 30 days.
It is unclear why the energy audit and measure installation visits do not occur at the same time. As we discuss in the Tiering/Segmentation section of this decision, the Whole Neighborhood Approach shall include energy audits and measure installation that occur at the same time, except where impossible.
SoCalGas proposes to increase energy education sessions in order to further the Commission's goal of accomplishing the programmatic initiative of reaching 25% of all willing and eligible households in the 2009-11 period. SoCalGas anticipates that the increase in energy education sessions, combined with SoCalGas' new customized, audit-based approach to energy education, will generate greater adoption of energy saving practices by customers. Based on the results of the customized audit, energy education tailored to the individual customer will consist of the following:
Measures to be installed and associated energy savings; customer-generated goals related to energy use; potential benefits to the customer and the environment and economy; potential improvements to health, comfort, safety, and quality of life; and comparison of energy usage patterns of households with similar characteristics.
SoCalGas plans to identify household energy behaviors and install the appropriate mix of measures that will improve the comfort of the residence, while also assuring that any potentially unsafe conditions are found and corrected.44 In addition, the energy education component of the program will continue to provide safety and comfort related information covering topics such as natural gas and electric safety rules, what do to if you smell gas, helping the environment through energy efficiency (including water conservation) and reducing greenhouse gases emissions, and other low income assistance programs.
SoCalGas will conduct energy education at the same time that LIEE customers are qualified and enrolled in the LIEE program and SoCalGas anticipates that the majority of customers receive energy efficient measures within 30 days of the enrollment date. As we note in connection with our Whole Neighborhood Approach discussion, we expect all IOUs to hasten this process so that, except where impossible, energy audits and measure installation occur at the same time.
DRA objects to PG&E's proposal to expand its 2007-2008 pilot of Energy Education workshops in 2009-11. Noting that such workshops are not connected to the LIEE program delivery model of obtaining immediate installations and savings, DRA asks that the Commission remove the costs of the energy education workshops from the LIEE budget.
A W.I.S.H. also opposes funding of education-only programs. "[W]e enthusiastically endorse the ALJ's admonition that energy education or CFLs alone will not carry the day, but rather that enduring measures are needed."45
5.3. Discussion
We disallow the portion of SCE's budget devoted to effort that involves education-only kits not tied to measure installation. We also disallow SCE's proposal for "door-to-door canvassing structured to provide energy education and awareness to low income customers who might otherwise not be treated through LIEE due to ineligibility for LIEE measures." PG&E's Energy Education workshops also violate the principles set forth above, and we disallow them.
We continue to allow all the IOUs and their representatives to conduct education that results in new LIEE enrollments or measure installation, or that occurs as part of an energy audit. We allow IOUs to fund facilitated education, including workshops, provided such workshops target low income persons eligible or likely to be eligible for LIEE and take steps to enroll customers in LIEE. Our intent is to disallow classroom-type education for customers who are not LIEE eligible or who the IOUs (or their representatives) do not attempt to enroll in the LIEE program after receiving the educational information. We also disallow distribution of educational kits or other materials to customers who the IOU does not enroll in the LIEE program. Such education will happen as part of the single statewide ME&O program in a more coordinated way, as we discuss in the next section.
42 The data provided below under "IOUs' Education Proposals" come from the responses to ALJ Thomas' Ruling Seeking Further Information on Large Investor Owned Utilities' 2009-11 Low income Energy Efficiency/Care Application, filed June 17, 2008.
43 Response of Southern California Edison Company to the 2008 Administrative Law Judge's Ruling Seeking Further Information On Large Investor Owned Utilities' 2009-11 Low Income Energy Efficiency/CARE Applications, filed June 27, 2008, p. 3.
44 As we discuss elsewhere in this decision, we require the IOUs to install all feasible measures (as "feasible" is explained in this decision) in all homes, regardless of energy use. To the extent SoCalGas or any other IOU proposes to install different measures based on different levels of energy use, we do not allow such action. IOUs should install measures based on what is feasible in a particular housing type, and what measures the 0.25 cost-effectiveness list allows.
45 Comments by [A W.I.S.H.] on Applications for Low Income Programs for 2009-11, filed August 1, 2008, p. 1.