14. Leveraging of LIEE with Other Programs Offered in California
14.1. Introduction
We require IOUs to prove that efforts at "leveraging" their LIEE program dollars with programs outside the IOU are effective. We define leveraging as
an IOU's effort to coordinate its LIEE programs with programs outside the IOU that serve low income customers, including programs offered by the public, private, non-profit or for-profit, local, state, and federal government sectors that result in energy efficiency measure installations in low income households.
The Commission has long attempted to require such leveraging, but the results thus far are less than optimal. We therefore require the IOUs to track and report in the annual filings the extent to which their leveraging efforts result in partnerships or other collaboration with non-IOU sources, and most importantly, in dollar savings, energy savings and benefits, and/or increases in program enrollment. We require this showing to ensure that leveraging efforts yield direct benefits to low income households and the LIEE program overall.
14.2. Parties' Positions
PG&E's application describes five new pilot projects that will help PG&E leverage its own LIEE program with the resources of other groups to better find and serve traditionally hard-to-reach low and very low income customers, including shut-in seniors and persons with disabilities, near homeless families with children, neighborhoods in so much need that they require complete revitalization, rural and/or remote populations, and non-English speaking families.
These pilots include working with Habitat for Humanity, Meals on Wheels, the City of San Jose, the City of San Joaquin (Fresno County), Public Housing Authorities (PHAs), as well as other IOUs. In addition, PG&E proposes to: (1) use its CARE customer list in an attempt to enroll all willing CARE customers in LIEE programs, which will provide significantly more customers than needed for the 25% Plan target for 2009-11; (2) incorporate CARE and LIEE enrollment into the public housing intake process; (3) support LIHEAP by waiving the minimum measure rule,93 supporting federal legislation, and continuing the refrigerator leveraging program94; (4) support the CSI by ensuring all LIEE retrofits are performed before solar panels are installed on low income homes or after customers are on the solar waiting list; (5) expand funding of the REACH PLUS Program; and (6) achieve economies of scale by bulk purchasing products where possible.
SDG&E currently coordinates its LIEE program promotions with its Medical Baseline program to leverage with agencies that serve persons with disabilities, as well as with SoCalGas' LIEE program where SDG&E and SoCalGas plan to co-brand activities, in order to increase customer awareness of the LIEE programs and services available, and reduce costs.
SDG&E plans to coordinate future efforts with various communities and agencies including LIHEAP, the San Diego County Health and Human Services, City of Chula Vista, National City, City of San Marcos, San Ysidro community, Metropolitan Water District, California American Water Company, the San Diego Unified School District, and 211 San Diego. SDG&E and the Metropolitan Water District (MWD) are in negotiations to develop a partnership to leverage available program funds for the direct installation of high-efficiency clothes washers. MWD proposes to contribute $110 towards the purchase cost of each high efficiency clothes washer that SDG&E's LIEE program installs.
SCE states that it will continue to leverage and expand its partnerships with local organizations and will seek to include organizations representing seniors, persons with disabilities, mobile home and apartment associations and other groups with ties to potentially eligible customers. In addition, through a coordinated effort with SoCalGas, SCE will continue to leverage the outreach of customers in the areas jointly served by SCE and SoCalGas.
SCE also proposes new leveraging opportunities with the Home Energy Efficiency Rebates (HEER) program, Multifamily Energy Efficiency Rebate Program (MFEER), California New Homes Program, Comprehensive Mobile Home Program (CMHP), Home Energy Efficiency Survey (HEES), Efficient Affordable Housing (EAH), WE&T School Program, Mobile Energy Unit (MEU), Community Language Outreach Program (CLEO), Energy Leader Partnership (ELP), Summer Discount Plan (SDP), Advanced Metering Infrastructure, Medical Baseline, and The Energy Assistance Fund/Rate Relief Assistance Program.
SoCalGas will continue to coordinate its LIEE program with SDG&E's LIEE program in their overlapping service territory in South Orange County, with plans to co-brand activities with other IOUs to increase customer awareness about the LIEE programs and services available as well as developing joint forms with SCE, thus streamlining the enrollment process for both the customer and LIEE program personnel.
SoCalGas also plans to coordinate future efforts with various communities and agencies including LIHEAP, the Imperial Irrigation District, the MWD, Los Angeles Department of Water and Power, in addition to other various cities and local communities, water agencies, and CBOs. Like SDG&E, SoCalGas and the MWD are in negotiations to develop a partnership to leverage available program funds for the direct installation of high-efficiency clothes washers. MWD proposes to contribute $110 towards the purchase cost of each high efficiency clothes washer that SoCalGas' LIEE program installs.
In its protest, DRA expresses concern that the IOUs only propose leveraging that result in dollar savings through existing rather than new leveraging mechanisms. DRA recommends the Commission or the IOUs create a "leveraging application." In its August 1, 2008 brief,95 DRA recommends that all utilities measure leveraging by the following criteria: duplicative activities eliminated, ratepayer costs saved, and resources attracted to serve households increased.
14.3. Discussion
We require the IOUs' leveraging projects to meet three objective criteria. The leveraging must increase energy savings, result in new customer enrollments, or save program costs.
Because the IOUs' description of their leveraging efforts include instances where they intend to coordinate their own programs, it is clear that a definition of leveraging is required. Leveraging does not include an IOU's internal efforts to coordinate programs. (Such activity is considered integration, which we discuss earlier in this decision.) Instead, we define leveraging as
an IOU's effort to coordinate its LIEE programs with programs outside the IOU that serve low income customers, including programs offered by the public, private, non-profit or for-profit, local, state, and federal government sectors that result in energy efficiency measure installations in low income households.
In setting forth a strategic direction for energy efficiency, D.07-10-032 emphasized the need to leverage resources by looking beyond the boundaries of utility territories, Commission jurisdiction, and existing energy efficiency programs. In D.07-12-051, the Commission reiterated this emphasis for LIEE programs and required the utilities to broaden the scope of their efforts, and coordinate with other agencies and businesses in designing, delivering and implementing LIEE programs.
In the Plan, we outline a strategy of increasing collaboration and leveraging of other low income programs and services in order to meet the goal of making the LIEE programs an energy resource. The Plan calls on the IOUs to work with various participants in the industry to identify key areas where data sharing is possible and advantageous; seek legislative changes to ease data sharing between agencies; and develop partnerships with community organizations and other agencies to leverage resources available from local governments, federal, state, and private project funding sources.
The Commission commends the IOUs for providing lists of entities with which they will continue to coordinate or new efforts they will pursue going forward. We direct the IOUs to continue to explore new opportunities and coordinate actual program delivery to promote long term enduring energy savings and cost efficiency. However, simply listing leveraging efforts and new opportunities is not sufficient to meet the criteria we set forth below. The efforts and associated benefits must be measurable.
In response to an ALJ ruling on the subject of leveraging,96 each IOU agreed on the appropriateness of objective metrics for assessing the success of the IOUs' leveraging programs. The IOUs suggested, however, that such metrics be developed at an upcoming Low Income Joint Utility Public Meeting.97 In DRA's response to the ALJ ruling, DRA agreed that the Commission should establish objective metrics by which to assess IOU leveraging efforts and require the IOUs to report their efforts in their annual reports provided each May.98 At the July 17, 2008 workshop on the IOUs' LIEE budget applications, Commission staff presented a preliminary draft of the criteria we discuss here, and each IOU agreed in principle to track and report their performance based on them.
The IOUs shall the following three criteria to measure the level of success of each of their leveraging efforts and partnerships. Further, all partnerships must be outside the IOU and be the subject of an MOU.
(i) Dollars saved. Leveraging efforts are measurable and quantifiable in terms of dollars saved by the IOU (Shared/contributed/ donated resources, elimination of redundant processes, shared/contributed marketing materials, discounts or reductions in the cost of installation, replacement, and repair of measures, among others are just some examples of cost savings to the IOU).
(ii) Energy savings/benefits. Leveraging efforts are measurable and quantifiable in terms of home energy benefits/ savings to the eligible households.
(iii) Enrollment increases. Leveraging efforts are measurable and quantifiable in terms of program enrollment increases and/or customers served.
We will require that the IOUs measure each of the existing and proposed leveraging efforts listed in their applications using these metrics and report the status of each in their annual reports provided each May to the Commission. The IOUs shall identify the level to which the proposed leveraging efforts meet each criterion, and in cases where the leveraging effort or relationship does not meet a criterion, shall provide a reasonable explanation. Energy Division shall make recommendations to the Commission if the IOUs' leveraging efforts are failing to meet the objective metrics we establish here, and the IOUs shall cooperate with the Energy Division, as necessary to assist the division in making its recommendations.
Setting the above criteria will help transition the LIEE program into a resource program that results in home energy benefits to the low income community while also creating costs savings for the IOUs. As identified in the Commission-issued Plan, successful leveraging is a goal that will in the end help streamline and improve customer identification and program delivery. The above criteria should encourage and foster beneficial leveraging partnerships.
The most obvious leveraging opportunity is the federal LIHEAP program, administered by the DCSD. The record of the July 17, 2008 workshop provides evidence that leveraging between the IOU programs and LIHEAP requires improvement. This Commission will execute a MOU with the DCSD to ensure we are facilitating leveraging to the maximum extent possible, and we have initiated contacts for this process, but we need the IOUs to focus far more attention in this area.
From the workshop record, we know that the IOUs' current programs do not adequately leverage with LIHEAP. They do not always know if a house has had LIHEAP treatment until they get there. This data vacuum is untenable, and IOUs shall immediately change it. The IOUs shall also make arrangement with DCSD or LIHEAP contractors to have their personnel trained on what the LIHEAP program entails. This training should accomplish two things - build bridges between LIEE and LIHEAP personnel, so they can begin working closely together - and make sure LIEE personnel are well aware of the nature and services of the LIHEAP program.
The IOUs make proposals for better LIHEAP leveraging. For example, SDG&E will work to: (1) implement a structured referral system to allow for flexibility between program participation where customers can be referred to the other party should a service or measure not be provided in one program; (2) track customer referrals in the program database and measures installed by LIEE or LIHEAP; and (3) provide LIHEAP contractors serving the San Diego area access to SDG&E's LIEE database to enable them to pre-screen their clients to see if they have received LIEE services from SDG&E along with a list of the measures installed. SoCalGas proposes data sharing and a structured referral system with the LIHEAP program to avoid duplication of effort. PG&E contracts with LIHEAP for distribution of bulk purchased refrigerators. This is a good start, although we are surprised this leveraging is not already taking place.
Several parties point out in comments that there is no LIHEAP database in place that allows LIEE providers to know whether a house has received LIHEAP measures or what those measures are. We cannot require the IOUs to gather information that does not exist. However, we expect the IOUs to enter into an MOU with DCSD and, along with the Commission, to work toward development of such a database. It is untenable that decades into the LIEE program, there is no means of obtaining or estimating such data. The IOUs shall fully cooperate with efforts to remedy the situation, and shall use whatever means currently available to them to learn which homes have already received LIHEAP service, and what measures are already in those homes.
The goal is for LIHEAP and LIEE measure installation to happen at the same time, or sequentially, as part of the Whole Neighborhood Approach. The IOUs shall, as part of their leveraging strategies, immediately begin the process of trying to close data gaps that hamper LIHEAP-LIEE leveraging. We expect to see significant progress toward a goal of 100% LIHEAP and LIEE leveraging and coordination in the IOUs annual reports.
93 PG&E proposes a change the LIEE and LIHEAP home weatherization minimum three-measure rules to qualify a home for treatment.
94 Under this program, interested LIHEAP agencies that are not LIEE contractors may contract with PG&E to provide refrigerators to eligible PG&E customers. By providing the refrigerator under LIEE funding, the LIHEAP agency can stretch its dollars to offer more services to more homes.
95 Brief of the Division of Ratepayer Advocates on the Applications of Pacific Gas & Electric Company, San Diego Gas & Electric Company, Southern California Gas Company, and Southern California Edison Company for Approval of 2009-11 LIEE and Care Programs and Funding, filed August 1, 2008, pp. 30-33.
96 ALJ Thomas' Second Ruling Seeking Further Information on Large Investor Owned Utilities' 2009-11 Low Income Energy Efficiency/Care Application, filed June 25, 2008 (ALJ Second Ruling), p. A-2.
97 Response Of Pacific Gas And Electric Company (U 39 M) To June 25, 2008 Administrative Law Judge's Ruling Seeking Further Information On Large Investor-Owned Utilities' 2009-11 Low Income Energy Efficiency/CARE Applications, filed July 7, 2008, pp. 5-6; Response Of San Diego Gas And Electric Company To The Administrative Law Judge's Second Ruling Seeking Further Information From The Large Investor-Owned Utilities' 2009 - 2011 Low Income Energy Efficiency/Care Applications, filed July 7, 2008, pp. 8-9; Response Of Southern California Gas Company To The Administrative Law Judge's Second Ruling Seeking Further Information From The Large Investor-Owned Utilities' 2009 - 2011 Low Income Energy Efficiency/CARE Applications, filed July 7, 2008, pp. 6-7; Response Of Southern California Edison Company (U 338-E) To The Administrative Law Judge's Second Ruling Seeking Further Information On Large Investor-Owned Utilities' 2009-11 Low Income Energy Efficiency/Care Applications, filed July 7, 2008, pp. 4-5.
98 Response of the Division of Ratepayer Advocates to the Administrative Law Judge's June 25, 2008 Ruling, filed July 7, 2008, p. 2.
