2. Procedural Background
Joint Staff posted draft EM&V protocols to the website on October 4, 2005, and on the same day I solicited written comments from interested parties on those drafts by ruling.2 As noted in that ruling, Joint Staff's draft protocols did not yet include certain protocols, such as the resource planning component of the integrated EM&V cycle, a process for updating the DEER, and evaluator "how to" protocols for emerging technologies, codes and standards and for measuring persistence and technical degradation.
Opening comments were filed on October 17, 2005 by Southern California Edison Company (SCE), The Utility Reform Network, Natural Resources Defense Council, Office of Ratepayer Advocates (ORA),3 Pacific Gas and Electric Company (PG&E) and jointly by Southern California Gas Company and San Diego Gas & Electric Company. Reply comments were filed on October 24, 2005 by PG&E, SCE, ORA, and Women's Energy Matters.
In response to these comments, Joint Staff and its consultants revised the draft protocols and posted them on the website for public review on December 2, 2005. A two-day workshop to discuss these revisions was held on December 13 and 14, 2005 in San Francisco, with a call-in number for participation by parties who could not attend in person. Approximately 35 individuals and/or organizations attended the workshop, including the program administrators, implementers, EM&V experts, ratepayer advocate groups, among others.
2 See Administrative Law Judge's Ruling Soliciting Comments on Draft Protocols for the Evaluation, Measurement and Verification of Energy Efficiency, October 4, 2005.
3 ORA has recently been renamed the Division of Ratepayer Advocates (DRA).
