1) Viewing Energy Upgrade California as a market transformation oriented program;

2) Making a long-term commitment to Energy Upgrade California, including a stepwise declining incentive approach;

3) Requiring building permit information to receive incentives for HVAC in the Energy Upgrade California program, and requiring compliance with new legislation aimed at improving code compliance;

4) Expanding the role of local governments in the Energy Upgrade California effort;

5) Increasing the emphasis on workforce training in the Energy Upgrade California program;

6) Fine-tuning Energy Upgrade California incentive design to appeal to moderate- and middle-income households;

7) Improving the Energy Upgrade California program and HERs software; and

8) Other program direction related to clarifying the definition of the program and adding specificity to the Energy Upgrade California PIPs.

Reach all existing homes and maximize their energy efficiency potential through delivery of a comprehensive package of cost-effective, whole house energy efficiency retrofit measures - including building shell upgrades, high efficiency HVAC units, and emerging deep energy reduction initiatives - with comprehensive audits, installation services and attractive financing. This can be achieved through parallel and coordinated initiatives among utility programs, private market actors, and state and local government policies.203

By definition, a long-term market transformation program (like Energy Upgrade California) begins in a very different place than it ends; in a successful program, cost-effectiveness metrics improve consistently over time to the point that the new practices, technologies, etc., become something like standard practice. The existing building retrofit space is on the front-end of a 10+ year effort, and we suggest that its cost-effectiveness be evaluated periodically through a series of volume-based or other similar milestones. Such an approach would respect the coming evolution of this marketplace and keep in view the long-term goals of the Commission."205

a. The IOUs should add incentives aimed at increasing the participation of HVAC contractors in the Energy Upgrade California program;

b. The IOUs should streamline review procedures for converting or "upselling" HVAC emergency replacement jobs into full whole house Energy Upgrade California jobs; and,

c. The IOUs should require that, for the HVAC upstream incentive and Energy Upgrade California programs, contractors represent and warrant that all applicable permits have been obtained.207

1. Energy Upgrade California jobs involving HVAC replacements must include submittal of the HVAC permit number and a contractor certification that appropriate permits have been obtained, for inclusion in IOU Energy Upgrade California program records.

2. The IOUs shall make a showing in their 2013-2014 applications of all programs to which the requirements above apply, and present copies of the incentive/rebate applications or other documentation providing evidence that they are fully in compliance with SB 454 and this decision.

1. Consider local government pilots aimed at building support for comprehensive energy improvements at the time of home purchase, accomplished via home energy rating and increased installation incentives; and,

2. Explore ways to improve Energy Upgrade California participation amongst moderate income households, by aligning "basic" and "advanced" incentive pathways or replacing the current "basic" approach with a "menu" of approaches, and/or increasing incentives for income-qualified households.216

· Evaluate Energy Upgrade California multifamily program elements launched in the 2011 -2012 period to inform their further expansion in the 2015-2017 period;

· Consider the recommendations of the Multifamily Subcommittee of the California Home Energy Retrofit Coordinating Council (HERCC) and the approaches emerging from the Energy Savings Assistance Program (ESAP) multifamily whole building program development to refine future Energy Upgrade California multifamily program elements;221

· Pursue all avenues to overcome the split incentive barrier;

· Increase targeted outreach to multifamily building owners to drive demand; and

· Ensure that all central system measures (i.e., boilers, central air, water, and heaters) become available via the existing MFEER program, so that the complexity associated with multifamily building owner access to single measure rebates is decreased.222

· Targeted outreach. Local governments are in the best position to market the new whole building incentives and recruit participation in collaboration with industry partners;

· Integrated technical assistance. Local governments can help property owners prioritize their building improvements and refer them to the appropriate resources;

· Training and workforce development. Local governments can sponsor trainings for auditors/raters that serve utility programs as well as other financing programs; and

· Addressing split incentives. Local governments can create educational resources for renters and multifamily property owners.223

1) Should be required to meet national NREL Best Test and/or RESNET standards;

2) Include standardized data reporting requirements to ensure that each approved software calculates energy savings in a manner consistent with other software in the program;

3) Support, but not require, integration of code compliance features within the energy modeling software; and

4) Should allow reflection of the occupants' actual energy usage, i.e., should not rely solely on averages.

1) Move all "feasible" plug load and appliance subsidy programs upstream to manufacturers to reduce program administrative costs, and develop clear criteria for the appropriate incentive delivery channel for all incented measures;

2) Reduce program costs by capturing efficiencies in the development of retailer partnerships across appliance types;

3) Reorient appliance recycling program activities to reflect market changes; and

4) Strive to rapidly transition technologies from the Plug Load program into Title 20 codes.241


NTG ratio











1) Add New Appliances: Expand recycling efforts to include clothes washers and air conditioners;

2) Switch to Distribution Center Pick-Ups: Reduce overall program costs by directing retailers to pick up units for recycling. IOU program collections of appliances in the home could be replaced by collections at partner retailer distribution centers. IOUs must avoid duplicating existing efforts with these strategies;

3) Emphasize High Consumption and Secondary Units: Target units with highest savings potential and emphasize collection and recycling of vintage models, secondary units, and extra freezers;

4) Influence Appliance Purchaser's Decision: Use the results of current recycling retailer trials to determine the best approaches to partnering with retailers. These partnerships could seek to cost-effectively capture savings through influencing a new appliance purchaser's decision to retire their old units. IOU retailer partnerships could include delivering new appliances at the same time as collecting old units for recycling. The IOUs should seek to coordinate collection of old units with appliance manufacturers and recyclers;

5) Participants Receive Appliance Incentives upon Surrender of old Appliance: Condition the provision of appliance incentives upon surrender of older units for recycling;

6) Transition of Recycling to Market Actors: Transition the current appliance recycling program to market players by a specific date;

7) Highest Standard of Recycling: Require ARP participating recyclers to comply with highest standards of recycling, including for GHG emissions in refrigerants and foam insulation; and

8) Properly Target Multifamily Residences: Develop new recycling approaches for the multifamily sector, including a bulk exchange approach.

1) Use incentive design to encourage the early adoption of base and "Reach" 2013 Title 24 Standards;248

2) Increase incentive levels to make the program more attractive to participating home builders;

3) Emphasize measures that incorporate future code cycles in Residential New Construction design curriculum, and technical and design templates; and

4) Support development of a Zero Net Energy Roadmap that identifies efficiency measures likely to be adopted into Title 24 Standards in 2017 and 2020 for inclusion in the IOU Residential New Construction program.

202 Strategic Plan at 11.

203 Programmatic Guiding Ruling (December 12, 2011) at 7.

204 D.09-09-047 at 73: "This is not a hard cap, ... but a budget target." See also Programmatic Guidance Ruling (December 7, 2011) at A32.

205 CCSE Reply Comments on Programmatic Guidance Ruling (January 6, 2011) at 4; and, CCSE Comments on Phase IV Scoping Memo (November 8, 2011).

206 Strategic Plan at 11 and 18.

207 Programmatic Guidance Ruling (December 7, 2011), at A33.

208 PG&E's minimum energy savings threshold for Energy Upgrade California advanced path rebates is 15%, whereas SDG&E and SCE/SoCalGas apply a 10% minimum threshold (see "Statewide Residential Program Implementation Plan" at http://eega.cpuc.ca.gov/Main2010PIPs.aspx ).

209 Environmental Health Coalition Reply Comments to Programmatic Guidance Ruling at 2.

210 We note that the 2010-2012 Upstream HVAC Incentive Program is currently operated as a commercial program. The Staff proposal was silent as to whether it applied to residential only. Therefore, we address commercial, as well as residential, in this discussion. Further, we extend this discussion to include any statewide, third-party, or utility local programs offering incentives for HVAC equipment requiring a permit, including but not limited to the Energy Upgrade California, MFEER, Home Energy Efficiency Rebates, Deemed Incentives, and Calculated Incentives programs, etc.

211 PUC 399.4(a)(1).

212 CBPCA Comments on Programmatic Guidance Ruling (December 23, 2011) at 5.

213 Programmatic Guidance Ruling, Attachment A at A32.

214 Statewide Marketing and Outreach Ruling at 1.

215 NRDC, Greenlining, Ella Baker Center for Human Rights, Green for All, CILMT, DRA, CBPCA, and BPI.

216 Programmatic Guidance Ruling at A33.

217 See "Technical Support Contract" for AB 758 Program Development, CEC, at http://www.energy.ca.gov/ab758/documents/AB_758_Technical_Support_Contract_Scope_of_Work.pdf.

218 D.09-09-047 at 120.

219 We understand that some CEC American Recovery and Reinvestment Act-funded Energy Upgrade California pilots are testing the "whole neighborhood" approach, and would prefer to see evaluation results from these pilots before mandating them on a broader scale.

220 Residential Appliance Saturation Survey (2010). CEC.

221 "Improving California's Multifamily Buildings: Opportunities and Recommendations for Green Retrofit and Rehab Programs: Findings from the Multifamily Subcommittee of the California Home Energy Retrofit Coordinating Council. (April 2011).

222 Programmatic Guidance Ruling at A34.

223 LGSEC, Comments on Programmatic Guidance Ruling; D 09-09-047 at 120.

224 The one-stop-shop should apply to the forthcoming multifamily Energy Upgrade California program. Program implementers should also be adequately trained to ensure that the one-stop-shop includes relevant non-utility incentives for multifamily buildings and/or units that quality as low income.

225 Strategic Plan at 18.

226 Strategic Plan at 20.

227 D.09-09-047 at 120.

228 Officially known as "HERs for Field Verification and Diagnostic Testing," the 1999 Home Energy Reports I regulations established the basic framework for Home Energy Reports rater training, certification, and quality assurance systems. See http://www.energy.ca.gov/HERS/.

229 A residence in compliance with Title 24 in the year it is rated is awarded a Home Energy Reports II score of one hundred, and is considered a "reference home" against which other homes are compared. A Home Energy Reports II score of "zero" is intended to indicate a "zero net energy home." A typical range of Home Energy Reports scores for homes built before 2008 would be 101 - 250.

230 CBPCA, Efficiency First, CCSE, SolarCity, BPI, and DRA.

231 BIG Comments on Programmatic Guidance Ruling.

232 RESNET (the Residential Energy Services Network) was founded in 1995 by the National Association of State Energy Officials and Energy Rated Homes of America to develop a national market for home energy rating systems and energy efficient mortgages. RESNET's standards are recognized by the federal government for verification of building energy performance for such programs as federal tax credits, the EPA's ENERGY STAR program, and the U.S. DOE's Building America Program. See http://www.resnet.us/about.

233 This coalition includes American Council for an Energy Efficient Economy; Alliance to Save Energy, NRDC, RESNET, and Efficiency First.

234 DRA Comments on Programmatic Guidance Ruling (December 23, 2011) at 5.

235 See D.11-07-056 at 143: "Availability of Aggregated Usage Data. Covered entities shall permit the use of aggregated usage data that is removed of all personally-identifiable information to be used for analysis, reporting or program management provided that the release of that data does not disclose or reveal specific customer information because of the size of the group, rate classification, or nature of the information."

236 Roughly stated, the "15/15" approach adopted in D.97-10-031 requires that aggregated information provided by an IOU without customer written authorization must be aggregate data of at least 15 customers, and that a single customer's load must be less than 15% of the aggregated data. D.97-10-031 addressed non-residential customer information only.

237 "Anonymized" data does not reveal the specific identity or location of the customer.

238 We discuss multifamily elements of the Energy Upgrade California program separately.

239 This excludes the Multifamily Energy Efficiency Rebate (MFEER) program budget. MFEER includes rebates for some appliances, and is discussed in the Energy Upgrade California multifamily section above.

240 Excluding the Appliance Recycling Program which is addressed in a separate subsection.

241 Programmatic Guidance Ruling, at A30.

242 Programmatic Guidance Ruling at A5.

243 Programmatic Guidance Ruling at A39.

244 Programmatic Guidance Ruling, Attachment A at A40.

245 PG&E's ARP program was not a free-standing program during this period, so there is no ARP program specific total resource cost estimate available.

246 Note that D.11-07-030 updating ex ante energy savings values will impact these reported Total Resource Costs during the 2010-2012 period, mostly downward. We do not have access to the updated ARP Total Resource Costs based on these updated ex ante values at this time, however.

247 See Programmatic Guidance Ruling (December 7, 2012) at A40 for information on the party making each of these recommendations.

248 "Reach" codes are 15% and 30% more efficient than "base" Title 24 codes, as articulated in California's Green Building Standards Code's voluntary Tier 1 and Tier 2 standards respectively. See: http://www.hcd.ca.gov/CALGreen.html.

249 Programmatic Guidance Ruling at A37.

250 Strategic Plan at 6.

251 D.08-09-040 at 16, 18, and 19.

252 Programmatic Guidance Ruling at A37.

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