10. Lighting Programs
D.09-09-047 approved, as a part of the Statewide Program for Residential Energy Efficiency (SPREE), $78 million for the Basic Compact Fluorescent Lamp subprogram and $89 million for the Advanced Lighting subprogram.285 These programs provide discounts to customers that greatly reduce their cost of energy efficient lighting products. The Commission also approved a budget of $1.5 million for the Lighting Market Transformation program.286 This program focuses on developing and testing market transformation strategies for emerging lighting technologies and commercially viable, advanced lighting technologies into the utility energy efficiency programs.
The Staff proposal contains several recommended changes to the IOU lighting programs for the 2013-2014 transition portfolio:
· Upstream rebates for basic Compact Fluorescent Lamps should be phased-out or significantly reduced;
· The existing residential lighting programs and the Lighting Market Transformation program should be unified into a new statewide Lighting Program consisting of four subprograms: (1) Lighting Market Transformation, (2) Emerging Lighting Technology,287 (3) Lighting Innovation,288 and (4) Primary Lighting;289
· Lighting measures should be consolidated for the residential and nonresidential sectors;
· The Lighting Market Transformation subprogram should continue its current activities but also serve as a coordination program that oversees the progression of new lighting measures from the proposed Emerging Lighting Technology subprogram to the Lighting Innovation and Primary Lighting subprograms; and
· Rebates for advanced lighting including light emitting diodes (LEDs), specialty Compact Fluorescent Lamps,290 efficient incandescent lamps, and dimmable linear fluorescent ballast products should be supported in the 2013-2014 portfolio. The proposal also suggests that rebates for general service screw base light emitting diode lamps should be provided only for products that meet a particular quality standard developed by the California Energy Commission. To maintain lower administration costs, the rebates are proposed to be applied upstream, although they may also be applied midstream for products typically purchased by lighting contractors.
Ten parties filed comments on Commission Staff's lighting proposals for 2013-2014, and eight parties filed reply comments. We address the parties' comments based on each proposal as follows:
DRA supports the elimination of upstream rebates for basic Compact Fluorescent Lamps.291 DRA cites research that indicates the market has transformed and that the saturation rate has remained stagnant at 21% of all sockets. DRA claims this is despite decades of utility-managed basic Compact Fluorescent Lamps programs.292 TURN and SCE support the proposal to eliminate or significantly reduce upstream rebates. SCE explains it has been ramping down rebates for basic Compact Fluorescent Lamps and proposes to continue this during the 2013-2014 transition portfolio.293 LGSEC agrees with the overall assessment regarding basic Compact Fluorescent Lamps.
Ecology Action, City of Berkeley, and the City and County of San Francisco suggest that upstream rebates for basic Compact Fluorescent Lamps should be eliminated but also recommend that rebates and support for downstream comprehensive lighting upgrades still include basic Compact Fluorescent Lamps. These parties' comments generally contend that this direction should be taken to ensure minimal lost savings.294 NRDC states that if potential in the Compact Fluorescent Lamps market remains, the Commission should allow the IOUs to capture those savings with a program designed to maximize customer benefits.295 Synergy Companies endorses NRDC's comments regarding basic Compact Fluorescent Lamps.296
PG&E contends that upstream rebates for basic Compact Fluorescent Lamps should not be eliminated, as cost-effective savings still exist. PG&E contends basic Compact Fluorescent Lamps should be part of a broader channel strategy to provide incentives through retailers serving low-income and hard-to-reach customers.297 SDG&E/SoCalGas recommend that we focus on supporting lighting solutions based on the merits of Total Resource Cost and total energy savings over a product's life, including basic Compact Fluorescent Lamps.298
The Strategic Plan sets forth the Commission's vision for the lighting market with regard to support for basic Compact Fluorescent Lamps: "Utilities will begin to phase traditional mass market Compact Fluorescent Lamps bulb promotions and giveaways out of program portfolios and shift focus toward new lighting technologies and other innovative programs that focus on lasting energy savings and improved consumer uptake."299
A majority of the commenting parties indicate the Commission should not completely remove support for basic Compact Fluorescent Lamps in the 2013-2014 portfolio if it is determined there is available cost effective savings potential remaining. Some parties indicate the rebates should be shifted downstream, echoing the same sentiment that if cost effective savings remain in basic Compact Fluorescent Lamps, the Commission should not pass up the opportunity to capture them.
The 2011 Potential Study indicates that there is remaining cost-effective potential in basic Compact Fluorescent Lamps. While the study indicates this remaining potential is substantially diminished from previous years, this nonetheless contradicts DRA's position that no savings potential remains for Compact Fluorescent Lamps.
As determined in the 2011 Potential Study, the market potential for lighting for basic Compact Fluorescent Lamps in 2013 is 64.13 gWh, and for 2014 it is 34.32 gWh. The incremental market potential for advanced lighting measures, which includes all measures including fixtures, ballasts, controls, light emitting diodes, and specialty Compact Fluorescent Lamps (but excludes basic Compact Fluorescent Lamps), is 562.5 gWh for 2013 and 544.22 gWh for 2014. The incremental market potential for light emitting diodes measures is 56.30 gWh for 2013 and 66.53 gWh for 2014. The incremental market potential for specialty Compact Fluorescent Lamps is 104.5 gWh for 2013 and 118 gWh for 2014. We graphically break out the individual components of the total market potential remaining in lighting for 2013.
We conclude that we should not ignore available cost effective savings that basic Compact Fluorescent Lamps can still provide, particularly when our overall energy efficiency goals for the transition period are less than previous cycles. The IOUs are directed to propose upstream rebates in the Primary Lighting subprogram for basic Compact Fluorescent Lamps to capture the remaining market potential as indicated by the 2011 Potential Study.300 A majority of commenting parties support this direction. We emphasize that the utilities' rebate program for basic Compact Fluorescent Lamps should be limited in size, meaning that its design and budget should be tailored to the limited remaining market potential for basic Compact Fluorescent Lamps. We further clarify that any Compact Fluorescent Lamps potential captured through the Energy Savings Assistance Program (which counts towards the utilities' energy savings goals) during the same period shall be deducted from the amount of Compact Fluorescent Lamp potential targeted and budgeted for in the 2013-2014 energy efficiency program cycle. In their applications, the utilities shall provide detailed testimony and workpapers if necessary, to demonstrate how their proposed basic Compact Fluorescent Lamps program complies with this limitation. The utilities are expected to target specialty Compact Fluorescent Lamps through appropriate program designs to capture the remaining potential in these applications. Specialty Compact Fluorescent Lamps are discussed below in the lighting section of this decision.
The Strategic Plan envisioned phasing out support for basic Compact Fluorescent Lamps. Our guidance to the utilities to propose a much smaller basic Compact Fluorescent Lamps program for the transition period is a step in the phase out process envisioned by the Strategic Plan.
DRA supports the lighting recommendations that emphasize a longer term strategy for market transformation.301 DRA contends the program design should focus on the critical product development "chasm" to take the measures from the early adopter market stage to the early majority.302
SDG&E and SoCalGas concur with the Guidance Ruling Proposal that the IOU lighting program should institute a framework that provides a pathway of support for market transformation.303 They recommend that this process be focused on a market approach that helps develop products, creates awareness, and provides the products at an affordable price. SDG&E and SoCalGas suggest the "lighting program should cover both residential and non-residential sectors, which would provide greater synergy and improve the program's overall effectiveness."304
PG&E recommends the lighting programs continue in the new portfolio as they are addressed in the current portfolio. PG&E asserts that the current rebates best meet the unique needs of each customer segment, many third-party and local government programs incorporate lighting offerings already, and Emerging Technologies currently addresses lighting properly.
SCE comments that an emerging technology program dedicated to lighting runs contrary to the Integrated Demand-Side Management (IDSM) priorities set by the Commission, and that a Lighting Innovation subprogram would be duplicative of Staff's proposed Emerging Lighting Technology subprogram.
The Strategic Plan articulates our vision of the lighting market and future utility lighting programs:
The residential lighting industry will undergo a substantial transformation through the deployment of high-efficiency and high-performance lighting technologies supported by state and national code standards...The utilities will begin to...shift focus toward new lighting technologies and other innovative programs that focus on lasting energy savings ....305
With this in mind, Staff proposes to redesign the IOU lighting programs to (1) more effectively facilitate market transformation for advanced lighting products, and (2) simplify and reduce the number of programs.
One point that is emphasized in the party comments is the need to develop the lighting market in a way that will provide greater and deeper long-term savings. Like resource acquisition and immediate energy savings, the promotion and facilitation of lighting market transformation is crucial to an effective lighting program. We direct the IOUs to include a Statewide Lighting Program in their applications. Specifically, the IOUs are directed to include lighting measures applicable to the residential and non-residential sectors in the Statewide Lighting program. We see benefit to reducing the number and complexity of programs by consolidating lighting measures into a single statewide program. We agree with SDG&E, SoCalGas, and DRA that to facilitate market transformation and a long-term savings strategy, measures for all sectors need to focus on market transformation. Contrary to PG&Es comments, we believe this change will more effectively address the unique market segments by more expeditiously transforming lighting markets in all sectors.
Second, we direct the IOUs to continue supporting technology assessment of pre-commercialized lighting measures in the Emerging Technology Program in the 2013-2014 portfolio. We believe an Emerging Lighting Technology subprogram for lighting is unnecessary and risks duplication of effort. We are confident that the existing Emerging Technology Program, as modified below in this decision, can spur the innovation of new lighting products.
Third, we direct the utilities to propose a Lighting Innovation subprogram to support advanced lighting technologies aimed at early adopters. We concur with DRA that we need to dedicate resources to help these innovative lighting technologies bridge the "chasm" between the early adopters and the early majority. From the early stages of product development, promising measures that exit the Emerging Technologies Program should transition to the Lighting Innovation subprogram for further market development. Addressing SCE's concern that this subprogram would be duplicative of the Emerging Technologies Program efforts, the Lighting Innovation subprogram would support demonstration and pilot projects of measures in the very early stages of commercialization, not pre-commercialization. Moreover, the scale of the demonstration and pilot projects in the Lighting Innovation subprogram should be of a greater scale than those in the Emerging Technologies Program. This will help determine which measures should be eventually supported on a larger scale with upstream rebates.
Finally, we direct the IOUs to propose a Primary Lighting subprogram in the Statewide Lighting Program for the purpose of supporting lighting measures that have reached a greater level of commercialization. This subprogram should receive a majority of the lighting funds and would facilitate rapid market adoption through cost-effective upstream rebates.306 Specific measures that should be in the Primary Lighting subprogram include basic Compact Fluorescent Lamps (as discussed previously) and additional measures that are addressed in greater detail below. This will complete the pathway of market transformation, as measures transfer from the Emerging Technology Program, to the Lighting Innovation subprogram, and then to the Primary Lighting subprogram.
Seeing Staff's proposal as a "fresh approach to program implementation for greater market transformation and deeper energy savings," SDG&E and SoCalGas agree the Lighting Market Transformation program should oversee the progression of lighting measures in the IOU lighting programs.307 However, PG&E suggests the Lighting Market Transformation program should continue serving the same function as it does in the 2010-2012 portfolio, focusing narrowly on developing and testing market transformation strategies.
SCE raises the concern that the Lighting Market Transformation subprogram could be viewed as a peer advisory board that is a separate entity from the utilities. It warns against any of its program administration authority being repositioned to a peer advisory board. SCE argues that D.05-01-055 establishes the IOUs as the program administrators and asserts that legal obstacles prevent peer advisory boards from managing any ratepayer money without statutory authorization.
The Strategic Plan sets a goal to "develop and implement coordinated policies, procedures, and other market interventions that eliminate barriers, accelerate lighting market transformation in California and provide incentives for best practice lighting technologies and systems."308 Further, D.07-10-032 discusses market transformation as it pertains to the lighting market, stating, "[s]hort-term programs such as the replacement of incandescent light bulbs with compact fluorescent lamps bulbs must be accompanied by programs to encourage new technologies in lighting..."
In light of our longstanding position and parties' comments, we direct the IOUs to propose a Lighting Market Transformation subprogram within the Statewide Lighting Program directed herein. The Lighting Market Transformation subprogram should continue developing and testing market transformation strategies, as authorized in D.09-09-047. Using the results of the strategies developed, the mission of the Lighting Market Transformation subprogram would be to facilitate and expedite lighting market transformation. It would do this by overseeing the progression of lighting measures from the Emerging Technology subprogram to the Primary Lighting subprogram. Further, the Lighting Market Transformation subprogram would be tasked with ensuring lighting has adequate representation in the Emerging Technology Program to ensure measures are being evaluated for potential inclusion in the Lighting Innovation subprogram. The Lighting Market Transformation subprogram should contain representatives from each of the utilities and Commission Staff.
We agree with PG&E that the current function of the Lighting Market Transformation program is important and should remain. However, we believe that broadening the Lighting Market Transformation in the specified manner more closely aligns with our policy aims. We find SCE's concerns in regards to the use of advisory groups to be unfounded since the Lighting Market Transformation subprogram would not act as a peer advisory group - and the IOUs will be the administrators of the Statewide Lighting Program.
CILMT concurs with the Staff proposal and supports advanced lighting products in the transition portfolio. SCE encourages the Commission to capture the savings potential that remains for lighting products, including advanced Compact Fluorescent Lamps and light emitting diodes. PG&E agrees that directional light emitting diodes and dimmable linear fluorescent ballasts should be supported in the transition portfolio, but cautions against dimmable Compact Fluorescent Lamps being supported. PG&E contends that the technology enabling dimmable Compact Fluorescent Lamps is not ready for market support, as the user experience with those products has been negative up to this point.309 DRA and WEM disagree, stating that dimmable Compact Fluorescent Lamps can help achieve greater energy savings.310
WEM states that EnergyStar and Design Lights Consortium have provided adequate light emitting diode quality specifications for the Commission to establish as a baseline quality standard for rebates.311 SDG&E and SoCalGas put forth a similar recommendation, stating that the current specifications allowing only Design Lights Consortium or EnergyStar labeled light emitting diode is sufficient to ensure long-lasting high-quality products.312 DRA states that Commission Staff and the IOUs should work closely with EnergyStar, Design Lights Consortium, and the California Lighting Technology Center to create a more advanced light emitting diode standard for California.313 DRA and WEM recommend that all light emitting diode products that receive ratepayer support should include a "Lighting Facts"314 label to help consumers understand the quality of an individual product.315
Finally, TURN cautions that the Commission should determine whether light emitting diodes will likely only replace Compact Fluorescent Lamps in the marketplace, which would not improve energy savings to a significant degree.316
Consistent with the Strategic Plan's emphasis on advanced lighting products, the Staff proposal recommends providing upstream rebates for light emitting diode, specialty Compact Fluorescent Lamps, efficient incandescent lamp, and dimmable linear fluorescent ballast products in the Statewide Lighting Program.317 The 2011 Potential Study indicates substantial achievable savings are available from these advanced lighting measures.
Parties generally favor supporting light emitting diode products in the 2013-2014 portfolio. While the baseline information TURN identified is not widely available, the 2011 Potential Study indicates there is substantial energy savings potential in light emitting diode measures. Much of this is due to the fact that light emitting diode and Compact Fluorescent Lamps technologies tend to be complementary; many applications that are adequate for Compact Fluorescent Lamps, such as omnidirectional installations in portable desktop luminaires, are not as suitable for current widely available light emitting diodes, and vice versa.
In light of the 2011 Potential Study findings and supportive party comments, we direct the IOUs to propose upstream rebates for light emitting diode (LED) measures, including LED down lamps and screw base LED general service lamps, in the Primary Lighting subprogram directed herein.318 In California there is substantial energy saving potential for the replacement of inefficient incandescent down lamps that are deployed in buildings all across the state with more efficient LED down lamps.
We expect the California Energy Commission to adopt a lighting quality standard for LEDs in the current Title 20 Rulemaking. We direct the IOUs to only propose incentives for LED products that adhere to that standard. For example, regarding quality standards, we direct the IOUs to only propose rebates for general service screw base LED products that are consistent with the quality standards developed by the California Energy Commission. We concur that Commission Staff, the IOUs, and the California Energy Commission should consult with U.S. Environmental Protection Agency's (EPA) ENERGY STAR program, Design Lights Consortium, and the California Lighting Technology Center in the California Energy Commission's establishment of a California general service LED standard. We agree with DRA and direct the IOUs to only propose rebates for LED products that have a U.S. Department of Energy Lighting Facts® label, a program of the U.S. Department of Energy and U.S. Federal Trade Commission.319
As noted in D.09-09-047, the Commission is focusing support on high efficiency cost-effective lighting products like specialty Compact Fluorescent Lamps.320 The 2011 Potential Study indicates there are substantial savings remaining for specialty Compact Fluorescent Lamps products. With the exception of dimmable Compact Fluorescent Lamps, party comments support giving incentives for specialty Compact Fluorescent Lamps in the 2013-2014 portfolio. We are concerned about PG&E's contention that the quality of currently available dimmable Compact Fluorescent Lamps is insufficient for ratepayer funding to support these technologies. In deference to this argument, we direct the IOUs to propose upstream rebates for specialty Compact Fluorescent Lamps products, with the exception of dimmable Compact Fluorescent Lamps products, in the new Primary Lighting subprogram.321 However, Party comments regarding support for dimmable linear fluorescent ballasts are overwhelmingly positive. Dimmable linear fluorescent ballasts achieve considerable savings by enabling lower lighting levels when the full lighting capacity of a particular linear florescent lamp is not needed. Accordingly, we direct the IOUs to propose upstream rebates for dimmable linear fluorescent ballasts in the new Primary Lighting subprogram.
285 D.09-09-047 at 140 -141.
286 Budgeted through the staff disposition of Advice Letter 3065-G-B/3562-E-B, dated September 17, 2010 and approved on October 21, 2010.
287 This subprogram would contain lighting measures that are currently supported in the Emerging Technology Program and would also support future emerging lighting technology measures. It would primarily develop small pilots and demonstration projects. As markets for measures are tested and demonstrated through this subprogram and become more mature, they would transition to the Lighting Innovation Program.
288 This subprogram would be designed as an intermediary step to foster markets for measures that are more mature than those in the Emerging Lighting Technology subprogram but less so than those in the Primary Lighting subprogram. (See next footnote). It would develop medium scale pilots and demonstration projects to identify measures that should be supported in the Primary Lighting subprogram.
289 The Staff Proposal originally called this the "Basic Lighting" subprogram. To avoid confusion with basic Compact Fluorescent Lamps, we will rename this the "Primary Lighting" subprogram.
290 Specialty Compact Fluorescent Lamps are mainly Compact Fluorescent Lamps not included in the 2010-2012 Basic Compact Fluorescent Lamps lighting program.
291 DRA Comments on Programmatic Guidance Ruling at 7.
292 DRA Comments on Phase IV Scoping Memo at 1-2.
293 SCE Comments on Phase IV Scoping Memo at 4.
294 City and County of San Francisco Comments on Phase IV Scoping Memo at 2.
295 NRDC Comments on Phase IV Scoping Memo at 2.
296 Synergy Companies Comments on Phase IV Scoping Memo at 3-4.
297 PG&E Comments on Programmatic Guidance Ruling at 13.
298 SDG&E and SoCalGas Comments on Programmatic Guidance Ruling at 11.
299 Strategic Plan at 11.
300 These rebates are applied upstream to minimize administration costs.
301 DRA Comments on Programmatic Guidance Ruling at 7.
302 DRA Comments on Programmatic Guidance Ruling, Appendix A at 5.
303 SDG&E and SoCalGas Comments on Programmatic Guidance Ruling at 10.
304 Id.
305 Strategic Plan at 11.
306 These rebates are applied upstream to minimize administration costs, however the rebates may also be applied midstream for products typically purchased by lighting contractors.
307 SDG&E and SoCalGas Comments on Programmatic Guidance Ruling at 10.
308 Strategic Plan at 99.
309 PG&E Comments on Programmatic Guidance Ruling at 12-13.
310 DRA Comments on Programmatic Guidance Ruling at 7-9.
311 WEM Comments on Programmatic Guidance Ruling at 10.
312 SDG&E and SoCalGas Comments on Programmatic Guidance Ruling at 10.
313 DRA Comments on Programmatic Guidance Ruling at 3.
314 A program of the U.S. DOE, the Lighting Facts® label provides detailed information for consumers, including luminaire light output, efficacy (lumens per watt), measured power (watts), correlated color temperature, and color rendering index. http://www.lightingfacts.com.
315 DRA Comments on Programmatic Guidance Ruling at 3.
316 TURN Comments on Programmatic Guidance Ruling at 8.
317 These rebates may also be applied midstream for products typically purchased by lighting contractors.
318 These rebates may also be applied midstream for products typically purchased by lighting contractors.
319 As of February 2, 2012, the U.S. Department of Energy Lighting Facts® label was provided on 4339 products. http://www.lightingfacts.com.
320 D.09-09-047 at 126.
321 These rebates may also be applied midstream for products typically purchased by lighting contractors.
