Wood Gottstein Agenda Dec. Low Income Energy Efficiency Standardization Project (Phase 3), Calculations For Bill Savings And Reporting Requirements Manual (Phase 2), Including Cost-Effectiveness Testing Of Low-Income Programs.

Relating to Chapter 7 of the Policy and Procedures Manual

SESCO raises several issues relating to Chapter 7 of the Policy and Procedures Manual. SESCO's comments are reproduced below in italics. The Team's response is as follows:

· Section 7.2.5 "should make provisions for homes in which the utility or other authorized party provides a measure pre-approval." The Team does not consider it necessary to include language on measure pre-approval in this section. If pre-approval is used, it is required to consider a measure feasible.

· Section 7.3.2 "does not specify if the caulking on the first floor of a structure should be on the interior or the exterior." The WIS Manual sets specific criteria for 1) selecting caulking materials, and 2) where caulking can be applied. The WIS Manual allows interior caulking around plumbing and electrical penetrations, which blower door studies indicate are major sources of infiltration.

· Section 7.3.4 "should not forbid ... attic insulation because the inspector may have difficulties in the inspection." The actual wording of the non-feasibility condition in Section 7.3.4 is "an inspector cannot gain safe physical access to all treated areas of the attic." The issue here is not one of convenience, but rather of quality control and safety. Inspections of attic insulation jobs are necessary to ensure that insulation was actually installed, the insulation was installed properly, and that no hazards were created. It is unreasonable to require inspectors to inspect a measure when they cannot gain safe access to the measure.

· Section 7.3.9 should be changed to indicate that "energy efficient faucet aerators may be added unless there are pre-existing energy efficient faucet aerators." The energy savings from replacing a standard aerator with a low-flow aerator are very small and the Team urges the Commission to reject SESCO's suggestion.

· Section 7.3.17 should indicate in which CEC climate zones evaporative coolers will be made available. The Team concurs, and suggests revising the last bullet of Section 7.3.17 to read: "Evaporative coolers are available only in CEC climate zones 2, 3, 4, 5, 9, 10, 11, 12, 13, 14, 15, and 16." Availability of evaporative coolers on a utility service area basis will of course be determined by the CEC climate zones which each service areas encompasses.

· Section 7.3.17 (on evaporative coolers) should indicate "when window/wall units should be installed and when portable units are to be installed." Due to rapid deployment, the Team does not feel that it is necessary to restrict installation to specific types of evaporative coolers in individual circumstances at this time. The more general question of the relative efficacy of window/wall evaporative coolers and portable evaporative units should be considered in the more general process of LIEE Program measure assessment.

· Section 7.3.19, "the comparability of refrigerator sizing... should be better defined." The Team's intent was that specific sizing requirements would be covered in contractor training sessions. However, the Team agrees that this policy should be clarified. We propose to use the following language: "The replacement refrigerator shall be equal to or larger than the existing unit, not to exceed 19 cubic feet. However, when two refrigerators and/or freezers are exchanged for a single unit, the replacement unit may be larger than the larger of the two existing units, provided that the new unit is no larger than 23 cubic feet."

· Some priority should be established among evaporative coolers, air conditioners, and whole house fans. This is done to some extent in Appendix D, which deals with rapid deployment measures like high efficiency air conditioners and whole house fans. Sections D.2.2 and D.3.4 indicate that "air conditioners should be replaced only in climate areas not covered by the evaporative cooler program, or where temperatures regularly exceed 100 degrees during the summer months." This language was taken directly from D.01-05-033 (OP 12). Section D.8.2 of the Policies and Procedures Manual indicates: The Team's recommended Policies and Procedures Manual, does not prohibit the installation of both high efficiency air conditioners and evaporative coolers in those climate zones where both are eligible. The Team does not propose any priorities other than those detailed in D.01-05-033.

· Evaporative cooler maintenance should be allowed "only in those areas where evaporative coolers are allowed to be installed." The Team does not feel that this restriction is necessary. If an existing evaporative cooler is present, regardless of climate zone, it will use less energy if it is maintained properly than if it is not. The question is not the efficacy of the customer's initial acquisition of the evaporative cooler, but rather the energy savings that can be achieved through maintenance. Note that, per Section D.9.2, non-operational units will be replaced only in CEC climate zones where evaporative coolers are eligible.