VII. Conclusion
We approve SCE's revised request to supplement its energy efficiency activities during the summer of 2005 with the following modifications:
1. As part of the approved $57 million in new expenditures, SCE shall first use $18.7 million in unspent, uncommitted funds from past years.
2. SCE should aggressively seek customers to purchase house fans, pool pumps and air conditioners through its expanded point-of-sale (instant rebate) program.
3. SCE shall not, at this time, remove the age limitation for refrigerators and freezers qualifying for the recycling rebate program.
4. SCE shall not increase the rebate incentive for freezer-only recycling. SCE may redistribute the additional $4 million requested for the recycling program for use in the point-of-sale program, as needed.
5. In its initial comments on the draft decision, SCE shall offer proposals to incorporate the recommendations of ORA, discussed above, as they relate to the Small & Hard-to-Reach business proposal. These comments shall include a proposal for requiring participating customers to adopt a more comprehensive set of measures beyond the summer light bulb replacement.
6. SCE shall withhold any larger-than-current incentive payments for participants in the Summer 2005 Standard Performance Contract lighting retrofit effort until the customer has implemented a more comprehensive plan pursuant to the Standard Performance Contract Program.
1. SCE has identified $18.7 million in unspent, uncommitted funds from past years.
2. It is not reasonable to approve new revenues when there are existing uncommitted funds available.
3. The question of whether or not it is appropriate to focus spending more on one sector as opposed to another is too important and complex to resolve in an expedited proceeding such as this.
4. SCE's adjustments in response to concerns voiced by TURN bring proposed spending closer to the balance achieved by existing programs.
5. The least effective use of a rebate dollar, on a per-unit basis, would be to encourage the purchase of an ENERGY STARâ refrigerator.
6. SCE's revised rebate programs provide a chance to accelerate load reduction in advance of this summer's potential high demand, and will not pose significant new ratepayer costs unless measure are actually installed within the timeframe of the program.
7. It will be beneficial to all involved if more incremental incentive dollars go to the installation of whole house fans, pool pumps and air conditioners, and fewer go to ENERGY STARâ refrigerators.
8. We lack the factual basis in this proceeding to determine that SCE cannot effectively achieve its refrigerator/freezer recycling penetration goals without lifting the age restriction imposed in D.03-12-060
9. The record does not support an increased incentive for freezer recycling.
10. Because we are approving neither the new $15 incentive, nor the removal of the age limit, it is less likely that SCE will need all of the proposed $4 million in additional funds to support its recycling program this summer, regardless of its success in attracting new customers.
11. Even if the small and hard-to-reach summer program would succeed in producing short-run savings with the installation of relatively short-lived compact fluorescent bulbs in place of incandescent bulbs, it may reduce SCE's ability to achieve greater long-run savings by focusing exclusively on lighting measures.
12. By offering higher incentive payments to business customers undertaking only lighting changes this summer, SCE may lose the opportunity to help the same customers achieve greater savings through a more comprehensive energy efficiency strategy.
13. In order to avoid penalizing customers that have applied for participation in this program while this application is pending, SCE proposes to offer the increased rebates to any customer that submitted an application on or after the date that SCE filed this application. This appears to be a reasonable approach provided that SCE only pay the higher-than-current incentives to customers that bring the measures into effect prior to August 31, 2005.
14. The incremental funds for this program would be derived from procurement funds, which are not supported by direct access customers.
1. SCE should redirect $18.7 million in uncommitted funds for the purposes approved in this decision, and fund only the remaining amounts with new revenues.
2. No hearings are necessary.
3. For this reason, the Commission should not require further adjustments to the residential/nonresidential budget balance solely in the name of equity.
4. SCE should be particularly aggressive in pursuing the accelerated implementation of whole house fans, pool pumps and air conditioning.
5. We should not approve SCE's proposed increased incentives for freezer recycling.
6. We should allow SCE to redirect to the point-of-sale rebate program any of $4 million in additional funds approved for the recycling program that it needs to support its efforts to promote the early implementation of whole house fans, pool pumps and air conditioners.
7. If SCE wants to pursue lighting improvements through small and hard-to-reach customers this summer, it must find a way to draw these customers into a broader energy efficiency effort.
8. In order to ensure that SCE is not inadvertently encouraging customers to seek lighting changes in lieu of a more comprehensive approach, we should approve SCE's proposal for Summer 2005 standard performance contracts with the following modification: SCE may offer higher incentive payments for Standard Performance Contract customers that install more efficient lighting this summer, but participating customers must agree to adopt a more comprehensive energy efficiency plan within a reasonable period of time. SCE should withhold any larger-than-current incentive payments until the customer has implemented a more comprehensive plan pursuant to the Standard Performance Contract Program.
9. SCE's proposal for ratemaking treatment is consistent with existing practice and therefore should be approved.
10. We are not persuaded that such direct access customers should be allowed to participate in the Summer Standard Performance Contract.
11. The Commission should approve the revised proposal subject to the conditions set forth in this decision.
12. Consistent with D.03-12-060 et al., SCE should have 100% flexibility to shift the procurement funds approved in this decision between programs designed to reach the company's peak sharing goals for Summer 2005.
IT IS ORDERED that:
1. Southern California Edison Company's (SCE) revised request to supplement its energy efficiency activities during the summer of 2005 is approved with the following modifications:
a. As part of the approved $57 million in new expenditures, SCE shall first use $18.7 million in unspent, uncommitted funds from past years.
b. SCE should aggressively seek customers to purchase house fans, pool pumps and air conditioners through its expanded point-of-sale (instant rebate) program.
c. SCE shall not, at this time, remove the age limitation for refrigerators and freezers qualifying for the recycling rebate program.
d. SCE shall not increase the rebate incentive for freezer-only recycling. SCE may redistribute the additional $4 million requested for the recycling program for use in the point-of-sale program, as needed.
e. In its initial comments on the draft decision, SCE shall offer proposals to incorporate the recommendations of the Office of Ratepayer Advocates, discussed above, as they relate to the Small & Hard-to-Reach business proposal. These comments shall include a proposal for requiring participating customers to adopt a more comprehensive set of measures beyond the summer light bulb replacement.
f. SCE shall withhold any larger-than-current incentive payments for participants in the Summer 2005 Standard Performance Contract lighting retrofit effort until the customer has implemented a more comprehensive plan pursuant to the Standard Performance Contract Program.
2. SCE shall have 100% flexibility to shift the procurement funds approved in this decision between energy efficiency programs designed to reach the company's peak shaving goals for Summer 2005.
3. Application 05-02-029 is closed.
This order is effective today.
Dated , at San Francisco, California.
