IV. Programs Selected
A. Statewide Residential Programs
1. Statewide Residential Retrofit Programs
The Commission designated the statewide residential retrofit category for programs aimed at securing energy savings in existing single-family and multi-family residential homes. These programs include:
· Home energy efficiency surveys
· Appliance recycling
· Single family unit rebates for energy efficiency equipment (no lighting)
· Multi-family unit rebates for energy efficiency equipment (lighting and non-lighting)
a. Home Energy Efficiency Surveys
Each IOU proposes to conduct surveys to assist consumers in determining how they might improve the energy efficiency of their homes. These programs rely on a combination of online and mail surveys. IOU customers fill out the surveys and the individual IOUs offering the programs analyze the results and provide an informal audit to participating customers indicating ways to increase their home energy efficiency. We generally approve the IOUs' proposals with the following exceptions aimed at making the programs consistent.
We adopt SoCalGas' performance targets for each IOU, as they strike an appropriate balance between cost and performance. SoCalGas proposes to conduct 3,000 mail-in and 2,000 online audits at a cost of $150,000. The average cost of each audit is $30. Sixty percent of their proposed audits are by mail, while forty-percent are planned to be done on-line. The other three utilities should be able to conduct audits at no additional per-item cost. Therefore, we will hold the utilities to the performance targets listed in the table below, which we base on SoCalGas' targets.
Moreover, Edison proposes to "explore" creating a Spanish-language written version of its survey. We believe each IOU should develop and make available a Spanish-language written version for both mailing and web-posting within two months of the launch of their programs. We also require that written versions be offered in at least one Asian language of the IOUs' choice, as appropriate, in each IOU territory. IOUs should choose the most prevalent Asian language in their territory. Since it is likely that hard-to-reach customers will be difficult to target through web-based audits, at least fifty percent of mailed surveys should be sent to hard-to-reach customers.
PG&E did not provide a separate proposal for this program. The Commission's Energy Division requested that they do so, but PG&E responded after the due date. Because we believe surveys are a key part of any residential home energy efficiency program, we will require PG&E to conduct them in its territory. We will expect to see program details in PG&E's Program Implementation Plan, but set the budget and thereby the performance targets for this program at the same level as that for Edison, as set out in the following table. We have adjusted PG&E's Single Family Rebates budget to reflect the $900,000 of its funding that we are reallocating to this program.
We approve the following program targets and budgets:
Home Energy Efficiency Surveys |
Mail Audits |
Online Audits |
Total Audits |
Program Budget |
EM&V Budget |
Total Budget |
PG&E |
18,000 |
12,000 |
30,000 |
$900,000 |
$107,000 |
$1,007,000 |
SCE |
18,000 |
12,000 |
30,000 |
$900,000 |
$81,000 |
$981,000 |
SCG |
3,000 |
2,000 |
5,000 |
$150,000 |
$24,000 |
$174,000 |
SDGE |
4,000 |
2,667 |
6,667 |
$200,000 |
$34,000 |
$234,000 |
Total |
43,000 |
28,667 |
71,667 |
$2,150,000 |
$246,000 |
$2,396,000 |
b. Appliance Recycling
In D.01-11-066, we urged applicants to propose programs for refrigerator and other appliance recycling:
Refrigerator, freezer, and room air-conditioner recycling has been offered in various geographic areas within the state through several prior Commission and utility programs. This year, the Commission intends to emphasize programs that reach regions of the state previously unserved by earlier appliance recycling programs to maximize statewide availability. We encourage the utilities to partner with other entities offering these services in specific geographic areas. Any appliance retirement program should offer comprehensive toxic material recycling and disposal in conformance with California environmental laws and regulations and permitting requirements.5
In response, each IOU proposed an appliance recycling plan, although the plans differ somewhat among utilities in terms of the number of units they propose to recycle, the budgets, and the consumer incentive structure. The Appliance Recycling Centers of America, Inc. (ARCA) filed comments critical, primarily, of PG&E's proposal. ARCA claims that the PG&E proposal (1) is inconsistent with that of the other large electric IOUs; (2) inappropriately adds additional incentives for consumers purchasing new Energy Star® appliances, rather than emphasizing recycling of old appliances6; and (3) offers inadequate energy savings and appliance recycling goals.
We set the refrigerator/freezer recycling incentive payment at $35, with the option for an energy efficiency product incentive (i.e., a five pack of compact fluorescent light bulbs) in exchange for the removal of an operable primary or secondary unit. We find that, in general, the IOUs propose to recycle too few units for too much money. We estimate that the SBX1 57 funds will result in the recycling of 80,000 appliances at a cost of $15 million, at a per-unit cost of $209.15; this figure includes profit and EM&V costs.8 The Commission's administrative budget as program administrator is 2.5% or $5.25 on a unit cost basis. In contrast, the IOUs propose to recycle only 30,637 units at a cost of nearly $7 million. The average proposed cost per unit, across IOUs, is $228. On a unit-cost basis, therefore, the IOU's proposed programs for 2002 are significantly more costly than the SBX1 5 programs. The IOUs shall run this program at a unit cost of $200 per unit.9 We adjust the IOUs' targets and budgets to be consistent with the latter programs.
We are also concerned about the duplication of administrative expense that will result if each IOU runs its own separate program. We will reduce administrative expense by appointing Edison as the one administrator to oversee the appliance recycling program statewide. Edison already has a track record in this role. As ARCA points out, we appointed Edison the program administrator for PG&E and SDG&E, as well as its own program, in connection with the 2000 Summer Initiative.10 As a result of the Summer Initiative-funded programs in PG&E's and SDG&E's service territories, nearly 37,000 working inefficient refrigerators and freezers were retired and recycled.11 PG&E and SDG&E should arrange to transfer funds to Edison for payment purposes.
We approve the following program details:
Appliance Recycling |
Energy Reduction Targets (kWh) |
Demand Reduction Targets (kW)12 |
Number of Units Targeted for Removal |
Program Budget |
EM&V Budget |
Total Budget |
PG&E |
19,038,824 |
2,925 |
9,105 |
$1,680,000 |
$141,000 |
$1,821,000 |
SCE |
42,939,291 |
6,597 |
20,535 |
$4,000,000 |
$107,000 |
$4,107,000 |
SDGE |
10,925,629 |
1,679 |
5,225 |
$1,000,000 |
$45,000 |
$1,045,000 |
Total |
72,903,744 |
11,200 |
34,865 |
$6,680,000 |
$293,000 |
$6,973,000 |
*SoCalGas will contribute $32,000 to the EM&V activities associated with this program.
c. Single-Family Unit Rebates For Energy Efficiency Equipment (No Lighting)
The IOUs also proposed to offer consumer rebates for upgrading to energy efficient appliances. In contrast to recycling programs that pay the consumer an incentive for recycling an old unit, rebate programs pay the consumer for purchasing a new energy efficient appliance or measure. These "downstream rebates" as they are called, target the residential single-family market. Measures covered include programmable thermostats, insulation, windows, water heaters, clothes and dishwashers, furnaces, heat pumps, air conditioners and pool pumps.
In accordance with the requirement that the programs be consistent statewide, we have modified the programs as shown in the table below. We have increased PG&E's energy savings targets due to the fact that their administrative per-unit costs were far higher than those of the other IOUs for a majority of the proposed measures.
We approve the following program details:
Single Family Energy Efficiency Rebates |
Energy Reduction Targets (kWh) |
Demand Reduction Targets (kW) |
Energy Reduction Targets (ths) |
Program Budget |
EM&V Budget |
Total Budget |
PG&E |
16,767,505 |
18,910 |
1,426,372 |
$12,816,000 |
$269,000 |
$13,085,000 |
SCE |
19,039,000 |
6,770 |
|
$5,850,000 |
$203,000 |
$6,053,000 |
SCG |
2,586,000 |
1,380 |
925,000 |
$2,598,000 |
$61,000 |
$2,659,000 |
SDGE |
8,466,000 |
6,460 |
336,893 |
$3,197,000 |
$85,000 |
$3,282,000 |
Total |
46,858,505 |
33,520 |
2,688,265 |
$24,461,000 |
$618,000 |
$25,079,000 |
d. Multi-Family Unit Rebates For Energy Efficiency Equipment (Lighting and Non-Lighting)
This category of proposals focuses on paying rebates to owners of multi-dwelling units for upgrading appliances and lighting to more efficient units. In some cases, the building owner's contractor, rather than the owner, may receive the rebate. Because SDG&E proposed the same program budget as did SoCalGas, we will hold SDG&E to the same kW and kWh targets as those proposed by SoCalGas.
We fund the following IOU programs in this category and approve the following program details:
Multi Family Energy Efficiency Rebates |
Energy Reduction Targets (kWh) |
Demand Reduction Targets (kW) |
Energy Reduction Targets (ths) |
Program Budget |
EM&V Budget |
Total Budget |
PG&E |
3,751,245 |
4,420 |
708,970 |
$3,304,000 |
$179,000 |
$3,483,000 |
SCE |
8,850,000 |
1,090 |
|
$2,000,000 |
$136,000 |
$2,136,000 |
SCG |
2,440,484 |
840 |
575,000 |
$1,500,000 |
$41,000 |
$1,541,000 |
SDGE |
2,440,484 |
840 |
279,599 |
$1,500,000 |
$57,000 |
$1,557,000 |
Total |
17,482,213 |
7,190 |
1,563,569 |
$8,304,000 |
$413,000 |
$8,717,000 |
2. Statewide Residential New Construction
In D.01-11-066, we invited proposals focused on statewide residential new construction. Such programs focus on paying residential contractors and homebuilders incentives to construct new residences with energy efficient products.
We received proposals from all four IOUs, and amend them with the following requirements:
· We will require that the IOUs develop two distinct residential new construction programs, one for single-family homes and one for multi-family homes. We feel that a distinct multi-family residential new construction program can better target builders of multi-family buildings. In this decision we approve the overall Residential New Construction budget, but require the IOUs to develop two separate budgets and program plans to be submitted in their Program Implementation Plans. PG&E and SoCalGas set benchmarks of 9,000 and 2,893 multi-family units respectively. We require that both Edison and SDG&E set benchmarks for multi-family units as well, and report them in their Program Implementation Plans.
· To ensure that PGC funds are equitably distributed to all customers, we will require that 20% of direct implementation funds allocated to this program be reserved for units constructed for hard-to-reach customers, as defined in the Energy Efficiency Policy Manual.13 IOUs shall describe in their Program Implementation Plans how they will meet this 20% goal, which can include any combination of the following housing types:
o Housing for senior citizens
o Housing for individuals with special needs
o Housing for lower-to-moderate income households
o Rental units
· We impose a requirement that at least 15% of all claimed installations of energy efficiency measures be verified with an inspection. We will not allow incentives to be paid without proof of inspection of at least a 15% random sample of installations by a California Home Energy Efficiency Rating System (CHEERS) or Home Efficiency Rating System (HERS)-certified inspector.
We will enforce these requirements by holding back a portion of the final 15% payment, subject to the qualifications set forth in Section VII below.
We approve the following program details:
CA Energy Star New Homes Program |
Energy Reduction Targets (kWh) |
Demand Reduction Targets (kW) |
Energy Reduction Targets (ths) |
Program Budget |
EM&V Budget |
Total Budget |
PG&E |
3,914,428 |
4,204 |
259,580 |
$6,520,000 |
$285,000 |
$6,805,000 |
SCE |
3,156,000 |
3,390 |
|
$4,000,000 |
$216,000 |
$4,216,000 |
SCG |
521,000 |
4,000 |
86,000 |
$1,484,000 |
$65,000 |
$1,549,000 |
SDGE |
1,262,000 |
1,350 |
93,856 |
$2,058,000 |
$90,000 |
$2,148,000 |
Total |
8,853,428 |
12,944 |
439,436 |
$14,062,000 |
$656,000 |
$14,718,000 |
B. Statewide Nonresidential Programs
We also solicited proposals from the IOUs to serve the statewide nonresidential market. As with the residential programs, the proposals fall into two general categories: retrofit and new construction. We discuss these programs in turn.
1. Statewide Nonresidential Retrofit Programs
As we stated in D.01-11-066:
The Commission will continue to support energy efficiency retrofits in the small, medium and large commercial building sectors. We expect to select a mix of programs emphasizing technical support, capacity-building, emerging technology demonstration, and quality assurance. Because of current high energy prices and the lower cost of energy saving devices, incentive payments are less necessary than they once were to encourage energy efficiency, especially in the large commercial sector.14
We received nonresidential retrofit proposals in five general categories: (1) Nonresidential Standard Performance Contract (SPC) programs,15 (2) Express Efficiency programs,16 (3) Nonresidential audit programs, (4) Building operator training programs, and (5) Emerging technologies programs.
a. Nonresidential SPC Programs
PG&E, Edison, and SDG&E submitted nonresidential SPC program proposals. PG&E and Edison refer to the program as "ExpressSPC"; SDG&E uses the name "Standard Performance Contract." There should be one common name for this statewide program to avoid confusion and provide continuity from the perspective of the program participants. We shall continue to refer to this program as the "Nonresidential Standard Performance Contract (SPC)" program, as SDG&E has proposed.
The National Association of Energy Service Companies (NAESCO) pointed out in its comments that the IOUs' proposals differ in one significant way. While the Edison proposal seeks to offer SPC services through third party Energy Efficiency Service Providers (EESPs) with its customer account representatives only providing general promotion and program information to customers, PG&E's and SDG&E's proposals stated that SPC will be delivered via utility account service representatives, EESPs, and line channels or similar groups. NAESCO challenges PG&E's and SDG&E's proposals as anticompetitive, claiming that "allowing the regulated monopoly utility company to use regulated utility resources to compete in the energy services market" will "squash[]" the "nascent energy service industry . . . by unfair competition from utilities."17
In their reply comments, both PG&E and SDG&E clarified their intended program role. PG&E indicated that it has no desire to compete with EESPs in program delivery (i.e., project development, finance, or Measurement & Verification (M&V)), but that the Commission should not preclude the utility from promoting the programs and giving out program information to its customers. PG&E suggested that the Commission have EESPs and similar groups deliver program services, but allow utility representatives to provide assistance to first-time program applicants. Similarly, SDG&E clarified that it agrees that SDG&E account representatives and staff should be able to promote the program but not implement projects on behalf of customers.
Although we agree with NAESCO that it is Commission policy to encourage third party energy service providers to compete to provide energy services in this customer segment, the issue has been rendered moot by PG&E's and SDG&E's clarification of their program role. We expect the program to be primarily delivered through third party EESPs with utility representatives providing general promotion and program information to customers. Utility representatives should also be authorized to provide application assistance to program applicants as needed.
The IOUs also propose to carry out lighting retrofits in the context of their nonresidential SPC programs.18 As we stated in D.01-11-066, "The Commission will also emphasize non-lighting measures, or lighting only in combination with other measures, particularly in medium and large customer facilities."19 The IOUs' proposals appear to differ with respect to the availability of incentives for lighting measures under the program. Edison proposes to offer incentives to lighting systems measures only in conjunction with other measures, i.e., in a comprehensive retrofit project, with at least 20% of the energy savings attributable to the non-lighting measures. PG&E and SDG&E offer the same incentive levels for lighting measures as Edison, but without the additional requirements specified in Edison's proposal.
We approve the incentive levels for lighting measures as proposed by the IOUs, but adopt Edison's approach. Thus, we limit the availability of incentives for lighting measures to comprehensive retrofit projects that also include other non-lighting measures, consistent with our directive in D.01-11-066. We will require the other IOUs to include such a requirement in their SPC programs. In addition, we expect that the IOUs will continue to emphasize non-lighting measures in their SPC programs as they have done in the past years20 and devote at least 70% of the SPC financial incentives to non-lighting retrofits.
Furthermore, there is a free ridership problem in the area of lighting retrofits for the large SPC program.21 That is, parties receiving the incentives might have undertaken the relatively inexpensive and simple lighting change-outs even without energy efficiency program incentives.
In order to ensure that scarce energy efficiency program dollars are devoted only to customers who would not have upgraded their buildings without the incentives, we will not allow the IOUs to pay incentives to large customers carrying out upgrades with "first generation"22 energy efficient lighting technology. Such upgrades are already inexpensive and highly profitable for builders and contractors, and we do not believe incentives are necessary to encourage such retrofits. However, we will allow the IOUs to pay incentives for installation of "second generation" and/or "third generation" lighting technology, because builders and contractors still require incentives for these more expensive, less profitable retrofits.23
Finally, Edison has proposed to save 41,719 MWh in their portion of the SPC program. Based upon Edison's past performance, their proposed budget, and the proposed continuity of program design, the draft decision revised this target to 48,772 MWh. Edison's comments on the draft decision argue that this target is too high since this year's program has higher hard-to-reach and non-lighting targets. In response to these comments, the Energy Division issued a data request to Edison and confirmed Edison's response. (See Attachments 9 and 10.) We therefore accept Edison's proposed energy savings and demand reduction targets of 41,719 MWh.
With the changes we make above, we adopt the following funding and energy savings levels for each IOU in the nonresidential SPC program category:
Standard Performance Contract |
Energy Reduction Targets (kWh) |
Demand Reduction Targets (kW) |
Energy Reduction Targets (ths) |
Program Budget |
EM&V Budget* |
Total Budget |
PG&E |
15,734,455 |
3,147 |
1,493,187 |
$7,800,000 |
$250,000 |
$8,050,000 |
SCE |
41,719,000 |
8,620 |
|
$9,650,000 |
$189,000 |
$9,839,000 |
SDGE |
8,568,000 |
1,070 |
186,089 |
$2,700,000 |
$79,000 |
$2,779,000 |
Total |
73,074,455 |
12,837 |
1,679,276 |
$20,150,000 |
$518,000 |
$20,668,000 |
* SoCalGas will contribute $57,000 to the EM&V activities associated with this program.
b. Express Efficiency Programs
Express Efficiency programs pay rebates to distributors and small- to medium-sized nonresidential customers for equipping facilities with selected energy efficiency measures. When we sought such proposals in D.01-11-066, we stated that,
For 2002, we hope to see a program similar to the Express Efficiency program offered by the utilities in the past, but limited to the small and very small business segment (average monthly power demand up to 200 kW). Customer rebates could be offered for the following technologies (or others):
· T8 and/or T5 lamps
· Electronic ballasts
· Lighting controls such as photocell controllers and occupancy sensors
· Compact fluorescent lamps (CFLs)
· High-efficiency motors
· [HVAC] measures
The Commission may fund one or more small business rebate programs on a statewide basis.24
In response, the four IOUs propose a statewide Express Efficiency program for businesses whose monthly demand does not surpass 500 kW, and whose annual gas usage does not exceed 250,000 therms. Because program eligibility is limited to these participants, the free-ridership problem discussed in connection with the SPC program is less of a concern. Therefore, we do not impose on the Express Efficiency program the limitations on lighting retrofits we imposed within the SPC program.
However, because Express Efficiency and SPC share the small and medium-sized customer market, opportunities exist to leverage promotional activities. Recognizing the magnitude of this market and the current difficulties in satisfying its potential, we follow the recommendation of the 1999 State-Level Small/Medium Nonresidential MA&E Study25 and instruct the IOUs to ensure that all nonresidential programs available to this customer class coordinate information, marketing, and education efforts.26
The IOUs propose to change the existing Express Efficiency application process in one key respect: while the current programs require a customer to "reserve" a rebate before installing the energy efficient product, the proposed program would eliminate this requirement. While the reservation system may be an additional hurdle, its benefits should not be ignored. In 2001, reservations assured potential customers of a rebate upon installation of energy efficient measures. We believe such certainty is crucial to encouraging investment in energy efficiency among small and medium sized customers, and therefore require the IOUs to continue to allow for rebate reservations in the Express Efficiency program.
Finally, Edison has proposed to save 58,697 MWh and 13.93 MW in their portion of the Express program. Based upon the share of the small and medium customer market in Edison's territory, Edison's past performance in the Express program, and upon Edison's proposed budget, the draft decision revised these savings targets to 80,940 MWh and 17.55 MW.
Edison's comments on the draft decision claim that these targets cannot be met without making significant changes in program design, such as altering Express marketing to focus upon the largest eligible customer class, and limiting incentives for certain measures. In response to Edison's comments, the Energy Division issued a data request with the purpose of determining the extent to which the mix of measures anticipated by the proposed Express Efficiency program differed from the mix of measures installed in prior years. Based upon the response to this request (Attachment 10), we find that the Express program proposes to de-emphasize lighting measures. We therefore revise the Express energy savings target to 64,303 MWh, but accept Edison's demand reduction target of 13.93 MW.
We approve the following plans and budgets in this category:
Energy Reduction Targets (kWh) |
Demand Reduction Targets (kW) |
Energy Reduction Targets (ths) |
Program Budget |
EM&V Budget |
Total Budget | |
PG&E |
155,382,003 |
29,288 |
8,761 |
$11,607,000 |
$320,000 |
$11,927,000 |
SCE |
64,303,000 |
13,930 |
|
$6,000,000 |
$242,000 |
$6,242,000 |
SCG |
17,000 |
|
2,190,000 |
$2,433,000 |
$73,000 |
$2,506,000 |
SDGE |
47,452,000 |
9,040 |
607,310 |
$3,104,000 |
$101,000 |
$3,205,000 |
Total |
283,791,003 |
55,878 |
2,806,071 |
$23,144,000 |
$736,000 |
$23,880,000 |
c. Nonresidential Audit Programs
Nonresidential audit programs are designed to inform small, medium and large nonresidential customers how to reduce their energy bills by the use of energy efficient measures. The programs generally rely on phone, online and software-based surveys for small and medium customers, and on-site audits for large customers. All four IOUs applied for such funding.
Because these programs reach out to customers who may not initially be seeking energy efficiency upgrades, we are especially interested in assuring statewide uniformity in this category. First, the IOUs should use one common, consumer-friendly, name for these programs. Edison refers to its program as "Nonresidential Energy Surveys," while the other three IOUs refer to the program as "Nonresidential Energy Audit." We shall use the latter program title consistent with the majority's nomenclature.
Second, while there is consistency among the four IOUs regarding the availability of mail-in, CD ROM, on-line, and phone audits to various customer classes, there appear to be differences with respect to the availability of on-site audits as shown below:
PG&E |
SDG&E |
SCG |
SCE | |
Hard to reach |
_ |
_ |
* | |
Very small |
_ |
* | ||
Small |
_ |
_ |
_ | |
Medium |
_ |
_ |
_ |
_ |
Large |
_ |
_ |
N/A |
_ |
* SCE has proposed a local program that will offer energy surveys that target hard-to-reach and underserved customers.
The IOUs should make their on-site audits available to the same set of customers with the same eligibility requirements. They should address this issue in their Program Implementation Plans.
With respect to on-line audits, both PG&E and SDG&E indicated that this type of audit "will be available in the future" for small and medium customers, whereas it is already available to Edison and SoCalGas customers. PG&E and SDG&E should provide a timeline for the development and availability of on-line audits to their small and medium customers in their Program Implementation Plans.
Third, unlike the other IOUs, PG&E described a program component called "How To Do an Energy Audit," which offers both theoretical and on-site training to qualified personnel of a variety of organizations to enable them to provide comprehensive energy efficiency services.27 We support such training efforts to the extent that they are not offered through other IOU education and training programs, and require that the other IOUs offer similar training as part of their Nonresidential Energy Audit Programs. The IOUs should provide detailed description of this training component and an itemized budget (out of the total program budget) in their Program Implementation Plans.28
The IOUs did not propose program performance goals for this particular program, noting that it is an information program and therefore only subject to the two-stage payment schedule contingent upon acceptance of their Program Implementation Plans and quarterly reports. As we discuss further in Section VI.D. below, we require accountability in all program categories-including information programs-as a prerequisite to program payment. The IOUs should identify certain performance targets that they intend to achieve and track in quarterly reports in their Program Implementation Plans. One performance target could be the number of audits achieved by type of audit and by customer class.
We approve the following budgets for the IOUs' nonresidential energy audit programs:
Nonresidential Energy Audit |
Program Budget |
EM&V Budget |
Total Budget |
PG&E |
$2,650,000 |
$228,000 |
$2,878,000 |
SCE |
$1,400,000 |
$173,000 |
$1,573,000 |
SCG |
$2,400,000 |
$52,000 |
$2,452,000 |
SDGE |
$700,000 |
$72,000 |
$772,000 |
Total |
7,150,000 |
525,000 |
7,675,000 |
d. Building Operator Certification and Training
We defined building operator certification and training programs in D.01-11-066:
Building operator certification and training programs would educate operators of large and medium commercial buildings, including public buildings, on short- and long-term peak demand and energy savings strategies for their buildings. After participating in training activities, individual building operators could become certified in efficient building operation.29
The programs the IOUs propose offer three separate components: classroom training; practical, project-specific training; and certification. As is true for so many of the IOUs' proposals, we are concerned about the lack of consistency in program details. For example, Edison has already identified two subcontractors with which it will work on its program, and was able to describe in some detail the program delivery process and implementation timetable, while the other IOUs intend to put the program out for competitive bid if/when funded.30
It makes sense to develop uniform certification criteria so that an individual trained in this area can work anywhere in the state, rather than being restricted to a particular IOU's territory. Therefore, while we generally approve the IOUs' proposed budgets, we will require further work from the IOUs to ensure program uniformity. We order all four large IOUs jointly to develop standard training curricula, testing and other certification standards. They shall consult with the Energy Division during this process. Once the IOUs develop, and the Commission or the assigned Commissioner approves such standard criteria, PG&E, SDG&E, and SCG may then solicit competitive bids from program providers to roll out their programs. All IOUs should ensure that their subcontractors implement the program consistent with the approved standards.
The IOUs should develop the standard training curricula, testing and other certification standards and submit them for Commission or assigned Commissioner approval no later than 30 days after issuance of this decision. The Commission will retain ownership of the curricula and other aspects of the training program. The IOUs should be able to roll out their programs within 30 days after the Commission or its representative approves these standards.
The IOUs should submit a detailed timeline of activities for this program in their Program Implementation Plans as required in Section VI(A) below. In addition, the IOUs should identify the performance targets they propose to achieve in this program and track in their quarterly reports. Some possible performance targets may include the number of building operators enrolling in the program, the number of certified building operators, and the number of training courses offered.
We approve the following budgets for these programs:
Building Operator Certification and Training |
Program Budget |
EM&V Budget |
Total Budget |
PG&E |
$258,000 |
$35,000 |
$293,000 |
SCE |
$500,000 |
$26,000 |
$526,000 |
SCG |
$150,000 |
$8,000 |
$158,000 |
SDGE |
$150,000 |
$11,000 |
$161,000 |
Total |
1,058,000 |
80,000 |
1,138,000 |
e. Emerging Technologies
The IOUs also included a category of "emerging technology" proposals designed to move emerging energy efficient technologies to market. While the funding they seek for this work is modest, these programs are important to the development of the next generation of energy efficient devices. Our only real concern with the IOUs' proposals is that they do not adequately document how previous expenditures in this area have helped move products to market. We will require that the IOUs do so in 2002.
As the IOUs point out, large commercial players (architects and designers, builders and contractors) are hesitant to commit to installing new energy efficient technology without extra marketing and training, on-site demonstrations, seminars and the like. Funding in this area focuses on the efforts of the Emerging Technologies Coordinating Council, in which the four large IOUs and the California Energy Commission (CEC), through its Public Interest Energy Research (PIER) program,31 coordinate their efforts to develop emerging technologies and move them to market.
We support these programs and will fund them. However, we will require the IOUs to report on the extent to which funding this Commission awards advances the cause of emerging energy efficient technologies. For each emerging technology set forth on the CEC's PIER website at http://www.energy.ca.gov/pier/programs.html, we will require that the IOUs describe in their 2002 quarterly reports how PGC funding is moving these technologies to market.
We fund the following IOU emerging technology programs:
Emerging Technologies |
Program Budget* |
EM&V Budget |
Total Budget |
PG&E |
$300,000 |
$43,000 |
$343,000 |
SCE |
$650,000 |
$33,000 |
$683,000 |
SCG |
$600,000 |
$10,000 |
$610,000 |
SDGE |
$80,000 |
$14,000 |
$94,000 |
Total |
1,630,000 |
100,000 |
1,730,000 |
* SoCalGas will fund its program as follows: $150,000 under nonresidential retrofit and $450,000 under statewide cross cutting. SoCalGas proposes to augment this budget with $100,000 of local program funds. Review of this request will be made during local program proposal review.
2. Statewide Nonresidential New Construction Programs/Savings by Design
We urged the IOUs to set a new benchmark above the current June 2001 Title 24 building code standards in proposing statewide nonresidential new construction programs. We stated that,
The setting of the new benchmark should be undertaken in consultation with the CEC and support CEC goals for further code revisions for the 2005 cycle. Similar to the utilities' past Savings by Design program, we would expect this type of program to de-emphasize prescriptive technological approaches in favor of providing incentives to include efficiency during the design process. The Commission prefers a whole-building design approach.32
In response, the IOUs proposed various versions of their past "Savings by Design" programs. In addition to new construction, these programs are open to projects that involve rebuilding from the ground up. In these programs, building architects, design teams, building owners and/or developers receive incentives based on the percentage by which the work exceeds Title 24 standards. Building owners or designers receive an incentive if work exceeds 10% above Title 24 building energy efficiency standards; if the work exceeds standards by 15%, the architects and design team also receive an incentive.
As noted above, we stated in D.01-11-066 that we preferred a "whole-building" approach to such projects. The whole-building approach, as contrasted to the "systems" approach, incorporates energy efficiency concepts into the design of an entire construction project, rather than encouraging the installation of a limited number of energy efficiency measures. In the past, the IOUs' Savings by Design programs have focused on the latter, prescriptive approach,33 and they continue to do so. In order to ensure that the market migrates to a whole-building approach, we will require that 50% of the direct program implementation funds be reserved for encouraging energy reductions that come from such whole-building-oriented projects. The remaining budget (up to 50% of direct implementation funds) may be devoted to projects using the prescriptive approach. A portion of the final 15% payment will be devoted to ensuring IOU compliance with this goal.
In summary, we approve the following program budgets and savings goals for the Savings by Design programs:
Savings by Design |
Energy Reduction Targets (kWh) |
Demand Reduction Targets (kW) |
Energy Reduction Targets (ths) |
Program Budget* |
EM&V Budget |
Total Budget |
PG&E |
35,000,000 |
14,800 |
300,000 |
$9,707,000 |
$339,000 |
$10,046,000 |
SCE |
33,256,000 |
7,780 |
|
$7,674,000 |
$256,000 |
$7,930,000 |
SCG |
8,486,000 |
4,630 |
49,000 |
$1,973,000 |
$77,000 |
$2,050,000 |
SDGE |
10,832,000 |
2,090 |
141,784 |
$3,143,000 |
$107,000 |
$3,250,000 |
Total |
87,574,000 |
29,300 |
490,784 |
22,497,000 |
779,000 |
23,276,000 |
*SCE and SDG&E will draw $700,000 and $400,000 of their program budgets, respectively, from the non-residential
retrofit funds. PG&E will draw $1,007,000 of its program budget from statewide crosscutting funds.
C. Statewide Cross-Cutting Programs
We stated in D.01-11-06 that,
A cross-cutting program may target both residential and nonresidential consumers as participants. In addition, the programs may simply support other programs. Finally, such programs could include retrofit or new construction markets.34
We received four types of statewide cross-cutting program applications, for: (1) statewide marketing and outreach programs, which were the subject of competitive bids by non-IOUs; (2) education and training programs; (3) codes and standards advocacy; and (4) statewide upstream residential lighting program. We discuss each type of program in turn.
1. Statewide Marketing and Outreach Programs
We allowed for competitive bidding for statewide marketing and outreach programs so that IOUs and/or non-IOUs might be funded to deliver consumer marketing and outreach messages. In addition to the IOU proposals, we received 12 proposals from the following third parties: the Department of Consumer Affairs (DCA), Univision Television Group (Univision), Energy Solutions, InSync Information Systems (InSync), ADM Associates (ADM; 3 proposals), Global Energy Partners (Global), California Home Energy Efficiency Rating System, Inc. (CHEERS), Richard Heath and Associates (Heath), Geothermal Heat Pump Consortium (Geothermal), and SBW Consulting (SBW).
The ADM, Global, CHEERS, Heath, Geothermal, and SBW proposals did not actually propose qualifying marketing and outreach programs, and we have removed them from consideration in this category. Instead, we will consider those proposals for funding in the "local programs" category to be discussed in a subsequent decision. As we pointed out in D.01-11-066, statewide marketing and outreach programs
should continue statewide messages on simple things individual consumers can do to reduce their bills and the risk of rolling blackouts, and/or increase consumer awareness of and participation in the statewide programs available to them. The Commission desires program proposals that maintain a consistent statewide message through a mass-market advertising campaign.35
Programs proposing to train and educate industry participants such as the lodging, convenience store, and contractor sub-sectors (ADM), schools (Geothermal), manufacturers and builders (Heath), or inspectors (CHEERS) are not such programs. Proposals promoting more efficient motors (Global) or improving industrial processes (SBW) likewise do not fit the category. Such proposals target narrow audiences and do not target individual consumers with mass-market advertising. Thus, we did not further consider these proposals in this category. As stated above, we will consider these proposals for funding as "local programs" to be described in a subsequent decision.
We do not select IOU proposals in this category because IOUs are already receiving more than $9 million in outreach and marketing funding connected with their individual statewide programs. Many of their proposed activities are contingent on other marketing and outreach efforts, funded primarily by the State of California, including the DCA. We believe we can achieve a more consistent message, and spend this funding most effectively, if the funding goes directly to the DCA. DCA has worked collaboratively with the IOUs in the past and plans to continue doing so.36 We believe the IOUs can work with the DCA and Univision in the context of the programs we are funding to increase the effectiveness of the energy efficiency message statewide. We expect the IOUs to utilize a portion of their marketing funds allocated to specific programs to work with DCA, Univision, and any other State-sponsored marketing efforts focused on energy efficiency, in order to leverage all of the various marketing dollars most effectively.
Moreover, we expect the IOUs to use their own $9 million in marketing and outreach funding collaboratively with one another. That is, to the extent the IOUs offer the same programs, they should advertise them together. We believe that such collaboration ultimately will reduce the likelihood of duplicate expenditures to advertise the same programs. The IOUs shall keep the Commission's Energy Division informed in their quarterly reports of what they are doing to further this collaborative goal. They shall also explain in their Program Implementation Plans how they will work together on marketing/advertising like programs around the state. We are especially interested in IOU collaboration on big ticket marketing such as television advertising. The IOUs shall explain how they will coordinate such advertising in their Plans. We also will require the IOUs to adhere to the same requirements we impose on DCA and Univision with regard to the use of the funding for energy efficiency messages. The primary emphasis of all IOU PGC-funded marketing shall be energy efficiency.
Of the remaining third party proposals, we scored DCA's and Univision's the highest. These proposals meet the D.01-11-066 prerequisites, in that they involve mass-market advertising campaigns that target individual consumers on a statewide basis. The proposals offered by Energy Solutions and InSync involve mass mailing campaigns and targeted e-mail messages. Energy Solutions proposed directing its message to building contractors, which may only indirectly benefit a general audience. InSync would target hard-to-reach residential customers and building contractors. We feel we can make better use of our limited resources by using television, radio, and print advertising.
The DCA proposal seeks the entire statewide marketing and outreach budget to continue the state's Flex Your Power campaign, which began in the summer of 2001. On January 11, 2002, the Commission's Energy Division sent DCA a data request seeking clarification of its proposal.37 Because the funding we award here is targeted for energy efficiency efforts, we must ensure that the DCA spends any funding we might award on an energy efficiency message, rather than a conservation message.
We wholeheartedly support the goal of conservation and congratulate all Californians for their efforts to conserve energy in the past year. Nonetheless, the conservation message has dominated the Flex Your Power campaigns to date, and informs consumers to turn out lights, unplug a second refrigerator, or use dishwashers and clothes washers at non-peak times. The message we prefer is focused not on making these behavioral changes, but rather on persuading consumers to make permanent changes to their homes so that energy savings are not dependent on behavior once the energy efficient measures are installed. As we stated in the Energy Efficiency Policy Manual, "the following types of activities are not eligible for energy efficiency program funding out of PGC funds: . . . Load-shifting programs that rely only on temporary or impermanent behavioral change (programs that install permanent equipment to manage load, such as energy management systems, are eligible)."38
Therefore, the data request asked whether the Flex Your Power advertising content/message was already finalized. The DCA responded to the data request on January 22, 2002.39 It stated the following with regard to the content of the Flex Your Power message:
Future Flex Your Power radio and television messages could be developed to include information about statewide energy efficiency programs, in addition to basic conservation information, if adequate funding were available. . . .
Should the Department develop a plan for informing the public about energy efficiency programs, we would utilize radio and print ads, rather than television spots. Radio and print are the best media for providing the public with the more complex information inherent in energy efficient programs and products. This is because of the longer format of radio (60 seconds, as opposed to television's 30 seconds) and the staying power of printed information.40
As a condition of granting funding to DCA, we will require that all funding we award be used solely on energy efficiency messages. As we note in Section VII, the DCA has almost $50 million in other funding that it may spend as it deems appropriate. If at all possible, we would like DCA to include television ads encouraging viewers to invest in energy efficiency to save energy and money on future energy bills without sacrificing comfort. The foregoing DCA response indicate that it remains feasible to craft such messages in time for Summer 2002, when the Flex Your Power campaign will gear up for the year. As a further requirement for funding, we require DCA to consult with IOU energy efficiency program managers to coordinate the timing of statewide and IOU messages and programs. However, the DCA will have ultimate responsibility for program content as long as it acts consistently with this decision.
Because the DCA's Flex Your Power program is so well-known, we expect consumers will go to its website for energy efficiency information. Therefore, we expect the DCA to use a portion of its funding to update its website to reflect this Commission's statewide and local energy efficiency programs. The website should contain a user-friendly guide to those programs, with links to program providers. The DCA will be responsible to gather this data, using contact information furnished by the Commission's Energy Division, as further described in Section VII.
Finally, because we prefer to use the statewide marketing and outreach budget to fund more than one project, we will award the DCA $8.057 million of the total $10.057 million available in this category.
The Univision proposal targets the Spanish-speaking population that makes up one-third of California residents. Univision proposes to develop a series of vignettes to air on television during a 3-month period and to promote the energy efficiency message at community events and celebrations in each of eleven markets. We will fund this program at $2.0 million. On January 28, 2002, the Commission's Energy Division sent Univision a data request seeking additional information on Univision's ability to present energy efficiency messages. Univision's January 28, 2002 response indicated such messages were feasible.41
As a condition of funding, Univision shall deliver an energy efficiency message, rather than one focused on conservation. Univision proposes to disseminate information on CARE and low-income weatherization. We support leveraging dollars in this manner, so long as the majority of Univision's content focuses on energy efficiency. As a further requirement for funding, we direct Univision to consult with IOU energy efficiency program managers to coordinate timing of statewide and IOU messages and programs.
We direct Edison to contract with the DCA and Univision in connection with these proposals, and to include language in the contracts designed to ensure that the funding is only used on energy efficiency messages as we describe them above and in the Energy Efficiency Policy Manual.42 Program payment will depend on DCA's and Univision's compliance with the contractual requirements, which in turn shall address the concerns we express here. The other IOUs shall transfer allocated PGC funds for statewide marketing and outreach to Edison so that it may compensate DCA and Univision. In all cases, the Commission will retain all ownership interest in all content developed with the funding it awards here.
In summary, we fund the following programs in the statewide marketing and outreach category:
Statewide Marketing and Outreach |
Funding Source |
Total Budget | |||
PG&E |
Edison |
SDG&E |
SoCalGas | ||
Department of Consumer Affairs |
$3,483,329 |
$2,683,797 |
$1,099,155 |
$790,719 |
$8,057,000 |
Univision Television Group |
$864,671 |
$666,203 |
$272,845 |
$196,281 |
$2,000,000 |
Total |
4,348,000 |
3,350,000 |
1,372,000 |
987,000 |
10,057,000 |
2. Education and Training Programs
We did not include education and training programs in our list of examples of statewide programs in D.01-11-066. Rather, we stated in our discussion of local programs that we would "continue to support education, training/capability-building, and outreach efforts in local communities across the state."
Nonetheless, we believe statewide education and training programs have value for California consumers and will fund them as part of the statewide cross-cutting programs. These programs involve the education and training of contractors, architects and designers, residential developers and builders, manufacturers, commercial users, environmental organizations, agricultural users, and others on means to improve energy efficiency.
The IOUs, except for SDG&E, offer most of their education and training programs at "energy centers." Each of the IOUs also described plans to extend their programs to reach more participants and offer services to hard-to-reach customers. Some programs will be taken "on-the-road," offered through partnership with other agencies, offered in languages besides English, or through targeted association meetings. In its Program Implementation Plan, each IOU shall set forth appropriate performance measures to gauge their success in serving hard-to-reach customers as mentioned in their proposals.
We approve the following program details:
Education and Training |
Program Budget* |
EM&V Budget |
Total Budget |
PG&E |
$1,069,000 |
$137,000 |
$1,206,000 |
SCE |
$3,813,000 |
$104,000 |
$3,917,000 |
SCG |
$1,374,000 |
$31,000 |
$1,405,000 |
SDGE |
$1,100,000 |
$43,000 |
$1,143,000 |
Total |
7,356,000 |
315,000 |
7,671,000 |
* SoCalGas proposes funding $300,000 of their education and training program from local funding. PG&E's and SCE's proposed program budgets were reduced to increase funding for Codes & Standards Advocacy program.
3. Codes and Standards Advocacy
In the area of codes and standards advocacy, we are faced with something of an anomaly. The IOUs propose to spend less money on programs than either this Commission or the CEC believe is needed. According to the CEC, which filed comments on this aspect of the IOUs' proposals, the IOUs' efforts have been very useful in its development of codes and standards.43 Because improvement in building codes and standards can have a profound effect on energy savings, the CEC urges the Commission to fund these programs at past levels.
The CEC explains that it is in the midst of a proceeding aiming to implement Assembly Bill 97044 by adopting new standards effective in 2005. The CEC expects to adopt the new standards in 2003. The CEC also is implementing provisions of AB 549,45 relating to existing buildings. The CEC is looking to expand building energy efficiency standards requirements for alterations and renovations.
The CEC states that utility advocacy in this area is central to the success of its current codes and standards efforts. The CEC requests that the Commission fund the IOUs' codes and standards advocacy work at $2.2 million for 2002, and that PG&E receive $1.4 million for this work, an amount equal to its 2001 expenditure.
We agree with the CEC that building codes and standards upgrades produce notable energy savings, and share the desire that improvement continue in this area. Indeed, the last time the codes and standards were upgraded, the energy savings were significant. According to CEC, "savings of approximately 60 [megawatts (MW)] in the first year [are] attributable to utility Codes and Standards efforts [related to the CEC's implementation of the AB 970 Emergency Building Standards proceeding]."46 By way of comparison, of the recently approved below 300MW power plants on the CEC website,47 five of the nine listed plants had capacity below 60MW.
We are especially interested in seeing improvement in the area of energy efficiency standards for residential retrofits, where we believe most of the new savings will come. Therefore, we approve the IOUs' requests for codes and standards funding, but increase the funding amounts as follows:
Codes & Standards Advocacy |
Program Budget* |
EM&V Budget |
Total Budget |
PG&E |
$818,000 |
$28,000 |
$846,000 |
SCE |
$887,500 |
$21,000 |
$908,500 |
SCG |
$150,000 |
$6,000 |
$156,000 |
SDGE |
$100,000 |
$9,000 |
$109,000 |
Total |
1,955,500 |
64,000 |
2,019,500 |
*PG&E's and SCE's proposed program budgets were increased by reallocating funds from Education and Training, and Upstream Residential Lighting programs.
PG&E and Edison should explain in their Program Implementation Plans how they will expand their Codes and Standards programs to meaningfully apply the extra funds.
4. Statewide Upstream Residential Lighting Program
Decision 01-11-066 emphasized continuing and even expanding upstream lighting programs in 2002. The utilities propose to broaden availability of Energy Star® qualified lighting products to include lighting fixtures, ceiling fans and other lighting measures in more stores and outlets. Retailers or manufacturers will receive financial incentives that will be passed on to the customer. Incentives will flow to customers either directly in the form of a point-of-purchase rebate, or through an incentive to the manufacturer so that product will be available at a discounted price.
The utilities have indicated that they will target the hard-to-reach through the "addition of non-traditional delivery channels" such as grocery stores, drug stores, and outlets in remote locations. The IOUs should develop specific performance goals in their Program Implementation Plans for increasing the quantity of product provided to these types of delivery channels. These goals should also measure whether the program is affording hard-to-reach customers better access to Energy Star® lighting products.
We will adjust the kWh savings so that the goals are proportional to the CFL units used in the TRC workpapers, using SDG&E as the base. In addition, we will require that at least 15% of the rebate budget be reserved for customers in rural areas, in order to enhance service to hard-to-reach customers. In addition, we will require that 10% of the rebate funds also be reserved for redemption through purchases from new delivery channels of grocery and drug stores.
In summary, we will fund the cross-cutting lighting programs as follows:
Upstream Residential Lighting |
Energy Reduction Targets (kWh) |
Demand Reduction Targets (kW) |
Program Budget* |
EM&V Budget** |
Total Budget |
PG&E |
226,000,000 |
16,156 |
$5,803,000 |
$185,000 |
$5,988,000 |
SCE |
45,000,000 |
4,170 |
$1,999,500 |
$140,000 |
$2,139,500 |
SDGE |
22,500,000 |
3,120 |
$1,543,000 |
$58,000 |
$1,601,000 |
Total |
293,500,000 |
23,446 |
$9,345,500 |
$383,000 |
$9,728,500 |
* PG&E's and SCE's program budgets reduced to increase funding for Codes & Standards Advocacy program.
** SoCalGas will contribute $42,000 to the EM&V activities associated with this program.
5 D.01-11-066, mimeo., at 11. 6 ARCA also claims that PG&E's proposal to pay incentives for new appliances is contrary to Pub. Util. Code § 399.4(b)(2), which provides that the Commission shall ensure that "no energy efficiency funds are used to provide incentives for the purchase of new energy-efficient refrigerators." We ruled in our decision funding energy efficiency programs for 2001 that § 399.4(b)(2) applies to programs funded by PGC collections made after January 1, 2002. D.01-01-060, mimeo., at 11. Thus, ARCA is correct that § 399.4(b)(2) prohibits the use of PGC funds for this purpose after January 1, 2002, the funding period for which the IOUs have applied in this proceeding, and we do not approve any such funding in this decision. By the same token, there may be programs that tie refrigerator change-outs to other activities, with the incentive payable only for the latter. Such programs would be consistent with § 399(b)(2). 7 California Legislature, 2001-02 First Extraordinary Session, Senate Bill 5. 8 Appliance Early Retirement and Recycling Agreement for Refrigerators, Freezers and Room Air Conditioners, between Appliance Recycling Centers of America Inc. and the CPUC, dated June 12, 2001, available at http://www.cpuc.ca.gov/static/industry/electric/energy+efficiency/energy+efficiency+rulemaking.htm 9 $200 (rounded) = $209.15 (recycling fee) + $5.25 (admin fee, rounded) less $15.00 (incentive reduction). 10 See Application 99-09-049 et seq. 11 The Multi-Megawatt Refrigerator/Freezer Recycling Summer Initiative Program Final Report, December 2001, at 3, available at http://www.cpuc.ca.gov/static/industry/electric/energy+efficiency/energy+efficiency+rulemaking.htm 12 Energy reduction targets specify how many kilowatt hours should be saved. Demand reduction targets show how many kilowatts of demand should be eliminated by the energy efficiency programs we fund. 13 Energy Efficiency Policy Manual, Attachment 1 to D.01-11-066, at 12. Residential Hard-to-Reach customers are those who do not have easy access to program information or generally do not participate in energy efficiency programs due to language, income, housing type, geographic, or home ownership (split incentives) barrier. These barriers are defined as 1) language - primary language spoken is other than English, and/or, 2) Income - those customers who fall into the moderate income level (income levels less than 400% of federal poverty guideline), and/or 3) housing type - multi-family and mobile Home tenants, and/or 4) geographic - residents of areas other than the San Francisco Bay Area, San Diego, area, Los Angeles Basin or Sacramento, and/or 5) homeownership - renters. 14 D.01-11-066, mimeo., at 12. 15 The nonresidential SPC programs pay incentives for custom-designed energy efficient retrofit projects in existing business facilities, as contrasted with the Express Efficiency programs, which prescribe a list of energy efficient upgrades eligible for incentives. Unlike Express Efficiency programs, the SPC programs may include large businesses among those entities eligible for incentives. These program approaches offer incentives on the basis of verified energy savings, rather than by prescribing replacement of specific equipment. Thus, such programs offer more flexibility for comprehensive projects to reduce energy consumption overall in a building. 16 Express Efficiency programs are similar to nonresidential SPC programs except that they pay incentives on an appliance-by-appliance basis, rather than paying for a package of energy efficient products. These programs serve only small and medium businesses. 17 Comments of the National Association of Energy Services Companies (NAESCO) on the Delivery of the Express SPC Programs as Filed in the Utility Statewide Plans on December 14, 2001 (NAESCO Comments), filed January 7, 2002, at . Id. at 3. 18 The Energy Efficiency Policy Manual defines SPC programs as follows:- Programs consisting of a set of agreements between the administrator or implementer and a number of project sponsors (either Implementers or Customers) to deliver energy savings from the installation of energy efficiency measures and technologies at a facility or set of facilities. These agreements are for a pre-specified price per unit of energy savings, measured using a pre-specified set of Measurement and Verification (M&V) protocols. An SPC program is an open-ended offer with a pre-specified price and set of terms.
Energy Efficiency Policy Manual at 10.
