3. Positions of Parties

Comments and reply comments were received from the following parties:

Table 1 summarizes the key points discussed by the parties in their opening comments filed April 25, 2008, regarding Energy Division's recommendations and related issues.

Table 1

 

Supports

Does Not Support

ED Recommendation: A total market gross goal for IOU service territories for procurement planning, carbon emissions regulation, and to identify the realistic savings potential.

DRA, CE Council, WEM, NRDC, ACEEE

  

ED Recommendation: An Expansive Net goal for IOU service territories for measuring achievement toward the TMG.

CE Council, NRDC

DRA, WEM, ACEEE

ED Recommendation: Commit staff and contractor resources to develop any

proper evaluation, measurement, and verification protocols not in existence today to attribute savings for additional program impacts.

NRDC

ACEEE

ED Recommendation: Adopt Mid-Level Scenario as Total Market Gross

NRDC

WEM

ED Recommendation: Adopt Mid-Level Scenario IOU Gross as a proxy for Expansive Net that should serve as basis for a reauthorized risk/reward mechanism.

NRDC

DRA, WEM

Request update with current Avoided Costs and DEER Updates:

SCE, PG&E, SDG&E, SCG, CE Council, ACEEE

Need clarification of the purpose of TMG goal:

SCE, PG&E, SDG&E, SCG, DRA

Need clarification of the purpose of Expanded net goal:

SCE, PG&E, SDG&E, SCG, DRA

Parties in their opening comments expressed various concerns about lack of full understanding of methodological elements of the Itron Goals Update Report and/or Energy Division recommendations. Largely, this was the result of Energy Division's recommendation of a complex new goal structure whose attribution protocols would be developed in the interim period before 2012 (see Energy Division Recommendation 3, above). Parties presented mixed levels of comfort with a hybrid structure that would rely on these undeveloped protocols.

In parallel to the 2020 goals update element of this proceeding, an April 21, 2008 Ruling19 for the 2009-2011 energy efficiency program portfolios applications required the utilities to use updated 2007 generation cost values, carbon reduction value, and 2008 Database for Energy Efficient Resources (DEER) values. This Ruling updated the underlying baseline inputs for calculations of economic potential and avoided costs soon after Energy Division's goals recommendations were made. For this reason many parties expressed concerns about a lack of consistency between updated values to be used in the 2009-2011 utility portfolio filings, and the earlier era data that supported the Itron Goals Update Report. While these issues were subsequently discussed in workshops, parties generally agreed that the numerical targets from the Itron Goals Update Report and Energy Division recommendations should not be adopted at this time on a final basis, nor used to set goals for individual utility portfolios.

In comments, parties to a large extent coalesced around a single recommendation: The Commission should adopt a Total Market Gross (TMG) goal at this time from the scenarios within the Itron Goals Update Report, but not utility portfolio-specific goals, and should update both the TMG goal and establish utility portfolio-specific goals with new data before 2011. Parties reiterated their views on this topic at the May 14 PHC, and in subsequent comments dated June 11, 2008.20

Parties also agreed that an update of the goals must occur in a timely manner to be useful for planning purposes for 2012-2014 energy efficiency programs. However, parties differed on when the update should occur. We discuss these issues below in Section 6.

19 This Ruling can be found at http://docs.cpuc.ca.gov/efile/RULINGS/81727.pdf.

20 See comments from SCE, PG&E, SDG&E, SCG, NRDC, DRA, and CE Council dated June 11, 2008.

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