6. Updating Goals for 2012 Through 2020
In today's decision, we establish interim TMG goals for each IOU service territory for the years 2012 through 2020. These TMG goals will be transmitted to CARB for AB 32 purposes, and will be used by IOUs for procurement planning in the 2010 LTPP. TMG goals also represent and support the direction given to the California Energy Efficiency Strategic Plan of innovation, integration, and collaboration by illustrating the savings in addition to traditional IOU programs that is reasonable to anticipate with the current growing market interest. We adopt these goals with the understanding that the underlying data is imperfect, but are sufficiently robust for use at this time. We recognize the need to update TMG goals and to establish IOU program-specific expansive net goals. At the PHC and in their June 11, 2008 comments, parties suggested different methods, inputs, and timetables for goal updates and new IOU-specific goals. All parties agree that this effort must be completed before 2011 in order to allow the IOUs to incorporate the new goals into their energy efficiency portfolio planning process for 2012 through 2014.
The differences in the positions of parties lie in the valuation of priorities. Quickly updating the underlying data to rerun the TMG and establishing IOU program specific goals provides the longest amount of time for IOU program managers to get familiar with this new structure. A quick update would also provide the least amount of additional information, likely no more than the final 2008 DEER update numbers and possibly the updated 2008 Market Price Referent (MPR) used to establish avoided costs. The key data not included in a quick update schedule would be any evaluation, measurement and verification (EM&V) results from 2006-2008, subsequent DEER updates, or any information from the 2010 evaluation of the RRIM. Completion of a TMG 2012-2020 energy saving goals update and establishment of 2012-2020 IOU program-specific energy savings goals closer to 2011 would produce a more robust and representative set of goals, but would leave the least amount of time for utilities to plan their 2012-2014 energy efficiency portfolios.
In the June 11, 2008 comments, the majority of parties favored a TMG update and establishment of IOU program-specific goals that would benefit from the input of the 2006 -2008 Impact Evaluation studies, scheduled to be completed in March, 2010.44 DRA believes the update should wait until the Commission's evaluation of the utility risk/reward incentive mechanism is complete45 and the 2011 minimum performance standard (MPS) is established46 both in February, 2011. In response, NRDC suggests that DRA's recommendation to move the update after February, 2011 would not provide adequate time for IOU program planning to occur.47
We agree with DRA that the schedule for updating the 2012-2020 goals should incorporate information from the 2006-2008 Impact Evaluation studies and resulting DEER updates. However, waiting until early 2011 to begin the goals update and establish utility-specific goals would necessarily delay planning and implementation of 2012-2014 energy efficiency portfolios. Since the Impact Evaluation studies and DEER updates are scheduled for March 2010, we expect the 2012-2020 goals update and new utility-specific goal process to begin soon after that. We also agree with NRDC and the IOUs that the establishment of final goals for 2012-2020 must be completed with adequate time for 2012-2014 portfolio planning to occur. We find that the update must be completed by October, 2010 for adequate portfolio planning lead time. We direct Energy Division to manage the scheduling details of this update including the review of market effects protocols, and the vintage of data used. In addition, we direct that the update process must include at a minimum a rerun of the ASSET model48 with 2006-2008 ex-post DEER numbers, and the 2009 adopted market price referent.
44 Parties commenting in favor of this portion of the schedule included PG&E, SDG&E, SCG, and DRA.
45 DRA Reply Comments, p. 7.
46 DRA June 11, 2008 Comments, p. 6.
47 NRDC reply Comments, p. 4.
48 The 2008 IOU Potential Study output data was developed with the ASSET model by Itron.
