6. Whole House Programs

D.09-09-047, OP 21(a) states: "Pacific Gas and Electric Company, Southern California Edison Company, San Diego Gas & Electric Company, and Southern California Gas Company shall include a Prescriptive Whole House Retrofit Program (PWHRP) in their statewide residential program, consistent with guidance provided in this decision." The new statewide PWHRP was to be in addition to the utilities' respective local Whole House Prescriptive program (WHPP). These programs are collectively referred to as "Whole House Programs" and are designed to comprehensively address the potential for energy savings in residential buildings.

Since the issuance of D.09-09-047, Joint IOUs state that they have worked closely with Energy Division to further develop the Whole House Program designs. A program implementation plan was filed via Advice Letter on January 29, 2010 seeking Commission approval of the Whole House Program.⁸ The Commission issued final approval of the Whole House Program on March 29, 2010. In collaboration with Energy Division, the Joint IOUs are currently continuing analysis on this program to determine the technical potential for energy savings, program cost effectiveness, and other parameters.

Joint IOUs state that they, along with Energy Division, have determined it is technically infeasible for the PHWRP to achieve an average of 20% annual energy savings by the end of 2012. Joint IOUs request the Commission modify the requirement to reach an average of 20% annual energy savings for the Whole House Programs by the end of the cycle, to an average of 10%⁹ for the Prescriptive (PWRHP or "Basic" Program) strategy by the end of the cycle. The Joint IOUs do not request a lowering of the annual savings target for the WHPP (average savings per home), which would therefore remain at 20% Joint IOUs state they will also continue to evaluate an appropriate average savings per home threshold for the PHRWP program.

For the Advanced Home Program Portion of their respective local WHPPs, Southern California Edison Company (SCE), San Diego Gas and Electric Company (SDG&E) and Southern California Gas Company (SoCalGas) request a minimum 10% energy savings per treated home/unit for the Advanced Home Program portion in their respective local WHPP. PG&E requests a15% minimum energy savings for its customers.

Additionally, the Joint IOUs' Whole House Program implementation plan acknowledges the importance of the low income, middle income, and multifamily customers and commits to seeking to expand the program offering during the 2010-2012 program cycle to potentially include multifamily housing units.¹⁰ However, currently there is no identified process for approval of such a plan. Thus, Joint IOUs propose a modification to clearly require the Joint IOUs to file a supplemental Advice Letter outlining program plans for such an expansion if the utilities deem such an expansion is appropriate and feasible.

Lastly, Joint IOUs request the language be modified to clarify the decision's guidance for the IOUs to "aim at reducing the annual energy consumption of 130,000 homes over three years by 20% through comprehensive retrofits." D.09-09-047 at 9. Joint IOUs request a modification to clearly state that these market penetration and energy savings figures represent an aspirational goal and are for the entire state, not specific to the IOUs.

DRA/TURN agree that the requirements for the Statewide Whole House Program should be modified, but not to the extent that the Joint Utilities request. DRA/TURN do not oppose the reduction of the savings goal for the PWHRP, but recommend denial of the request to lower the goals for the Advanced Home Program. DRA/TURN reasons that the higher incentives and additional expenditures authorized for the WHPP should produce a higher level of savings than achieved under the Basic Program. DRA/TURN claim that there is insufficient information to support the Joint Utilities' request on this point.

We will adopt the uncontested proposed modifications to the Statewide Whole House Program for the PWHRP. We agree that the annual savings goals for this program, while reasonable at the time adopted, may be technically infeasible at this time. For the WHPP, as noted above, the Joint Utilities did not request to lower the annual savings goals for this program from the current 20% (average per home); therefore, as stated in D.09-09-047, the WHPP's should continue to "seek to drive the market to retrofit at least 1% of California homes in the utility service areas to at least 20% annual savings by the end of the program cycle." We note the Joint Utilities intent to lower the threshold for the WHPP to 10% for SCE, SDG&E and SoCalGas and for PG&E, to 15% annual energy savings. These lower incentive thresholds are consistent with an annual average goal of 20% energy savings per home and thus do not require explicit approval herein.

⁸ PG&E 3087-G/3608-E, SCE Advice 2430-E, SDG&E Advice 2144-E/1926-G, SCG Advice 4070. PG&E's advice letter was supplemented by PG&E Advice 3087-G-A et al on March 5, 2010.

⁹ PG&E requests the CPUC's approval to measure savings for a subset of Prescriptive homes/units to properly characterize baseline energy consumption and modeled savings improvements. After properly measuring and determining appropriate savings estimates for Prescriptive homes, PG&E will work with Energy Division to properly set the Prescriptive Deemed Savings.

¹⁰ Advice 3087-G et al, Attachment 1 at 13.