7. Categorization and Assignment of Proceeding
This proceeding is categorized as Ratesetting. The assigned Commissioner is Dian M. Grueneich and the assigned ALJ is David M. Gamson.
1. D.09-09-047 found that the majority of measures found in the SCE portion of the Palm Desert Partnership are not innovative measures, but rather are standard measures that are offered routinely by SCE in other energy efficiency programs, with the exception of the early retirement of residential air conditioning systems.
2. The Impact Evaluation did not conduct any rigorous impact analysis of the SoCalGas portion of the Partnership because of very little program activity.
3. The Impact Evaluation for SCE found: a) RCA realization rates were exceedingly low; b) there were relatively low realization rates for early retirement of residential AC units; and c) gross savings of the early retirement program were significantly higher than ex ante projections. The Impact Evaluation recommended improved documentation of RCA measures, a higher level of oversight and quality control of installation contractors and other improvements for the three SCE programs evaluated.
4. The Process Evaluation excluded the SoCalGas component of the pilot program from evaluation because there was essentially nothing presented by SoCalGas to evaluate. The Process Evaluation found that nearly all of the SoCalGas Partnership program costs of $990,000 were spent on operating and administrative activities, with less than $6,000 paid in incentives.
5. SCE's claim to have achieved 71% of energy savings and 69% of demand reduction (compared to its five-year goals established in 2006) through 2009 is unverified.
6. The Process Evaluation found anecdotal evidence that the Partnership's program value was greater than the sum of its parts.
7. The Process Evaluation found that it was unlikely the Partnership would be cost-effective even if allowed to run a full five years.
8. The Process Evaluation found concerns about poorly defined program design. Regarding innovation, the Process Evaluation was hampered by "the absence of a clear explanation of the program logic that linked program actions to intended actions" and "the absence of detailed quantitative and qualitative data to support the direct linking of program actions with outcomes."
9. The Process Evaluation could not conclude whether or not many of the strategies used in the Partnership by SCE are successful or replicable.
10. The utilities' critique of the Impact and Process Evaluations appropriately point out certain imperfections in the evaluations and raise a number of methodological questions. However, the specific issues raised do not undermine the basic findings of these reports.
11. A full evaluation of the Partnership is not yet possible, due to both data problems and the potential for future benefits from improvements in the Partnership.
12. The Partnership has shown value to the Palm Desert community, and the energy efficiency community in California as a whole, as a means to test a wide variety of energy efficiency strategies in one geographic location.
13. While it is unclear that the efforts of the Partnership are replicable in other areas of California, further efforts may provide a basis for replication.
14. The Partnership proposes certain support activities for AB 811 program development, which may be in violation of D.09-09-047 at 285, unless they conform to certain exceptions provided in that decision.
1. It is reasonable to rely on the Impact and Process Evaluations to determine the future of the Partnership.
2. SoCalGas' participation in the Partnership should not continue, due to minimal benefits, high administrative costs and a low likelihood of improvement.
3. SCE's participation in the Partnership should continue, based on a reasonable level of benefits to date and a reasonable likelihood of further improvements.
4. SCE's Program Implementation Plan should be modified to take into account recommendations found in the Impact and Process Evaluations, and to provide additional information about the Partnership including a demonstration of how proposed AB 811 development support activities conform to D.09-09-047.
5. It is reasonable to allow SCE to shift funds from other approved energy efficiency programs to fund the Partnership through 2012.
6. It is reasonable to continue funding levels for the Partnership at levels consistent with the funding approved in D.10-06-039.
IT IS ORDERED that:
1. Southern California Edison Company is authorized to shift a total of $6.936 million, from the following energy efficiency funds approved in Decision 09-09-047, to the Palm Desert Demonstration Partnership for 2010 through 2012:
a. $5,744,000 from the Residential Energy Efficiency Program;
b. $638,000 from the Commercial Energy Efficiency Program;
c. $176,600 from the Residential and Commercial Heating, Ventilation and Air Conditioning Program; and
d. $422,000 from the Energy Leader Partnership Program.
2. Southern California Gas Company's Application is denied.
3. Southern California Edison Company shall file an Advice Letter no later than 45 days after the effective date of this decision to revise the Palm Desert Demonstration Partnership Program Implementation Plan, consistent with D.09-09-047 and recommendations of the Energy Division Impact and Process Evaluations. The Advice Letter shall also include information responsive to the items in Appendix A to this decision.
This proceeding is closed.
Dated December 16, 2010, at San Francisco, California.
MICHAEL R. PEEVEY
President
DIAN M. GRUENEICH
JOHN A. BOHN
TIMOTHY ALAN SIMON
NANCY E. RYAN
Commissioners
Appendix A
The Advice Letter referenced in Ordering Paragraph 3 of this decision shall include the following information:
1. Budget Allocation - Provide a line item budget that details the funding allocation to each resource and non-resource program element represented in the Program Implementation Plan (PIP). Account for all ratepayer funds requested. Describe how the funds will be used for the program elements.
2. Savings Source - Provide a breakdown of where projected savings are expected to come from, accounting for all of the projected savings. Include a line item for technologies where appropriate, and statewide or third party resource programs funded under the demonstration program budget (e.g., pool pumps, higher than normal incentives, or Whole House Retrofit Program, Energy Efficiency Upgrade Program, etc.)
3. Links Statewide - Provide a detailed description of whether the resource programs listed in the program description are statewide programs, third party programs, or programs uniquely offered by the Palm Desert Demonstration Partnership (Partnership). What is the relationship of these programs to the Palm Desert Demonstration Partnership? (e.g., which elements in the partnership do they leverage, or how does the partnership leverage them?) Describe where and how the notable technologies referred to in the program description are being offered in other parts of Southern California Edison Company (SCE) territory.
4. Making Sense of Logic Model - A large array of resource, non-resource and policy elements are presented briefly in the pilot description. The logic model does not discretely show how each of these various elements relate to each other, and to intended program outputs and outcomes. Identify individual program components and describe which program outputs, outcomes or goals they will impact and how.
5. Partner Roles - Provide a detailed description of the roles, responsibilities and goals of the City of Palm Desert, utility staff, and Energy Coalition, and any other partner for each of the program components. Note which if any program elements are predominantly or solely the responsibility of a non-utility partner, such as the City of Palm Desert. Describe the management and decision-making structure, noting who holds ultimate responsibility for the demonstration, or for which parts of it. Include in the line item budget requested above the allocation for each of the partners, including Energy Coalition.
6. Data and Tracking - The impact and process evaluations of the 2007-2008 Palm Desert Partnership & Demonstration Program cited deficiencies and made recommendations regarding program reporting and tracking. Further, a Commission evaluation of 2006-2008 local government partnership non-resource program elements found a general lack of targets and tracking of referral, audit and training components among local government partnerships statewide. This indirect impact evaluation provided a template tool to facilitate a standardized method of tracking and capture of basic program and participant information, and several concrete recommendations. Explain how the pilot is addressing these needs and recommendations. In addition, provide a detailed description of how SCE is structuring program reporting and tracking for resource and non-resource elements in order to capture data that supports a) assessment of success of program strategies, b) the direct linking of individual program actions with outcomes, c) timely reporting and feedback, d) assessment of the demonstration nature of the pilot, including replicability and scalability, and e) cost-effectiveness based on budgeting detailed enough to allow for a cost-benefit analysis of individual strategies. How will SCE insure data is captured correctly and in a timely manner, in order to support assessment of success?
7. Evaluation Plan - Explain what data (identified above) and methods will be used to evaluate the pilot. How will SCE determine whether program elements are successful, and whether they can be scaled up for broader use in larger locales? Which strategies (such as elevated incentive levels) need to be assessed early in the cycle? How will SCE insure there is no double counting of energy savings? Identify the need for baseline setting, and performance metrics. (Per Decision 09-09-047 pilot project criteria.)
8. AB 811 Development Support - Demonstrate how the specific AB 811 support activities funded through the Partnership conform to one or more of the three exceptions to the Commission's "general prohibition against utility direct involvement of the utilities in community financing program development" (D.09-09-047 at 285). If specific activities cannot be shown to conform with D.09-09-047 prohibitions, then these activities should be eliminated from the PIP and any funding through the Partnership.
(End of Appendix A)
