Protests to the Applications

Protests to the utilities' PY 2001 applications were filed by the CEC, TURN, the Residential Energy Efficiency Clearing House, Inc. (REECH), NAESCO, RESCUE/SESCO, Primis, and Robert Mowris and Associates (Mowris). Comments were filed by the Sierra Club and Appliance Recycling Centers of America, Inc. (ARCA).

In their protests, intervenors and protestants raise issues primarily relating to the proposed overall program portfolio and budget allocations as well as to individual program design and budgets. Intervenors and protestants argue that the utilities' program portfolios do not comply with the directives set forth in D.00-07-017 and the mandate of AB 970 and fail to produce maximum energy and demand savings. They raise issues with respect to individual programs, making suggestions for improved program design, proposing new programs and energy efficiency measures, different financial measures, and changed incentive levels, and seeking the elimination of programs that they believe are not successful. They disagree over program priorities, budget allocations, and funding levels and challenge the reasonableness of the utilities' proposed shareholder incentives and milestones. ORA also seeks a return to the pre-1998 recorded net benefits mechanism for calculating shareholder incentives that requires ex post savings measurement over time and the institutionalization of protocols and standards for review and verification. ORA also seeks to prohibit commercial customers who have an electric load in excess of 500 kw from obtaining any financial assistance under these programs. TURN and REECH object to the inclusion of carry-over funds and balancing account interest in PY 2001 budgets. REECH also seeks better information about program administration and administrative costs, management structure, and budgets to evaluate whether the utility administrators are properly using PGC funds.