XII. Membership and Role of the EAG
1. Parties' Positions
PG&E proposes that the EAG be available as an advisory body to give input into the CPT program. Several parties suggest that PG&E create additional EAG member slots beyond those PG&E lists, and PG&E agrees to these changes. CCSF also proposes that the EAG be given some decision making authority over the CPT. CCSF also asks that EAG members be appointed by an independent entity (CCSF suggests DRA), because it is concerned a PG&E-dominated EAG will direct which protocols CCAR develops next. CCSF has its own priorities for which protocols are most needed, and they may not jibe with PG&E's preferences.
DRA states that its "experience with advisory groups in the context of energy efficiency has been that they are of questionable value."41 Therefore, DRA suggests other changes to the CPT to make it more accountable, without focusing on EAG.
2. Discussion
We adopt the parties' proposed changes in membership of the EAG (to which PG&E has agreed), but reject the other suggestions. We believe we have built sufficient accountability into the program by requiring PG&E to meet a minimum GHG reduction target, preview its marketing plan with the Commission, and engage in regular reporting of program results. We do not believe giving the EAG a decision making role in the program is appropriate, but we will require PG&E to address recommendations it receives from the EAG.
Therefore, as PG&E agrees, the EAG shall include a representative of each of the following interests, with a representative trade or consumer group an adequate substitute for direct representation: residential customers, large business, small business, non-profits, environmental groups, environmental justice groups, local governments and state environmental agencies, agriculture, low income groups 42 and the Commission staff.
PG&E shall also have a conflict of interest screen for any member of the EAG. No person or group may serve on the EAG that has a direct financial interest in the CPT program. Thus, potential GHG contracting parties, marketing firms, or others that may receive direct funding from the CPT program budget may not serve on the EAG.
41 DRA opening comments at 6.
42 We understand that low-income customers are less likely to enroll in the CPT due to the cost premium. However, we encourage PG&E to consider creative alternatives to enable their low income customers to also participate in reducing GHG emissions. In addition, to the extent that there is an educational component to the marketing campaign, it is appropriate to consider outreach to all customers regardless of income level.
