XIII. TURN's Proposal to Restrict Gas Allowances

TURN proposes that customers not be given an allowance for space heating or water heating unless gas will be used for both. TURN states that this will eliminate uneconomic substitution of electricity for gas. TURN also points out that it is virtually impossible to pass the CEC's Title 24 building efficiency standards and install electric water heating where gas is available.

Sempra opposes TURN's recommendation because it would reduce the service options available to the applicant.

TURN's proposal would discourage use of electric resistance space heating and water heating where gas is available. However, there may be cases where gas is available, but use of tankless point-of-use electric water heaters or electric heat pumps for space or water heating is appropriate. The record does not contain sufficient information for us to address this possibility. Thus, we do not adopt TURN's recommendation.