Issue 5: Should the Commission increase the revenue requirement in this proceeding to produce more conservation activities by Edison?
Position of Parties
NRDC argues that unless the CPUC acts in this proceeding, funds for Commission-directed energy efficiency programs in Edison's service territory will "decrease by 18% in 2002 from budget levels in 2001."29 NRDC notes that in 2001, the passage of Senate Bill X-5 resulted in a $19.2 million increase in conservation funding in Edison's service territory. Since this allocation of funds applied only in 2001, without Commission action, NRDC contends that conservation budgets will decrease. NRDC maintains that it is appropriate for the Commission to consider its request in this proceeding because Rulemaking (R.) 01-08-028 considers only how to spend conservation funds, not the funding level.
Edison opposes the NRDC request, stating that R.01-08-028 offers the appropriate venue for considering not only conservation expenses, but also the level of funding. Edison cautions that it would be "inappropriate to mix funding for energy efficiency programs with Edison's distribution rates."30
ORA opposes NRDC's proposal on several grounds. First, ORA states that NRDC has failed to justify the restoration of the conservation funding. Second, ORA argues that NRDC has "only the vaguest notions about what these funds will finance in the way of conservation programs."31 ORA concludes that unless the Commission is willing to specify in this proceeding exactly how Edison should spend these funds, the Commission should deal with the funding issue in R.01-08-028.
TURN also opposes NRDC's proposal, arguing that granting an increase in funds to one utility is "premature."32 TURN recommends that the Commission examine Demand-Side Management (DSM) issues for all utilities "as part of the overall review of year 2002 programs and the rulemaking on DSM administration."33 TURN opposes additional funding at this time in part because it believes that "Edison has done a miserable job of running DSM programs."34
Discussion: The Commission will consider the level of DSM expenditures in R.01-08-028.
We concur with the analysis of ORA, TURN, and Edison and agree that this is not the appropriate proceeding for setting the level of conservation spending for Edison.
29 NRDC, Opening Brief, p. 16; Exhibit 400, p. 21. 30 Edison, Reply Brief, p. 13. 31 ORA, Reply Brief, p. 11. 32 TURN, Opening Brief, p. 4. 33 TURN, Opening Brief, p. 4. 34 TURN, Opening Brief, p. 3.
