Issues Raised by the Applications

In their protests or comments on the issuance of an Interim Decision, 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. Protestants and interested parties 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.

Most of the parties support issuance of an Interim Decision approving, subject to mid-term modification, the bulk of the utilities' proposed programs, budgets, and activities, effective January 1, 2001, excluding shareholder incentives and milestones.⁷ A few parties support issuance of an Interim Decision but only contingent on our approval or disapproval of specific programs or budgets, e.g., enhancement of TPI budgets (Primis and Mowris) or approval of a new recorded net benefits mechanism with ex post savings measurement, protocols, and policies, rejection of nonresidential rebate programs, and elimination from program participation of large commercial customers (ORA). The CEC proposes that the utilities be authorized to implement 90% of their program budgets on an interim basis.