II. Discussion

A. Edison's MA&E Plans, Studies, and Budgets

In its revised plan, Edison provides more detail about its studies than that set forth in its application. Edison proposes some new studies to develop reliable estimates of energy savings and peak load reductions for specific programs. Edison's proposed new studies are reasonable and approved.

Edison also proposes to abandon some of its previously proposed studies, asking that it be relieved from several of the requirements of D.00-07-017. Edison proposes alternative means of compliance for some of the requirements.

First, Edison proposes to abandon quarterly reporting of changes in energy efficiency measure saturation levels. (D.00-07-017, Ordering Paragraph 54.) Instead, Edison proposes to provide an update on energy efficiency measure saturation levels one time, for PY 2002 planning purposes. This is reasonable, not only for Edison, but also for all the utilities. The utilities should provide a report on energy efficiency saturation levels in their Annual Reports.

Second, Edison proposes to abandon quarterly reporting and the special analyses necessary to establish program participation by "hard-to-reach" segments of residential and small nonresidential customers. (D.00-07-017, Ordering Paragraphs 35, 36, and 66.)³ Instead, Edison proposes to provide reports on segment participation in its Annual Report on PY 2001 programs, using available data sources, but not commissioning special new studies to gather additional data.

Efficient and equitable use of the public goods charge requires that all customers have the opportunity to fully participate in energy efficiency programs. We have previously determined that there are large groups of customers who contribute to the public goods charge but who do not receive energy efficiency services. We have categorized these customers as "underserved" or "hard-to-reach." We have also found the utilities' outreach efforts lacking. Full participation by all customers is particularly important during the current energy shortage. It would not be in the public interest to eliminate all efforts to identify and target customers who are not being reached by current utility-administered programs. Thus, we reinstate Edison's budget for the hard-to-reach analyses.⁴

Edison's request to provide the required information in its Annual Report instead of on a quarterly basis is reasonable not only for Edison but for all the utilities. The utilities should submit the required information in their Annual Reports.

Third, Edison asks that it be relieved from providing data on five of the eighty-two performance indicators related to long-term market transformation goals that it proposed in response to Ordering Paragraph 76 in D.00-07-017.⁵ Edison proposes to eliminate the following five surveys and instead include these or related, broader indicators in statewide studies:

· A survey of pre- and post-program energy efficiency awareness of a sample of customers reached by the residential mass market program

· A survey of customer awareness of the cost of operating inefficient appliances

· An exit survey at retailers of customer awareness of high-performance windows, and

· Surveys for both the nonresidential renovation/remodeling and the nonresidential new construction sectors of the frequency of energy efficiency requirements in Requests for Proposals for projects, and of the frequency of requests for energy efficiency design experience in Requests for Qualifications sent to design professionals.

Edison's request is reasonable. Edison's reports on the statewide studies should specifically identify how these indicators were addressed in those studies. Edison's utility-specific MA&E studies and budgets are approved as set forth on Attachment A.

B. PG&E's MA&E Plans, Studies, and Budgets

In its revised plan, PG&E provides more detail regarding its proposed utility-specific studies than that set forth in its application. PG&E proposes new studies to evaluate demand and energy savings for new residential and nonresidential programs, such as the residential 1-2-3 cashback program, and the nonresidential air conditioning and task lighting programs. PG&E's new studies appear reasonable and are approved.

PG&E also asks for "relief" from some of the requirements of D.00-07-017. First, PG&E seeks to be relieved of its obligation to track non-residential program participation, particularly for the Standard Program Contract (SPC) program. (D.00-07-017, Ordering paragraph 49.)⁶ Program participation information is essential for the operation of an efficient, effective, and equitable energy efficiency program and it is important that all the utilities continue to track participation. However, we will only require PG&E and the other utilities to track participation going forward and looking backward three years. The utilities should focus on sorting and presenting data already tracked to answer basic questions about repeat customer and Energy Service Company (ESCO) participation, by subsector. The utilities are not required to recontact participants from years prior to the issuance of D.00-07-017 to obtain necessary data.

Second, PG&E seeks relief from the requirement that it perform a saturation study for commercial lighting and other end-uses suspected of being more than 50% saturated. (D.00-07-017, Ordering paragraph 54.) Instead, PG&E proposes to include this topic in its newly-proposed Technical and Market Potential for Energy Efficiency in the Nonresidential Sector study. This request is reasonable so long as PG&E ensures that commercial lighting saturation is covered in the Technical and Market Potential study and demonstrates such inclusion in its study report. PG&E should also report on saturation in its Annual Report.

Third, PG&E seeks relief from performing studies to assess "performance indicators" related to milestones for all programs. (D.00-07-017, Ordering paragraph 76.) Performance indicators provide useful information for the design and implementation of future programs and should not be eliminated. However, recognizing that funds are necessary for new studies relating to new programs, we allow PG&E to perform a scaled-back version of the "performance indicator" studies, with a reduced budget. PG&E should include a summary of the proposed scaled-back studies in its next Quarterly Report.

PG&E did not propose any studies or budget for the hard-to-reach segment analysis required in D.00-07-017 (Ordering Paragraphs 35, 36, and 66). As we stated earlier, efficient and equitable use of the public goods charge requires that all customers have the opportunity to fully participate in energy efficiency programs and it would not be in the public interest to eliminate all efforts to identify and target customers who are not being reached by current utility-administered programs. Thus, we require PG&E, like the other utilities, to conduct appropriate studies. PG&E may limit the scope of its studies to certain customer segments and/or programs, as it deems necessary, but should ensure that the studies performed are funded sufficiently to produce usable results. PG&E should file the required information in its Annual Report. ⁷

PG&E's utility-specific MA&E studies and budgets are approved as set forth on Attachment A:

C. SDG&E's MA&E Plans, Studies, and Budgets

In its revised plan, SDG&E provides more detail about its proposed studies than that set forth in its application. SDG&E proposes new MA&E studies for its new programs and funds for measurement of PY 2000 Summer Initiative programs. SDG&E's new studies are reasonable and approved.

SDG&E also proposes to reduce funding for studies related to market effects milestones and for performance indicators. Because SDG&E will still be performing some studies of performance indicators, consistent with the other utilities, SDG&E's proposed reductions are reasonable and are adopted.⁸

SDG&E's utility-specific MA&E studies and budgets are approved as set forth on Attachment A.

D. SoCalGas' MA&E Plans, Studies and Budgets

In its revised plan, SoCalGas provides more detail regarding its proposed studies than that set forth in its application. SoCalGas proposes new studies to evaluate new programs. The new studies are reasonable and are approved.

SoCalGas also seeks to be relieved from complying with some requirements of D.00-07-017. Specifically, it does not propose to conduct any studies to facilitate the hard-to-reach segment analyses required by D.00-07-017, Ordering Paragraphs 35, 36, and 66. As we stated earlier, efficient and equitable use of the public goods charge requires that all customers have the opportunity to fully participate in energy efficiency programs and it would not be in the public interest to eliminate all efforts to identify and target customers who are not being reached by current utility-administered programs. Thus, we require SoCalGas, like the other utilities, to conduct appropriate studies. Recognizing that funds are necessary for SoCalGas' new studies supporting program offerings, we allow SoCalGas to cut back on the originally proposed studies and budgets. SoCalGas may limit the scope of its studies to certain customer segments and/or programs as it deems necessary, but should ensure that the studies performed are funded sufficiently to produce usable results. SoCalGas should file the required information in its Annual Report.⁹

SoCalGas also requests that it be relieved of the requirement to comply with quarterly reporting of energy efficiency measure saturation data given the cost of obtaining sufficiently accurate and detailed data. Energy efficiency programs should not be providing incentives where the market is already saturated. Thus, this information is important and should be collected. SoCalGas should conduct appropriate studies and, like the other utilities, report on measure saturation data in its Annual Report.

SoCalGas' utility-specific MA&E studies and budgets are approved as set forth on Attachment A.

E. CEC MA&E Study Plans

The utilities' revised MA&E plans provide further clarification and background, with supporting summary tables, of the funding requests for CEC-implemented studies. The specific projects and budget proposed are the same as in the original applications. They explain the request as follows. In Resolution E-3592, the Commission authorized $2.1 million for 2 years to the CEC for Title 20 data collection activities, for a total of $4.2 million, as follows:

	1999	2000
Commercial End Use Survey (CEUS)	$1.7 million	$1.7 million
Updates to Database of Energy Efficiency Resources (DEER)	$400,000	$400,000
Total	$2.1 million	$2.1 million

The utilities' PY 2000 and 2001 applications (filed on September 27, 1999), proposed to use the $2.1 million budgeted for the CEC-administered programs in PY 2000 for a Residential Appliance Saturation Survey (RASS) instead of the CEUS and DEER projects. They further requested an additional $2.1 million for PY 2001 to fund the second half of the CEUS and additional DEER projects administered by the CEC. The following table illustrates the proposal:

	1999	2000	2001
CEUS	$1.7 million		$1.7 million
DEER Updates	$400,000		$400,000
Residential Appliance Saturation Survey (RASS)		$2.1 million
Total	$2.1 million	$2.1 million	$2.1 million

The utilities' PY 2001 applications (filed on November 15, 2000), proposes to reallocate the PY 2000 funds for CEC-administered programs, with $1.9 million going to RASS and $200,000 to CEUS. The applications reiterate the previous request for an additional $2.1 million ($1.7 million for CEUS and $400,000 for DEER) for 2001. The current proposal as set forth on Attachment A.

The proposed studies are reasonable and necessary to provide basic data, particularly on customer characteristics, energy use, and energy-using technologies. Further, the CEUS and DEER studies have begun and require second year funding and funds have been encumbered for the RASS. We adopt the proposed funding for CEC-administered studies as set forth on Attachment A.

Each utility should allocate the following budget set forth on Attachment A to fund the CEC-sponsored studies.