OF THE STATE OF CALIFORNIA
Order Instituting Rulemaking to Examine the Commission's Future Energy Efficiency Policies, Administration and Programs. |
R.01-08-028 (Filed August 23, 2001) |
American Synergy Corporation with Robert Mowris and Associates respectfully submit the following information in response to questions received March 13, 2002 about the "Comprehensive Hard-to-Reach Mobile Home Energy Savings Program" in the Pacific Gas & Electric (PG&E) service territory.
18 March 2002
Mr. Tuukka Hess
Energy Division
State of California
Public Utilities Commission
505 Van Ness Avenue
San Francisco, CA 94102-3296
Dear Tuukka:
We appreciate your letter seeking additional information on our proposal entitled "Comprehensive Hard-to-Reach Mobile Home Energy Savings Program." I have itemized each item that you have requested clarification or more information with a number and the request for information, with our response in Italics.
1. The program claims to "provide a comprehensive energy program to 4000 small commercial customers." (pg. 6 of proposal) Nowhere are plans for this small commercial program mentioned. Do you plan on offering services to this sector? If so, please provide appropriate details.
On the original and hard copies of the proposal this item was supposed to have been crossed-out and initialed. One may have slipped through where it was not crossed off. If it still appears in the proposal, this is in error and should be deleted. I went back and noticed in the electronic filing that it is already deleted.
2. What measures will be provided to the typical mobile home? Please include the number of units installed on a per-measure basis. (e.g. X # compact fluorescent light bulbs.)
Typical measures that will be installed include a combination of the following items:
We anticipate that the mobile home customers that we target will require many of these measures since few contractors specialize in servicing mobile homes and there is a great need for serving these customers and homes (one of the most underserved and hard-to-reach markets).
The mobile home property manager or owner will be contacted about the availability of this comprehensive hard-to-reach energy savings program. With permission of the park manager, each mobile home customer will receive a letter informing him or her of the program. The mobile home owner will call our office for a scheduled appointment. We do not "cold" call customers directly - they call us.
At the appointed time, the trained technician will do a survey of the mobile home to see what energy efficient measures that it stands in need of. Once an assessment is completed, the technician and work crew will perform whatever measures are needed to fully maximize energy savings and satisfaction for the customer. Pre- and post-test results are provided to the customer to indicate the improvement of their system.
It is our estimate that 6,000 mobile home owners will require some type of energy efficiency measure to maximize their energy efficiency, as projected above. Some homes will already have certain measures installed. Because most of the measures have a long-term permanence, we will install what is needed.
3. Will the services provided to mobile home residents include the conduction of Combustion Appliance Safety testing? If so, please provide the budget details associated with this work, on a per-test basis.
If the Commission requires the use of CAS testing for all affected energy efficiency programs, then ASC and RMA will incorporate such testing into our programs. Such a requirements, should they be required at all, should be implemented in a uniform state-wide procedure for all IOUs and all costs for the testing should come solely from IOU funds outside of PGC funds.
This is the procedure already approved by the Commission in the Commission's LIEE dockets for similar requirements. It is our understanding that PG&E does not include this requirement for its own upcoming (2002) Residential or Multi-Family rebate and retrofit programs. Nor do any of the other IOUs include this testing for their Statewide or Local programs involving combustion appliances or other measures affecting combustion appliance safety.
While the IOU residential and multi-family rebate programs are not as comprehensive and do not include, for example, duct testing and sealing work or AC Diagnostics, they do include infiltration reducing measures such as window repair and replacement and attic insulation packages which usually include infiltration reduction features.
The issue of CAS tests being required when retrofits may reduce infiltration rate has been extensively reviewed in a number of dockets, especially in the low-income dockets. In these, the Commission has not required CAS tests be mandated. To date the Commission has left it up to the utilities to determine under what circumstances to require CAS tests and when (before or after installation).
The Commission does have an open docket item to determine the need for such tests and, if needed, how to standardize their use. However, in ALL related decisions, the Commission has required that if PG&E or any other IOU does require any CAS tests, these be paid for by the IOUs, which have been budgeted funds for these, and that the costs NOT be charged to PGC funds. For this reason, we have not included these as a measure or as a cost. The Commission does not require the use of CAS tests to date. And if they do become required, then we expect that the cost of these will be charged to the utilities' general funds and not to the PGC funds. If CAS testing is to be required at all, the utilities should use a uniform state-wide procedure for all CAS testing required and that any costs for the testing shall come solely from IOU funds outside of PGC funds. This is the procedure already approved by the Commission in the Commission's LIEE dockets.
ASC has performed many thousands of duct tests and seals on mobile homes in the Southern California Edison and Southern California Gas areas, without the requirement of a CAS test. We also completed a 3rd party initiative with San Diego Gas & Electric with over 1,000 mobile homes, and once again, there was no requirement of a CAS test.
However, if a CAS test is required, the cost to perform this work takes approximately 30-45 minutes and the per-test cost would be $50.00 per site. If the customer does not pass the CAS test, both the customer and utility will be informed for corrective action. Corrective action would be the responsibility of the customer.
If, indeed, the CPUC requires a CAS test for each mobile home to be paid for from our budget, then ASC will need to modify or reduce the total number of proposed mobile homes served to accommodate this added service.
4. Does the program intend to include safeguards to ensure that, on the whole, a comprehensive package of energy efficiency measures will be delivered to mobile home residents? If so, please provide details of these safeguards.
Our installers and auditors are trained to evaluate each potential mobile home participant to determine the most complete set of comprehensive measures to install. All technicians are thoroughly trained on duct testing and sealing and air conditioner tune-ups.8 A thorough audit of each mobile home is performed to see if the measures mentioned above are installed. Measures are noted on data collection/installation forms or entered electronically into our Microsoft Access Mobile Home Database. Technicians report their pre-test and post-test information in order to verify proper installation (a sample of our Mobile Homes database data collection screens are shown in Attachment 1). These data collection forms will be modified specifically for this proposal.
During the year of 2001, American Synergy Corporation successfully completed a number of Mobile Home Projects and also participated in the Summer Initiative Program. During those programs American Synergy Corporation and Robert Mowris and Associates established a track record of installing a variety of measures that worked toward realizing a comprehensive package view versus installation of one or two measures. In one of the projects, a 3rd party initiative, designed to improve the energy efficiency of mobile homes, ASC and RMA completed Duct Test/Seals, AC Diagnostic Tune-ups, CFL installations on 95% of homes and installed Programmable Thermostats on 13% of homes. During the SIP program ASC completed 51% duct seals, 35% water heater blankets, 26% weather stripping, 65% CFL installations, 39% Low-Flow Showerheads, and 24% aerators.
One of the key parts of this proposal is the strong accountability component established by the ME&V services provided by Robert Mowris and Associates. ASC and RMA are independent companies to one another. Robert Mowris and Associates have a solid reputation as energy efficiency engineer and have worked with ASC to safeguard that a comprehensive package of energy efficiency measures are installed. We will account for the production.
One important additional item is that American Synergy has been a reputable energy efficiency contractor for over 20 years in California. It has a history of completing its benchmarks as outlined. ASC and RMA hope to still be making a contribution 20 years from now. That will only be possible as ASC and RMA completes the work as outlined.
American Synergy's Mission Statement is "We Treat People Right". That applies to customers, employees and the individuals or organizations that we contract to do work for.
We believe that the most significant safeguards are our track record, and the independent accountability set up within the program of ME&V.
5. Does the program intend to include safeguards to ensure that contractors do not use public purpose funds to promote services not included under this program? (i.e. Contractor promotes own services to residents when conducting program work.) If so, please provide details of these safeguards.
This program intends to safeguard the use of public purpose funds by installing the work that is outlined in our proposal. We will not offer "other" services unless it is absolutely necessary. For example, if a customer has a non-functional duct system or air conditioner system and desires a functional system, then we will offer to install a functional system at the most reasonable cost possible and take advantage of incentives where appropriate from other statewide programs (i.e., incentives for SEER 12 or better ac units under the 1-2-3 Cash Back Program). This will allow our program to complement existing programs wherever possible without promoting our own self-interest.
Our goals are to maximize energy savings and customer satisfaction by providing an innovative comprehensive energy efficiency program to hard-to-reach mobile home customers. One of the most significant safeguards will be the accountability that American Synergy will provide that accounts for the work done for each customer.
Conclusion:
American Synergy Corporation along with Robert Mowris and Associates appreciate the opportunity to respond to Tuukka Hess' request for clarification. We are excited about the possibilities of working in conjunction with the Commission and Utility to provide these much needed services to a group of ratepayers and customers that are clearly hard-to-reach and underserved because of their economic status, living facilities, and unique demographics. We wish to assure the commission that ASC and RMA will do everything in their power to complete this project in a way that will make us all proud and in a way that will leave a lasting impact in energy conservation and savings.
Sincerely yours,
_____________________
Steven R. Shallenberger, President ASC
Email: Shallenbgr@aol.com
For and in behalf of:
Kathleen E. Carlson, President RMA
Email: rmowris@earthlink.net
Attachment 1. Mobile Home Database Data Collection Screens
Figure 1. Duct Testing and Sealing Data Collection Screen (Computed cfm and cfm/ton leakage reduction are computed and checked to ensure quality control).
Figure 2. AC Diagnostic Tune-up Data Collection Screen (Superheat and subcooling values and refrigerant properties are checked when data is entered to ensure quality control).
Figure 3. CFL Data Collection Screen (Watts reduced are calculated in database to ensure quality control).
Attached please find SDG&E's response to your request for information on the Local Nonresidential Retrofit EZ Turnkey proposal. If you have any questions or require additional information, please do not hesitate to contact me.
<<Document.pdf>> <<SDGE Response to ED DR 3_11 re EZTurnkey.xls>>
J. C. Yamagata
Sempra Energy
Regulatory Affairs
Phone: 858-654-1755
Fax: 858-654-1788
Email:
jyamagata@sempra.com
The Energy Coalition
1540 South Coast Highway, Suite 204, Laguna Beach, CA 92651 (949) 497-5110 fax (949) 497-6406
STATE OF CALIFORNIA GRAY DAVIS, Governor
PUBLIC UTILITIES COMMISSION
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3298
March 13, 2002
Jonathan Kaufman Sent via email: Jon_Kaufman@solem.com
Secretary
California Building Performance Performance Contractors Association
550 Kearny Street, Suite 1010
San Francisco, CA 94108
This correspondence is written regarding the California Building Performance Contractors Association program proposal entitled "Comprehensive Whole-House Residential Retrofit Program." We request the following additional information regarding your proposal:
Number of retrofits accomplished.
· Pg. 17 of the proposal states "The program's market development goal is the education of public demand to allow completion of a target of at least 1000 retrofits within the program's 21-month term."
· Pg. 26 states that "We have projected conservatively that a total of at least 4000 retrofits can be anticipated with only a two-year extension of the analysis in each of the project's two initial cities, using only the personnel trained initially - i.e., as if our program stopped completely after 2003."
· The TRC table on page 26 expects 2000 retrofits in 2002-2003 only, and 8000 retrofits to 2004, same providers only.
· Page 28 claims that by the end of the second year, some 2000 homes will be retrofitted and within four years, about 8000 homes will be completed by the crews trained during this initial two-year program..."
Page 28 also notes that "In the first two years, CBPCA training can reach a minimum of 200 students in the target areas, comprising at least 50 loosely defined crews (20 in year one, 30 more in year two), with at least half of this new capability committed to pursue this new business. ...Each team will complete at least 50 comprehensive home retrofits per year..."
Using the information from pg. 28 (20 crews trained in year 1, 10 of which perform energy-efficient retrofits of 50 houses each year; 30 crews trained in year 2, 15 of which perform energy efficient retrofits of 50 houses per year), it appears that the crews trained in year 1 will perform 500 retrofits per year; and that the crews trained in year two will perform 750 retrofits per year. Using this information, it is difficult to understand the abovementioned performance targets. More specifically:
· Pg. 17 (1000 retrofits within 21-month period) appears to underestimate.
· The text within page 26 appears to be consistent with these calculations.
· The TRC table on page 26 appears to overestimate the number of retrofits through 2004, as does the claim on page 28.
Please provide clear calculations on how many retrofits are expected to occur at the end of the first year of the program, the end of the second year of the program, at the end of one year after the program is over, and at the end of two years after the program is over.
A response should be provided via e-mail, by noon on Tuesday, March 19, 2002. Please send your response to tdh@cpuc.ca.gov. If you wish to mail a hard copy as well, please use the address listed in the above letterhead, Attn: Tuukka Hess, Energy Division.
Thanking you in advance for your prompt response,
Energy Division Staff
CPUC
March 22, 2002
Energy Division Staff
C/o Tuukka Hess
California Public Utilities Commission
505 Van Ness Avenue
San Francisco, CA 94102-3298
RE: R. 01-02-028: Staff Request for Further Information on CBPCA Proposal
"Comprehensive While-House Residential Retrofit Program"
To the Energy Division Staff:
Thank you for your letter dated March 13. The designated recipient, Jon Kaufman, was out of the country (and still is) so the California Building Performance Contractors Association was unaware of the letter until today, when an assistant checked Jon's e-mail. I have just received this letter from her on Friday afternoon, March 22. We apologize for this communications lapse and hope that you will still find this response useful in your evaluation.
We frankly acknowledge the inconsistency of targets within the CBPCA proposal. The appropriate minimum number of retrofits to be completed was the subject of extensive debate among our participants right up until the proposal was submitted. When the final choice (2000 units) was made, we now see that not all the references in the various sections of the proposal were found and corrected. We make no excuse for this oversight. However, the correct numbers and their underlying logic are easily provided through this letter, and remain realistic and consistent.
The Statements on page 17, 26 and 28 re 1000 retrofits are in error and should have been corrected. As much as we might prefer such a conservative target as cited on page 17, 1000 is incorrect. 2000 is the correct number throughout the proposal. Achievement of only 1000 units would fail to meet your very difficult cost-effectiveness tests. We believe those tests are unduly limited and penalize a growth-oriented program such as ours, but we believe in our program and understand the need for a common basis of evaluation for all proposals.
On page 26, the reference to 4000 units within a 4-year period follows from the 1000, and is also incorrect. The correct estimate of this extended period's completions is 8000, as shown in the table on the same page. This non-linear expansion from 2000 as of yearend 2 to 8000 as of yearend 4 occurs because there is no further training-time penalty and all 50 contractors are working at an average rate of 50 or more completions per year. We actually assume that those crews will gain in efficiency and demand, resulting in a gradual increase in the number of jobs they complete each year.
Our text description of the contractor-capacity logic on page 28 was also in error since it was scaled to the superseded 1000-unit target. The correct number of students within the two cities over two years was intended to be 400 rather than the 200 cited, resulting in 100 "crews" trained over the two years. This is still a realistic expectation given the size of the targeted specialty-contractor populations in those areas. To illustrate this further, we estimated approximately ten training sessions, each divided into 1-day segments for each of four specialties. This results in an average of 10 different students per 1-day session, which we believe is a realistic level of success for our intensive contractor outreach program. These 400 individuals represent a small fraction of the specialty-contractor and key-employee populations in the two target areas. In addition, some of the 400 will be new entrants (e.g., energy raters) rather than employees of existing contractor firms.
The resulting estimates of completions lead to the following totals:
Year 1: 500 (Fresno only)
Year 2: 1750 (Fresno and San Jose)
Subsequent years: 2500-3000 per year (assuming no further training)
The two-year total is 2250, somewhat more than our target. Our intent here was to demonstrate that reasonable assumptions lead to more contractor capacity during the project term than our target, so these numbers tend to lead to a different (higher) total.
We also note that we have been highly conservative in other aspects of our estimates. For example, we assume that fully half the trainees will not pursue the new CBPCA retrofit approach. We also assume that no contractors will leverage our training by expanding their own capability beyond the personnel we actually train-which is a very conservative view. Actual levels of contractor capacity created by our program are likely to be significantly higher than these estimates, particularly if we can begin training in San Jose before the end of the first year. And finally, the estimated average of 50 jobs per crew per year may also be conservative, since in practice many retrofit projects are completed in only 1-2 days of time actually on the job. Each crew may be able to complete well over the 50 jobs estimated.
Although not mentioned in the proposal, we also considered the size of the housing stock in both target areas to be sure that our projected market penetration rate was not unrealistic. The two cities alone, without their surrounding suburbs, constitute about 500,000 homes per the latest housing census. Our 2000 completions therefore represent less than half of one percent penetration over two years-a very conservative
interpretation of the early market demand. Since most contractors (and particularly the larger ones whom we believe will champion this innovative program) actually serve a larger area, the 2000 units actually represent an even smaller market penetration.
The TRC and Participant Test calculations are correct as stated. They are based on 2000 retrofits completed within the 21-month program term. Note in the proposal's spreadsheet that we specify an estimated 1400 completions in Fresno and 600 in San Jose. This is based on the much earlier start in the Fresno area, which has the effect of allowing training of a larger number of contractors in that area and providing more time for them to complete projects.
I hope these explanations provide the information you need. We appreciate this opportunity to further clarify our proposal, and we particularly appreciate the obvious thoroughness of your consideration of this uniquely innovative proposal. If you have further questions, it may be most practical to direct them to me.
For the California Building Performance Contractors Association,
Robert L. Knight
Board Member
(President, Bevilacqua-Knight, Inc.)
510.444.8707
STATE OF CALIFORNIA GRAY DAVIS, Governor
PUBLIC UTILITIES COMMISSION
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3298
March 13, 2002
Bruce Mast Sent via email: bmast@frontierassoc.com
Frontier Associates
P.O. Box 31356
Oakland, CA 94604
This correspondence is written regarding the Frontier Associates program proposal entitled "Green Building Technical Support Services." We request the following additional information regarding your proposal:
· Detailed advisory plans. In what manner will participating cities and/or counties will be advised to adopt the ACWMA residential green building guidelines, and USGBC LEED commercial guidelines and rating system? For example, if financial incentive programs will be suggested, please outline suggested incentive structures. If other methods of adoption will be suggested, please outline suggested plans.
A response should be provided via e-mail, by noon on Tuesday, March 19, 2002. Please send your response to tdh@cpuc.ca.gov. If you wish to mail a hard copy as well, please use the address listed in the above letterhead, Attn: Tuukka Hess, Energy Division.
Thanking you in advance for your prompt response,
Energy Division Staff
CPUC
Frontier Associates
4131 Spicewood Springs Road, Bldg. O, #3
Austin, TX 78704
May 17, 2002
Tuukka Hess
Energy Division, Public Utility Commission
505 Van Ness Avenue
San Francisco, CA 94102-3298
Dear Mr. Hess:
On behalf of Frontier Associates and our project partner, Austin Energy, I appreciate the opportunity to provide additional clarification on our Proposal for Green Building Technical Support Services, submitted to the PUC in response to R.01-08-028. I also apologize for the confusion in not recognizing your communication as being specifically directed to me.
In your letter of March 14, you asked for additional information about the manner in which participating cities and/or counties will be advised to adopt the ACWMA and USGBC guidelines. The specific answer to this question will vary on a case-by-case basis but we can sketch out some guiding principles.
The most important principle is that the adoption strategy must be politically viable. Thus it must be consistent with the mandate the governing body has given its staff to develop such a program. If staff is developing a Green Building proposal to present to the governing body for approval, the plan must address specific issues and concerns council members or supervisors might have. The adoption strategy must take into account the relationships between the governing agency, the construction and real estate industries, the broader business community, the voters, community groups, and other stakeholders. As these examples illustrate, we will need to explore the political context within each agency considering adoption in order to craft an adoption strategy that acknowledges any constraints and capitalizes on any opportunities. In some cases, we may be able to modify that context via education and persuasion but we can never ignore it.
A second key principle is that the adoption strategy must represent sound public policy. We consider sound public policies to be those that are cost effective, broadly speaking. We recognize that the benefits of green building are often more difficult to quantify than the costs. Nevertheless, a dispassionate assessment of a sound policy should lead to the conclusion that the likely benefits well outweigh the expected costs, at least from a societal perspective.
A third key principle is that the adoption strategy must be financially and institutionally viable; that is, it must be sustainable. We recognize that a primary barrier limiting local governments' ability to develop green building programs is a lack of technical and human resources. Our proposal is tailored to overcome that barrier. Still our involvement is designed to be of limited duration. The Frontier Team will help develop an adoption strategy but then we will exit the scene. At that point, the agency must be capable of carrying it out over the long term. Thus, the strategy must fit within the agency's financial resources and the policy priorities it has set for those resources. In-house responsibilities must fit within the agency's available staffing.
A corollary to the first two principles is that, all else being equal, the adoption strategy should be generally consistent with the green building adoption strategies in neighboring jurisdictions. This is not to suggest that sensible strategies should be watered down or discarded in mere deference to the neighbors; nor that there is no room for creativity in designing good strategies. We simply mean that uniform program guidelines across jurisdictional boundaries facilitate compliance, thus reducing compliance costs (and improving cost effectiveness) and improving political viability. In designing an adoption strategy, the value of uniformity should be considered.
It is our intention to promote the Alameda County Residential Green Building Guidelines for residential construction in the area due to the fact that Alameda County's guidelines were written by a local development committee made up of government officials, respected leaders in the local building industry who work throughout the San Francisco Bay area, and are known U.S. experts in the field of green building. Their guidelines are of high quality, are appropriate for the local climate, are appropriate for the local building industry, and are already showing signs of strong acceptance by the local building industry and the local marketplace. This does not exclude the option of a local government agency from using their own guidelines, but the Alameda guidelines do create a very appropriate template for the region.
It is our intention to promote the use of the US Green Building Council's Leadership in Energy and Environmental Design (LEED) Commercial Green Building Rating System for use in designing, building, maintaining, and evaluating municipal and institutional buildings. Although this does not preclude the use of another system by a government agency, we have chosen this system because it has become the standard rating system throughout the country for evaluating commercial green buildings. It is an organized, thoughtful and doable system. Government agencies have consistently and dominantly chosen this system over any other system as their primary evaluation and specification tool. LEED has also been heavily funded and supported by the US Department of Energy and Environmental Protection Agency. Among others, it is being used by the US Dept. of State, US Forest Service, US National Parks Service, US Department of Commerce, US Department of the Navy/Air Force/Marines, and the Cities of New York, Austin, Portland, and Seattle.
Given these considerations, we see our role as helping agency staff assess the trade-offs of a variety of possible adoption strategies and then design and implement a plan that fits their needs. Adoption strategies could include any of the following:
_ Direct financial incentives for green building projects
_ Incorporation of green building incentives or requirements in the planning code
_ Project-specific design assistance
_ Marketing support
_ Education and training for members of the construction, real estate, and financing industries and then general public
_ Resource guides and referrals
_ Building commissioning
_ Demonstration projects
_ Builder and/or building certification
This list is by no means exhaustive. As I have hopefully made clear, we will not advocate for a specific adoption strategy. Rather we will act as facilitators, providing technical support and information to help policy makers choose strategies that fit their needs and circumstances.
Thank you again for this opportunity to respond to your questions. I would welcome any other inquiries you might have.
Sincerely,
Bruce Mast
Manager, California Operations
STATE OF CALIFORNIA GRAY DAVIS, Governor
PUBLIC UTILITIES COMMISSION
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3298
March 13, 2002
