7. Assignment of Proceeding

Commissioner Dian M. Grueneich is the assigned Commissioner and David M. Gamson is the assigned ALJ in this proceeding.

Findings of Fact

1. The draft California Long-Term Energy Efficiency Strategic Plan built upon the foundation of A.08-06-004 (the joint Utility-submitted California Energy Efficiency Strategic Plan) and the hundreds of individuals and organizations who participated in workshops leading to the joint Utility application.

2. The final California Long-Term Energy Efficiency Strategic Plan (Plan) is intended to engage actions to use energy more efficiently by leaders and stakeholders both within the Commission's regulatory jurisdiction and beyond, recognizing that the various actors must work collaboratively over the long-term to leverage all of the available resources to change the way Californians use energy at home and at work.

3. The Plan includes a number of strategies which can be implemented starting in the 2009-2011 timeframe.

4. The Plan will need to be updated over time to take into account technological and market developments and the evaluation of programs already implemented.

5. California would benefit from establishment of a broadly based neutral and independent organization to help guide energy efficiency policy recommendations and market transformation activities across the state.

6. Due to time constraints the cost-effectiveness of the Plan or the metrics of measuring the achievement of market transformation have not been addressed.

Conclusions of Law

1. The California Long-Term Energy Efficiency Strategic Plan should be adopted.

2. The Plan should be integrated into the utilities' 2009-2011 energy efficiency program applications, as applicable.

3. The Plan should be updated before the next round of utility energy efficiency program applications, regarding 2012-2014 programs, are filed in 2011.

4. We cannot lawfully delegate our jurisdictional responsibilities to another entity.

ORDER

IT IS ORDERED that:

1. The California Long-Term Energy Efficiency Strategic Plan, Attachment A to this decision is adopted.

2. Southern California Edison Company (SCE), Southern California Gas Company (SoCalGas), San Diego Gas & Electric Company (SDG&E) and Pacific Gas and Electric Company (PG&E) shall file amendments to their 2009-2011 energy efficiency program applications (A.08-07-021, A.08-07-022, A.08-07-023, and A.08-07-031, respectively) to incorporate elements of the adopted Plan (Attachment A of this Decision), when and as directed by the assigned Commissioner and/or Administrative Law Judge in the consolidated A.08-07-021, A.08-07-022, A.08-07-023, and A.08-07-031 docket.

3. SCE, SoCalGas, SDG&E and PG&E shall assist the Energy Division and the Commission on our development of a statewide energy efficiency brand and an integrated marketing education and outreach (ME&O) strategy.

4. The Energy Division, in consultation with the assigned Commissioner and Administrative Law Judge, shall take the steps necessary to implement the Plan, including: (a) reviewing Low-Income Energy Efficiency (LIEE) programs for consistency with the goals and directives of the Plan; (b) reviewing allocation of funding for LIEE programs to ascertain consistency with the Plan; (c) development of a statewide energy efficiency brand and integrated ME&O strategy; and (d) forming the task forces and working groups identified in the adopted Plan (Attachment A of this Decision). The Executive Director shall consult with the California Energy Commission, the California Air Resources Board and other agencies to identify Plan areas for which non-CPUC agencies may take a lead role.

5. The Plan shall be updated in 2010.

6. Rulemaking 08-07-011 and Application 08-06-004 are closed.

This order is effective today.

Dated September 18, 2008, at San Francisco, California.

MICHAEL R. PEEVEY

President

DIAN M. GRUENEICH

JOHN A. BOHN

RACHELLE B. CHONG

TIMOTHY ALAN SIMON

Commissioners

Appendix 1

Summary of Comments on the draft California Long-Term
Energy Efficiency Strategic Plan

Who

All Comments

UC Davis Western Cooling Efficiency Center

1) Add as partner to all cooling strategies, also CA Lighting Technology Center and Center for Built Environment; 2) Add strategies that include partnerships with IOUs, manufacturers and customers, in ET area; 3) Recognize peak-demand reduction as first in line power source; 4) take a different approach to assessing peak power (KW) impacts that values the cost to build and maintain a peaking power plant-in E3 calculator.

CA League of Food Processors

1) work with CEC, CARB, Regional Air Districts, State Water Resources Control board and others for unified comprehensive strategy; 2) support for pilot project; 3) Supports formation of CA Industrial Energy Efficiency Alliance (IOUs, CPUC, other agencies, private industry reps). NEEA as model

National Assoc. of Energy Service Companies

RESIDENTIAL: 1) do not defer multi-family strategies, develop them now; 2) encourage ESCOs, via pilot programs, to expand scope of services; rather than try and transform existing home improvement contractors into ESCOs: ESCOs can do real marketing and take on risk, while contractors are reactive; 3) direct IOUs to do `formative' M&V work in first year of innovative and third party programs; 4) do not subject water-energy pilots to TRC until pilots reviewed and methodology added to E3; 5) more radical approaches to existing commercial sector may be needed: tiered utility rates and/or `utility provided EE, delivered by third parties or the building owner,' a condition of electric service.

Air Conditioning Contractors of America (ACCA)

A variety of detailed HVAC comments and recommendations.

CA Building Association Industry

Add back in the two top priorities of the residential sector WG: existing res market achieve 40% reduction in energy use by 2020 (Bali Treaty high goal); all new homes meet or exceed Title 24 by 2011.

Community Action Agency of San Mateo County

Detailed LIEE comments; process was too rushed.

Ice Energy

1) Prioritize acceleration and adoption of peak-reducing EE technologies; 2) Supports TDV and TACM strategies, but notes that peak time of use rates moving in wrong direction. Changing this would have large impact on SP goals; 3) Permanent Load Shifting (PLS) should be recognized as DSM activity.

Local Gov. Sustainability Coalition

1) Coordinate with ARB, regional air resources and water quality boards; 2) engage LGs in discussion with other state agencies about best way to leverage LGs towards state energy/environment goals, outside of SF/Sacto and driven by regional/ LGs; 3) continue meetings around state and schedule periodic update meetings.

City of San Diego

1) endorsed CEESP goals; 2) create CEEA that also tackles integration/coordination issues; 3) reject IOU policy proposal to allow IOU credit for actions motivated by local ordinances; 4) include consideration of comprehensive statewide rate and price design issues; 5) CPUC leadership; 6) provide LGP budget info in 2009-2011 proceeding.

CC San Francisco

1) CPUC retain leadership, work cooperatively with POUs, emphasize IOU LGPs, both key to SP LG goals; 2) create a NEEA-like CA Sustainable Energy Alliance; adopt standard MT definition, utilizing stakeholder input; 3) CPUC should coordinate IDSM programs, not IOUs; 4) Develop schedule and outreach program for addition of stakeholders; evaluation of pilot and other relevant programs; party opportunities for comment on results of findings. A variety of detailed comments on the plan, including DSM .

TURN

1) Add chapter to Plan focusing on role of customer `pull' incentives and non-C&S market push strategies for all EE equipment and appliances (consumers, manufacturers, retailers). On phasing out CFLs, CA and CPUC should ensure that big box retailers will continue discounted CFLs as IOUs phase out buy-downs. CA should also negotiate next phase - LEDs -- with manufacturers and retailers. Learn from SERB refrigerator program, that was a huge success as `market push' strategy. 2) says $2.7 billion in net resource benefits claims of 06-08 EE programs is inaccurate, based on outdated net benefit methodologies; 3) objects to phrase `rigorous' c-e analysis (p. 6), suggests adding that EE activities in Plan for IOUs will be funded by ratepayers, as part of c-e portfolios. 4) res lighting programs are not `models,' and suggests other wording. E.g., IOUs did not use influence to require mercury min. content requirements on CFL manufacturers, whereas big box stores did; also, CA CFL programs are more costly than upstream programs elsewhere in U.S.

Community Environmental Council

1) Modify ZNE definition for med-high rise commercial buildings as achieving this with current definition is impossible; new definition should allow for offsite RE and/or other zero low carbon energy sources. See LNBL report for info (provides cite); 2) Add a section on MT, with CPUC to take active role in regulating MT and establishing a CEEA or "CIEO"; 3) strengthen LG section to make goals more explicit and remove redundancies; 4) modify Res ZNE goal to focus not on ZNE standards by 2020, but all new Res starts as ZNE by 2020, the CPUC's original goal; the same applies to Comm. ZNE goal; 5) remove `aspirational' modifier from Comm. ZNE goal; 6) Add quantitative targets for HVAC BBEES vision: (50% improvement in EE in HVAC sector for all new installations by 2020 and 75% by 2030); take REGIONAL approach to HVAC issue; 7) IDSM should be called "one stop shop" and focus on consumer, not IOUs; IOU IDSM pilots should run 2009 and become `real' in 2010; IDSM programs and pilots should be run by non-IOU entities, including POUs; 8) cite new green building standard as example of `beyond code,' and indicate CPUC support for LG's that adopt beyond T-24 codes; 9) apply `one-stop shop' term to whole house approaches- consumers understand it -- and accelerate pilot to `real' program timeline; 10) LG chapter should add quantitative and bold goals into vision statement for LGs (suggests restating existing `goal results' as vision/goals); also, encourage LGs to adopt Architecture 2030 challenge; 11) MT emphasis- modify definitions in Plan, and add MT as major theme to R&T chapter, identifying linkages over time; 12) 2 year update process; 13) improve use of c-e and potential studies in planning; 14) include transport (PHEVs, nat gas vehicles); 15) enforcement- urge CEC to take up its statutorily-granted duty of taking over local building depts. If enforcement doesn't meet legislative mandates.

DRA

1) Articulate process and timetable to set MT criteria; 2) consider lifecycle carbon footprints; water-energy and transportation issues should be included, mention Smart Grid; 3) establish task forces and sub-committees; 4) ensure state ownership of EE brand to avoid over-proliferation of rating systems; 5) manage LG partnerships at level done with state agencies, in coordination with CEC, coordinated by statewide MT agency serving interests of state; 6) whole house seal/brand cannot be managed by IOUs; 7) proper CFL disposal should be added to Plan, and statewide approach on LEDs; 8) Plug load focus good and should consider `golden carrot' program to incent manufacturers. Should be led by statewide MT entity, coordinated in short term by CPUC with subcommittee on plug loads; 9) LIEE-many detailed comments provided; COMM: 10) develop GBI strategy in SP, with LA county as model (cite not included); benchmark labeling should link with branding efforts; 11) IND- emphasize benefits of `green'; 12) C&S- does not support lead IOU role in C&S; should be led by CEC and local govts; 13) DSM- conservation should be in Plan; new OIR needed, c-e work needed; AMI is fulcrum; detailed suggestions on IDSM chapter; 14) WE&T - long term, statewide MT entity should oversee; assessment should be run by Commission, guided by stakeholder task force; 15) ME&O- fast track state-managed brand, extremely important; segmentation, technology solutions, integration of messaging, coordination with WE&T; 16) R&T- add milestones for who will lead statewide R&T effort, and who will manage RD&D projects, and provide direction to ET program - emphasis must be on MT and resource acquisition (not feeding technologies into EE programs).

2030 Inc. Architecture 2030

1) Residential Sector interim goals: 100% of new homes and major renovations to surpass 2005 Title 24 standards by 20% by 2011, 35% 2015 and 55% by 2020. Additional details on res. Stretch goals provided.
2) Commercial sector interim goals: 5% net zero starting in 2009; renovation goals also provided.
3) Review existing homes goals.
4) 2030 challenge clarification.

NRDC

1) Add reference to `loading order' in Intro; 1b) Supports plan to identify MT goals and metrics and recommends CPUC lead stakeholder process on this; 2) supports addressing multi-family in next phase; 3) strongly supports plug loads emphasis and suggests harmonizing approaches on this across sectors; make C&S language consistent across R, C, & C&S chapters; 4) supports existing comm. Building 50% ZNE stretch goal and suggests that criteria for building retrofits be strengthened to use best available EE and RE technologies, CPUC working with CEC and stakeholders on this; 5) operational AND asset value ratings are needed, e.g., role of asset value ratings like Home Energy Rating System should be expanded in C&R real estate market; 6) CPUC should establish a timeline for review and adjustment of plan strategies as needed, identify key procedures for stakeholder participation and increased outreach, hold sector workshops to determine who will lead needed task forces and strategies, and establish metrics to determine the success and timeliness of strategies. 7) Several additional technical/word-smithing comments (water heating, vol. EE graphic, LIEE strategies.

CA Center for Sustainable Energy

1) Multi-party approach must be put into practice within portfolios and plans- can third parties including NGOs monitor and advise on programs as they progress?, are EM&V in-progress learnings affecting active programs? Hold meetings throughout CA; 2) Plan should state how IOU LTPP can reflect Plan goals and strategies. A more integrated, multi-party approach to EE is needed in IOUs LTPPs, and explicit demonstration of EE at top of loading order. Require EE before CSI; permit NGOs to access EE education funds; 3) set aside funds for NGO education-only programs that are precursors to MT, ensure integrated one-stop website; 4) C&S should ensure some level of uniformity between themselves and NGO/EPA energy star certification programs, POS and energy tips to renters when move in are good;

Women's Energy Matters

1) Develop process to focus on peak demand reductions from IDSM/EE; require IOUs to reveal locations of EE reductions; 2) Investigate how EE can participate in Forward Capacity Market, as is done in New England, and qualify as peak resources. Work with Cal-ISO on this. 3) Supports one year bridge funding.

CA Municipal Utilities Association

PROCESS: 1) slow process down; 2) some goals not appropriate for all entities or areas; don't apply work product to entities outside CPUC jurisdiction; CPUC should support immediate est. of NEEA type entity (neutral, independent), (RETI allowed better participation); ensure proper pacing and structure during implementation to allow smaller entity participation.
GOALS: 1) apply cost-benefit analysis; 2) identify stretch goals; 3) water-energy nexus issue suitable for independent body; 4) caution on dispersal of grid reliability costs of self gen to all grid users; must be done by ratemaking authority for relevant utility; 5) MUNIs lack jurisdiction to advance local codes; another reason an independent body is needed.

Joint Committee on Energy and Environmental Policy (JCEEP)

1) Ensure simple and transparent means of inclusion in discussions; 2) Emphasize HVAC in existing buildings via improved incentive programs; 3) remove 20 ton limitation on HVAC issues; 4) provides guidelines for WE&T jumpstarting HVAC education; 5) mention labor management training entities in WE&T chapter.
JCEEP = Sheet Metal and Air Conditioning National Contractors Association (SMACNA) and Ca Local Unions of Sheet Metal Workers International Association (SMWIA)

IOUs

Plan:

1) Existing Comm. building ZNE goal is unrealistic, wasn't fully vetted, and would overwhelm all other BBEES

2) Plan should expand discussion of importance of other players and potential roles

3) DSM coordination needs to be re-added, and foundational IDSM issues (metrics, avoiding LOs) must be resolved

4) Emphasize Smart Grid and AMI, including refer to ongoing RD&D, such as the CEC's "defining the pathway to the CA Smart Grid of 2020" project

5) Provide direction to creating full partnerships with technology stakeholders

6) C&S- indicate that compliance is state agency responsibility, not IOUs; emphasize CA work to strengthen federal appliance and equipment standards; underscore links with ET, essential for MT

7) Add LG roles back in

8) ME&O - distinguish between general messaging (brand) and program marketing, and provide for regional & consumer differences

9) Policy requirements should be included: a) explicit regulatory coordination strategy is needed, with goals and timetables; b) costs/benefits of MT should be in c-e calculations, but not RRIM, but Plan should acknowledge that a fair RRIM is needed (as in EAP); c) should include process and explicit goals to support MT, including metrics to set goals and measure progress, c-e methods to value timing and benefits, and comprehensive policy statements

OIR:

10) Adopt all CEESP strategies, what is needed is details on managing process, cost-benefit review to screen and rank strategies, and determination of priority level for LIEE

11) ZNE- a public-private partnership and targeted support is needed. LG & CEC must expedite project approval and code enforcement, financial resources needed, and enabling policies as suggested by financial sector

12) Detailed implementation plans needed

13) CPUC as moderator and motivator, should ensure reg. agency coordination

14) Consider MT definitions with stakeholders on ongoing basis, on market by market basis

15) IDSM - CPUC should address foundational issues and support technical process to address metrics/methods

16) Add a needed LIEE strategy-- to integrate LIEE with EE programs

17) Updating requiring data collection, analysis, substantive workshops, mapping realistic paths for individual strategies, collaboration. IOUs to file SP proposal by June 2010, vetted and then adopted by CPUC

CEESP:

18) don't delay programs one year

19) Financing needs more emphasis

20) Enforcement is key, will support this, as well as C&S analysis

21) Support more c-e analysis

(END OF APPENDIX 1)

Appendix 2

Summary of Reply Comments on the draft California Long-Term Energy Efficiency Strategic Plan

Who

Comment

CA Center for Sustainable Energy

1) Need paradigm shift toward broad-based stakeholder planning model, "CA Sustainable Energy Alliance" (CEC, CARB, IOUs, POUs, EM&V experts, local govt.).

2) Explicit MT goals, c-e methods, policy statement needed.

3) ME&O branding importance- define deliverables within each program, must do much better incorporating LIEE.

4) Simply code branding to `gold, silver, bronze' system, including for government (state) codes, and not just for homes.
5) Rate structure inconsistency impedes EE advance.

Local Govt Sustainable Energy Coalition

1) Different Admin. Approach is Needed for Energy /Climate Change goals (NEEA is good model).

2) In interim, CPUC should facilitate regional sustainability offices with mission to develop and deliver EE programs, starting with existing regional LGPs or CCSE. Must be independent and address broader AB32 issues (i.e., beyond IOUs).

3) Need process more accessible to small entities, need to work with sister agencies to make neutral clearinghouse-- regional sustainability offices would help, need education on state energy/environment goals.

4) Funding beyond PGC needed.
5) Evaluate rate design, as is currently deterrent.

NAESCO

1) Supports CLFP suggestion of identification of need for a CA Industrial Energy Alliance in the Plan, composed of CPUC, IOU, other agencies, other stakeholders. NAESCO would actively participate.

2) Supports DRA, TURN comments on need to move to whole house approaches. But, current TRC incentive structure impedes this, and lack of multi-family focus in Plan is a problem.
3) IOUs need clear CPUC signal to get IOU movement on this. Suggests a CPUC `kicker' incentive for savings produced by comprehensive residential programs, calculated to make IOUs indifferent to inherently lower TRC scores of res programs, and thus encourage more third parties to develop innovative programs.

WISH

1) need to do better including LIEE perspectives

2) cost-effectiveness is unclear and needs to be remedied; EE is societally c-e, and there are many non-energy benefits around quality of life (such as equity, energy affordability, bill savings, safety, comfort). These must really be mentioned in Plan

3) CLFs should not supplant enduring measures (i.e., not just CFLs, and must do CFL disposal education)

4) Workforce Training in Low Income Communities is Vital

5) Plan must include multi-family focus, and LIEE reps must be part of this

6) Supports DRA `whole house' emphasis, including solar, water, transport, for LIEE folks

7) CPUC must ensure IOU LIEE segmented approach doesn't hurt whole house goals of Plan
8) The rush for a Plan may have hurt LIEE interests

DRA

1) Policy issues should be assigned to a separate section of the SP only the extent they address needs of statewide coordination; IOU policy proposals properly discussed in 2009-11 portfolio context, not in SP.

2) SP process must always be led by entity representing state of California

3) DSM integration should be expansive in scope and result in cost savings. Scope should include option of organizational changes within the IOUs, CPUC or other agencies, new relationships, integration of DSM programs and proceedings and integration of state and federal policies

4) AMI and Smart Grid should get greater attention in Plan, but role not overstated. Disagree with IOUs that these are `necessary to attain the levels of EE in the Plan' AMI key DSM issue, not driver of SP. Plan should still reference Smart Grid OIR and potential with DR
5) Ratepayers only one funding source for Plan

NRDC

1) Strongly supports POS for residential sector in Plan, should be expanded to other sectors; SP should also include strategies to capture savings at "Time of service change' for all appropriate sectors

2) Need for outreach to involve additional stakeholders in implementation

3) Supports `one-stop-shop' approach for all sectors in Plan (info, rebates, lists of auditors & retrofit contractors, linked to statewide M&O)

4) Supports updating TAC and TDV to improve assessment of avoided cost of HVAC tech & compliance (i.e., agrees with Ice Energy)

5) Keep on schedule to avoid 09-11 delays

6) Acknowledge IOU policy issues in Plan, address at CPUC

7) Strongly supports code compliance, CEC-LG collaboration; IOUs role developing C&S is good, should continue. Plan should include non-CPUC actors list for C&S and other places where currently lacking.

8) ZNE goals are good; modify definitions to make attainable (i.e., supports CEC opening comments). Don't require ZNE through codes.

9) Plan should include strategy to start a comprehensive review of CA lighting market, including CFL saturation levels in sockets. Supports IOU programs to `pull' lighting, including reducing IOU incentives for standard CFLs, and, rather, incentivizing improved CFLs (dimmable, low mercury, better specs, etc). IOUs should have flexibility to run `golden carrot' programs as TURN suggests, and tiered rebates, improved ET, including `PEARL'; C&S chapter should include review of current lighting options in Title 24. Don't rely on state/fed. regulations
10) CPUC MT effort should collaborate with many Parties. Supports CEC suggestion to delete sentence in Plan stating that AB1109 ensures MT of lighting in CA; CPUC needs to develop MT rules/guidelines actually.

TURN

1) MT- agrees with Party recommendations, and reiterates need for CEEA.
2) Appended paper on `Regional EE Market Transformation in the U.S.'

Joint IOUs

1) Support CEEA as a forum for collaboration and coordination (with other program administrators, other national, regional and non-CA state bodies, overseeing some of the task forces identified in the Plan where program administrators have lead role, soliciting stakeholder input on MT Programs), not as an entity to take over EE program implementation, as suggested by SD

2) ZNE goals/definitions need to be addressed, but should not be `locked in' in current Plan. This includes the ambitious 50% existing commercial buildings by 2030 goal, or any unachievable pre-2030 intermediate goals for ZNE new construction or existing buildings. Development/resolution of these issues should be priority for next round of work.

3) Policy issues must be addressed by CPUC: Top priorities: a) timing/cost of benefits of long-term MT, and b) attribution issues. Another ten policy issues raised in IOU Plan (June 2). CPUC should focus on policy issues raised in 09-11 portfolios.

4) Plan should recognize critical roles of others without waiting to act. Final Plan should add emphasis, clarity and direction on importance of others' roles.

5) Do not delay 2009-11 program start. Several arguments provided.

6) IOUs should continue to contribute on C&S. Strongly support C&S enforcement emphasis and a collaborative approach with CEC, LGs to work on this.

7) Agree on importance of TOU & rate design issues, but this proceeding is inappropriate place to address these.

8) LIEE program design issues should be addressed in LIEE proceeding. LIEE outreach issues to improve LIEE folks participation in SP process should be addressed in next round of SP planning

9) Opposes JCEEP `requirements' on WE&T, as would preclude most parties from delivering HVAC training, for instance, and would disallow existing IOU training center programs.

(END OF APPENDIX 2)

D0809040 Attachment A

Who	All Comments
UC Davis Western Cooling Efficiency Center	1) Add as partner to all cooling strategies, also CA Lighting Technology Center and Center for Built Environment; 2) Add strategies that include partnerships with IOUs, manufacturers and customers, in ET area; 3) Recognize peak-demand reduction as first in line power source; 4) take a different approach to assessing peak power (KW) impacts that values the cost to build and maintain a peaking power plant-in E3 calculator.
CA League of Food Processors	1) work with CEC, CARB, Regional Air Districts, State Water Resources Control board and others for unified comprehensive strategy; 2) support for pilot project; 3) Supports formation of CA Industrial Energy Efficiency Alliance (IOUs, CPUC, other agencies, private industry reps). NEEA as model
National Assoc. of Energy Service Companies	RESIDENTIAL: 1) do not defer multi-family strategies, develop them now; 2) encourage ESCOs, via pilot programs, to expand scope of services; rather than try and transform existing home improvement contractors into ESCOs: ESCOs can do real marketing and take on risk, while contractors are reactive; 3) direct IOUs to do `formative' M&V work in first year of innovative and third party programs; 4) do not subject water-energy pilots to TRC until pilots reviewed and methodology added to E3; 5) more radical approaches to existing commercial sector may be needed: tiered utility rates and/or `utility provided EE, delivered by third parties or the building owner,' a condition of electric service.
Air Conditioning Contractors of America (ACCA)	A variety of detailed HVAC comments and recommendations.
CA Building Association Industry	Add back in the two top priorities of the residential sector WG: existing res market achieve 40% reduction in energy use by 2020 (Bali Treaty high goal); all new homes meet or exceed Title 24 by 2011.
Community Action Agency of San Mateo County	Detailed LIEE comments; process was too rushed.
Ice Energy	1) Prioritize acceleration and adoption of peak-reducing EE technologies; 2) Supports TDV and TACM strategies, but notes that peak time of use rates moving in wrong direction. Changing this would have large impact on SP goals; 3) Permanent Load Shifting (PLS) should be recognized as DSM activity.
Local Gov. Sustainability Coalition	1) Coordinate with ARB, regional air resources and water quality boards; 2) engage LGs in discussion with other state agencies about best way to leverage LGs towards state energy/environment goals, outside of SF/Sacto and driven by regional/ LGs; 3) continue meetings around state and schedule periodic update meetings.
City of San Diego	1) endorsed CEESP goals; 2) create CEEA that also tackles integration/coordination issues; 3) reject IOU policy proposal to allow IOU credit for actions motivated by local ordinances; 4) include consideration of comprehensive statewide rate and price design issues; 5) CPUC leadership; 6) provide LGP budget info in 2009-2011 proceeding.
CC San Francisco	1) CPUC retain leadership, work cooperatively with POUs, emphasize IOU LGPs, both key to SP LG goals; 2) create a NEEA-like CA Sustainable Energy Alliance; adopt standard MT definition, utilizing stakeholder input; 3) CPUC should coordinate IDSM programs, not IOUs; 4) Develop schedule and outreach program for addition of stakeholders; evaluation of pilot and other relevant programs; party opportunities for comment on results of findings. A variety of detailed comments on the plan, including DSM .
TURN	1) Add chapter to Plan focusing on role of customer `pull' incentives and non-C&S market push strategies for all EE equipment and appliances (consumers, manufacturers, retailers). On phasing out CFLs, CA and CPUC should ensure that big box retailers will continue discounted CFLs as IOUs phase out buy-downs. CA should also negotiate next phase - LEDs -- with manufacturers and retailers. Learn from SERB refrigerator program, that was a huge success as `market push' strategy. 2) says $2.7 billion in net resource benefits claims of 06-08 EE programs is inaccurate, based on outdated net benefit methodologies; 3) objects to phrase `rigorous' c-e analysis (p. 6), suggests adding that EE activities in Plan for IOUs will be funded by ratepayers, as part of c-e portfolios. 4) res lighting programs are not `models,' and suggests other wording. E.g., IOUs did not use influence to require mercury min. content requirements on CFL manufacturers, whereas big box stores did; also, CA CFL programs are more costly than upstream programs elsewhere in U.S.
Community Environmental Council	1) Modify ZNE definition for med-high rise commercial buildings as achieving this with current definition is impossible; new definition should allow for offsite RE and/or other zero low carbon energy sources. See LNBL report for info (provides cite); 2) Add a section on MT, with CPUC to take active role in regulating MT and establishing a CEEA or "CIEO"; 3) strengthen LG section to make goals more explicit and remove redundancies; 4) modify Res ZNE goal to focus not on ZNE standards by 2020, but all new Res starts as ZNE by 2020, the CPUC's original goal; the same applies to Comm. ZNE goal; 5) remove `aspirational' modifier from Comm. ZNE goal; 6) Add quantitative targets for HVAC BBEES vision: (50% improvement in EE in HVAC sector for all new installations by 2020 and 75% by 2030); take REGIONAL approach to HVAC issue; 7) IDSM should be called "one stop shop" and focus on consumer, not IOUs; IOU IDSM pilots should run 2009 and become `real' in 2010; IDSM programs and pilots should be run by non-IOU entities, including POUs; 8) cite new green building standard as example of `beyond code,' and indicate CPUC support for LG's that adopt beyond T-24 codes; 9) apply `one-stop shop' term to whole house approaches- consumers understand it -- and accelerate pilot to `real' program timeline; 10) LG chapter should add quantitative and bold goals into vision statement for LGs (suggests restating existing `goal results' as vision/goals); also, encourage LGs to adopt Architecture 2030 challenge; 11) MT emphasis- modify definitions in Plan, and add MT as major theme to R&T chapter, identifying linkages over time; 12) 2 year update process; 13) improve use of c-e and potential studies in planning; 14) include transport (PHEVs, nat gas vehicles); 15) enforcement- urge CEC to take up its statutorily-granted duty of taking over local building depts. If enforcement doesn't meet legislative mandates.
DRA	1) Articulate process and timetable to set MT criteria; 2) consider lifecycle carbon footprints; water-energy and transportation issues should be included, mention Smart Grid; 3) establish task forces and sub-committees; 4) ensure state ownership of EE brand to avoid over-proliferation of rating systems; 5) manage LG partnerships at level done with state agencies, in coordination with CEC, coordinated by statewide MT agency serving interests of state; 6) whole house seal/brand cannot be managed by IOUs; 7) proper CFL disposal should be added to Plan, and statewide approach on LEDs; 8) Plug load focus good and should consider `golden carrot' program to incent manufacturers. Should be led by statewide MT entity, coordinated in short term by CPUC with subcommittee on plug loads; 9) LIEE-many detailed comments provided; COMM: 10) develop GBI strategy in SP, with LA county as model (cite not included); benchmark labeling should link with branding efforts; 11) IND- emphasize benefits of `green'; 12) C&S- does not support lead IOU role in C&S; should be led by CEC and local govts; 13) DSM- conservation should be in Plan; new OIR needed, c-e work needed; AMI is fulcrum; detailed suggestions on IDSM chapter; 14) WE&T - long term, statewide MT entity should oversee; assessment should be run by Commission, guided by stakeholder task force; 15) ME&O- fast track state-managed brand, extremely important; segmentation, technology solutions, integration of messaging, coordination with WE&T; 16) R&T- add milestones for who will lead statewide R&T effort, and who will manage RD&D projects, and provide direction to ET program - emphasis must be on MT and resource acquisition (not feeding technologies into EE programs).
2030 Inc. Architecture 2030	1) Residential Sector interim goals: 100% of new homes and major renovations to surpass 2005 Title 24 standards by 20% by 2011, 35% 2015 and 55% by 2020. Additional details on res. Stretch goals provided. 2) Commercial sector interim goals: 5% net zero starting in 2009; renovation goals also provided. 3) Review existing homes goals. 4) 2030 challenge clarification.
NRDC	1) Add reference to `loading order' in Intro; 1b) Supports plan to identify MT goals and metrics and recommends CPUC lead stakeholder process on this; 2) supports addressing multi-family in next phase; 3) strongly supports plug loads emphasis and suggests harmonizing approaches on this across sectors; make C&S language consistent across R, C, & C&S chapters; 4) supports existing comm. Building 50% ZNE stretch goal and suggests that criteria for building retrofits be strengthened to use best available EE and RE technologies, CPUC working with CEC and stakeholders on this; 5) operational AND asset value ratings are needed, e.g., role of asset value ratings like Home Energy Rating System should be expanded in C&R real estate market; 6) CPUC should establish a timeline for review and adjustment of plan strategies as needed, identify key procedures for stakeholder participation and increased outreach, hold sector workshops to determine who will lead needed task forces and strategies, and establish metrics to determine the success and timeliness of strategies. 7) Several additional technical/word-smithing comments (water heating, vol. EE graphic, LIEE strategies.
CA Center for Sustainable Energy	1) Multi-party approach must be put into practice within portfolios and plans- can third parties including NGOs monitor and advise on programs as they progress?, are EM&V in-progress learnings affecting active programs? Hold meetings throughout CA; 2) Plan should state how IOU LTPP can reflect Plan goals and strategies. A more integrated, multi-party approach to EE is needed in IOUs LTPPs, and explicit demonstration of EE at top of loading order. Require EE before CSI; permit NGOs to access EE education funds; 3) set aside funds for NGO education-only programs that are precursors to MT, ensure integrated one-stop website; 4) C&S should ensure some level of uniformity between themselves and NGO/EPA energy star certification programs, POS and energy tips to renters when move in are good;
Women's Energy Matters	1) Develop process to focus on peak demand reductions from IDSM/EE; require IOUs to reveal locations of EE reductions; 2) Investigate how EE can participate in Forward Capacity Market, as is done in New England, and qualify as peak resources. Work with Cal-ISO on this. 3) Supports one year bridge funding.
CA Municipal Utilities Association	PROCESS: 1) slow process down; 2) some goals not appropriate for all entities or areas; don't apply work product to entities outside CPUC jurisdiction; CPUC should support immediate est. of NEEA type entity (neutral, independent), (RETI allowed better participation); ensure proper pacing and structure during implementation to allow smaller entity participation. GOALS: 1) apply cost-benefit analysis; 2) identify stretch goals; 3) water-energy nexus issue suitable for independent body; 4) caution on dispersal of grid reliability costs of self gen to all grid users; must be done by ratemaking authority for relevant utility; 5) MUNIs lack jurisdiction to advance local codes; another reason an independent body is needed.
Joint Committee on Energy and Environmental Policy (JCEEP)	1) Ensure simple and transparent means of inclusion in discussions; 2) Emphasize HVAC in existing buildings via improved incentive programs; 3) remove 20 ton limitation on HVAC issues; 4) provides guidelines for WE&T jumpstarting HVAC education; 5) mention labor management training entities in WE&T chapter. JCEEP = Sheet Metal and Air Conditioning National Contractors Association (SMACNA) and Ca Local Unions of Sheet Metal Workers International Association (SMWIA)
IOUs	Plan: 1) Existing Comm. building ZNE goal is unrealistic, wasn't fully vetted, and would overwhelm all other BBEES 2) Plan should expand discussion of importance of other players and potential roles 3) DSM coordination needs to be re-added, and foundational IDSM issues (metrics, avoiding LOs) must be resolved 4) Emphasize Smart Grid and AMI, including refer to ongoing RD&D, such as the CEC's "defining the pathway to the CA Smart Grid of 2020" project 5) Provide direction to creating full partnerships with technology stakeholders 6) C&S- indicate that compliance is state agency responsibility, not IOUs; emphasize CA work to strengthen federal appliance and equipment standards; underscore links with ET, essential for MT 7) Add LG roles back in 8) ME&O - distinguish between general messaging (brand) and program marketing, and provide for regional & consumer differences 9) Policy requirements should be included: a) explicit regulatory coordination strategy is needed, with goals and timetables; b) costs/benefits of MT should be in c-e calculations, but not RRIM, but Plan should acknowledge that a fair RRIM is needed (as in EAP); c) should include process and explicit goals to support MT, including metrics to set goals and measure progress, c-e methods to value timing and benefits, and comprehensive policy statements OIR: 10) Adopt all CEESP strategies, what is needed is details on managing process, cost-benefit review to screen and rank strategies, and determination of priority level for LIEE 11) ZNE- a public-private partnership and targeted support is needed. LG & CEC must expedite project approval and code enforcement, financial resources needed, and enabling policies as suggested by financial sector 12) Detailed implementation plans needed 13) CPUC as moderator and motivator, should ensure reg. agency coordination 14) Consider MT definitions with stakeholders on ongoing basis, on market by market basis 15) IDSM - CPUC should address foundational issues and support technical process to address metrics/methods 16) Add a needed LIEE strategy-- to integrate LIEE with EE programs 17) Updating requiring data collection, analysis, substantive workshops, mapping realistic paths for individual strategies, collaboration. IOUs to file SP proposal by June 2010, vetted and then adopted by CPUC CEESP: 18) don't delay programs one year 19) Financing needs more emphasis 20) Enforcement is key, will support this, as well as C&S analysis 21) Support more c-e analysis

Who	Comment
CA Center for Sustainable Energy	1) Need paradigm shift toward broad-based stakeholder planning model, "CA Sustainable Energy Alliance" (CEC, CARB, IOUs, POUs, EM&V experts, local govt.). 2) Explicit MT goals, c-e methods, policy statement needed. 3) ME&O branding importance- define deliverables within each program, must do much better incorporating LIEE. 4) Simply code branding to `gold, silver, bronze' system, including for government (state) codes, and not just for homes. 5) Rate structure inconsistency impedes EE advance.
Local Govt Sustainable Energy Coalition	1) Different Admin. Approach is Needed for Energy /Climate Change goals (NEEA is good model). 2) In interim, CPUC should facilitate regional sustainability offices with mission to develop and deliver EE programs, starting with existing regional LGPs or CCSE. Must be independent and address broader AB32 issues (i.e., beyond IOUs). 3) Need process more accessible to small entities, need to work with sister agencies to make neutral clearinghouse-- regional sustainability offices would help, need education on state energy/environment goals. 4) Funding beyond PGC needed. 5) Evaluate rate design, as is currently deterrent.
NAESCO	1) Supports CLFP suggestion of identification of need for a CA Industrial Energy Alliance in the Plan, composed of CPUC, IOU, other agencies, other stakeholders. NAESCO would actively participate. 2) Supports DRA, TURN comments on need to move to whole house approaches. But, current TRC incentive structure impedes this, and lack of multi-family focus in Plan is a problem. 3) IOUs need clear CPUC signal to get IOU movement on this. Suggests a CPUC `kicker' incentive for savings produced by comprehensive residential programs, calculated to make IOUs indifferent to inherently lower TRC scores of res programs, and thus encourage more third parties to develop innovative programs.
WISH	1) need to do better including LIEE perspectives 2) cost-effectiveness is unclear and needs to be remedied; EE is societally c-e, and there are many non-energy benefits around quality of life (such as equity, energy affordability, bill savings, safety, comfort). These must really be mentioned in Plan 3) CLFs should not supplant enduring measures (i.e., not just CFLs, and must do CFL disposal education) 4) Workforce Training in Low Income Communities is Vital 5) Plan must include multi-family focus, and LIEE reps must be part of this 6) Supports DRA `whole house' emphasis, including solar, water, transport, for LIEE folks 7) CPUC must ensure IOU LIEE segmented approach doesn't hurt whole house goals of Plan 8) The rush for a Plan may have hurt LIEE interests
DRA	1) Policy issues should be assigned to a separate section of the SP only the extent they address needs of statewide coordination; IOU policy proposals properly discussed in 2009-11 portfolio context, not in SP. 2) SP process must always be led by entity representing state of California 3) DSM integration should be expansive in scope and result in cost savings. Scope should include option of organizational changes within the IOUs, CPUC or other agencies, new relationships, integration of DSM programs and proceedings and integration of state and federal policies 4) AMI and Smart Grid should get greater attention in Plan, but role not overstated. Disagree with IOUs that these are `necessary to attain the levels of EE in the Plan' AMI key DSM issue, not driver of SP. Plan should still reference Smart Grid OIR and potential with DR 5) Ratepayers only one funding source for Plan
NRDC	1) Strongly supports POS for residential sector in Plan, should be expanded to other sectors; SP should also include strategies to capture savings at "Time of service change' for all appropriate sectors 2) Need for outreach to involve additional stakeholders in implementation 3) Supports `one-stop-shop' approach for all sectors in Plan (info, rebates, lists of auditors & retrofit contractors, linked to statewide M&O) 4) Supports updating TAC and TDV to improve assessment of avoided cost of HVAC tech & compliance (i.e., agrees with Ice Energy) 5) Keep on schedule to avoid 09-11 delays 6) Acknowledge IOU policy issues in Plan, address at CPUC 7) Strongly supports code compliance, CEC-LG collaboration; IOUs role developing C&S is good, should continue. Plan should include non-CPUC actors list for C&S and other places where currently lacking. 8) ZNE goals are good; modify definitions to make attainable (i.e., supports CEC opening comments). Don't require ZNE through codes. 9) Plan should include strategy to start a comprehensive review of CA lighting market, including CFL saturation levels in sockets. Supports IOU programs to `pull' lighting, including reducing IOU incentives for standard CFLs, and, rather, incentivizing improved CFLs (dimmable, low mercury, better specs, etc). IOUs should have flexibility to run `golden carrot' programs as TURN suggests, and tiered rebates, improved ET, including `PEARL'; C&S chapter should include review of current lighting options in Title 24. Don't rely on state/fed. regulations 10) CPUC MT effort should collaborate with many Parties. Supports CEC suggestion to delete sentence in Plan stating that AB1109 ensures MT of lighting in CA; CPUC needs to develop MT rules/guidelines actually.
TURN	1) MT- agrees with Party recommendations, and reiterates need for CEEA. 2) Appended paper on `Regional EE Market Transformation in the U.S.'
Joint IOUs	1) Support CEEA as a forum for collaboration and coordination (with other program administrators, other national, regional and non-CA state bodies, overseeing some of the task forces identified in the Plan where program administrators have lead role, soliciting stakeholder input on MT Programs), not as an entity to take over EE program implementation, as suggested by SD 2) ZNE goals/definitions need to be addressed, but should not be `locked in' in current Plan. This includes the ambitious 50% existing commercial buildings by 2030 goal, or any unachievable pre-2030 intermediate goals for ZNE new construction or existing buildings. Development/resolution of these issues should be priority for next round of work. 3) Policy issues must be addressed by CPUC: Top priorities: a) timing/cost of benefits of long-term MT, and b) attribution issues. Another ten policy issues raised in IOU Plan (June 2). CPUC should focus on policy issues raised in 09-11 portfolios. 4) Plan should recognize critical roles of others without waiting to act. Final Plan should add emphasis, clarity and direction on importance of others' roles. 5) Do not delay 2009-11 program start. Several arguments provided. 6) IOUs should continue to contribute on C&S. Strongly support C&S enforcement emphasis and a collaborative approach with CEC, LGs to work on this. 7) Agree on importance of TOU & rate design issues, but this proceeding is inappropriate place to address these. 8) LIEE program design issues should be addressed in LIEE proceeding. LIEE outreach issues to improve LIEE folks participation in SP process should be addressed in next round of SP planning 9) Opposes JCEEP `requirements' on WE&T, as would preclude most parties from delivering HVAC training, for instance, and would disallow existing IOU training center programs.