II. Proposals and Comments Received

A. Proposals

The Commission received a wide range of program proposals and recommendations from 24 different parties, including the investor-owned utilities, manufacturers, vendors, energy service companies (ESCOs), consultants, municipal corporations, government entities, research and advocacy groups, and electric end users, proposing over 50 different programs. The proposals seek a total funding of over $500 million and project demand reduction impacts of approximately 1,800 MW (assuming unlimited funding). Other interested parties, while not proposing specific projects, provided comments on suggested principles and criteria to govern program selection. Table 1 below summarizes the proposals received for the Summer Initiative.

Table 1. Summer Initiative Proposals Received

Proposed by:	Program Activity Description:
Investor-Owned Utilities
Pacific Gas & Electric (PG&E)	Large SPC peak kW reduction program Small SPC peak kW reduction program Express Efficiency peak program LED traffic lights Express Efficiency packaged AC program Voluntary load curtailment Savings by Design premium incentives Residential pool pump efficiency Refrigerator recycling Cross-cutting solicitation for peak demand
Southern California Edison (SCE)	Enhanced Express Efficiency SPC peak demand reduction Residential refrigerator recycling Savings by Design premium incentives Cooperative demand response initiative AC cycling load control (advice letter 1464-E) Pool pump tripper (advice letter 1463-E)
San Diego Gas & Electric (SDG&E)	Program enhancements Residential hard to reach outreach Residential increased promotion Whole house fans Mail-in audits Pool pump efficiency Nonresidential HVAC incentives Nonresidential increased promotion New initiatives Residential refrigerator recycling Residential hard to reach appliances Halogen torchiere turn-in events LED traffic lights Nonresidential high efficiency lighting Multifamily tenant improvements Savings by Design premium incentives
Southern California Gas Company (SoCalGas)	Gas comfort cooling Gas refrigeration Gas air compression Gas municipal water pumping Gas agricultural water pumping Distributed generation
Manufacturers and Corporations
Silicon Energy and Andersen Consulting	Statewide load management infrastructure
Silicon Energy and Carrier Corporation	Direct residential HVAC load control
Cannon Technologies, Inc.	Direct load control (filed after deadline)
Ecos Consulting	Halogen torchiere replacement program
Appliance Recycling Centers of America (ARCA)	Residential refrigerator recycling program
Res-Team (residential ESCOs and ESPs)	Hard to reach residential program
NAESCO	Comments on principles for summer initiative
Distributed Power Coalition of America (DPRA)	Letter of support

California Cities
City of Concord	City facility daytime peak reduction
City of Oakland	Various city demand and energy reductions
City of Santa Monica	PowerLight Corporation proposals for PVs
Government/Research/Advocacy
California Energy Commission (CEC)	Price responsive HVAC Large commercial AC tune-up Home AC tune-up Enhanced residential peak shed Statewide pool pump tripping Statewide new home quality assurance Statewide Energy Star Homes Statewide nonresidential building Commissioning Statewide cool communities/white roofs Statewide LED traffic lights Water/wastewater pump retrofits
Electric Power Research Institute (EPRI)	Demand responsiveness pilot and research Study
Global Green USA	Peak load public outreach campaign
Office of Ratepayer Advocates (ORA)	Various modifications to utility programs
Electric End Users and Their Organizations
California Oil Producers Electric Cooperative (COPE)	Fluid pumping efficiency program Waste gas to electric generation
Humboldt Creamery Association	Demand reduction measures
Nurseryman's Power Cooperative	On-site cogeneration
Presidio Trust	Energy efficiency building retrofits
University of California and Cal State	Campus energy efficiency retrofits

B. Comments

Comments on the proposals were received from various interested parties, including Appliance Recycling Centers of America (ARCA), City of San Jose, Electric Power Research Institute (EPRI), Latino Issues Forum/Greenlining Institute (LIF/Greenlining), National Association of Energy Service Companies (NAESCO), Natural Resources Defense Council (NRDC), Office of Ratepayer Advocates (ORA), Pacific Gas & Electric Company (PG&E), Plurimi, Inc., Res-Team, Sierra Club, Silicon Energy, San Diego Gas & Electric Company (SDG&E), Southern California Gas Company (SoCalGas), Southern California Edison Company (Edison), The Utility Reform Network (TURN), University of California and Cal State, and Utility Savings and Refund (which submitted the Nurseryman's Power Cooperative proposal).

Several groups, including LIF/Greenlining and the Res-Team stress the importance of considering equity issues when evaluating the various submitted programs, contending that all ratepayers, including smaller consumers, should derive benefit from Summer Initiative funds. The NRDC, the Sierra Club, and TURN suggest criteria for program evaluation and selection. The Sierra Club and NRDC also oppose use of Summer Initiative funds for supply side and load management proposals, while TURN and the Res-Team oppose use of these funds for proposals that target load shifting, all contending that such use would be inappropriate and contrary to Pub. Util. Code § 381.

The utilities generally reiterate their original positions and advocate that other programs to be operated in parallel to existing utility programs. Other groups support some of the utility programs, such as NAESCO, which supports the utilities' Standard Performance Contract (SPC) mechanisms. The Res-Team and Utility Savings and Refund Services object to reapplying for funding through utility programs or recommend against utility administered programs. The other parties also primarily restate their original proposals, sometimes providing additional support or requesting more funds.

C. A Hearing is Not Necessary

Several parties strongly opined that a hearing on these proposals was not necessary. Only one participating party, Plurimi, Inc., specifically requested hearings. Plurimi, Inc., an internet start-up company that offers internet-based load curtailment products, did not submit a proposal for funding under the Summer Initiative, but filed reply comments apparently upon learning that proposals had been submitted by one of its competitors. Plurimi's concern is that there be a bidding process that will allow all interested emerging technology companies to compete for funding instead of granting one company a lock on a statewide load curtailment system.

Upon reviewing the proposals submitted and considering the parties' arguments, we find that a hearing is not necessary and would only further delay our ability to expeditiously effect energy savings for this summer and the summer of 2001. We are sympathetic to Plurimi's concerns and note that we have not selected any internet-based load curtailment products or services for funding under the Summer Initiative, partially for these reasons. These proposals, as others, may be considered further in the future.

Without exception, the proposals submitted represent activities that will benefit California electric consumers. We commend all parties who came forward with ideas and hope that, whether or not their proposals are selected for funding as part of the Summer Initiative, they will continue to work with us, the utility administrators, and the consumers to move toward even better demand-side energy efficiency options in California in the future.