On February 17, 2023 the Bay Area Regional Energy Network ("BayREN") requested a revision of the due date for energy efficiency ("EE") program administrators ("PAs") to file their Joint Cooperation Memoranda ("JCMs") for programs operating in 2024 from June 15, 2023 to 90 days after the adoption of the final Decision adopting 2024 and beyond EE portfolios in Applications ("A.") 22-02-005, et al. Decision ("D.") 18-05-041 requires the filing of a JCM via a Tier 2 advice letter no later than June 15 of each year which would address the subsequent calendar year’s program offerings. However, A. 22-02-005 et al. would launch, terminate, or modify, in some cases substantially, the program offerings of the PAs, so BayREN points out that the current JCM due date would require the PAs to prepare a JCM without knowing which programs they will offer in 2024.
In a separate communication, also on February 17, 2023, BayREN sought clarification regarding the biannual budget advice letter ("BBAL") for 2022-2023 required by D.21-05-031. D.21-05-031 directs “program administrators [to] combine both program years (2022 and 2023) into one ABAL, to be filed on September 1, 2021, covering both years” and states that “[b]udget requests must stay under the cap authorized for the current business plan period, unchanged from D.18-05-041.” (D.21-05-031 at 52-53). BayREN requested confirmation of its understanding, which is that funds set forth in the BBAL are fungible between program year 2022 and program year 2023, meaning, for example, that unspent 2022 funds could be expended in 2023.
