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Energy Efficiency
R. 13-11-005
March 28, 2022

Draft Resolution Certifies Peninsula Clean Energy’s ETA AL

The Draft Resolution certifies Peninsula Clean Energy’s (“PCE”) AL 20-E requesting to Elect to Administer (“ETA”) its Energy Efficiency (“EE”) Plan. PCE’s approved budget is $4,678,563 over the course of its three-year EE Program Plan which is modeled after Marin Clean Energy’s FLEXmarket. The funding will come from PG&E’s EE Portfolio Budget. Comments on the Resolution are due April 18 and a vote on the Resolution is scheduled for May 5.

PCE’s Proposed EE Plan

PCE proposed an offering based on Marin Clean Energy’s FLEXmarket program, with a budget of $4,678,563 over three years. The FLEXmarket structure allows: (a) for PCE to set a price-point for distributed energy services provided by implementers and (b) paying the implementers according to that price-point based on the implementers’ actual performance yield, as measured by meter-based data analysis.

Under FLEXmarket, PCE would offer financial incentives in exchange for proven electricity usage reductions for PCE customers of all building types. Any eligible implementers would be allowed to enroll in the program. These implementers would then work with PCE customers to maximize the customers’ overall EE improvements and peak load reduction. Implementers would receive an incentive payment for proven EE gains, calculated using the open-source CalTRACK methodology for population level Normalized Metered Energy Consumption (“NMEC”)10 analysis for sites treated through the program.

Finally, PCE projects that over its 3-year program term, their FLEXmarket will create a net peak demand reduction impact of 831 kW, and gross energy savings of 5,658,165 kWh. They also forecast that the program’s cost-effectiveness is a Total Resource Cost (TRC) of 1.02 and a Program Administrator Cost (PAC) of 1.39 over the three years of the program.

PG&E’s Protest

The Commission disagreed with PG&E’s protest that the FLEXmarket program as filed in supplemental AL 20- E-A is duplicative of PG&E’s MAP as approved in D.21-12-011.

The Commission also rejected PG&E’s argument that the PCE effort would cause customer and implementer confusion with two entities administering different MAP efforts with possibly different rules.

We believe that the programs have significant differences in the program design, program rules around cost-effectiveness and the duration the programs will be offered. Also, PCE will have their own marketing materials that must clearly delineate the programs, which will also be reviewed by CPUC staff. Finally, since PCE renamed their effort to FLEXmarket in their supplemental we believe that these concerns by PG&E are addressed

Update Links
Draft Resolution E-5197
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