The California Public Utilities Commission’s (“CPUC’s”) Energy Division (“ED”) rejected Orange County Power Authority’s (“OCPA’s”) Advice Letter (“AL”) 4-E, in which OCPA elected to administer a cost-effective energy efficiency (“EE”) program, because OCPA included the budgets and programs of Regional Energy Networks (“RENs”) within its funding calculation. The ED’s response to AL 4-E states that RENs apply to the CPUC independently of the IOUs for EE funding and any request to modify the maximum funding formula would require a motion to do so.
The following is brief summary:
In AL 4-E, OCPA argues that the D.14-01-033 adoption of the maximum funding that a CCA can request for an EE program should not only include Investor-Owned Utilities (“IOUs”) budgets, but also RENs and other non-IOU Program Administrator (“PA”) budgets. However, the ED claims that the maximum funding formula for Community Choice Aggregators (“CCAs”) who pursue the elect to administer (“ETA”) option is clearly limited to the IOU budget in which the CCA is seeking CPUC authorization to offer their programs and does not include other non-IOU PAs.
D.14-01-033 set the formula for the maximum funding that a CCA who pursue the ETA route can request when establishing a budget. The formula of the CCA maximum funding = Total electricity EE non-bypassable charge collection from the CCA’s customers – (total electricity EE non-bypassable charge collections from the CCA’s customers * % of the applicable IOU portfolio budget that was dedicated to statewide and regional programs in the most recently authorized program cycle).
Because OCPA included REN budgets and programs that offer EE programs in SCE’s service territory within their maximum funding calculation, the amount OCPA requested in AL-4E was significantly increased. The ED’s response to AL 4-E states that RENs apply to the CPUC independently of the IOUs for EE funding and programs, are responsible for designing their own portfolios and programs, and follow different rules from the IOUs. The ED also points out that all other CCAs who have successfully pursued the ETA process since the first RENs were approved correctly applied the maximum funding formula and did not include RENs budgets. Finally, the ED states that the OCPA cannot request a change to the decision language on the maximum funding formula through an AL, but may file a motion requesting to do so in the current EE proceeding (R.13-11-005) or petition to modifyD.14-01-033.
