Parties Filed Comments on the EE Proposed Decision

Comments generally focused on revising Ordering Paragraph ("OP") 1, which limits incremental funding access to existing authorized energy efficiency program administrators ("PA"), sets the application filing deadline to 45 days after the Decision is approved, and provides IOUs with discretion over administration of funds allocated to their respective service territories.

Peninsula Clean Energy

PCE submitted comments requesting that (1) Commission expand eligibility to CCAs with pending ETA Advice Letters and (2) The PD provide more concrete guidance regarding funding allocation.

CCA Eligibility

• PD should be modified to expand Market Access program (“MAP”) to include all CCAs that have pending ETA Advice Letters.
  ‍
• Encouraging more CCA participation is critical to ensuring the MAP program’s success in reducing peak load by summer 2022
  ‍
• Ordering Paragraph ("OP") 1 should be modified to include:

Current EE Program Administrators and CCAs with pending elect to administer advice letters shall be eligible to seek funding for Market Access programs. The Commission will expedite consideration of pending CCA elect to administer advice letters.

Funding Allocation

• The Commission should specify a minimum guaranteed funding amount for CCA MAPs and clarify that MAPs must be non-overlapping
  ‍
• The PD should be amended to ensure that if the total funding requests for an IOU’s service area exceed the proportional amount of the $150 million program funding allocated to that service area, implementing CCAs receive guaranteed MAP funding up to a specified level.
  ‍
• The guaranteed funding amount should be calculated by multiplying the CCA’s customer load as a fraction of the relevant IOU’s load by the total MAP budget for the IOU’s service area, based on the load figures used in the current IRP cycle.

• To avoid disputed over funding access, a new OP should be added to state:

If the combined Market Access Program budget requests for an IOU’s service area exceed the proportional share of the overall program budget assigned to that service area, implementing CCAs shall be guaranteed Market Access Program funding up to a level calculated by multiplying the CCA’s customer load as a fraction of the relevant IOU’s load by the total Market Access Program budget for the IOU’s service area, based on the load figures used in the current Integrated Resources Planning cycle.

• To avoid issued with program overlap, a new OP should be added to state:

Market Access Programs shall be deployed on a non-overlapping basis. As the most local “level” of PA, each CCA that implements a Market Access Program shall be the sole Market Access Program provider for its service area. RENs that choose to implement Market Access Programs shall have sole responsibility for implementing Market Access Programs for their geographic areas, minus those communities with CCA-implemented Market Access Programs. IOUs shall not deploy Market Access Programs in communities that are served by CCA or REN Market Access Programs.

‍

CalChoice

CalChoice submitted comments indicating support for PCE’s proposal and also requesting that the PD be modified to allow for non-PA CCAs to join and participate in eligible CCAs’ MAP programs.

• PD should be modified to allow CCAs that do not have PA status or pending ETA advice letters before the Commission to join and participate in MAP programs implemented by CCAs that are MAP-eligible.
  ‍
• The Commission recently approved a similar joint construct for the Disadvantaged Communities Green Tariff (“DAC-GT”) program.
  ‍
• The PD should include a new OP stating:

Any CCA that is eligible to implement a Market Access Program and elects to do so may, at its discretion, allow one or more other, non-eligible CCAs to join its Market Access program. In doing so, the eligible CCA shall be solely responsible for program implementation, but the customers of all CCAs in the combined program shall be eligible for program offerings on an equal basis. Joint CCAs may limit or target program offerings based on customer class. Any CCAs wishing to implement a Joint MAP must notify the Commission and all PAs within 20 days of the effective date of this Decision. To qualify for funding, the eligible CCA implementing a combined program shall file a single Tier-2 advice letter on behalf of all CCAs participating in the combined program within 45 days of the effective date of this decision, containing the information specified in OP 1. The maximum guaranteed funding amount for the combined program shall calculated by combining the proportional load shares for all CCA programs participating in the joint MAP and multiplying that against the total funding allocated to the relevant IOU’s service area.

East Bay Community Energy

EBCE submitted comments requesting (1) that the PD be modified to allow any CCA with a pending ETA AL to access MAP funding and (2) that the PD confirm that CCAs will be allocated a minimum funding amount.

• Allowing greater CCA participation in the Market Access Program lends to local initiatives meeting local needs and interests. This modification to the PD will widen the scope of meeting diverse customer segments such as low- and moderate-income customers, which is necessary to advance reliability in an expedited and equitable manner.
  ‍
• Propose that OP 1 be modified to specify:

Current Energy Efficiency Program Administrators and Community Choice Aggregators with pending elect-to-administer advice letters (“Eligible Entities”) shall be eligible to seek funding for Market Access programs .
‍

• The PD does not provide clear direction for determining funding allocation for non-IOU program administrators.
  ‍
• EBCE recommends that allocation of the Market Access Program is calculated based on the load share of the CCA’s customers compared to the IOU’s total load. For example, if the CCA’s customer load is 10% of the respective IOU’s total load share, then the CCA is given up to 10% of the Market Access Program funds for its EE programs.
  ‍
• Propose a new OP be added to address minimum funding:
  ‍

If the combined Market Access Program budget requests for an IOU’s service area exceed the proportional share of the overall program budget assigned to that service area, implementing CCAs shall be guaranteed Market Access Program funding up to a level calculated by multiplying the CCA’s customer load as a fraction of the relevant IOU’s load by the total Market Access Program budget for the IOU’s service area, based on the load figures used in the current Integrated Resources Planning cycle

RECURVE

Recurve submitted comments requesting that MAP funds be made available to all CCAs via the AL process and that the filing deadline be extended.

‍

• We recommend that the CPUC modify Conclusion of Law 15 and Ordering Paragraph 1 to enable any CCA to be approved to administer the Market Access funds (only) via a Tier 2 Advice Letter (staff approval).
  ‍
• We are also concerned that 45 days may be too short a timeline to file an advice letter and encourage the Commission to extend the period 15 days and allow an option to re-file after summer 2022
  ‍
• Ordering Paragraph 1 should be revised to state:
  ‍

PG&E, SCE, and SDG&E shall meet and confer with the other energy efficiency program administrators, and CCAs, operating within their geographic territories to discuss program collaboration and budget allocation. Subsequent to these meetings, to access these funds, any existing authorized energy efficiency program administrator, or CCA, interested in deploying this program shall file a Tier 2 advice letter within 45 days 60 days after the effective date of this decision . . .and may re-file for additional funds or to establish a new market for 2023.

‍

SDG&E 

SDG&E submitted comments indicating doubt that it can deliver incremental energy savings in the region and requesting more time to submit the MAP Advice Letters.

The timing for the MAP funding Advice Letter should be extended to October 31 to allow more time to identify incremental customer markets, establish a reasonable incremental peak demand savings target, program budget, develop the required implementation details, and meet and confer with other program administrators.

‍