Protests and Comments on EE Business and Portfolio Plans

Several parties filed responses addressing certain aspects of the business and portfolio plans to be considered in the consolidated proceeding.

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Association of Bay Area Governments and County of Ventura (“BayREN” and 3C-REN”)

• BayREN and 3C-REN believe that clear coordination is necessary within and beyond the proceeding.
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• They recommend evaluating the complete portfolio of Energy Efficiency (“EE”) offerings approved in R.13-11-005, including each of the present applications before the Commission as well as separately approved EE offerings and advice letters.
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• BayREN and 3C-REN believe the Commission should make clear what resources are available for ratepayers. They request the Commission update its ratepayer-facing website on energy and EE so that customers can find all of the programs and funding streams for which they may be eligible.

California Efficiency and Demand Management Council

• The Council generally supports the Energy Efficiency Strategic Business Plan and the Portfolio Plan, including their stated commitment to the State’s goals for EE and inclusiveness, and many of the Program Administrators’ (“PAs”) recommendations for improvement in the processes governing their development and implementation.
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• The Council reminds the Commission of the California’s commitment to advance EE and an improved environment, and the Council believes that the Commission should put more of a spotlight on EE funding. The Council believes the proposed annual expenditures are, in many cases, lower than the pre-2024 period during which time the Biennial Budget Advice Letters (“BBALs”) showed budget increases. Because of this, there is a shortage of delivery capability.
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• The Council is also concerned that the PAs have a history of not fully spending their EE budgets; thus, the Commission should oversee PA behavior and take steps to ensure the PAs fulfill their commitments, expend budget allocations for contractors engaged to deliver EE, and ensure that ratepayers get the benefits they are owed
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• The Council supports Marin Clean Energy’s (“MCE”) recommendation for the Commission to include non-energy benefits (“NEBs”) as a metric for equity programs. They recommend the Commission:

Enervee

• Enervee recommends the Commission focus California’s EE programs to emphasize plug-load and appliance efficiency because they are a significant contributor to residential energy usage.
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• Enervee believes California’s energy policy should encourage private spending by customers on energy efficient and flexible load devices, so participant impacts should not be a factor in calculating cost-effectiveness metrics
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• Enervee believes, if the Commission approves RuralREN’s proposed microloan product, the product should be designed to ensure that it does not overlap or duplicate other similar offerings that are already available to consumers.
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PG&E

• PG&E believes that requests for data sharing that involve data beyond EE are out of scope for the proceeding, such as the MCE’s proposal that the Commission require PG&E and MCE to exchange Demand Response (“DR”) program participation data to facilitate eligibility verification.
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• PG&E believes that consideration of cost effectiveness changes should remain in the Integrated Distributed Energy Resources (“IDER”) proceeding or its successor so that EE cost effectiveness metrics remain consistent with other DERs.

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Public Advocates (“Cal Advocates”)

• Cal Advocates supports the determination that hearings are likely necessary, to establish means of accountability that ensure ratepayers receive the benefits of nearly $4 billion dollars in revenue returns requested by the PAs for EE programs, $1.3 billion of which is dedicated to Market Support and Equity programs and is not subject to cost-effectiveness requirements.
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• Cal Advocates requests that the Commission set a schedule that provides adequate opportunity for discovery, analysis, preparation of testimony, and preparation for evidentiary hearings
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Recurve Analytics

• Recurve believes the CET has not kept pace with program innovation does not accommodate the unique characteristics of meter-based programs; thus, the Commission should approve the use of open-source tools to fill these gaps.
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• Recurve also recommends their tool, FLEXvalue, an open-source valuation engine to assess the value of changes in customer energy consumption relative to the system value reflected in the Commission's ACC. They propose that FLEXvalue be approved for use by PAs to submit forecasted impacts in their budget advice letters and for final claims.
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• Recurve also recommends the Commission order the provision of data under appropriate security agreements so all PAs can implement and evaluate EE programs. The Commission should explicitly order the IOUs to provide RENs, or their agents the data needed to optimize program deployment and assess comparative impacts under a security agreement to implement population-NMEC programs per the classification as a primary purpose use case.
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• Recurve believes the Commission should recognize the additional value of electrification in the natural gas avoided costs to synchronize with state policy to decarbonize the economy. As a result, the Commission should recognize the limited value that is currently placed on avoided natural gas as a barrier to program coordination for efficiency and decarbonization and reconcile this value in updates to the ACC.
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• Recurve supports PG&E's policy changes to enable EE portfolios of the future. Optimizing the portfolio around TSB will be foundation to supporting decarbonization and aligning energy demand and supply

Redwood Coast Energy Authority (“RCEA or RuralREN”)

• RuralREN supports expanding the definition of HTR to include the public sector facilities that meet the geographic criteria approved in Resolution G-3497 and D.18-05-041. This will incentivize both resource acquisition program implementers and equity program implementers to focus on HTR public sector customers.
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• RuralREN supports 3C-REN’s recommendation that the IOUs should streamline non IOU PAs’ access to customer-authorized billing data. To ensure effective data sharing, the data access process should be formally adopted and overseen by the Commission and standardized across all IOUs
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• RuralREN supports proposals for greater program integration and integration of demand side management (“IDSM”) activities.
• RuralREN believes that all PAs should be allowed to offer upstream/midstream measures, that are not otherwise offered in statewide programs, to effectively reach all customers.
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• RuralREN believes the Commission should continue to evaluate cost effectiveness tests, specifically the TRC as a measure of the efficacy of portfolio programs.
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• RuralREN supports SoCalGas’s recommendation that a program’s influence on the customer decision to pursue an EE project should be immediately evaluated by the Commission following project completion.
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• RuralREN supports further consideration of portfolio planning timeline alignment to allow for methodical, comprehensive party input and holistic consideration of the implications could result from shifting away from the policy that allows Community Choice Aggregators (“CCAs”) and RENs to propose to become new PAs at any time.
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• RuralREN recommends bifurcating the proceeding so their motion can be considered in a separate track of this proceeding with an accelerated schedule.

Sonoma Clean Power ("SCP")

• SCP highlights that their Sonoma County customers benefit from BayREN’s programs, but their Mendocino County customers are unable to access BayREN’s valuable program offerings. Thus, SCP believes that RuralREN is uniquely positioned to address the inequity and access issues faced by Mendocino County and the many other rural areas across the State.

Southern California Gas Company (“SoCalGas”)

• SoCalGas believes that the EE Business Plan proceeding is not the appropriate procedural pathway for Southern California Edison Company(“SCE”) to raise an issue that would not impact its own application.
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Southern California Regional Energy Network (“SoCalREN”)

• SoCalREN supports the timely approval of all PA’s business plan applications to help California meet its clean energy goals.
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• SoCalREN believes the Commission should continue to support innovative portfolios that provide a unique value and prioritize equity in the EE marketplace. It is imperative to the State’s objectives that the Commission continue to support non-traditional EE portfolios so that RENs can continue to meet the needs of these underserved and marginalized communities.
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• SoCalREN believes the Commission should approve SoCalREN’s business plan application and allow SoCalREN to continue building upon its successful portfolio of programs. This will allow to the continuation and expansion of successful approaches to complement, address gaps, and develop innovate solutions that serve ratepayer needs and add significant customer value.

Small Business Utility Advocates ("SBUA")

• SBUA believes that eligible energy savings programs should aggressively target small businesses and that business plans should analyze market opportunities in the small business sector, identify barriers, and present robust strategies to overcome those barriers going forward.
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• SBUA believes the Commission should ensure that small businesses receive technical and financial assistance for decarbonizing their energy usage, including heat pump technologies (space and hot water) and food service equipment.
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• SBUA is interested in ensuring that Market Support and Equity programs explicitly assess their impact on the small business community.
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• SBUA will be requesting that the Commission require the PAs to submit specific data relating to the percent of contracts awarded to women, minority, disabled veteran, and LGBTQ businesses.
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• SBUA believes the Commission should solicit data from the PAs to determine which PAs are partnering with Recurve to offer the FLEXMarket access program. Additionally, the Commission should require PAs to provide information relating to aggregators and implementers – specifically pertaining to the proportion of savings that are retained, and the proportion that is allocated to the customers.
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