Application No. A.14-11-011
Exhibit No:_________________
Witness:_Aguirre, Mark / Yao, Hugh
Application of Southern California Edison Company (U 338E) for Approval of its Energy Savings Assistance and California Alternate Rates for Energy Programs and Budgets for Program Years 2015-2017.
Application 14-11-007
(Filed November 18, 2014)
And Related Matters.
Application 14-11-009 Application 14-11-010 Application 14-11-011
PREPARED REBUTTAL TESTIMONY OF MARK AGUIRRE AND HUGH YAO ON BEHALF OF SOUTHERN CALIFORNIA GAS COMPANY
BEFORE THE PUBLIC UTILITIES COMMISSION
OF THE STATE OF CALIFORNIA
May 22, 2015
1
2
3
4
5
6
7
8
9
10
11
12
13 14
15
16
17
18
19
20
21
22
23
24
INI.
T
observati
operation
appreciat
beneficia
In
with, mo
those com
T
proposals
factual in
SII.U
As n
SoCalGa
specifica
•
•
NTRODUC
The purpose o
ions offered
ns. SoCalGa
tes that every
al and effecti
n large part,
st of SoCalG
mponents of
To the extent
s, this rebutt
nformation in
OCALGASUNOPPOSE
noted above,
as requests th
ally approved
Approval
opposed b
and Outre
Administr
CPUC) E
Approval
Decision
CTION
of this rebutt
in testimony
as is grateful
y party has o
ive possible
parties have
Gas’ proposa
f its proposal
parties have
tal testimony
n support of
S REQUESTED REQUES
several com
hat the below
d in the final
of SoCalGa
by any party
each, Measur
ration, and th
nergy Divisi
to shift fund
(D.) 08-11-0
tal testimony
y relative to
l for the deta
offered its pr
program for
e either been
als. SoCalG
l that are uno
e offered test
y directly res
f SoCalGas’
TS THAT TSTS
mponents of S
w unopposed
l Decision as
as’ 2015 – 20
y, including b
rement and E
he Californi
ion categorie
ds in the ESA
031 and as m
MA/HY-1
y is to respo
the Energy
ailed and tho
roposals with
r SoCalGas’
n silent on, or
Gas requests t
opposed by a
timony that
sponds and p
proposals.
THE COMM
SoCalGas’ p
d requests be
s proposed:
017 ESA Pro
budgets requ
Evaluation S
a Public Uti
es.
A Program c
modified by D
1
nd to parties
Savings Ass
oughtful testi
h the intent o
customers.
r have expre
that the Com
any party.
opposes or g
provides clar
MISSION G
proposal are
e granted by
ogram propo
uested under
Studies, Reg
ilities Comm
consistent w
D.10-10-008
s’ positions,
sistance (“ES
imony of par
of making E
essed suppor
mmission ado
goes beyond
rification and
GRANT SOC
not opposed
the Commis
osed plans an
r Training Ce
gulatory Com
mission (Com
with fund shif
8.
proposals, a
SA”) Progra
rties, and
ESA the mos
rt and agreem
opt, as propo
d SoCalGas’
d relevant,
CALGAS’
d by any par
ssion and
nd budgets n
enter, Marke
mpliance, Ge
mmission or
fting authori
and
am
st
ment
osed,
rty.
not
eting
eneral
ity in
MA/HY-2
• Approval of the mix of measures reflected in Application Attachment A-5. 1
• Approval to add new measures as proposed in Section II.E.1.b. of the Direct 2
Testimony of Mark Aguirre and Hugh Yao. 3
• Approval of the marketing and outreach elements requested in the Direct Testimony 4
of Mark Aguirre and Hugh Yao. 5
• Approval to use the methodology adopted for the eligible population as revised in 6
Mark Aguirre and Hugh Yao, pending resolution of the “unwillingness” factor 7
contested by some parties. 8
• Approval to relax the modified 3 Measure Minimum (“3MM”) Rule in the cases of 9
multifamily units and measures installed in anticipation of a third measure as 10
proposed in the Direct Testimony of Mark Aguirre and Hugh Yao, which was 11
unopposed by any party.1 12
• Approval to offer Energy Education to income qualified customers that do not meet 13
the 3MM Rule. 14
• Approval to continue integration and leveraging efforts. 15
• Approval of statewide impact evaluation, low income needs assessment, energy 16
education (Phase 2) and cost-effectiveness studies for the 2015-2017 program cycle. 17
1 Direct Testimony of Southern California Edison (“SCE”), November 18, 2014, pp.99-100; Report of The Office of Ratepayer Advocates on The Consolidated Proceedings Regarding Energy Saving Assistance Program , April 27, 2015, K.C. Watts-Zagha and Louis Irwin, witnesses, p.42; Direct Testimony of Pacific Gas and Electric Company (“PG&E”), p.2-13; Prepared Testimony of Allan Rago on behalf the Energy Efficiency Council , p.5; Testimony of James Hodges on Behalf of The East Los Angeles Community Union (“TELACU”), the Maravilla Foundation, and the Association of California Community and Energy Services, p. 14; Testimony of Marin Clean Energy, pp.9-10.
1
2 3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
DIII.
A
T
and the E
proposal
proposal,
enrollme
counsels
supports
year prop
associate
witness D
back serv
O
ESA Pro
adapt its
proposes
groups.”4
Furnace,
2 “TURN restore deadditional3 EEC at psupport P4 Report oSaving As
DISCUSSIO
SoCaA.Enrol
The Office of
Energy Effic
to perform p
, based on a
nts. TURN2
caution in e
the more ag
posal. This t
ed with SoCa
Daniel Rend
vices.
ORA in its te
gram that pr
program in r
multiple im
4 These imp
neither of w
supports a reegraded measul energy savinp.6: “The goaG&E’s recom
of The Office ssistance Prog
ON OF PAR
lGas’ Propollments in 2
f Ratepayer A
iency Counc
post-2002 re
preference t
2 and EEC su
ensuring the
ggressive 8-y
testimony w
alGas’ propo
ler will addr
stimony ack
rovide increm
response to
mprovements
provements i
which was av
eturn to the prures and also ngs” at p.20. al should be tommendation o
of Ratepayergram (ESA) A
TIES’ SPEC
osal to Perfo015-2017 Sh
Advocates (“
cil (“EEC”)
e-enrollment
that the prog
upport the el
first-time en
year go-back
will address th
osal and part
ress policy-r
knowledges t
mental impro
changing ne
in response
include the tu
vailable 10 y
revious 10-Yeto provide ne
o provide custof using 8 year Advocates oApril 27, 201
MA/HY-3
CIFIC TES
orm a Limithould Be Ad
“ORA”), Th
address in th
ts in 2015-20
gram undergo
lements of S
nrollments ar
k rule propos
he operation
ties concerns
elated consid
that SoCalG
ovements, st
eeds of its low
e to Commiss
ub spout me
years ago. O
ear Go-Back Rewer technolo
tomers with tars and need aon The Conso5, K.C. Watt
3
STIMONY
ted Numberdopted
he Utility Re
heir respectiv
017. ORA r
o “redesign”
SoCalGas’ pr
re not “depri
sed by PG&E
nal and outre
s, while the t
derations as
Gas proposed
tating that So
w income cu
sion guidanc
easure and H
ORA also not
Rule because ogies and serv
the necessary as the only rulolidated Procets-Zagha and
r of Post-20
eform Netwo
ve testimony
recommends
” prior to beg
roposal, alth
ioritized,” an
E, rather tha
each conside
testimony of
sociated wit
d to introduce
oCalGas’ pr
ustomers. So
ce, studies an
High Efficien
tes the poten
it provides avices in furthe
home improvles for go-baceedings RegarLouis Irwin,
002 Re-
ork (“TURN
y SoCalGas’
denial of th
ginning any
hough TURN
nd EEC3
an SoCalGas
rations
f SoCalGas
th providing
e elements to
roposal, “wo
oCalGas
nd working
ncy (“HE”)
ntial value of
an opportunityerance of
vements and cks.” rding Energy witnesses, at
”),
’
his
re-
N
’ 10-
go-
o the
ould
f
y to
we
p.10.
MA/HY-4
SoCalGas’ proposal to target high energy users for the HE Furnace.5 SoCalGas also proposes in 1
the early stages of implementing the 10-Year Go-Back Rule, to target customers considered high 2
energy users.6 This element is particularly important because, while it is projected to involve a 3
relatively small number of units, it will provide SoCalGas with practical experience in targeting 4
measures based on usage – an element not currently part of the program, and which will require 5
development of new procedures and system enhancements. 6
Similarly, the proposed gradual ramp up of go-back units side by side with an achievable 7
number of 2020-goal units provides the opportunity to develop needed procedures and systems 8
to manage the program under a scenario that is inevitable as 2020 goal units are eventually 9
depleted. The modest number of go-backs proposed would be sufficient to begin to gauge 10
response to the program among go-back customers, and to adapt the marketing message 11
accordingly. While there will be transitional challenges to any new programmatic initiatives, 12
waiting for every 2020 goal unit to be treated before beginning to seek out go-backs will 13
exacerbate these challenges, an issue that will be felt most directly by SoCalGas’ contractors, 14
and acknowledged by ORA.7 15
ORA states “the Commission should deny the ESA II proposals, and the associated 16
budgets of PG&E and SoCalGas.”8 It is important to clarify that if the Commission adopts 17
SoCalGas’ recommended annual unit goal of 110,000 treated homes, there should not be a 18
separate, incremental budget reduction associated with denial of the 10-year Go-Back Rule 19
5 “SoCalGas plans to limit HE Furnaces only to those dwellings that have furnaces at or below AFUE. Furthermore, SoCalGas ensures that HE Furnaces will go to those most in need and also those with the greatest potential to save energy.” Id. at p. 13. 6 “SoCalGas also proposes, in the early stages of implementing the Rule, to target customers considered high energy users, based on energy burden, and based on health, comfort and safety criteria.” Direct Testimony of Daniel Rendler, at p.23. 7 K.C. Watts-Zagha and Louis Irwin, at p. 41. 8 Id. p. 40.
MA/HY-5
proposal. As stated in Direct Prepared Testimony, “SoCalGas does not expect a significantly 1
different cost per treated unit whether the Commission approves, denies or alters SoCalGas’ 2
proposal to include 10-year go-back units already treated since 2002. . . Removing the 10-year 3
go-back proposal altogether would not impact SoCalGas’ proposed budget, as long as total 4
treated units are maintained at 110,000 per year.”9 Thus, in the event the Commission does not 5
adopt the 10-year go-back proposal, but adopts SoCalGas’ proposed 110,000 treated homes goal, 6
there should be no adjustment from the proposed budget. 7
Although TURN supports SoCalGas’ go-back proposal, it identified a concern that go-8
backs could result in inadequate priority to the most difficult 2020-goal units (not previously 9
treated since 2002). While noting that SoCalGas has committed to, and proposed a plan for 10
achieving the 2020 goal, these concerns and the necessary controls were also identified by 11
SoCalGas, “SoCalGas proposes to prioritize units not yet treated since 2002. In order to do so, 12
SoCalGas will need to control the outreach and enrollment activities of contractors. SoCalGas 13
believes that it can develop the needed systems and controls during 2015. These consist of 14
system enhancements to track and limit authorization of contractors to work leads on post-2002 15
re-enrollments, as well as some new program rules and contract provisions that can be designed 16
and rolled out as early as mid-2015.”10 17
The referenced contract provisions specifically will include separate goals and dollars for 18
each contractor allocated re-enrollments under the 10-year Go-Back Rule. System enhancements 19
will include providing contractors the ability to distinguish eligible previously-enrolled leads 20
from never-enrolled and ineligible customers, providing SoCalGas the ability to separately track 21
contractor production within the re-enrollment and never-enrolled categories, and providing 22
9 Prepared Direct Testimony of Mark Aguirre and Hugh Yao, dated November 18, 2014, at p. 130. 10 Prepared Direct Testimony of Mark Aguirre and Hugh Yao, dated November 18, 2014, at p. 30.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17 18
19
20
SoCalGa
related to
T
any aban
the 2020
and 90,00
level, lea
be the mo
F
provide s
are likely
these cus
the themo
contribut
F
a limited
B
In
24% base
11 Id. at pp12 As provsavings oftherms; T13 Direct T
as the ability
o re-enrollme
Thus, SoCalG
ndonment or
goal at a ste
00 units tow
aving room t
ost challengi
inally, the m
significant sa
y to have wo
stomers the H
ostatic show
tors to SoCa
or the above
d number of r
SoCaB.Popul
n testimony,
ed on the res
p. 14 – 22. vided in attachf 8-65 thermsSV provides Testimony of
to regulate c
ents.
Gas’ proposa
reduction in
eady pace of
ward the 2020
o make adju
ing to enroll
measures that
avings. In ad
orn out after
High Efficien
wer valve (TS
lGas’ energy
e reasons So
re-enrollmen
lGas’ Propolation For P
SoCalGas d
sults of the L
hment to Agus depending o1-3 therms; a
f Mark Aguirr
contractor le
al to reintrod
n emphasis o
f 80,000 unit
0 goal in 201
ustments in th
l.
t will be offe
ddition to ren
ten or more
ncy Forced A
SV), and the
y saving por
CalGas’ pro
nts should be
osal to DeduPurposes Of
described in
Low Income
uirre/Yao teston housing typand Tub Spoure & Hugh Ya
MA/HY-6
ead generatio
duce the 10-y
on the 2020 g
ts per year.11
15, 2016, an
he later year
ered to go-ba
newing meas
years, the pr
Air Unit (HE
thermostati
rtfolio.12
oposal to re-i
e adopted.
uct 24% “Uf Setting 202
detail its pro
Needs Asse
imony at Exhpe and climatut provides 22ao pp.15-22.
6
on and billin
year Go-Bac
goal. SoCal
1 The propo
d 2017 respe
rs, and antici
ack custome
sures such a
rogram will
E FAU) furn
ic tub spout,
introduce the
Unwilling” C20 Goal Sho
oposal to ado
essment (“LI
hibit 2, HE FAe zone; HE cl
2-35 therms.
ng activities
ck Rule does
Gas estimate
sal to treat 1
ectively goe
ipating that t
ers under thi
as air sealing
offer for the
nace, the HE
all of which
e 10-year Go
Customers Fould Be Ado
opt an unwil
INA”) study
AU furnace prlothes washer
specifically
s not represe
es it can ach
105,000, 100
s beyond thi
the last units
s proposal
g measures th
e first time to
E clothes was
h are substan
o-Back Rule
From Eligibopted
llingness rate
y.13 Pacific G
rovides first yr provides 31
ent
hieve
0,000,
is
s will
hat
o
sher,
ntial
e for
ble
e of
Gas
year
MA/HY-7
& Electric Company (PG&E), Southern California Edison (SCE), and San Diego Gas & Electric 1
(SDG&E) also proposed similar revisions to willingness.14 2
In its testimony, EEC advises against making any adjustments at this time: “before the 3
IOUs lower their estimated eligible population; the Commission should wait to see if the 4
recommendations put forth in the applications for increasing participation through policy 5
changes and increased efforts actually work.”15 6
Despite minor variations among the IOUs,16 all generally support immediate adjustments 7
in program expectations based on the LINA results. Other than EEC, no party has argued that 8
the unwillingness assumption should not be revised upward. The Commission itself, in 9
maintaining the previously adopted 5% unwillingness assumption in D.12-08-044, anticipated 10
modifying this assumption for 2015-2017, “at this time the Commission still does not have 11
adequate data to modify this figure. However, the new Needs Assessment being conducted 12
pursuant to this decision in the upcoming months should inform the Commission on this issue for 13
the upcoming 2015-2017 program cycle.”17 14
Maintaining the status quo as proposed by EEC will have negative consequences. In 15
calculating remaining untreated customers in its application, SoCalGas relied on the 2013 Athens 16
14 SDG&E proposes 19% unwillingness (See Prepared Direct Testimony of Alex Kim p.AYK-18 “The calculation for the percentage of total eligible that are unwilling to participate was based on the research conducted in the LINA Study. The LINA Study estimated that 48% of the eligible, non-treated homes would be unwilling to participate in the ESA Program. For 2013, the year in which the research was conducted, this is analogous to 19% of the total eligible population in SDG&E’s service territory.”) PG&E proposes 48% unwilling among the untreated population, which is not converted to a percent of all eligible (see Landry/O’Drain/Smith Table 2-3 p.2-18.) This is equivalent to SoCalGas’ approach as pointed out at Aguirre/Yao p.15 “24% of the eligible population … corresponds to the conclusion in the LINA Study that 52% of current program non-participantes were willing.” SCE proposes 21.5% unwillingness (See “Energy Savings Assistance (ESA) Program Plan and Budget Proposal for the 2015-2017 Program Cycle”, Lim/Samiullah/Weber, at p.19 Table II-3. 15 EEC Prepared Testimony of Allan Rago, at p.5 16 The IOUs are SoCalGas, SDG&E, SCE, and PG&E. 17 LINA Study, stating at p. 264.
1
2
3
4
5
6
7
8
9
10
11 12
13
14
15
16
17
18
19
Research
homes in
factor of
on the LI
2020, or
would ha
accountin
budget w
SoCalGa
are proje
C
In
take step
specifica
informati
over time
househol
provide a
18 2020 pr19 As state2015, $1,0therefore million inyears, are the 5% un20 Preparep. 9
h estimate to
n SoCalGas’
5% (from th
INA study, i
73,000 addi
ave led to an
ng for 10-ye
would be roug
as’ ratepayer
cted to be un
SoCaC.Upgra
n testimony,
s to incorpor
ally informat
ion data base
e the IOUs w
lds than they
appropriate s
rojection is baed at Aguirre/065/unit in 20have resulted
n 2017, for a tremoved, all
nwillingness aed Testimony
project that
territory.18
he program c
t would resu
tional custom
n annual goal
ar go-back r
ghly $230 m
rs and little c
nwilling to p
lGas’ Propoades That S
the Center f
rate data col
ion identifyi
e. CforAT a
will develop
y have had to
service to ho
ased on 1% an/Yao p.130, in016, and $1,0d in incrementtotal of $230 m else equal thassumption, cof Dmitri Be
by the end o
If the Comm
cycle beginn
ult in an addi
mers per yea
l for SoCalG
re-enrollmen
million over t
correspondin
participate.
osed BudgetSupport Cus
for Accessib
llected throu
ing persons w
argues that “
a much broa
o date. This i
ouseholds wi
nnual growthncremental un
089/unit in 20tal budget of million. Even
he 3-year ESAcompared withelser, Submitt
MA/HY-8
of 2020, ther
mission inste
ning in 2012)
itional 19%,
ar for the rem
Gas of at leas
nts. The incr
three years,1
ng benefit to
t Should Bestomers wit
ble Technolo
ugh the enrol
with disabili
“By effective
ader informa
is important
ith disabled m
as adopted innits would res17. Treating $73 million inn if the re-enr
A budget proph $375 millioed on Behalf
8
re will be 2.3
ead chose to
) rather than
or 437,000
maining 6 ye
st 153,000 un
remental imp
9 with negat
SoCalGas’
e Adopted Tth Disabiliti
ogy (“CforAT
llment of cus
ities, into the
ely maintain
ation base ab
going forwa
members.” 2
n D.08-11-03sult in prosed73,000 additn 2015, $78 mrollment unitsposal would bon as currentlyf of The Cente
3 million inc
retain the un
n a 24% unw
customers to
ears. Such a
nits per year
pact on SoC
tive consequ
low-income
To Ensure Nes Can Be C
T”) recomm
stomers in th
eir primary c
ing and distr
bout disabled
ard as the ut
20 SoCalGas
1, at p.110. d budget impational customemillion in 201s, totaling $37
be roughly $56y proposed. er for Accessi
come-eligibl
nwillingness
willingness ba
o be treated
an assumptio
r before
CalGas’ prop
uences for
customers w
Needed IT Completed
mends the IOU
he ESA Prog
customer
ributing data
d customer
ilities seek t
agrees that
act of $998/uners per year w16, and $79 7 million over68 million us
ible Technolo
le
s
ased
by
on
osed
who
Us
gram,
a,
to
nit in would
r 3 ing
ogy,
1
2
3
4
5
6
7
8
9
10 11
12
13
14
15
16
17
18
19
20
21
incorpora
Applicati
ESA syst
HEAT da
disability
customer
Program
handle de
its Gener
D
S
except w
the dispro
this meas
HVAC Im
testimony
(“Maravi
witness H
prescript
prescript
21 Prepare22 Prepare23 ORA T24 TELAC
ating this dat
ion, propose
tems. As sta
atabase can
y to SoCalGa
rs...Including
customers th
esignation.”2
ral Administ
SoCaD.When
oCalGas rec
when required
oportionate n
sure. The te
mpact Evalu
y of The Eas
illa”), and th
Hodges, opp
ive duct seal
ive duct seal
ed Direct Tested Direct Testestimony (W
CU Testimony
ta is benefic
ed funding fo
ated at Aguir
send records
as’ main cus
g ESA Progr
he communi
21 Therefore
tration budge
lGas’ Propon Not Requi
commends th
d by Title 24
number of te
stimony of O
uation showe
st Los Angel
he Associatio
oses elimina
ling proposa
ling proposa
timony of Matimony of Maatts-Zagha), ay,at p. 2.
ial, and as p
or IT enhanc
rre/Yao, “So
s of ESA Pro
stomer datab
ram disabilit
ication and n
e, SoCalGas
et proposal t
osal To Elimired For Co
hat duct testi
4.22 The prim
ests relative
ORA suppor
ed no measur
les Commun
on of Califor
ation of this
al.24 Witness
al is more ap
ark Aguirre anark Aguirre anat p.14.
MA/HY-9
art of its 201
cements to fa
oCalGas is p
ogram custom
base (“CIS”)
ty records in
notification b
respectfully
to ensure the
minate Ductompliance S
ing and seali
mary reason
to seals, wh
rts SoCalGas
rable saving
nity Union (“
rnia Commu
measure and
s Hodges do
ppropriate or
nd Hugh Yaond Hugh Yao
9
15 – 2017 L
acilitate this
proposing IT
mers who ar
that also tra
n CIS, will m
benefits asso
y requests th
ese planned u
t Testing anhould Be A
ing be retire
cited for eli
hich reduces
s’ proposal s
gs for Duct T
“TELACU”)
unity and Ene
d offers supp
oes not offer
r preferable r
, at p. 97. , dated Novem
ow Income P
transfer of i
enhancemen
re identified
acks special h
make it possib
ociated with
hat the Comm
upgrades can
nd Sealing AAdopted
d as a Progr
imination of
the cost effe
stating that “
Testing and S
), the Marav
ergy Service
port for SDG
any details w
relative to th
mber 18, 201
Programs
information
nts, so that t
as having a
handle
ble to offer E
the special
mission appr
n move forw
As A Measur
am measure
f this measur
ectiveness fo
“[t]he recent
Sealing.”23 T
villa Foundat
es (“ACCES
G&E’s
why the
he SoCalGas
4, at p. 105.
from
the
ESA
rove
ward.
re
e
e is
or
The
tion
S”)
.
1
2
3
4 5 6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
proposal
effectiven
SoCalGa
E
T
of core m
standards
zones and
common
SoCa
discussio
beneficia
variation
necessita
effectiven
W
workshop
lighting a
showerhe
weatheriz
already o
25 Testimo26 Testimo
. SoCalGas
ness challen
as proposal.
The CE.All IOThoro
The testimony
measures be a
s and termin
d the fuel so
core set of m
alGas is gene
on, but does n
al. In additi
ns, the housin
ates an IOU-
ness criteria
While propos
ps or other m
and linear flu
eads/ valves
zation, pipe
offers throug
ony of Amy Dony of Amy D
would still p
nges in other
CommissionOUs, Or Reqough Vettin
y of NRDC,
adopted for
nology where
ource of each
measures.
erally not op
not believe t
on to the afo
ng stock acro
specific mea
.
sing that the
methods,”26 w
uorescents; i
, faucet aera
insulation an
gh the ESA p
Dryden on behDryden on beh
provide this
installation
n Should Noquire Utiliti
ng Through
NCLC, and
all utilities,
e possible.”2
h IOU fuel w
pposed to sta
that establish
orementione
oss the state
asure mix tha
set of core m
witness Dryd
interior LED
ators, HVAC
nd Tier 2 po
program all o
half of NRDChalf of NRDC
MA/HY-10
measure wh
circumstanc
ot Impose A ies to Offer Regulatory
d CHPC witn
stating that t
5 She goes o
would need to
andardizing t
hing a core s
d climate zo
and across i
at takes into
measures to b
den suggests
Ds; low flow
C tune up, wa
ower strips.”
of witness D
C, NCLC, andC, NCLC, and
0
hen required
ces, the Com
Common SOr Elimina
y Process
ness Dryden
the intent is
on to state th
o be conside
terminology
set of measu
one variation
individual IO
o account me
be adopted “
s for conside
showerhead
ater heater re
It should be
Dryden’s sug
d CHPC, at pd CHPC, at p
by code. G
mmission sho
Set of ESA Mate Measure
n proposes th
to “create co
hat variation
ered before e
for ease of c
ures is necess
ns and IOU f
OU service t
easure feasib
“could be de
eration, “Inte
ds; thermosta
epair/ replac
e noted that
gested meas
.11.
.11.
Given the cos
ould approve
Measures foes Without
hat a common
onsistency in
ns in climate
establishing
comparison
sary or
fuel source
territories
bility and cos
efined throug
erior CFL
atic
cement,
SoCalGas
sures that are
st-
e the
or
n set
n
a
and
st-
gh
e
MA/HY-11
appropriate to a gas utility: low flow showerheads, thermostatic shower valves, faucet aerators, 1
HVAC (furnace) tune up, water heater repair/replacement, weatherization, and pipe 2
insulation.Furthermore, SoCalGas routinely reviews and evaluates offerings of other utilities and 3
newly available technology, and shares its information with other ESA Program providers. The 4
Commission is not overly burdened by reviewing the proposals of each of the various IOUs 5
separately, to the extent their measure proposals and justifications vary. Thus, establishing a 6
common set of core measures is unnecessary. 7
Witness Dryden also proposes that a “new process be developed to allow submission of 8
new measures by stakeholders in addition to utilities for consideration and retirement of 9
measures” incorporating “some clear criteria for measure approval” to be developed by the 10
Commission. 11
SoCalGas agrees that clarity of the measure approval criteria is valuable for purposes of 12
planning, assessing measures, and developing proper showings. However, SoCalGas does not 13
agree that the current process is necessarily inadequate or that stakeholders’ proposals are not 14
given every consideration in that process. IOUs regularly hold public meetings in advance of 15
developing measure proposal as part of their budget applications, and SoCalGas evaluates the 16
merit of such proposals to the extent they are applicable to a gas-only utility. Furthermore, 17
interested parties and members of the public have direct access to the regulatory process. Parties 18
are free in this proceeding, as NRDC/NCLC/CHPC has done, to propose consideration of 19
measures.27 Such proposals receive their due weight. SoCalGas is not opposed to improvements 20
27 Witness Dryden states, “[w]e recommend the Commission evaluate the following measures as part of this proceeding or through the measure evaluation stakeholder process described above: Package terminal air conditioners and heat pumps, Energy Star Qualified cooling fans, refrigerant charge verification, bathroom exhaust fans, bathroom exhaust fan controls, window film, tub diverter with thermostatic function, LED lighting.” ibid. p.12. Of the measures listed, the tub diverter with thermostatic function or
1
2
3
4
5
6
7
8
9
10
11
12 13
14
15
16
17
18
19
20
21
to the pro
adjustme
thorough
opportun
W
best of m
appear to
offer the
equipmen
high effic
basis for
F
T
“Commis
awaiting
obtain an
enrollme
(“CSLB”
salespers
this chap
thermostathe Rebututility. 28 Testimo29 The test
ocess for adj
ents maintain
h showing as
nity.
Witness Dryd
my ability for
o be correct f
following m
nt, furnace r
ciency cloth
any conclus
SoCaF.Licen
The testimony
ssion should
their HISR
n Home Impr
nt work for
”) requireme
son” (“HIS”)
pter to solicit
atic tub spout ttal Testimony
ony of Amy Dtimony of TE
usting the m
n the IOUs a
to a measur
den provides
r ESA and M
for SoCalGa
measures: du
repair & repl
es washers.
sion about co
lGas Supponsing Proces
y of TELAC
d direct the IO
badge.”29 S
rovement Sa
the ESA Pro
ents. Per the
) is a person
t, sell, negoti
is proposed iy of Daniel R
Dryden on behELACU, Mara
measure portf
ability to full
re’s suitabilit
s a table show
MFEER for th
as ESA. The
ct sealing, ai
lacement, pip
Because thi
onsistency ac
orts Explorass Without V
CU, Maravill
OU’s to allo
oCalGas req
alesperson R
ogram to com
Business an
employed b
iate, or execu
n SoCalGas’ Rendler, and n
half of NRDCavilla, and AC
MA/HY-12
folio. SoCal
ly evaluate p
ty to ESA. T
wing “a list o
he IOUs.”28
e table incorr
ir sealing / e
pe insulation
is table is no
cross IOUs o
ation of WayViolating CS
la, and ACC
ow assessors
quires that it
Registration (
mply with C
nd Profession
by a home im
ute contracts
pending applno other measu
C, NCLC, andCCES witness
2
lGas’ interes
proposed me
The current
of approved
It should be
rectly indica
envelope / w
n, water heat
ot complete,
or gaps in m
ys To MitigSLB Rules
CES witness
to work wit
ts Outreach S
(“HISR”) be
alifornia Sta
ns Code, a “
mprovement
s for home im
lication, heat ures are argua
d CHPC, at ps Hodges, at p
st is in ensur
asures and t
process prov
d measures co
e noted that
ates that SoC
weatherization
ter repair &
it should no
measure offer
gate Delays I
Hodges, stat
th a tempora
Specialists (“
efore perform
ate Licensing
“Home impro
contractor li
mprovemen
pumps are adably applicab
.21-23 “Appep.2.
ring that any
o present a
vides for thi
ompiled to t
this list doe
CalGas does
n, space hea
replacement
ot be used as
rings.
In HISR
tes that the
ary badge wh
“assessors”)
ming any
g Board
ovement
icensed unde
nts, for the sa
ddressed furthble to a gas-on
endix A”
y
s
the
s not
not
ating
t, and
the
hile
er
ale,
her in nly
1
2
3
4
5
6
7
8
9 10
11
12
13
14
15
16
17
18
19
20
installatio
hot tubs.”
“you soli
outside th
contracts
Registrat
S
mitigate
G
O
evaluatio
Impleme
new mea
because i
for its ne
W
assumpti
Impleme
the conte
30 Californhttp://legi31 CSLB whttp://wwHIS.aspx.32 Report Saving As33 Id.
on or furnish
”30 The CSL
icit, sell, neg
he contracto
s).”31 SoCal
tion in accor
oCalGas is g
HIS Registr
The CG.Meas
ORA propose
on plan for ea
ntation Plan
asures in the
it finds that S
wly propose
While ORA i
ons or even
ntation Plan
ext of propos
nia Business ainfo.legislaturwebsite at: w.cslb.ca.gov. of The Officessistance Prog
hing of home
LB website s
gotiate or exe
r’s normal p
lGas believe
rdance with C
generally op
ation proces
Commissionure Introdu
es in its testim
ach of these
n describing t
program. “32
SDG&E has
ed measures.
is free in its t
to propose a
ns (“PIPs) tha
sing every ne
and Professiore.ca.gov/face
v/Contractors/
e of Ratepayegram (ESA) A
e improveme
states that re
ecute home i
place of busin
es the work o
CSLB requir
pen to workin
ssing delays
n Should Nouction, Othe
mony “The
[proposed n
the evaluatio
2 ORA recom
s “made ques
.
testimony, a
alternative es
at were that
ew measure
ons Code, Chaes/codes_disp
/Applicants/H
er Advocates oApril 27, 201
MA/HY-13
ent goods or
egistration of
improvemen
ness (regard
of its contrac
rements.
ng with its c
while compl
ot Adopt Timer Than As
Commission
new] measur
on, and asso
mmends this
stionable ass
as it has done
stimates of s
were applica
may inhibit
apter 9, ArticplaySection.xh
Home_Improv
on The Conso5, K.C. Watt
3
r services, or
f a HIS with
nt contracts f
dless of the d
ctors’ Outrea
ontractors an
lying with C
me-ConsumDictated by
n should requ
res, and to fi
ciated budge
s additional a
sumptions ab
e, to call into
savings, the
able for pilo
beneficial p
le 10, Sectionhtml?lawCod
vement_Regi
olidated Procts-Zagha and
r swimming
h the CSLB i
for a license
dollar amoun
ach Speciali
nd exploring
CSLB require
ming Procedy Specific N
quire SDG&E
le a Program
et, before int
administrativ
bout the sav
o question S
introduction
ot proposals a
program enh
n 7152. de=BPC§
istration/Befo
eedings RegaLouis Irwin,
pools, spas,
s required if
ed contractor
nt of those
sts requires H
g ways to
ements.
dures For Neew Criteria
E to develop
m
troducing th
ve process
ings values”
DG&E’s
n of Program
and applied
ancements.
tionNum=715
ore_Applying_
arding Energywitnesses, at
, or
f
r
HIS
ew a
p an
hese
”33
m
in
52.
_For_
y p.37.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18 19
20
21
Developi
Efficienc
measure
requirem
negative
to move
failed to
O
more flex
Letter pro
Group.34
SoCalGa
fulfill the
following
TURN’s
F
introduct
H
T
SoCalGa
34 Prepare22. 35 Prepare3.
ing and filin
cy programs
level (it is d
ments that tak
ramification
forward with
meet specifi
Other parties,
xibility to m
ocess for int
On the con
as believes th
e spirit of the
g the impact
proposal is
or the above
tion should n
SoCaH.FAU
TURN “stron
as.”35 SoCal
ed Testimony
ed Testimony
g detailed ev
outside of th
done by prog
ke additional
ns on measur
h production
ic criteria, or
, in contrast
ake changes
troducing ne
ndition the la
his to be a pr
e ORA reque
t evaluation t
further discu
e reasons, OR
not be adopte
lGas AnticiProposal
ngly supports
Gas appreci
of Cynthia K
of Cynthia K
valuation and
he low incom
gram). PIP d
l time, and li
re developer
n of their pro
r that the cur
to ORA’s re
s mid-cycle.
ew measures
atter step can
referable app
est. Informa
to be conduc
ussed in the
RA’s propos
ed at this tim
ipates Very
s the additio
ates TURN
K. Mitchell, Su
K. Mitchell, Su
MA/HY-14
d PIPs, a pra
me environm
development
ikely add a le
rs and suppli
oducts. ORA
rrent approac
ecommendat
For example
after confer
n be done in
proach for tim
ation regardi
cted for each
testimony of
sal to require
me.
Few “Stand
n of HE FAU
and other pa
ubmitted on B
ubmitted on B
4
actice more i
ment, is typic
t, submission
evel of unce
iers who mu
A has not dem
ch ought to b
tion, made p
e, TURN req
rring with a M
a timely ma
mely measu
ing new mea
h program cy
f witness Re
e the develop
dard” FAU
U furnaces a
arty support
Behalf of The
Behalf of The
in line with
cally not don
n and approv
ertainty, whic
ust decide wh
monstrated th
be changed.
proposals to a
quested a Ti
Mid-Cycle W
anner (e.g., w
ure introducti
asures will a
ycle. SoCalG
endler.
pment of PIP
Installation
as a measure
for this prop
e Utility Refo
e Utility Refo
Energy
ne solely at t
val will intro
ch can have
hether and h
hat SDG&E
accommodat
er 2 Advice
Working
within 30 day
ion, and can
also be availa
Gas’ suppor
Ps for measu
ns Under HE
e by
posal While
orm Network,
orm Network,
the
oduce
ow
E has
te
ys),
n
able
rt for
ure
E
e
at p.
at p.
MA/HY-15
acknowledging there are instances that the HE FAU is not feasible, but a new standard FAU 1
furnace is still desirable, TURN asks that SoCalGas be required “to provide a specific 2
justification for each instance in which a standard FAU furnace is installed for health, safety, and 3
comfort reasons, instead of a HE furnace.”36 4
HE FAU furnaces have specific technical installation requirements that cannot always be 5
met. In particular, these relate to venting and condensate drain. SoCalGas anticipates these 6
cases will be very few. In general, the location of an existing FAU can be such that the PVC 7
venting or condensate drain, required for HE but not for standard FAUs, cannot be physically 8
accommodated either at all, or without incurring substantial additional costs. In such cases the 9
only way of moving forward with a new HE FAU would be to install it in a different location 10
than the existing FAU, or incur additional parts and labor costs which in most cases would be 11
prohibitively expensive. SoCalGas does not intend to offer the measure in such instances. 12
Instances involving these particular technical issues, which may be uncommon, are the only ones 13
SoCalGas foresees in which a “standard” FAU would be installed in lieu of an HE FAU. Such 14
instances would be recorded by SoCalGas with justification details, and are subject to audit by 15
the CPUC. Other than in these cases, SoCalGas’ proposal is to no longer replace furnaces with 16
standard FAUs. 17
SoCalGas believes the above discussion of the specific scenarios where a standard FAU 18
replacement would be necessary responds to TURN’s interest in justification, and provides the 19
Commission useful additional detail. If TURN’s testimony is meant to propose an ongoing 20
reporting requirement for each individual case encountered, SoCalGas opposes this proposal. 21
Such a requirement would be burdensome and unnecessary because SoCalGas’ regular monthly 22
36 Id. at pp. 3 – 4.
1
2
3
4
5 6 7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
and annu
because,
audit. Fo
in SoCalG
I.
T
thermost
interprets
previousl
that have
customer
Go-Back
ten years
thermost
feasible m
and wate
return to
spout me
measure,
2020 pro
37 Testimo38 Prepare39 Prepare
ual reports w
as mentione
or these reas
Gas’ Applic
SoCa.PreviRules
The testimony
atic tub spou
s the Joint Pa
ly treated ho
e never recei
rs not treated
k Rule so as t
s (but were tr
atic tub spou
measures in
er savings be
homes soon
easure. Notw
returning to
ogrammatic i
ony of Amy Ded Direct Tested Direct Test
will differenti
ed above, the
ons, SoCalG
cation and tes
lGas Shouldously Treat
s
y of Joint Pa
ut measure s
arties testim
omes as well
ved ESA Pro
d since 2002
to treat hom
reated in or a
ut measure to
its Program.
enefits of this
ner than wha
withstanding
o these home
initiative.
Dryden on behtimony of Dantimony of Ma
iate HE FAU
e specific ca
Gas’ HE FAU
stimony.
d Not Be Reted Homes O
arties witnes
should be ado
mony as propo
l as homes ye
ogram servic
. In its App
es if the resi
after 2002).3
o these prev
. Although S
s measure in
at the Go-Bac
the cost effe
es would div
half of the NRniel J. Rendle
ark Aguirre an
MA/HY-16
U as a new m
ses will be r
U measure p
equired To IOther Than
s Dryden sta
opted for “n
osing that th
et to be treat
ces, the IOU
lication, SoC
idence has no
38 This mean
iously treate
SoCalGas ha
n its Applicat
ck Rule allow
ectiveness of
vert resource
RDC, NCLC,er dated Novend Hugh Yao
6
measure from
recorded by
proposal shou
Install the Tn As Allowed
ates that SoC
new and exist
his measure b
ted. Current
Us are require
CalGas prop
ot received m
ns that SoCa
ed customers
as outlined t
tion,39 SoCa
ws solely to
f returning to
es away from
, and the CHPember 18, 201 dates Novem
m other furna
SoCalGas an
uld be adopt
Thermostatd Under Pr
CalGas’ prop
ting projects
be available
tly, in additi
ed to provid
poses to retur
measures wi
alGas would
s in addition
the significan
alGas disagre
install the th
o a home to
m SoCalGas
PC, at p. 26. 14, at pp. 10-
mber 18, 2014
ace activity,
nd subject to
ted as descri
tic Tub Spouogram Go-B
posed
s.”37 SoCalG
for all
on to custom
de measures t
rn to the 10-
ithin the prev
d offer the
n to all other
nce of the en
ees that it sh
hermostatic
provide one
meeting the
12. 4, at p. 108.
and
o
ibed
ut In Back
Gas
mers
to
-Year
vious
nergy
hould
tub
e
1 2 3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
J
M
not curre
enforcem
immigrat
‘hidden c
N
or “hidde
challenge
“undocum
current a
detail to u
train “loc
organizat
large com
(Commu
value of u
is an esta
A
three-me
40 Testimo41 Id., at p42 Testimo
THE .CUSTUSEF
Menten hypo
ently served d
ment of existi
tion enforcem
community’
Nevertheless,
en” commun
es that SoCa
mented resid
pplication, S
understand t
cal trusted m
tions within
mponent of S
unity Help an
using local C
ablished part
Aside from th
asure minim
ony of Marin p. 8. ony of Marin
MARIN CLTOMER TAFUL INFOR
thesizes that
due to the re
ing health an
ment actions
of individua
, the MCE P
nities. Many
alGas has als
dent may fea
SoCalGas ha
the role of im
messengers fr
the commun
SoCalGas’ e
nd Awarenes
CBO’s. Thu
t of the exist
he concerns
mum and the
Clean Energy
Clean Energy
LEAN ENEARGET IS NRMATION
t many “low
esident or ow
nd safety cod
s. The reside
als...”40
Pilot does not
y of the chall
so identified.
ar providing
as requested
mmigration s
rom existing
nity. Commu
xisting and c
ss of Natural
us, the recogn
ing outreach
on how to im
“rule that a
y, at p. i.
y, at p. 15.
MA/HY-17
ERGY PILONOT UNIQ
w-income sing
wner anticipa
de violations
ents and own
t offer uniqu
lenges that th
. For exampl
any persona
funding to s
status as a ba
g CBOs...”42
unity-Based
current outre
l Gas and El
nition and d
h approach.
mprove com
single measu
7
OT APPROAQUE AND U
gle-family a
ating negativ
s, privacy in
ners of these
ue solutions
he MCE Pilo
le, Menten s
al or income
study this pa
arrier to outr
Yet SoCalG
Organizatio
each. Moreo
lectricity Ser
deployment o
mmunity outre
ure cannot b
ACH TO RUNLIKELY
and multifam
ve consequen
nfringements
e homes are
for outreach
ot purported
suggests that
information
articular issu
reach. The M
Gas also dep
ons (“CBOs”
over, the CH
rvices) demo
of “local trus
each, Mente
be revised un
REACHINGY TO REND
mily homes a
nces, such a
s, and
members of
h to hard-to-r
dly addresses
t an
n...”41 In the
e in greater
MCE Pilot w
ploys trusted
”) represent a
HANGES pil
onstrates the
sted messeng
en argues tha
ntil ten years
G ITS ER
are
s
f a
reach
s are
e
would
d
a
lot
gers”
at the
s
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15 16 17
18
19
20
21
22
after it w
concern,
recomme
T
program
example,
by levera
eligibility
would be
savings a
suggest a
T
testimony
in achiev
K
T
(“NCLC”
parties”)
the Energ
LINC Ho
43 I44 I45 I46 T
was installed”
the MCE pi
ended a simi
The MCE Pil
and do not d
, the MCE p
aging “additi
y exists”,45 b
e scalable an
account for “
a large-scale
The rationale
y, but the pr
ving its objec
UTILK.PROPMUL
The natural re
”) and califo
submitted te
gy and Clim
ousing; Lind
Id., p. 10. Id., p. 10. Id., p. 17. Testimony of
” can “creat
lot would us
lar tactic in
lot also prop
demonstrate
ilot propose
ional funding
but the testim
nd workable
“matching” a
implementa
that Menten
oposed pilot
ctives.
LITIES SHOPERTY OWTIFAMILY
esources def
ornia housing
estimony fro
ate program
dsay Robbins
Marin Clean
e barriers to
se “an owner
its applicatio
oses ideas th
a feasible w
s “to alleviat
g sources fo
mony provid
on a statewi
and “incentiv
ation.
n provides fo
t, as presente
OULD BE FWNER ANDY PROPERT
fense counci
g partnership
om the follow
m of the NRD
s, an indepen
Energy, at p.
MA/HY-18
accessing p
r or manager
on.
hat are widel
way to expan
te” the landl
r health and
es no reason
de level. Li
vizing the fa
or the MCE
ed, does not
FREE TO WD TENANT TIES
l (“NRDC”)
p (“CHPC”)
wing witness
DC; Samara L
ndent consul
21.
8
program serv
r affidavit.”4
ly divergent
nd to a large-
lord’s fear of
d safety upgra
nable expecta
ikewise, the
amily’s own
Pilot reinfor
lend itself to
WORK WITTO ACHIE
), national co
together (he
ses: Maria S
Larson, Dire
ltant to the N
vices.”43 To
44 SoCalGas
from the ex
-scale implem
f health and
ades where m
ation that su
proposal to
energy savi
rces much of
o assisting th
TH BOTH TEVE ENRO
onsumer law
ereafter refer
Stamas, Proje
ector of Sust
NRDC; Davi
address this
s has also
xisting ESA
mentation. F
safety viola
mutual prog
uch a solution
establish a
ngs”46 does
f SoCalGas’
he ESA prog
THE OLLMENT I
w center
rred to as “jo
ect Attorney
tainability fo
id Hepinstal
s
For
ations
gram
n
not
gram
IN
oint
y in
or
l,
MA/HY-19
Executive Director of the Association for Energy Affordability (AEA); and John Wells, Vice 1
President of Real Estate & Energy Services at Action for Boston Community Development 2
(ABCD). Their testimony addressed different topics that impact aspects of SoCalGas’ 3
Application regarding the ESA Program. 4
Joint Parties witness Stamas presented policy overview testimony. Larson testified 5
regarding multi-family enrollment and the Single Point of Contact (“SPOC”). Robbins testified 6
regarding best practices and specific ideas from the Program Design Guide: Energy Efficiency 7
Programs in Multifamily Affordable Housing; Hepinstall testified on “New York’s federal, state, 8
and utility efficiency programs . . .”,47 and Wells testified on his work in Boston, Massachusetts 9
and the surrounding region. 10
Taken in the aggregate, SoCalGas welcomes case studies and best practices. 11
Nevertheless, SoCalGas does not believe the Joint Parties’ testimony successfully argues for any 12
radical departure from SoCalGas’ marketing outreach for the ESA Program. Where states or 13
studies have identified intriguing approaches, these can be studied by a Working Group if the 14
Commission finds value in further exploration. 15
SoCalGas diverges with Stamas’ testimony’s support for working “directly with building 16
owners as the program participant and only directly solicit tenants for in-unit measures if 17
building owners are unresponsive”.48 Even if one were to be inclined towards Stamas’ approach, 18
she does not demonstrate that there is an existing infrastructure to market to building owners 19
exclusively. It would be needlessly disruptive to eliminate outreach to the individual tenants 20
without a demonstrated channel and capacity to reach the building owner. 21
47 Direct Testimony of NRDC (Robbins), Exhibit 6, at p. 3. 48 Direct Testimony of NRDC (Stamas), at p. 23.
MA/HY-20
Although SoCalGas objects to Stamas’ restriction of outreach, SoCalGas welcomes 1
increased outreach; thus, SoCalGas supports Stamas’ emphasis on marketing directly to the 2
building owner. SoCalGas is requesting resources to fund the Single Point of Contact (SPOC) 3
role to enhance outreach to building owners. The SPOC has support in Larson’s testimony, 4
where he points out, “The energy efficiency programs have different administrators and different 5
rules . . . We need the SPOC to help us sort this out, and coordinate program delivery so the 6
energy efficiency systems work together properly. An effective SPOC will maximize the energy 7
efficiency gains, and minimize the service delivery visits experienced by multifamily owners and 8
tenants” (p. 8). In addition, the SPOC will coordinate and facilitate ESA Program contractor 9
visits to minimize disruptions to building owners and tenants. SoCalGas will also leverage the 10
lessons learned and best practices from a demonstration project 49 utilizing SPOC for multifamily 11
buildings. 12
Currently, the ESA Program is promoted to both single-family and multifamily residents. 13
Currently, SoCalGas markets to both the tenant and the building owner. In its application, 14
SoCalGas proposes to enhance marketing to the building owner by implementing a single point 15
of contact program for the building owner while also continuing its marketing to individual 16
tenants. Thus, Stamas’ testimony suggests an unnecessarily restrictive approach. Even if one 17
favors outreach to the building owner, the testimony does not prove why such outreach should be 18
to the exclusion of outreach to the individual tenant. 19
49 Low-Income Oversight Board in July 10, 2012 presentation on Integrated Multifamily Demonstration Project.
1 2
3
4
5
6
7
8
9
10
11 12
13
14
15
16
17
18
19
20
L
In
relating t
allow the
S
effectiven
timing of
coincides
Commiss
M
S
furnace.5
less than
Applicati
according
which is
furnace m
same app
50 The TesMaravilla13. 51 Prepare52 There aPrograms
SoCaL.The T
n the testimo
to the Cost-E
e IOUs to im
oCalGas res
ness, will be
f when final
s with the an
sion regardin
SoCaM.Claim
oCalGas pro
51 Furnaces w
, or equal to
ion, the estim
g to the curr
equal to an
measures, En
proach when
stimony of Jaa Foundation,
ed Direct Testare limited exc, and unique T
lGas ShouldTime Of The
ony of TELA
Effectivess W
mplement the
spectfully no
e available at
data is avail
nnual report
ng the timing
lGas Shouldm Therm Sa
oposed in its
will only be
an annual fu
mated annua
rent practice
80 AFUE ra
nergy Efficie
n estimating
ames Hodges and the Asso
timony of Maceptions to thTo-Code pilo
d Continue e Annual R
ACU, Marav
Working Gro
eir programs
otes that the 2
t the time of
lable, and th
filing date.
g for reportin
d Use The Navings For H
s Application
eligible to r
uel unit effic
al savings pe
-- as the inc
ating. In the
ency general
savings in it
on behalf of Tociation of Ca
ark Aguirre anhis practice, suot programs.
MA/HY-2
To Report Aeport Filing
villa, and AC
oup, and also
and report r
2016 ESA P
f the 2016 an
he time requi
SoCalGas a
ng results re
Next ImpactHE FAU Fur
n to replace c
receive a HE
ciency (“AFU
er installed H
cremental sav
Energy Effi
lly claim sav
ts application
The East Losalifornia Com
nd Hugh Yaouch as saving
1
Annual Cosg.
CCES, witne
o recommend
results at the
Program resu
nnual report,
ired to run th
asks that any
eflects this co
t Evaluationrnaces
certain furna
E FAU furna
UE”) rating
HE FAU furn
vings above
iciency prog
vings above
n.
Angeles Commmunity and E
, dated Novemgs attributed to
st-Effective
ss Hodges a
ds that the C
e end of 2016
ults, includin
, which is M
he cost-effec
recommend
onsideration
n Study To
aces with a H
ace if the cur
of 65. For t
nace was cal
a furnace al
grams, for rep
code.52 SoC
mmunity UniEnergy Servie
mber 18, 201o the Codes a
ness Result
ddresses ma
Commission
6.50
ng cost-
May 1, 2017.
ctiveness mo
dation from t
n.
Estimate A
HE FAU
rrent furnace
the SoCalGa
lculated
lready at cod
place on bur
CalGas took
on (TELACUes (ACCES), p
4, at pp.108 –and Standards
s At
atters
The
odels,
the
nd
e is
as
de,
rnout
the
U), the page
– 110. s
1
2
3
4
5
6 7
8
9
10
11
12
13
14
15
16
17
18
19
O
Furnaces
with ORA
Evaluatio
from this
N
O
in the cos
T
model th
compreh
costs of p
model.
S
water sav
applicabl
currently
their resu
53 Prepare16. 54 Prepare10. 55 Order InInvestor O
ORA recomm
s only to thos
A, and recom
on study, wh
s measure.
SoCaN.Calcu
ORA recomm
st-effectiven
There is a wa
at reflects sa
ensive appro
providing wa
oCalGas agr
vings (in the
le; however,
y working on
ults for appli
ed Direct Test
ed Direct Test
nstituting RulOwned Utiliti
mends this es
se dwellings
mmends the
hich does a p
lGas Shouldulating Cost
mends that U
ness tests.54
ater/sewer sa
avings on wa
oach in calcu
ater to custo
rees with OR
form of wat
this is a com
n this issue o
icability.
timony of Off
timony of Off
lemaking intoes and Water
stimate shou
s that have fu
therm savin
pre/post billin
d Claim Wat-Effectiven
Utilities shou
avings partici
ater bills. Th
ulating water
mers is not a
RA that the I
ter conserva
mplicated tas
of water savin
fice of Ratepa
fice of Ratepa
o Policies to Pr Sector to Pro
MA/HY-22
uld be adjuste
urnaces at or
ngs for HE fu
ng analysis a
ater Savingsess
ld account fo
ipant benefit
his water sav
r savings and
accounted fo
IOUs should
ation and ene
sk. The Wat
ngs, and onc
ayer Advocat
ayer Advocat
Promote a Paromote Water-
2
ed since SoC
r below 65 A
urnaces be es
and therefor
s As A Non-
for the water
t calculated
vings estima
d should be
or in the curr
d be able to r
ergy reductio
ter-Energy N
ce completed
tes, dated Ap
tes, dated Ap
rtnershop Fra-Energy Nexu
CalGas plans
AFUE.53 SoC
stimated in t
re will estima
-Energy Ben
r savings of w
in the non-e
ation does no
updated. Fu
rent non-ene
reflect the be
on) for all m
Nexus proce
d, SoCalGas
pril 27, 2015,
pril 27, 2015,
amework betwus Programs (
s to limit HE
CalGas agre
the next Imp
ate total sav
nefit When
water measu
energy benef
ot take a
urther, avoid
ergy benefits
enefits of tot
measures
eeding55 is
s will review
at p. 13, lines
at p. 44, lines
ween Energy (R.13-12-011
E
ees
pact
ings
ures
fits
ded
s
tal
w
s 15-
s 8-
).
1
2
3
4
5
6 7
8
9
10
11
12
13
14
15
16
17
18
19
20
In
(“EM&V
SoCalGa
Income P
Energy N
O
In
measures
mentions
solution.5
A
some of t
should be
Commiss
Programs
administr
miss actu
populatio
demograp
56 Prepare128. 57 Prepare26.
n its Applica
V”) study titl
as proposes t
Programs co
Nexus procee
ImpaO.Energ
n its testimon
s, rather than
s using the D
57
Although SoC
the instabilit
e understood
sion Staff. S
s will be mo
rative work
ual changes o
on and low-i
phics (i.e., h
ed Direct Test
ed Direct Test
ation, SoCalG
led “Equity C
that the scop
st-effectiven
eding.
ct Evaluatiogy Savings
ny, ORA rec
n changing s
Database of E
CalGas appr
ty of energy
d that DEER
SoCalGas is
ore stable, an
of unknown
of a targeted
income popu
household siz
timony of Ma
timony of Off
Gas propose
Criteria and
pe of the stud
ness tests, wh
on Studies S
commends th
avings estim
Energy Effic
eciates the s
savings curr
R values are u
not convinc
nd may result
value. Mor
d low-income
ulations may
ze) that do n
ark Aguirre an
fice of Ratepa
MA/HY-23
es an Evaluat
Non-Energy
dy address ho
hich include
Should Be U
he utilities u
mates with ea
cient Resourc
sentiment exp
rently estima
updated acco
ed that relian
t in complex
re fundamen
e population
y have differe
not correspon
nd Hugh Yao
ayer Advocat
3
tion, Measur
y Benefits Ev
ow to includ
es reviewing
Used As The
utilize a cons
ach new prog
ces (“DEER
pressed by O
ated through
ording to the
ance upon DE
xities that lea
ntally import
n. DEER est
ent energy u
nd with the g
, dated Novem
tes, dated Apr
rement and V
valuation Jo
de water savi
the results o
e Primary S
sistent range
gram applica
R”) values as
ORA for see
h Impact Eva
e determinat
EER for Low
ad to additio
tant, DEER e
timates repre
uses, practice
general popu
mber 18, 201
ril 27, 2015, a
Verficiation
oint Study.”56
ings in the L
of the Water
Source For
of savings p
ation, and O
a possible
eking to remo
aluations, it
ion of
w Income
onal
estimates wo
esent the gen
es and
ulation. Furt
4, at pp. 127
at p. 45, lines
6
Low
r-
per
ORA
ove
ould
neral
ther,
–
23-
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
a billing
represent
P
S
issues wi
Evaluatio
reliability
program.
In
consultan
effective
means to
SoCalGa
18 month
and impr
can learn
statistica
T
input into
of these s
the upcom
58 Prepare59 Id., Exh
analysis, wh
tation of how
ImpaP.
oCalGas lar
ith the prior
ons, and will
y, consistenc
.
n particular,
nts to collect
impact eval
o project imp
as’ proposed
hs will also a
rovements. I
n from prior
l techniques
The current p
o the studies
studies, and
ming Impact
ed Direct Testhibit 1, at p. 4
hich is comp
w energy usa
ct Evaluatio
rgely agrees
Impact Eval
l continue to
cy and overa
SoCalGas a
t better data,
luations that
pacts due to c
timeframe o
allow for mo
In its testimo
evaluations
to improve
process by w
s should allow
SoCalGas w
t Evaluation
timony of Off4.
leted as part
age changes
ons Should
with ORA’s
luations.58 S
o provide exp
all predictive
agrees that a
, use a variet
can not only
changes in p
of initiating t
ore realistic r
ony, SoCalG
and would b
our knowled
which the util
w for ongoin
welcomes the
.
fice of Ratepa
MA/HY-24
t of the Impa
before and a
be Improve
s assessment
SoCalGas rec
pert technica
e quality of t
longer time
ty of approac
y address rel
program or c
the study in
reviews of d
Gas maintain
benefit from
dge and und
lities, the Co
ng improvem
ese suggestio
ayer Advocat
4
act Evaluatio
after particip
ed
t and position
cognizes lim
al input wher
the Impact E
frame will b
ches to syste
liability of re
hanges in ta
2015 and co
draft results a
ned its positio
more rigoro
derstanding o
ommission an
ments in accu
ons as part o
tes, dated Apr
on Studies is
pating in the
n regarding
mitations of t
re possible t
Evaluations f
be beneficial
ematically an
esults, but al
argeting of th
onducting it
and any need
on that futur
ous attention
of ESA impa
nd external p
uracy, reliab
of developing
ril 27, 2015, a
s a more accu
ESA Progra
some of the
the prior Imp
to improve th
for the ESA
l for allowin
nalyze data f
lso provide
he program.
over a span
ded modifica
re evaluation
n to some of t
act results.59
parties provi
bility and val
g and execut
at pp. 49-57.
urate
am.
pact
he
ng
for
of
ation
ns
the
ide
lidity
ting
1 2
3
4
5
6
7
8
9
10 11
12
13
14
15
16
17
18
19
20
21
22
Q
In
results.
T
expertise
with IOU
non-biase
are invol
R
T
program
and asser
approach
from that
surveys w
based on
informati
many fac
the cost w
impact ev
The EQ.Lead
n its testimon
The Commiss
e on EM&V
U staff involv
ed results. T
ved. SoCalG
Non-ER.Evalu
The testimony
non-energy
rts that this c
h for several
t of the impa
with large str
data already
ion that can
ctors describ
would be “re
valuation du
Energy DiviEM&V Stu
ny, MCE pro
sion’s Energ
practices. C
vement and p
This process
Gas recomm
Energy Benuation
y of Lisa Sk
benefits (“N
can be done
reasons. Th
act evaluatio
ratified samp
y collected b
support the
ed above, as
elatively sma
ue to the larg
sion And Ioudies
oposes a pilo
gy Division (
Currently, low
public input
allows inpu
mends this pr
nefits Should
kumatz on be
NEBs”) be re
“for a relativ
he methodolo
on. The NEB
ples, while t
by the IOUs.
non-energy
s well as tim
all,” and in f
ge samples re
MA/HY-25
ous Along W
ot program t
(“ED”) and t
w-income E
. A consulta
ut from all re
rocess contin
d Not Be Es
ehalf of NRD
e-estimated a
vely small co
ogy for estim
Bs study wou
the impact ev
The Impac
benefit estim
me and budge
fact would li
equired to ob
5
With Public
that includes
the four IOU
EM&V studie
ant is hired t
elevant partie
nue for any f
stimated Sol
DC, NCLC,
as part of the
ost.” SoCal
mating NEB
uld likely inv
valuation is
ct Evaluation
mates, but th
et. In additio
ikely be simi
btain represe
Input Shou
s a final repo
Us have dedi
es are manag
to conduct st
es and a vari
future EM&V
lely Throug
and CHPC s
e regular imp
Gas disagree
s is significa
volve detaile
typically a b
ns may be ab
his will be de
on, SoCalGa
ilar to the co
entative resu
uld Continue
ort with EM&
icated staff w
ged by the E
tudies to ens
iety of exper
V studies.
gh An Impac
suggests that
pact evaluati
es with this
antly differen
ed customer
billing analy
ble to provid
ependent on
as disagrees t
ost of doing t
ults.
e To
&V
with
ED,
sure
rts
ct
t
ions
nt
r
sis
de
that
the
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
SIV.
M
Californi
Custome
I j
supply, r
managing
including
term supp
efficiency
Assistanc
I
2011. My
the day-t
Gas Com
I
Los Ange
of Southe
I ha
TATEMEN
My name is M
ia, 90013. I a
r Programs M
joined SoCa
egulatory af
g marketing
g energy effi
ply agreeme
y programs;
ce Program.
assumed my
y principal r
o-day oversi
mpany.
hold a Bach
eles and a M
ern Californ
ave not prev
NT OF QUA
Mark Aguirr
am employe
Manager for
alGas in 198
ffairs and low
and sales fo
iciency prog
ents; providin
and managi
y current pos
esponsibiliti
ight of the E
helors Degree
Master of Bus
ia.
iously testifi
ALIFICATI
e. My busine
d at Souther
r the Energy
4 and have h
w-income en
or SoCalGas
ram implem
ng policy an
ing and direc
sition manag
ies include
Energy Savin
e in Chemic
siness Admi
ied before th
MA/HY-26
IONS OF M
ess address i
rn California
Savings As
held manage
nergy efficien
’ largest com
mentation; ad
nd regulatory
cting the day
ging the Ener
ngs Assistanc
al Engineeri
nistration in
he Commissi
6
MARK AGU
is 555 W. Fi
a Gas Compa
sistance Pro
ement positio
ncy. My wo
mmercial and
dministering
y support for
y-to-day acti
rgy Savings
ce Program
ing from the
n Marketing/
ion.
UIRRE
ifth Street, L
any (“SoCal
ogram.
ons in marke
ork experienc
d industrial c
SoCalGas’ m
r SoCalGas’
ivities of the
Assistance
for the South
University
/Finance from
Los Angeles,
Gas”) as the
eting, sales,
ce has includ
customers
mid and long
energy
e Energy Sav
Program in
hern Califor
of California
m the Unive
,
e
gas
ded:
g
vings
July
rnia
a,
ersity
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
SV.
M
Californi
Assistanc
Income P
and lever
I j
in the fol
Commer
2009 and
well as o
of Scienc
Administ
Engineer
I
TATEMEN
My name is H
ia, 90013. I a
ce Programs
Program Mar
raging effort
joined SoCa
llowing area
cial & Indus
d have been c
ther program
ce degree in
tration degre
r in the State
have not pre
NT OF QUA
Hugh Yao. M
am employe
s Manager. M
rketing and
ts.
alGas in 199
s: Gas Engin
strial Market
continuously
ms such as M
Chemical E
ee from USC
e of Californi
eviously test
ALIFICATI
My business
d at Souther
My principal
Outreach for
6 and have h
neering, Gas
ting and Cus
y involved w
Medical Base
ngineering f
C in 2003. I a
ia.
tified before
MA/HY-27
IONS OF H
address is 55
rn California
responsibili
r the CARE
held numero
s Storage Op
stomer Assis
with supporti
eline and Ga
from UCLA
am also a reg
the Commis
7
HUGH YAO
55 W. 5th St
a Gas Compa
ities are to m
and ESA Pr
ous positions
perations, Ma
stance. I join
ing CARE an
as Assistance
in 1996 and
gistered Pro
ssion.
O
treet, Los A
any as a Cus
manage SoCa
rogram, inclu
s of increasin
ajor Markets
ned Custome
nd ESA Pro
e Fund. I ear
d a Master of
fessional Me
ngeles,
stomer
alGas’ Low-
uding integr
ng responsib
s Strategy,
er Assistance
gram goals,
rned a Bache
f Business
echanical
-
ration
bility
e in
as
elor