Regulatory Policy Activity and Resources
CPUC Seeks Party Comments On SW and 3P Programs by Friday, June 17th
On May 24th, 2016, CPUC Administrative Law Judge (ALJ) Julie Fitch issued a ruling seeking parties’ input on several potential program delivery changes to the statewide and third-party offerings in the California Public Utilities Commission’s (Commission) energy efficiency portfolios. The ruling includes 28 questions related to several conceptual proposals presented in the ruling.
Comments are due by Friday, June 17, 2016.
Complete Ruling, conceptual proposals, and related questions
The Ruling, in response to SB350 and previous workshops in 2015, presents CPUC-developed proposals for potential approaches to addressing both statewide and third-party program requirements. Those proposals are presented in this ruling. The Commission seeks input on whether to implement some or all aspects of the proposals. We strongly recommend that you read the full 17-page ruling for details that were omitted here to preserve brevity of these summaries.
The Statewide Proposals:
The Third-Party Proposals:
OPTION 1: Eliminate the 20% third-party requirement and allow IOUs to choose freely how to allocate program delivery responsibilities between utility personnel and third-parties.
OPTION 2: Require that all program delivery for the commercial sector, not only for statewide programs but also for local and regional programs, be handled by third-parties, with exceptions to be considered by the Commission.
Why Does This Matter to You?
This ruling seeks comments on the options outlined above as well as 28 questions located in the ruling. The comments provided through this process will shape the future of Statewide and 3rd party programs, directly impacting how HVAC will be handled in California’s future energy efficiency program framework, beginning as early as 2017.
Many stakeholders believe that true “statewide-ness” is the best way to eliminate barriers to customer participation and reduce administration costs by creating a single program across the state that will improve accessibility and economies of scale. Many others believe that a statewide program may not be well equipped to handle local and regional differences throughout the state, thereby creating barriers and added costs for those local or regional participants.
As stated above, a set of statewide “subprogram” categories are proposed, to be treated as statewide under the proposed statewide definition. Specifically called out in the Statewide Proposals are HVAC Residential and Commercial Upstream subprograms. Subprograms that are not specifically HVAC, but may include HVAC as a component are Residential New Construction, Codes & Standards-Compliance Improvement, Building Code Advocacy, Emerging Technologies, Deemed and Calculated Incentives programs, as well as Integrated Pilots, Programs, and Activities.
The conversation regarding the right mix of program administration parties is as old as the energy efficiency industry and there are as many opinions on the matter as there are participants. Some parties believe that administration of programs should be given solely to third-parties to ensure strong innovation and nimbleness, while others believe that sole administration should be handled by the IOUs to take advantage of invested costs, customer reach, and efficiencies already realized. Other parties believe that a mix, of varying proportions, be shared between the two to capitalize on the features and benefits that both administration types bring to the table.
There are a number of other significant opinions and considerations that are presented in this ruling, through communications from all parties of the proceeding, that make this ruling, and its request for your comments, particularly important.
How Do You Get Involved and Respond?
Since this is a formal proceeding, members must be Party to the proceeding. For the purpose of this proceeding, it may be easiest to file a “motion for party status” with the CPUC. If you would like to file a motion for party status, the CPUC’s Public Advisor's Office provides templates you can use to create your documents.Please click herefor templates and examples for Filing a motion for party status. Please feel free to contact me directly with any questions you may have regarding the process of becoming a party to CPUC proceedings.