Application: 22-02-
(U 39 M)
Exhibit No.:
Date: February 15, 2022
Witness(es): Various
PACIFIC GAS AND ELECTRIC COMPANY
ENERGY EFFICIENCY 2024 BUSINESS-PORTFOLIO PLAN
PG&E ENERGY EFFICIENCY 2024-2031 STRATEGIC BUSINESS PLAN
PREPARED TESTIMONY
EXHIBIT 1
-i-
PACIFIC GAS AND ELECTRIC COMPANY
ENERGY EFFICIENCY 2024 BUSINESS-PORTFOLIO PLAN
PREPARED TESTIMONY
TABLE OF CONTENTS
Chapter
Title
Witness
Exhibit 1
PG&E ENERGY EFFICIENCY 2024-2031
STRATEGIC BUSINESS PLAN
1
PG&E'S VISION FOR ENERGY EFFICIENCY IN
CALIFORNIA: 2024-2031
David Poster
2
ANNUAL PORTFOLIO BUDGETS FOR 2024-2031
Michael D. Burger
3
RECOMMENDATIONS FOR NEW OR MODIFIED
ENERGY EFFICIENCY POLICY
Caroline Massad
Francis
Attachment A
SUMMARY LIST OF POLICY CHANGES
Caroline Massad
Francis
Appendix A
STATEMENTS OF QUALIFICATIONS
Robert W. Bohn
Ben Brown
Michael D. Burger
Caroline Massad
Francis
Rebecca Madsen
David Poster
Exhibit 2
PG&E ENERGY EFFICIENCY 2024-2027
PORTFOLIO PLAN
1
PORTFOLIO SUMMARY
David Poster
2
FORECAST METHODOLOGY
Robert W. Bohn
Attachment A
PG&E ENERGY EFFICIENCY 2024-2027
PROGRAM-LEVEL ANNUAL COST VARIANCE
EXPLANATIONS
Robert W. Bohn
3
SEGMENTATION STRATEGY
Ben Brown
Attachment A
PROGRAM LEVEL AND SEGMENT LEVEL
METRICS AND TARGETS
Ben Brown
4
SECTOR STRATEGY
Michael D. Burger
Attachment A
RESIDENTIAL PROGRAM CARDS
Michael D. Burger
PACIFIC GAS AND ELECTRIC COMPANY
ENERGY EFFICIENCY 2024 BUSINESS-PORTFOLIO PLAN
PREPARED TESTIMONY
TABLE OF CONTENTS
(CONTINUED)
-ii-
Chapter
Title
Witness
Attachment B
COMMERCIAL PROGRAM CARDS
Michael D. Burger
Attachment C
PUBLIC PROGRAM CARDS
Michael D. Burger
Attachment D
AGRICULTURAL PROGRAM CARDS
Michael D. Burger
Attachment E
INDUSTRIAL PROGRAM CARDS
Michael D. Burger
Attachment F
CODES AND STANDARDS PROGRAM CARDS
Michael D. Burger
Attachment G
NEW CONSTRUCTION PROGRAM CARDS
Michael D. Burger
Attachment H
LOCAL GOVERNMENT PARTNERSHIPS
PROGRAM CARDS
Michael D. Burger
Attachment I
WORKFORCE EDUCATION AND TRAINING
PROGRAM CARDS
Michael D. Burger
Attachment J
FINANCE PROGRAM CARDS
Michael D. Burger
5
PORTFOLIO MANAGEMENT
Michael D. Burger
6
EVALUATION, MEASUREMENT AND
VERIFICATION
Caroline Massad
Francis
7
COST AND COST RECOVERY
Rebecca Madsen
Appendix A
PG&E ENERGY EFFICIENCY 2024-2027 CEDARS
FILING SUBMISSION LINKS AND RECEIPTS
Exhibit 3
PG&E'S RESPONSES, PURSUANT TO ENERGY
DIVISION TEMPLATE
1
PG&E'S ENERGY EFFICIENCY 2024-2031
APPLICATION TABLES, PURSUANT TO ENERGY
DIVISION TEMPLATE
Michael D. Burger
(PG&E-1)
PACIFIC GAS AND ELECTRIC COMPANY
CHAPTER 1
PG&E’S VISION FOR
ENERGY EFFICIENCY IN CALIFORNIA: 2024-2031
(PG&E-1)
1-i
PACIFIC GAS AND ELECTRIC COMPANY
CHAPTER 1
PG&E’S VISION FOR
ENERGY EFFICIENCY IN CALIFORNIA: 2024-2031
TABLE OF CONTENTS
A. Introduction ....................................................................................................... 1-1
1. PG&E’s Core Values .................................................................................. 1-1
2. PG&E’s Vision for EE in California ............................................................. 1-2
3. Background and Purpose of Application .................................................... 1-4
a. Summary of Request ........................................................................... 1-6
b. Support for Request ............................................................................ 1-7
c. Organization of the Remainder of This Chapter .................................. 1-7
B. Description of PG&E’s Service Territory ........................................................... 1-8
C. Principles of PG&E’s EE Portfolio .................................................................. 1-11
1. We Deliver Excellent Customer Experiences ........................................... 1-11
2. We Are Leaders in Environmental Stewardship ....................................... 1-11
3. We Are Here to Serve Our Hometowns ................................................... 1-12
D. PG&E’s EE Portfolio Goals and Desired Outcomes ....................................... 1-13
1. Portfolio Goal: Optimize Delivery of TSB ................................................ 1-15
2. Portfolio Goal: Support Economy-Wide Carbon Neutrality By 2045 ........ 1-15
3. Portfolio Goal: Shape Energy Demand to Match Supply ......................... 1-17
4. Portfolio Goal: Support Customer Resiliency .......................................... 1-19
E. PG&E’s EE Strategies for 2024-2031 ............................................................. 1-20
1. Portfolio Strategies ................................................................................... 1-20
a. Strategy #1: Deliver TSB By Meeting Customers Where
They Are ............................................................................................ 1-21
1) Offer a Diverse EE Portfolio ........................................................ 1-21
2) Design a Portfolio to Meet Customers Where They Are .............. 1-22
(PG&E-1)
PACIFIC GAS AND ELECTRIC COMPANY
CHAPTER 1
PG&E’S VISION FOR
ENERGY EFFICIENCY IN CALIFORNIA: 2024-2031
TABLE OF CONTENTS
(CONTINUED)
1-ii
3) Enhanced Digital Strategy and Personalized Customer
Journeys ...................................................................................... 1-23
b. Strategy #2: Pursue a Multi-Pronged Approach to Building
Decarbonization ................................................................................. 1-23
1) Support Electrification in Existing and New Buildings ................. 1-23
2) Technical Support and Advocacy Through C&S ......................... 1-28
3) Decarbonize through Equipment Support ................................... 1-28
c. Strategy #3: Deploy Technologies That Are Grid-Responsive and
Demand Flexible ................................................................................ 1-30
1) Align the EE Portfolio With PG&E’s Enterprise-Wide
Coordinated Supply and Load Strategy ...................................... 1-30
2) Utilize the Meter-Based Platform Throughout our Portfolio ......... 1-31
d. Strategy #4: Contribute to Cost Saving Resiliency Solutions for
Customers ......................................................................................... 1-32
1) Use EE to Reduce Customer Costs for Resiliency Solutions ...... 1-33
2) Use EE to Support Individual Customer Resiliency Solutions ..... 1-33
e. Strategy #5: Properly Value the Benefits of EE ................................ 1-33
2. Portfolio Management Strategies ............................................................. 1-34
a. Segmentation Strategy Summary ...................................................... 1-34
b. Sector Strategy .................................................................................. 1-35
c. Budget Distribution Strategy .............................................................. 1-36
d. Outsourcing ....................................................................................... 1-36
1) Strategy to Maintain Outsourcing Target ..................................... 1-36
2) Solicitation Strategies .................................................................. 1-37
e. Portfolio Coordination ........................................................................ 1-38
(PG&E-1)
PACIFIC GAS AND ELECTRIC COMPANY
CHAPTER 1
PG&E’S VISION FOR
ENERGY EFFICIENCY IN CALIFORNIA: 2024-2031
TABLE OF CONTENTS
(CONTINUED)
1-iii
3. Evaluation, Measurement and Verification ............................................... 1-39
4. Alignment of Business Plan Strategies and Outcomes With
Legislative and CPUC Requirements ....................................................... 1-39
a. Portfolio Design and Budget Alignment With Relevant Action
Plans Beyond the EE Proceeding ...................................................... 1-40
(PG&E-1)
1-1
PACIFIC GAS AND ELECTRIC COMPANY 1
CHAPTER 1 2
PG&E’S VISION FOR 3
ENERGY EFFICIENCY IN CALIFORNIA: 2024-2031 4
A. Introduction 5
In compliance with Decision (D.) 21-05-031, Pacific Gas and Electric 6
Company (PG&E) files this Energy Efficiency (EE) Application requesting an 7
authorized budget cap for its eight-year strategic business plan covering 8
program years 2024-2031, and a four-year revenue requirement request for a 9
program portfolio plan covering 2024-2027.
1
PG&E’s testimony generally aligns 10
with and responds to the prompts in the template created by the Energy Division 11
(Energy Division template), pursuant to D.21-05-031.
2
12
This Exhibit presents PG&E’s strategic business plan and annual budgets 13
for its EE portfolio for 2024-2031. This Exhibit also provides PG&E’s 14
recommendations for new or modified EE policy. 15
With PG&E’s eight-year strategic business plan as the foundation, Exhibit 2 16
presents PG&E’s four-year portfolio plan (2024-2027). 17
1. PG&E’s Core Values 18
PG&E is honored to serve nearly 16 million people across northern and 19
central California with some of the nation’s cleanest energy.
3
At PG&E, we 20
believe customer service is at the core of everything we do, and we are 21
guided by our core purpose of delivering for our hometowns, serving our 22
planet, and leading with love. PG&E’s responsibility as an energy provider 23
to our customers goes beyond our core mission of providing safe, reliable, 24
affordable, and clean energy. We believe that we have a responsibility to 25
build a better future for everyone whose lives we touch. We will measure 26
1
Assessment of Energy Efficiency Potential and Goals and Modification of Portfolio
Approval and Oversight Process, D.21-05-031, Ordering Paragraph (OP) 5, p. 81.
2
D.21-05-031, OP 6, p. 82. While PG&E generally aligns with the Energy Division
template, where necessary, PG&E includes additional information and/or integrates
similar sections . See October 20, 2021 Email from Energy Division “R.13-11-005
Energy Efficiency 2024-2031 Business Plan Templates”.
3
Information from: https://www.pgecorp.com/corp_responsibility/reports/2021/pf01_pge_
overview.html.
(PG&E-1)
1-2
our progress along three areas – focusing on how our programs impact the 1
people we serve, the planet we inhabit, and California’s prosperity. All these 2
changes are done with one focus in mind: to better serve our customers. 3
PG&E’s EE portfolio is an integral piece of protecting the environment 4
and creating a better energy future for our customers. We believe clean 5
energy should be affordable for and inclusive of all economic backgrounds. 6
Our wide range of EE programs help customers reduce their energy use and 7
save money. PG&E’s EE Application details the next generation of our EE 8
portfolio, which is positioned to deliver on these privileges. 9
2. PG&E’s Vision for EE in California 10
PG&E's vision is for EE to help keep customer energy bills affordable, 11
reduce energy demand on the grid, build customer resiliency to climate 12
change, and advance building decarbonization in California. EE is integral 13
to energy sustainability, which is why PG&E has worked for more than four 14
decades to support customer efforts to reduce energy usage. At PG&E we 15
are reaching for new heights pursuing California’s clean energy goals while 16
balancing affordability and equity. 17
EE is a key component of a much broader clean energy and building 18
decarbonization strategy for California.
4
California has passed significant 19
legislation in the pursuit of carbon neutrality,
5
including Senate Bill (SB) 100 20
(2018),
6
which requires renewable energy and zero-carbon resources to 21
supply 100 percent of total electric retail sales in California by 2045,
7
and 22
Executive Order B-55-18 calling for economy-wide carbon neutrality by 23
2045.
8
The California Energy Commission’s (CEC) 2019 EE Action Plan 24
4
Other key components include resources such as distributed solar generation and
energy storage.
5
“Carbon neutrality means that all greenhouse gas (GHG) emissions emitted into the
atmosphere are balanced in equal measure by GHGs that are removed from the
atmosphere, either through carbon sinks or carbon capture and storage.” From
Achieving Carbon Neutrality in California, Energy and Environmental Economics, Inc.
(E3), p. 1.
6
https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201720180SB100.
7
Ibid.
8
https://www.ca.gov/archive/gov39/wp-content/uploads/2018/09/9.10.18-Executive-Or
der.pdf.
(PG&E-1)
1-3
affirmed that, “energy efficiency is a key piece of California’s efforts to 1
lessen the impacts of climate change.”
9
PG&E’s 2024-2031 EE strategic 2
business plan supports the goals of zero-carbon electricity and 3
economy-wide carbon neutrality, and will work as part of the solution to 4
combat climate change through EE and building decarbonization. Exhibit 2 5
presents how PG&E plans to make progress towards overcoming these 6
challenges in 2024-2027. 7
PG&E’s EE strategic business plan for 2024-2031 is built on portfolio 8
principles, goals, and strategies that enable us to deliver on both our 9
commitments and our vision. PG&E’s three portfolio principles lay the 10
foundation for our portfolio’s goals and strategies. These principles 11
represent our portfolio’s core values that are present in all portfolio activities. 12
PG&E pursues four portfolio goals to achieve key milestones by the end of 13
2027 and 2031. These goals and their associated outcomes are 14
implemented through our portfolio’s strategies. PG&E’s five portfolio 15
strategies guide the broad implementation direction of our portfolio’s 16
activities. These strategies are key for guiding both where and how to direct 17
our portfolio’s funding. See Figure 1-1 for the overview of PG&E’s portfolio 18
principles, goals, and strategies. 19
9
CEC, 2019 California Energy Efficiency Action Plan, December 2019, p. 1.
(PG&E-1)
1-4
FIGURE 1-1
SUMMARY OF PG&E’S EE PORTFOLIO GUIDING PRINCIPLES, GOALS, AND STRATEGIES
3. Background and Purpose of Application 1
In May 2021, the California Public Utilities Commission (CPUC or 2
Commission) issued D.21-05-031 that adopted three major changes in EE 3
policy: (1) a new goals metric, Total System Benefit (TSB); (2) an approach 4
to “segmenting” EE portfolios by program purpose; and (3) a modified 5
portfolio process that requires each EE portfolio administrator (PA)
10
to file 6
an application every four years that includes a four-year detailed program 7
portfolio plan and an eight-year strategic business plan.
11
8
Moving to TSB as the new goals metric and segmenting EE portfolios by 9
program purpose can enable PAs to provide greater value to customers, 10
help achieve California’s long term climate goals and policy objectives, 11
better support equity communities, and focus EE programs on the full range 12
of benefits they can provide to the electric and gas systems. PG&E 13
10
PG&E uses the term “portfolio administrator”, rather than “program administrator”, to
refer to those administering portfolios of EE programs primarily implemented by third
parties.
11
Assessment of Energy Efficiency Potential and Goals and Modification of Portfolio
Approval and Oversight Process, D.21-05-031, pp. 2-3.
(PG&E-1)
1-5
leverages this framework to deliver on the broad portfolio goals outlined in 1
this eight-year strategic business plan. 2
TSB, defined as “the sum of the benefit that a measure provides to the 3
electric and natural gas systems,”
12
replaces energy savings and peak 4
demand goals beginning in 2024.
13
TSB expresses, in Net Present Value 5
dollars, the lifecycle energy, ancillary services, generation capacity, 6
transmission and distribution capacity, and greenhouse gas (GHG) benefits 7
of EE activities, on an annual basis.
14
TSB ties EE goals directly to the 8
avoided cost value of EE savings, capturing the benefits of saving energy 9
during high value hours of the day and year. It is also fuel agnostic and can 10
facilitate the pursuit of building electrification through fuel substitution. In 11
this application, PG&E explains how it will optimize its portfolio to deliver 12
TSB for California. 13
The second policy change directs PAs to assign programs in their EE 14
portfolios to categories, or “segments,” based on their primary purpose.
15
15
There are three segments: resource acquisition (RA), equity, and market 16
support (MS). Codes and Standards (C&S) programs are considered a 17
separate category. Cost-effectiveness requirements apply to the RA 18
segment
16
while the equity and MS segments must adhere to a budget 19
cap.
17
Because cost-effectiveness requirements apply only to the RA 20
12
D.21-09-037, Conclusions of Law (COL) 5, p. 28
13
D.21-05-031, OP 4, p. 81.
14
CPUC TSB Technical Guidance, Version 1.2, October 25, 2021, p. 1. See also p. 7:
“The ACC produces hourly avoided cost values, and the ACC output table for electric
avoided costs instructs the CET whether to use input kW or kWh values, depending
on when the energy is saved. The avoided cost rate is based on price forecasts,
measure impact profiles, climate zones, program administrator, etc. Benefits
associated with avoided kW are only accrued in peak hours, and these benefits flow
into the measure benefits calculation outputted by the CET.”
15
D.21-05-031, OP 2, p. 81.
16
D.21-05-031, OP 3, p. 81 states,
“Beginning in program year 2022, energy efficiency program administrators who are
investor-owned utilities or community choice aggregators shall ensure that the
forecasted benefits exceed the costs of the resource acquisition segments of their
portfolios, as measured by the Total Resource Cost test, without considering Codes
and Standards programs.”
17
D.21-05-031, OP 3-4, p. 81 and p. 16.
(PG&E-1)
1-6
segment, segmentation addresses the increased pressures IOUs 1
experience trying to maintain cost-effective EE portfolios “while also 2
delivering a balanced portfolio that meets all of the Commission’s numerous 3
policy objectives.”
18
PG&E continues to balance cost-effective program 4
delivery with critical policy objectives through equity and MS programs. 5
PG&E presents an EE portfolio with a RA segment that is overall forecasted 6
to achieve a cumulative Total Resource Cost (TRC) ratio greater than 1.0 for 7
each of the four-year portfolio cycles. PG&E has balanced its RA segment 8
in line with the CPUC’s expectations
19
and through the portfolio 9
management strategies discussed in section E.2 below and Exhibit 2, 10
Chapter 5, PG&E will continue to focus on cost-effective program delivery 11
through effective program performance management. See Exhibit 2, 12
Chapter 3 for PG&E’s portfolio segmentation strategy. 13
This eight-year strategic business plan provides high-level descriptions 14
of the following six areas requested by the Energy Division:
20
(1) a 15
description of PG&E’s service territory; (2) the desired outcomes for PG&E’s 16
EE portfolio; (3) major portfolio strategies to achieve the desired outcomes; 17
(4) portfolio management strategies such as portfolio segmentation, sector 18
strategies, budget distribution, outsourcing, and portfolio coordination; 19
(5) evaluation, measurement and verification (EM&V) strategies; and 20
(6) alignment with legislative and CPUC requirements and relevant action 21
plans. 22
a. Summary of Request 23
PG&E requests that the Commission approve its eight-year 24
authorized budget cap request for 2024-2031 of approximately 25
$2.8 billion, which includes two four-year portfolio cycles. The 26
18
D.21-05-031, p. 10.
19
D.21-05-031, at p. 22 in discussion regarding TRC ratio requirement of 1.0 or greater:
“This does not mean that each individual resource acquisition program must be
cost-effective on its own. Program administrators may balance their resource
acquisition programs within the resource acquisition segment of their portfolios to
ensure that the segment overall meets the 1.0 criteria.”
20
EE Business Plan and Application Template – Final from ED with EMV, received via
Energy Efficiency Proceeding Service List Rulemaking (R.) 13-11-005 on October 20,
2021.
(PG&E-1)
1-7
authorized budget cap includes approximately $566 million requested on 1
behalf of Regional Energy Networks (RENs) and Community Choice 2
Aggregators (CCAs) within PG&E’s territory.
21
3
The first four-year portfolio cycle covers 2024-2027 and includes a 4
revenue requirement of approximately $1.4 billion inclusive of 5
approximately $272.7 million requested on behalf of RENs and CCAs 6
within PG&E’s territory. See Chapter 2 for detail regarding the 7
eight-year authorized budget cap request. See Exhibit 2, Chapter 2 for 8
the 2024-2027 forecast methodology. 9
b. Support for Request 10
PG&E’s request for 2024-2031 enables PG&E to achieve 11
cumulative TSB of approximately $1.9 billion and a TRC ratio
22
for its 12
RA portfolio of 1.16. It also enables PG&E to support legislative and 13
climate priorities for California such as doubling EE and reducing GHG 14
emissions and executing on the portfolio strategies further described 15
below. Section E.4 below provides more information on the alignment of 16
PG&E’s strategic business plan with legislative and CPUC requirements 17
and relevant action plans. 18
c. Organization of the Remainder of This Chapter 19
• Section B – Description of PG&E’s Service Territory; 20
• Section C – Principles of PG&E’s EE Portfolio; 21
• Section D – PG&E’s EE Portfolio Goals and Desired Outcomes; and 22
• Section E – PG&E’s EE Portfolio Strategies for 2024-2031. 23
21
This request reflects the budget needs for 2024-2031 of RENs and CCAs approved for
PA status as of January 14, 2022. This includes Bay Area Regional Energy Network
(BayREN), CleanPowerSF, Marin Clean Energy (MCE), San Jose Clean Energy (SJCE)
and Tri-County Regional Energy Network (3C-REN). Should REN or CCA filing
budgets differ from what is provided, or should REN or CCA PA statuses change,
PG&E’s authorized budget cap request will need to be amended. PG&E’s may need to
submit supplemental or revised testimony. See Chapter 3 for PG&E’s proposal to
account for changes in REN and/or CCA PA status.
22
California Standard Practice Manual discusses TRC beginning on p. 18.
https://www.cpuc.ca.gov/-/media/cpuc-website/files/uploadedfiles/cpuc_public_website/
content/utilities_and_industries/energy_-_electricity_and_natural_gas/cpuc-standard-pr
actice-manual.pdf.
(PG&E-1)
1-8
B. Description of PG&E’s Service Territory 1
PG&E delivers some of the nation’s cleanest energy
23
to approximately 2
16 million people throughout a 70,000-square-mile service area in northern and 3
central California. There are approximately 5.5 million electric customer 4
accounts and 4.5 million natural gas customer accounts.
24
In 2021, PG&E 5
established a Regional Service Model that has five regions: 6
1) North Coast; 7
2) North Valley/Sierra; 8
3) Bay Area; 9
4) South Bay/Central Coast; and 10
5) Central Valley. 11
PG&E’s EE portfolio intends to work within these five regions to address 12
customer and community specific needs. See Figure 1-2 for PG&E’s 13
regionalization map. 14
23
About 85 percent of the electricity delivered is GHG-free. PG&E 2021 Corporate
Sustainability Report.
24
PG&E Corporate Sustainability Report, as of December 31, 2020, 4.8 million residential
and 0.7 million commercial, industrial, and other electric distribution accounts;
4.3 million residential and 0.2 million commercial and industrial natural gas distribution
accounts.
(PG&E-1)
1-9
FIGURE 1-2
PG&E REGIONALIZATION MAP
PG&E provides brief discussions on certain areas of diversity within our 1
territory that provide opportunities and challenges for the proposed EE portfolio. 2
Diversity in Income and Economic Resources 3
At PG&E, we believe clean energy should be affordable for and accessible 4
to customers of all economic backgrounds, but recognize that within PG&E’s 5
service territory, there are certain geographic areas in which customers may 6
face greater burdens to affording essential utility services. An analysis in the 7
CPUC’s 2019 Annual Affordability Report finds that these geographic areas are 8
“where utility services are currently least affordable for low-income households 9
(PG&E-1)
1-10
(as measured by AR
20
)
25
and where residents are most vulnerable to future 1
increases in essential service (as measured by SEVI).”
26
PG&E’s EE portfolio 2
provides broad opportunities to help customers reduce their energy use and 3
save money by making essential services more affordable. Pursuant to 4
D.21-05-031, PG&E’s EE portfolio includes funding for equity segment programs 5
that provide EE to hard-to-reach or underserved customers and disadvantaged 6
communities (DAC) to advance the Commission’s Environmental and Social 7
Justice (ESJ) Action Plan draft 2.0.
27
See Exhibit 2, Chapter 3, Section E for 8
the equity segment strategy. One example of an equity segment program is the 9
new Residential Equity Placeholder program that targets low to 10
moderate-income customers with certain EE and retrofit electrification solutions. 11
See Exhibit 2, Chapter 4, D.1. 12
Diversity of Geography and Terrain 13
More than half of PG&E’s service territory lies in the High Fire Threat 14
Districts (HFTD) Tiers 2 and 3 as identified by the CPUC in 2018.
28
15
Approximately 10 percent of PG&E’s electric customers
29
reside in HFTD areas. 16
PG&E’s EE portfolio can play a role to support energy resiliency particularly for 17
customers in HFTD.
30
18
25
An abbreviation for the Affordability Ratio (AR) for household in the 20th percentile of
the income distribution
26
2019 Annual Affordability Report, April 2021, CPUC, p. 10. For more information, see
the following link:
https://www.cpuc.ca.gov/-/media/cpuc-website/industries-and-topics/reports/2019-annu
al-affordability-report.pdf. Socioeconomic Vulnerability Index (SEVI): Describes the
relative socioeconomic characteristics of communities – in terms of poverty,
unemployment, educational attainment, linguistic isolation, and percent of income spent
on housing – to quantify how the same utility cost may affect one community’s ability to
pay more than another’s.
27
D.21-05-031, p. 81, OPs 2 and 4. See also ESJ Action Plan, Draft 2.0, available at:
https://www.cpuc.ca.gov/esjactionplan/.
28
Available at: https://cpuc_firemap2.sig-gis.com/ (last accessed Feb. 9, 2022). Tier 2
consists of areas on the CPUC Fire Threat Map where there is an elevated risk for
wildfires. Tier 3 consists of areas on the CPUC Fire Threat Map where there is an
extreme risk for wildfires.
29
With a “customer” defined as an electric meter or service point, each of which generally
represents at least one household or business.
30
“Energy resiliency” in this context refers to ensuring that homes, businesses, and
facilities have reliable energy.
(PG&E-1)
1-11
C. Principles of PG&E’s EE Portfolio 1
This section details the underlying principles of PG&E’s EE portfolio for the 2
years covered in this strategic business plan from 2024-2031. PG&E’s EE 3
portfolio vision is built on three guiding principles: (1) We Deliver Excellent 4
Customer Experiences; (2) We are Leaders in Environmental Stewardship; and 5
(3) We are Here to Serve our Hometowns. 6
1. We Deliver Excellent Customer Experiences 7
PG&E is focused on providing excellent customer experiences to 8
increase the overall participation and engagement in EE. PG&E will strive 9
for a portfolio of EE offerings that: 10
• Are easy to participate in; 11
• Are integrated with other energy management programs; and 12
• Provide for a more personalized and digitized customer experience. 13
Through supporting its customers, PG&E hopes to build energy 14
resiliency to climate change, reduce GHG emissions, lower customer utility 15
costs and improve grid reliability. PG&E’s EE portfolio includes plans to 16
engage customers as energy saving partners and build long-term 17
relationships to drive positive change. 18
2. We Are Leaders in Environmental Stewardship 19
PG&E embraces its role in achieving California’s goal of carbon 20
neutrality and to move to a climate-resilient economy. PG&E’s EE portfolio 21
can address climate change by both delivering solutions that help to 22
decarbonize customer’s homes and buildings and by supporting the use of 23
clean and renewable energy resources powering our electric system.
31
24
Through PG&E’s EE portfolio of energy savings measures, PG&E can 25
help reduce the overall carbon emissions of our customers’ homes and 26
businesses by permanently reducing their energy consumption. The energy 27
savings that PG&E delivers to our customers removes: 28
31
For example, shortly after filing its EE application, PG&E intends to file a separately
funded, but complementary, application for a GHG-optimized building decarbonization
offering (similar to Southern California Edison's (SCE) Clean Energy Optimization Pilot
(CEOP)).
(PG&E-1)
1-12
• Carbon emissions through both avoiding the need to generate electricity 1
through non-renewable means (such as natural gas fueled power 2
plants); and 3
• The end-use combustion of natural gas in our customer homes and 4
businesses. 5
PG&E’s EE portfolio also leverages fuel-substitution energy savings 6
measures where we can retire old, inefficient natural gas equipment. PG&E 7
can provide our customers support for high-efficiency electric equipment in 8
their place. 9
As PG&E’s electricity supply moves towards 100 percent clean and 10
renewable energy by 2045 to meet our Renewable Portfolio Standard goal, 11
we understand that energy supply availability and cost are key 12
considerations when developing and providing customer energy savings 13
products, programs, and services through our EE portfolio. PG&E’s EE 14
portfolio is working closely with other PG&E demand and energy supply 15
teams to ensure that we can offer a comprehensive Demand Side 16
Management (DSM) approach to reducing customer demand and energy 17
use and provide options to support a safe, reliable, affordable, and clean 18
energy supply. 19
3. We Are Here to Serve Our Hometowns 20
PG&E’s EE portfolio will help serve our hometowns by expanding 21
customer access with more equity-based program offerings, supporting 22
customer resiliency, and enabling the workforce of tomorrow through 23
workforce, education, and training. PG&E also believes that EE can support 24
affordability through a thoughtfully procured portfolio of programs that 25
achieve cost-savings for all customers (not only program participants). 26
Part of serving our hometowns is making sure that everyone and 27
everything is safe. Safety is embedded in everything we do. PG&E uses a 28
comprehensive safety plan for ensuring the safety of our customers, 29
contractors, and employees as we conduct energy efficiency program 30
operations. Our processes include identifying risk level rankings (Low, 31
Medium, High) based on pre-existing contractor safety standard criteria. We 32
provide additional oversight and monitoring of our contractors out in the field 33
by performing regular safety observations. In addition, PG&E is sensitive to 34
(PG&E-1)
1-13
customers’ needs during the COVID-19 pandemic and will continue to adjust 1
its programs as needed to safely meet its customers’ needs. 2
D. PG&E’s EE Portfolio Goals and Desired Outcomes 3
PG&E’s EE portfolio goals for 2024-2031 are as follows: (1) optimize 4
delivery of TSB; (2) support California’s goal of economy-wide carbon neutrality 5
by 2045; (3) shape energy demand to match supply, and (4) support customer 6
resiliency. The portfolio strategies and tactics in PG&E’s EE portfolio application 7
are designed to pursue these goals and promote these outcomes. 8
PG&E is pursuing these goals to achieve key milestone desired outcomes 9
throughout this application period outlined in Figure 1-3 below. PG&E provides 10
these aspirational targets by 2027 and by 2031. 11
(PG&E-1)
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FIGURE 1-3
PG&E EE PORTFOLIO DESIRED OUTCOMES
_______________
(a) PG&E’s cumulative TSB goals for 2024-2027 adopted in D.21-09-037, p.19.
(b) PG&E’s cumulative TSB goals for 2024-2031 adopted in D.21-09-037, p.19.
(c) Cumulative lifecycle CO2 emissions from PG&E’s EE Application CET output forecast, converted from
short tons to metric tons, including codes and standards.
(d) PG&E is defining this timeframe as the hours of 4pm to 9pm, every day to align with a frequently used peak
pricing period of PG&E’s electric rate plans. PG&E will measure progress towards this goal in watt-hours
(Wh) as opposed to only DEER defined peak watts.
(e) PG&E is not including a target figure as the savings in watt-hours for only the specific time periods of
concern is not yet an available CET output. PG&E-recommended improvements to CET outputs and overall
EE benefit calculations are discussed in subsequent chapters throughout this application.
(PG&E-1)
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1. Portfolio Goal: Optimize Delivery of TSB 1
As the new adopted metric, one of PG&E’s key considerations in 2
optimizing for TSB focuses on delivering programs and services at multiple 3
interaction points, and deploying a variety of program types, intervention
32
4
approaches, and transaction structures to increase customer participation. 5
This increased participation will help PG&E deliver on its TSB portfolio 6
metric by generating benefits from all customer sectors across our diverse 7
service territory. 8
PG&E plans to measure progress towards achieving this portfolio goal 9
by delivering at least the cumulative TSB goal by the end of each of our two 10
portfolio cycles, by 2027 and by 2031, as required by D.21-09-037.
33
These 11
cumulative figures are provided in Figure 1-3. 12
Additional details on PG&E’s approach to portfolio optimization are 13
included in Exhibit 2, Chapter 5 of this application. 14
2. Portfolio Goal: Support Economy-Wide Carbon Neutrality By 2045 15
PG&E is committed to helping California succeed in reaching its climate 16
commitments of reducing GHG emissions by 40 percent below 1990 levels 17
by 2030,
34
and ultimately reaching economy-wide carbon neutrality by 18
2045.
35
Based on recent reporting from the California Air Resources Board 19
(CARB),
36
“California will require much deeper GHG emissions reductions 20
to reach its [targets]”
37
and “by any measure, in any scenario, achieving 21
32
PG&E uses the term “intervention” to broadly cover the various points at which our
portfolio’s funded activities influence a customer or other market actors’ behavior or
actions, and it is through this influence that we can generate value in the form of
benefits for our customers.
33
D.21-09-037, p. 19.
34
See California SB 32 (2016).
35
See California Executive Order B-55-18 (2018).
36
California Greenhouse Gas Emissions for 2000 to 2019: Trends of Emissions and
Other Indicators, CARB, July 28, 2021, available at:
https://ww2.arb.ca.gov/sites/default/files/classic/cc/ca_ghg_inventory_trends_2000-201
9.pdf
37
https://ww2.arb.ca.gov/news/latest-state-greenhouse-gas-inventory-shows-emissions-c
ontinue-drop-below-2020-target.
(PG&E-1)
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carbon neutrality by 2045 will require a wholesale transformation of 1
California’s energy economy.”
38
2
PG&E recognizes that meeting this challenge and supporting 3
California’s climate commitments requires an EE portfolio focused on 4
innovative and integrated building decarbonization and electrification 5
solutions.
39
To ensure that our EE portfolio is aligned with and contributing 6
to California’s decarbonization goals, PG&E sets a target of 35.4 million 7
metric tons of cumulative lifecycle carbon dioxide (CO
2
) emissions 8
reductions
40
through our EE portfolio by 2031 (see Figure 1-3). GHG 9
emissions reductions is a useful metric to track progress towards the state’s 10
carbon neutrality target by 2045 because it is a common unit of 11
measurement for decarbonization. This GHG reduction target results from 12
PG&E’s embrace of building and end-use electrification, our commitment to 13
helping ensure California has a capable and qualified workforce able to 14
implement these carbon reduction investments, our continued leadership in 15
building codes and appliance standards advocacy, and our support for local 16
jurisdictions and the building community. PG&E’s EE portfolio is also 17
coordinating with other customer energy management portfolios and energy 18
supply teams to deliver comprehensive, renewable energy optimized load 19
management practices to further reduce GHG emissions from our 20
customers’ electricity use and to help meet the needs of a reliable and 21
low-carbon energy system of the future. See Section D.3 regarding this 22
coordination. 23
38
Achieving Carbon Neutrality in California: PATHWAYS Scenarios Developed for the
California Air Resources Board, E3, p. 9.
39
For example, as stated above shortly after filing its EE application, PG&E intends to file
a separately funded, but complementary, application for a GHG-optimized building
decarbonization offering (similar to SCE’s CEOP).
40
PG&E selected this metric because it is available as an output from the CPUC’s
Cost-Effectiveness Tool (CET). The EE portfolio’s contribution toward carbon neutrality
may be understated because lifecycle CO
2
emissions reduction only captures the
emissions reductions associated with interventions in PG&E’s EE portfolio that deliver
energy savings, while additional activities that support GHG emissions reductions, but
do not directly deliver energy savings such as Workforce Education and Training
(WE&T) programs are not captured through this metric. Additionally, GHG emissions
reductions from low-GWP refrigerant measures are not captured in this metric. CO
2
equivalent may be a better metric however this is not available as a CET output.
(PG&E-1)
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Qualitatively, PG&E is proposing two related outcomes by the end of 1
each the two four-year portfolio cycles. During the first portfolio cycle of 2
2024-2027, PG&E plans to increase the rate of electrification above the 3
natural rate of adoption by making electrification simple, easy, convenient, 4
and valued by customers. By the end of the second portfolio cycle in 2031, 5
PG&E anticipates electrification will be a primary focus of its EE portfolio 6
and plans to remove natural gas equipment financial support except where 7
there are no viable alternatives. 8
3. Portfolio Goal: Shape Energy Demand to Match Supply 9
Achieving California’s goal of renewable energy and zero-carbon 10
resources supplying 100 percent of total electric retail sales in California by 11
2045 will require an increase in clean, but variable, renewable generation
41
12
and a reduction (or elimination) of fossil-based, but firm, fast-ramping 13
generation.
42
The CEC Draft Staff Analysis of Potential Amendments to the 14
Load Management Standards notes that “as renewable resources replace 15
conventional fossil-fuel powered plants, the electric grid will place increasing 16
value on resources that can balance supply and demand.”
43
The 2021 17
SB 100 Joint Agency Report describes load flexibility as, “the ability to shift 18
electricity use to other parts of the day,” and describes load flexibility as 19
“critical” to electric reliability and affordability, noting that it can also reduce 20
GHG emissions by shifting electricity use to times when the grid relies on 21
cleaner energy.
44
The need for resources that can balance supply and 22
demand will likely be heightened further as PG&E looks ahead to retiring its 23
2,200 megawatt Diablo Canyon Power Plant in 2025. 24
41
For example, solar photovoltaic generation only generates electricity when the sun is
shining, and wind turbines only generate in correct wind conditions.
42
For example, natural gas power plants would be able to generate electricity whenever
needed, regardless of external conditions.
43
Draft Staff Analysis of Potential Amendments to the Load Management Standards, p. 7.
Available:
https://www.energy.ca.gov/publications/2021/analysis-potential-amendments-load-man
agement-standards.
44
Available here:
https://www.energy.ca.gov/publications/2021/2021-sb-100-joint-agency-report-achieving
-100-percent-clean-electricity.
(PG&E-1)
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Broadly, shaping energy demand to match supply means delivering the 1
right demand-side resources, in the right places, and at the right times, to 2
keep the grid operating and delivering power to customers. In practice, this 3
effort requires coordination of multiple DSM activities, including electric rate 4
design, demand response (DR), distributed generation and energy storage, 5
electric vehicle charging, and EE. 6
PG&E’s EE portfolio can help shape energy demand to match supply by 7
providing: 8
a) EE products and services that permanently reduce load during times of 9
unavailable, high-cost, or non-renewable supply; 10
b) EE products that have flexible demand capabilities (products able to 11
reduce, shift, or shape usage in response to customer or grid needs, or 12
electric retail rates); and 13
c) Integrated demand side management (IDSM) programs able to deliver 14
EE in combination with one or more DSM activities (other DSM activities 15
are mentioned above). 16
PG&E plans to quantitatively measure progress on this goal by tracking 17
the delivered energy savings during anticipated times of electric system 18
constraint. See Figure 1-3 for more information. 19
Qualitatively, PG&E proposes two distinct but related outcomes by the 20
end of each of the two portfolio cycles by 2027 and by 2031. During our first 21
portfolio cycle of 2024-2027, PG&E intends to track customer awareness of, 22
and access to opportunities to manage their energy use to support a clean 23
and reliable electric grid. By the end of the second portfolio period, PG&E 24
intends to leverage our entire DSM portfolio of customer programs, including 25
our EE portfolio, to provide customers a comprehensive and integrated 26
pathway to manage their energy use to support a clean and reliable electric 27
grid. 28
(PG&E-1)
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4. Portfolio Goal: Support Customer Resiliency
45
1
As stated above, more than half of PG&E’s service territory lies in the 2
HFTD, Tiers 2 and 3, as identified by the CPUC in 2018.
46
Customers in 3
these HFTD areas may be more interested in ensuring customer resiliency, 4
and PG&E’s EE portfolio can play a role in supporting these efforts. 5
PG&E’s EE portfolio is committed to supporting statewide GHG 6
reduction and carbon neutrality efforts, and to slow and hopefully reverse 7
the impacts of climate change. However, even with this focus on combating 8
climate change, PG&E recognizes that in the near term for the safety of our 9
customers and communities, PG&E may need to turn off power in certain 10
communities during severe weather events to help prevent wildfires. These 11
Public Safety Power Shutoffs (PSPS) are a necessary tool of last resort to 12
help keep our customers safe from wildfires. 13
EE has long been placed first in the “loading order” of resources 14
potentially available to meet energy needs.
47
Since EE products and 15
services can both reduce customer load as well as provide customers the 16
tools to manage their energy use on an ongoing basis, our EE portfolio can 17
help reduce the amount of generation needed to power customer homes 18
and businesses. 19
We plan to measure our progress in supporting customer resiliency 20
through the breadth of customers and resiliency projects that can leverage 21
45
We use the term customer resiliency to mean the ability for a customer or community to
keep their homes and businesses powered through alternative sources during an
outage event. These alternative power sources may be individual customer owned
generation and energy storage assets, community solutions such as a microgrid using
locally sited power generators which operate during outage events. It can also include
a permanent alternative power solution such as a remote grid or fixed power solution.
46
Available at: https://cpuc_firemap2.sig-gis.com/ (last accessed Feb. 9, 2022). Tier 2
consists of areas on the CPUC Fire Threat Map where there is an elevated risk for
wildfires. Tier 3 consists of areas on the CPUC Fire Threat Map where there is an
extreme risk for wildfires.
47
First adopted in the California Energy Action Plan in 2003, and reaffirmed in State of
California Energy Action Plan II, 2005. “As stated in EAP I and reiterated here, cost
effective energy efficiency is the resource of first choice for meeting California’s energy
needs. Energy efficiency is the least cost, most reliable, and most
environmentally-sensitive resource, and minimizes our contribution to climate change.
California’s energy efficiency programs are the most successful in the nation and we
want to continue to build upon those successes.” p. 3.
(PG&E-1)
1-20
EE to generate overall cost savings for our customers. Additional details 1
regarding the resiliency projects supported by our EE portfolio are discussed 2
below in Section E.1. Our 2024-2027 portfolio offers resiliency support 3
programs that intend to achieve cost savings for resiliency projects designed 4
and implemented in coordination with EE. By the end of our 2031 portfolio, 5
PG&E anticipates expanding this EE support across our portfolio and 6
throughout our service territory so that an even broader scope of resiliency 7
projects may optimally size their electricity generation and other 8
infrastructure assets by first employing all cost saving EE measures. 9
E. PG&E’s EE Strategies for 2024-2031 10
1. Portfolio Strategies 11
This section summarizes the key strategies for PG&E’s EE portfolio for 12
the eight-year strategic business plan period of 2024-2031: (1) deliver TSB 13
by meeting customers where they are; (2) pursue a multi-pronged approach 14
to building decarbonization; (3) deploy technologies that are grid-responsive 15
and demand flexible; (4) contribute to cost-saving resiliency solutions for 16
customers; and (5) properly value the benefits of EE. As these key 17
strategies also form the basis for PG&E’s 2024-2027 portfolio plan, PG&E 18
includes more detail as referenced accordingly. 19
The following strategy prompts in italics requested by the CPUC in the 20
Energy Division template are mapped to the above five PG&E strategies, as 21
noted below in Table 1-1: 22
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TABLE 1-1
STRATEGY PROMPT MAPPING
Line
No.
Strategy Prompts from Energy Division Template
PG&E Portfolio Strategy
That Addresses CPUC
Prompt
1
Strategy for application/use of various and new methods for
savings forecasting and quantification methods
(e.g., normalized metered energy consumption (NMEC)
including requirements in Public Resources Code Section
25310(c)(5)).
Strategy #3
2
Strategies for market intervention and EE adoption:
e.g., targeted points of intervention; delivery
channels/platforms/methods.
Strategies #1-4
3
New strategies for spurring innovation: e.g., cultivating new,
diverse, businesses to enter EE design/implementation,
cultivating relationships with traditional actors in other markets
to enter EE design/implementation, supporting the adoption of
new and evolving GHG reducing technologies.
Strategies #1-4
4
Strategy for incorporating low global warming potential (GWP)
refrigerants in the portfolio
Strategy #2
a. Strategy #1: Deliver TSB By Meeting Customers Where They Are 1
Delivering programs and services structured to address customer 2
concerns and potential barriers to participating in EE programs, and 3
which are offered through multiple interventions
48
and interaction points, 4
can meet customers’ needs and increase participation. Increasing 5
participation is one pathway to delivering on PG&E’s EE portfolio metric 6
of TSB by generating benefits from a wide range of customer sectors 7
across our service territory. PG&E proposes three key tactics below to 8
pursue this strategy: (1) offer a diverse EE portfolio; (2) design a 9
portfolio that meets customers where they are; and (3) enhance digital 10
strategies and personalize customer journeys. 11
1) Offer a Diverse EE Portfolio 12
PG&E will leverage its PA role to develop complementary 13
interventions, programs, and strategies that provide customers 14
opportunities to participate in EE that best suit their needs. PG&E’s 15
48
Interventions are actions taken by the program administrator to influence a customer’s
energy efficiency. This can be in the form of activities including but not limited to:
financial incentives, technical assistance, efficiency C&S, and informational products.
See Exhibit 2, Chapter 4 for details on interventions.
(PG&E-1)
1-22
EE portfolio will employ diverse programs, services, transaction 1
structures (such as financing and performance-based incentives), 2
and intervention channels. Our commitment to offering a varied 3
portfolio will allow PG&E to deliver timely solutions for customers 4
related to: replacing aging infrastructure with new, high-efficiency 5
solutions; helping customers upgrade their facilities without 6
disrupting their operations; creating ongoing energy management 7
partnerships to control operating costs; and offering attractive capital 8
access structures allowing customers to make investments in EE 9
without jeopardizing other needs. See Exhibit 2, Chapter 4, 10
Sections D and E for more detail. 11
2) Design a Portfolio to Meet Customers Where They Are 12
PG&E’s role as a PA is to design a portfolio of programs that 13
meets the needs of its diverse population of customers. PG&E’s 14
customers’ perceptions about EE and energy management are 15
highly varied. See Exhibit 2, Chapter 4, Section A.3 for insights on 16
PG&E’s customer perceptions. PG&E identifies three areas to 17
deliver on its portfolio strategy through customer-centric principles: 18
(1) increasing awareness of EE and energy management 19
opportunities; (2) providing motivation for customers to pursue EE; 20
and (3) removing barriers that could impede customers’ participation 21
in EE. 22
As part of this, marketing is a critical element of the customer 23
experience. This includes broad awareness and education as well 24
as more program specific marketing. This dual approach engages 25
customers through multiple channels, to drive EE program adoption 26
and energy management behavior change. PG&E’s marketing uses 27
a combination of traditional and newer marketing channels to meet 28
customers where they are. Through multi-touch and multi-channel 29
campaigns, customers move through the program adoption journey 30
including awareness, interest, evaluation, and conversion. PG&E 31
intends to continue to use this marketing approach to drive 32
participation in EE programs and deliver on our portfolio goals. See 33
Exhibit 2, Chapter 4, Section A.4 for more detail. 34
(PG&E-1)
1-23
3) Enhanced Digital Strategy and Personalized Customer 1
Journeys 2
PG&E plans to expand online customer access to information 3
and will connect customers to technical experts who can help them 4
create EE and decarbonization action plans. PG&E’s online EE 5
solutions aim to provide personalized recommendations to 6
customers for planning and implementing EE and decarbonization 7
activities. These solutions can provide customers with information 8
regarding their energy bills and energy use, rate plan options, 9
energy management programs including EE and DR, and clean 10
energy solutions for their homes, businesses, and transportation. 11
PG&E anticipates that simplified, tailored customer experiences will 12
lead to increased customer participation across our EE portfolio and 13
other energy management programs. See Exhibit 2, Chapter 4 for 14
more details. 15
b. Strategy #2: Pursue a Multi-Pronged Approach to Building 16
Decarbonization 17
PG&E is committed to supporting building decarbonization while 18
keeping energy affordable by managing an equitable and viable 19
transition to zero-carbon energy alternatives for customers. Within EE 20
programs, PG&E’s support for building decarbonization reflects the 21
different needs of customers and communities with programmatic 22
approaches such as equipment incentive and financing programs, 23
customer education, WE&T, and advocacy to improve appliance 24
standards and building codes. PG&E provides its high-level vision for its 25
building decarbonization strategies through EE below. 26
1) Support Electrification in Existing and New Buildings 27
While PG&E’s approach to building electrification differs for 28
existing and new buildings, the desired outcome for both is for 29
all-electric or electric-ready buildings. 30
a) Existing Building Electrification 31
Decarbonizing California’s existing building stock must be 32
done thoughtfully as it has the potential to exacerbate issues of 33
(PG&E-1)
1-24
affordability and equity for remaining gas customers. As E3 1
highlights in its report The Challenge of Retail Gas in 2
California’s Low-Carbon Future, “unsustainable increases in gas 3
rates and customer energy bills could be seen after 2030, 4
negatively affecting customers who are least able to switch 5
away from gas, including renters and low-income residents.”
49
6
By leveraging zonal electrification or whole building 7
electrification approaches—rather than single appliance 8
incentives—PG&E can mitigate impacts to future gas system 9
costs and gas rates to facilitate an equitable transition to a 10
decarbonized future. Figure 1-4 below depicts this order of 11
preference for existing building electrification. Brief 12
explanations for each of those approaches is provided below. 13
FIGURE 1-4
PG&E’S PREFERRED ORDER FOR EXISTING BUILDING ELECTRIFICATION
1) Zonal electrification, also known as strategic 14
de-commissioning of the natural gas system, prioritizes 15
whole building electrification for entire regions. This 16
approach is guided by PG&E’s vision to preserve customer 17
affordability while maximizing emission reductions. The 18
approach uses PG&E data to identify zones with system 19
49
Found at:
https://www.energy.ca.gov/sites/default/files/2021-06/CEC-500-2019-055-F.pdf, p. iii.
(PG&E-1)
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conditions and natural gas asset characteristics—such as, 1
but not limited to, age of assets, risks, number of customers, 2
and system throughput—that can provide insight about 3
locations that may warrant further engineering and/or 4
costing review for zonal electrification. While zonal 5
electrification is likely to have the best long-term outcome 6
for our customers, it requires highly targeted enrollment and 7
the complete electrification of all customers in a particular 8
“zone” to enable natural gas asset decommissioning. As a 9
result, while this might be the preferred approach, it may be 10
difficult to achieve. PG&E proposes new zonal 11
electrification placeholder programs to support a broader 12
enterprise strategy and investment into zonal electrification. 13
See Exhibit 2, Chapter 4, Section D.1 and D.2 for 14
information on PG&E’s new zonal electrification placeholder 15
programs. 16
2) Whole-building electrification focuses on replacing all 17
existing natural gas end uses within individual buildings or 18
groups of buildings with high-efficiency electric alternatives. 19
Whole-building electrification can help with long-term 20
affordability for participating customers as it removes 21
individual natural gas equipment and the associated PG&E 22
natural gas system operations and maintenance costs. 23
Additionally, whole-building electrification removes the need 24
for PG&E to provide natural gas service to the individual 25
electrified customer and therefore may make zonal 26
electrification easier in the future since there would be fewer 27
gas customers in an area to have to fully electrify. 28
3) Targeted electrification for harder-to-electrify technologies 29
and customer sectors focuses on the pursuit of partial 30
electrification of existing buildings when whole building 31
electrification is not possible or feasible. Certain 32
technologies such as cooking equipment may be 33
harder-to-electrify due to barriers such as customer 34
(PG&E-1)
1-26
preference, the higher cost of induction cooktops compared 1
to gas cooktops,
50
and may require changes to cooking 2
technique and kitchen layouts.
51
The CEC notes: 3
“even though gas cooking is only the third-largest 4
contributor to GHGs from homes, it contributes to the 5
need to extend gas lines to new homes and the reason 6
why some homeowners are reluctant to go 7
all-electric.”
52
8
Similarly, in commercial buildings, cooking accounts for less 9
than one-fourth of gas consumption in buildings.
53
As 10
such, targeted efforts focusing on cooking electrification 11
could have significant benefits (in the form of reduced gas 12
system costs) beyond those realized by the participating 13
customer. In instances when zonal or whole building 14
electrification is not possible, it may be beneficial to focus 15
efforts on electrifying appliances or other technologies 16
where possible areas during times when implementation 17
costs are lower, such as when customers are already 18
planning on replacing equipment upon failure or as a part of 19
all-electric new construction. However, as discussed in 20
Section E.1.b.3, PG&E is limited in its ability to focus its 21
funding for technology-based programs that can influence 22
availability of viable electric alternatives to gas appliances 23
and therefore intends to focus its funding on overcoming 24
other barriers through WE&T and C&S for these technology 25
areas. 26
PG&E includes several strategies and tactics to support 27
existing building electrification across these three approaches 28
50
California Building Decarbonization Assessment – Final Commission Report, CEC,
August 13, 2021, p. 82.
51
Ibid, p. 87.
52
Ibid, p. 86.
53
California Building Decarbonization Assessment – Final Commission Report, CEC,
August 13, 2021, pp. 30-31, Figure 7, citing California Commercial End Use Survey.
(PG&E-1)
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that are discussed in more detail in Exhibit 2, Chapters 1 and 4. 1
These include: 2
• A new placeholder program for zonal electrification in the 3
equity segment for which PG&E intends to leverage the 4
CPUC’s AR and SEVI/SEVI-DAC
54
metrics to target this 5
program in geographic areas that include underserved and 6
vulnerable communities; 7
• Statewide new construction programs that support existing 8
building electrification by providing two pathways toward 9
whole-building electrification for retrofits by requiring either 10
the complete conversion to all-electric end uses and 11
removal of gas meters, or pre-requisites to dwellings and 12
buildings to be electric-ready if they are not yet able to fully 13
remove gas end-uses; and 14
• Local and statewide WE&T programs to reduce the barriers 15
customers face when considering fuel substitution for 16
gas-to-electric appliances. 17
b) New Building Electrification 18
Newly constructed buildings can have the lowest 19
decarbonization costs because there are no existing appliances 20
or infrastructure to remove or replace and electrification can be 21
a part of the design up front. PG&E’s strategy to address new 22
building electrification is centered around two key areas: 23
(1) statewide new construction programs and (2) C&S 24
programs. 25
PG&E is the lead program administrator for the statewide 26
new construction programs for the residential and 27
non-residential sectors. The statewide new construction 28
programs include a pathway for builders and developers to 29
pursue an all-electric option for newly constructed buildings that 30
are designed without any gas end-uses, therefore eliminating 31
54
SEVI-DAC is Socioeconomic Vulnerability Index-Disadvantaged Communities.
(PG&E-1)
1-28
the need for gas meters and natural gas service. See Exhibit 2, 1
Chapter 4, Section E.3 for more detail. 2
2) Technical Support and Advocacy Through C&S 3
While building decarbonization and electrification are important 4
tools in meeting California’s climate goals, there are significant 5
market barriers to achieving these policy initiatives through tangible 6
changes in the built environment. Advocating for advancements in 7
state, federal, and regional regulations can accelerate the transition 8
to low-carbon buildings and the use of appliances that have the 9
greatest decarbonization potential. PG&E has long been a leader in 10
building codes and appliance standards advocacy and providing 11
technical support to local jurisdictions and state agencies in EE. 12
PG&E expanded its C&S support to other areas including 13
decarbonization and water efficiency. 14
PG&E is the lead program administrator for the statewide C&S 15
programs. See Exhibit 2, Chapter 4, Section E.1, for PG&E’s C&S 16
strategies that support building decarbonization. This includes 17
coordination with new construction programs for enhanced data 18
collection to support future building codes and appliance standards, 19
a new local program focused on participating in building code and 20
appliances standard decarbonization rulemakings, supporting local 21
governments’ local energy ordinances (also known as reach codes) 22
through technical support, and code readiness and compliance 23
improvement programs that can support the building industry in its 24
building decarbonization efforts. 25
3) Decarbonize through Equipment Support 26
PG&E’s EE portfolio provides financial assistance in the form of 27
incentives and financing to encourage the adoption of energy 28
efficient end-use appliances. With the increased focus on building 29
decarbonization and the need for a managed transition from gas to 30
electric systems, there should be increased focus on the end-uses 31
through which those energy savings are delivered and a focus on 32
overall GHG reductions rather than energy savings alone. 33
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Limit Natural Gas Equipment Support 1
It is important to support a building decarbonization transition 2
that is rooted in equity and affordability for customers. PG&E 3
recognizes the unique needs of certain customers, such as those in 4
the industrial and agricultural sectors, that rely on natural gas to 5
power core business practices and therefore may be unable to 6
electrify their buildings or equipment. In these situations, PG&E can 7
work closely with those customers to deliver opportunities to reduce 8
their energy use and carbon footprint without disruptions to their 9
core operations. For other customer sectors, by the end of the 10
eight-year business plan period, PG&E anticipates limiting its 11
financial support for long-life gas equipment except where there is 12
no viable alternative.
55
13
Incorporate Low-GWP Refrigerants. 14
Pursuant to the Energy Division template, PG&E provides this 15
information regarding incorporating low-GWP refrigerants. PG&E 16
recognizes the impact refrigerants from space and water heating 17
equipment have on emissions in the building sector
56
and the need 18
to address those emissions in the pursuit of carbon neutrality. 19
PG&E uses the Commission’s Refrigerant Avoided Cost Calculator 20
55
In instances where PG&E has limited ability to impact funding decisions on equipment
support, such as for statewide programs for which PG&E is not the lead program
administrator, funding may continue for long-life gas equipment in PG&E’s territory.
D.18-05-041 (pp. 185-186, OP 18) directed that the lead program administrator for each
statewide program shall have sole responsibility for the program. PG&E is not the lead
for any technology-based statewide programs.
56
From CARB (https://ww2.arb.ca.gov/resources/documents/high-gwp-refrigerants.):
“Global Warming Potential, or GWP, is a measure of how destructive a climate
pollutant is. Refrigerants today are often thousands of times more polluting than
carbon dioxide (CO
2
). The GWP of a gas refers to the total contribution to global
warming resulting from the emission of one unit of that gas relative to one unit of the
reference gas, CO
2
, which is assigned a value of 1. GWPs can also be used to
define the impact GHG gases will have on global warming over different time periods
or time horizons. These are usually 20 years, 100 years, and 500 years. A time
horizon of 100 years is used by regulators (e.g., the California Air Resources
Board).”
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to guide its use of low-GWP refrigerant measures in the portfolio 1
forecasts of this application.
57
2
PG&E can address barriers to adoption of low-GWP refrigerant 3
measures through WE&T. PG&E also intends to support the 4
adoption of low-GWP appliances into California’s building code, as 5
well as in regulations to be adopted by the Environmental Protection 6
Agency, CARB, and other California state agencies as appropriate. 7
Further details on PG&E’s strategies to incorporate low-GWP 8
refrigerants into its EE portfolio can be found in Exhibit 2, Chapter 1, 9
Section C.2. 10
c. Strategy #3: Deploy Technologies That Are Grid-Responsive and 11
Demand Flexible 12
As PG&E looks forward to a grid powered by variable, renewable 13
generation that may be operated by PG&E, another non-utility load 14
serving entity, or even other customers through Distributed Energy 15
Resources (DER),
58
we recognize that our EE portfolio must provide 16
solutions to match these evolving grid characteristics to continue to 17
provide our customers with safe, reliable, affordable, and clean energy. 18
PG&E offers the following tactics to operationalize this strategy. 19
1) Align the EE Portfolio With PG&E’s Enterprise-Wide 20
Coordinated Supply and Load Strategy 21
PG&E recognizes that our electric system needs the right 22
resources, in the right places, at the right times to adapt to changing 23
grid conditions. These needs include more flexible resources to 24
accommodate greater amounts of renewable generation, more 25
distributed resources at appropriate locations on the electric grid, 26
and a cost-effective pathway to implementing these changes. 27
PG&E’s customers need to be a part of this solution, with clear 28
57
D.21-05-031, OP 16.
58
DERs can be defined as:
“…distribution-connected distributed generation resources such as energy efficiency,
demand response, customer generation (e.g., rooftop solar), energy storage,
alternative fuel vehicles (e.g., electric vehicles), and water-energy conservation.”
Source: https://www.cpuc.ca.gov/demand_side/.
(PG&E-1)
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pathways to engage in the full spectrum of load management 1
programs and electric rate products that allow them to utilize the full 2
potential of their DERs.
59
3
PG&E is working to implement an enterprise-wide coordinated 4
supply and load strategy to accomplish these needs, and intends to 5
position our EE portfolio to play a key role in delivering both: 6
a) A cohesive, accessible, and clear customer experience; and 7
b) A comprehensive, innovative, customer energy management 8
portfolio strategy. 9
2) Utilize the Meter-Based Platform Throughout our Portfolio 10
Pursuant to the Energy Division template, PG&E provides 11
information on its strategies to use savings forecasting and 12
quantification methods such as NMEC where cost-effective and 13
feasible. PG&E refers to approaches to calculating savings and 14
TSB using metered customer energy usage data (meter data) as the 15
meter-based platform. The meter-based platform comprises three 16
primary approaches: NMEC, strategic energy management, and 17
experimental or quasi-experimental methods. 18
Meter-based approaches can play a key role in PG&E’s EE 19
portfolio in several ways. First, they can enable more granular 20
measurement and targeting of EE savings. They can accomplish 21
this by measuring the impact of programs on the customers 22
participating (rather than relying on average values), and by 23
providing regular feedback to implementers and customers about 24
program impacts. Feedback can both support load flexibility and 25
help to identify if an intervention is not working. Second, 26
meter-based approaches can enable projects that are more 27
challenging, or not possible, to pursue through approaches that rely 28
on engineering calculations. Meter-based approaches measure 29
59
By full potential, PG&E means utilizing DERs to reduce, shift, or shape usage in
response to customer or grid needs or electric retail rates.
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savings from the existing conditions
60
of a customer’s building, and 1
therefore enable programs to target “stranded potential”
61
and 2
capture the impact of behavioral, operational, and 3
retrocommissioning interventions. Meter-based approaches also 4
capture the impact at the meter of whole-building or whole-system 5
interventions, and in doing so can support deeper-savings projects. 6
Finally, as meter-based approaches continue to evolve, they may 7
facilitate integration with other DERs (e.g., DR and energy storage) 8
by measuring the overall impact from all demand-side interventions 9
on energy usage from the grid. PG&E envisions continuing to 10
expand the use of meter-based approaches where these 11
measurement methods are cost-effective and feasible to measure, 12
pay for, and claim EE savings. 13
d. Strategy #4: Contribute to Cost Saving Resiliency Solutions for 14
Customers 15
PG&E intends to leverage our EE portfolio to support solutions that 16
increase customer resiliency. Load reductions achieved when 17
implementing EE interventions may be able to deliver cost savings to 18
individual participants and all customers when incorporated into the 19
scope of a resiliency solution project. PG&E offers two tactics to 20
operationalize this strategy. 21
60
Information on EE baselines including existing conditions and code baselines can be
found here:
https://www.cpuc.ca.gov/industries-and-topics/electrical-energy/demand-side-managem
ent/energy-efficiency/energy-efficiency-baselines.
61
The Energy Efficiency Potential and Goals Study for 2018 and Beyond defines stranded
potential as:
“the opportunities for energy efficiency that are not currently captured by either PA
rebate programs or codes and standards. Stranded Potential is below code savings
that is not materializing in the market because there is no incentive for the customer
to upgrade their existing equipment given current program rebate policy. Under
AB802, PAs could start offering rebates for bringing existing equipment up to code
thus motivating a whole new subset of customers to install energy efficiency and
capturing the Stranded Potential.”
Navigant, Energy Efficiency Potential and Goals Study for 2018 and Beyond, p.4, Aug.
23, 2017.
(https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M194/K614/194614840.PDF , last
accessed Feb. 9, 2022).
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1) Use EE to Reduce Customer Costs for Resiliency Solutions 1
PG&E’s Wildfire Mitigation Plan (WMP)
62
plans for the 2
construction and operation of microgrids and remote grids as 3
alternative ways to provide electricity to our customers either during 4
outage events (in the case of microgrids) or else as a permanent 5
localized electric system (in the case of remote grids). Exhibit 2, 6
Chapter 4, Sections D.1 and D.3 include PG&E’s EE proposals to 7
partner with microgrids and remote grid construction and operation 8
programs to provide participating customers with permanent load 9
reducing solutions to reduce energy generation demand and these 10
microgrid and remote grid costs. 11
2) Use EE to Support Individual Customer Resiliency Solutions 12
PG&E also plans to use its EE portfolio to support individual 13
customer’s resiliency solutions through programs that provide 14
permanent load reduction or technical assistance for identification of 15
resiliency opportunities. 16
PG&E understands that our customers are increasingly 17
interested in installing electricity generation and backup electricity 18
storage to prevent losing power during power outage events. Both 19
the initial construction and ongoing operating costs are highly 20
dependent on individual energy needs. Therefore, PG&E intends to 21
position its EE portfolio to provide permanent load reducing 22
solutions that may reduce these resiliency project costs.
63
23
e. Strategy #5: Properly Value the Benefits of EE 24
The goals and strategies outlined above and detailed across 25
PG&E’s testimony offer additional customer benefits that extend beyond 26
62
PG&E 2021 WMP is available at:
https://www.pge.com/pge_global/common/pdfs/safety/emergency-preparedness/natural
-disaster/wildfires/wildfire-mitigation-plan/2021-Wildfire-Safety-Plan.pdf. PG&E expects
to file its 2022 WMP on February 25, 2022 which will include information in microgrids
and remote grids. Note: this is not a direct link, one has to do a search.
63
Department of Energy Factsheet discusses cost savings and passive survivability
benefits of EE:
https://betterbuildingssolutioncenter.energy.gov/sites/default/files/attachments/DOE%20
BB%20Resilience.pdf.
(PG&E-1)
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those that are currently measured and reported in EE. PG&E 1
understands that to better focus on the people we serve, the planet we 2
inhabit, and California’s prosperity, we must demonstrate the benefits 3
our EE portfolio expects to provide to our customers in return for their 4
investments in it. While PG&E plans to demonstrate the benefits we will 5
deliver according to the current set of EE metrics during the 2024-2027 6
portfolio plan years, updating the TSB calculation to include certain 7
additional energy system benefits may encourage PAs to more directly 8
incorporate these types of activities in the second four-year portfolio 9
cycle from 2028-2031. 10
The three additional benefit areas are: 11
1) localized distribution system benefits; 12
2) resiliency support benefits; and 13
3) retrofit building electrification benefits. 14
These benefit areas and PG&E’s proposed next steps toward 15
quantifying the value of these benefits and including them in the TSB 16
calculation are discussed in more detail in Chapter 3. 17
2. Portfolio Management Strategies 18
a. Segmentation Strategy Summary 19
D.21-05-031 requires that all PAs assign each EE program ID to 20
one of three segments—RA, MS, or equity—based on the program’s 21
primary purpose.
64
C&S remains a separate segment. 22
PG&E’s position is that a program is in the RA segment unless its 23
primary purpose aligns with MS or equity objectives, rather than with RA 24
objectives. As recognized in D.21-05-031,
65
while an individual 25
program may only be assigned to one segment at any point in time, it is 26
often the case that programs have multiple objectives. 27
The forecasted cost-effectiveness of a program was not a 28
determinant in the segment assignments, however D.21-05-031 29
64
D.21-05-031, OP 2. The Decision also confirmed (p.16) that C&S is separate: “C&S
programs will remain separate as well, as previously defined in D.12-05-015.” EM&V
funds are assigned to an EM&V segment for reporting purposes in California Energy
Data and Reporting System.
65
D.21-05-031, pp. 15-16.
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acknowledges “the conflict between cost-effectiveness and other equally 1
or more important policy objectives such as equity and support for the 2
energy efficiency market”.
66
Portfolio segmentation enables PG&E and 3
other IOUs to still support equity and MS activities valued by the 4
Commission and include programs that may have otherwise been 5
retired from the portfolio or not considered in a solicitation. See 6
Exhibit 2, Chapter 3 for more detail on PG&E’s segmentation strategy. 7
b. Sector Strategy 8
PG&E plans to serve customers across the following sectors: 9
Residential, Commercial, Public, Agricultural, and Industrial. PG&E also 10
includes six cross-cutting sectors in its EE portfolio: C&S, Emerging 11
Technologies, New Construction, Local Government Partnerships, 12
WE&T, and Finance. These sectors are discussed in Exhibit 2, 13
Chapter 4, Sections D and E. 14
PG&E identifies the following seven intervention strategies and 15
cross-cutting efforts designed to achieve our portfolio goals. While the 16
details vary by sector, and not all are used in each customer sector, 17
these intervention strategies represent the core of the activities across 18
the customer and cross-cutting sectors. The categories of intervention 19
strategies below are intended to guide, but not limit, our efforts over the 20
next several years: 21
• make participation in EE easier; 22
• provide access to capital; 23
• provide education and training to raise awareness; broaden 24
engagement with EE and participants’ interaction with other energy 25
management solutions; 26
• accelerate adoption of advanced technologies that contribute to 27
building decarbonization and enable flexible demand; 28
• offer targeted programs that support policy priorities, such as 29
electrification and decarbonization, resiliency, and reliability; 30
• provide behavioral and operational interventions; and 31
• expand access to programs to underserved communities. 32
66
D.21-05-031, pp. 13-14.
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c. Budget Distribution Strategy 1
PG&E distributed its forecasted budget to achieve the broader EE 2
portfolio goals described in Section D. In addition, PG&E distributed its 3
budget to optimize for other factors including cost-effective goals for the 4
RA segment. 5
PG&E’s portfolio budget distributions are built upon the budget 6
distributions from PG&E’s recent third-party program solicitations from 7
2018-2021. For statewide programs led by other PAs, PG&E provides 8
funding to the lead program administrators
67
based on the current 9
proportional share contribution percentage
68
as required by 10
D.18-05-041.
69
PG&E has not exercised its option to adjust its 11
proportional share within 20 percent;
70
therefore, budget distributions 12
are based upon the proportional share contribution percentages as filed 13
in its 2022-2023 Energy Efficiency Biennial Budget Annual Advice 14
Letter.
71
15
PG&E also distributed budget across its portfolio to reflect the move 16
to portfolio segmentation as directed in D.21-05-031
72
and forecasts to 17
maintain budget levels for MS and equity segments within 30 percent of 18
its portfolio budget on a cumulative basis across each four-year portfolio 19
cycle. 20
Further detail on PG&E’s forecast methodology can be found in 21
Exhibit 2, Chapter 2. 22
d. Outsourcing 23
1) Strategy to Maintain Outsourcing Target 24
Since 2018, PG&E has conducted third-party solicitations for 25
local programs and for statewide programs for which it was the 26
67
As assigned in Table 3 (pp. 91-92) and Table 4 (p. 92) in D.18-05-041.
68
See Exhibit 2, Chapter 2, Section B.2.
69
D.18-05-041, OP 22, pp. 186-187.
70
D.18-05-041, COL 18, p. 173 requires IOUs to fund statewide programs at levels within
20 percent of their proportional share based on load.
71
PG&E Advice Letter (AL) 4521-G-A/6385-E-A, (January 7, 2022). This advice letter is
pending Commission disposition.
72
D.21-05-031, OP 9, p. 75.
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assigned lead program administrator.
73
PG&E’s local multi-sector 1
solicitation was designed to provide flexibility for bidders to propose 2
innovative program designs targeting any customer sector or 3
combination of sectors, and spanned the entire customer portfolio in 4
a single, coordinated solicitation effort. PG&E will continue to build 5
and iterate upon this portfolio of programs throughout the strategic 6
business plan years of 2024-2031 to deliver on its broader portfolio 7
objectives. 8
As directed in D.16-08-019 and re-affirmed in D.18-01-004 and 9
D.18-05-041,
74
PG&E forecasts that at least 60 percent of its total 10
portfolio budget will be allocated to programs that meet the updated 11
third-party definition
75
for each year of the eight-year strategic 12
business plan period of 2024-2031. See Exhibit 2, Chapter 5 13
Section E for more detail on PG&E’s strategies to maintain the 14
outsourcing target. 15
PG&E recognizes the future procurement landscape will be 16
different and focused on incremental adjustments to the portfolio 17
rather than wholesale changes, building upon the foundation of new 18
programs recently awarded. PG&E’s EE procurement will focus on 19
maintaining outsourcing levels above the minimum 60 percent 20
budget requirement, while actively managing the performance of the 21
EE programs to determine when it may be appropriate to replace or 22
amend existing programs. 23
2) Solicitation Strategies 24
Based on its experience and feedback received from its peer 25
resource group and independent evaluators, PG&E plans to adapt 26
its solicitation approach in two key areas: (1) drive improvements to 27
the procurement process, and (2) expand coordination of EE 28
73
D.18-05-041, pp. 182-183; OP 26,p. 188 and Table 3, pp. 91-92.
74
Id.
75
D.16-08-019, OP 10, p. 111. Third-party definition:
“To be designated as ‘third party,’ the program must be proposed, designed,
implemented, and delivered by non-utility personnel under contract to a utility
portfolio administrator.”
(PG&E-1)
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portfolio activities with DER procurements. See Exhibit 2, Chapter 5 1
Section E.2. 2
e. Portfolio Coordination 3
As the EE landscape has grown in California, the number of entities 4
with whom PG&E must coordinate has also grown. 5
Statewide Programs 6
PG&E is an active participant coordinating with the other IOUs for 7
statewide programs. IOU program administrator coordination has 8
evolved through the new statewide program model adopted in 9
D.16-08-019 in which one lead program administrator administers a 10
statewide program on behalf of the other IOUs.
76
PG&E supports 11
continued coordination among the IOUs as part of its strategic business 12
plan period and looks to identify areas of improvement. See Exhibit 2, 13
Chapter 5, Section F.1 for more detail. 14
Coordination with non-IOU PAs 15
The non-IOU PAs include: (1) RENs and (2) CCAs. As of 16
January 14, 2022, the approved non-IOU PAs in PG&E’s service 17
territory and included in this application are: the BayREN, 18
CleanPowerSF, Marin Clean Energy, SJCE, and the 3C-REN. Other 19
parties have submitted proposals to administer EE portfolios but have 20
not yet been approved. 21
Coordination with CCAs and RENs Pending Approval by the CPUC 22
PG&E does not include forecasts for entities that recently submitted 23
proposals
77
requesting approval to become PAs. Therefore, funding for 24
these potential portfolios is not included in PG&E’s eight-year authorized 25
budget cap request. PG&E requests that funding for PA portfolios not 26
approved by January 14, 2022 be considered incremental to PG&E’s 27
eight‑year authorized budget cap request. See Chapter 3 for PG&E’s 28
policy requests. 29
76
D.16-08-019, pp. 61-62.
77
East Bay Clean Energy Advice No.28-E, (October 21, 2021); Peninsula Clean Energy
(PCE) AL PCE 20-E, (November 19, 2021); and Sonoma Clean Power (SCP) AL
SCP 016-E, (December 1, 2021).
(PG&E-1)
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Coordination with Other DSM Programs 1
PG&E understands that strong coordination with other DSM 2
programs and portfolios is key to meeting its portfolio goals and 3
delivering on CPUC performance metrics. PG&E will coordinate through 4
both program implementation and through the solicitation process 5
employed in its procurement of new programs. 6
For program implementation, PG&E plans to leverage DSM 7
coordination to meet our portfolio goal of shaping energy demand to 8
match supply. Other portfolios such as DR, rate products, distributed 9
generation and energy storage, and electric vehicle charging could be 10
leveraged to offer customers comprehensive and IDSM options for 11
managing and reducing their energy use. Similarly, PG&E’s EE portfolio 12
will coordinate with programs offered through our income-qualified 13
portfolio such as the Energy Savings Assistance program to ensure 14
equity in access and affordability for eligible customers. Additional 15
details regarding specific customer sector and program coordination are 16
available in Exhibit 2, Chapter 4. 17
Beyond coordinating program implementation, PG&E is proposing 18
key improvements to our solicitation approaches to enable the EE 19
portfolio to expand its procurement scope and service. See Exhibit 2, 20
Chapter 5, Section E. 21
3. Evaluation, Measurement and Verification 22
From 2024 to 2031, PG&E will use EM&V as a tool to understand the 23
performance of its EE portfolio and help to continuously improve it. PG&E’s 24
primary goals for its EM&V activities are to: (1) support the accuracy of 25
ex ante claims, (2) inform portfolio design and management, and 26
(3) collaborate with the Commission to support accurate and actionable 27
ex post impact evaluations. See Exhibit 2, Chapter 6 for more detail. 28
4. Alignment of Business Plan Strategies and Outcomes With Legislative 29
and CPUC Requirements 30
PG&E has aligned its 2024-2031 strategic business plan with legislative 31
and CPUC requirements as shown in Table 1-2 below. PG&E discusses 32
(PG&E-1)
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alignment with both high-level portfolio strategies and more specific 1
strategies. 2
TABLE 1-2
ALIGNMENT OF CPUC DECISIONS AND LEGISLATIVE REQUIREMENTS GUIDING PG&E’S
STRATEGIC BUSINESS PLAN
Line
No.
Area
Points of Alignment
1
Application Structure
Application aligns with application requirements in D.21-05-031
2
High-Level
Strategies
Development of PG&E’s forecast is guided by the EE goals approved in D.21-09-037.
The shift to TSB goals, portfolio segmentation, and a new portfolio process in D.21-05-031
guides PG&E’s overall approach.
SB 100 (2018), Executive Order B-55-18, and SB 350 (2015) carbon neutrality and GHG
reduction goals inform the portfolio’s focus on decarbonization.
PG&E’s high-level approach is also guided by goals of California Long-Term EE Strategic
Plan,
(a)
including:
• Continually strengthening and expanding efficiency requirements in building codes
and appliance standards; improving code compliance and enforcement;
• Whole building and deep savings approaches;
• IDSM approaches;
• Building demand for EE in the industrial and agricultural sectors; and
• Building workforce capacity.
3
Specific Strategies
Statewide programs align with D.18-05-041 and D.16-08-019.
Third-party outsourcing aligns with D.18-01-004 and D.16-08-019.
WE&T programs align with applicable requirements in D.18-10-008.
Fuel substitution strategies informed by guidance in D.19-08-009.
Use of meter-based approaches informed by recognition of NMEC approach in and
requirements of D.16-08-019 and Assembly Bill 802 (2015).
Measures to promote low-global-warming potential refrigerants align with SB 1013 (2018)
and D.21-05-031.
_______________
(a) Engage 360. California Energy Efficiency Strategic Plan, January 2011 Update. Last accessed January 10, 2022 at:
https://www.cpuc.ca.gov/-/media/cpuc-website/files/legacyfiles/c/5303-caenergyefficiencystrategicplan-jan2011.pdf.
a. Portfolio Design and Budget Alignment With Relevant Action Plans 3
Beyond the EE Proceeding 4
PG&E has aligned its 2024-2031 strategic business plan with the 5
relevant action plans as shown in Table 1-3 below. 6
(PG&E-1)
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TABLE 1-3
ALIGNMENT OF PG&E’S STRATEGIC BUSINESS PLAN WITH RELEVANT REGULATORY
ACTION PLANS BEYOND THE EE PROCEEDING
Line
No.
Action Plan
Area of alignment
1
CPUC Draft DER Action
Plan, version 2.0
(a)
PG&E discusses how EE can integrate with and support other customer programs
and PG&E and Commission objectives, in line with the focus in this action plan’s
DER customer programs track on improving coordination and planning across
proceedings. PG&E’s goals of using EE to shape energy demand to match supply,
supporting customer resiliency, and optimizing delivery of TSB align with the DER
action plan’s goal of enabling all customers “to effectively manage their energy
usage” while ensuring equity, aligning with evolution in rate design, load flexibility,
distribution planning objectives, and integrated resource planning objectives.
2
CPUC Environmental &
Social Justice Action Plan
Draft 2.0
(c)
PG&E’s plans to serve the equity segment, and integrate equity considerations in
other programs, to align with this action plan’s goals of consistent integration of
equity and access considerations throughout CPUC regulatory activities and
increased investment in clean energy resources to benefit ESJ communities.
PG&E’s WE&T programs will promote “high road” career paths (i.e., strategies
focused on economic growth, economic equity, shared prosperity, and a clean
environment) as discussed in the action plan.
3
CEC 2019 EE Action
Plan
(d)
This plan, which offers a comprehensive roadmap for achieving California’s EE and
building decarbonization goals, informs PG&E’s approach in multiple ways. For
example:
PG&E’s goal of supporting economy-wide carbon neutrality by 2045 aligns with this
action plan’s recommendation that programs, research, and policies to work toward
“robust, sustainable efficiency marketplaces” with goals of doubling EE savings,
reducing barriers to EE, and reducing GHG emissions levels from buildings by
2030.
PG&E’s goal of optimizing delivery of TSB aligns with this action plan’s
recommendation to work toward reducing barriers to EE.
PG&E’s goals of shaping energy demand to match supply and supporting customer
resiliency align with this action plan’s recommendation to work toward IDSM.
_______________
(a) CPUC, Distributed Energy Resources Action Plan: Aligning Vision and Action, version 2.0, Draft, July 23, 2021. Last
accessed January 10, 2022 at:
https://www.cpuc.ca.gov/-/media/cpuc-website/divisions/energy-division/documents/distributed-energy-resources-acti
on-plan/draft-der-action-plan-20-public.pdf
(b) Draft DER Action Plan 2.0, p. 18
(c) CPUC, Environmental & Social Justice Action Plan, Draft 2.0, October 26, 2021. Last accessed January 10, 2022 at:
https://www.cpuc.ca.gov/-/media/cpuc-website/divisions/news-and-outreach/documents/news-office/key-issues/esj/dr
aft-cpuc-esj-2010262021c.pdf
(d) CEC, 2019 California Energy Efficiency Action Plan, Final Staff Report, November 2019, CEC-400-2019-010-SF.
Last accessed January 10, 2022 at: https://www.energy.ca.gov/filebrowser/download/1900
(PG&E-1)
PACIFIC GAS AND ELECTRIC COMPANY
CHAPTER 2
ANNUAL PORTFOLIO BUDGETS FOR 2024-2031
(PG&E-1)
2-i
PACIFIC GAS AND ELECTRIC COMPANY
CHAPTER 2
ANNUAL PORTFOLIO BUDGETS FOR 2024-2031
TABLE OF CONTENTS
A. Introduction ....................................................................................................... 2-1
1. Scope and Purpose ................................................................................... 2-1
2. Summary of Request ................................................................................. 2-1
3. Support for the Request ............................................................................. 2-3
(PG&E-1)
2-1
PACIFIC GAS AND ELECTRIC COMPANY 1
CHAPTER 2 2
ANNUAL PORTFOLIO BUDGETS FOR 2024-2031 3
A. Introduction 4
1. Scope and Purpose 5
This chapter provides the annual projected portfolio forecast budgets 6
that sum to the eight-year budget cap request. This chapter also includes 7
savings, cost-effectiveness, and Total System Benefit (TSB) forecasts. 8
In Chapter 1, PG&E describes its portfolio vision, goals, and strategies 9
that support the eight-year budget cap request. Figure 1-3 in Chapter 1 10
highlights PG&E’s desired outcomes for its Energy Efficiency (EE) portfolio. 11
2. Summary of Request 12
PG&E requests that the Commission approve its eight-year budget cap 13
request for 2024-2031 of approximately $2.8 billion, which includes two 14
four-year portfolio cycles (2024-2027 and 2028-2031). The budget cap 15
includes approximately $566 million requested on behalf of Regional Energy 16
Networks (RENs) and Community Choice Aggregators (CCAs) approved for 17
Portfolio Administrator (PA) status within PG&E’s territory.
1
The first 18
four-year portfolio cycle covers 2024-2027 and includes a revenue 19
requirement of approximately $1.4 billion inclusive of approximately 20
$272.7 million requested on behalf of RENs and CCAs approved for PA 21
status within PG&E’s territory.
2
22
1
This request reflects the budget needs of RENs and CCAs approved for PA status as of
January 14, 2022 for program years 2024-2031. This includes Bay Area Regional
Energy Network (BayREN), Tri-County Regional Energy Network (3C-REN),
CleanPowerSF, Marin Clean Energy (MCE), and San Jose Clean Energy (SJCE).
Should REN or CCA filing budgets differ from what is provided, or should REN or CCA
PA statuses change, PG&E’s authorized budget cap request will need to be amended.
PG&E can work with Commission staff to determine the correct regulatory process by
which PG&E can amend this request. PG&E proposes methods for adjusting its budget
cap to account for changes in REN and/or CCA PA status in Chapter 3.
2
Ibid.
2-2
(PG&E-1)
TABLE 2-1
2024-2031 BUDGET CAP REQUEST
Line
No.
2024
2025
2026
2027
2028
2029
2030
2031
Total
1
PG&E EE Portfolio
$272,067,674
$274,280,720
$273,707,915
$275,099,169
$276,847,755
$279,540,628
$283,136,819
$287,613,431
$2,222,294,111
2
BayREN Request
38,101,638
40,336,985
41,278,573
42,059,441
42,900,629
43,758,642
44,633,815
45,526,491
338,596,214
3
MCE Request
19,273,639
19,522,249
19,584,021
19,837,407
19,905,308
19,976,604
20,051,465
20,130,069
158,280,762
4
3C-REN Request
(a)
7,244,336
7,627,211
8,002,482
8,296,593
8,586,973
8,887,518
9,198,581
9,520,531
67,364,224
5
San Jose Clean Power
Request
(b)
–
–
–
–
–
–
–
–
–
6
CleanPowerSF
Request
1,571,732
–
–
–
–
–
–
–
1,571,732
7
Total Authorized
Budget Cap Request
$338,259,019
$341,767,165
$342,572,991
$345,292,609
$348,240,666
$352,163,392
$357,020,679
$362,790,521
$2,788,107,043
_______________
(a) PG&E’s portion of 3C-REN’s budget is 45.6 percent.
(b) PG&E transferred SJCE’s 3-year 2022-2024 authorized budget to SJCE in one lump sum in October 2021, using PG&E’s 2021 funds.
(PG&E-1)
2-3
3. Support for the Request 1
PG&E’s eight-year budget cap request supports its forecast to achieve 2
cumulative TSB of approximately $2.1 billion and a Total Resource Cost 3
(TRC) ratio for its resource acquisition segment of 1.16. See Table 2-2 and 4
Table 2-4. Although first year net savings are no longer an energy efficiency 5
goal metric,
3
forecasted first year net energy savings are still tracked
4
and 6
provided below pursuant to the Energy Division EE Business Plan and 7
Application template.
5
See Table 2-5 and Table 2-6. 8
3
Decision (D.) 21-05-031 replaced the first year net energy savings goal metrics with
Total System Benefit.
4
D.21-05-031, Col 2, p. 74.
5
EE Business Plan and Application Template – Final from ED with EMV, received via
Energy Efficiency Proceeding Service List R.13-11-005 on October 20, 2021.
2-4
(PG&E-1)
TABLE 2-2
TRC COST-EFFECTIVENESS FORECAST FOR 2024-2031
TABLE 2-3
PAC COST-EFFECTIVENESS FORECAST FOR 2024-2031
TABLE 2-4
TOTAL SYSTEM BENEFIT FOR 2024-2031
Line
No.
TRC by Segment
2024
2025
2026
2027
2028
2029
2030
2031
Cumulative
1
Resource Acquisition
0.97
1.00
1.08
1.12
1.19
1.24
1.30
1.38
1.16
2
Market Support
0.61
0.65
0.65
0.69
0.72
0.76
0.80
0.85
0.72
3
Equity
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
4
Evaluation
Measurement &
Verification
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
5
Portfolio w/out C&S
0.77
0.79
0.84
0.88
0.93
0.97
1.01
1.07
0.91
6
Codes and Standards
1.56
1.51
1.48
1.46
1.53
1.59
1.66
1.75
1.55
7
Portfolio w/ C&S
1.29
1.26
1.25
1.25
1.28
1.31
1.35
1.41
1.30
Line
No.
TRC by Segment
2024
2025
2026
2027
2028
2029
2030
2031
Cumulative
1
Resource Acquisition
1.15
1.19
1.28
1.34
1.41
1.47
1.54
1.64
1.38
2
Market Support
1.08
1.15
1.12
1.16
1.28
1.42
1.59
1.80
1.33
3
Equity
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
4
Evaluation
Measurement &
Verification
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
5
Portfolio w/out C&S
1.01
1.05
1.10
1.14
1.22
1.30
1.38
1.49
1.21
6
Codes and Standards
26.22
24.16
22.36
21.82
19.04
17.22
17.06
16.96
20.60
7
Portfolio w/ C&S
4.32
4.12
3.99
3.87
3.57
3.39
3.43
3.49
3.77
Line
No.
TRC by Segment
2024
2025
2026
2027
2028
2029
2030
2031
Cumulative
1
Total System Benefit
$218,132,682
$228,194,451
$236,664,773
$249,031,099
$266,401,266
$284,495,617
$305,723,178
$333,640,871
$2,122,283,937
2-5
(PG&E-1)
TABLE 2-5
SAVINGS FORECAST INCLUDING CODES AND STANDARDS 2024-2031
TABLE 2-6
SAVINGS FORECAST EXCLUDING CODES AND STANDARDS 2024-2031
Line
No.
Energy Savings with
Codes and Standards
2024
2025
2026
2027
2028
2029
2030
2031
Cumulative
1
First Year Net kW
309,190
292,475
278,159
261,881
232,519
213,743
206,881
200,240
1,995,088
2
First Year Net kWh
1,642,847,205
1,515,142,554
1,423,521,887
1,326,068,114
1,198,753,032
1,068,800,247
1,018,430,760
1,013,600,214
10,207,164,013
3
First Year Net Therms
44,660,626
44,181,643
40,161,573
36,334,216
33,517,778
32,818,954
33,254,643
32,614,647
297,544,081
4
Lifecycle Net kWh
19,976,939,374
18,047,484,267
16,879,760,722
15,823,025,659
13,881,525,781
11,895,351,903
11,097,837,642
10,978,934,170
118,580,859,518
5
Lifecycle Net Therms
507,044,770
501,029,262
450,119,217
409,145,830
358,254,986
342,959,970
346,680,937
332,134,992
3,247,369,963
6
Lifecycle CO2 (metric tons)
5,604,954
5,330,982
4,942,884
4,618,361
5,604,954
5,330,982
4,942,884
4,618,361
40,994,364
Line
No.
Energy Savings with
Codes and Standards
2024
2025
2026
2027
2028
2029
2030
2031
Cumulative
1
First Year Net kW
73,404
72,505
73,678
75,300
75,756
76,454
77,381
78,529
603,007
2
First Year Net kWh
439,632,127
435,096,986
439,952,329
442,395,840
448,042,506
455,379,195
464,404,444
475,152,845
3,600,056,273
3
First Year Net Therms
19,700,361
19,833,482
19,293,612
18,772,229
19,149,357
19,555,796
19,991,485
20,456,753
156,753,076
4
Lifecycle Net kWh
2,510,118,651
2,498,392,821
2,542,239,500
2,573,145,308
2,625,288,662
2,697,648,420
2,790,705,449
2,905,394,446
21,142,933,256
5
Lifecycle Net Therms
122,087,408
125,741,452
115,060,022
112,857,392
115,845,226
119,197,115
122,918,082
127,019,042
960,725,739
6
Lifecycle CO2 (metric tons)
1,088,894
1,119,553
1,081,620
1,085,538
1,088,894
1,119,553
1,081,620
1,085,538
8,751,209
(PG&E-1)
2-6
The budget requests for RENs and CCAs included in this forecast are 1
current as of January 14, 2022. PG&E requests that budgets for any new RENs 2
and CCAs approved after this EE application filing are incremental to PG&E’s 3
budget cap request. PG&E provides recommendations for increasing its budget 4
cap in Chapter 3. 5
(PG&E-1)
PACIFIC GAS AND ELECTRIC COMPANY
CHAPTER 3
RECOMMENDATIONS FOR NEW OR MODIFIED ENERGY
EFFICIENCY POLICY
(PG&E-1)
3-i
PACIFIC GAS AND ELECTRIC COMPANY
CHAPTER 3
RECOMMENDATIONS FOR NEW OR MODIFIED ENERGY EFFICIENCY POLICY
TABLE OF CONTENTS
A. Introduction ....................................................................................................... 3-1
B. Policy Changes to Enable EE Portfolios of the Future...................................... 3-2
1. Value and Report Location- or Intervention-Specific Energy System
Benefits ...................................................................................................... 3-2
2. Update IDSM Rules to Support Comprehensive Load Management
and Enable Greater Program Integration ................................................... 3-5
3. Realize the Full Potential of Meter-Based Methods for Industrial
Process and Non-Building Projects ............................................................ 3-7
4. Bolster and Improve Critical Tools for TSB Tracking and Portfolio
Transparency ........................................................................................... 3-11
5. Expand the Range of Options for Procurement Approaches ................... 3-13
C. Policy Changes to Address Portfolio Administration Issues ........................... 3-16
1. Treat Future Approved PA Budgets as Incremental to IOUs’
Application Budget Caps .......................................................................... 3-16
2. Align Portfolio Planning Timelines for All PAs .......................................... 3-18
3. Require Joint Coordination Memoranda for All PAs ................................. 3-21
4. Simplify the Process for Regulatory Filings that Request Cost
Recovery .................................................................................................. 3-23
5. Clarify the Timing of Custom Claims and NMEC True-up Claims ............ 3-24
6. Develop a Process to Regularly Update Statewide
Funding percentages ............................................................................... 3-27
D. Conclusion ...................................................................................................... 3-28
(PG&E-1)
3-1
PACIFIC GAS AND ELECTRIC COMPANY 1
CHAPTER 3 2
RECOMMENDATIONS FOR NEW OR MODIFIED ENERGY 3
EFFICIENCY POLICY 4
A. Introduction 5
This chapter discusses Pacific Gas and Electric Company’s (PG&E) 6
proposals for policy modifications to support the vision outlined in Chapter 1 of 7
this application. 8
Chapter 1 outlines the following goals for PG&E’s energy efficiency (EE) 9
portfolio in 2024-2031: 10
1) Optimize delivery of Total System Benefit (TSB); 11
2) Support economy-wide carbon neutrality by 2045; 12
3) Shape energy demand to match supply; and 13
4) Support customer resiliency. 14
To achieve these goals, PG&E proposes policy changes under two main 15
categories: (1) changes to enable EE portfolios of the future, and (2) changes to 16
address portfolio administration issues. These changes are summarized in 17
Attachment A. 18
PG&E’s portfolio forecast and plans described in Exhibit 2 of this application 19
are largely based on current policy, rather than the changes proposed herein, 20
except as noted below. For example, PG&E’s portfolio forecast described in 21
Exhibit 2 does not include the benefits described in Section B.1 of this chapter. 22
However, if implemented, these policy changes would likely complement and 23
enhance PG&E’s EE strategies. If the California Public Utilities Commission 24
(CPUC or Commission) adopts policy changes that are not incorporated into 25
PG&E’s current portfolio forecast, PG&E would update its portfolio plans in its 26
September 2023 True-up Advice Letter (AL) or September 2025 Mid-Cycle 27
Update AL, depending when policy changes are adopted. 28
The remainder of this chapter is organized as follows: 29
• Section B: Policy Changes to Enable EE Portfolios of the Future 30
• Section C: Policy Changes to Address Portfolio Administration Issues 31
• Section D: Conclusion 32
(PG&E-1)
3-2
B. Policy Changes to Enable EE Portfolios of the Future 1
For EE portfolios to best support decarbonization, alignment of energy 2
demand and supply, and resiliency, the regulatory framework in which they 3
operate must evolve. The shift to TSB goals in Decision (D.) 21-05-031 helped 4
set EE on a path toward optimizing for grid and energy system benefits, rather 5
than simply pursuing first-year energy savings. The policy changes PG&E 6
proposes would help EE portfolio administrators (PA) further tune their offerings 7
for the full range of benefits EE can provide. 8
PG&E proposes policy changes below to: (1) value and report location- or 9
intervention-specific energy system benefits; (2) update Integrated Demand Side 10
Management (IDSM) rules to support comprehensive load management and 11
enable greater program integration; (3) realize the full potential of meter-based 12
methods for industrial process and non-building projects; (4) bolster and improve 13
critical tools for TSB tracking and portfolio transparency; and (5) expand the 14
range of options for procurement approaches. 15
1. Value and Report Location- or Intervention-Specific Energy System 16
Benefits 17
In order to reflect the full value of EE interventions to the electric grid 18
and gas system, PG&E proposes incorporating certain additional energy 19
system benefits into the TSB calculation. While PG&E introduces these 20
benefits below, it recommends discussion in a broader venue such as the 21
Integrated Distributed Energy Resources (IDER) proceeding (Rulemaking 22
(R.) 14-10-003) or its successor proceeding. 23
D.21-05-031 expresses a desire to “capture all of the policy goals and 24
benefits of energy efficiency” as part of its reason for moving to TSB as a 25
goals metric.
1
However, as of the filing of this application, the TSB 26
calculation is largely based on current avoided cost benefits defined in the 27
IDER proceeding.
2
IDER avoided costs capture system-average avoided 28
costs, but may not capture all quantifiable energy system benefits, 29
particularly those that are specific to particular locations or interventions. 30
For example, the avoided cost calculator (ACC) tracks most avoided costs 31
1
D.21-05-031 at p. 8.
2
CPUC, Total System Benefit Technical Guidance, Version 1.2, October 25, 2021, p. 2.
(PG&E-1)
3-3
at a system level,
3
but the localized distribution system benefits discussed 1
below would not be defined at a system level. Incorporating these additional 2
benefits into the TSB calculation would help TSB more accurately reflect the 3
value to the energy system of EE interventions. Incorporating these 4
additional benefits into the TSB calculation would also align with 5
Commission guidance on how to account for avoided gas infrastructure 6
costs in all-electric new construction programs.
4
In addition, because EE 7
PAs optimize their portfolios to meet TSB goals, adding these benefits into 8
the TSB calculation would encourage EE portfolios to find ways to provide 9
them. 10
Below, PG&E discusses several benefits that represent value to the 11
electric grid and/or gas system that EE and other distributed energy 12
resources (DER) could provide. These energy system benefits are not 13
currently valued as avoided costs in IDER or elsewhere, nor are they 14
currently included in the calculation of TSB. PG&E discusses strategies that 15
could yield these benefits in Chapter 1. PG&E asserts it would be beneficial 16
for stakeholders to explore these energy system benefits as part of a 17
broader proceeding such as IDER or its successor. 18
• Localized Distribution System Benefits – PG&E envisions using 19
locationally-targeted EE interventions to delay or reduce the need for 20
forecasted distribution system infrastructure investments. R.13-11-005 21
explored locational targeting in 2014, to address transmission and 22
generation constraints;
5
tightly targeted interventions could also focus 23
on distribution system benefits. 24
3
See 2021 DERs ACC Documentation, Version 1b, available at:
https://willdan.app.box.com/v/2021CPUCAvoidedCosts/file/825224047481
(last accessed August 30, 2021).
4
As stated in the Commission’s TSB Technical Guidance document:
The full benefits portion of the TSB value is calculated by adding together the
avoided costs applied on a kWh or therm basis, the avoided cost of refrigerant
leakage, and the avoided gas infrastructure costs. The avoided gas infrastructure
cost values were approved through Advice Letters 4386-G/6094-E and
4387-G/6095-E. These values may be updated through the EE proceeding
(R.13-11-005), the IDER proceeding (R.14-10-003), or by resolution.
(CPUC, TSB Technical Guidance, Version 1.2, October 25, 2021, p. 8.)
5
D.14-10-046, Section 3.4 at pp. 79-89.
(PG&E-1)
3-4
• Resiliency Support Benefits – PG&E customers currently fund the 1
installation of microgrids or remote grids in areas where replacing other 2
infrastructure with a microgrid will prove less costly for customers in the 3
long run.
6
Ratepayers also pay for backup generation or energy 4
storage for certain customers in high fire threat areas.
7
Installing EE 5
measures prior to installation of the microgrid, generator, or energy 6
storage can help reduce the generation or storage capacity that affected 7
customers need, thus reducing the impact of these costs on customer 8
rates. 9
• Retrofit Building Electrification Benefits – Electrification of existing 10
buildings may confer energy system benefits. For example, when gas 11
appliances are replaced with electric appliances in existing buildings, the 12
gas system and gas customers could benefit from reductions in gas 13
asset operations and maintenance (O&M) costs or the ability to 14
decommission entire sections of gas assets. However, in almost all 15
cases, for these potential benefits to be realized, the entire premise 16
(rather than a selection of individual appliances) would need to be 17
electrified. 18
The Commission notes in D.21-05-031 that it expects the metric it uses 19
for EE goals will influence PAs’ choices about how to manage their 20
portfolios.
8
PG&E agrees that goals and metrics influence portfolio 21
optimization decisions, and therefore supports the consideration of the 22
additional benefits above to incentivize PAs to work toward the policy goals 23
they represent and accurately capture the full range of benefits of EE 24
interventions. 25
6
A.21-06-021, Exhibit (PG&E-4), page 4.3-27 – 4.3-28 (Remote Grid), p. 4.3-45 to 4.3-46
(Temporary Distribution Microgrids).
7
For example, A.21-06-021, Exhibit (PG&E-4), page 4.3-44.
8
D.21-05-031 at p. 9 reads:
Use of a single, lifecycle TSB metric, expressed annually, will tie the goals for the
program administrators directly to the avoided cost value of energy efficiency
savings, which should encourage achievement of savings that deliver high value.
(PG&E-1)
3-5
2. Update IDSM Rules to Support Comprehensive Load Management and 1
Enable Greater Program Integration 2
PG&E proposes that the Commission update existing IDSM rules to 3
facilitate development and implementation of comprehensive load 4
management programs. 5
The Commission’s DER action plan articulates a vision in which flexible 6
load management
9
and IDSM are prominent themes.
10
PG&E’s goals in 7
Chapter 1 also envision EE portfolios that are more closely integrated with 8
other demand-side interventions. Offering programs that combine 9
incentives for, enrollment in, and/or installation of multiple demand-side 10
interventions could serve customers by streamlining participation. 11
Integrated programs could also support the electric grid and gas system by 12
encouraging projects that manage customers’ load more comprehensively 13
and produce greater energy system benefits. They may also support 14
specific state policy goals. For example, Senate Bill (SB) 49
11
calls on the 15
California Energy Commission to incorporate flexible demand-capable 16
devices
12
into appliance standards. The rollout of these devices could 17
support the goals of multiple demand-side management programs: providing 18
TSB and reducing energy usage in the long term, as well as shifting load 19
away from constrained times and toward times of higher renewable 20
generation. 21
Under current rules it is difficult for PAs to offer programs that combine 22
funding or interventions authorized in multiple CPUC proceedings or 23
recognize benefits that accrue across multiple proceedings. To address this 24
issue, PG&E proposes a mechanism for PAs to propose, and for the 25
9
Flexible load management is defined as “steps taken to reduce power demand at peak
load times or shift some of it to off-peak times.” CPUC, Distributed Energy Resources
Action Plan Aligning Vision and Action, Draft, July 23, 2021, p. 25.
10
CPUC, Distributed Energy Resources Action Plan Aligning Vision and Action, Draft,
July 23, 2021. See tracks one and four.
11
SB 49, Approved by Governor October 9, 2019, Bill Text - SB-49 Energy: appliance
standards and State Water Project assessment. (ca.gov).
12
Devices that can “schedule, shift, or curtail the electrical demand of a load-serving
entity’s customer through direct action by the customer or through action by a third
party, the load serving entity, or a grid balancing authority, with the customer’s consent”
(California Public Resources Code Section 25402(7)(A)).
(PG&E-1)
3-6
Commission to delegate to its staff to assess on a case-by-case basis, 1
programs that integrate demand-side management approaches including 2
EE, demand response (DR), distributed generation, managed electric 3
vehicle charging, and time-varying or dynamic pricing. 4
In the past, the Commission has articulated a desire to offer IDSM 5
programs and to use EE as a forum in which to do so. D.07-10-032 6
presented a broad vision for IDSM, ordering investor-owned utilities (IOU) to 7
integrate demand-side customer programs “in a coherent and efficient 8
manner.”
13
IOU portfolios that followed included proposals for IDSM 9
programs and approaches.
14
As far back as 2012, PAs had identified that 10
lack of shared funding was a barrier to integration among demand-side 11
programs.
15
D.18-05-041 ordered PAs to set aside funding for specific EE 12
and DR integration objectives.
16
The use of those funds is subject to 13
several requirements and policy principles which limit the ways IOUs can 14
use them. Below are examples of current requirements: 15
• Residential IDSM efforts should focus on heating, ventilation, and air 16
conditioning (HVAC) technologies and facilitating automatic response to 17
time varying rates; 18
• Non-residential IDSM efforts should focus on HVAC and lighting control 19
technologies; 20
• Non-residential customers must enroll in a DR program for at least one 21
year, and up to three years if an incentive is involved; and 22
• IDSM projects should ensure there is no incremental measure or 23
transaction cost to participate in a DR program after an EE program.
17
24
While these requirements are clear in terms of the desired focus, IDSM 25
efforts that do not meet them may offer value as well—including those that 26
seek to integrate demand-side management approaches other than EE and 27
DR. PG&E proposes that the Commission permit PAs to file ALs for new 28
13
D.07-10-032 at p. 5.
14
See, for example, D.14-10-046, pp. 110-111.
15
D.12-05-015 at pp. 317-318.
16
D.18-05-041, OP 10, p.184.
17
D.18-05-041, pp. 36-38 details requirements and policy principles that govern IDSM
activities.
(PG&E-1)
3-7
IDSM programs. The EE proceeding can serve as a venue because the 1
Commission has historically designated it as the forum for IDSM proposals, 2
or another venue could be explored.
18
New programs could integrate 3
interventions and funding from different proceedings, as EE-DR IDSM funds 4
do. New program proposals would address any needs for rule flexibility 5
within involved proceedings, and the Commission or its staff could consider 6
them on a case-by-case basis. This approach would offer more flexibility 7
than creating a pot of specific IDSM funds from specific sources. 8
3. Realize the Full Potential of Meter-Based Methods for Industrial 9
Process and Non-Building Projects 10
PG&E proposes that the Commission update policy to permit broader 11
use of meter-based methods
19
to calculate the TSB of industrial process 12
projects,
20
and revise rules related to the use of normalized metered energy 13
consumption (NMEC) methods for certain non-building projects. Current 14
decision language limits the conditions under which industrial process 15
projects may use site-level NMEC
21
and third-party programs may use 16
SEM,
22
as detailed below. PG&E requests the Commission update policy 17
to make this method available for industrial process projects. This change 18
would unlock these projects’ TSB potential and could also foster the 19
18
See D.12-05-015 at p. 313.
19
PG&E uses the term “meter-based methods” in this section to refer collectively to
site-level NMEC as well as the Strategic Energy Management (SEM) approach. SEM
calculation methods are sometimes considered to be a subset of site-level NMEC
methods, and sometimes considered separate. The term “meter-based” is intended to
be general and inclusive.
20
In this chapter, PG&E uses the phrase “industrial process projects” to refer to industrial
O&M and behavioral, retrocommissioning, and operational activities.
21
Site-level NMEC is an approach to assessing project savings or TSB by comparing
pre- and post-intervention energy consumption data from the building, site, or system.
Energy consumption data are “normalized,” or mathematically adjusted for factors that
affect energy consumption and are unrelated to the EE intervention(s)—such as
weather or production level (PG&E Resource Savings Rulebook, version 2.0, pp. 98-99.
Available at: PGE_Resource_Savings_Rulebook_2nd_edition.pdf).
22
SEM is a holistic, whole-facility approach to energy savings that focuses on business
practice change affecting organizational culture to reduce energy waste and improve
energy intensity through behavioral and operational change (PG&E Resource Savings
Rulebook, version 2.0, p. 100. Available at:
PGE_Resource_Savings_Rulebook_2nd_edition.pdf).
(PG&E-1)
3-8
development of new, innovative approaches to providing EE to industrial 1
customers. 2
Current policy limits the conditions under which industrial process 3
projects may use meter-based methods in two ways. First, per D.16-08-019 4
and D.18-01-004, only programs that follow the California Industrial SEM 5
Design Guide (SEM Design Guide)
23
may use NMEC or similar 6
meter-based approaches.
24
As D.16-08-019 notes and the 2016 Staff 7
White Paper on Energy Efficiency Baselines details, concerns over the 8
difficulty of determining whether a program influenced a customer to bring 9
equipment up to industry standard practice drove the Commission’s decision 10
to place this limitation.
25
11
Second, in D.18-01-004, the Commission concluded that SEM programs 12
that followed the SEM Design Guide should not “count” toward IOUs’ third 13
party percentage requirements.
26
This restriction limits the adoption of 14
industrial SEM because IOUs must outsource a majority of their 15
programs,
27
and therefore may not have the capacity to support 16
non-third-party-qualifying SEM programs. This limit was intended to be 17
specific to the first two years of the first round of SEM programs, and the 18
Commission signaled a willingness to revisit it in the future.
28
Although the 19
Commission has not done so to date, the timing to revisit the issue is 20
23
Sergio Dias Consulting, LLC, California Industrial SEM Design Guide, version 1.0
February 8, 2017
https://pda.energydataweb.com/api/downloads/1758/CA_Ind_SEM_Design_Guide_v1.0
.pdf.
24
D.16-08-019 declines to apply default existing conditions baseline to industrial and
agricultural process projects at 37-38, but permits the use of NMEC through SEM
programs at 38-39. D.18-01-004 at 47 clarifies and reaffirms the limitation. The
CPUC’s NMEC rulebook reiterates this rule on page 8.
25
D.16-08-019, Sec. 3.8 at pp. 37-43; E-Mail Ruling Attaching Corrected Version of Staff
Whitepaper on Energy Efficiency Baselines and Extending Comment/Reply Deadlines,
R.13-11-005, April 28, 2016, pp. 24-25.
26
D.18-01-004, Conclusion of Law 27, pp. 59-60.
27
D.18-01-004, OP 1, p. 61.
28
D.18-01-004 at pp. 47-48.
(PG&E-1)
3-9
appropriate given the recent release of the draft 2018-19 Industrial SEM 1
Impact Evaluation.
29
2
Two policy changes could resolve these issues. The Commission could: 3
1) Permit the use of NMEC for industrial process projects that meet 4
site-level NMEC qualifying criteria; and/or 5
2) Permit PAs to count programs that follow the SEM Design Guide toward 6
their third-party outsourcing targets. 7
PG&E requests that the Commission make both changes, for the 8
reasons discussed below. 9
The first policy change would allow greater flexibility in program design 10
and make it possible for industrial programs to use both custom and NMEC 11
methods, whichever is appropriate for the project. The Commission could 12
still assess the appropriateness of projects on a case-by-case basis.
30
In 13
addition, it could encourage the development of new, innovative industrial 14
project approaches that incorporate feedback from metered energy 15
consumption data. 16
The second policy change would encourage further expansion of the 17
current industrial SEM approach, and the full incorporation of the best 18
practices in the SEM Design Guide into programs managed and otherwise 19
designed by third parties. The current SEM approach’s value is 20
demonstrated in the positive results of a recent impact evaluation, which 21
29
SBW Consulting, Inc. 2018-19 Industrial Strategic Energy Management (SEM) Impact
Evaluation:
January 31, 2022. Available at:
https://pda.energydataweb.com/api/view/2582/GroupD-SEM 2018-19 Impact Evaluation
PDF Final.pdf.
30
E-Mail Ruling Attaching Corrected Version of Staff Whitepaper on Energy Efficiency
Baselines and Extending Comment/Reply Deadlines, R.13-11-005, April 28, 2016,
p. 24.
(PG&E-1)
3-10
found high realization rates and a near-1.0 net-to-gross ratio—indicating that 1
claimed savings largely withstood the scrutiny of evaluators.
31
2
Should the Commission approve these changes regarding industrial 3
process projects, PG&E respectfully requests that the Commission direct 4
Energy Division staff to update the NMEC Rulebook,
32
and revisit 5
associated language about the permissibility of using NMEC for other 6
non-building projects to ensure it is aligned with Commission decision 7
language and intent. For example, the current NMEC Rulebook prohibits 8
the use of NMEC for all projects outside of existing buildings,
33
which may 9
be interpreted to include agricultural process projects. However, 10
D.16-08-019 authorizes the use of NMEC for agricultural maintenance, 11
operational, and retrocommissioning projects.
34
In addition, PG&E requests 12
the Commission or its staff clarify rules around the permissibility of NMEC to 13
building-adjacent projects, such as parking lot lights. 14
Changes to policy on the appropriate uses of site-level NMEC or other 15
meter-based calculation methods could be addressed in the NMEC working 16
group, which is in progress as of Q1 2022, or in another regulatory venue. 17
31
SBW Consulting, Inc. 2018-19 Industrial Strategic Energy Management (SEM) Impact
Evaluation:
January 31, 2022. Available at:
https://pda.energydataweb.com/api/view/2582/GroupD-SEM 2018-19 Impact Evaluation
PDF Final.pdf.
Realization rate is the ratio of project savings that a PA claims to the project savings
calculated by a Commission-contracted evaluator. A higher realization rate indicates
that evaluators found a claim was more accurate. Net-to-gross ratio is the ratio of
savings net of free ridership (that is, savings that would not have happened in the
absence of the program), compared to the observed savings, some of which might be
driven by factors other than the program. A 1.0 net-to-gross ratio indicates that all of a
project’s savings were attributable to the program.
32
CPUC, Rulebook for Programs and Projects Based on Normalized Metered Energy
Consumption, version 2.0, January 7, 2020. (CPUC NMEC Rulebook). Last accessed
January 8, 2022 at:
https://www.cpuc.ca.gov/-/media/cpuc-website/files/legacyfiles/n/6442463694-nmec-rul
ebook2-0.pdf.
33
CPUC NMEC Rulebook, p. 8: “NMEC projects must occur in existing buildings.”
34
D.16-08-019 at p. 43.
(PG&E-1)
3-11
4. Bolster and Improve Critical Tools for TSB Tracking and Portfolio 1
Transparency 2
PG&E proposes that the Commission bolster and improve two tools PAs 3
depend on to run EE portfolios: the California Energy Data and Reporting 4
System (CEDARS) and the Cost Effectiveness Tool (CET).
35
CEDARS is 5
the Commission website that houses PAs’ monthly and quarterly program 6
tracking data, quantitative portfolio forecasts, and program information and 7
implementation plans. High-level data on each PA’s progress toward its 8
goals and cost effectiveness are also available in a dashboard format. The 9
CET is a calculation tool housed within CEDARS that is used to calculate 10
TSB and cost-effectiveness. 11
Despite the essential role they play in facilitating TSB calculation and 12
stakeholder transparency, funding for CEDARS and the CET has historically 13
been limited, and upgrades that could improve portfolio functioning have 14
lagged. PG&E proposes that the Commission encourage Energy Division 15
staff to increase funding for CEDARS and the CET and more thoroughly 16
engage PAs and other stakeholders in their oversight and maintenance. 17
CEDARS and the CET are key to the functioning of EE programs and 18
portfolios in the following ways: 19
• TSB calculation: The CET is the source of official TSB calculations. 20
Therefore, users will need to run the CET every time they want to 21
understand a project or program’s TSB, for project development, 22
program management, or calculation of performance payments. 23
• Transparency and archiving historical information: CEDARS makes 24
available to stakeholders detailed information on the achievements of 25
EE programs, including historical performance information. 26
Stakeholders can sign up to receive electronic alerts when information is 27
posted or updated. In addition, detailed, anonymized and 28
35
CEDARS is the CPUC’s EE portfolio data website. EE PAs upload monthly tracking
data to CEDARS, as well as quarterly savings claims, budget and portfolio forecasts,
and program implementation plans and other program documentation. Stakeholders
may view PAs’ performance against their goals, read program documents, and
download program performance data. The CET is a module embedded in CEDARS
that executes TSB and cost-effectiveness calculations. PAs upload a spreadsheet
containing parameters needed to calculate TSB and cost-effectiveness, and the CET
returns those values, as well as other such as avoided GHG emissions.
(PG&E-1)
3-12
non-confidential data on programs and installed projects are available 1
for public download. 2
However, these tools require more resources for ongoing maintenance, 3
to add functions to comply with Commission direction or improve program 4
and portfolio efficiency, and to ensure they can be updated quickly and 5
without errors in response to policy changes. Recent compliance updates to 6
the tools have included the addition of avoided gas infrastructure costs and 7
low-global warming potential refrigerant benefits to the CET, and the 8
addition of functionality to properly display the costs and benefits of 9
statewide programs to CEDARS. Beyond compliance updates, examples of 10
improvements that would enhance program and portfolio efficiency include: 11
• Capability of the CET to accept project-specific load shapes.
36
This 12
would enable more accurate tracking of when energy savings occur, and 13
therefore more accurate calculation of TSB, which values system 14
benefits by time of day and year; 15
• Addition of an application programming interface (API) to allow 16
system-to-system communication between PAs’ and implementers’ 17
project data systems and the CET and CEDARS, to enable automated 18
TSB calculation and significantly streamline reporting; 19
• Creation of more robust documentation and training for CET users, so 20
that implementers, PA staff, and other stakeholders feel equally 21
equipped to use the tool, and technical experts can replicate and review 22
the code; and 23
• Addition of a module to allow CPUC-contracted evaluators to access 24
more detailed program tracking data than is available for public 25
download, such that acquisition of data for impact evaluations is as 26
efficient as possible. 27
In addition to an increase in funding, PG&E proposes the Commission 28
direct Energy Division staff to work with PAs to create a governance 29
committee for both the CET and CEDARS, which would provide a venue in 30
which PAs and regulators could prioritize when and how improvements are 31
36
Load shapes show the distribution of energy reduction over each hour of the year, for a
total of 8,760 values.
(PG&E-1)
3-13
made, oversee the budget, and advocate to ensure that the important role 1
these tools play in the functioning of EE portfolios is recognized. One recent 2
positive step in this direction is the Energy Division’s establishment of a CET 3
Project Coordination Group, however, PG&E envisions a more 4
comprehensive governance committee that addresses both CEDARS and 5
the CET. The governance system could be modeled on the California 6
Technical Forum’s (CalTF) implementation of the Electronic Technical 7
Resource Manual (eTRM) database of EE ex ante values.
37
Through a 8
collaborative effort between CalTF, stakeholders, and the Commission, the 9
eTRM now serves as the data source of record for ex ante values.
38
PG&E 10
envisions that the governance committee could engage a coordinator to 11
facilitate its meetings, work with software developers, provide project 12
management, and report to governance committee members on progress. 13
The governance committee could include PAs and energy division staff; 14
other stakeholders could participate ad hoc. 15
One possible mechanism for increasing funding for CEDARS and the 16
CET is for the IOUs to provide funding for their development from the PA 17
portion of their Evaluation, Measurement & Verification (EM&V) budgets.
39
18
PG&E has included funding for this effort in its EM&V forecast budget in 19
Exhibit 2, Chapter 6. 20
5. Expand the Range of Options for Procurement Approaches 21
To enable EE portfolios that can adapt to both gradually evolving and 22
quickly shifting market needs, PG&E requests that the Commission expand 23
the set of acceptable procurement approaches for third party programs. The 24
Commission contemplates a discussion of modifications to the third-party 25
37
Ex ante values are quantitative parameters used to calculate energy savings, TSB, or
cost-effectiveness values PAs report to the Commission.
38
Resolution (Res.) E-5152, p. 25.
39
As detailed in Exhibit 2, Chapter 6, Section C, a set four percent of each PA’s budget is
devoted to EM&V, and those EM&V funds are allocated between PAs and the CPUC.
CEDARS development and maintenance are currently funded out of the CPUC’s portion
of EM&V funds. As detailed in Exhibit 2, Chapter 6, Section 6, IOUs may request a
larger-than-default share of EM&V funds. PG&E envisions that IOUs could request a
larger share of EM&V funds to cover CEDARS and CET development costs if
necessary. This would parallel the manner in which EM&V funds supported eTRM
development.
(PG&E-1)
3-14
solicitation process in the Assigned Commissioner and Administrative Law 1
Judges’ Amended Scoping Ruling (December 2021 Scoping Ruling).
40
The 2
December 2021 Scoping Ruling gives an example of revisiting the use 3
cases for a single-stage solicitation process. PG&E supports this idea and 4
proposes to expand beyond one- and two-stage EE solicitations to also 5
permit all-source requests for proposal (RFPs) and a “market access” 6
procurement model, as authorized for near-term summer reliability programs 7
in D.21-12-011. PG&E discusses in more detail how it would use these 8
procurement models to manage its portfolio in Exhibit 2, Chapter 5, Section 9
E.2. PG&E also requests that the Commission or its staff regularly engage 10
with stakeholders to explore additional procurement approaches other than 11
those listed here. 12
D.18-01-004 established a two-stage solicitation process currently used 13
for third-party EE programs.
41
As PG&E and other stakeholders have 14
previously noted, this process requires significant time and resources from 15
program administrators and implementers and is not well-suited to respond 16
to rapidly-evolving market conditions.
42
D.21-12-011 authorizes the use of 17
a more flexible “market access” approach to procurement of summer 18
reliability-focused projects during 2022-2023. In this approach, rather than 19
signing a contract to deliver on certain goals or metrics, implementers who 20
meet pre-determined eligibility criteria may submit projects as they identify 21
them.
43
This approach may appeal to smaller implementers who lack 22
resources to participate in large RFPs. D.21-12-011 also permits 23
single-stage solicitations for reliability-focused programs,
44
whereas 24
40
Assigned Commissioner and Administrative Law Judges’ Amended Scoping Ruling,
December 23, 2021, p. 4.
41
D.18-01-004, p. 31.
42
See, for example, PG&E’s Opening Comments to the Administrative Law Judge’s
E-Mail Ruling Requesting Comments/Proposals to Address Governor’s Proclamation of
July 30, 2021, pp. 10-11; Comments of Recurve Analytics, Inc. on Email Ruling
Requesting Comments/Proposals to Address Governor’s Proclamation of July 30, 2021,
p. 5.
43
D.21-12-011 at pp. 24-25.
44
D.21-12-011 at pp. 34-35.
(PG&E-1)
3-15
single-stage solicitations have been limited for mainstream EE programs.
45
1
As discussed in Exhibit 2, Chapter 5, Section E.2, two-stage, single-stage, 2
and market access solicitation approaches offer different benefits. In 3
particular, two-stage solicitations can be effective for managing high 4
volumes of submittals; single-stage solicitations are comparatively 5
streamlined and offer versatility through scoring criteria based on complexity 6
of need; and a “market access” approach may create opportunities for 7
smaller providers, increase customer choice, and lower delivery risk for 8
implementers due to the shorter-term nature of contracts. Overall, 9
approaches that streamline the solicitation process and allow PAs to move 10
more nimbly to solicit new programs could open the door to program 11
innovation or participation in EE by a more diverse range of implementers. 12
In addition to the use of the two-stage, single-stage, and market access 13
models for EE interventions, PG&E advocates that the Commission 14
delegate to Energy Division staff the authority to permit EE PAs to run 15
all-source solicitations on a case-by-case basis. These solicitations are 16
technology neutral and would be open to EE interventions as well as other 17
DERs, allowing comparisons between complex and dissimilar program 18
proposals. Similar to the logic by which EE could become a venue for IDSM 19
proposals described in section B.2 of this chapter, EE could become a 20
venue for all-source solicitations for DERs. 21
New procurement approaches also come with risks and tradeoffs, as 22
Exhibit 2, Chapter 5, Section E.2 details. PG&E understands that the 23
Commission may wish to identify opportunities for PAs to experiment with 24
them prior to adopting them broadly. Near-term summer reliability programs 25
offer an opportunity to experiment with single-stage solicitations and the 26
“market access” approach. PG&E requests that at a minimum, the 27
Commission engage stakeholders in providing feedback and reviewing the 28
results of these experiments, and that if the results are positive, the 29
Commission permit other EE programs to use these approaches. 30
Furthermore, PG&E requests that the Commission identify opportunities to 31
45
D.18-01-004 at p. 31.
(PG&E-1)
3-16
permit PAs to run all-source solicitations or consider proposals from PAs to 1
do so. 2
C. Policy Changes to Address Portfolio Administration Issues 3
PG&E proposes changes below to: (1) treat future approved PA budgets as 4
incremental to IOUs’ application budget caps; (2) align portfolio planning 5
timelines for all PAs; (3) require joint cooperation memoranda (JCMs) for all 6
PAs; (4) simplify the process for regulatory filings that request cost recovery; 7
(5) clarify the timing of custom claims and NMEC true-up claims; and (6) develop 8
a process to regularly update EE statewide funding percentages. Each of these 9
changes would address a portfolio administration issue to help EE PAs and their 10
program portfolios function more smoothly, better serve customers, and meet 11
regulatory goals. 12
1. Treat Future Approved PA Budgets as Incremental to IOUs’ Application 13
Budget Caps 14
PG&E proposes that, when new PAs are approved to administer EE 15
programs outside of the four-year application cycle,
46
the new PAs’ budgets 16
be considered incremental to IOUs’ eight-year application budget caps.
47
17
D.21-05-031 requires PAs to request an eight-year budget cap in each 18
application they file, covering the eight years the business plan element of 19
their application addresses. The budget cap can only be revised every four 20
years—when the PA files a new application.
48
Currently, Community 21
Choice Aggregators (CCA) and Regional Energy Networks (REN)
49
may 22
propose to become new EE PAs at any time.
50
REN and CCA budgets are 23
46
Established per D.21-05-031, OP 5, pp. 81-82 and Section 5.
47
As established per D.21-05-031, OP 5, pp. 81-82.
48
D.21-05-031, OP 5, pp. 81-82.
49
RENs are local government entities or collaborations that independently administer EE
programs. The concept was originally introduced in D.12-05-015 (see Sec.6.1.3).
D.19-12-021, Section 2, discusses updated Commission policies on RENs.
50
D.14-01-033, OP 4 and OP 6, pp. 50-51; D.19-12-021 OP 2, pp. 88-89. The following
pathways exist for these entities to propose EE portfolios: a CCA may file an application
to administer an EE portfolio (D.14-01-033 OP4); a CCA may alternatively file a Tier 3
AL “electing” to administer a smaller and more limited EE portfolio (D.14-01-033, OP 6);
and a new REN may form by bringing a motion in an open EE proceeding
(D.19-12-021, OP 2).
(PG&E-1)
3-17
part of IOUs’ EE cost recovery budgets
51
because IOUs collect funds from 1
customers to pass through to REN and CCA PAs that operate in their 2
territory.
52
If a new REN or CCA is approved to administer EE programs 3
between the application filing dates for existing PAs, no regulatory 4
mechanism currently exists for IOUs to adjust their budget caps. If enough 5
RENs or CCAs within an IOU’s territory become portfolio administrators in 6
between application filing dates—or if their approved budget requests are 7
large enough—the IOU must either reduce its own programs or exceed its 8
approved budget cap. 9
To avoid this issue, PG&E respectfully requests that the Commission 10
exclude REN and CCA costs from IOUs’ application budget caps. PG&E 11
also asks that the Commission affirm each existing PA’s application budget 12
cap applies only to that PA itself. This affirmation would be consistent with 13
the Commission’s acknowledgement in Res.E-5166, Certification of San 14
Jose Clean Energy’s Energy Efficiency Program Administration Plan, that 15
budget for a new REN or CCA is “incremental” to the budget of the IOU(s) 16
whose territory the REN or CCA overlaps.
53
17
PG&E’s eight-year budget cap request described in Chapter 2 reflects 18
the budget needs of non-IOU PAs approved for PA status as of January 14, 19
2022 for program years 2024-2031. Should REN or CCA filing budgets 20
differ from what was provided by January 14, 2022, or should a new 21
non-IOU PA be approved to administer EE programs in PG&E’s territory, 22
PG&E would need to amend its authorized budget cap request. If the policy 23
change requested in this section is not adopted, PG&E will work with 24
Commission staff to determine the correct regulatory process by which to 25
51
See, for example, PG&E’s AL 4303-G-A/5936-E-A, p. 32.
52
This is because RENs are not energy providers; IOUs act as billing agents for CCAs;
and CCAs that apply to administer EE portfolios are not limited to serving customers to
whom they provide energy, per a June 20, 2021 Administrative Law Judge’s ruling.
53
Res.E-5166, p. 19-20: “[W]ith regards to PG&E’s comments that the budget to fund
SJCE will result in incremental costs because PG&E has not accounted for the budget
of SJCE in their current rates and collections… we will strike part of the language under
the estimated cost heading on page one to remove that this resolution will not lead to
incremental additional costs. While we are confident that SJCE’s budget can be
absorbed with [PG&E] unspent/uncommitted funds, this may not always be the case as
future CCAs elect-to-administer ratepayer funded EE programs.”
(PG&E-1)
3-18
amend the request, if needed. However, if this policy change is adopted, 1
PG&E’s budget cap request would not need to be amended. 2
2. Align Portfolio Planning Timelines for All PAs 3
PG&E proposes that the Commission align the planning and funding 4
timelines of all EE PAs while allowing sufficient opportunities for potential 5
new program administrators to enter.
54
Currently, CCAs and RENs may 6
propose to become new EE PAs at any time. In addition to the budget 7
challenge discussed in the previous section, this staggered timing presents 8
several other planning challenges as PG&E has previously presented.
55
9
Staggered timing makes it difficult for regulators, stakeholders, and existing 10
PAs to assess the potential for program duplication in a new PA’s proposal 11
and makes it difficult for existing PAs to plan their programs. PG&E 12
recognizes that the Commission stated its intent to address “rules 13
associated with CCAs who elect to administer energy efficiency programs 14
and RENs” in the second half of 2022 in the December 2021 Scoping 15
Ruling, and acknowledges that this proposal may need to be considered 16
prior to 2024.
56
17
Alignment of the portfolio planning cycles for all PAs, new and existing, 18
would confer multiple benefits. First, it would help stakeholders and 19
regulators assess whether offerings serving the same territory complement 20
or duplicate each other. Second, it would facilitate coordination between 21
PAs who operate in overlapping territory or serve overlapping customer 22
populations, helping to minimize program redundancy and customer 23
confusion. Third, it would ensure that when new PAs come online, they 24
conform to the Commission’s most recent portfolio planning guidance and 25
expectations as quickly as is reasonable. 26
54
Public Utilities Code (Pub. Util. Code), Sec. 381.1, notes that the Commission “shall
consider the value of program continuity and planning certainty and the value of
allowing competitive opportunities for potentially new administrators.”
55
PG&E’s Reply Comments on Administrative Law Judge’s Ruling Seeking Comments on
Inland Regional Energy Network Business Plan, pp. 2-3; Comments of Pacific Gas and
Electric Company on Draft Resolution E-5166, pp.3-4; Pacific Gas and Electric
Company’s Response to CleanPowerSF’s Advice Letter 17-E, Election to Administer
Energy Efficiency Program Tier 2 Advice Letter; p. 2.
56
Assigned Commissioner and Administrative Law Judges’ Amended Scoping Ruling,
December 23, 2021, p. 6.
(PG&E-1)
3-19
To ensure alignment of portfolio planning schedules and the timely 1
implementation of the requirements in D.21-05-031, PG&E recommends 2
that, the Commission implement one of the following changes: 3
Option (1): Align new PA filings with the submission of existing PAs’ 4
applications, true up ALs, or mid-cycle review ALs. 5
This change would require all potential new PAs—including RENs, 6
apply-to-administer CCAs, and elect-to-administer CCAs—to file their 7
applications or elect-to-administer ALs in alignment with when existing PAs 8
file their applications every four years,
57
or with the portfolio true-up and 9
mid-cycle review ALs that PAs will file each September in the odd years.
58
10
To ensure that portfolio planning cycles remain consistent, the length of new 11
PAs’ portfolio plans would vary based on the milestone with which their filing 12
aligns (specifically: a new PA filing alongside existing PAs’ applications or 13
true-up ALs would file a four-year plan; a new PA filing alongside existing 14
PAs’ mid-cycle review ALs would file a two-year plan). This change would 15
have the benefit of aligning all PAs’ portfolio cycles and is PG&E’s preferred 16
approach. 17
To ensure that IOUs can include cost recovery for new PAs who operate 18
in their service territory in their applications or ALs, new PAs would need to 19
provide final budgets to IOU PAs far enough in advance of the filing date for 20
the upcoming application or AL that IOUs can incorporate those proposals 21
into their revenue requirements without creating a need for supplemental 22
filings or substitute sheets. Since this issue also relates to existing non-IOU 23
PAs, PG&E discusses a policy proposal to address it further down in this 24
section. 25
PG&E acknowledges that this proposal would limit the times at which 26
new PAs could access funds. However, because new PAs would have the 27
opportunity to request to become administrators of EE funds every two 28
years, PG&E believes this proposal strikes a balance between the planning 29
and coordination benefits of aligning portfolio cycles, and the risks of limiting 30
times at which new PAs may elect or apply. 31
57
See D.21-05-031, OP 5, pp.81-82 and Section 5.
58
D.21-05-031, OP 10, p. 83.
(PG&E-1)
3-20
In considering the optimal timing of these filings, the CPUC may wish to 1
consider whether it is appropriate for new PAs to file portfolio plans within a 2
certain amount of time after existing PAs file theirs, to facilitate new PAs’ 3
identification and filling of gaps in existing portfolios. This topic may be 4
appropriate for the policy discussion envisioned in the December 2021 5
Scoping Ruling. 6
Option (2): Limit consideration of funding for new PAs’ portfolios to the 7
remainder of the current program cycle. 8
PG&E offers this option as an alternative if the Commission determines 9
that it does not wish to pursue the first option above. This would mean, for 10
example, that if a new PA proposes an EE portfolio three years into a given 11
portfolio cycle, its funding would be approved for one year. To bring the new 12
PA’s portfolio planning timeline in line with that of existing PAs, the 13
Commission could consider permitting new PAs in this situation to submit 14
interim filings for consideration alongside existing PAs’ applications, such as 15
a Tier 2 AL similar to the true-up and mid-cycle ALs described in 16
D.21-05-031.
59
This interim filing could be submitted in coordination with 17
existing PAs’ next applications or true-up ALs, whichever filing date comes 18
most immediately after the new PA’s approval to administer EE programs. 19
This approach would place new PAs’ portfolios on the same schedule as 20
those of other PAs as quickly as possible, while continuing to permit new 21
PAs to file applications or elect-to-administer ALs at any time.
60
It would 22
also provide an opportunity to bring new PAs into alignment with up-to-date 23
Commission rules and guidance as quickly as possible. CCAs that apply to 24
administer EE programs are already subject to the most up-to-date rules 25
59
D.21-05-031 OP 10, p. 83.
60
See PG&E’s Reply Comments to the Administrative Law Judge’s Ruling Seeking
Comment on Inland Regional Energy Network Business Plan, p. 3; Opening Comments
of CalAdvocates to the Administrative Law Judge’s Ruling Seeking Comment on Inland
Regional Energy Network Business Plan, p.2.; Opening Comments of Southern
California Edison to the Administrative Law Judge’s Ruling Seeking Comment on Inland
Regional Energy Network Business Plan, pp. 3-4. This topic is also discussed in
D.12-11-013, pp. 8-9.
(PG&E-1)
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and guidance,
61
but under current rules, RENs and elect-to-administer 1
CCAs are not. 2
PG&E respectfully requests that the Commission consider these 3
solutions and adopt one of them. PG&E strongly recommends its first option 4
to align new PA applications or elections with existing PA filings, because it 5
most directly addresses the issue of staggered timing. However, PG&E 6
offers the second option as an alternative. 7
3. Require Joint Coordination Memoranda for All PAs 8
To ensure that there is a mechanism for coordination among PAs that 9
offer programs in the same service territory, PG&E requests the 10
Commission clarify that its Joint Cooperation Memorandum (JCM) filing 11
requirements extend to all instances in which IOU and non-IOU PAs offer 12
EE programs in overlapping territory. D.18-05-041, OP 38 establishes the 13
JCM process: 14
[t]he energy efficiency program administrators must submit annual joint 15
memoranda of cooperation between energy efficiency program 16
administrators with overlapping service areas.
62
17
Currently, parties differ with respect to the applicability of JCMs to CCAs 18
who elect to administer EE portfolios—rather than filing applications. PG&E 19
believes that JCMs should apply to all PAs who work in overlapping territory, 20
because the JCMs are the primary mechanism through which PAs can 21
coordinate on issues such as avoiding program overlap, double-dipping, and 22
customer confusion. The need for that coordination is no less when a PA 23
has elected to administer an EE portfolio. The Commission has recognized 24
the growing importance of coordination, stating, “The CPUC agrees with 25
PG&E that with more PAs offering EE programs there will be the need for 26
increased coordination with other PAs who overlap service territory.”
63
The 27
Commission indicated in Res.E-5180 that it intended to take up this issue in 28
the decision on PAs’ 2024-2031 application filings;
64
like the policy 29
61
D.14-01-033, OP 4, pp.50-51.
62
D.18-05-041, OP 38, pp.190-191.
63
Res. E-5050 at p.23.
64
Res.E-5180 at p. 23.
(PG&E-1)
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proposals discussed in sections C.1 and C.2., this proposal may also be 1
appropriate for the discussion of elect-to-administer CCA rules presaged in 2
the December 2021 Scoping Ruling. 3
As PG&E has noted previously,
65
it interprets the language of relevant 4
decisions to communicate that the JCM process should apply uniformly to all 5
types of PAs, including elect-to-administer CCAs. D.21-05-031, Ordering 6
Paragraph (OP) 7 reaffirms the JCM requirement applies to all PAs: 7
[a]ll program administrators shall continue to prepare and submit Joint 8
Cooperation Memoranda (JCMs), according to the existing 9
requirements.
66
10
D.14-01-033, which operationalizes the two pathways for CCAs to 11
administer EE programs outlined in Pub. Util. Code Sec. 381.1, 12
communicates in its discussion of the elect-to-administer option that it is a 13
pathway to “energy efficiency program administration,” like filing an 14
application under Pub. Util. Code Sec. 381.1(a-d).
67
Finally, the CPUC’s 15
EE Policy Manual defines “Program Administrator” simply as “[a]n entity 16
tasked with the functions of portfolio management of EE programs and 17
program choice.”
68
The applicability of the JCM requirement to all PAs may 18
be unclear because D.18-05-041, OP 38 includes a list of specific PAs 19
required to file JCMs, and does not include any CCAs that elected to 20
65
Comments of Pacific Gas and Electric Company on Draft Resolution E-5166, pp. 5-6;
Subject: Pacific Gas and Electric Company’s Response to CleanPowerSF’s Advice
Letter 17-E, Election to Administer Energy Efficiency Program Tier 2 Advice Letter, p. 3.
66
D.21-05-031, OP 7, p. 82.
67
D.14-01-033, p. 20, Section 3.2.4 of the decision begins, “As noted previously, SB 790
– modified Section 381.1 to give CCAs two options for energy efficiency program
administration” (emphasis added).
68
CPUC, Energy Efficiency Policy Manual, version 6.0, April 2020, p. 81-2. While the
policy manual is not formally adopted by the CPUC (see p. 8 of the manual), it
communicates Commission staff understanding of CPUC policy rules stipulated in
decisions and resolutions. It is therefore a relevant source for the generally accepted
understanding of terms such as “program administrator.”
(PG&E-1)
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administer EE programs.
69
However, this does not necessarily imply that 1
the JCM requirement applies to certain PAs and not others. 2
PG&E requests the Commission clarify that all IOU and non-IOU PAs 3
that work in overlapping territory must file JCMs. Doing so would ensure 4
that these PAs have a formal mechanism for collaboration and coordination, 5
to the ultimate benefit of the customers they serve. As with the above 6
proposal regarding PA filing timelines, PG&E acknowledges that this issue 7
may be discussed in the second half of 2022 per the December 2021 8
Scoping Ruling for this proceeding.
70
9
4. Simplify the Process for Regulatory Filings that Request Cost 10
Recovery 11
To simplify the process for regulatory filings that request cost recovery 12
or provide budget information aggregated across multiple PAs in one service 13
territory, PG&E requests that the Commission authorize staggered due 14
dates for IOU PAs and non-IOU PAs. Specifically, PG&E requests that the 15
Commission authorize IOU PAs who share territory with non-IOU PAs to 16
submit territory total or rate impact information two weeks after the primary 17
submission deadline. This approach will enable these IOUs to file total cost 18
recovery and rate impact figures that reflect final budgets and other 19
information for non-IOU PAs, without restricting the time for the non-IOU 20
PAs to finalize those numbers. 21
Currently, when filing ALs or applications that request to recover the 22
cost of EE programs, IOUs must request budgets early from RENs and 23
69
D.18-05-041, OP 38, p. 190-191. However, this specificity must be considered in
context. D.18-05-041 approved the EE business plans of a group of eight PAs, (see
D.18-05-041, p. 1), and so it is logical that it would address subsequent filing
requirements of those specific PAs. MCE was the only CCA included in this group, so it
makes sense that the decision at certain points refers to “MCE” rather than to “CCAs”
generally (see, for example, D.18-05-041, pp. 122-3). Further adding complexity,
approximately one month before D.18-05-041 was issued, the Commission certified the
election to administer EE programs of Lancaster Choice Energy (Lancaster), a CCA (in
Res.E-4917). D.18-05-041 does not direct Lancaster to file a JCM with any IOU.
However, this may be because D.18-05-041 was issued early in Lancaster’s tenure as a
PA, or because D.18-05-041 focuses on requirements for the PAs whose business
plans it approves.
70
See Assigned Commissioner and Administrative Law Judges’ Amended Scoping
Ruling, December 23, 2021, p. 6.
(PG&E-1)
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CCAs with whom they share territory so that the IOUs can incorporate REN 1
and CCA totals into their calculations. Last-minute changes made to 2
non-IOU PAs’ budgets can result in the need for IOUs to file supplemental 3
filings or substitute sheets, which adds administrative work and can make it 4
difficult for stakeholders to identify final cost and budget information. A 5
staggered deadline would enable non-IOU PAs to make relatively late 6
budget adjustments without causing IOUs to file supplemental filings or 7
substitute sheets, allow IOUs to confirm that they are using truly “final” 8
figures to calculate rate impacts, and reduce the potential for stakeholder 9
confusion. 10
5. Clarify the Timing of Custom Claims and NMEC True-up Claims 11
PG&E respectfully requests that the Commission clarify that custom 12
measure and project TSB
71
should be reported when all steps to finalize 13
TSB calculations have been completed—including physical installation, 14
commissioning, measurement and verification (M&V) of TSB, and 15
post-install quality control checks performed by the PA or the CPUC. PG&E 16
believes that current guidance leaves room for differing interpretations, 17
which has caused confusion in ex-post impact evaluations. A uniform 18
approach that requires custom project TSB to be finalized prior to reporting 19
will help to dispel confusion. Alongside this proposal, PG&E also makes a 20
related request that the Commission update a requirement that places a 21
time limit on NMEC claims, to account for the reporting process established 22
for NMEC claims and accommodate projects that track savings over multiple 23
years. 24
Three CPUC decisions address aspects of the timing of claims for 25
custom projects. 26
• D.04-09-060 introduces guidance that (1) energy savings of “actual 27
installations” of projects, not merely commitments, should be counted 28
71
Throughout this section, PG&E uses “TSB” and in some cases “savings/TSB” to refer to
savings, TSB, and other ex ante parameters that PAs report. Decisions cited in this
section were issued during a time when EE goals were set in energy and demand
savings and use the word “savings.”
(PG&E-1)
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toward savings goals, and (2) savings claims should be reported in the 1
calendar year in which measures are installed;
72
2
• D.05-04-051 reaffirms this guidance and orders program administrators 3
to follow it.
73
Neither D.04-09-060 nor D.05-04-051 defines when 4
installations are to be considered completed, leaving room for 5
interpretation as to whether “actual installation” means physical 6
installation only, or also includes steps to finalize the project 7
savings/TSB, such as those mentioned above; and 8
• D.11-07-030 requires PAs to follow the custom project ex ante review 9
process,
74
which requires PAs to calculate and pay final customer 10
incentives, and to report and claim any savings adjustments only after 11
the CPUC Energy Division’s post-installation inspection is complete.
75
12
PG&E proposes that project savings be reported once all steps to 13
finalize savings/TSB, including M&V tasks, are complete. This is consistent 14
with D.11-07-030, however, when M&V steps cause project finalization to 15
fall in a different year than when the project’s physical installation began, a 16
conflict may arise if a stakeholder interprets the two earlier decisions as 17
requiring that custom projects must be claimed in the year in which their 18
physical installation is completed. As custom projects undergo more 19
72
D.04-09-060, p. 33.
[O]nly actual installations should be counted towards these goals, and not
commitments. That means, for example, that the savings reported for PY2006 will
reflect measures actually installed during calendar year 2006 (January through
December), regardless of whether the commitments to install those measures were
made in PY2006 or in prior program year(s).
73
D.05-04-051 OP 17, pp. 96-97:
[O]nly actual installations should be counted towards these goals, and not
commitments, with the exception discussed below. That means, for example, that
the savings reported for PY2008 will reflect measures actually installed during
calendar year 2008 (January through December), regardless of whether the
commitments to install those measures were made in PY2008 or in prior program
year(s).
74
D.11-07-030 OP 7, p. 49 requires the IOUs to follow the custom project ex ante value
review process in Attachment B.
75
D.11-07-030 Attachment B details the “pre-installation review” and “post-installation
review” processes that allow the Energy Division to provide input on ex ante savings
development, including on post-installation M&V on projects selected by Energy
Division (ED). The IOUs are required to report in claims any savings adjustments made
after ED’s post-installation M&V inspection.
(PG&E-1)
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extensive M&V to verify ex ante calculations, projects—especially larger, 1
more complex, and projects with higher savings/TSB—take longer to close 2
out. This increases the likelihood the physical installation and the 3
finalization of savings will not fall into a single calendar year. In addition, 4
due to their complexity, these projects are much more likely to have their 5
post-install M&V savings updated from pre-installation estimates. Therefore, 6
reporting savings on a provisional basis with the prior year’s savings claims 7
would add administrative burden and administrative cost for limited benefit 8
and would increase the likelihood of confusion among stakeholders who 9
review ex ante claims data. 10
PG&E proposes that to resolve this matter, the Commission clarify that 11
PAs should claim savings for custom projects when project savings 12
verification steps are final. PG&E proposes the following language: 13
For custom projects, installation date shall be determined by project 14
finalization date, defined as the date when energy efficiency measures are 15
installed and commissioned, and all monitoring and verification (M&V) tasks 16
are completed, as determined by the program administrator. 17
For custom projects selected for CPUC ex ante review, installation date 18
shall be determined by project finalization date, determined after completion 19
of the CPUC review and approval of ex ante values, and determined by the 20
program administrator upon completion of all M&V tasks. 21
M&V tasks may include, but are not limited to, collection and approval of 22
invoices or other measure cost data, collection of all required forms such as 23
contractor license verification, and verification that approved savings and 24
other values are properly entered in the program administrator’s savings 25
and/or TSB calculations. 26
Similarly, PG&E also requests that the Commission eliminate an 27
out-of-date requirement related to the timing of NMEC claims. The 28
Administrative Law Judge’s Ruling Issuing Revised Rulebook for Programs 29
and Projects Leveraging Normalized Metered Energy Consumption
76
30
(NMEC Rulebook Ruling) requires PAs to “submit a final claim, with savings 31
76
This ruling, issued January 7, 2020, accompanied the release of the version of the
Commission’s NMEC Rulebook in use as of the time of this filing. Available at:
EnergyEfficiency2015-BeyondRollingPortfolios_Ruling_CPUC_20200107_591273.pdf.
(PG&E-1)
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calculated using NMEC methods after the performance period is complete, 1
for all NMEC-based savings counted toward goal attainment by January 31 2
of two years after the program year installed. For example, to count savings 3
form 2020 installed projects toward 2020 goal attainment, the PA must 4
submit a final savings claim for those projects by January 31, 2022.”
77
This 5
requirement does not account for the fact that NMEC project or program 6
M&V may not be complete by January 31 of the year after the NMEC 7
performance period is completed—for example, because project 8
calculations may take longer to execute. This requirement also does not 9
account for the fact that some programs and projects may have 10
performance periods that are too long to be able to report a final claim by 11
January 31 of two years after the installation year. 12
After the NMEC Rulebook Ruling was issued, PA and CPUC staff 13
collaborated to develop guidance and a process for reporting on NMEC 14
programs and projects.
78
Through this process, PAs report initial claims 15
when project installation is complete, based on estimates of project 16
savings/TSB, then “true-up” these estimates after NMEC M&V is 17
complete.
79
The use of estimated and true-up claims allows PAs to account 18
for the impacts of NMEC projects on a rolling basis, concurrently with 19
deemed and custom project/program impacts. As a result, the time limit put 20
in place in the NMEC Rulebook Ruling is no longer necessary, and PG&E 21
recommends striking this requirement. 22
6. Develop a Process to Regularly Update Statewide 23
Funding percentages 24
PG&E requests that the Commission direct Energy Division staff to 25
establish a process to regularly update IOU funding share 26
contribution percentages for EE statewide programs. Development of this 27
77
NMEC Rulebook Ruling, p. 9. The term “performance period” refers to the period after
project installation or implementation is complete, during which energy usage data is
monitored so that savings/TSB may be calculated using NMEC methods.
78
The basic structure of NMEC reporting is captured in Energy Division Staff Guidance:
NMEC Reporting, a document shared by an Energy Division staff member with PA EE
reporting staff by email on April 24, 2020. The NMEC reporting process has evolved
since 2020 but this document captures the basic principles.
79
See for example Energy Division Staff Guidance: NMEC Reporting, p. 2 and p. 3.
(PG&E-1)
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process could simply result from a discussion between Commission staff 1
and IOUs, or from engagement with a broader set of stakeholders. Current 2
funding share proportions are based on the IOU goals and budgets from 3
several years ago;
80
the goals have since been superseded and the 4
budgets were only authorized through 2025. PG&E requests that the IOUs, 5
in coordination with Energy Division staff, revisit the inputs for the 6
contribution percentage calculations prior to the planned 2023 True Up AL 7
covering 2024-2027. In addition, PG&E respectfully requests that the 8
Commission direct staff to work with IOUs to develop a process for regular 9
updates to these percentages, which could be tied to the four-year portfolio 10
application cycle, or to the EE Potential and Goals Study updates. 11
D. Conclusion 12
If adopted, PG&E’s proposals detailed above would combine to help EE 13
portfolios shift toward the future envisioned in D.21-05-031 and the CPUC’s 14
DER Action Plan, version 2.0, in which EE focuses on producing energy system 15
benefits, integrates with other demand-side programs, and supports flexible load 16
management. They would also help EE portfolios function more efficiently. 17
80
Funding shares for statewide programs are based on a methodology described in a joint
AL filed by the IOUs in 2018 (PG&E’s AL 5373-E-A/4009-G-A, Supplemental: San
Diego Gas & Electric Company, Southern California Gas Company, Southern California
Edison Company, and Pacific Gas & Electric Company’s Shared Funding Mechanism
Proposal Pursuant to Decision 18-05-041 (November 15, 2018)). As described on p. 4.,
these funding shares were based on 2018 EE Potential and Goals Study Goals and
portfolio budgets adopted in D.18-05-041. Available at: GAS_4009-G-A.pdf (pge.com).
(PG&E-1)
PACIFIC GAS AND ELECTRIC COMPANY
CHAPTER 3
ATTACHMENT A
SUMMARY LIST OF POLICY CHANGES
(PG&E-1)
3-AtchA-1
Exhibit 1, Chapter 3, Attachment A: Summary List of Policy Changes
In this attachment, PG&E respectfully offers suggested language for how its policy
proposals described in Exhibit 1, Chapter 3 may be integrated into future Commission
decisions, should the Commission decide to make these changes. Where fitting, PG&E
suggests potential wording of findings of fact, conclusions of law, and ordering
paragraphs.
Policy Changes to Enable EE Portfolios of the Future
1. Value and Report Location- or Intervention-Specific Energy System
Benefits
o Suggested order:
The calculation of Total System Benefit (TSB) shall include both
(1) avoided costs incorporated into the Avoided Cost Calculator
(ACC), and (2) other applicable avoided costs that are adopted by
the Integrated Distributed Energy Resources (IDER) proceeding
(R.14-10-003)—or its successor—outside of the ACC.
o For a discussion of this issue, see Exhibit 1, Chapter 3, B.1.
2. Update Integrated Demand Side Management (IDSM) Rules to Support
Comprehensive Load Management and Enable Greater Program
Integration
o Suggested order:
Program administrators
1
may file Tier 2 or Tier 3 advice letters in
the EE proceeding proposing new IDSM programs. The advice
letter tier shall be determined in accordance with General Order
96-B, Industry Rule 5. These programs may integrate interventions
including, but not limited to: energy efficiency, demand response,
distributed generation, managed electric vehicle charging, and time
varying or dynamic pricing. These programs may integrate funding
1
In Exhibit 1, Chapter 3 and throughout its testimony, PG&E uses the term “portfolio administrator”,
rather than “program administrator”, to refer to those administering portfolios of EE programs primarily
implemented by third parties. However, PG&E uses the term “program administrator” in this attachment in
order to align with conventional Commission language.
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3-AtchA-2
from multiple Commission proceedings, and may have benefits
that accrue across multiple proceedings.
o For a discussion of this issue, see Exhibit 1, Chapter 3, B.2.
3. Realize the Full Potential of Meter-Based Methods for Industrial Process
and Non-Building Projects
o Suggested findings:
Ratepayer-funded industrial Strategic Energy Management (SEM)
programs in California served their first cohort between 2018 and
2020.
2
The 2018-19 Industrial SEM Impact Evaluation found high
realization rates and 1.0 or near-1.0 net-to-gross ratios.
Normalized metered energy consumption (NMEC, as defined in
the CPUC’s NMEC Rulebook, version 2.0
3
) can be used to
calculate ex ante savings and/or Total System Benefit (TSB) of
energy efficiency projects and programs, compared to a baseline
of existing conditions.
NMEC can be used to calculate ex ante savings and/or TSB of
energy efficiency operations & maintenance (O&M) and/or
behavioral, retrocommissioning, and operations (BRO)
interventions and activities.
Because it uses metered energy consumption data from
participating sites both before and after energy efficiency project or
measure implementation, site-level NMEC may be the most
appropriate method by which to calculate the savings and/or TSB
impacts of O&M or BRO activities on large, distinctive sites or
operations.
2
SBW Consulting, Inc. 2018-19 Industrial Strategic Energy Management (SEM) Impact Evaluation,
January 31, 2022, p. 15, Table 6. Available at:
https://pda.energydataweb.com/api/view/2582/GroupD-
SEM 2018-19 Impact Evaluation PDF Final.pdf
3
California Public Utilities Commission, Rulebook for Programs and Projects Based on Normalized
Metered Energy Consumption, version 2.0, January 7, 2020. (CPUC NMEC Rulebook). Last accessed
January 8, 2022 at:
https://www.cpuc.ca.gov/-/media/cpuc-website/files/legacyfiles/n/6442463694-nmec-
rulebook2-0.pdf
(PG&E-1)
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California’s building energy efficiency standards include within
scope outdoor lighting in building-attached functional areas,
parking areas and other hardscape.
4
o Suggested conclusions:
Because the initial two-year period of SEM program engagement
has concluded, it is logical to reevaluate limitations on NMEC
programs and projects intended to apply during the duration of that
period.
Because SEM programs have matured beyond their initial cohort
and have undergone ex post impact evaluation, it is logical to
evaluate whether to permit or encourage their expansion.
Permitting SEM programs that follow the SEM Design Guide to
“count” as third party would enable the expansion of best practices
detailed in this guide.
Across all sectors, projects and program approaches that use
O&M or BRO interventions and activities should have their
baselines set based on existing conditions, when NMEC methods
are used to assess ex ante savings or TSB in comparison to
existing conditions. This includes process-oriented industrial sector
projects and programs that are not part of a Strategic Energy
Management program.
It is logical to extend the applicability of NMEC to building-attached
or adjacent projects, such as outdoor lights subject to Title 24, part
6.
o Suggested orders:
IOUs may “count” otherwise-qualifying third party programs that
that follow the SEM Design Guide toward their third party
outsourcing targets.
Across all sectors, projects and program approaches that use
O&M or BRO interventions and activities shall have their baselines
4
Title 24, Part 6, and Associated Administrative Regulations. See, for example, Sec. 130.0(b)(2) and
Section 140.7. Available at: 2019 Building Energy Efficiency Standards (ca.gov)
(PG&E-1)
3-AtchA-4
set based on existing conditions when NMEC methods are used to
assess ex ante savings or TSB in comparison to existing
conditions. This includes process-oriented industrial sector projects
and programs that are not part of Commission-defined Strategic
Energy Management programs. Projects will remain subject to
applicable Commission ex ante review processes.
NMEC methods may be used to assess ex ante savings or TSB of
otherwise qualifying building-attached or adjacent projects or
measures. For the purposes of assessing whether or not these
projects qualify for the use of NMEC methods, building-attached or
adjacent measures shall be considered part of an “existing
building.”
Energy Division staff shall update the Commission’s Rulebook for
Programs and Projects Based on NMEC to reflect the above
orders, including clarifying the applicability of NMEC and existing
conditions baseline to process-oriented industrial and agricultural
sector projects, including those outside of Commission-defined
Strategic Energy Management programs.
o For further discussion of these issues, see Exhibit 1, Chapter 3, B.3.
4. Bolster and Improve Critical Tools for TSB Tracking and Portfolio
Transparency
o Suggested orders:
Energy Division staff shall ensure adequate funding for the
California Energy Data Reporting System (CEDARS) and the EE
Cost-Effectiveness Tool (CET).
Energy Division staff shall work with the EE program
administrators to develop a stakeholder governance committee for
CEDARS and the CET. The governance committee shall comprise
staff of energy efficiency program administrators and Energy
Division staff. The governance committee shall: (1) discuss the
relative priority of proposed improvements and updates to
CEDARS and the CET; (2) determine the schedule and budget for
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3-AtchA-5
updates to CEDARS and the CET; (3) solicit and review input from
other stakeholders on potential improvements and updates to
CEDARS and the CET; and (4) inform other stakeholders of plans
for CEDARS and CET development.
o For a discussion of this issue, see Exhibit 1, Chapter 3, B.4.
5. Expand the Range of Options for Procurement Approaches
o Suggested findings:
Several procurement options, including one- and two-stage
solicitations and the “market access” procurement model may be
useful for procuring EE programs. Each approach has different
strengths and use cases.
Two-stage solicitations are effective for managing high volumes of
proposal submittals, while single-stage solicitations are
comparatively streamlined and offer versatility. A “market access”
approach may create opportunities for smaller providers.
As IOUs’ EE portfolios move into a majority third-party outsourced
state, they may have a reduced need for large-scale, multi-sector
solicitations, and an increased need to run targeted, smaller-scale
solicitations with rapid turnaround.
Technology-neutral all-source solicitations may be useful for
procuring EE programs and other DERs, and would allow
comparisons between complex and dissimilar program proposals.
o Suggested conclusions:
EE program administrators should be permitted to use one- and
two-stage solicitations, and run “market access” style
procurements.
Two-stage solicitations should no longer be the predominant
approach for majority-outsourced EE portfolios.
EE program administrators should be permitted to run all-source
solicitations.
o Suggested order:
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EE program administrators may use one- or two-stage
solicitations, and may run “market access” style procurements.
o For a discussion of this issue, see Exhibit 1, Chapter 3, B.5.
Policy Changes to Address Portfolio Administration Issues
1. Treat Future Approved Program Administrator Budgets as Incremental to
IOUs’ Application Budget Caps
o Suggested language:
When new program administrators receive Commission approval
to administer EE programs outside of the 4-year application cycle
established in D.21-05-031, their funding requests shall be
considered incremental to IOUs’ current 8-year application budget
caps.
o For a discussion of this issue, see Exhibit 1, Chapter 3, C.1.
2. Align Portfolio Planning Timelines for All Program Administrators
o Suggested orders:
Parties requesting to become EE program administrators—either
by bringing a motion to form a new REN or through the application
or CCA elect-to-administer process—must align their filings with
existing program administrators’ applications, true-up advice
letters, or mid-cycle advice letters. To “align their filings” means
either to file on the due date for existing program administrators’
applications or advice letters, or to file within a reasonable time
period after the due date for existing program administrators’
applications or advice letters.
We delegate to Energy Division staff authority to define a
“reasonable time period” after the due date for existing program
administrators’ applications or advice letters in which parties
requesting to become new EE program administrators may make
their filings.
o For a discussion of this issue, as well discussion of an alternative
proposal, see Exhibit 1, Chapter 3, C.2.
(PG&E-1)
3-AtchA-7
3. Require Joint Cooperation Memoranda for All Program Administrators
o Suggested order:
All program administrators, including RENs, CCAs who apply to
administer EE programs, and CCAs who elect to administer EE
programs, shall continue to prepare and submit Joint Cooperation
Memoranda (JCMs), according to the existing requirements for the
content and timing of JCMs.
o For a discussion of this issue, see Exhibit 1, Chapter 3, C.3.
4. Simplify the Process for Regulatory Filings that Request Cost Recovery
o Suggested order:
In applications, advice letters, and other filings in which Investor
Owned Utility (IOU) program administrators request cost recovery
on behalf of Regional Energy Networks, Community Choice
Aggregators, or other program administrators, IOUs shall submit all
required elements of the filing by the filing submission deadline,
with the exception of territory-level budget and TSB totals or rate
impacts. IOUs shall separately submit territory-level totals and/or
rate impacts that reflect the combined final budgets and TSB
forecasts from all program administrators on behalf of whom they
are requesting cost recovery. This separate submission shall be
considered supplemental to the filing, and shall be submitted 10
business days after the filing submission deadline for the original
filing.
o For a discussion of this issue, see Exhibit 1, Chapter 3, C.4.
5. Clarify the Timing of Custom Claims and NMEC True-up Claims
o Suggested findings:
Energy Division Staff Guidance: NMEC Reporting (NMEC
Reporting Guidance) describes the two-stage process by which ex
ante claims for measures and projects that use NMEC methods to
calculate savings and/or TSB are reported.
• Note: PG&E respectfully suggests that, after Energy
Division staff have the opportunity to update this guidance
(PG&E-1)
3-AtchA-8
to reflect any changes made after April 2020, the NMEC
reporting guidance be incorporated into or attached to a
future updated version of the CPUC’s NMEC Rulebook.
Although program administrators report “estimated” claims for
NMEC programs and projects prior to the completion of M&V,
claims for NMEC programs and projects are considered final only
after they have been trued up to post-M&V values.
o Suggested orders:
Program administrators shall report final ex ante savings and/or
TSB claims for custom/calculated measures and projects only after
all M&V tasks are completed, as determined by the program
administrator.
• For custom projects, installation date shall be determined by
project finalization date, defined as the date when energy
efficiency measures are installed and commissioned, and all
M&V tasks are completed, as determined by the program
administrator.
• For custom projects selected for CPUC ex ante review,
installation date shall be determined by project finalization
date, determined after completion of the CPUC review and
approval of ex ante values, and determined by the program
administrator upon completion of all M&V tasks.
• M&V tasks may include, but are not limited to, collection and
approval of invoices or other measure cost data, collection
of all required forms such as contractor license verification,
and verification that approved savings and other values are
properly entered in the program administrator’s savings
and/or TSB calculations.
Program administrators shall report final ex ante savings and/or
TSB claims calculated using normalized metered energy
consumption (NMEC) only after all M&V tasks are completed, as
determined by the program administrator.
(PG&E-1)
3-AtchA-9
o For a discussion of these issues, see Exhibit 1, Chapter 3, C.5.
6. Develop a Process to Regularly Update EE Statewide Funding Percentages
o Suggested orders:
Energy Division staff shall work with IOU staff to update IOU
funding share contribution percentages to be used in IOUs’ 2023
True Up Advice Letters.
Energy Division staff shall work with IOU staff to develop a process
to regularly update IOU funding share contribution percentages for
EE statewide programs.
o For a discussion of this issue, see Exhibit 1, Chapter 3, C.6.
(PG&E-1)
PACIFIC GAS AND ELECTRIC COMPANY
APPENDIX A
STATEMENTS OF QUALIFICATIONS
RWB-1
PACIFIC GAS AND ELECTRIC COMPANY 1
STATEMENT OF QUALIFICATIONS OF ROBERT W. BOHN 2
Q 1 Please state your name and business address. 3
A 1 My name is Robert W. Bohn, and am currently working remotely as Pacific 4
Gas and Electric Company (PG&E) transitions from its prior location at 5
77 Beale Street, San Francisco, California to 300 Lakeside Drive, Oakland, 6
California. 7
Q 2 Briefly describe your responsibilities at PG&E. 8
A 2 I am a Principal Portfolio Manager on the Energy Efficiency (EE) Portfolio 9
Strategy and Optimization team. I am the optimization lead for PG&E’s EE 10
portfolio. My functional responsibilities include leading PG&E’s EE portfolio 11
forecasting efforts for regulatory filings and advising PG&E EE leadership on 12
portfolio performance using EE program and portfolio data. I conduct EE 13
measure and program benefit-cost analyses and help the PG&E EE team 14
better understand the cost effectiveness of EE interventions. I also analyze 15
EE market and policy changes which impact PG&E’s EE portfolio. 16
Q 3 Please summarize your educational and professional background. 17
A 3 I received a Bachelor of Science in mechanical engineering from University 18
of California, Los Angeles in 2008. After graduating, I received a 19
commission in the United States Marine Corps and served on active duty 20
until 2015. I attended the University of California, Davis Graduate School of 21
Management and received a Master of Business Administration in 2017. 22
Upon graduation, I joined PG&E as a product manager on the Energy 23
Efficiency Product Management team. In 2019, I transitioned to my current 24
role as a portfolio manager on the newly formed Portfolio Strategy and 25
Optimization team. 26
Q 4 What is the purpose of your testimony? 27
A 4 I am sponsoring the following testimony and workpapers in support of 28
PG&E’s Energy Efficiency 2024 Business-Portfolio Plan Application: 29
• Exhibit 2, “PG&E Energy Efficiency 2024-2027 Portfolio Plan”: 30
− Chapter 2, “Forecast Methodology”; 31
− Chapter 2, Attachment A, “PG&E Energy Efficiency 2024-2027 32
Program-Level Annual Cost Variance Explanations.” 33
RWB-2
Q 5 Does this conclude your statement of qualifications? 1
A 5 Yes, it does. 2
BB-1
PACIFIC GAS AND ELECTRIC COMPANY 1
STATEMENT OF QUALIFICATIONS OF BEN BROWN 2
Q 1 Please state your name and business address. 3
A 1 My name is Ben Brown, and am currently working remotely as Pacific Gas 4
and Electric Company (PG&E) transitions from its prior location at 77 Beale 5
Street, San Francisco, California to 300 Lakeside Drive, Oakland, California. 6
Q 2 Briefly describe your responsibilities at PG&E. 7
A 2 I am a Principal Strategic Analyst on the Energy Efficiency Portfolio Strategy 8
and Optimization team. I am the portfolio strategy development lead for 9
PG&E’s Energy Efficiency portfolio. My functional responsibilities include 10
developing and supporting energy efficiency portfolio strategic plans in 11
alignment with regulatory requirements and internal priorities as well as 12
contributing to California Public Utilities Commission filings within the energy 13
efficiency proceeding as well as other proceedings involving energy 14
efficiency coordination. 15
Q 3 Please summarize your educational and professional background. 16
A 3 I have held various program management and business analyst positions of 17
increasing responsibility within PG&E’s Energy Efficiency Portfolio since 18
2016. Prior to 2016, I held an employment tax analyst position at PG&E. I 19
hold Bachelor of Arts degrees in Political Science and Rhetoric from the 20
University of California, Berkeley. 21
Q 4 What is the purpose of your testimony? 22
A 4 I am sponsoring the following testimony in support of PG&E’s Energy 23
Efficiency 2024 Business-Portfolio Plan Application: 24
• Exhibit 2, “PG&E Energy Efficiency 2024-2027 Portfolio Plan”: 25
− Chapter 3, “Segmentation Strategy”; 26
− Chapter 3, Attachment A, “Program Level and Segment Level 27
Metrics and Targets.” 28
Q 5 Does this conclude your statement of qualifications? 29
A 5 Yes, it does. 30
MDB-1
PACIFIC GAS AND ELECTRIC COMPANY 1
STATEMENT OF QUALIFICATIONS OF MICHAEL D. BURGER 2
Q 1 Please state your name and business address. 3
A 1 My name is Michael D. Burger, and am currently working remotely as Pacific 4
Gas and Electric Company (PG&E) transitions from its prior location at 5
77 Beale Street, San Francisco, California to 300 Lakeside Drive, Oakland, 6
California. 7
Q 2 Briefly describe your responsibilities at PG&E. 8
A 2 I am the senior manager over the Energy Efficiency Portfolio Strategy and 9
Program Oversight group within the Customer Energy Solutions 10
Department. I am responsible for strategy, optimization, delivery and 11
oversight of PG&E’s Energy Efficiency programs across residential and non-12
residential sectors, including Codes and Standards and Local Government 13
Partnerships. 14
Q 3 Please summarize your educational and professional background. 15
A 3 I received a Bachelor of Arts degree in business administration from Niagara 16
University in 2004. Before joining PG&E in 2006, I worked for 17
PricewaterhouseCoopers in the Assurance and Business Advisory group. 18
Since joining PG&E in 2006, I have held a variety of positions with 19
increasing responsibility. I was a business finance analyst supporting Power 20
Generation; senior business finance analyst supporting Risk and Regulatory 21
Relations; supervisor/acting manager-business finance supporting 22
Integrated Demand Side Management; manager of the Portfolio Data and 23
Analysis group within Integrated Demand Side Management; manager of 24
the Financial Reporting and Governance team within Customer Energy 25
Solutions. 26
Q 4 What is the purpose of your testimony? 27
A 4 I am sponsoring the following testimony in in support of PG&E’s Energy 28
Efficiency 2024 Strategic Business and Portfolio Plan Application: 29
• Exhibit 1, “PG&E Energy Efficiency 2024-2031 Strategic Business Plan”: 30
− Chapter 2, “Annual Portfolio Budgets for 2024-2031.” 31
MDB-2
• Exhibit 2, “PG&E Energy Efficiency 2024-2027 Portfolio Plan”: 1
− Chapter 4, “Sector Strategy”; 2
− Chapter 4, Attachments A through J; and 3
− Chapter 5, “Portfolio Management.” 4
• Exhibit 3, “PG&E’s Responses, Pursuant to Energy Division Template”: 5
− Chapter 1, “PG&E’s Energy Efficiency 2024-2031 Application 6
Tables, Pursuant to Energy Division Template”; and 7
− Chapter 2, “PG&E’s Energy Efficiency 2024-2027 Supplemental 8
Budget Narrative Information, Pursuant to Energy Division 9
Template.” 10
Q 5 Does this conclude your statement of qualifications? 11
A 5 Yes, it does. 12
CMF-1
PACIFIC GAS AND ELECTRIC COMPANY 1
STATEMENT OF QUALIFICATIONS OF CAROLINE MASSAD 2
FRANCIS 3
Q 1 Please state your name and business address. 4
A 1 My name is Caroline Massad Francis, and am currently working remotely as 5
Pacific Gas and Electric Company (PG&E) transitions from its prior location 6
at 77 Beale Street, San Francisco, California to 300 Lakeside Drive, 7
Oakland, California. 8
Q 2 Briefly describe your responsibilities at PG&E. 9
A 2 I am manager of the Energy Efficiency (EE) Policy Shaping, Analysis and 10
Compliance Team within the Customer Energy Solutions Department. 11
I oversee analysts who focus on policy and compliance matters, data 12
reporting, and Evaluation, Measurement and Verification (EM&V) for 13
PG&E’s EE programs. 14
Q 3 Please summarize your educational and professional background. 15
A 3 I received a Bachelor of Arts degree in sociology from Yale University in 16
2005 and a Master of Public Policy degree from the University of Michigan in 17
2012. Prior to joining PG&E, my experience included working as a research 18
analyst at Mathematica Policy Research, a public policy and economic 19
consulting firm, from 2012 to 2016. Since joining PG&E in 2016, I have held 20
a variety of positions with increasing responsibility. I was a Senior Analyst 21
with the EE EM&V team; acting supervisor of the Customer Programs 22
Measurement and Evaluation team, which provides evaluation support to 23
customer programs outside of EE; and supervisor over the EE reporting and 24
ex ante policy staff on my current team. I have held my current position 25
since January 2021 (acting between January and October 2021 and 26
permanently since October 2021). 27
Q 4 What is the purpose of your testimony? 28
A 4 I am sponsoring the following testimony in support of PG&E’s Energy 29
Efficiency 2024 Business-Portfolio Plan Application: 30
• Exhibit 1, “PG&E Energy Efficiency 2024-2031 Strategic Business Plan”: 31
− Chapter 3, “Recommendations For New or Modified Energy 32
Efficiency Policies”; and 33
CMF-2
− Chapter 3, Attachment A, “Summary List of Policy Changes.” 1
• Exhibit 2, “PG&E Energy Efficiency 2024-2027 Portfolio Plan”: 2
− Chapter 6, “Evaluation, Measurement and Verification.” 3
Q 5 Does this conclude your statement of qualifications? 4
A 5 Yes, it does. 5
RM-1
PACIFIC GAS AND ELECTRIC COMPANY 1
STATEMENT OF QUALIFICATIONS OF REBECCA MADSEN 2
Q 1 Please state your name and business address. 3
A 1 My name is Rebecca Madsen, and am currently working remotely as Pacific 4
Gas and Electric Company (PG&E) transitions from its prior location at 5
77 Beale Street, San Francisco, California to 300 Lakeside Drive, Oakland, 6
California. 7
Q 2 Briefly describe your responsibilities at PG&E. 8
A 2 I am an Expert Regulatory Analysis and Forecasting Analyst in PG&E’s 9
Energy Accounting Department, within the Controller's organization. In this 10
position, I am responsible for ensuring the recovery of the costs included in 11
cases from customers. I advise on emerging regulatory issues, act as a 12
cost recovery witness for cases, and implement cost recovery requirements 13
in California Public Utilities Commission (CPUC) decisions. I am also 14
responsible for process improvements and documentation of existing 15
processes. 16
Q 3 Please summarize your educational and professional background. 17
A 3 I earned a Bachelor of Arts degree in Archaeology from the George 18
Washington University and an Associate in Science degree in Accounting 19
from Skyline College. I have been a registered Certified Public Accountant 20
in California (License 118069) since 2013. 21
I have been with PG&E since 2015. During that time, I have worked 22
within the Energy Accounting Department of the Controller’s organization, 23
where I was responsible for performing month end close activities, including 24
recording journal entries, reconciling accounts, and performing variance 25
analysis, related mainly to Public Purpose Programs. I was also responsible 26
for reading and interpreting decisions and resolutions issued by the CPUC, 27
understanding the accounting impacts, and recording the related journal 28
entries and preparing the supporting documentation. 29
My current assignment is described in A 2. 30
RM-2
Q 4 What is the purpose of your testimony? 1
A 4 I am sponsoring the following testimony in support of PG&E’s Energy 2
Efficiency 2024 Business-Portfolio Plan Application: 3
• Exhibit 2, “PG&E Energy Efficiency 2024-2027 Portfolio Plan”: 4
− Chapter 7, “Cost and Cost Recovery.” 5
Q 5 Does this conclude your statement of qualifications? 6
A 5 Yes, it does. 7
DP-1
PACIFIC GAS AND ELECTRIC COMPANY 1
STATEMENT OF QUALIFICATIONS OF DAVID POSTER 2
Q 1 Please state your name and business address. 3
A 1 My name is David Poster, and am currently working remotely as Pacific Gas 4
and Electric Company (PG&E) transitions from its prior location at 77 Beale 5
Street, San Francisco, California to 300 Lakeside Drive, Oakland, California. 6
Q 2 Briefly describe your responsibilities at PG&E. 7
A 2 I am the Director of the Energy Efficiency (EE) organization at PG&E 8
overseeing the company’s portfolio of EE solutions aimed at helping 9
customers eliminate unnecessary energy use and supporting California in 10
achieving a cleaner and more reliable energy future. 11
Q 3 Please summarize your educational and professional background. 12
A 3 Prior to my current role, I held several other important roles within PG&E 13
including Senior Manager of EE Operations, Manager of Residential 14
Programs and Manager of Policy and Strategy. I hold a Bachelor’s degree 15
in Economics from the University of Puget Sound. 16
Q 4 What is the purpose of your testimony? 17
A 4 I am sponsoring the following testimony in support of PG&E’s Energy 18
Efficiency 2024 Business-Portfolio Plan Application: 19
• Exhibit 1, “PG&E Energy Efficiency 2024-2031 Strategic Business Plan”: 20
− Chapter 1, “PG&E’s Vision for Energy Efficiency in California: 21
2024-2031.” 22
• Exhibit 2, “PG&E Energy Efficiency 2024-2027 Portfolio Plan”: 23
− Chapter 1, “Portfolio Summary.” 24
Q 5 Does this conclude your statement of qualifications? 25
A 5 Yes, it does. 26
