BEFORE THE PUBLIC UTILITIES COMMISSION OF THE … · LAW-#1493051 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA ... 73 (10) Private College Campus Housing Energy

LAW-#1493051

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE

STATE OF CALIFORNIA

Application of Southern California Edison Company (U 338-E) for Approval of its 2009-2011 Energy Efficiency Program Plans And Associated Public Goods Charge (PGC) And Procurement Funding Requests

)))))

Application ________ (Filed July 21, 2008)

APPLICATION OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) FOR APPROVAL OF ITS 2009-2011 ENERGY EFFICIENCY PROGRAM PLANS AND

PUBLIC GOODS CHARGE AND PROCUREMENT FUNDING REQUESTS

LARRY R. COPE JENNIFER SHIGEKAWA

Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY

2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626) 302-2570 Facsimile: (626) 302-7740 E-mail: [email protected]

Dated: July 21, 2008

APPLICATION OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) FOR APPROVAL OF ITS 2009-2011 ENERGY EFFICIENCY PROGRAM PLANS AND PUBLIC

GOODS CHARGE AND PROCUREMENT FUNDING REQUESTS

Section Title Page

-i-

I. INTRODUCTION AND EXECUTIVE SUMMARY.....................................................................2

A. SCE Proposed Portfolio .......................................................................................................2

B. Summary Tables And Pie Charts Of Portfolios And Energy Efficiency Measure Groupings..............................................................................................................6

1. Energy Savings And Demand Reduction ................................................................6

2. End Use Savings ......................................................................................................6

3. Budget ......................................................................................................................7

C. Elements Of The 2009-2011 Portfolio Are Designed To Reflect The Strategic Plan .......................................................................................................................8

D. Estimated Budgets And Savings For New Approaches.......................................................9

E. Charts Summarizing Projected Energy Savings From Each Of The Four Major Sectors For The Program Cycle; And, Charts Of Expected Savings Against Estimated Baseload Consumption, Averaged Over Three Years.........................10

II. PROPOSED ENERGY EFFICIENCY POLICIES AND RULES CHANGES FOR 2009-2011 .............................................................................................................................10

A. Introduction........................................................................................................................10

B. Joint IOUs Requested Policies...........................................................................................13

1. Per-Unit Benefit And Cost Assumptions Should Be Adopted For 2009-2011 Portfolio Planning (Ex-Ante) And Also Used For Portfolio Evaluation ...............................................................................................13

a) The Use of Ex Ante Estimates Matches the Commission’s Focus On Long-Term Savings And Innovative Portfolio Designs.......................................................................................................13

b) Fully-Vetted Ex Ante Estimates Should Provide Realistic Estimates of Savings and Benefits.............................................................14

c) Using the Same Benchmark Allows for Certainty.....................................15

d) Savings Assumptions Should Include Limited IOU-Proposed Revisions To The 2008 Database for Energy Efficiency Resources (DEER) Update Issued by The



TABLE OF CONTENTS (CONTINUED)

Table Page

-ii-

Energy Division on May 30, 2008 and Should be Adopted by The Commission For Portfolio Planning And Portfolio Evaluation ..................................................................................................16

e) Evaluation Studies of Energy Savings (ex post) Should Inform Future Planning Efforts And Not be Used to Reassess Prior Program Performance ........................................................17

f) The Process for Inclusion of New Measures Should be Altered........................................................................................................17

2. Cumulative Savings Should Be Defined As The Sum Of The Annual Savings Goals For The Three-Year Portfolio Period................................18

3. IOUs Should Receive Energy Efficiency Savings Credit For Energy Efficiency Actions Taken By Customers Who May Be Motivated By State Policies or Legislation, Local Codes And Ordinances, or Multiple Sources of “Green” Messaging.......................................19

4. Activity Costs In Direct Support Of The California Energy Efficiency Strategic Plan Should Be Exempt From The Shareholder Risk Reward Incentive Mechanism...................................................20

5. Gross Metrics Should Be Used For The Calculation Of Performance Toward The Minimum Performance Standard (MPS) And Performance Earnings Basis (PEB) Under The RRIM..................................22

a) The Use Of A Performance Earnings Basis Based Upon Gross Accomplishments Aligns With The Long-Term, Collaborative Focus Of The State For Energy Efficiency .........................23

b) Adoption Of Gross Metrics For PEB May Warrant Changes To The RRIM, Including The Shared Savings Rates ................................24

6. Adopt A Collaborative Process And Commission Review That Allow For Appropriate Evaluation And Vetting Of EM&V Study Design, Implementation And Results ....................................................................25

a) The Current Process...................................................................................25

b) Past Processes That Addressed These Issues.............................................26

c) Recommendations......................................................................................26




Table Page

-iii-

C. Other Policy Issue Modifications To Allow For Successful Implementation Of The 2009-2011 Portfolio ....................................................................27

1. Use Post-Tax Discount Rate For Benefits .............................................................27

2. Mid-Cycle Funding Augmentation Rules Should Be Revised ..............................27

D. Savings From Codes And Standards Should Count Towards The Commission’s Goals ..........................................................................................................28

E. The Role Of The Peer Review Group Should Be Clarified To Ensure Fairness ..............................................................................................................................29

F. Treatment Of CEESP Costs And Energy Savings.............................................................29

III. SCE’S PORTFOLIO REFLECTS STATE ENERGY POLICIES AND THE STRATEGIC PLAN ......................................................................................................................31

A. State Energy Policy And Initiatives...................................................................................31

1. Energy Action Plan ................................................................................................31

2. AB 32 Goals And Efforts or Effects ......................................................................32

3. Governor’s Green Building Initiative ....................................................................32

B. Statewide Energy Efficiency Strategic Plan ......................................................................33

1. Portfolios Reflect Regional And Local Variations Complementing The Strategic Plan ..................................................................................................33

2. Portfolios Contain Appropriate Strategies And Program Designs For The Three Statewide Initiatives.......................................................................34

a) Residential New Construction ...................................................................34

b) Commercial New Construction..................................................................35

c) Heating, Ventilation and Air Conditioning (HVAC) Industry ......................................................................................................37

C. Strategic Plan Vision For All Sectors ................................................................................37

1. Existing Residential ...............................................................................................37




Table Page

-iv-

2. Existing Commercial .............................................................................................38

3. Industrial ................................................................................................................40

4. Agricultural ............................................................................................................42

5. Emerging Technologies .........................................................................................43

6. Codes And Standards.............................................................................................44

7. Local Government .................................................................................................44

8. DSM Integration ....................................................................................................45

9. Marketing, Education And Outreach .....................................................................45

10. Workforce Education and Training .......................................................................46

11. Low Income Energy Efficiency .............................................................................47

D. Strategic Plan Outlook For Ten Years And Beyond..........................................................48

1. Program Line Item And Budget For Strategic Planning........................................48

2. New 2009-2011 Pilot Project Programs, Based On The Strategic Plan ........................................................................................................................50

3. Long-Term Savings Methodologies ......................................................................50

IV. SCE’S PROPOSED ENERGY EFFICIENCY PORTFOLIO.......................................................51

A. The Proposed Portfolio Meets Or Exceeds The Energy Efficiency Goals ........................51

1. Portfolios Meet Or Exceed 2011 Cumulative Savings Goals................................51

2. Portfolios And Funding Levels Appropriately Balance Short-Term And Long-Term Savings........................................................................................52

3. Portfolios Reasonably Allocate Funding Among Market Sectors.........................53

4. Portfolios Cost-Effectiveness Takes into Account Uncertainty ............................54

5. Portfolios Are Designed To Overcome Barriers And to Advance Integration ..............................................................................................................58




Table Page

-v-

B. Proposed Portfolio Design Achieves Savings Objectives .................................................60

1. Strategies To Reduce Critical Peak Loads And Improve System Load Factors...........................................................................................................60

2. Strategies To Minimize Lost Opportunities...........................................................60

3. Successful And Cost-Effective Programs Have Been Continued..........................61

4. Program Design Reflects Cumulative Savings ......................................................62

5. How The Potential Inclusion Of Energy Savings From “Spillover” Activities Has Been Reflected In Program Design................................................62

6. How Utilities Propose That Potential Energy Savings From Market Transformation Programs Should Be Measured....................................................63

7. Emerging Technologies That Are Anticipated To Increase Savings Potential .................................................................................................................63

8. Portfolios Contribute To The Green Building Initiative........................................64

C. Proposed Portfolio Design Reflects Market Strategies, Integration, And Delivery Channels To Enhance Customer Participation In Demand-Side Resources ...........................................................................................................................64

1. Summary Of Proposed Programs...........................................................................64

a) Residential Programs .................................................................................65

(1) Appliance Recycling......................................................................65

(2) Home Energy Efficiency Rebates..................................................65

(3) Business And Consumer Electronics Program ..............................66

(4) Plug Load Program ........................................................................66

(5) Residential Lighting Incentive Program For Basic CFL’s .............................................................................................66

(6) Advanced Consumer Lighting Program ........................................67

(7) Multi-Family Energy Efficiency Program.....................................67




Table Page

-vi-

(8) Comprehensive Mobile Home Program ........................................67

(9) Comprehensive Home Performance Program ...............................68

(10) Home Energy Efficiency Survey ...................................................68

(11) Efficient Affordable Housing ........................................................68

(12) Online Buyer’s Guide ....................................................................68

(13) California New Homes Program....................................................69

(14) Manufactured Housing New Construction ....................................69

b) Non-Residential Programs .........................................................................69

(1) MSP – Industrial Sector .................................................................70

(2) MSP – Agricultural Sector.............................................................70

(3) MSP – Commercial And Small Business ......................................71

(1) Residential/Light Commercial HVAC Program............................71

(2) Commercial New Construction Quality Assurance (CNCQA).......................................................................................71

(3) Business Incentives Element..........................................................72

(4) Industrial Energy Efficiency Program ...........................................72

(5) Agricultural Energy Efficiency Program.......................................72

(6) Financial Solutions Element ..........................................................73

(7) Business Services Element ............................................................73

(8) Commercial Energy Efficiency Program.......................................73

(9) Entertainment Centers Energy Efficiency .....................................73

(10) Private College Campus Housing Energy Efficiency Program..........................................................................................74




Table Page

-vii-

(11) Management Affiliates Program....................................................74

(12) K-12 Private Schools and Colleges Audit and Retrofit Program ............................................................................74

(13) Healthcare Energy Efficiency Program .........................................74

(14) California Preschool Energy Efficiency Program..........................75

(15) Integrated DSM Food Processing Pilot..........................................75

(16) Automated Energy Review For Schools........................................75

(17) Savings By Design.........................................................................76

(18) Sustainable Portfolios ....................................................................76

(19) Monitoring-Based Commission .....................................................76

(20) Leased Office Space Retrofit Program ..........................................76

(21) Data Center Energy Efficiency Program .......................................77

(22) Monitoring-Based Persistence Commissioning Program..........................................................................................77

(23) Data Center Optimization Program ...............................................77

c) Partnerships................................................................................................77

(1) Local Governmental Partnerships..................................................78

(2) Institutional Partnerships ...............................................................79

d) Crosscutting Programs ...............................................................................80

(1) Emerging Technologies Program ..................................................80

(2) Codes & Standards Program..........................................................80

(3) Sustainable Communities Program................................................80

(4) Workforce Education & Training (WE&T)...................................81




Table Page

-viii-

(5) Marketing, Education & Outreach.................................................81

e) Solicitations................................................................................................82

(1) Third Party Solicitations ................................................................82

2. Third Party Contracts.............................................................................................82

a) Process, Criteria, and Statewide Consistency ............................................82

b) Third-Party Programs Continued From 2006-2008...................................84

c) Efforts to Expand Third-Party Programs And Results of Competitive Bid Selection Process............................................................85

d) Review with Peer Review Group (PRG) ...................................................86

e) Implementer Contracts...............................................................................86

3. Partnerships............................................................................................................86

a) Proposed Partnership And Statewide Consistency ....................................86

b) Statewide Consistency ...............................................................................87

c) Government and Institutional Opportunities .............................................87

d) Criteria And Process ..................................................................................88

e) Peer Review Group Review.......................................................................89

f) PRG Recommendations and Responses ....................................................90

g) Policy Manual ............................................................................................90

h) Palm Desert Partnership.............................................................................90

4. Market Transformation Strategies .........................................................................91

5. Proposals for On-Bill Financing ............................................................................91

a) Small Business and Institutional Customers..............................................91

b) Proposal for On-Bill Financing for Residential Customers.......................92




Table Page

-ix-

6. Proposed Program Delivery And Market Outreach...............................................92

a) Marketing and Outreach Programs ............................................................92

b) Discussion of Context and Funding Integration ........................................94

(1) Demand Response and Advanced Metering Infrastructure..................................................................................94

(2) California Solar Initiative, Including Commission And CEC Programs........................................................................94

(3) Low-Income Energy Efficiency.....................................................95

(4) Distributed Generation...................................................................95

7. Proposed Training Programs..................................................................................95

V. PROPOSED FUNDING REQUESTS AND FUND-SHIFTING PROPOSALS ARE REASONABLE ....................................................................................................................97

A. Funding Request Is Reasonable .........................................................................................97

1. Proposed Funding Levels Are Reasonable And Should Be Adopted....................97

2. Certain Costs Not Included In Cost-Effectiveness Calculations Per The Strategic Plan And Commission Decision......................................................97

B. Proposed Interim Bridge Funding May Be Necessary To Avoid Program Interruption ........................................................................................................................98

C. Proposed Fund-Shifting And Program Flexibility Proposals Are Reasonable .........................................................................................................................99

1. Modify Treatment of Mid-cycle Funding Augmentation ....................................100

2. Recognize The Elimination Of The Policy Advisory Group For 2009-2011 ............................................................................................................101

3. Provide Additional Clarity to Prior Year’s Fund Shifting Guidelines To Reduce Confusion ........................................................................101

4. Funding Proposal For Rolling Budget Cycle As Set Forth In D.07-10-032 ..................................................................................................................102




Table Page

-x-

5. Proposal For Encumbering Funds From Subsequent Budget Cycles ..................102

VI. PROPOSED EVALUATION, MEASUREMENT & VERFICATION PLANS AND BUDGETS .........................................................................................................................103

A. Funding Principles And Overall Funding Request ..........................................................103

B. Proposed SCE Studies And Activities .............................................................................104

1. Program Specific Analyses ..................................................................................104

a) Process Evaluations and Evaluability Assessments.................................104

b) Program-Linked Market Analysis Studies...............................................105

c) Early Measurement And Verification/Baseline Activities ......................105

2. SCE Cross-Cutting EM&V Activities .................................................................106

a) Energy Efficiency Forecasting, Forecasting Model, and Annual Savings Model.............................................................................106

b) Market Segment Studies ..........................................................................106

c) Basic Data Collection and Analysis: Demographic, Business, and Weather Data ....................................................................106

d) Portfolio Analysis ....................................................................................107

e) Program Best Practices Updates ..............................................................107

f) Multi-Client Studies.................................................................................107

g) Conference/Organization Support ...........................................................108

h) CALMAC Support and Website..............................................................108

i) Statewide Saturation Surveys ..................................................................108

3. SCE’s EM&V Staffing ........................................................................................109

VII. REVENUE REQUIREMENTS AND COST RECOVERY........................................................110

A. Overview..........................................................................................................................110




Table Page

-xi-

B. PGC Energy Efficiency Ratemaking ...............................................................................112

C. Procurement Energy Efficiency Ratemaking...................................................................113

D. On-Bill Financing (OBF) Balancing Account .................................................................114

E. Rate Recovery Of Energy Efficiency Program Costs......................................................115

F. Rate And Bill Impact Analysis ........................................................................................116

G. Revenue Requirements and Cost Recovery.....................................................................116

VIII. ORGANIZATION OF SCE'S TESTIMONY..............................................................................116

IX. STATUTORY AND PROCEDURAL REQUIREMENTS.........................................................117

A. Statutory and Procedural Authority .................................................................................117

B. Rule 2.1 ............................................................................................................................118

1. Proposed Categorization ......................................................................................118

2. Need for Hearings and Proposed Schedule for Resolution of Issues...................118

3. Issues To Be Considered......................................................................................119

4. Legal Name and Correspondence ........................................................................119

C. Articles of Incorporation – Rule 2.2 ................................................................................120

D. Authority to Increase Rates – Rule 3.2 ............................................................................120

1. Balance Sheet and Income Statement – Rule 3.2(a)(1) .......................................121

2. Present and Proposed Rates – Rule 3.2(a)(2) and (a)(3)......................................121

3. Description of SCE’s Service Territory and Utility System – Rule 3.2(a)(4)_ .............................................................................................................121

4. Summary of Earnings – Rule 3.2(a)(5)................................................................121

5. Depreciation – Rule 3.2(a)(7) ..............................................................................121

6. Capital Stock and Proxy Statement – Rule 3.2(a)(8)...........................................121




Table Page

-xii-

7. Statement Pursuant to Rule 3.2(a)(10).................................................................122

8. Service of Notice – Rule 3.2(b), (c) and (d) ........................................................122

E. Service List ......................................................................................................................122

F. Index of Exhibits And Appendices To This Application – Rule 23(g) ...........................122

X. CONCLUSION............................................................................................................................123

APPENDIX A SCE’S BALANCE SHEET AND INCOME STATEMENT .............................................1

APPENDIX B SCE’S 2008 SUMMARY OF EARNINGS ........................................................................4

APPENDIX C LIST OF COUNTIES AND MUNICIPALITIES SERVED...............................................2

APPENDIX D SCE 2009-2011 ENERGY EFFICIENCY PROGRAM PLAN ABBREVIATIONS & ACRONYMS............................................................................................21



LIST OF TABLES

Table Page

-xiii-

Table I-1 Energy and Demand Response Savings...................................................................................... 6

Table I-2 Energy Savings and Demand Reduction by End Use ................................................................. 7

Table I-3 Annual Budgets........................................................................................................................... 8

Table I-4 Estimated Budgets And Savings For New Approaches.............................................................. 9

Table I-5 Energy Savings And Demand Reduction By Market Sector s.................................................. 10

Table II-6 Proposed SCE Costs To Exclude From 2009-2011 Earnings Mechanism.............................. 30

Table IV-7 Comparison of SCE’s Portfolio and Energy Efficiency Potential by Sector 2009-2011....... 54

Table IV-8 Comparison of SCE’s Portfolio and Energy Potential by End Use 2009-2011..................... 54

Table IV-9 Total Resource Cost (TRC).................................................................................................... 55

Table IV-10 Program Administrator Cost (PAC)..................................................................................... 56

Table IV-11 Total Resource Cost (TRC) With Higher Carbon Adder..................................................... 57

Table IV-12 Program Administrator Cost (PAC) With Higher Carbon Adder ........................................ 57

Table IV-13 Scenarios Based on Key Parameters Influencing Cost-effectiveness .................................. 58

Table IV-14 Abstract Evaluation Criteria................................................................................................. 89

Table IV-15 Summary of Marketing Budget............................................................................................ 93

Table VII-16 Requested Energy Efficiency Authorized Program Costs Increase ($000) ...................... 111

Table VII-17 Procurement Energy Efficiency Authorized Program Funding (Illustrative (000)) ......... 114

1

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE

STATE OF CALIFORNIA

Application of Southern California Edison Company (U 338-E) for Approval of its 2009-2011 Energy Efficiency Program Plans And Associated Public Goods Charge (PGC) And Procurement Funding Requests

)))))

Application ________ (Filed June 23, 2008)

APPLICATION OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) FOR APPROVAL OF ITS 2009-2011 ENERGY EFFICIENCY PROGRAM PLANS AND

PUBLIC GOODS CHARGE AND PROCUREMENT FUNDING REQUESTS

Pursuant to Rules 1 and 2 of the California Public Utilities Commission’s (Commission

or CPUC) Rules of Practice and Procedure, prior Commission decisions regarding energy

efficiency programs and funding, the Commission’s Decision 07-10-032 dated October 18, 2007,

and the subsequent rulings of the Assigned Commissioner and Administrative Law Judge issued

on February 29, 2008, May 15, 2008 and June 2, 2008; Southern California Edison Company

(SCE) respectfully requests that the Commission approve its 2009-2011 Energy Efficiency

Program Plans and Request for Public Goods Charge (PGC) and Procurement Funding

(Application).1 This filing consists of this Application, testimony in support of the Application

(Exhibit SCE-1), supporting tables and charts (Exhibit SCE-2), detailed program plan

1 This Application is filed pursuant to and in compliance with all Commission Decisions related to energy efficiency, including Decision 04-09-060, “Interim Opinion: Energy Savings Goals for Program Year 2006 and Beyond”; Decision 05-01-055, “Interim Opinion on the Administrative Structure for Energy Efficiency: Threshold Issues,” Decision 05-04-051, “Interim Opinion: Updated Policy Rules for Post-2005 Energy Efficiency and Threshold Issues related to Evaluation, Measurement, and Verification of Energy Efficiency Programs”; and Decision 07-10-032, “Interim Opinion on Issues Relating to Future Savings Goals and Program Planning for 2009-2011 Energy Efficiency and Beyond.”

2

descriptions (Exhibit SCE-3 and SCE-4), SCE’s DSM Integration and Coordination (Exhibit

SCE-5), SCE’s PIP-Strategic Plan matrix (Exhibit SCE-6), 2009-2011 Energy Efficiency AB 32

impact (Exhibit SCE-7) and workpapers supporting SCE’s Proposed Scenario (Exhibit SCE-8).

I.

INTRODUCTION AND EXECUTIVE SUMMARY

A. SCE Proposed Portfolio

In this Application and supporting testimony, SCE requests approval of its 2009-2011

energy efficiency program plans, SCE’s proposed energy efficiency policies and rules changes,

and SCE’s funding requests. SCE requests authority to fund these programs through: (1) its

existing Energy Efficiency-related Public Goods Charge (PGC); (2) its existing Procurement

Energy Efficiency-related Public Purpose Programs Charge (PPPC); and (3) an increase in its

Procurement Energy Efficiency-related PPPC.

However, within the framework of the new CEESP, and its call for long term market

transformative actions, several selective changes to current policies would enable SCE to more

effectively rise to the challenge of meeting the Commission’s aggressive and visionary goals.

These proposed policy and rule changes are listed in Exhibit SCE-1, Chapter II, Proposed Policy

and Rule Changes.

SCE believes that approval of this Application will promote the Commission’s and the

strategic plan’s goals of resource procurement and market transformation from the provision of

energy efficiency products and services, and of bold, long-term strategies for efficiency. SCE’s

proposed portfolio, with selective proposed policy changes, represents an investment of $1.344

billion that will generate an unprecedented 6.022 billion kilowatt hours of cumulative gross

annualized energy savings and 1,225 megawatts of gross peak demand reduction, and produce

more than $4.708 billion in gross resource benefits to ratepayers. A full detailed showing of this

scenario is shown in Exhibit SCE-2.

3

SCE also ran a scenario compliant with the 2009-2011 Commission directives. Under

this plan, the portfolio represents an investment of $1.344 billion that will generate 5.666 billion

kilowatt hours of cumulative gross annualized energy savings and 1,215 megawatts of gross peak

demand reduction, and produce over $2.942 billion in gross resource benefits to ratepayers. A

full presentation of this scenario is shown in Exhibit SCE.2.2

In Decision 07-10-032, the Commission concluded the goals adopted for SCE in

Decision 04-09-060 are reasonable and appropriate to use in the 2009-2011 program planning

cycle.3 The Decision suggests that the proposed energy efficiency program propose plans and

funding levels to meet the adopted goals. That Decision provided that the goals must be

aggressive and must stretch the capabilities and efforts of those involved. In order to facilitate

that the Decision authorized a three-year program implementation and funding cycle.4

Decision 07-10-032 affirmed Decision 05-01-055, which ordered the investor-owned

utilities5 (IOUs) to assume responsibility for program choice and portfolio management

functions for post-2005 energy efficiency programs. Decision 07-10-032 required, among other

items, that the IOUs file their applications no later than May 15, 2008, for Commission approval

of the proposed statewide strategic plan, energy efficiency program plans, and funding levels

through both the public goods charge and procurement rates, for the three-year program

implementation and funding cycle beginning January 1, 2009.6

A subsequent Assigned Commissioner’s Ruling Regarding Due Dates for 2009-2011

Energy Efficiency Portfolio Plans and Energy Efficiency Strategic Plan Application dated

May 5, 2008, extending the deadline for the portfolio plans to June 23, 2008 and the deadline for

2 Gross goals were used in compliance wit the Proposed Decision adopting interim energy efficiency savings goals for 2012-2020 dated July 1, 2008, p. 2.

3 D.07-10-032, p. 114-115, and 151. 4 D.07-10-032, p. 11, also see D.04-09-060, p. 22. 5 SCE, Pacific Gas and Electric Company, San Diego Gas and Electric, and Southern California Gas Company. 6 D.07-10-032 Ordering Paragraph 4, 10 and 12, pp. 145 – 147.

4

the Strategic Plan to June 2, 2008.7 The strategic plan (A.08-06-004) was filed by the IOUs on

June 2, 2008; the deadline for the portfolio plans was subsequently extended to July 21, 2008, by

Assigned Commissioner’s And Administrative Law Judge’s Ruling Resetting Date For 2008-

2011 Energy Efficiency Program Applications, dated June 2, 2008.8

Decision 05-04-051 clarified the goals, policies, and administrative framework and

Decision 07-10-032, directed that utility energy efficiency performance should be evaluated on

the basis of overall portfolio achievement rather than individual programs.9 Consistent with that

decision, SCE’s Application presents a portfolio which exceeds the established goals.

Decision 07-10-032 requires the utilities to file a final strategic plan as part of their

application. “The Strategic Plan shall include proposals for industrial energy efficiency

programs . . .In addition, the final proposed strategic plan should include a list of all major

comments received on the draft plan and the utilities’ response as to the disposition of each.”10

The IOUs prepared the Strategic Plan over a three-month period and involved the participation of

many individuals and organizations in over 35 workshops and hundreds of participants. The

objective of the Strategic Plan is to define newer approaches to aggressively provide energy

efficiency to California consumers and to significantly contribute to the state’s goal of having

reasonably priced, stable, reliable and clean energy resources through 2020 and beyond.

SCE’s 2009-2011 Energy Efficiency Application is intended to fully realize all cost

effective energy efficiency as a reliable and robust resource, consistent with the State of

California’s vision of energy efficiency and all activities as communicated in the state’s Energy

Action Plan (EAP).11 SCE’s proposed portfolio offers a unified program approach where all

7 ACR dated May 5, 2008. 8 ACR dated June 2, 2008. 9 D.05-04-051, p. 7 also D.07-10-032, p. 12. 10 D.07-10-032, Ordering Paragraph 5, p. 145. 11 The Energy Action Plan identifies specific goals and actions to ensure that adequate, reliable and reasonably-

priced electrical power and natural gas supplies are achieved and provided through cost-effective and environmentally sound strategies. A copy of the Energy Action Plan is posted on the Commission’s website at http://www.cpuc.ca.gov/static/energy/electric/energy+action+plan/index.htm. See also, Decision 05-06-043,

Continued on the next page

5

programs work together seamlessly to encourage customers to take the appropriate actions

towards energy efficiency. SCE will rely on a combination of short- and long-term solutions to

energy efficiency that are consistent with SCE’s commitment to making energy efficiency part of

its long-term resource solution.

SCE’s energy efficiency portfolio is focused on strategies that immediately reap cost-

effective energy efficiency savings and demand reductions while looking beyond the 2009-2011

planning cycle to ensure energy efficiency as a reliable and robust resource and the first resource

to meet new demand. SCE will maximize the benefits of diversity within the portfolio, among

approaches, measures, markets, delivery channels and implementers. SCE’s portfolio will create

a framework for sustainable energy efficiency and other demand reducing programs and a

process for achieving extensive energy savings through short-term programs and long-term

planning. SCE will maximize the potential of its programs by engaging in collaborative efforts

with others in planning and delivering energy efficiency savings. SCE will continue to develop

and sustain partnerships to continue to build toward a durable distributed infrastructure of local

energy efficiency networks. SCE views partnerships as an effective means to encourage

customers on a local level to embrace energy efficiency. Finally, SCE will look to emerging

technologies and promising program designs to build the future for energy efficiency.

One important aspect of the regulatory and business environment guiding the design and

development of the 2009-2011 energy efficiency portfolio is the need to be strategic,

comprehensive and “big and bold.” This Application makes important and essential steps in that

direction.

Continued from the previous page

mimeo, p. 15; Energy Efficiency Policy Manual Version 3 (Policy Rules), Rule II.2 (Attachment 3 to D.05-04-051).

6

B. Summary Tables And Pie Charts Of Portfolios And Energy Efficiency Measure

Groupings

1. Energy Savings And Demand Reduction

SCE’s 2009-2011 portfolio represents 6.022 billion kilowatt hours of cumulative

annualized energy savings and 1,225 megawatts of peak demand reduction. See Table I-1 below

for energy savings and demand reduction by year. Exhibit SCE-2, Table 1.1 includes a detailed

projection.

Table I-1 Energy and Demand Response Savings

Note: Includes forecast of Low Income Energy Efficiency and Codes and Standards impacts for the 2009-2011 program cycle.

Energy Savings (GWh) by Year

70 16 3

1658

19922112

171

0

500

1000

1500

2000

2500

2009 2010 2011 2012 2013 2014 2015

Demand Reduction (MW) by Year

35

428409

332

1416

0

50

100

150

200

250

300

350

400

450

2009 2010 2011 2012 2013 2014 2015

2. End Use Savings

SCE’s 2009-2011 portfolio savings is comprised of HVAC, lighting, refrigeration

and other miscellaneous end uses. The break out of energy savings and demand reduction

among end uses is shown below in Table I-2.

7

Table I-2 Energy Savings and Demand Reduction by End Use

Residential Energy Savings (GWh) by End Use

Appliances

Consumer Electronics

Cooking Appliances

HVAC

Lighting

Pool Pump

Refrigeration

Water Heating

Other

Residential Demand Reduction (MW) by End Use

Appliances

Consumer Electronics

Cooking Appliances

HVAC

Lighting

Pool Pump

Refrigeration

Water Heating

Other

Nonresidential Energy Savings (GWh) by End Use

HVAC

Lighting

Office

Process

Refrigeration

Other

Nonresidential Demand Reduction (MW) by End Use

HVAC

Lighting

Office

Process

Refrigeration

Other

3. Budget

SCE’s 2009-2011 portfolio represents $1.344 billion. Table I-3 below represents

SCE’s proposed annual budget. Exhibit SCE-2, Table 4.1 contains SCE’s proposed yearly and

total budget by program.

8

Table I-3 Annual Budgets

2009 Budget 2010 Budget 2011 Budget Total 2009-2011 Program Cycle Budget

Total SCE Program Budget 366,666,000$ 428,377,000$ 460,257,520$ 1,255,300,520$ Total SCE/CPUC EM&V Budget 22,118,000$ 33,177,000$ 33,083,480$ 88,378,480$ Total SCE Portfolio Budget 388,784,000$ 461,554,000$ 493,341,000$ 1,343,679,000$

C. Elements Of The 2009-2011 Portfolio Are Designed To Reflect The Strategic Plan

In Decision 07-10-032, the Commission approved a ground-breaking new requirement

for the State’s IOUs to prepare a joint strategic plan for energy efficiency through 2020 and

beyond, as “a directed, statewide strategic planning effort [that] will deliver more savings from

existing measures, create new savings opportunities for the future, and afford efficiencies in the

development and delivery of new programs.12 The Decision required the filing of a final plan by

May 15, 2008, simultaneous with the filing of the proposed 2009-2011 energy efficiency

portfolio plans. On March 8, 2008, SCE and the other IOUs submitted a (supplemented) draft

California Energy Efficiency Strategic Plan (CEESP) and submitted the final CEESP June 2,

2008 per the May 5, 2008 Assigned Commissioner’s Ruling. CEESP influenced programs

permeate this Application. Additionally, there are numerous initiatives throughout this

application that are designed to better integrate the energy efficiency activities and goals with

those of the other demand-side resources. During the 2009-2011 program period (and beyond)

the goal of more robustly integrating and coordinating energy efficiency with other demand-side

resources – and improving the portfolio’s contributions to greenhouse, peak load management

and low-income goals – will be infused into the efforts of key SCE activities including:

12 D.07-10-032 dated October 18, 2007, p. 20.

9

D. Estimated Budgets And Savings For New Approaches

The proposed budgets and savings for the program activities listed above in Section Care

included in Table I-4 below.

Table I-4 Estimated Budgets And Savings For New Approaches

SCE Program Total 2009-2011 Program Cycle Budget Total kWh Total kW

Residential/Light Commercial HVAC 75,575,000$ 125,810,327 89,092 California New Homes Program 31,562,000$ 18,325,987 17,396 Manufactured Housing New Construction Program 3,477,000$ 2,827,100 1,807 Commercial New Construction Quality Assurance 4,992,000$ - - Automatic Energy Review for Schools Program 1,992,000$ 2,900,732 650 Savings by Design 46,776,000$ 210,761,425 43,912 Local Government Partnership Program – An Energy Leader Model for the Future 6,363,000$ 16,270,899 3,259 Community Energy Partnership 3,848,000$ 10,000,000 1,986 Beaumont Energy Leader Partnership 567,000$ 1,250,000 251 Desert Cities Energy Leader Partnership 1,470,000$ 3,750,000 728 Eastern Sierra Energy Leader Partnership Program 949,000$ 2,250,000 487 Kern County Energy Watch Partnership 2,618,000$ 6,743,750 1,354 Long Beach Energy Leader Partnership 1,841,000$ 4,619,795 907 Orange County Cities Energy Leader Partnership 2,198,000$ 5,625,000 1,104 Ridgecrest Energy Leader Partnership 781,000$ 1,856,250 376 Santa Ana Energy Leader Partnership 1,842,000$ 4,750,000 943 Simi Valley Energy Leader Partnership 390,000$ 625,000 126 Ventura County Energy Leader Partnership 4,766,000$ 12,500,000 2,454 South County Energy Leader Partnership 2,930,000$ 7,500,000 1,472 South Bay Energy Leader Partnership 2,935,000$ 7,500,000 1,490 South Gate Energy Leader Partnership 793,000$ 1,875,000 372 San Gabriel Valley Energy Leader Partnership 1,979,000$ 5,000,000 1,011 San Joaquin Valley Partnership 2,205,000$ 5,625,000 1,129 Palm Desert Partnership 20,597,000$ 61,185,110 16,118 California Community Colleges Energy Efficiency Partnership 11,915,000$ 38,926,292 5,774 California Department of Corrections and Rehabilitation/IOU Partnership Energy Efficiency 3,207,000$ 7,188,089 1,066 SCE/SCG/County of Los Angeles Partnership-Energy Efficiency 2,708,000$ 7,188,096 1,140 Riverside/SCE/SCG Partnership Program 3,688,000$ 8,042,578 1,425 UC/CSU/IOU Partnership 13,872,000$ 45,516,901 6,705 San Bernardino County Partnership 2,163,000$ 5,466,335 874 State of California/IOU Partnership 3,630,000$ 7,982,776 1,184 Institutional and Government Resource for Energy Efficiency Now (IGREEN) Program for New Partnership 4,249,000$ 9,384,376 1,392 Sustainable Communities Program 14,965,000$ - - Codes and Standards Program 8,463,000$ 372,565,322 91,517 Emerging Technologies Program 18,313,000$ - - Financial Solutions 30,381,000$ Business and Consumer Electronics Program 11,925,000$ 44,211,905 14,994 Statewide Marketing, Education and Outreach 20,213,514$ - - Statewide Marketing, Education & Outreach Strategic Plan 2,941,000$ - - Workforce Education and Training – EARTH Education & Training Program 9,012,000$ 4,508,372 755 Workforce Education and Training Synergies 35,877,000$ - - Workforce Education and Training Strategic Planning 3,462,000$ Strategic Planning Team 7,780,000$ Industrial Energy Efficiency Program 60,811,000$ - - Agriculture Energy Efficiency Program 17,198,000$ - - Total 510,219,514$ 1,070,532,417 315,252

10

E. Charts Summarizing Projected Energy Savings From Each Of The Four Major

Sectors For The Program Cycle; And, Charts Of Expected Savings Against

Estimated Baseload Consumption, Averaged Over Three Years

Table I-5 below shows projected energy savings and demand reduction from each of the

four major sectors (Residential, Commercial, Agricultural, and Industrial). Exhibit SCE-2, Table

1.3 includes a detailed break down by sector of SCE’s proposed budget, energy saving, and

demand reduction. Exhibit SCE-2, Table 1.4 also includes a break down of energy efficiency

measures.

Table I-5 Energy Savings And Demand Reduction By Market Sector s

Note: Does not include forecast of Low Income Energy Efficiency and Codes and Standards impacts for the 2009-2011 program cycle.

Energy Savings (GWh) by Market Sector

Residential

Commercial

Industrial

Agricultural

Demand Reduction (MW) by Market Sector

Residential

Commercial

Industrial

Agricultural

II.

PROPOSED ENERGY EFFICIENCY POLICIES AND RULES CHANGES

FOR 2009-2011

A. Introduction

The four California investor-owned utilities (Pacific Gas and Electric Company, Southern

California Edison Company, San Diego Gas and Electric Company, and Southern California Gas

Company, jointly known as the Joint IOUs) propose necessary and key policy modifications

enabling the success of energy efficiency in the 2009-2011 period and beyond. Adoption of

these policies is essential to both Assembly Bill 32 (AB 32) goal achievement and the big, bold

11

visions laid out by the Commission in D.07-10-032. The Joint IOUs’ proposal focuses on

maximizing the gross energy savings necessary to meet California’s aggressive vision for energy

efficiency. The Joint IOUs request that these policy recommendations be adopted concurrent

with the adoption of each IOU’s recommended portfolio.

The Joint IOUs recommend these policy changes in order to achieve a more workable

system of assumptions that allows the IOUs to focus on execution of energy efficiency portfolios

that support all of the State’s energy efficiency goals articulated in the California Energy

Efficiency Strategic Plan (CEESP), including the Big, Bold Energy Efficiency Strategies; AB 32

- The California Global Warming Solutions Act of 2006; and the state’s Energy Action Plan

(EAP).

The Joint IOUs request these policy changes in order to allow for and encourage real

collaboration, cooperation, and innovation among all the parties that the Commission asks to join

together to make energy efficiency a way of life in California. The Joint IOUs are concerned

that if these policy changes are not made, the Joint IOUs will not be able to implement energy

efficiency portfolios that achieve the energy savings and demand reduction goals and adequately

support the CEESP, AB 32 Greenhouse Gas (GHG) reduction, and EAP goals.

Specifically, the Joint IOUs request the following policy changes:

1. Benefit and measure cost assumptions that are adopted for 2009-2011 Portfolio

planning (ex-ante) should also be used for Portfolio evaluation.

• Benefit and measure cost assumptions should include limited IOU-proposed

revisions to the 2008 Database for Energy Efficiency Resources (DEER) update

issued by the Energy Division on May 30, 2008.

• Evaluation studies of energy savings (ex post) should inform future planning

efforts and not be used to reassess prior program year performance.

• The process for adding measures to a portfolio should be modified to match the

use of ex ante estimates.

12

2. Cumulative savings should be defined as the sum of the annual savings goals for the

three-year portfolio period upon which the proposed budget is based.

3. IOUs should receive energy efficiency savings credit for energy efficiency actions

taken by customers who may be motivated by state policies or legislation, local codes

and ordinances, or multiple sources of “green” messaging.

4. Activities in direct support of the Strategic Plan that do not produce measurable, cost-

effective savings in 2009-2011 should be exempt from the risk/reward incentive

mechanism (RRIM) and included in a new performance earnings mechanism.

5. Gross metrics should be used for the calculation of performance toward the minimum

performance standard (MPS) and performance earnings basis (PEB) under the RRIM.

• Adoption of gross goals for PEB may warrant changes to the RRIM, potentially

including the shared-savings rates, in order to maintain an appropriate balance of

risk and reward between shareholders and customers.

6. A collaborative process should be adopted to allow for appropriate review and vetting

of EM&V study design, implementation, and results. This process should allow for

full Commission review.

The IOUs proposed energy efficiency portfolios for 2009-2011 are developed contingent

upon the Commission adoption of the above-described policy changes. The energy savings and

cost effectiveness of the recommended portfolios are summarized in the IOUs’ individual

testimony and tables. The individual IOU testimony also includes results for a base scenario that

employs the May 30, 2008, DEER updates and current other Commission policy positions. The

IOUs are not able to develop and implement reasonable portfolios that meet all the Commission

adopted energy savings goals if the IOU recommended policies are not adopted. Accordingly, to

ensure that IOUs are able to implement portfolios that maximize energy efficiency and

greenhouse gas reductions and support the Commission’s long-term vision for efficiency as

presented in the CEESP, the Joint IOUs urge the Commission to adopt the proposed policy

changes.

13

B. Joint IOUs Requested Policies

1. Per-Unit Benefit And Cost Assumptions Should Be Adopted For 2009-2011

Portfolio Planning (Ex-Ante) And Also Used For Portfolio Evaluation

The Application supports the Commission’s goals for both short-term and long-

term resource benefits to the State, focusing on a mix of both existing and emerging technologies

and programs. The benefits and measure costs supporting this Application are based upon the

best available information with regard to the benefits and costs of the underlying measures

promoted. The Commission should use the per-unit benefit metrics (kWh, KW, EUL) and

measure costs adopted in this proceeding as the basis of measuring performance throughout this

proceeding.

The goals for the period 2004-2013 set forth in D.04-09-060 were created using a

set of facts regarding benefits and measure costs available at that time. Variations in the

underlying inputs call into question whether the energy savings potential, upon which the goals

are based, continues to exist. Accordingly, the Joint IOUs are being requested by the

Commission to produce energy savings that are higher than the achievable potential in 2009-

2011, even using gross metrics, based on recent estimates of benefits and measure costs. It is

essential that measurement of the portfolio be done on an ex ante basis to allow the IOUs to

implement their portfolios as filed and to maximize the short-term and long-term energy savings

and benefits for California.

a) The Use of Ex Ante Estimates Matches the Commission’s Focus On

Long-Term Savings And Innovative Portfolio Designs

The 2009-2011 Application is for a portfolio which provides long-term

resource benefits through the promotion of both current and future energy efficiency

technologies. The use of ex ante estimates in both the planning and evaluation of portfolio

results will allow the administrators to focus on delivering the portfolios adopted in this

14

proceeding. However, the risk of ex post measurement will hamper the ability to achieve the

Commission-established targets in the short- and long-term. The continued use of ex post

estimates will unnecessarily expose the portfolios to second-guessing and after-the-fact

adjustments, which will ultimately stifle creativity and innovation, and promote use of only the

old tried-and-true measures and programs. Ex post uncertainty provides the inherent message

that in order to reduce the risk of changes in savings assumptions, it is necessary to only offer

measures whose savings are known. Obviously, the use of ex ante savings estimates will

encourage and promote innovation in the portfolios.

b) Fully-Vetted Ex Ante Estimates Should Provide Realistic Estimates of

Savings and Benefits

The Commission extended the deadline for the submittal of these

Applications to include the incorporation of new portfolio cost and benefit estimates. In the

adoption of the final portfolios for 2009-2011 the Commission should utilize the time spent

during the submittal and review of these Applications to fully receive comments on the cost and

benefit estimates and use these reviewed numbers in the evaluation of 2009-2011 portfolio

performance. In the development of policy rules for the 2006-2008 portfolios the Commission

collected information with regard to the accuracy of ex ante estimates in California.

The use of ex ante estimates throughout the program cycle is an extension

of the previous policy adopted by the Commission in the current Energy Efficiency Policy Rules

(Policy Rules). That is, to allow for exemptions from ex post measurement for measures that

have: (1) ex ante per unit savings assumptions that are already estimated with a high degree of

certainty and updated on a regular basis; and (2) low external variability.13 In the adoption of the

current Policy Rules the Commission allowed for the use of ex ante estimates and determined

that under such circumstances where the ex ante assumptions were updated on a schedule, it

13 D.05-04-051, OP# 8, p.93.

15

would not be necessary to tie compensation to ex post load impact evaluations. The Commission

should utilize the ex ante estimates of per-measure savings and measure costs in lieu of ex post

savings.

c) Using the Same Benchmark Allows for Certainty

The use of ex post studies to inform future planning efforts, and not to

reassess prior program year performance, will reduce potential controversy over measurement

results. As a matter of policy, it is undesirable to adopt a benchmark for performance which

relies upon factors which are not under the control of the participants. It would be unfair to the

administrators to continue to alter the benefit and cost metrics which were utilized to establish

the goals and portfolios and to change these metrics after program implementation. The

administrators should be able to implement the portfolios in good faith using established

standards to achieve the energy savings targets. They should only have their results adjusted for

matters under their control (i.e., number of measures installed and program costs.)

Resource acquisition energy efficiency programs provide long-lasting and

verifiable energy and capacity savings. As discussed further below, the continued use of

California’s rigorous, reasonable protocols for measuring program energy and demand savings

will ensure the quality and validity of the studies performed and the accuracy of the resulting

energy savings and demand reduction benefits continue to be updated each cycle. These energy

savings and demand reduction estimates and algorithms should be approved prior to the

beginning of each program year and would be utilized along with the verified installations and

costs in the computation of performance. This approach provides the best means of ensuring the

reliability of energy savings estimates.

The performance earnings basis should focus program administrators on

the desired performance that is directly under their control — assuring correct installations of

equipment in areas and facilities where they are expected to provide the forecasted savings.

16

d) Savings Assumptions Should Include Limited IOU-Proposed

Revisions To The 2008 Database for Energy Efficiency Resources

(DEER) Update Issued by The Energy Division on May 30, 2008 and

Should be Adopted by The Commission For Portfolio Planning And

Portfolio Evaluation

SCE’s recommended portfolio includes modifications to the proposed

values from the Database for Energy Efficient Resources (DEER) database, as supported by the

workpapers in Exhibit SCE-8, and as further discussed in detail in Chapter II. C. 1. of the

Testimony (Exhibit SCE-1). The recommended portfolio is based upon updated cost-

effectiveness metrics that the utilities believe are more appropriate for portfolio planning

purposes than those currently included in DEER.

The updated DEER numbers from the Energy Division significantly alter

the amount of feasible energy efficiency savings available from utility programs, but not the

recommended 2012-2020 energy efficiency savings goals. It is critically important that the

portfolio metrics for use in both goal-setting and program evaluation be adopted by the

Commission based upon realistic and attainable data and assumptions.

Unrealistic and/or changing program assumptions also creates uncertainty

and inconsistency in program implementation which negatively impacts the ability and

willingness of manufacturers, distributors, retailers, contractors, local government partnerships,

and consumers to participate in the programs. This policy-generated uncertainty is certainly not

consistent with state objectives to maximize our use of cost effective energy efficiency as a

resource.

The energy efficiency values recommended by the IOUs in support of this

portfolio are realistic and based upon rigorous analysis and do not so dramatically impact the

program results that other market participants are inclined to reduce or abandon their

participation. Such values should be the basis for the approval of this Application and in the

evaluation of program performance.

17

e) Evaluation Studies of Energy Savings (ex post) Should Inform Future

Planning Efforts And Not be Used to Reassess Prior Program

Performance

Currently, the protocols adopted for measurement of portfolio impacts

include an estimation of the amount of free ridership from a particular program design, in

addition to other after-the-fact estimates. While such measurement provides useful information

as to the effects of a particular program design, there are issues with the use of such information

as an exact point-estimate of the amount of free ridership from a program. Studies performed

years after a program may not provide information relevant to current program design.

Information on free riders should be compiled, but used for improving program design, and not

determining whether a savings metric is met.

f) The Process for Inclusion of New Measures Should be Altered

The Joint IOUs understand that moving to the proposed ex ante

framework, where achievements are measured using the same energy savings assumptions

approved by the Commission in portfolio planning, will necessitate a change to the current

process for adding new measures. In D.05-09-043, the Commission outlines a process for

adding new measures that requires informal review from the PRG (and the former Program

Advisory Group). In light of the proposed framework, the Joint IOUs request that the process for

new measures be altered to allow for proper, more formal review by the Energy Division and the

PRG of benefit and measure costs prior to inclusion of that measure in the IOU’s portfolio.

The Joint IOUs believe their proposed process provides the PRG and the

Energy Division ample opportunity to review proposed benefit and measure cost values while

facilitating the inclusion of new measures through a timely process.

18

2. Cumulative Savings Should Be Defined As The Sum Of The Annual Savings

Goals For The Three-Year Portfolio Period

The Joint IOUs recommend reconsideration of the current treatment of cumulative

savings in determining whether the 2009-2011 applications meet the requirement to propose

portfolios that show savings targets that are equal to the total annual electricity savings goals

established for 2009-2011 and at the same time ensure the total savings available in a given year

are equal to the cumulative savings goals for that year beginning in 2004.

The uncertainties and incompleteness of evaluation results creates moving targets

as to what is the actual level of cumulative achievement every time new information is released

by the Energy Division. Portfolios cannot and should not be planned based on moving targets

that change from year to year as one can never be sure that budgets and program designs are

appropriately set. Therefore, the Joint Utilities propose that the Commission defer consideration

of cumulative savings until the savings goals for 2012 and beyond are set. Since the PY 2006-

2008 evaluations will not be completed until 2010, it would be most appropriate to evaluate the

actual cumulative achievement at that time and make Decisions on future portfolios at that time.

This is consistent with the July 1, 2008 proposed decision “Adopting Interim Energy Efficiency

Savings Goals for 2012 Through 2020, and Defining Energy Efficiency Savings foals for 2009

Through 2011” (at page 31) which states,

“We agree with DRA that the schedule for updating the 2012-2020 goals should incorporate information from the 2006-2008 Impact Evaluation studies and resulting DEER updates.”

19

3. IOUs Should Receive Energy Efficiency Savings Credit For Energy

Efficiency Actions Taken By Customers Who May Be Motivated By State

Policies or Legislation, Local Codes And Ordinances, or Multiple Sources of

“Green” Messaging

In D.07-10-032, the CPUC made visionary statements about the future direction

of energy efficiency. The CPUC acknowledged that programs need to be leveraged and

integrated to ensure maximum energy savings for the State. D.07-10-032 states:

In the past, we have emphasized utility programs, utility funding and utility customers.14 This is logical given the limits of our legal jurisdiction, but this approach has resulted in fractured energy efficiency program development and delivery. Cost-effective use of resources for maximum reductions in energy demand will require the commitment of the most influential decision-makers who can affect comprehensive change. In order to reach a goal of making energy efficiency an integral part of “business as usual,” we need a pronounced commitment from business and government leaders and a more collaborative approach that involves all key stakeholders. We emphasize the need for enhanced cooperation and collaboration and commit to a leadership role in reaching out to key leaders to engage participation in this effort and direct the IOUs to do likewise.15 (emphasis added)

Unfortunately, the traditional regulatory framework, in which savings can only be

applied to the Commission’s goals if they are attributable to the IOU’s energy efficiency

14 At the same time, we have supported the important role of third parties – e.g., by requiring at least 20% of portfolio funding be competitively bid to third parties, by directing the utilities to assist in the development of the state’s energy efficiency codes and standards, by use of advisory groups, etc. (D.05-01-055). Our directives today build upon this past policy emphasis.

15 In addition to our commitments for this leadership role under the National Action Plan, and the Joint Action Framework on Climate Change, supra, our actions today provide for international collaborative efforts and exchange of information on energy efficiency, in accordance with the Agreement on Cooperation Between the California Public Utilities Commission, the California Energy Commission, and the Jiangsu Provincial Economic and Trade Commission, entered into on September 2, 2005, and the United Kingdom and California Announcement on Climate Change & Clean Energy Collaboration, dated July 31, 2006. We take official notice of these agreements; they can be found at http://www.cpuc.ca.gov/static/energy/electric/energy+efficiency/ee+general+info/california-jiangsumou_final.pdf http://www.cpuc.ca.gov/static/energy/electric/energy+efficiency/ee+general+info/west+coast+comm+joint+committments+on+climate+change+final.pdf.

20

program, does not motivate increased cooperation and collaboration. In fact, the current

framework does the opposite as the utilities “compete” with other agencies to have energy

savings attributable to their programs. To maximize energy savings in support of the State’s

aggressive GHG goals, the Commission should explicitly recognize energy efficiency savings

credit for energy efficiency actions taken by customers who may be motivated by state policies

or legislation, local codes and ordinances, or multiple sources of “green” messaging. Energy

savings and demand reduction estimates should be developed for these activities and the net-to-

gross ratio should be set to 1.0 in the cost-effectiveness calculations.

The Joint IOUs are requesting the same treatment the Commission provided for

the Governor’s Green Building Initiative in D.05-09-043 in which they found that utility support

for this State initiative would not be reduced by free ridership reductions. An extension of such

treatment for other State initiatives, including GHG reduction, allows for increased collaboration

in making energy efficiency a way of life in California.

4. Activity Costs In Direct Support Of The California Energy Efficiency

Strategic Plan Should Be Exempt From The Shareholder Risk Reward

Incentive Mechanism

In D.07-10-032, the Commission stated that “all parties will agree that California

(and likely other regions as well) will achieve far greater savings if the IOUs and Commission

actively engage in coordinated, long-term planning.” On June 2, 2008, the joint IOUs jointly

filed a proposed CEESP.16 Contained within the proposed CEESP are various goals for

California, both near and long-term. To realize the achievement of the CEESP goals, California

will need support from a vast number of market actors.

16 California Energy Efficiency Strategic Plan And Appendices And Joint Application Of Pacific Gas And Electric Company (U 39 M), Southern California Edison Company, San Diego Gas & Electric Company And Southern California Gas Company Submitting The California Energy Efficiency Strategic Plan, June 2, 2008, Docket No. R06 04 010

21

However, many of the CEESP-oriented items may not produce measurable,

and/or minimal or non-cost-effective energy savings in the near-term. The CEESP-oriented

items include market characterization reports, research, convening of stakeholders to discuss

visionary energy efficiency, support of CEC or local government activities, pilots, and workforce

development, among other things. While the Joint IOUs look forward to furthering the CEESP

for California consumers, it is of concern that the CEESP may not receive adequate financial

support in light of existing policy rules.

The Joint IOUs propose specialized treatment of the costs and a new performance

mechanism for these discrete CEESP activities. The Joint IOUs request that activities be exempt

from the risk/reward mechanism if:

a. The activity explicitly supports a Plan Strategy; and

b. The activity will produce minimal or no cost-effective, measurable savings in

2009-2011.

The Commission’s concurrence with this exemption will ensure there is a policy

framework that would support the long-term, innovative activities necessary to achieve the

vision in the CEESP.

To ensure that costs for the Strategic Plan do not remove the more wide-scale

energy efficiency benefit from utility customers, the Joint IOUs will include all the savings and

costs, including those from exempted programs, in its cost-effectiveness showing calculation of

this 2009-2011 portfolio. Each of the Joint IOUs will ensure that the portfolios, including

exempted programs, also remain cost effective to ensure that utility customers continue to

receive a positive benefit from energy efficiency programs. The cost effectiveness showing for

this portfolio, with and without exempted programs, is discussed in Chapter IV of Exhibit SCE-

1.

The Joint IOUs also propose a new performance earnings mechanism for discrete

activities undertaken in support of the CEESP. The Joint IOUs recommend a performance

earnings mechanism for Strategic Plan strategies to ensure adequate attention is paid not only to

22

the achievement of the Commission’s short-term energy savings goals but also to support various

discrete activities that directly support the vision of the CEESP. The Joint IOUs recommend a

metric-based performance adder approach for specific programs.

5. Gross Metrics Should Be Used For The Calculation Of Performance Toward

The Minimum Performance Standard (MPS) And Performance Earnings

Basis (PEB) Under The RRIM

The utilities support the use of goals and performance basis metrics which are

linked together and represent aggressive, yet achievable benchmarks for energy efficiency

efforts. In addition, the utilities support the development of goals which are based upon the best

available information on the potential for energy efficiency and which align with all of the

Commission policies – including the use of energy efficiency as a reliable energy resource, as an

important factor in the reduction of greenhouse gases from electricity generation, and in support

of the Commission’s long-term, “big, bold” strategies for energy efficiency. The use of gross

goals, as recommended in the July 1, 2008 Draft Decision in the Energy Efficiency

Rulemaking,17 appropriately aligns the potential for energy efficiency in California, the goals set

forth by the Commission as a target for the utilities to aim for in the development of portfolios in

this proceeding and in the implementation of these portfolios in 2009-2011, and the focus by the

utilities for increased collaboration among all stakeholders to meet these goals. The utilization

of goals at the “gross” level better reflects the “big, bold” policies being promoted by the State

and will promote increased collaboration among all parties towards achievement of these goals

and other policy goals being discussed in this Rulemaking. The use of gross goals properly

aligns the estimates of energy efficiency program results with the real impacts of reduced load

from these programs on the utility systems. The Commission should continue to align the

objectives of the programs – delivery of energy savings to customers – with the performance

17 Draft Decision Adopting Interim Energy Efficiency Savings Goals For 2012 Through 2020, And Defining Energy Efficiency Savings Goals for 2009 Through 2011, OP#4, p. 35.

23

incentive mechanism. Neither procurement planners nor greenhouse gas reduction calculations

need consider net-to-gross ratios. This should be extended to the performance metrics for energy

efficiency.

a) The Use Of A Performance Earnings Basis Based Upon Gross

Accomplishments Aligns With The Long-Term, Collaborative Focus

Of The State For Energy Efficiency

The utilities recommend that the 2009-2011 goals be designated as gross

goals, as currently recommended in the July 1 Draft Decision. That is, the 2009-2011 goals

would reflect the total savings, inclusive of program free riders. Utilizing gross goals and a gross

performance earnings basis calculation for the 2009-2011 period can open up the opportunity for

more program options which support the long-term goals for energy efficiency than the use of

net goals. The use of gross goals should allow for parties to focus less on the attribution of

savings and more on maximizing the energy savings potential of energy efficiency programs in

California.

The continued use of net goals and a net performance basis would not

embody the “big, bold” concepts being promoted throughout the remainder of the proceeding. In

order to focus on the overarching policies for energy efficiency, including “big, bold” ideas, it is

appropriate to remove this inherent penalty included in the use of net-to-gross ratios. The

utilities recommend the adoption of gross level goals and a gross performance basis calculation

for 2009-2011 which supports the development and delivery of expanded program options and

support the long-term policy goals for energy efficiency in California.

Ultimately, it is gross savings impacts delivered to customers that affect

future resource needs and GHG emissions levels. The use of gross savings and benefits as a

metric will align the utility program results with the system impacts and reduced GHG

emissions.

24

b) Adoption Of Gross Metrics For PEB May Warrant Changes To The

RRIM, Including The Shared Savings Rates

The shared savings rates adopted in D.07-09-043 were adopted to provide

utilities with financial incentives sufficient to overcome the disincentives to energy efficiency

when compared with supply-side, “steel-in-the-ground” investments. As noted in D.07-09-043:

“31. Utility investors are attracted by opportunities to earn returns, and absent energy efficiency incentives, utilities only earn on supply-side investments. Recognition of this fundamental disincentive to energy efficiency has been expressed in prior Commission energy efficiency decisions, the federal Energy Policy Act of 1992, California’s 2003 Energy Action Plan, the National Action Plan for Energy Efficiency and in the Commission’s 2006 Procurement Incentive Framework decision, D.06-02-063.”

The Decision adopting these 2009-2011 portfolio Applications should

include an appropriate shared savings rate to accommodate the recommended change in policy to

gross metrics, while still providing incentives which are sufficient to overcome the disincentives

of pursuing energy efficiency versus “steel-in-the-ground” investments. The use of gross

savings and benefits in the evaluation of performance and in the performance earnings basis

calculation will necessitate a re-examination of the shared savings rates previously adopted by

the Commission, which were based upon the 2006-2008 portfolios and Policy Rules. In order to

continue to meet the Commission’s policy objectives for a performance incentive mechanism,

including a level of earnings potential which provides a clear signal to utility investors that

achieving and exceeding the Commission’s savings goals (and maximizing ratepayer net benefits

in the process) will create meaningful and sustainable shareholder value; the Commission should

utilize this proceeding to align the use of gross metrics with an update to the shared savings rate

utilized by the IOUs. As part of such a review the Commission should also revisit the estimates

of applicable earnings amounts, given the increased resource benefits being provided through

each of the Joint IOUs’ portfolios submitted in these Applications. The Joint IOUs look forward

to working with the Commission in the determination of an appropriate shared savings rate

25

which matches the use of gross savings and which provides an amount of earnings which

considers the amount of customer benefits being provided through the recommended portfolios.

6. Adopt A Collaborative Process And Commission Review That Allow For

Appropriate Evaluation And Vetting Of EM&V Study Design,

Implementation And Results

a) The Current Process

The currently mandated process for design, implementation, and use of

results of EM&V studies has only minimal requirements and opportunities for utility review and

input and no forum for Commission review of disputes over the studies.

The mandated opportunities for utility and stakeholder review and

comment are at only two stages: broad (not detailed) study designs and the draft final reports.

Individual Energy Division staff members make the final decisions on the conduct of the studies

and use of study results.

However, there is no Commission requirement for additional review and

input opportunities. In addition, if utilities disagree with the final decisions made by an ED staff

member or with the processes used to gather and respond to input for a particular study, there is

no forum for addressing this disagreement.

In the earnings claim process, either for an interim or final claim, the

utilities receive a draft report from the Energy Division on the success of their programs and are

allowed only one chance to provide written comments to the Energy Division. A final report is

then completed and passed along to the utilities for their Advice Letter submittal of claims. The

Advice Letter is to include the decisions made in the Final Report by the Energy Division. The

current process has no provision for review by the Commission, even in cases where the

framework established in the Commission’s energy efficiency earnings decision may not be

implemented in accordance with the policies set forth by the Commission.

26

b) Past Processes That Addressed These Issues

From 1998-2005, statewide studies were managed by a single entity (then,

a utility), but had ongoing oversight and review by a study advisory group composed of utility

and regulatory staff representatives, sometimes also including California Energy Commission

and other organizations. Before that, the California DSM Measurement Advisory Committee

(CADMAC) performed a similar function, as an ongoing forum for discussion of study methods

among utilities, CPUC and CEC staff, and other stakeholders.

The process for 1994-1997 energy efficiency earnings claims required the

utilities to file Applications for shareholder earnings, followed by review and recommendation

reports from the independent consultants hired by the Commission’s Division of Ratepayer

Advocates, hearings, when necessary, and ultimately a decision from the Commission, in the

Annual Earnings Assessment Proceeding (AEAP). While hearings were rarely necessary during

the time period the AEAP process was in place, they were utilized to settle disputes of fact which

were unable to be resolved between the utilities and the Division of Ratepayer Advocates or the

Administrative Law Judge’s consultants.

c) Recommendations

First, SCE recommends a return to statewide advisory groups for

statewide studies, whether managed by the Energy Division or the utilities. This structure

provides for an ongoing, two-way flow of information for the studies that can prevent

misunderstandings about program information, identify and resolve emerging issues as study

methodologies are implemented, and reduce the possibilities for final study results to be based on

misunderstandings, errors or inferior methods.

Secondly, there needs to be an opportunity for Commission review. Only

through the availability of a review process can the Commission ensure that the policies set forth

in the energy efficiency earnings decision are being properly implemented and provide an

appropriate forum for resolution of any unresolved disputes over final reports.

27

C. Other Policy Issue Modifications To Allow For Successful Implementation Of The

2009-2011 Portfolio

1. Use Post-Tax Discount Rate For Benefits

The discount rate utilized by SCE in this Application is consistent with Policy

Rule IV.2 of Decision 05-04-051. That is, the discount rate reflects SCE’s Weighted Average

Cost of Capital (WACC), as adopted in Decision 07-12-049. SCE’s discount rate is "tax-

adjusted" and consistent with the treatment of discounting in the current (2006-2008) cycle,

utilized in the development of the risk-reward mechanism, and consistent with the methodology

being recommended by PG&E concurrently in this proceeding. That is, the discount rate is the

weighted average of the common equity cost and the preferred stock cost, plus the weighted

average of the long-term debt cost after a tax deduction for interest expense is applied. SCE

believes any final determination of the Commission on the appropriate WACC for energy

efficiency should be used in the energy efficiency proceeding only.

2. Mid-Cycle Funding Augmentation Rules Should Be Revised

SCE proposes to modify the 2006-2008 mid-cycle funding policy rule for 2009-

2011 to allow utilities to count all installed energy efficiency results towards the Commission’s

aggressive energy savings and demand reduction goals. As a result of this rule, IOUs are now

discouraged from pursuing all cost-effective energy efficiency even though there may be energy

efficiency funds available from prior years. The utilities propose the elimination of the 2006-

2008 mid-cycle funding augmentation rule for 2009-2011 as it: (1) creates a disincentive to

propose new programs with augmented funding; (2) punishes, unnecessarily, IOUs when market

conditions change which may require additional funds to incent customers in order to achieve the

Commission energy efficiency goals, and (3) creates a contradiction to the California’s Energy

Action Policy and Commission policy to pursue all cost-effective energy efficiency.

28

The mid-cycle rule also contradicts California’s Energy Action Plan which calls

for the pursuit of all cost-effective energy efficiency by discouraging IOUs to supplement their

program portfolios with promising new/enhanced programs. Thus, for 2009-2011, SCE proposes

to modify the mid-cycle funding policy rule to allow all utilities to count all installed energy

efficiency results towards the Commission’s aggressive energy savings and demand reduction

goals.

D. Savings From Codes And Standards Should Count Towards The Commission’s

Goals

Energy savings and demand reductions associated with Codes and Standards (C&S) work

influenced by IOU efforts over the years should count towards the achievement of the

Commission energy efficiency goals. Specifically, SCE proposes that the following C&S

program work count towards the achievement of the 2009-2011 energy efficiency goals: (a) 100

percent of savings from post-2006 Codes and Standards Advocacy Programs; and (b) 50 percent

of savings from pre-2006 Codes and Standards Advocacy Programs. In the event a C&S effort is

initiated during the 2009-2011 cycle and placed into code during the same cycle, 100 percent of

the 2009-2011 C&S savings would also count towards the achievement of the 2009-2011 goals.

Consistent with the proposal to use the same estimates in both the planning and

evaluation of portfolio results, SCE proposes adoption of the energy savings and demand

reduction estimates for C&S shown in this Application.

Finally, SCE proposes that any costs associated with the 2009-2011 C&S program be

excluded from the calculation of the program portfolio earnings mechanism (i.e., performance

earnings basis). Instead, SCE proposes the 2009-2011 C&S program be part of a CEESP

earnings mechanism as this work is an essential part to the overall success of many of the

strategies envisioned in the CEESP.

29

E. The Role Of The Peer Review Group Should Be Clarified To Ensure Fairness

The Joint IOUs recommend that the Peer Review Group (PRG) oversight responsibilities

be clarified with respect to government partnerships that it be limited to “local” government

partnerships. This would mean that the PRG would oversee the development of criteria and

selection of local government partnerships, as it does with the competitive program solicitations.

Consistent with the current 2006-2008 practices, the utilities should be allowed, without PRG

oversight, to develop “partnerships” with other entities who are not “local” governments but with

whom it is appropriate to treat the entity on “more equal footing, in terms of involvement in

program design and planning, information sharing and program implementation” as described in

Policy Rule VI.5.18

F. Treatment Of CEESP Costs And Energy Savings

As shown in Exhibit SCE-6, there are a number of areas in which the CEESP calls for

studies, market characterization, research, local government initiatives, and development of

training materials, among other things, that will not result in cost-effective energy savings in

2009-2011. SCE proposes that costs with a significant commitment to CEESP-related activities

not producing measurable and/or cost-effective savings in the 2009-2011 period be removed

from the shareholder earnings mechanism (i.e., performance earnings basis) in order to avoid a

perverse disincentive for the utilities engaging in such activities. However, SCE proposes to

include the costs within the portfolio cost-effectiveness calculation to ensure that the portfolio as

a whole delivers positive benefit to customers.

In addition, to encourage energy savings from CEESP activities, SCE proposes to count

any measurable energy savings of these CEESP program activities towards meeting its energy

savings and demand reduction goals and its minimum performance standard requirements.

18 Assigned Commissioner’s Ruling on Revision 4.0 of the Energy Efficiency Policy Manual, Energy Efficiency Policy Manual Version 3.1, January 8, 2008.

30

The table below showcases the programs and corresponding costs that SCE requests be

outside of the shareholder earnings mechanism (i.e., performance earnings basis) but allow

measurable energy savings to be counted towards the achievement of the energy efficiency goals

(i.e., minimum performance standard):

Table II-6 Proposed SCE Costs To Exclude From 2009-2011 Earnings Mechanism

Program/Activity Budget ($ in millions) Workforce Education & Training19 $12.474Statewide Marketing, Education, & Outreach $23.155Strategic Planning Team $7.780Emerging Technologies Program $18.313Sustainable Communities Program $14.965California New Homes Program $31.562Manufactured Housing New Construction Program $3.477Codes & Standards $8.463Financial Solutions $30.381

Strategic Plan-Oriented EM&V Studies20 TBD*

Total Budget $150.570 Total Portfolio Budget $1,344 % of Total Portfolio Budget 11.20%

19 Includes WE&T EARTH Education and Training and WE&T Strategic Planning. 20 Budgets will be identified as the EM&V plan is developed.

31

III.

SCE’S PORTFOLIO REFLECTS STATE ENERGY POLICIES AND THE STRATEGIC

PLAN

A. State Energy Policy And Initiatives

1. Energy Action Plan

The joint Energy Action Plan 2008 Update builds upon the previous Energy

Action Plans, as well as recent statutes and gubernatorial directives, while maintaining energy

efficiency and demand-side management as its foundation. The Energy Action Plan Update

notes importantly that:

“…it will not be enough to replicate current strategies for delivery of energy efficiency options to consumers. To meet the AB 32 goals, we will need to employ new and innovative approaches not yet tried. Toward this end, the Public Utilities Commission launched a strategic planning process to develop comprehensive, long-term strategies for sustainable energy efficiency savings to achieve the ultimate goal of making energy efficiency a way of life for Californians.”21

SCE’s Application is focused on meeting the objectives of the Energy Action

Plan. As noted elsewhere in this Application, SCE’s portfolio is intended to go well beyond

existing efficiency efforts and begin a new phase of more strategic, coordinated and effective

activities. These activities are designed to face the enormous energy and environmental

challenges California faces and will over time change the nature of the utility efficiency activities

as envisioned in the Energy Action Plan.

SCE’s portfolio of programs is designed to maximize cost-effective energy and

demand reductions through a combination of resource acquisition and market transformational

initiatives that address each consuming sector. SCE’s portfolio is designed to improve upon the

course of previous programs by increasingly influencing the actions of key non-utility actors,

21 2008 Energy Action Plan Update, pp. 7-8

32

such as local governments, the California Energy Commission (CEC), and manufacturers of

energy consuming applications.

2. AB 32 Goals And Efforts or Effects

Perhaps no change in the regulatory and business environment of SCE’s energy

efficiency portfolio since the application for the last portfolio is as profound as the passage of

AB 32. The Energy Action Plan Update puts it this way:

The most important development in California energy policy in the past two years, if not the past several decades, is the arrival at consensus that California must act to decrease its greenhouse gas emissions to reduce the impact of climate change.22

Due to the developing nature of the implementation of AB 32, and potential

federal actions, there is significant uncertainty regarding the future price of CO2, which is being

addressed in R.08-02-007.

As required by Decision 07-10-032, SCE’s Application is also accompanied by

Exhibit SCE-7, a report on “The status of AB 32’s implementation and proposed program

changes that would complement rules and policies, if adopted, including programs targeting

energy efficiency measures in the industrial sector.”23 While it is impossible to develop

precisely the appropriate program changes at this point, SCE is well aware of the nexus between

our programs and the actions that may be taken by emitters to meet their obligations under AB

32.

3. Governor’s Green Building Initiative

In December 2004, Governor Schwarzenegger signed Executive Order S-20-04,

which was accompanied by the Green Building Action Plan. Together, they became known as

the state’s Green Building Initiative (GBI).

22 2008 Energy Action Plan Update, p. 2. 23 Decision 07-10-032, dated October 18, 2007, p. 147. See also, SCE Exhibit-7.

33

SCE’s Application provides several programs and opportunities for State

agencies, departments and other entities under the direct executive authority of the Governor to

take measures to reduce grid-based energy purchases for state-owned buildings through the

installation of cost-effective efficiency measures.

In addition, SCE proposes to continue statewide Marketing, Education &

Outreach programs that create general awareness of energy efficiency opportunities across the

State. Further, SCE’s Application proposes targeted, program-specific marketing to assist

customers in participating in the specific programs that benefit them.

B. Statewide Energy Efficiency Strategic Plan

1. Portfolios Reflect Regional And Local Variations Complementing The

Strategic Plan

The proposed portfolio strongly reflects the CEESP which, among other goals,

integrates the energy efficiency activities of the four IOUs as well as non-IOU statewide actors.

Nonetheless, as the D.07-10-032 recognizes there are – and should be – remain regional and

local variations in program activities. Even within a single IOU’s service territory, there are

regional and local factors that may warrant specific program activities. These include climate,

building stock, building ownership and rental patterns, grid performance issues, local leadership

and interest, and commercial and industrial consumer types.

Examples of proposed activities that retain regional and/or local variations, even

while remaining a component of a statewide, integrated energy efficiency strategy, include:

• Sustainable Communities Program – the program coordinates with localized

non-energy offerings such as water agencies and Air quality Management

District (AQMD) incentives, if any.

• Local Government Partnerships – the partnerships vary based upon local

conditions including climate, building stock, community leadership, etc. The

new Energy Leader model is designed to create energy partnerships with local

34

governments that will vary based upon local effectiveness. Partnerships also

include a tiered incentive structure that offers higher levels of support as the

city and its community achieves higher levels of installed energy savings.

• SCE’s advanced meter (SmartConnect™) deployment – the deployment of

SCE’s advanced metering infrastructure will produce data to more specifically

target energy efficiency and DSM measures based on local factors.

2. Portfolios Contain Appropriate Strategies And Program Designs For The

Three Statewide Initiatives

The proposed 2009-2011 portfolio contains numerous appropriate strategies and

program designs intended to achieve the three statewide initiatives including residential ZNE,

commercial ZNE and transformed HVAC. These are described below:

a) Residential New Construction

The 2009-2011 program cycle begins the first three-year increment of the

12-year time period covered by the California Energy Efficiency Strategic Plan. To support the

aims of the CEESP, and begin to advance residential new construction toward the Big Bold

Energy Efficiency Strategies (BBEES), SCE plans a robust, multifaceted residential new

construction program reflecting the strategies embodied in CEESP.

The California New Homes Program (CANHP) encourages single and

multi-family builders of all production volumes to construct homes which exceed California’s

Title 24 standards by a minimum of ten percent thereby reducing energy usage through a

combination of incentives, technical education, design assistance and verification.

The pay-for-performance incentive structure for the 2009-2011 CANHP

will change from the previous three-tiered structure to a graduated incentive model closely

modeled on Savings By Design’s whole building approach. Starting from ten percent better than

Title 24 and ramping up through 35 percent, projects will be paid on ascending scale per

annualized kWh and therm. Project teams will also be rewarded for peak kW reductions.

35

Similarly, CANHP is working to integrate our Demand Side Management

offerings to builders. CANHP is exploring coordination of Demand Response to reward builders

for installing Programmable Communicating Thermostats and is proposing that air conditioning

cycling controllers be installed at construction of the new home. In addition to the direct energy

savings incentives, builders will also be eligible for additional independent incentives for such

items as, smaller houses and ENERGY STAR homes.

Utility programs have traditionally been limited to energy efficiency, but

the explosion of green into the residential sector, and the increasing awareness of green in the

marketplace in general have created an opportunity to pursue energy efficiency in the context of

green.

SCP recognizes that integration of DSM approaches and truly integrated

design are critical to achieving zero net new construction. This can only be done when the entire

suite of DSM offerings is available (electric transportation, demand response, energy efficiency,

SmartConnect™, and distributed generation), and those offerings will be maximally effective

when they are part of a truly integrated design.

b) Commercial New Construction

The 2009-2011 program cycle for new commercial construction will

reflect elements of the strategies contained in the CEESP.

SCE will continue to offer the statewide Savings By Design (SBD)

program, which works to reduce the electric energy needs of new and expanding commercial,

industrial, governmental and institutional facilities throughout SCE’s service territory. Savings

By Design will offer a full spectrum of support to building owners, architects, engineers, and

other specialized consultants, providing the tools and information necessary to achieve optimum

energy and resource efficiency in their projects.

By providing multi-level design, technical, and financial assistance to

influence the basic design of a customer’s project, Savings By Design’s focused intervention will

36

lessen lost opportunities that may result when a building’s energy performance is not a primary

consideration in the design of a project. The Savings By Design program will promote energy

efficiency to customers with new construction/remodel projects through three complementary

components – Whole Building Approach (Integrated Design/WBA), Systems Approach, and a

Simplified Approach for Small Projects to its customers with new construction or major

remodel/renovation projects:

The WBA is the preferred method of promoting energy savings because it

enables a design team to consider integrated, optimized energy efficiency solutions. The

Systems Approach (SA) is a performance-based method utilizing a quick energy savings

calculation tool to optimize efficiency choices. It is straightforward and participants may find it

the best available option for certain types of projects. The Simplified Approach for Small

Projects, a web based deliverable, will offer project advice on common energy efficiency

strategies applicable to customers’ project types.

For 2009-2011, Savings By Design will offer additional financial

incentives beyond direct kWh and kW incentives to Systems Approach and WBA projects that

achieve green building certification, perform building commissioning during design and

construction, and/or establish and follow a building measurement and verification plan after

occupancy. These sustainability incentives are to encourage buildings to be designed as well as

possible, be built as designed, and to be operated as they are built.

In addition to the Savings By Design program, SCE will continue to offer

the Sustainable Communities Program (SCP). SCP seeks to expand the traditional focus of

utility programs from energy efficiency to sustainable development, addressing commercial and

residential construction practices that affect occupant health and environmental well-being. This

includes energy use as well as non-traditional sources of energy savings, such as water

efficiency.

SCP recognizes that critical to achieving zero net new construction is the

integration of DSM approaches and fully integrated design. This can only be done when the

37

entire suite of DSM offerings is available (electric transportation, demand response, energy

efficiency, SmartConnect™, and distributed generation), and those offerings will be most

effective when they are part of a truly integrated design. SCE will use SBD and SCP to make

progress towards the milestones of the CEESP.

c) Heating, Ventilation and Air Conditioning (HVAC) Industry

Residential/Light Commercial HVAC Program

SCE’s 2009-2011 Residential/Light Commercial HVAC Program will

continue the transformation process of California’s HVAC market to ensure that “technology,

equipment, installation and maintenance are of the highest quality to promote energy efficiency

and peak load reduction in California’s climate” consistent with the CEESP. SCE proposes

building towards this vision by implementing a variety of downstream, midstream and upstream

strategies designed to affect a positive influence on the overall behavior of all stakeholders.

Residential strategies envision code compliant central air conditioners and promotion of ongoing

equipment maintenance. Upstream strategies will be used to increase shipments of innovative

HVAC equipment that offers better peak demand and energy efficient performance in

California’s hot dry climate. Increased emphasis will be placed on statewide marketing and

branding efforts and contractor training and education.

C. Strategic Plan Vision For All Sectors

1. Existing Residential

SCE’s portfolio of residential programs includes several programs that directly

support the CEESP:

• The Comprehensive Home Performance Program (CHPP) solicits, trains, and

assists residential repair and renovation contractors to build capable

contracting teams and to do whole-house diagnostics of energy-related

38

deficiencies, propose comprehensive improvement packages and undertake to

complete the renovations.

• The Business and Consumer Electronics Incentive Program provides

midstream incentives to increase the stocking and promotion of high

efficiency electronic products including computers, computer monitors, cable

and satellite set-top boxes, televisions and additional business and consumer

electronics as they become available to the market.

• On-Line Buyers Guide is a new service designed to provide residential

consumers with a single website that will contain all the information and tools

needed to overcome market barriers that prevent them from purchasing energy

efficiency equipment on their own and/or prevent them from participating in

utility programs. The guide consists of an interactive technology experience

that has a substantial data base that provides product recommendation,

shopping guide, available rebate and incentives and a list of retailers. The

Energy Efficiency On-Line Buyers Guide supports residential sector strategy

to achieve full “one-stop shop” integration of DSM delivery.

2. Existing Commercial

The commercial building sector is among SCE’s largest consumers of electricity.

As such, it is also the largest potential market for energy efficiency. This portfolio included

programs that target existing commercial buildings and proposes how to best address this high

potential during the 2009-2011 program cycle.

Recognizing the high savings potential for the commercial sector, SCE’s

Application includes new programmatic concepts and methods to align energy efficiency and the

existing commercial building programs with the goals of the CEESP. The objective is to

motivate the commercial building market to accelerate its implementation of energy efficiency so

39

that the programmatic concepts and methods are designed to meet energy efficiency and AB32

usage reduction goals.

This will be accomplished through strategies, which are meant to align with and

complement the CEESP.

• Utilization of the Energy Benchmarking Program to create market awareness

and demand for more efficient buildings. This program will not initially yield

savings, but it will go beyond the requirements of AB1103 and will integrate

benchmarking as a core service, and serve as a lead for other commercial

programs.

• More comprehensive treatment through Retro-commissioning (RCx)

Assessment and Repair Program. The program educates building contractors

and owners to run their facilities more efficiently through the building

operator certification program. Current market penetration of RCx is

relatively small. This program aims to increase this market penetration by

two to three percent.

• The Financing Solutions Program offers enhancement of On-Bill Financing,

development, and solicitation of innovative financing mechanisms. This will

augment the current incentive offerings and encourage increased program

participation by lowering and removing barriers for participation.

• Comprehensive Approach: the Commercial Energy Efficiency Programs and

related solicitations include a comprehensive approach, to existing

commercial space. This approach has traditionally only been available for

new construction. This approach emphasizes comprehensiveness, minimizes

lost opportunities and increases the building operators’ awareness of how

operations impact energy savings.

• Development of tools that will help support the quantification of savings for

program related purposes and for aiding the sales and marketing messaging

40

aimed at selling energy efficiency savings to potential customers. This will be

an augmentation and consolidation of existing tools with new enhancements

for measures not currently included. By making these tools more readily

available, it is expected that customers will be able to make better informed

decisions, which should entice them to implement more energy efficiency

measures.

There are numerous crosscutting items including comprehensive HVAC,

government initiatives, worker training and outreach, new construction and codes and standards

that are identified in specific sections of this plan that are key to this sector.

Implementation of this plan will require the identification of key technologies and

services in coordination with the Emerging Technologies Program and program planning groups

at SCE. New technologies are also supported by other programs designed to incubate, pilot and

ultimately mainstream successful technologies into core programs.

Coordination and Planning with statewide groups will occur through program

operations, and the planning group will ensure that the latest technologies and services are

coordinated among the other IOUs and stakeholders. Common marketing and outreach will be

coordinated to be cost-effective and deliver a similar message.

There will also be additional outreach and coordination for this sector that will be

aligned by major sub-segment elements that have specific needs and/or barriers. Sub-segments

will be addressed through a comprehensive team approach which may include, where practical,

the statewide programs will coordinate with the other relevant stakeholders to deliver

comprehensive statewide offerings that may be best rolled out on a statewide basis.

3. Industrial

SCE’s industrial sector strategy is an extension of the 2006-2008 Industrial

Program. Along with SCE’s Industrial Sector Strategy, it is designed to overcome well-defined

41

barriers (or limits) to the adoption of energy efficiency and has a clear vision and strategy. The

industrial sector strategy is aligned with the CEESP.

SCE’s vision for the industrial sector is focused on a partnership between

consumer and utility in which the utility supports the ongoing profitability of the consumer in

exchange for energy and demand savings. Risk management dominates industrial decisions,

including those related to energy management. SCE’s industrial strategy is to position energy

efficiency, in general, and the utility, in specific, as risk management resources.

The program targets energy efficiency opportunities in industrial processes and

systems (although cost-effective building measures will be bundled along with process

improvements to prevent lost opportunities), which are historically difficult to penetrate. The

program is structured to reflect the industrial consumer’s reluctance to alter elements of a

working production process for reasons other than product output or quality.

In addition to the barriers that limit adoption of energy efficiency measures across

all customer groups, there are additional barriers that affect the decisions of process industries’

management. This program is designed to mitigate those barriers through a systems approach to

identifying potential and by means of presenting those opportunities within a comprehensive

business context. Key barriers identified include:

• Costs associated with energy efficiency • Uncertainty over project savings • Time commitment required for energy efficiency projects • Uncertainty about continued industrial process operations

Therefore, energy efficiency programs for industrial customers need to

incorporate elements to reduce the uncertainty, cost, and time commitment associated with

energy efficiency decisions.

The Industrial program is coordinated with the other investor owned utilities to

ensure, at a minimum, consistent incentive levels and information. In addition, the utilities

cooperate to offer a joint audit and recommendation package to facilities that bridge service

42

territories. Consumers are thus provided with seamless access to efficiency throughout

California.

4. Agricultural

SCE’s Energy Efficiency Portfolio targeted approach to the Agricultural and

Water Systems Market Segment (AgMSP) includes food production enterprises, crop production

enterprises, and public and private water system enterprises.

The California Energy Efficiency Strategic Plan sets forth the following vision for

the Agricultural Sector:

“Energy efficiency will support the long-term success of California agriculture, including through increased profitability, support of AB32 compliance, and support of renewable energy goals.”24

The 2009-2011 Energy Efficiency Portfolio includes a plan for the AgMSP. This

plan supports the strategy of market characterization and goal-setting,25 by dedicating resources

for a detailed analysis and review of electricity usage, peak demand, and electricity use/intensity

within SCE’s service territory. The characterization effort will support more targeted and cost-

effective delivery of Energy Efficiency programs by better identifying customers with similar

business models and similar energy consumption patterns.

The AgMSP supports the CEESP Strategy of providing greater levels of financing

and incentives to this market segment. The portfolio includes a Financial Solutions Program,

which provides for SCE’s on-bill financing, third party asset-based financing, and third party

project financing for energy efficiency projects adopted by SCE business customers. SCE also

intends to modify incentive levels within the Agricultural Energy Efficiency Program (AgEE)

program to provide greater incentive for demand reduction and to encourage timely completion

of energy efficiency programs that have been committed to by the customer. This combination

24 California Energy Efficiency Strategic Plan, dated June 2, 2008, p. 5-1. 25 Id., p. 5-17.

43

of access to finance and higher incentives promotes higher levels of program adoption within the

sector.

The 2009-2011 AgMSP supports the CEESP’s goal of maximizing the energy

efficiency contributions of emerging technologies by providing seed capital for Energy

Efficiency Research and Development and Early Stage Energy Efficiency Technologies.

Emerging technologies will also be tested and, where applicable, showcased at SCE’s

Technology Centers. The AgMSP also plans for continued work and program development

around reduced water usage which has, as a secondary benefit, reduced electricity use. Lessons

learned from the Water Efficiency Pilot Program will be used in designing new customized

programs that lead with water savings.

As SCE continues into the 2009-2011 program cycle employing existing

programs and testing new programs within the Agricultural Market Segment, it will continue to

identify those programs that require or would benefit from a greater level of statewide

coordination on a program and market segment level.

5. Emerging Technologies

The Emerging Technology Program (ETP) will work with CEC, PIER, and

RD&D Communities through the Emerging Technology Coordinating Council to assure their

research portfolios are aligned with the IOUs and statewide strategic plan so that the energy

savings goals can be achieved. The Emerging Technology Program will also focus on

development, enhancement, deployment and operation of energy efficiency related technology

which is fundamental to achieving California’s energy efficiency vision and goals to successfully

implement the CEESP. The ETP will deliver information, insights, analytical tools, and

resources to help enable adoption of innovative technologies and support the penetration of new

applications to existing technologies. This information exchange will reduce investor

uncertainty and make energy efficiency investments more attractive. This will result in the

acceleration of introduction of energy efficiency products into the market.

44

6. Codes And Standards

The Codes & Standards (C&S) program directs initiatives that will enhance state

and federal building and appliance standards to codify cost-effective, reliable, persistent, and

verifiable demand side measures in support of maximizing portfolio energy savings, demand

reduction and demand response. Codes and Standards Enhancement (CASE) studies for energy

efficiency improvements are performed for promising design practices and technologies and are

presented to standards and code-setting bodies. The C&S program will support the zero-net

energy initiatives by advocating for Title 24 building energy standards that meet zero energy

requirements for residential new construction by 2020 and commercial buildings by 2030.

7. Local Government

Local government partnerships provide a number of key functions relating to

energy efficiency, conservation, and alternative energy. SCE endorses the vision of the Strategic

Plan to strengthen and capitalize upon the capacity of local governments to encourage leadership,

codes and standards enforcement, and community outreach. Local governments will take the

lead by example in support of the achievement of aggressive energy savings goals.

Many local governments are working to develop local ordinances or programs to

build a sustainable environment. SCE’s partnership programs will work with these partners,

with support from the DSM programs such as the Sustainable Communities Programs, the Codes

and Standards Program, and New Construction. These programs will support government and

institutions to simplify and standardize relevant policies and codes as well as create model local

ordinances or programs to facilitate adoption by local jurisdictions. Peer-to-Peer support is

considered a key part of this strategy. The Partnership program will provide forums for local

governments to come together and share best practices and to learn from and support each other.

SCE has developed a strong history of working closely with a variety of

institutional and local government partners to implement demand side management. These

partnerships enable the customers to focus on, learn about, and implement energy efficiency,

45

conservation, demand response, load shifting, and renewable energy within their own facilities.

In doing so, the partnerships assist the government agencies in complying with the state’s Energy

Efficiency Strategic Plan and tap into innovation.

8. DSM Integration

SCE’s 2009-2011 portfolio supports the key CEESP goal of DSM integration and

coordination, which include establishing integration procedures, piloting DSM integration

programs and improving regulatory coordination. For full discussion of integrated DSM, see

Exhibit SCE-5.

9. Marketing, Education And Outreach

The objective of SCE’s marketing, education and outreach efforts from 2009 to

2011 is to maximize energy savings and encourage customers to adopt an energy efficient

lifestyle. Marketing, education and outreach campaigns and materials will be developed in a

manner that leverages statewide branding, in order to maximize participation, market

transformation and adoption of long-term energy efficiency behaviors. SCE’s marketing efforts

are consistent with the CEESP, its objectives and its efforts to leverage an integrated portfolio of

DSM programs. The integrated marketing campaigns use customer segmentation research to

better understand our customers and provide them with a wide range of options. Segmentation

will also enable SCE to customize the characteristics of its offerings, providing customers with

solutions that are relevant to their needs.

In order to achieve SCE’s key objectives, marketing efforts will be designated to

move consumers through a continuum from awareness, to attitude change, to behavioral change.

The objective is to increase energy savings and use multiple layers of integrated marketing to

effectively reach customers, and motivate them.

Emphasis will be placed on program bundling, which involves pulling together

relevant energy efficiency, demand response, low income energy efficiency, California Solar

Initiative (CSI) programs, and SmartConnect™ rates and technology enabled offerings. Program

46

bundling will allow SCE to provide consumers with holistic energy management solutions, while

making them aware of SCE’s relevant offerings.

Accomplishing the long-term goal of maximizing energy savings and changing

consumer behavior requires a marketing effort across all stakeholders with responsibility for

energy efficiency in all sectors. SCE will coordinate with market players and leverage best

practices to move customers to take action through:

• Statewide branding

• Coordination between IOUs

• Utilization of several market factors, such as retail partnerships, business

partnerships, local governments, trade associations and non-profit

organizations

10. Workforce Education and Training

The California Energy Efficiency Strategic Plan, prepared by the IOUs, identifies

Workforce Education & Training (WE&T) as an important cross-cutting activity that focuses on

educating and training people to perform the jobs needed to reach California’s clean energy

goals. WE&T strategies require a comprehensive and collaborative approach to education and

training that focus on the development of new jobs that currently do not exist (based on market

sector needs), supplemental training and expanded outreach methods for new and existing

programs, and increasing awareness and demand for green careers.

SCE’s 2009-2011 Workforce Education & Training Program includes three

important core delivery components: 1) WE&T Strategic Planning; 2) WE&T Synergies, and 3)

WE&T EARTH Education and Training. Each component is designed to target specific market

segments, and accomplish the larger education and training CEESP goals and objectives.

The WE&T Strategic Planning and Implementation Program component is a

statewide program that serves as the planning and support function to long-range activities. The

WE&T Strategic Planning and Implementation component will facilitate implementation and

47

completion of the five key activities identified in the CEESP as necessary to drive long-term

WE&T development and strategic planning. The five key activities include: 1) Initial scoping

study and needs assessment of training and education resources; 2) Evaluate cost-benefit analysis

tools for investments in WE&T; 3) WE&T web portal for education and training initiatives and

opportunities; 4) Ongoing dialogue with key market stakeholders; and 5) Form a WE&T Task

Force to manage the scoping study and needs assessment, and facilitate the on-going

development and accomplishment of statewide WE&T activities.

The WE&T Synergies Program component utilizes SCE’s Energy Centers,

Technology Test Centers, and other information and training venues and program

implementation strategies, to provide comprehensive education and training offerings to a variety

of customers across all market sectors. This program is dynamically designed with the ability to

focus training to accommodate specific market sector training needs.

11. Low Income Energy Efficiency

The Low Income Residential Sector of the CEESP identifies several strategies to

ensure maximum realization of the Commission’s programmatic initiative, “To provide all

eligible customers the opportunity to participate in the LIEE programs and to offer those who

wish to participate in all cost-effective energy efficiency measures in their residences by 2020.”26

SCE’s Low Income Energy Efficiency (LIEE) proposals for 2009-2011 include

cost-effective measures for all eligible customers. The portfolio of cost-effective measures is

augmented by measures that produce long term and enduring savings, such as cooling measures,

which help promote the comfort, health and safety of eligible low income customers. SCE’s

proposed LIEE program is designed to achieve 1/4th of the Programmatic Initiative by

December 2011, and provide enduring savings. To achieve the Programmatic Initiative, SCE is

requesting a three-year program budget of $165 million. The increased program budget over

26 D.07-12-051, dated December, 20, 2007, p. 4.

48

2007-2008 funding levels, together with leveraging the resources of other entities, and improving

integration with SCE’s energy efficiency and demand-side programs, enables SCE to provide the

measures and reach the number of homes required to achieve 1/4th of the Programmatic

Initiative and achieve the 95,628 annual MWh and 35.6 MW demand reduction by year-end

2011. SCE’s complete low-income assistance programs proposal (Application 08-05-026) was

filed with the Commission on May 15, 2008.

D. Strategic Plan Outlook For Ten Years And Beyond

1. Program Line Item And Budget For Strategic Planning

Due to the importance of California’s “next generation” strategic planning, SCE

proposes establishing an energy efficiency Strategic Planning Team. This dedicated Team will

help lead SCE’s strategic planning, including collaboration with the Commission and other key

actors towards the goals, strategies, actions, and results put forward in the CEESP. SCE

proposes a budget of $7.78 million for the 2009-2011 cycle to support this new organization.

SCE’s Strategic Planning Team will serve several key roles that range from the

analytical to the logistical. SCE will have the Team directly lead many of these strategic

planning responsibilities while at other times also assisting others – notably SCE energy

efficiency senior management and program staff – who will have leading roles. The Team’s

responsibilities include:

• Conducting, designing and/or collaborating in the research, evaluation,

analysis, budgeting and other functions that are essential to strategic

planning development and implementation.

• Working with Commissioners and the Commission staff regarding

implementation of the current CEESP.

• Working with SCE management and staff regarding implementing

programs called for in the CEESP, such as SBD, CANHP, DSM and CSI.

49

• Collaborate with other key actors and stakeholders described in the

CEESP, and the other IOUs and the CEC.

• Coordinate (on either a start up or ongoing basis) SCE’s role in the

proposed California Energy Efficiency Alliance and California Energy

Efficiency Summit.

The IOUs plan to establish and contribute to a California Energy Efficiency

Alliance (CEEA). CEEA is dedicated to a forum for market transformation energy efficiency

program administrators in California willing to devote substantial resources and coordinate

activities to further the market transformation objectives and strategies in the CEESP. Proposed

activities of the CEEA would include:

• Sharing information among program administrators;

• Supporting coordination of programs and portfolios.

• Coordinating with other energy efficiency program administrators’ and

regional groups.

• Aligning with the efforts of national organizations promoting energy

efficiency.

• Establishing and overseeing some of the task forces as identified in the

CEESP.

The CEESP calls for SCE, other utilities, and the Commission to host an annual

“California Energy Efficiency Summit.” This event would review CEESP activities from the

previous year, outline near-term actions, and showcase exemplary accomplishments.

In summary, SCE proposes a substantial dedication of personnel, budget and

other resources so that we can strongly maintain ongoing strategic planning efforts, and do so

without being unduly distracted by “day to day” operational events. Our new energy efficiency

Strategic Planning Team will have staff that is both analytic and action-oriented with the

multiple goals of rigorous planning, innovative engineering, planning and quality assurance

(EP&QA).

50

2. New 2009-2011 Pilot Project Programs, Based On The Strategic Plan

SCE’s 2009-2011 portfolio includes multiple pilot programs in support of the

CEESP goals and strategies for both residential and nonresidential consumers, including the

commercial, industrial, and agricultural and water systems segments.

These include:

• Business and Consumer Electronics Program

• Energy Benchmarking

• Energy Efficiency Loan Program

• New IDEEA and Statewide Solicitations, and

• AB 32 Carbon Emission Reduction Pilot

3. Long-Term Savings Methodologies

The proposed portfolio is intended to provide both short-term and long-term

energy efficiency solutions, including the ability to work with market participants to affect

changes ten years or more into the future. SCE’s portfolio is designed to support various long-

term ventures, such as those discussed above: Residential New Construction, Commercial New

Construction, and driving the transformation process of California’s HVAC market. The

portfolio also continues to support the development of codes and standards, as well as identifying

and testing the viability of emerging technologies. There is no distinct regulatory treatment

required beyond the adoption of the recommended budget levels, the fund-shifting proposal set

forth by SCE in this Application and the ability to encumber funds in the 2009-2011 cycle which

can be funded from the subsequent program cycles. SCE’s recommended funding in this

Application, concurrent with its proposed fund-shifting rules and the ability to use funding from

future cycles, will allow SCE to fund the commitments for installation forecast in this

Application.

51

IV.

SCE’S PROPOSED ENERGY EFFICIENCY PORTFOLIO

This chapter of the application provides narrative and data to support SCE’s proposed

energy efficiency portfolio for 2009-2011.

A. The Proposed Portfolio Meets Or Exceeds The Energy Efficiency Goals

1. Portfolios Meet Or Exceed 2011 Cumulative Savings Goals

SCE’s recommended portfolio meets the cumulative savings goals for the three-

year cycle. As discussed in the Policy section of this Application, SCE recommends a

cumulative goal be adopted which reflects cumulative savings beginning in 2009 and ending in

2011.

SCE’s also provides a calculation scenario which follows the direction of D.07-

10-032, calculating the expected cumulative savings of the portfolio plans using 2004 as the base

year. The calculation of these savings is based upon the following:

o 2004 and 2005 net savings results as reported in draft or final program

impact studies, where available;

o 2004 and 2005 net savings results from forecasts, where impact studies are

not available;

o 2006 and 2007 net savings results, with 2008 results replicated from 2007;

and

o 2009-2011 results as forecast in this proceeding.

These scenarios do not include the cumulative impacts for savings occurring

during this period for programs implemented prior to 2004, or other items which were not

explicitly included in the studies or forecasts of savings. It is unclear as to whether all of the

studies included the full commitments made in the 2004-2005 program cycle and SCE’s Summer

Initiative programs implemented in this timeframe. Such inclusions may alter the analysis

52

performed for this Application. SCE would expect to see the cumulative effect of these savings

continue over time as participants continue to install the measures which were installed

previously, particularly as codes and standards improve over time. SCE looks forward to further

addressing this analysis in order to ensure that the appropriate calculation is performed which

allows the IOUs to meet the Commission’s policy and resource goals while providing cost-

effective portfolios to customers.

2. Portfolios And Funding Levels Appropriately Balance Short-Term And

Long-Term Savings

The proposed portfolio is intended to provide both short-term and long-term

energy efficiency solutions, including implementation of the Energy Efficiency Strategic Plan,

which is intended to affect changes ten years or more into the future. Short-term savings are

supported by the implementation of the full set of resource programs, designed to focus on

immediate savings for customers, the immediate replacement of supply-side resources, and the

immediate reduction of greenhouse gases. SCE’s portfolio is also designed to support various

long-term ventures, such as those discussed above: Residential New Construction, Commercial

New Construction, and driving the transformation process of California’s HVAC market. In

addition, the portfolio includes substantial contributions to programs such as Marketing

Education and Outreach, and Workforce Education and Training, each with a significant focus

on long-term benefits to the state. The portfolio also continues to support the development of

codes and standards, as well as identifying and testing the viability of emerging technologies.

The average useful life of SCE’s portfolio proposed in this Application is approximately 10.9

years, increased from approximately 9.8 years in SCE’s 2006-2008 Application. SCE proposes a

diverse portfolio of approaches and measures to address the short-term and long-term needs of

all customers through a multitude of delivery channels and program implementers.

53

3. Portfolios Reasonably Allocate Funding Among Market Sectors

Since 2001, multiple Commission funded studies of energy efficiency potential in

California have been performed. These studies have been performed by consulting firms

recognized internationally as experts in the assessment of energy efficiency potential.

In planning SCE’s 2009-2011 program portfolio, SCE’s planners made judicious

use of these studies of energy efficiency potential to inform their planning process. SCE used

the results of both the 2006 California Energy Efficiency Potential Study27 and the draft

California Energy Efficiency Potential Study 200828 to their guide decision-making regarding

SCE’s program offerings.

SCE attempted to align the portfolio planning with estimates of energy efficiency

potential by sector for the four customer sectors identified in the California Energy Efficiency

Strategic Plan: Residential, Commercial, Industrial, and Agriculture. The 2006 and 2008 Itron

Studies of energy efficiency potential provides a significant amount of useful information for

residential, commercial and institutional. For agriculture, SCE used the best data available.

SCE used the energy efficiency potential studies to align programs with the

available potential by sectors. Table IV-7 below compares SCE’s 2009-2011 Energy Efficiency

Portfolio with the results of the California Energy Efficiency Potential Study 2008 (Draft), for

SCE’s service territory.

27 California Energy Efficiency Potential Study 2006, Itron, Inc., KEMA, Inc., RLW Analytics, Inc., and Architectural Energy Corp., May 2006.

28 California Energy Efficiency Potential Study 2008 (Draft), Itron, Inc., February 2008.

54

Table IV-7 Comparison of SCE’s Portfolio and Energy Efficiency Potential by Sector

2009-2011 SCE Portfolio SCE Potential - 2009-2011*

Sector kWh kW kWh kW

Residential 31.0% 26.9% 36.5% 24.0%Commercial 48.6% 57.6% 47.4% 65.4%Industrial 17.6% 11.8% 16.1% 10.5%Agriculture 2.8% 3.7% - - Total 100.0% 100.0% 100.0% 100.0%

SCE also used data regarding potential by end use to guide the type and mix of

measures included in the portfolio. Table IV-8 compares SCE’s proposed portfolio with the

results of the 2008 Itron energy efficiency potential study.

Table IV-8 Comparison of SCE’s Portfolio and Energy Potential by End Use 2009-2011

SCE Portfolio SCE Potential - 2009-2011* End Use kWh kW kWh kW

HVAC 19.1% 32.5% 19.3% 47.0%Lighting 47.6% 37.7% 56.8% 38.3%Refrigeration 9.1% 8.8% 13.0% 7.8%Misc/Other 17.5% 16.2% 1.6% 1.3%Compressed Air 1.0% 0.6% 1.6% 1.0%Drives 1.8% 0.9% 1.6% 1.0%Pumps 3.8% 3.4% 6.0% 3.6% Total 100.0% 100.0% 100.0% 100.0% *Results based on Draft California Energy Efficiency Potential Study 2008, Itron Inc. (Full Restricted Scenario)

4. Portfolios Cost-Effectiveness Takes into Account Uncertainty

SCE has planned its energy efficiency portfolio consistent with the Commission’s

goal of procuring all available cost-effective energy efficiency.29 Through a diverse set of

program offerings, SCE’s energy efficiency portfolio is focused on strategies that harvest cost-

29 Public Utilities Code § 701.1(b).

55

effective energy efficiency savings and demand reductions while looking beyond the 2009-2011

planning cycle to ensure energy efficiency remains a reliable and robust resource.

The Energy Efficiency Standard Practice Manual outlines the methodologies and

indicators used to perform a dual-test cost-effectiveness evaluation, which consist of the Total

Resource Cost (TRC) test and the Program Administrator Cost (PAC) test.30 The E3 Calculator,

which is the Commission-approved tool to run cost-effectiveness calculations, contains the

aforementioned methodologies and indicators. SCE has developed its portfolio and its cost-

effectiveness outputs using the E3 Calculator methodology. The portfolio is in compliance with

the April 21 ACR requiring the IOUs to use the updated 2007 generation cost values adopted in

the Commission’s October 4, 2007 Resolution E-4118. SCE presents its prospective showing of

cost-effectiveness of its 2009-2011 energy efficiency portfolio in the tables below.

Table IV-9 Total Resource Cost (TRC)

Total Costs $2,768,163,336 Total Savings $4,707,984,831 Total Benefits $1,939,821,494 Benefit/Cost Ratio 1.70 Levelized Cost per kWh Saved (cents/kWh) $0.067 Levelized Cost per therm Saved ($/therm) --

30 California Standard Practice Manual, pp. 18-25.

56

Table IV-10 Program Administrator Cost (PAC)

Total Costs $1,571,711,696 Total Savings $4,707,984,831 Total Net Benefits $3,136,273,135 Benefit/Cost Ratio 3.00 Levelized Cost per kWh Saved (cents/kWh) $0.035 Levelized Cost per therm Saved ($/therm) --

The cost-effectiveness tests are derived to calculate the benefits and costs

associated with the implementation of energy efficiency programs. The benefit and cost

calculations are driven by specific key parameters, including Expected Useful Lives (EUL), Net-

to-Gross Ratios (NTG) measurements, and measure energy use impacts. SCE, in compliance

with Commission direction, in the Assigned Commissioner’s and Administrative Law Judge’s

Ruling dated May 5, 2008 has used the May 30, 2008 release of DEER with specific changes

discussed in this Application, this includes estimates of the key parameters to calculate the ex-

ante energy savings, demand reduction, and cost-effectiveness forecasts. Current measurement

and evaluation protocols establish a process over the course of the program cycle to evaluate the

ex-ante impacts in order to determine the proper ex-post evaluation of the portfolio. This process

creates an inherent uncertainty in program planning because it subjects the impacts of the

portfolio to change four years removed from the beginning of the program cycle.

In response to the Assigned Commissioner’s and Assigned Law Judge’s Ruling

dated April 21, 2008, SCE presents its prospective showing of cost-effectiveness using a higher

$30/ton carbon adder value in the tables below.

57

Table IV-11 Total Resource Cost (TRC) With Higher Carbon Adder

Total Costs $2,808,728,276 Total Savings $5,047,648,905 Total Benefits $2,238,920,629 Benefit/Cost Ratio 1.80 Levelized Cost per kWh Saved (cents/kWh) $0.067 Levelized Cost per therm Saved ($/therm) --

Table IV-12 Program Administrator Cost (PAC)

With Higher Carbon Adder Total Costs $1,612,276,635 Total Savings $5,047,648,905 Total Benefits $3,435,372,270 Benefit/Cost Ratio 3.13 Levelized Cost per kWh Saved (cents/kWh) $0.035 Levelized Cost per therm Saved ($/therm) --

SCE has planned its 2009-2011 energy efficiency portfolio to account for the

uncertainty around evaluating its portfolio using two sets of different assumptions and believes

that its portfolio will remain cost-effective despite any reasonable variation between ex ante and

ex post assumptions. SCE has conducted the following scenarios, based upon the key parameters

influencing cost-effectiveness, which illustrate the effects on its portfolio’s energy savings,

demand reduction, and cost-effectiveness.

58

Table IV-13 Scenarios Based on Key Parameters Influencing Cost-effectiveness

Scenario Adjustment FactorEnergy Savings

(kWh)Demand Reduction

(MW) Cost-Effectiveness

SCE 2009-11 Proposal None 6,021,687,168 1,225,051 1.70

Gross Measure Costs Adjustment Increase by 10% - - 1.59

Gross Measure Costs Adjustment Increase by 20% - - 1.48

Effective Useful Life Decrease by 10% - - 1.54

Effective Useful Life Decrease by 20% - - 1.41

Gross Measure Costs Adjustment / Effective Useful Life

Increase by 10% / Decrease by 10% - - 1.43

Gross Measure Costs Adjustment / Effective Useful Life

Increase by 20% / Decrease by 20% - - 1.23

5. Portfolios Are Designed To Overcome Barriers And to Advance Integration

In Decision 07-10-032 the Commission made several key changes to the previous

regulatory framework for efficiency programs. One, market transformation initiatives were

embraced and, two, an imperative was placed on integration – across utility service areas, utility

ownership types, state agencies, and demand-side programs. SCE has been and remains

supportive of these changes.

The portfolio proposes activities that address each major component of the market

transformation continuum and their respective barriers.

• R&D and Emerging Technology. This application proposes enhancing and

expanding the statewide Emerging Technology program to better mine

innovation, understand consumers, assess market exposure and support

climate and environmental efforts.

• Education and Outreach. At the heart of voluntary market transformation is

overcoming informational and motivational barriers by educating consumers

59

and other energy/efficiency decision-makers about the merits of energy

efficiency.

• Financial Incentives. Voluntary market transformation often relies heavily

on providing financial incentives to overcome the barriers of high first costs

and/or discomfort with new (energy efficient) products. This application

follows that pattern.

• WE&T. Responding to the shortage of trained efficiency-implementing

workers is essential if markets are to be transformed thoroughly and quickly.

This application supports the CEESP’s strategies in this area.

• Codes & Standards. Decision 07-10-032 and the CEESP place great

emphasis on the adoption of and compliance with aggressive energy codes

and standards. This application proposes enhancing and expanding the

statewide Codes & Standards program.

SCE’s Application also advances the intertwined integration agendas.

“Integration” is used in Decision 07-10-032 and CEESP to indicate integration and coordination

among demand-side options; but it also refers to integration across utilities (preferably statewide)

and integration between utilities and government agencies. Proposed actions include:

• Integration across utility companies, such as ME&O, Emerging Technologies,

California New Homes, and others.

• Utility-agency coordination such as working closely with the CEC, CPUC and

local governments on codes & standards development ad compliance.

• Integration among demand-side resource activities include a wide array of

activities planned as described in Exhibit SCE-5.

60

B. Proposed Portfolio Design Achieves Savings Objectives

1. Strategies To Reduce Critical Peak Loads And Improve System Load

Factors

As shown in Section IV.A, SCE’s 2009-2011 energy efficiency portfolio includes

measures that encompass all major end uses. The portfolio is structured across end uses to

provide both energy and demand savings, creating a complete energy efficiency resource. SCE’s

proposed 2009-2011 energy efficiency portfolio has a peak-to-energy ratio of 0.198. In March

and April 2008, Energy Division issued proposed energy and demand savings goals for

California IOUs. For SCE the proposed goals have an implied peak-to-energy ratio of 0.177 for

the period 2009-2011.31 By comparison, the peak-to-energy ratio for SCE’s 2006-2007 energy

efficiency programs was approximately 0.165. Overall, SCE has increased the on peak

reductions of its proposed 2009-2011 energy efficiency portfolio from recent levels and in

comparison to the Commission’s proposed energy efficiency goals.

2. Strategies To Minimize Lost Opportunities

SCE’s 2009-2011 portfolio of residential programs is generally designed to avoid

lost opportunities through a “comprehensiveness” strategy. Programs are promoted and designed

to encourage comprehensive projects that are not limited to only the most cost effective

measures. In the residential sector, lost opportunities are most likely to arise when a consumer

elects to upgrade only one or two elements of a heating/cooling system or invasive building

envelop improvement.

SCE’s comprehensive approach encourages consumers to look at the complete

picture of managing energy and demand. Where programs are targeted to specific end-uses or

31Assistance in Updating the Energy Efficiency Savings Goals for 2012 and Beyond, Itron, Inc., May 2008. This statistic compares 2009 – 2011 cumulative demand reductions from Table E3-18 and cumulative 2009 – 2011 energy savings from Table C2-18.

61

equipment, care is taken to select equipment that does not create lost opportunities in most

circumstances (e.g., refrigerator replacement, light bulb exchanges). SCE’s programs are

supported by general advertising campaigns. The campaigns encourage residential consumers to

pursue all cost effective opportunities energy efficiency improvements.

The focus on comprehensiveness is to assure that hard-to-reach vertical markets

segments are fully considered and that projects implemented at individual customer locations

consider all available measures, not simply those that are easiest to install or most cost effective.

SCE also revisits customers’ specific energy audit data to assess whether there may be renewed

opportunities to implement recommendations from audit filings, and minimize lost opportunities.

Both Institutional and Local Government Partnerships promote a comprehensive

approach to minimize lost opportunities in local government and institutional facilities. In

general, this market segment has the most potential for lost opportunities. Lost opportunities

occur when higher efficiency opportunities are not identified or are valued-engineered out of a

project due to lack of funds or lack of management support. Partnerships help minimize these

lost opportunities by putting a team of experts with the customer to communicate and facilitate

the potential results of energy efficiency to decision makers within these organizations.

3. Successful And Cost-Effective Programs Have Been Continued

SCE’s overarching goal for energy efficiency programs is to procure cost

effective energy savings. SCE’s portfolio will continue to rely on proven programs such as the

Business Incentive Element – Calculated/Customized and Itemized Retrofits (formerly named

Standard Performance Contract and Express Efficiency), which have successfully demonstrated

the ability to achieve cost effective energy and demand savings over the near term. SCE will

continue to place emphasis on those programs that have a proven ability for longer term energy

savings such as Savings By Design, and Sustainable Communities. Additionally, SCE will

incorporate several successful 2006-2008 IDEEA programs and measures into its core energy

efficiency offerings.

62

4. Program Design Reflects Cumulative Savings

As discussed in more detail above, SCE’s recommended portfolio meets the

cumulative savings goals for the three-year cycle. This is performed through a focus on both

long-term and short-term measures, combined with the full support of the Energy Efficiency

Strategic Plan. The quantification of the long-term impacts of the Energy Efficiency Strategic

Plan is difficult, but the efforts in support of the Plan are throughout this Application and are

focused on cumulative savings from both short-term strategies being implemented today and the

impact of the Strategic Plan in the long term.

SCE proposes a diverse portfolio of approaches and measures to address the

short-term and long-term needs of all customers through a multitude of delivery channels and

programs. This portfolio is designed to focus on continuing to pursue long-term savings and

allow SCE to address the need for long-term, cumulative savings to meet the resource needs of

California.

5. How The Potential Inclusion Of Energy Savings From “Spillover” Activities

Has Been Reflected In Program Design

Current policy rules do not allow energy savings from “spillover” activities to be

counted towards energy savings goals. Consequently, SCE’s portfolio has been designed to be

cost-effective without counting spillover effects.

However, given the social value and the Commission’s interest in generating

savings beyond direct program participation, SCE is including in its portfolio some nominally

non-cost effective programs focused on spillover effects.

Additionally, in the development of its 2009-2011 portfolio, SCE looked for

opportunities to create spillover effects that can be generated on top of clearly countable savings.

While the initial projects generate countable savings, the intent is that trained design teams will

then use the integrated design approaches they’ve learned to produce more efficient buildings in

future projects, without receiving further incentives.

63

6. How Utilities Propose That Potential Energy Savings From Market

Transformation Programs Should Be Measured

SCE highly recommends the following two nationally-praised market

transformation measurement works developed with California Public Goods Charge funds and

overseen by statewide advisory groups including regulatory and utility evaluation personnel:

• A Framework for Planning and Assessing Publicly Funded Energy Efficiency

(2001, http://www.calmac.org/events/20010301PGE0023ME.pdf) and

• The California Evaluation Framework,

(http://www.calmac.org/events/California_Evaluation_Framework_June_2004

.pdf ).

The CFL direct installation and rebate programs represent one of the most

impressive energy efficiency market transformation examples to date.

The CFL programs took an obscure technology, demonstrated its efficacy, and

have gradually built increasing demand for it year after year. The result has been a continuing

reduction in cost and an increase in the number of manufacturers, available lamp varieties, and

the number and types of retail outlets. SCE’s goal moving into 2009-2011 will be to spread

awareness and availability of specialty CFLs that will fit into the many fixtures that cannot

accept standard CFLs.

7. Emerging Technologies That Are Anticipated To Increase Savings Potential

The Emerging Technology Program (ETP) disseminates information to customers

through seminars, workshops, technical conferences, and professional journals. The status of the

latest technologies is posted at web sites accessible to the general public so that customers can

adopt the cost effective technologies in their residence or business. The information generated

by the ETP is also disseminated through energy efficiency programs. The ETP efforts include

the Technology Research Incubator Outreach (TRIO) program, aimed at contributing to

64

technology adoption by influencing the attractiveness of energy efficiency technology

investment and development in California.

8. Portfolios Contribute To The Green Building Initiative

In December 2004, Governor Schwarzenegger signed Executive Order S-20-04,

which was accompanied by the Green Building Action Plan. Together they became known as

the state’s Green Building Initiative (GBI). The GBI places great attention on buildings owned

by the State, but also addresses furthering green buildings that are owned and managed by other

public, institutional and for-profit commercial entities.

SCE’s Application provides numerous programs and opportunities for State

agencies, departments, and other entities under the direct executive authority of the Governor to

take measures to reduce grid-based energy purchases for state-owned buildings through the

installation of cost-effective efficiency measures under SCE’s proposed programs. SCE is

proposing several important buildings sector-wide actions that will greatly facilitate the GBI and

address many of the major obstacles to furthering green building projects. These actions include,

developing consistent benchmarking of facilities, supporting retro-commissioning, expansion of

Titles 24 and 20 Codes & Standards, coordination with the PIER program, promotion of

integrated building design, development of California-oriented HVAC technologies, and

establishment of a buildings-sector “Zero/Low-Energy Financing Task Force” to advance

innovative green building financing options.

C. Proposed Portfolio Design Reflects Market Strategies, Integration, And Delivery

Channels To Enhance Customer Participation In Demand-Side Resources

1. Summary Of Proposed Programs

This section provides an overview of SCE’s proposed program offerings for

program years 2009-2011. Each of the programs in SCE’s portfolio is described in detail in the

Program Implementation Plans in Exhibits SCE-3 and SCE-4. SCE’s portfolio incorporates the

65

successful elements of previous program designs while making innovative changes to maximize

the resource benefits derived from the programs and to align with the long term CEESP.

a) Residential Programs

The residential consumer base of Southern California Edison constitutes

one of the most diverse and challenging collection of electricity consumers in the nation in terms

of geography and diversity. SCE’s residential energy efficiency portfolio delivers a wide array

of programs and services for every California customer and advance the implementation of the

BBEES, the CEESP, and California’s Energy Action Plan (EAP).

(1) Appliance Recycling

The Appliance Recycling Program (ARP) produces cost-effective

long-term coincident peak demand reduction and long-term annual energy savings in residential

and non-residential market sectors. The program picks up operable, inefficient refrigerators and

freezers from residential dwellings and businesses in which they have been either primary or

secondary appliances, and prevents their continued operation by recycling them in an

environmentally safe manner.

(2) Home Energy Efficiency Rebates

The Home Energy Efficiency Rebates (HEER) encourages

customers to make an energy efficient choice when purchasing and installing household

appliances and equipment measures, by offering customers educational materials on energy

efficiency options and rebate and incentive offerings. The program offers an immediate rebate at

the retailer’s register through point-of-sale rebates for many measures, in addition to online

rebate forms.

66

(3) Business And Consumer Electronics Program

Business and Consumer Electronics Program (BCED) provides

retailers with midstream incentives to increase the stocking and promotion of qualifying, high

efficiency, electronic products. Potential categories include computers, computer monitors,

cable and satellite set-top boxes, televisions and other electronics as they become available. The

program continues to expand the point-of-sale rebate delivery method, and provides field support

services to update marketing materials in retail stores and provide support education to the

retailer sales force.

(4) Plug Load Program

The Plug Load Program is a non-resource program that takes an

active leadership role in addressing the energy use issues associated with the increasing demand

of plug load devices. The goal of the program is to report on all categories of plug load

information and influence market stakeholders to support energy efficient choices.

(5) Residential Lighting Incentive Program For Basic CFL’s

For 2009-2011, the upstream lighting programs have been split

into separate programs; the Residential Lighting Incentive Program for Basic CFLs and the

Advanced Consumer Lighting program. SCE’s Residential Lighting Incentive Program

represents a continuance of the existing Upstream Lighting Program within SCE’s residential

energy efficiency portfolio. This program provides customers with incentives in the form of

discounts that greatly reduce the cost of energy efficient lighting products to customers for basic

CFLs (i.e., screw-in bare spiral CFLs ≤ 30 Watts), and strives to influence future purchasing

behaviors of customers.

67

(6) Advanced Consumer Lighting Program

The Advanced Consumer Lighting (ACL) program provides

customers with incentives in the form of discounts that greatly reduce the cost of energy efficient

lighting products to customers. All forms of ENERGY STAR labeled screw-in compact

fluorescent lamps will be offered in the program other than screw-in bare spiral CFLs (Basic

CFLs). Also offered are ENERGY STAR labeled hardwired and plug-in fixtures. Additionally,

early production of general illumination screw-in halogen lamps that meet the 2012 state and

federal equipment standards will be eligible for incentives. Other subprograms are planned for

non-bare spiral products, such as the “California Super CFL” program, which will mitigate

market barriers to CFLs among high and upper medium income customers, and the Torchiere

and Plug-in Lamp Exchange Program. Web, catalog, phone sales, and lighting showroom store

outreach activities are also being planned.

(7) Multi-Family Energy Efficiency Program

The Multi-Family Energy Efficiency Program promotes prescribed

rebates for energy efficient products to motivate property owners /managers to install energy

efficient products in multifamily complexes, condominium complexes, and mobile home parks.

An additional objective is to heighten property owners/managers and tenants energy efficiency

awareness and knowledge.

(8) Comprehensive Mobile Home Program

The residential Comprehensive Mobile Home Program (CMHP) is

a direct install program designed to provide a comprehensive energy efficiency program to

mobile home customers in collaboration with local communities. The program installs energy

efficient products in the mobile home and common areas of the mobile home parks.

68

(9) Comprehensive Home Performance Program

The Comprehensive Home Performance program delivers

comprehensive improvements packages tailored to the needs of each existing home and its

owner. The program solicits, services, and trains qualified residential repair, and renovation

contractors to assemble capable contracting teams, perform whole-house diagnostics, propose a

comprehensive improvement package, and complete the improvements.

(10) Home Energy Efficiency Survey

The Home Energy Efficiency Survey (HEES) Program is an

implemented program used to outreach to customers in five languages (English, Spanish,

Chinese, Vietnamese, and Korean) and four delivery channels (mail-in, on-line, in-home and

phone surveys) to perform a variety of energy audits. The program provides survey results to

enable participants to understand how their energy and water use varies throughout the year.

(11) Efficient Affordable Housing

The Efficient Affordable Housing program is designed to address

the affordable housing retrofit market segment. The program will use a comprehensive

performance-based approach to encourage affordable housing property owners to choose the

most cost-effective measures to achieve a 20 percent energy improvement over existing building

conditions.

(12) Online Buyer’s Guide

The Energy Efficiency On-Line Buyer's Guide is a new service

designed to provide SCE’s residential customers with one web-based source for information and

tools needed to assist customers with purchasing energy efficient products and participating in

energy efficiency programs.

69

(13) California New Homes Program

The California New Homes Program (CANHP) is designed to

encourage single and multi-family builders of all production volumes to construct homes that

exceed California’s Title 24 energy efficiency standards by a minimum of 10 percent. This will

be achieved through a combination of incentives, technical education, design assistance, and

verification.

(14) Manufactured Housing New Construction

The Manufactured Housing New Construction Program is

designed to promote the construction of new manufactured homes in SCE’s service territory that

comply with ENERGY STAR energy efficiency standards. The Program targets manufacturers,

retailers, and homebuyers of new manufactured homes.

b) Non-Residential Programs

SCE’s 2009-2011 nonresidential portfolio is designed to reach a broad

spectrum of customers in each of the major sectors- commercial, industrial, agricultural and

government & institutions, and to align with the strategies and goals of the CEESP.

To achieve delivery of targeted energy efficiency solutions to specific

market segments and customers, SCE proposes a nonresidential program portfolio structured

with a hybrid program approach. The key innovation of the hybrid approach is the recognition

that assembling the individual offerings and services into segment- and customer-specific

solutions should be separated from the management of the offerings.

The hybrid approach will continue the traditional statewide and local

energy efficiency programs, such as Standard Performance Contract, Express Efficiency, and

Savings By Design, however, they will be managed as menus of offerings and services.

70

The Market Segment Plans describe how the key market segments will be

targeted with customized solutions chosen from the menu of offerings, but refer to the PIPs for

detailed descriptions of the individual offerings and services.32

Nonresidential Market Segment Plans

(1) MSP – Industrial Sector

The Industrial Market Segment within the SCE service territory

comprises a variety of major sub-segments, including oil and gas extract, communications,

plastics, glass, and industrial gases, among others. This segment is characterized by high

consumption and demand, high electricity usage intensity, and opportunities focused on motors,

pumps, controls and lighting measures. The Industrial Market Segment Plan (MSP) is a blend of

both innovative and proven tactics.

The energy efficiency programs proposed and implemented in the

industrial sector will be delivered through existing/core energy efficiency programs with

incentives, rebates, audits, retrocommissioning and other services.

(2) MSP – Agricultural Sector

The Agriculture and Water Systems MSP for the 2009-2011

program cycle addresses two characteristics of the sector that have historically been an obstacle

to adoption of energy efficiency throughout all regions of the country, and California in

particular: diversity of the customer base, and the relatively small proportion of electricity costs

compared with total operational costs. The MSP comprises a comprehensive set of strategies

and tactics to produce energy, environmental, and economic benefits. Its design enhances the

adoption of energy efficient equipment and practices among customers in this market sector

through a combination of existing and new programs.

32 See SCE Exhibits 3 and 4.

71

(3) MSP – Commercial And Small Business

The Commercial MSP provides a summary of SCE’s Energy

Efficiency (EE) program portfolio offered to SCE’s Commercial customers. SCE’s Commercial

MSP:

• Provides solution for all major commercial sub-segments, including

government and institutions;

• Develops solutions for common building types (e.g., office buildings,

retail space, lodging space, warehouses, etc.);

• Captures the “hard-to-reach” smaller (less than 200 kW demand)

customers that have similar buying characteristics, and

• Targets a buildings’ energy consumption profile.

Nonresidential Programs

(1) Residential/Light Commercial HVAC Program

The Residential/Light Commercial HVAC Program will continue

the transformation process of California’s HVAC market to ensure that “technology, equipment,

installation, and maintenance are of the highest quality to promote energy efficiency and peak

load reduction in California’s climate.”33 SCE proposes building towards this vision for HVAC

by implementing a variety of downstream, midstream, and upstream strategies designed to affect

a positive influence on the overall behavior of all stakeholders, including the use of quality

installation and maintenance.

(2) Commercial New Construction Quality Assurance (CNCQA)

The Commercial New Construction Quality Assurance Program is

designed to identify methods to ensure that customers with new buildings are realizing a level of

33 California Energy Efficiency Strategic Plan, dated June 2, 2008, p. 6-1.

72

energy performance consistent with California’s Building Energy Codes and Standards (Title

24). This program will explore ways for SCE to fill a more direct role in ensuring that customers

are receiving the full energy performance benefits out of their new buildings.

(3) Business Incentives Element

Through incentives and no-cost installation offerings across a full

range of measures, the Business Incentive Element helps business customers of all sizes and in

all nonresidential market segments by reducing financial costs of energy efficiency programs to

the customers for the implementation of these offerings.

The program will include coordination activities with entities such

as vendors, local governments, community and faith-based organizations, and other community

groups to promote program participation.

(4) Industrial Energy Efficiency Program

The Industrial Energy Efficiency Program is the primary-incentive

based program supporting the Industrial vertical market segments. It pays incentives to

industrial customers who install and use energy efficient hardware and equipment in their

operations and also provides services to industrial customers to help propel customers to

implementing energy efficiency.

(5) Agricultural Energy Efficiency Program

The Agricultural Energy Efficiency Program is the primary

incentive-based program supporting the Agriculture and Water Systems vertical market

segments. This program pays incentives to customers when they install energy efficient

hardware and equipment in their operations, and also provides services, including pump testing,

which provide design assistance for pumping systems.

73

(6) Financial Solutions Element

SCE’s Financial Solutions Element (FSE) will offer the

participants of energy efficiency projects access to capital funds and assistance to overcome

barriers related to project financing. These programs include, On-bill financing, Energy

Efficiency Loan Programs, and AB32 Carbon Emission Reduction Program.

(7) Business Services Element

The programs under the Business Services Element (BSE) help

commercial, industrial, government and institutions, and agricultural business customers of all

sizes identify and assess the potential for energy-efficiency projects’ implementation,

optimization, and sustainability. The program will provide services to help survey facility

processes and operations. In most cases, the identified energy efficiency projects will be eligible

for a financial incentive under one of SCE’s Business Incentive Element components.

(8) Commercial Energy Efficiency Program

The Commercial Energy Efficiency Program (CEEP) is the

primary-incentive based program (or rebate “engine”) supporting the commercial market sector

and is a major element of SCE’s implementation of the CEESP. CEEP will extensively leverage

the calculated and itemized retrofit offerings in the BIE, the business services offerings in the

BSE, and the financial services offerings in the FSE.

(9) Entertainment Centers Energy Efficiency

The primary objective of the Entertainment Centers Energy

Efficiency Program is to help facilities with highly variable occupancy such as movie theaters,

amusement parks, and auditoriums, realize energy savings in a cost effective manner. The

program includes energy audits, maintenance training, and low cost/no-cost measures, with an

emphasis on demand control ventilation technology.

74

(10) Private College Campus Housing Energy Efficiency Program

The Private College Campus Housing Energy Efficiency Program

offers energy efficiency measures, training, and financing to qualifying private college campus

housing facilities, including campus dining facilities or common area kitchens. The program

will include a comprehensive offering of installations, retrofits, and RCx and building

optimization to improve efficiency and will recruit and train students on some campuses to

conduct lighting energy surveys.

(11) Management Affiliates Program

The Management Affiliates Program (MAP) will primarily focus

on managing energy efficiency projects for commercial office buildings, retail department stores,

and other business buildings (from participating property management companies). The program

provides assistance to cities with specific energy efficiency program management needs. City

assistance will be in collaboration with other organizations, such as joint power agencies and

local governmental councils.

(12) K-12 Private Schools and Colleges Audit and Retrofit Program

The K-12 Private Schools and Colleges Program provides

comprehensive energy efficiency services to private preschools, K-12 schools, colleges,

universities, and trade/technical schools, including benchmarking and energy audits,

comprehensive direct installation of no-cost/low-cost measures, and incentives and installation

assistance.

(13) Healthcare Energy Efficiency Program

The Healthcare Energy Efficiency Program (HEEP) is a retrofit

program that provides comprehensive whole building/system technical audits comprehensive and

other services and establishes a permanent framework for a sustainable, long-term,

75

comprehensive energy management program for the medical office buildings. The program

provides a comprehensive approach to energy efficiency measures, including lighting and

lighting controls, HVAC systems and controls, and other equipment.

(14) California Preschool Energy Efficiency Program

The California Preschool Energy Efficiency Program targets both

public and private preschool facilities or preschool contractors, including stand-alone and shared-

space facilities. The program delivers cost effective energy and demand savings through a

comprehensive energy efficiency strategy that includes detailed audits, technical assistance,

financial analysis, and implementation of measures.

(15) Integrated DSM Food Processing Pilot

The Integrated Demand Side Management (IDSM) Food

Processing Pilot is a non-resource program in which industry, trade allies, and others partner to

promote integrated energy management solutions to end-use customers in the food processing

and refrigerated warehouse segments. Targeted customers include agricultural post-harvest

processors and food processing, fruit and vegetable processors (canners, dryers, and freezers),

prepared food manufacturers, wineries and other beverage manufacturers.

(16) Automated Energy Review For Schools

The Automatic Energy Review for Schools (AERS) Program will

increase the energy performance of new and modernized school buildings by utilizing

Department of State Architects (DSA) review and approval process. The program will flag and

refer projects that marginally exceed the energy code to the automatic plan review technical

assistance team for potential energy-saving design modification opportunities.

76

(17) Savings By Design

Savings by Design (SBD) provides the nonresidential new

construction industry with a broad palette of technical and financial resources to aid them in

designing new facilities to the most cost-effective energy and resource efficiency standards. The

program offers the Whole Building Approach and Systems Approach to its customers with new

construction or major remodel/renovation projects. The program will offer financial support for

design teams to undertake an integrated design process, as well as incentives to building owners.

(18) Sustainable Portfolios

The Sustainable Portfolios Program obtains commitments from

real estate owners, investors and major tenants throughout California to “green” their portfolios

of leased commercial office space. Participants are offered a comprehensive set of “one-stop”

turn-key services including strategic implementation plan development, and comprehensive

installations including HVAC retrofits, conversion to variable flow for air and water systems,

hybrid central plants, real-time ventilation controls, standard RCx and lighting upgrades.

(19) Monitoring-Based Commission

The Monitoring-Based Commissioning (MBCx) Program

combines RCx and continuous commissioning activities with ongoing, technology-based

monitoring to ensure persistent savings. The program exclusively targets commercial customers

that are eligible to participate in or are currently participating in Demand Response programs.

(20) Leased Office Space Retrofit Program

The Leased Office Space Retrofit Program provides non-owner

occupants of commercial office buildings, audits and installations of energy efficient lighting,

computer load management software, and HVAC equipment in their leased office space.

77

(21) Data Center Energy Efficiency Program

The Data Centers Energy Efficiency Program (DCEEP) is an

incentive program that promotes retrofit, RCx, and virtualization offerings to significantly reduce

the energy and demand use of data centers across multiple market segments. The program will

use a combination of traditional technologies combined with emerging technologies to offer

comprehensive solutions and will take a holistic approach towards data centers.

(22) Monitoring-Based Persistence Commissioning Program

The Monitoring-Based Persistence Commissioning (MBPCx)

Program will provide marketing, technical assistance, and financial incentives to facilities

including office buildings, hotels, hospitals, and colleges & universities (except UC/CSU/IOU

Partnership & Local Government Partnerships). The program will offer implementation of

traditional RCx measures as well as more comprehensive energy efficiency upgrades and

retrofits. The program also provides a rigorous RCx approach that facilitates the continuous

reporting and correction of deviations from optimal performance.

(23) Data Center Optimization Program

The Data Center Optimization Program (DCOP) targets a variety

of electric end uses such as facility site infrastructure loads (cooling, fans, pumps, lighting, and

uninterruptible power supplies), network, storage, and servers. The program aims to deliver

persistent savings through its detailed engineering audit, which will benchmark the data center,

give the customer instruction and a systems manual to maintain efficient systems.

c) Partnerships

SCE’s energy efficiency partnership program portfolio consists of

partnerships with local and state government organizations (governments) as well as with

institutional customers (institutions). SCE acknowledges that these governments and institutions

78

provide a number of key functions relating to demand side management, conservation, and

alternative energy and embraces the vision of the CEESP to strengthen and capitalize upon the

capacity of these governments and institutions to leverage their unique functions in codes and

standards enforcement, community outreach and leadership by example in support of

California’s aggressive energy savings goals.

(1) Local Governmental Partnerships

SCE intends on partnering with cities, counties, and other local

government organizations that have a vision for sustainability and a desire to provide leadership

to their communities. Partners will lead by example. They will take action in their own facilities

and provide opportunities for constituents to take action in their homes and businesses.

SCE’s 2009-2011 partnership program will be enhanced to reward

and recognize cities for participation in energy savings activities. The new model, Energy

Leader Partnership, (ELP) improves SCE’s current local government partnering strategy by

establishing a disciplined, concentrated approach to create consistency in program offerings and

improves clarity and ease of participation in community partnership programs. The allocation of

program budgets will be based on each partnership’s future commitments to achieve energy

efficiency and demand response in municipal facilities and within their communities. All

partnerships are resource programs and will include emphasis on coordination with demand

response and low income programs, and on green community concepts supported by the

Commission and statewide IOUs.

The incentive structure is tiered and offers higher levels of support

as higher levels of energy savings are achieved. 2009-2011 local government partnerships

currently include:

• Community Energy Partnerships

• Beaumont Energy Leader

• Desert Cities Energy Leader

79

• Eastern Sierra Energy Leader

• Kern County Energy Leader

• Long Beach Energy Leader

• Orange County Energy Leader

• Ridgecrest Energy Leader

• Santa Ana Energy Leader

• Simi Valley Energy Leader

• Ventura County Energy Leader

• South County Energy Leader

• South Gate Energy Leader

• San Gabriel Valley Energy Leader

• San Joaquin Valley Energy Leader

• Palm Desert Partnership

(2) Institutional Partnerships

SCE’s Institutional Partnerships are designed to create dynamic

and collaborative working relationships between investor owned utilities, state or local

governments and agencies or educational institutions. The objective is to reduce energy usage

through facility and equipment improvements, sharing best practices, and providing education

and training to key personnel. SCE proposes seven institutional partnerships for 2009-2011, and

proposes a mechanism for initiating new partnerships mid-cycle, as needed. 2009-2011

institutional partnerships include:

• California Community Colleges

• California Department of Corrections and Rehabilitation

• SCE-SCG County of Los Angeles Partnership

• County of Riverside Partnership

• UC/CSU/IOU Partnership

80

• County of San Bernardino Partnership

• State of California/IOU Partnership

d) Crosscutting Programs

SCE’s crosscutting programs cut across residential, nonresidential and/or

partnerships portfolios, delivering benefits to multiple sectors of customers, and directly guided

by the CEESP’s approach to crosscutting.

(1) Emerging Technologies Program

The Statewide Emerging Technologies (ET) program delivers

information, insights, analytical tools, and resources to enable acceleration and expansion of the

commercialization of innovative technologies and support promotion of innovative applications

of existing technologies. The activities contribute to energy savings statewide through an array

of mechanisms targeted at new cost-effective, high performance energy efficient technologies.

(2) Codes & Standards Program

The Statewide Codes & Standards (C&S) Program directs

initiatives to enhance building and appliance standards to codify cost-effective, reliable,

persistent, and verifiable demand-side measures in support of maximizing portfolio energy

savings and demand reduction. The program supports their implementation through activities

designed to maximize compliance.

(3) Sustainable Communities Program

The Sustainable Communities Program (CSP) encourages the

inclusion of sustainable elements and energy efficient features in campus projects, mixed-use

complexes, residential new construction, multi-family and transit-oriented developments, and

other projects whose scope exceeds traditional SCE programs. The program provides financial

incentives and customized technical assistance to encourage energy-efficient building design and

81

construction. SCP will also pilot technologies, design assistance, and economic strategies

toward ZNE.

(4) Workforce Education & Training (WE&T)

The Workforce Education & Training (WE&T) Program is an

education and information program that targets a wide range of customers, and is designed to

train and develop students and various members of the workforce through classroom training,

outreach, school curriculum, showcases, energy centers, and other methods. WE&T’s programs

include the EARTH Education and Training Program, WE&T Synergies, and WE&T Strategic

Planning.

(5) Marketing, Education & Outreach

(a) Statewide Marketing, Education & Outreach

Until the Commission completes their investigation into the

CEESP activities and renders a final decision regarding the long term plan for Statewide

ME&O,34 this program will continue implementing integrated statewide marketing and outreach

activities under the ‘umbrella’ of Flex Your Power (FYP), while working closely with the IOUs

and the Commission to integrate their campaign efforts to support the vision of the CEESP

through integration with energy efficiency, demand response, CSI, SmartConnect™, and low

income energy efficiency.

34 D.07-10-032 dated October 18, 2007, p. 67.

82

e) Solicitations

(1) Third Party Solicitations

SCE’s Third Party Solicitation Program is designed to enable

successful third party program administration, program implementation, and realization of cost

effective energy savings. In preparation for the 2009-2011 filing, five flights of solicitations

were held between November 2007 and May 2008; these will be supplemented by additional

solicitations and related support services, including development and improvement of tools used

to support the third party programs, throughout the 2009-2011 cycle.

2. Third Party Contracts

a) Process, Criteria, and Statewide Consistency

SCE’s 2009-2011 third party programs include continuing programs from

the 2006-2008 cycle and newly selected programs from the solicitations held between November

2007 and June 2008. Consistent with Commission direction to solicit new ideas via a

competitive process, the third party competitive solicitation process is a comprehensive and

multi-faceted approach that draws from the skill, experience, and creativity of the energy

efficiency community with the goal of enhancing current program design and uncovering new

approaches to capturing cost effective energy savings. Additionally, the program solicitations

promote comprehensive energy efficiency approaches and will focus on new ways to integrate

demand-side management offerings.

SCE offers two unique categories of solicitations for 2009-2011: general

and targeted. General solicitations allow bidders to design and submit their own proposals to

help SCE fill portfolio gaps and develop newer methods or program designs. Targeted

solicitations support identified markets and program needs. SCE offered local targeted

solicitations for identified market sector needs, and also participated in a statewide targeted

83

solicitation. This approach is consistent with Commission direction to conduct a competitive bid

“for the purpose of soliciting new ideas and proposals for improved portfolio performance”35

within this process are two types of approaches: state and local.

Solicitation Process

The Solicitations were staggered in “flights,” or groups of solicitations

that were released over time, allowing bidders greater opportunity and more time to respond to

multiple RFPs and IOUs the opportunity to evaluate and select proposals. The flight schedules

were coordinated and adopted by all IOUs, with the longest two-stage solicitations in the earlier

flights, and the shorter solicitations positioned in the later flights. Flight #1 included the

Statewide General and IDEEA Solicitations, Flights #2-4 included Statewide and Local Targeted

RFPs, SCE did not participate in Flight #3 and these solicitations were moved to Flight #5, so

SCE could develop its RFPs. SCE launched Flight #5 in late April 2008, which was primarily

designed to support vertical market segments of the nonresidential portfolio through a local

targeted solicitation. Although additional solicitations in support of 2009-2011 programs that

will launch January 2009 are not anticipated, SCE proposes to maintain the flexibility to conduct

additional solicitations, in the event additional energy savings are needed to support portfolio

goals.

Proposal Evaluation

The proposal review process involved an extensive evaluation of each

proposal based on scoring criteria jointly developed by the IOUs. To ensure a thorough, fair and

consistent evaluation of all aspects of the proposals, SCE established the following evaluation

process:

• Overall Program Scoring

• Technical Review

• Supplier Diversity

35 D. 05-01-055, Section 5.2.1, p. 94

84

• Portfolio Review

• Peer Review Group (PRG) Review

Criteria

The IOUs developed joint evaluation criteria for both the Targeted and

General Solicitations. The sets of criteria slightly differed and are set forth in detail in Exhibit

SCE-1.

Statewide Consistency

For 2009-2011, the IOUs streamlined the solicitation to solicit and accept

bids on a statewide level. This process was designed to provide bidders with an opportunity to

respond to one statewide RFP for each statewide program, thereby improving the quality of the

proposals, streamlining the utilities’ process, and simplifying the bidders’ process. The IOUs

developed common outreach, solicitation process, flight schedule, and scoring process and

criteria, and developed a statewide online portal, (PEPMA), for bidders, IOUs and the PRG. The

submission, review, and scoring of proposals were handled individually be each IOU. To ensure

selected programs offer a consistent statewide program and provide a common experience to the

customer, the IOUs have also formed statewide teams to manage the consistency of common

programs across the state.

Each statewide solicitation was coordinated by a lead IOU that was

responsible to coordinate the development and release of the RFP in close coordination with the

other IOUs. Bidders had the option to bid into any number of service territories, and were not

required to respond with a bid proposing a program that covers all four IOU territories.

b) Third-Party Programs Continued From 2006-2008

SCE proposes to continue offering third party programs and third party

contracts that were successfully implemented in the 2006-2008 program cycle. In order to

facilitate the identification of a successful third party programs, the IOUs agreed upon a success

85

criteria to be used to determine whether a program and/or implementer was successful and

should be continued into 2009-2011. The program evaluation criteria included:

• Program Goals and Achievements

• Program Costs

• Cost-effectiveness

• Actual Installed Measure Mix

• Customer Satisfaction/Program Quality

• Coordination/Vendor Relationship

• Regulatory and Reporting Compliance/Audits

• Energy Savings Claims

c) Efforts to Expand Third-Party Programs And Results of Competitive

Bid Selection Process

SCE worked with the IOUs to expand the call for abstracts/RFPs. The

IOUs shared outreach techniques including mailing lists with other IOUs, trade associates,

service lists, etc. to inform a greater number of potential bidders about upcoming program

solicitations. As result, SCE sent various calls for abstracts to over 2,700 potential bidders.

SCE’s efforts to expand third party programs included: (1) expanding targets RFPs to

incorporate programs designs from other IOUs 2006-2008 energy efficiency portfolio; (2)

expanding SCE’s 2006-2008 IDEEA program to statewide programs in 2009-2011, and (3)

developing the IDEEA 365 as a non-traditional method to expand SCE’s open solicitation

offering and to provide additional outreach during 2009-2011.

SCE successful 2009-2011 program solicitation process included several

new and promising program offerings, as shown in Exhibit SCE-2, Table 3.4. These selected

programs resulted in a successful statewide general solicitation, local innovative solicitation,

statewide targeted solicitation, and local targeted solicitation. SCE outreached to thousands of

86

potential bidders, received several hundred abstracted and proposals, and selected more than 28

program implementers.

d) Review with Peer Review Group (PRG)

In Decision 07-10-032, the Commission continued the role of the local

PRGs for 2009-2011. Specifically, for SCE, the Commission continued the role of the combined

SCE, SCG and PRG. To support the Commission’s vision for the PRG, SCE engaged its local

PRG during the portfolio planning process. SCE appreciates the insights and contributions of its

PRG during this long involved process.

e) Implementer Contracts

SCE has gained valuable experience over the past several years in

developing and administering third-party contracts. Based on this experienced, SCE proposes to

create third-party contracts that: (1) promote a “pay for performance” approach while

minimizing reliance on “time and material” contracting; (2) allow for immediate execution of

third-party contracts upon Commission approval of the 2009-2011 program portfolio; (3)

emphasize greater comprehensive approaches (e.g., multiple end uses); (4) promote DSM

integration and coordination, and (5) allow for increased funding for successful installation of

energy efficiency projects while providing for program closure for non-performing programs.

Reliance on these sound contracting approaches will allow successful programs to continue to

play an integral role in achieving SCE’s 2009-2011 energy efficiency goals.

3. Partnerships

a) Proposed Partnership And Statewide Consistency

The major change in SCE’s 2009-2011 partnership portfolio strategy has

been the selection and development of Local Government Partnership (LGP) programs. SCE’s

new Energy Leader (EL) model improves the current local government partnering strategy by

87

establishing a disciplined, concentrated approach for local agencies to achieve energy savings.

Partners will demonstrate leadership and environmental stewardship by taking action in their

own facilities as well as by engaging local business and residential customers to participate in

DSM programs.

To further support Local Governments and to help them mobilize their

community and set community-wide goals and strategies, SCE partnership offering will support

and reward local governments in the establishment of community-wide goals and strategies. The

Program will act as an outreach portal for energy efficiency services and programs, and promote

future community concepts.

Partners will enter the program at varying levels depending on past

participation in energy efficiency programs. Available program budgets will be based on future

commitments to achieve energy efficiency in municipal facilities and in the community.

Program offerings will include technical support, marketing, outreach, education efforts and

financial incentives for energy efficiency projects and demonstration projects.

b) Statewide Consistency

The Commission hosted workshops on January 29 and 31, 2008, to jointly

solicit existing local government partner input on partnerships moving forward into the new

cycle. The IOUs drafted 2009-2011 partnership selection criteria to reflect this input and

improve statewide consistency. With input from members of the PRG, the IOUs also jointly

developed a Call for Abstracts (CFA), a CFA schedule, and a pre-announcement notice.

Additionally, the IOUs worked together to develop a similar evaluation

process and document to capture the evaluators’ scores. SCE scored each proposal independent

of the other IOUs.

c) Government and Institutional Opportunities

SCE proposes to reserve a budget for these partnerships should they

materialize during the course of the three-year program cycle. In order to create a new

88

partnership, the government agency would develop an abstract similar to those used in the initial

program planning for the 2009-2011 program cycle. If the proposed partnership appears viable

and there are sufficient funds remaining, SCE will work with the partner to create a formal

partnership. If the partnership is statewide, the development will be coordinated with the

participating IOUs to ensure consistency in program development, program implementation plan,

incentive rates, management, and reporting.

d) Criteria And Process

D.07-10-032 gave the IOUs Peer Review Group (PRG) oversight over the

solicitation of local government partnerships. The development of selection criteria for the

2009-2011 Local Government Partnerships (LGP) was a collaborative process that included the

Local Government themselves, the Statewide IOU team, and the PRG. In January 2008, the

Commission held workshops with local governments to discuss strategic planning and potential

criteria 2009-2011 partnerships. Local governments suggested several criteria for that would

leverage the uniqueness of local governments to create change.

The IOUs used these suggestions to develop a draft document for review

by the PRG. The final list of criteria included:

• Cost Efficiency • Skill and Experience • Demonstrated Commitment • Municipal Facility Buildings • Feasibility • Integrated Approach • Comprehensiveness • Innovation and Reflects Strategic Plan

A Call for Abstracts (CFA) was drafted by the IOUs, reviewed by the

PRG, and issued on February 21, 2008 and required interested partnerships to submit their

abstracts by March 10, 2008.

Abstract evaluations consisted of two parts – the responsiveness of the

Abstract and its scoring. The IOUs first evaluated whether the Abstract met the threshold

89

requirements on a pass/fail basis. Only Abstracts that received a “pass” were further scored

according to the jointly agreed to evaluation activity.

Table IV-14 Abstract Evaluation Criteria

Item Criteria Weights

Part 1: Threshold Requirement

A. Abstract Responsiveness Pass/Fail

Part 2: Proposal Scoring

A. Cost Efficiency 20%

B. Skill and Experience 10%

C. Demonstrated Commitment 10%

D. Municipal Facilities 15%

E. Feasibility 10%

F. Integrated Approach 10%

G. Comprehensiveness 10%

H. Innovation and Reflects Strategic Planning Process

15%

e) Peer Review Group Review

Scores for each partnership were recorded on the summary sheet

submitted to PRG members on March 19, 2008 along with the actual abstract. PRG provided

formal feedback via a memorandum to government agency staff and IOU staff re: PRG vision

for and guidance on LGP programs. The purpose of the memorandum was to “cohesively shift

the current trajectory of LGP programs to programs that embody the spirit of the new paradigm

of the CEESP. SCE continued to work with the PRG and the Partners to improve and align the

program plans.

90

f) PRG Recommendations and Responses

The IOUs incorporated some of the PRG’s suggestions into the Selection

Criteria. Those included:

• The definition of a Quasi-Government Partnership;

• The addition of the “innovation and reflects strategic planning”

criteria.”

Some of the PRG suggestions were incorporated into the CFA document

and process:

• Existing partners would need to comply with CFA Criteria;

• Edits to CFA language and format; and

• All Local Government abstracts would be sent to the PRG for review.

g) Policy Manual

The IOUs and the PRG developed criteria that could be supported by the

existing energy efficiency policies with two exceptions – “integration” and “innovation.”

Current policy states partnership arrangements “should in no way diminish or dilute the

responsibility and accountability of Program Administrators to meet the Commission-adopted

savings goals.” Therefore, potential Partners were asked to identify those innovative and

strategic plan elements separately along with the applicable budgets.

h) Palm Desert Partnership

The Palm Desert Partnership program was filed in 2006 as a five-year

pilot demonstration program with a goal of reducing energy consumption and peak demand by

30%. The Commission approved the project on December 14, 2006, and provided that the

additional three years were to be included with the 2009-2011 energy efficiency program cycle

91

filing.36 Heavy emphasis will also continue on the promotion of SCE’s existing core programs in

addition to those available on this program. Results from operations in year one of this five-year

project, showed that participation in energy efficiency increased by more than a factor of four

since the inception of the partnership. The project will seek to develop an energy management

system for residential and small commercial customers and will pioneer methods to both affect

and measure energy savings associated with behavioral changes. Additional ordinance changes

will be considered to build upon the successes of the city-wide energy ordinance launched in

January 2007. A new method of financing energy efficiency projects is under development for

launch in 2009.

4. Market Transformation Strategies

Key market transformation strategies are summarized in Section III A.5.

Portfolios are designed to overcome barriers to market transformation and to advance

integration. Additional details are also discussed in the Program Implementation Plans in

Exhibits SCE-3 and SCE-4.

5. Proposals for On-Bill Financing

a) Small Business and Institutional Customers

SCE proposes to build on the success of the On-Bill Financing (OBF)

Pilot conducted during the 2006-2008 program cycle. In that cycle, OBF was offered to

qualified convenience store and small grocery store customers electing to participate in a direct

install energy efficiency program.

OBF is a standardized non resource offering designed to be leveraged by

multiple resource programs, rather than a targeted resource program as in 2006-2008. SCE

proposes to offer an OBF financing option for the nonresidential retrofit energy efficiency

36 D.06-12-013, dated December 14, 2006, OP# 1, p. 27.

92

programs under Business Incentive Elements, as well as for many of the market segment

programs implemented by third party contractors.

The proposed 2009-2011 OBF program is a significant expansion of the

2006-2008 pilot, with a proposed budget of approximately $26 million. All loans will be funded

through energy efficiency funding, as set out in this Application. The operation of this account is

described more fully in Exhibit SCE-1, Chapter VII, Revenue Requirements and Cost Recovery.

b) Proposal for On-Bill Financing for Residential Customers

SCE recognizes that an OBF option for residential customers has the

potential to significantly increase participation in both energy efficiency and the California Solar

Initiative (CSI). SCE proposes exploring the possibility of offering OBF as a financing option to

all qualified residential customers choosing to participate in both a residential energy efficiency

retrofit program and the CSI. However, there are several hurdles facing OBF loans for

residential customers, which are set forth in Exhibit SCE-1.

6. Proposed Program Delivery And Market Outreach

a) Marketing and Outreach Programs

Accomplishing the long-term goal of integrating demand side

management programs, maximizing energy savings and changing consumer behavior requires a

multi-layered marketing effort across all stakeholders with responsibility for energy efficiency in

all sectors. An effective marketing effort will move consumers through a continuum from

awareness, to attitude change, to action. The objective is to maximize energy savings and enable

long-term behavior using multiple layers of integrated approaches to effectively reach customers.

Moving customers from awareness to action will require both integrated and targeted marketing

campaigns. Targeted will be funded exclusively by the program being promoted, while

integrated will be funded by multiple programs.

93

Below is a summary of SCE’s approved, proposed, or anticipated

marketing budgets (budgets exclude labor):

Table IV-15 Summary of Marketing Budget

PROGRAM 2009 to 2011

MARKETING BUDGET (non-labor)

AMI (SmartConnect™) $37,058,929 California Solar Initiative (CSI)37 $1,500,000 Demand Response $21,711,450 Energy Efficiency $40,043,842 Low Income Energy Efficiency $1,425,000

Demand-side management programs will continue to be coordinated and

integrated, as appropriate, to increase energy efficiency participation, to avoid lost opportunities,

and to provide simple and intuitive solutions for customers. Integrated bundled efforts will be

used to maximize delivery and gain more widespread awareness of our offerings. Targeted

marketing efforts will also continue in order to meet specific program goals.

Marketing, education and outreach efforts will:

• Integrate DSM programs to provide holistic solutions

• Leverage SCE’s customer segmentation

• Make it easy for customers to participate

• Create interactive “self-service” tools to enable informed choices by

customers

• Leverage partnerships to extend reach (i.e., retailers, cities, community

agencies)

• Communicate with customers at the right

• Conduct pilots to test innovative programs and outreach tactics

37 2009-2011 CSI marketing budget is estimated, based on actual 2008 CSI budget allocation.

94

• Leverage SmartConnect™ technology to further educate and inform

customers on the benefits (i.e., lower bills) associated with the

integrated demand side management programs

• Cross-sell to customers as appropriate

b) Discussion of Context and Funding Integration

(1) Demand Response and Advanced Metering Infrastructure

SCE has actively pursued Integrated Demand Side Management

goals, and will evolve our goals even further in 2009 and beyond as a result of SCE’s new

SmartConnect™ (AMI) technologies, equipment, and offerings.

With the implementation of SmartConnect™, SCE will be able to

provide real time information to customers that can help them make more informed decisions

about their energy usage. Programs will be developed that give customers both an incentive to

save energy and help them reduce energy costs with varying levels of participation.

SmartConnect™ will provide the utility with an opportunity to conduct an integrated marketing

campaign that will customers understand their energy usage and its impact on their bills.

(2) California Solar Initiative, Including Commission And CEC

Programs

SCE will continue to promote the California Solar Initiative (CSI)

program to residential and business customers to increase awareness, participation and

application submissions. For cost efficiency and maximum reach, CSI messaging will be

included in ‘bundled’ marketing communications that present customers with the broad array of

SCE’s energy efficiency and demand response solutions. Vertical marketing efforts will be

implemented to drive participation from customers with the highest propensity to respond to the

‘go solar’ call to action.

95

SCE will identify opportunities to educate builders, new home

buyers, trade organizations and other stakeholders about the New Solar Homes Partnership

Program, which will provide incentives to homebuilders that incorporate high levels of energy

efficiency and high performing solar systems when building a new home.

(3) Low-Income Energy Efficiency

SCE will continue to reach out to low-income customers using

direct mail, fact sheets, savings guides, seasonal campaigns, brochures, and sce.com to increase

program enrollment, and will expand EE and LIEE in-home education to leverage information

on Green House Gas and SmartConnect™.

SCE will work to identify program design gaps between energy

efficiency and LIEE and evaluate solutions to ensure that all customers have the opportunity to

accelerate adoption of energy efficiency.

(4) Distributed Generation

SCE will continue to promote the use of cost and energy efficient

distributed generation applications by its customers. In addition, SCE will continue to

administer the Self Generation Incentive Program (SGIP) that provides economic incentives to

customers using clean, renewable, and efficient distributed generation technologies such as fuel

cells and wind turbines. SCE will also work to simplify and streamline the interconnection

process.

7. Proposed Training Programs

The Workforce Education and Training (WE&T) Portfolio is designed to promote

energy efficiency and other demand side offerings through a variety of training and educational

programs across residential and non-residential customer segments. The Portfolio’s overarching

goal is to continue the transformation of California’s business and residential customers to

integrate “energy” efficiency into everyday decisions.

96

As identified in the CEESP, the WE&T Program Portfolio will achieve its goals

through the implementation of five strategies. The strategies will include such things as

partnering with K-12 stakeholders to ensure energy education is provided from kindergarten

through high school, support community college and adult education efforts to offer energy

industry-driven career path training, incorporate energy efficiency training into traditional skilled

trade occupations, and identify appropriate goals and strategies to build California’s energy

efficiency workforce through 2020.

SCE will also initiate a needs assessment study that will be used to guide the

development of new workshops and seminars, determine key technical and non-technical subject

matter, and design effective ways to deliver the educational messages.

Under the guidance of the needs assessment report, the WE&T Program Portfolio

will provide training and workforce development opportunities through:

• Outreach to more participants in its education activities.

• Integration of comprehensive energy efficiency and demand side management

training.

• Increasing collaboration with statewide IOU program groups.

• Partnerships with the CEC and other organizations.

• Interaction with community colleges, trade colleges and the UC/CSU system.

• Leveraging SCE’s process for integrating emerging technology products.

• Training focused on energy regulation code changes.

SCE’s EARTH Educational programs, CLEO, and the MEU will bring their

services to schools, school districts, and communities in areas where low income, minorities and

other disadvantaged community constituents can be reached. The programs’ activities and

services will teach students at an early age (K-12) and residents about energy efficiency practices

whether at school, work, or at home. In addition, SCE will disseminate information on available

training, additional energy efficiency resources and career path training. This approach is set

forth in the CEESP.

97

V.

PROPOSED FUNDING REQUESTS AND FUND-SHIFTING PROPOSALS ARE

REASONABLE

A. Funding Request Is Reasonable

1. Proposed Funding Levels Are Reasonable And Should Be Adopted

SCE’s proposed 2009-2011 energy efficiency program portfolio budget supports

both the achievement of the Commission’s aggressive 2009-2011 energy efficiency goals as well

supports progress towards the realization of the long-term goals and specific strategies and

actions identified in the CEESP. The proposed 2009-2011 budget is an increase from SCE’s

2006-2008 energy efficiency portfolio budget. The proposed increase in funding over previous

program cycles is attributable to several factors including: (1) increased energy efficiency goals

set forth by the Commission; (2) reduced estimates for energy savings and demand reduction

resulting from measurement and evaluation work; (3) increased codes and standards; (4)

increased incentives levels to encourage customers to adopt the latest energy efficiency

technologies; and (5) increased resources needed to support the Commission’s big, bold energy

efficiency strategies38 and the other elements of the proposed CEESP. SCE’s proposed 2009-

2011 energy efficiency budget summary, by program, is presented below in Exhibit SCE-2,

Table 4.1.

2. Certain Costs Not Included In Cost-Effectiveness Calculations Per The

Strategic Plan And Commission Decision

The CEESP includes both near and long term goals for California. To realize the

CEESP goals, California will need support from a vast number of market actors. The IOUs’

38 D.07-10-032, dated October 18, 2007, OP #12, p. 147.

98

energy efficiency activities will play a part in supporting California’s energy efficiency goal

achievement. Many of these long-term IOU investments will not realize near-term (i.e., 2009-

2011) benefits to ratepayers but will be vital in providing energy efficiency solutions in the long-

term to ratepayers. Nevertheless, SCE proposes to include all forecasted costs associated with

supporting the long-term CEESP activities into the cost-effectiveness showing in SCE’s

Application to ensure ratepayers are funding a cost-effective energy efficiency portfolio.

SCE does propose removing any costs associated with long-term investments in

support of the CEESP from the 2009-201 utility energy efficiency incentive mechanism (i.e.,

Performance Earnings Basis Calculation). SCE also proposes a discrete utility earnings

mechanism to encourage and maintain focus on supporting the utilities’ contribution to the

CEESP. This will remove the incentive for IOUs to focus solely on near-term actions to achieve

near-term results.

B. Proposed Interim Bridge Funding May Be Necessary To Avoid Program

Interruption

If the Commission determines that a final decision on this Application will not be issued

before 2009, SCE requests that the Commission issue an interim bridge funding decision in

advance of its final decision authorizing the IOUs 2009-2011 proposed energy efficiency

portfolios and budgets. Pursuant to the May 5, 2008 Assigned Commissioner’s and

Administrative Law Judge’s Ruling Regarding Due Dates for 2009-2011 Energy Efficiency

Portfolio Plans, the due date for the IOUs’ 2009-2011 portfolio applications was extended to

June 23, 2008, resulting in a corresponding delay in the expected final decision from the

Commission. Specifically, that Ruling states “With these changes in due dates, we now

anticipate final decisions occurring in November or December 2008.” A later Ruling was issued

on June 2, 2008 further delaying the filing of IOU 2009-2011 portfolio applications until July 21,

2008, and the final decision possibly into 2009.

99

If a final decision on this Application is not issued by the end of 2008, SCE proposes to

continue successful 2006-2008 programs (i.e., IOU, third-party, and partnerships) into 2009 and

until the Commission issues a final decision on SCE’s 2009-2011 energy efficiency program

application. This will ensure there is no suspension of program delivery. SCE also proposes to

continue to fund planning activities for 2009-2011. However, SCE does not propose to execute

contracts for new 2009-2011 third-party programs and partnerships until the Commission issues

final approval of this Application. SCE will continue to work with potential implementers and

partners during 2008 on preparing 2009-2011 contracts for execution immediately upon

Commission approval of this Application. In addition, in order to ensure a smoother transition

from 2006-2008 programs to 2009-2011 programs and avoid customer confusion, SCE may

make selective changes (e.g., participant eligibility requirements, incentive levels) to any

program extended into the bridge period.

C. Proposed Fund-Shifting And Program Flexibility Proposals Are Reasonable

The fund shifting guidelines proposed in this Application for the 2009-2011 program

cycle (Guidelines) are an extension of the fund shifting guidelines approved for 2006-2008

energy efficiency programs as presented in the 2006-2008 Energy Efficiency Policy Manual with

key modifications.39 In the 2006-2008 program cycle, the Commission recognized and approved

the IOU program administrators’ need for flexibility to maximize energy savings. The

Guidelines will extend this flexibility into the 2009-2011 funding cycle. The Guidelines are

needed to provide the IOU program administrators with flexibility to manage the 2009-2011

portfolio adapt to changing market conditions, and optimize resource potential to meet the hard

line energy savings and demand reduction targets, annually and cumulatively. SCE proposes

selective modifications to the current Guidelines to: (1) change to the current treatment of mid-

cycle portfolio funding augmentation; (2) recognize the elimination of the policy advisory group

39 See Table IV-7, Proposed 2009-2011 Energy Efficiency Fund Shifting Guidelines, dated January 8, 2008, Attachment A, Table 8: Adopted Fund Shifting Rules p. A-2.

100

in 2009-2011; (3) clarify language contained within the 2006-2008 Guidelines for 2009-2011;

(4) clarify language addressing rolling program budget cycle; and (5) propose a process for

2009-2011 for encumbering funds from subsequent budget cycles.

1. Modify Treatment of Mid-cycle Funding Augmentation

In D.07-10-032, the Commission set a policy rule (rule 12, Section IV) not to

allow IOUs to claim energy savings and demand reductions results towards the achievement of

the Commission energy efficiency goals because mid-cycle funding augmentation provides a

“bonus” to utilities without any undue risk bestowed upon them.40 D.07-10-032 also indicates

that “in effect, mid-cycle funding augmentations provide the utilities with additional funding to

accomplish a goal that was set with a lower budget.”41 As a result of this rule, IOUs are now

discouraged from pursing all cost-effective energy efficiency even thought there may be energy

efficiency funds available from prior years. SCE proposes the elimination of the 2006-2008

mid-cycle funding augmentation rule for 2009-2011 as it: (1) creates a disincentive to propose

new programs with augmented funding; (2) punishes, unnecessarily, IOUs when market

conditions change which may require additional funds to incent customers in order to achieve the

Commission energy efficiency goals, and (3) creates a contradiction to the California’s Energy

Action Policy and Commission policy to pursue all cost-effective energy efficiency.

The inability to record results from mid-cycle funding sends the wrong signal to

IOUs to stifle program innovation and creation of promising programs. This is contrary to the

Commission’s desire to promote innovation and test new program designs. Another key fault of

the 2006-2008 mid-cycle funding augmentation rule is it assumes that during the program

implantation cycle the marketplace remains static and acts just as assumed during the planning

process. This is unrealistic. The marketplace is dynamic with many actors and unforeseen

40 D.07-10-032, dated October 18, 2007, OP#7, p. 143. 41 Id., p. 98.

101

influences which can foreclose expected opportunities as well as create new opportunities. The

mid-cycle rule also contradicts California’s Energy Action Plan which calls for the pursuit of all

cost-effective energy efficiency by discouraging IOUs to supplement their program portfolios

with promising new/enhanced programs. Thus, for 2009-2011, SCE proposes to modify the mid-

cycle funding policy rule to allow all utilities to count all installed energy efficiency results

towards the Commission’s aggressive energy savings and demand reduction goals.

2. Recognize The Elimination Of The Policy Advisory Group For 2009-2011

The proposed Guidelines also remove references to the local Program Advisory

Groups (PAGs) as the Commission has eliminated the local PAGs for the 2009-2011 cycle.42

During the 2006-2008 program cycle, the fund shifting guidelines directed the IOUs to seek

input from the local PAG members when proposing a significant shift of funds (e.g., 25% annual

among program categories).43 The proposed 2009-2011 Guidelines propose to replace the local

PAG with the local Peer Review Groups. This will provide the IOUs input from informed and

non-financially conflicted organizations44 on significant fund shifts during the program

implementation cycle.

3. Provide Additional Clarity to Prior Year’s Fund Shifting Guidelines To

Reduce Confusion

The proposed 2009-2011 Guidelines include clarifying language to the 2006-2008

fund shifting guidelines. For example, in proposing to add a new program (outside the

competitive bidding process)45 the IOUs would be required to file an advice letter but a full

Commission resolution would not be mandatory if the Commission deemed the proposal

42 D.07.10-032, dated October 18, 2007, OP# 29, p. 149. 43 D.05-09-043, dated September 22, 2005, p. 148. 44 Organizations that are not financially-linked to the implementation of IOU energy efficiency portfolios. 45 D.05-09-043, dated September 22, 2005, pp. 149,

102

acceptable. Also, the 2006-2008 policy rules provide the IOUs ability to carry funds from a

future funding cycle to a current cycle.46 The 2009-2011 Guidelines propose the following

clarifying language:

“12. Bridge Funding. Programs continuing from the 2009-2011 program cycle into the 2012-2014 cycle may use 2012-2014 funding to keep programs from shutting down prior to the end of the implementation cycle, once the 2012-2014 portfolio has been approved. Additionally, start-up costs for 2012-2014 programs may use 2012-2014 funding once the 2012-2014 portfolio has been approved although the previous implementation cycle has not concluded. Unspent or uncommitted funds from previous program years, or 2009-2011 funds that will not be needed should be used prior to using 2012-2014 funds. Both continuing program funding and start-up cost funding from 2009-2011 or from previous program years, are limited to 15% of the current budget cycle without Commission approval. An Advice Letter is required for funding in excess of this percentage.”

4. Funding Proposal For Rolling Budget Cycle As Set Forth In D.07-10-032

SCE is seeking the flexibility to encumber funds from next program cycle for

continuing programs, not to exceed 20 percent of the current program cycle budget set forth by

2009-2011 fund-shifting guidelines. SCE seeks this additional flexibility in order to keep the

programs from ramping up and down as the old program cycle comes to a close and the new

program cycle starts.

5. Proposal For Encumbering Funds From Subsequent Budget Cycles

The Guidelines provide the ability to carry back from next program budget cycle

15 percent of the current program cycle budget without Commission approval, to potentially

fund 2009-2011 energy efficiency activities to maintain program continuity and, more

importantly, capture potential cost-effective energy savings and demand reduction opportunities

during 2009-2011. Any shift in excess of 15 percent will be brought to the ALJ.

46 Energy Efficiency Policy Manual v.3.1, dated January 8, 2008, Attachment 1, Table 8, p.A-2.

103

VI.

PROPOSED EVALUATION, MEASUREMENT & VERFICATION PLANS AND

BUDGETS

The utilities will set aside eight percent of the total portfolio funding for both utility and

Commission managed EM&V studies, policy support, and strategic planning projects. This

section of the application will present the breakdown of the utilities’ proposed EM&V budget

between utility vs. Commission staff-managed projects, and describe the plans for the utilities’

own energy efficiency process evaluation and market analysis projects.

A. Funding Principles And Overall Funding Request

As directed by the Commission, SCE has added eight percent of the total amount

proposed for program portfolio funding as the preliminary budget for evaluation, measurement

and verification (EM&V) activities, both Commission-managed and utility-managed.

In 2006-2008, 72.5 percent of the EM&V funding was reserved for Commission-

managed studies, policy support, and strategic planning projects, and 27.5 percent of the EM&V

funding was allocated for utility-managed studies. SCE proposes that this allocation be

continued for 2009-2011, unless detailed analysis by the utilities and the Energy Division

supports a different allocation.

The budgets and allocations for EM&V need to be regarded as place holders until the

Energy Division and the utilities analyze the portfolio and determine the appropriate approach.

SCE suggests that eight percent of total proposed program budgets may now be an unnecessarily

large fraction to fund EM&V activities, since proposed program budgets have increased

considerably.

This request is for a three-year budget. As in 2006-2008, unspent funds will be carried

forward from year to year within the period as necessary, and may be carried over into years

after 2011 in order to conduct and complete evaluations of 2009-2011 programs and other 2009-

2011 studies as necessary.

104

The proposed SCE study and activity budgets that comprise this funding request are

described in the following sections and discussed in more depth in the Testimony. The specific

studies and activities and their budget levels provided are SCE’s best estimates at this point in

time for the evaluation and analysis needs over the next three years. Scope of work and therefore

costs of specified studies may change to meet new or different information needs. Budget

flexibility is critical to allow for changing study and analysis priorities and needs. Consequently,

SCE requests that the long-time practice of permitting full flexibility in the specific allocation of

EM&V funding be continued for 2009-2011.

Quarterly and annual reporting on study status and budgets will allow for tracking of

SCE’s EM&V activity. Energy Division staff will also be informed by the utilities’ submission

of draft process evaluation plans to allow for input by Energy Division and its contractors, as

well as continuing coordination with the staff and their evaluation contractors.

B. Proposed SCE Studies And Activities

SCE’s budget estimates for utility-managed EM&V activities are provided in overall

budget allocation tables in Exhibit SCE-2, Table 5.1. Descriptions of various areas included in

the budget estimates are provided in the testimony (Exhibit SCE-1). EM&V activities are

divided into two major categories: program-specific and cross-cutting.

1. Program Specific Analyses

a) Process Evaluations and Evaluability Assessments

Process evaluations review the design and operation of programs to

determine their effectiveness and their efficiency and to provide recommendations for program

improvements. Many of the programs in SCE’s 2009-2011 portfolio are either new programs or

programs that have significant modifications from their previous design. Consequently, SCE

will conduct one or more process evaluations for most of the programs in the portfolio. Process

evaluations will be important for determining whether to continue new programs and pilot

105

programs and for providing information needed to improve the design and operations of these

programs.

Evaluability assessments are a related category of study, with a specific

focus on assuring that programs are collecting the necessary information to conduct effective

impact, market effects, or process evaluations of the program. These are particularly important

for new programs and programs implemented by organizations new to the reporting and

evaluation requirements for Commission-regulated programs.

b) Program-Linked Market Analysis Studies

The budgets for market analyses allow for analyses of particular markets

central to the operation of specific SCE program and program components, such as emerging

technologies, financing, building and industrial process maintenance services and practices, and

structure and practices in the building construction, sale, and rental markets. With the increased

focus on emerging technologies, analyses of the market potential of program candidate

technologies will be particularly important.

c) Early Measurement And Verification/Baseline Activities

A particular focus in 2009-2011 will be quality control and process

improvement. The state has established demanding goals for the energy efficiency programs and

it is vital these programs efficiently deliver the full savings for which they are capable. Early,

small-sample measurement and verification efforts including collection of baseline data are

needed to assure that ex ante energy savings estimates are being achieved. Funding in this area

will cover internal staffing plus engineering contracts to conduct early measurement and

verification and baseline analyses to provide early feedback to program managers.

106

2. SCE Cross-Cutting EM&V Activities

a) Energy Efficiency Forecasting, Forecasting Model, and Annual

Savings Model

Energy efficiency program and portfolio forecasting and cost-

effectiveness analysis will be part of SCE’s market analysis activities. This work builds on the

energy efficiency potential studies that will be managed by Commission staff. It provides SCE

staffing for development of CPUC- and CEC-required energy efficiency forecasts and SCE-

specific analysis of energy efficiency program activity.

b) Market Segment Studies

These studies will sample customers’ attitudes towards energy use, energy

efficiency, conservation, and demand response. They will also collect information regarding

customers’ knowledge of energy efficiency and peak demand reduction options, sources of

information, demographic characteristics, and program participation. The results will be

provided to the utility, partnership, and third party personnel involved in marketing and outreach

activities to assist them in increasing the effectiveness of their messages and message delivery

methods.

c) Basic Data Collection and Analysis: Demographic, Business, and

Weather Data

Market analysis work includes the ongoing collection and maintenance of

base data needed for effective program design, targeting, analysis, and evaluation: demographic,

business classification, and weather data. SCE will contract for tailored demographic data as

well as use packaged demographic data available from SCE’s market research organization.

Business classification data and software will continue to be provided by EM&V funding, since

107

its primary uses are for energy efficiency and demand forecasting, energy efficiency potential

analysis, and program design, targeting, and marketing.

SCE maintains a system of 24 weather stations that provide data used to

estimate energy usage and energy savings of individual customers in multiple programs. These

data are also used in virtually all of the program impact evaluations of SCE programs.

d) Portfolio Analysis

This funding allows both consultant and internal evaluation staff work to

analyze coverage of markets, strategies, end uses, and technologies in SCE’s program portfolio.

It also funds exploration of optimal coordination among programs in delivery, marketing, and

outreach. Its goal is to make recommendations for refining current program coverage and to

provide input for the 2012-2014 program cycle. It will also gather information from other states

and utilities and coordinate with the energy efficiency forecasting/potential work that informs

program design.

e) Program Best Practices Updates

SCE will undertake selective updating of the statewide Best Practices

Database using its Portfolio Analysis work as a primary source of information about new

program reports and practices to be included.

f) Multi-Client Studies

Each year, several opportunities arise for SCE to participate in multi-client

studies dealing with energy efficiency program issues. Costs range from $10,000 to $50,000.

These studies provide a relatively low-cost option for gathering data. Usually they provide data

on a national level that can be used as at least a rough representation for SCE’s service territory.

Often regional breakdowns are available, providing something closer to data representative of

California.

108

These studies cover topics as diverse as Energy Star brand recognition,

customer attitudes and preferences, and program characteristics and funding. The American

Council for an Energy-Efficient Economy usually offers at least one such study each year on a

topic that is highly relevant for California energy efficiency programs.

g) Conference/Organization Support

Support of conferences and conference attendance for national and

regional conferences focused on energy efficiency programs and measurement and evaluation

issues will be part of SCE’s EM&V budget. Utility program management and evaluation staff

members as well as Commission energy efficiency oversight staff need the information and

professional development offered by these conferences to maintain their work at the premier

level that California programs and evaluation work currently attain. Such conferences also

provide access to studies completed by others that provide valuable information for California

program planning.

h) CALMAC Support and Website

The California Measurement Advisory Council (CALMAC) website

makes publicly available electronic copies of all energy efficiency studies completed with

Commission-authorized energy efficiency funding. The website also provides notification and

access to the activities of CALMAC. CALMAC serves as a forum for Commission and utility

measurement and evaluation staff to communicate and work together on evaluation issues.

Funding and staffing support will be provided to enable CALMAC meetings, workshops, and

forums and to maintain and enhance the website.

i) Statewide Saturation Surveys

The utilities are required by Title 20 of the California Code of Regulations

to conduct periodic surveys of their residential, commercial, and industrial customers and to

provide the survey results to the California Energy Commission for demand forecasting

109

purposes. These surveys are also used as primary data sources for energy efficiency potential

analyses. In addition, they are valuable sources of information for program managers to use in

targeting programs to customer segments. Funding is needed for each of the sectoral saturation

surveys during the 2009-2011 period. The estimated funding levels are based on the use of

detailed onsite surveys to gather data for representative samples needed to meet Title 20

requirements.

3. SCE’s EM&V Staffing

Specialized and experienced utility staffing is necessary for utility-administered

EM&V activities and for support of Joint Staff-administered activities. The appropriate activity

budgets include funding for needed contract work and for the following EM&V staff functions.

• Management of SCE studies.

• Conducting analyses internally to support program design, targeting, and

operations.

• Management and/or support of utility-managed statewide market analyses,

including saturation surveys.

• Providing program administrator and implementer input on research design

and draft reports of program impact evaluations managed by Joint Staff. This

includes gathering and conveying to Commission evaluation managers and

their contractors the information needs, issues and concerns of program

managers.

• Providing program tracking data, customer billing data, and other customer

data to evaluation contractors as needed for Commission-managed program

impact evaluations and other Commission EM&V activities.

• Coordination of study coverage and timing with the Commission’s evaluation

contractors in order to avoid unnecessary overlaps in data collection and

analysis, reduce potential customer burden from multiple contacts, and to

110

share data collected that might be helpful to the other group’s evaluation

contractors.

• Work with the Commission’s contractors and utility personnel to support the

contractors’ customer contact, survey, and measurement activities.

• Collection of data needed for operation, effective targeting, and analysis of

programs and for analysis of energy demand and energy savings potential,

including weather data and business classification data.

• Development and analysis of forecasts of energy and demand savings from

energy efficiency programs.

• Gather actionable study results and working with program managers to use

findings to improve programs.

VII.

REVENUE REQUIREMENTS AND COST RECOVERY

A. Overview

SCE is requesting an increase in its 2009-2011 energy efficiency funding levels in this

Application. Currently, SCE is authorized to recover costs associated with: (1) legislatively

mandated energy efficiency programs PGC; and (2) Commission authorized procurement-related

energy efficiency programs. As discussed in more detail later in Exhibit SCE-1, Chapter VII,

these two categories of energy efficiency funding (i.e., PGE and procurement-related) have

separate ratemaking treatment. Table VII-16, shows the requested increase in energy efficiency

program costs during the 2009-2011 period from the currently authorized funding amounts for

the 2006-2008 period.

111

Table VII-16 Requested Energy Efficiency Authorized Program Costs Increase

($000) 2009-2011 2006-2008 Increase

PGC Energy Efficiency 1/ 294,943 294,943 TBDProcurement Energy Efficiency 1,048,736 433,688 615,048 Est. Unspent/Uncommitted Funds 2/ (62,200) - (62,200) Total 1,281,479 728,631 552,848 D.05-09-043, D.05-11-011

Franchise Fees and Uncollectibles 6,251 D.06-05-016Total Increase Reflected In Rate Levels over 3-year period 559,099

1/ Will increase pursuant to PU Code Section 399.8. To the extent the PGC EE funding increases the Procurement EE funding will decrease equal and opposite so that the total EE funding is $1.344 billion over the 2009 - 2011 period.

2/ See Table 6.2 in Exhibit 2. This amount will be updated at the end of 2008 with actual unspent/uncommitted funds.

Current Authority

As set forth in Exhibit SCE-2, and as shown in Table 6.2, SCE has included as a source

of funding for the 2009 through 2011 energy efficiency programs the estimated unencumbered

funds from pre-2009 energy efficiency cycles at the end of 2008. SCE is currently estimating the

unencumbered funds recorded in the energy efficiency balancing accounts on December 31,

2008 to be $62.2 million. SCE will update this amount at the end of the year once the actual

unencumbered amount is known. In addition, SCE is not requesting to change the level of its

PGC energy efficiency funding. Consistent with the provisions of Public Utilities (PU) Code §

399.8 and Resolution E-3792,47 SCE will continue to submit an annual advice letter to the

Commission to escalate this funding level.

Finally, as discussed in more detail below, SCE is requesting to establish the On-Bill

Financing Loan Balancing Account (OBFLBA) to record differences between the On-Bill

Financing loan funding included as part of the procurement energy efficiency program funding

47 Resolution E-3792, OP# 7.

112

requested in this proceeding, the amount of actual loans provided to participating customers, and

their loan repayments.

B. PGC Energy Efficiency Ratemaking

SCE proposes no change to the currently-approved PGC energy efficiency ratemaking.

SCE’s current ratemaking associated with PGC energy efficiency includes: (1) the recovery of

the authorized PGC Energy Efficiency revenue requirement as set forth in PU Code § 399.8

through the operation of the Public Purpose Programs Adjustment Mechanism (PPPAM); and (2)

tracking the difference between the authorized PGC Energy Efficiency revenue requirement with

actually incurred PGC Energy Efficiency expenses in the Energy Efficiency Programs

Adjustment Mechanism (EEPAM) established in D.97-12-103. Unspent funds are refunded to

customers upon approval by the Commission.

On a monthly basis, SCE records its actual PGC energy efficiency program expenses in

the EEPAM. From this amount, SCE deducts one twelfth of the authorized PGC energy

efficiency revenues to determine the monthly over- or under-collection recorded in the

EEPAM.48 Effective January 1, 2002, Public Utilities (PU) Code § 399.8 extended funding for

the PGC energy efficiency program through January 1, 2012,49 and set SCE’s 2002 PGC energy

efficiency funding level at $90 million. PU Code § 399.8 also required utilities to annually

adjust the PGC target funding amounts at a rate equal to the lesser of the annual growth in

electric commodity sales or the gross domestic product deflator (GDP).

The Commission further directed the utilities in Resolution E-3792 to file an annual

Advice letter by March 31st of each year beginning in 2003 to determine the annual adjusted

funding amounts set forth in PU Code § 399.8. Advice Letter #2229-E established the Public

48 Due to the one-way nature of the EEPAM, any under-collections (i.e., excess expenditures) existing at the end of the authorized program cycle will not be eligible for recovery from customers.

49 Public Utilities (PU) Code § 381, effective September 24, 1996 required the major electric utilities to establish a nonbypassable Public Goods Charge (PGC) rate component in order to fund certain public interest programs including SCE’s energy efficiency (EE) programs through the year 2001.

113

Goods funding for 2008 to be $99.293 million, by applying SCE’s annual sales increase of 0.9%

to the 2007 Public Goods funding level.

SCE will file an advice letter by March 31, 2009 to establish the 2009 authorized energy

efficiency revenue by escalating the 2008 authorized level of $99.293 million by the lower of

either the GDP or SCE’s annual sales change. Interest accrues monthly to the EEPAM by

applying the three-month commercial paper rate to the average balance in the account.

C. Procurement Energy Efficiency Ratemaking

SCE’s current ratemaking associated with procurement energy efficiency includes: (1)

the recovery of the residentially determined50 procurement energy efficiency revenue

requirement authorized in D.05-09-043 and D.05-11-011 through the operation of the PPPAM;

and (2) tracking the difference between the authorized procurement energy efficiency revenue

requirement with actually incurred procurement energy efficiency expenses in the Procurement

Energy Efficiency Balancing Account (PEEBA) established in D.03-12-062.

On a monthly basis, SCE records its actual procurement-related energy efficiency

program expenses in the PEEBA. From this amount, SCE deducts one twelfth of the authorized

procurement-related energy efficiency revenues to determine the monthly over- or under-

collection recorded in the PEEBA.51 Interest accrues monthly to the PEEBA by applying the

three-month commercial paper rate to the average balance in the account. Unspent funds are

refunded to the customers upon approval by the Commission.

Table VII-17 below illustrates how SCE will determine the authorized procurement-

related energy efficiency program funding each year.

50 As described in Preliminary Statement FF, PPPAM, the annual procurement energy efficiency revenue requirement is determined residually by subtracting the authorized PGC Energy Efficiency revenue requirement from the total annual authorized energy efficiency funding levels. See also Table VII-18.

51 Due to the one-way nature of the PEEBA, any under-collections (i.e., excess expenditures) existing at the end of the authorized program cycle will not be eligible for recovery from customers.

114

Table VII-17 Procurement Energy Efficiency Authorized Program Funding (Illustrative

(000)) 2009 2010 2011 Total

1. Total Authorized Energy Efficiency Funding 1/ 326,584 461,554 493,341 1,281,479

2. Less: PGC EE 2/ 98,314 98,314 98,314 294,943

3. Total Procurement EE Funding (Line 1 - Line 2) 228,270 363,240 395,027 986,536

1/ As adopted in this proceeding2/ To be determined annually pursuant to PU Code 399.8 and Resolution E-3792. Therefore the authorized procurement EE funding will be determined residually.

D. On-Bill Financing (OBF) Balancing Account

In compliance with D.07-10-032, SCE will continue the 2006-2008 OBF Pilot program

as a part of the 2009-2011 procurement energy efficiency program. Advice Letter 2066-E,

established the 2006-2008 pilot program, effective December 30, 2006. SCE established the

OBF loan program initially by funding the OBF loans from SCE’s working cash. SCE currently

records the OBF Pilot Program expenses in the PEEBA.

As discussed in Exhibit SCE-1, Chapter IV, the Commission in D.07-10-03252 requires

SCE to continue to expand the OBF pilot program, increasing the customer base to include

institutional customers. In order to continue the expansion of this program, SCE proposes to

create a new interest bearing balancing account to “upfront” fund the OBF loans, tracking the

OBF authorized funding revenue (i.e., requested in this proceeding) for the loans, actual loan

dispersements and actual OBF loan repayments. SCE has included $20 million in energy

efficiency funding requested in this proceeding over the 2009 through 2011 period to fund the

loan portion of the program. SCE is requesting to begin to recover program funds through the

Public Purpose Program Charge for use as the principal to fund loans to participating customers.

The OBF Balancing Account will track only OBF loans and the repayments on all OBF loans.

52 D.07-10-032, Ordering Paragraph 13.

115

All other program expenses such as incentives, administrative expenses, and loan defaults will

continue to be recorded in the Procurement Energy Efficiency Balancing Account. Upon

approval to establish the OBF Balancing Account, SCE proposes to transfer the remaining loan

balances from the 2006-2008 OBF pilot program from the PEEBA to the OBF Balancing

Account.

E. Rate Recovery Of Energy Efficiency Program Costs

SCE recovers its currently authorized PGC energy efficiency and procurement energy

efficiency costs through its existing non-bypassable Public Purpose Programs Charge (PPPC),

which applies to all of SCE’s retail customers. Upon receiving a final decision on this

Application’s funding request, SCE will increase its annual authorized energy efficiency revenue

requirement by the amount approved by the Commission. As discussed above, assuming the

Commission adopts SCE’s energy efficiency funding request as filed, SCE’s energy efficiency

revenue requirement will increase by $552.8 million over the three year period (i.e., 2009-2011

to reflect energy efficiency revenue requirement of $1.281 billion.53

In order to reduce the number of rate changes, the Commission has established the annual

Energy Resource Recovery Account (ERRA) Forecast proceeding as the proper place to

consolidate all Commission-authorized revenue requirement changes into one rate level change.

Therefore, SCE proposes to include the 2009 PGC energy efficiency funding level submitted by

advice filing in March 2009 and procurement-related energy efficiency revenue requirement

approved in this proceeding in PPPC rate levels on or after January 1, 2009 as part of its 2009

ERRA Forecast proceeding revenue requirement and rate consolidation. This rate consolidation

will include the true-up of any undercollection that may accrue in the PPPAM due to the time lag

between implementing a revised procurement-related energy efficiency revenue requirement and

actually reflecting the revised revenue requirement in rate levels.

53 Subject to a year-end adjustment for any remaining unspent/uncommitted funds from pre-2009 funding cycle.

116

F. Rate And Bill Impact Analysis

In the Assigned Commissioner’s and Administrative Law Judge’s Ruling Regarding

2009-2011 Energy Efficiency Program Applications,54 the Commission directed SCE to provide

estimates of the net rate impacts and bill impacts associated with the proposed portfolio of

programs designed to meet the Commission-adopted energy savings goals. The methodology

should be consistent across utilities. The Commission also directed SCE to provide, separately,

any available unspent, uncommitted funds from previous cycles that will be included in the

budget. The aggregate increase resulting from the proposed increase to the Procurement Energy

Efficiency revenue requirement is 1.6% over rates in effect today.

G. Revenue Requirements and Cost Recovery

As detailed in Chapter V of this testimony, SCE requests that any Commission authorized

interim bridge funding will allow SCE to continue to record the currently authorized 2008

revenues in 2009 until a final Commission decision is issued for this Application. SCE further

requests that the final Commission decision authorizing 2009-2011 revenue requirement is made

effective January 1, 2009.

VIII.

ORGANIZATION OF SCE'S TESTIMONY

The testimony in support of this Application discusses SCE’s proposed Energy

Efficiency portfolio for 2009-2011. The testimony also includes SCE’s proposed cost recovery

mechanism for the costs estimated for the proposed program implementation for the same period.

The testimony is comprised of what has been marked as Exhibit SCE-1, which is

described below, Exhibit SCE-2, which contains the compliance tables and charts, Exhibit SCE-

3 and SCE-4 which describes the specific individual Program Implementation Plans (PIP),

54 Assigned Commissioner’s and Administrative Law Judge’s Ruling R.06-04-010 Regarding 2009 to 2011 Energy Efficiency Program Applications dated February 29, 2008, Attachment A, p. 6.

117

Exhibit SCE-5 the DSM Integration and Co-Ordination, Exhibit SCE-6, the strategic plan- PIP

Crosswalk, Exhibit SCE-7 the 2009-2011 energy efficiency AB32 impact, and Exhibit SCE-8

Work papers for Proposed Scenario.

Testimony in Support of Southern California Edison Company’s Application for

Approval of its 2009-2011 Energy Efficiency Program Plans and Public Goods Charge and

Procurement Funding Requests:

Chapter I: Introduction and Executive Summary

Chapter II: Proposed Energy Efficiency Policies and Rules Changes For 2009-2011

Programs

Chapter III: SCE’s Portfolio Reflects State Energy Policies and The Strategic Plan

Chapter IV: SCE’s Proposed Energy Efficiency Portfolio

Chapter V: Proposed Funding Requests and Fund-Shifting Proposals are Reasonable

Chapter VI: Proposed Evaluation Management and Verification Plans and Budgets

Chapter VII: Revenue Requirements and Cost Recovery

Appendix A: Witness Qualifications

Appendix B: Abbreviations and Acronyms

IX.

STATUTORY AND PROCEDURAL REQUIREMENTS

A. Statutory and Procedural Authority

This Application is made pursuant to the Commission’s Rules of Practice and

Procedures, and the California Public Utilities Code.

Rule 2.1 requires that all applications: (1) clearly and concisely state authority or relief

sought; (2) cite the statutory or other authority under which that relief is sought; and (3) be

verified by the applicant. Rule 2.1 sets forth further requirements that are addressed separately

below. The relief being sought is summarized in Sections I (Introduction and Executive

Summary) and X (Conclusion), and is further described in the testimony accompanying this

118

Application. The statutory and other authority under which this relief is being sought include

California Public Utilities Code Sections 451, 454, 454.3, 491, 701, 728, 729, Article 2 and Rule

3.2 of the Commission’s Rules of Practice and Procedure, and prior decisions, orders, and

resolutions of this Commission. SCE’s Application has been verified by an SCE officer as

provided in Rules 1.11 and 2.1.

B. Rule 2.1

Rule 2.1 requires that applications shall state “the proposed category for the proceeding,

the need for hearings, the issues to be considered, and a proposed schedule.” These requirements

are discussed below.

1. Proposed Categorization

SCE proposes to characterize this proceeding as “ratesetting” as defined in the

Commission’s Rules of Practice and Procedure, Rule 1.3(e) and Public Utilities Code

§1701.1 (c)(3).

2. Need for Hearings and Proposed Schedule for Resolution of Issues

SCE’s proposed schedule assumes that there may be evidentiary hearings

regarding SCE’s program portfolio. SCE proposes the following schedule, if hearings are

scheduled:

119

SCE files Application July 21, 2008 Daily Calendar Notice Appears July 21,2008 Protests Due August 8, 2008 Reply to Protests August 12, 2008 Prehearing Conference August 14, 2008 DRA and Intervenors File Opening Testimony

September 2, 2008

Rebuttal Testimony Due September 8, 2008 Hearings September 9-11, 2008 Concurrent Opening Briefs Due October 3, 2008 Concurrent Reply Briefs Due October 9, 2008 Commission Issues Proposed Decision October 30, 2008 Comments to Proposed Decision Due December 1, 2008 Replies to Comments to Proposed Decision

December 8, 2008

Commission Issues Final Decision December 15, 2008

3. Issues To Be Considered

The issues to be considered in this Application concern Commission approval of

SCE’s 2009-2011 energy efficiency program portfolio and funding requests for program years

for the portfolio.

4. Legal Name and Correspondence

Southern California Edison Company is an electric public utility organized and

existing under the laws of the State of California. The location of SCE’s principal place of

business is 2244 Walnut Grove Avenue, Post Office Box 800, Rosemead, California 91770.

SCE’s attorneys in this matter are Jennifer Shigekawa and Larry R. Cope. Correspondence or

communications regarding this application should be addressed to:

120

Larry R. Cope Senior Attorney Southern California Edison Company P.O. Box 800 2244 Walnut Grove Avenue Rosemead, California 91770 Telephone: (626) 302-2570 Facsimile: (626) 302-7740 e-mail: [email protected]

To request a copy of this application, please contact:

Jennifer Alderete Project Analyst Southern California Edison Company P.O. Box 800 2244 Walnut Grove Avenue Rosemead, California 91770 Telephone: (626) 302-6697 Facsimile: (626) 302-3119 E-mail: jennifer.alderete @sce.com

C. Articles of Incorporation – Rule 2.2

A copy of SCE’s Certificate of Restated Articles of Incorporation, effective on March 2,

2006, and presently in effect, certified by the California Secretary of State, was filed with the

Commission on March 14, 2006, in connection with Application No. 06-03-020, and is by

reference made a part hereof.

Certain classes and series of SCE’s capital stock are listed on a “national

securities exchange” as defined in the Securities Exchange Act of 1934 and copies of SCE’s

latest Annual Report to Shareholders and its latest proxy statement sent to its stockholders has

been filed with the Commission.

D. Authority to Increase Rates – Rule 3.2

Rule 3.2 requires that applications for authority to increase rates, or to implement

changes that would result in increased rates, contain the following data.

121

1. Balance Sheet and Income Statement – Rule 3.2(a)(1)

Appendix A to this application contains copies of SCE’s balance sheet as of

December 31, 2007, and income statement for the period ended December 31, 2007, the most

recent period available.

2. Present and Proposed Rates – Rule 3.2(a)(2) and (a)(3)

The cost recovery mechanism proposal is summarized in Section VII above.

The cost recovery mechanism proposal and the projected impact on rates are discussed in Exhibit

SCE-1.

3. Description of SCE’s Service Territory and Utility System – Rule 3.2(a)(4)_

Because this submittal is not a general rate application, this requirement is not

applicable.

4. Summary of Earnings – Rule 3.2(a)(5)

Rule 3.2(a)(5) requires:

A summary of earnings (rate of return summary) on a depreciated rate base for the test period or periods upon which applicant bases its justification for an increase.

SCE’s 2008 Summary of Earnings is attached hereto as Appendix B.

5. Depreciation – Rule 3.2(a)(7)


applicable.

6. Capital Stock and Proxy Statement – Rule 3.2(a)(8)


applicable.

122

7. Statement Pursuant to Rule 3.2(a)(10)

Rule 3.5(a)(10) requires the applicant to state whether its request is limited to

passing through to customers “only increased costs to the corporation for the services or

commodities furnished by it.” This application seeks only to pass through to SCE’s customers

the costs incurred by SCE in its Energy Efficiency Program.

8. Service of Notice – Rule 3.2(b), (c) and (d)

A list of the cities and counties affected by the rate changes resulting from this

application is attached as Appendix C. The State of California is also an SCE customer whose

rates would be affected by the proposed revisions.

As provided in Rule 3.2(b) – (d), notice of filing of this application will be:

(1) mailed to the appropriate officials of the state and the counties and cities listed in

Appendix C; (2) published in a newspaper of general circulation in each county in SCE’s service

territory within which the rate changes would be effective; and (3) mailed to all customers

affected by the proposed changes.

E. Service List

SCE is serving this application and its exhibits on all parties on the Commission’s service

lists for proceedings R.06-04-010 and R.07-01-042.

F. Index of Exhibits And Appendices To This Application – Rule 23(g)

SCE’s submission in support of this Application includes the following, all of which are

incorporated by reference herein:

Appendices

Appendix A - SCE’s Balance Sheet and Income Statement

Appendix B – SCE’s 2008 Summary of Earnings

Appendix C – List of Counties and Municipalities Served

123

Appendix D –Abbreviations and Acronyms

Exhibits Filed in Support of SCE’s Application

SCE-1: Testimony of Southern California Edison Company in Support of Its Application

For Approval Of Its 2009-2011 Energy Efficiency Program Plans And Public Goods Charge And

Procurement Funding Requests

SCE-2: Compliance Tables and Charts

SCE-3: SCE’s 2009-2011 Energy Efficiency Program Plans (1-41)

SCE-4: SCE’s 2009-2011 Energy Efficiency Program Plans (42-77)

SCE-5: SCE’s DSM, Integration and Co-ordination

SCE-6: SCE’s PIP-Strategic Plan, crosswalk

SCE-7: SCE’s 2009-2011 Energy Efficiency AB32 impact

SCE-8: SCE’s Workpapers For Proposed Scenario

X.

CONCLUSION

SCE is now ready to proceed with its showing in support of this Application.

WHEREFORE, Southern California Edison Company respectfully requests that the

Commission review this Application and expeditiously issue an order.

(1) Approving its 2009-2011 Energy Efficiency Program Portfolio as filed;

(2) Approving SCE’s Proposed Energy Efficiency Policies and Rules Changes; and

(3) Authorizing SCE to fund the programs as requested herein and in the manner and

amounts requested through (i) its existing Energy Efficiency-related Public Goods Charge, (ii) its

existing Procurement Energy Efficiency-related Public Purpose Programs Charge (PPPC), and

(iii) an increase in its Procurement Energy Efficiency-related PPPC.

124

Respectfully submitted,

SOUTHERN CALIFORNIA EDISON COMPANY

/s/ LYNDA L. ZIEGLER By: Lynda L. Ziegler

Senior Vice President, Customer Service

JENNIFER SHIGEKAWA LARRY R. COPE

/s/ LARRY R. COPE By: Larry R. Cope

Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY

2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626) 302-2570 Facsimile: (626) 302-7740 E-mail: [email protected]

July 21, 2008

VERIFICATION

I am an officer of Southern California Edison Company, a party to this action, and am

authorized to make this verification for and on its behalf, and I make this verification for that

reason. I am informed and believe and on that ground allege that the matters stated in the

document described above are true.

I declare under penalty of perjury under the laws of the State of California that the

foregoing is true and correct.

Executed on July 17, 2008, at Rosemead, California.

/s/ LYNDA L. ZIEGLER By: Lynda L. Ziegler

Senior Vice President, Customer Service

Appendix A

SCE’s Balance Sheet and Income Statement

A-1

UTILITY PLANT:

Utility plant, at original cost $20,707 Less - Accumulated depreciation and decommissioning (5,174)

15,533 Construction work in progress 1,693 Nuclear fuel, at amortized cost 177

17,403

OTHER PROPERTY AND INVESTMENTS:

Nonutility property - less accumulated provision for depreciation of $701 1,000 Nuclear decommissioning trusts 3,378 Other Investments 69

4,447

CURRENT ASSETS:

Cash and equivalents 252 Margin and collateral deposits 37 Receivables, including unbilled revenues, less reserves of $34 for uncollectible accounts 725 Accrued unbilled revenue 370 Inventory 283 Accumulated deferred income taxes - net 146 Derivative assets 54 Regulatory assets 197 Other current assets 188

2,252DEFERRED CHARGES:

Regulatory assets 2,721 Derivative assets 28 Other long-term assets 629

3,378

$27,480

APPENDIX A A-1

(Millions of Dollars)


BALANCE SHEET

DECEMBER 31, 2007

A S S E T S

A-2

CAPITALIZATION:

Common stock $2,168 Additional paid-in capital 507 Accumulated other comprehensive loss (15) Retained Earnings 3,568 Common shareholder's equity 6,228

Preferred and preference stock not subject to redemption requirements 929 Long-term debt 5,081

12,238

CURRENT LIABILITIES:

Short-term debt 500 Accounts payable 914 Accrued taxes 42 Accrued interest 126 Counterparty collateral 42 Customer deposits 218 Book overdrafts 204 Derivative liabilities 100 Regulatory liabilities 1,019 Other current liabilities 548

3,713DEFERRED CREDITS:

Accumulated deferred income taxes - net 2,556 Accumulated deferred investment tax credits 105 Customer advances 155 Derivative liabilities 13 Power purchase contracts 22 Accumulated provision for pensions and benefits 786 Asset retirement obligations 2,877 Regulatory liabilities 3,433 Other deferred credits and other long-term liabilities 1,136

11,083

Minority interest 446

$27,480

APPENDIX A A-2

BALANCE SHEET


(Millions of Dollars)

CAPITALIZATION AND LIABILITIES

DECEMBER 31, 2007

A-3

Appendix B

SCE’s 2008 Summary of Earnings

B-1

LineNo. Item Total

1. Base Revenues 4,113,324

2. Expenses:3. Operation & Maintenance 1,874,463 4. Depreciation 882,131 5. Taxes 617,599 6. Revenue Credits (170,624) 7. Total Expenses 3,203,569

8. Net Operating Revenue 909,755

9. Rate Base 10,397,198

10. Rate of Return 8.75%

1/ D.06-05-016/Advice Letter 2176-E and 2196-EIncludes one SONGS 2&3 refueling and maintenance outage

Southern California EdisonSummary of Earnings

2008 GRC-Related Adopted Revenue Requirement 1/

Thousands of Dollars

Appendix C

List of Counties and Municipalities Served

C-1

N A CITY CLERK CITY OF AVALON 410 AVALON CANYON RD PO BOX 707 AVALON, CA 90704 Cities and Counties

CITY OF BLYTHE CITY CLERK 235 N. BROADWAY CITY HALL BLYTHE, CA 92225 Cities and Counties

CITY OF CATHEDRAL CITY PLANNING DIRECTOR 68-700 AVENIDA LALO GUERRERO CATHEDRAL CITY, CA 92234 Cities and Counties

CALEXICO CHAMBER OF COMMERCE P.O. BOX 948 CALEXICO, CA 92232 Cities and Counties

CALEXICO CITY CLERK 608 HEBER AVENUE CALEXICO, CA 92231-2840 Cities and Counties

CITY OF COACHELLA PLANNING DIRECTOR 1515 SIXTH STREET COACHELLA, CA 92236 Cities and Counties

IMPERIAL COUNTY PLANNING DIRECTOR 940 MAIN STREET EL CENTRO, CA 92243 Cities and Counties

VALLEY OF IMPERIAL DEVELOPMENT ALLIANCE 836 MAIN STREET EL CENTRO, CA 92243 Cities and Counties

PLANNING DIRECTOR CITY OF INDIO 100 CIVIC CENTER MALL INDIO, CA 92201 Cities and Counties

GORDON HOYT CITY OF ANAHEIM P.O. BOX 3222 ANAHEIM, CA 92803 Cities and Counties

JOELLEN JACKSON IMPERIAL VALLEY CHAMBER OF COMMERCE 101 E 4TH STREET IMPERIAL, CA 92251 Cities and Counties

STEVE LARSON EXECUTIVE DIRECTOR CALIFORNIA PUBLIC UTILITIES COMMISSION 505 VAN NESS AVENUE, 5TH FLOOR SAN FRANCISCO, CA 94102-5512 Cities and Counties

WALLY LEIMGRUBER CHAIRMAN-BOARD OF SUPERVISORS COUNTY OF IMPERIAL 940 W. MAIN STREET EL CENTRO, CA 92243 Cities and Counties

THOMAS M MAYOR CITY OF WEST COVINA 1444 WEST GARVEY AVENUE P.O. BOX 1440 WEST COVINA, CA 91793 Cities and Counties

PICO RIVERA CITY ATTORNEY n/a 5615 PASSON BLVD PICO RIVERA, CA 90660 Cities and Counties

COUNTY OF ORANGE COUNTY COUNSEL HALL OF ADMINISTRATION BUILDING 333 W. SANTA ANA BLVD BUILDING 10 SANTA ANA, CA 92702 Cities and Counties

CITY OF PALM SPRINGS PLANNING DIRECTOR 3200 E. TAHQUITZ-MCCALLUM WAY PALM SPRINGS, CA 92262 Cities and Counties

CITY OF RANCHO MIRAGE PLANNING DIRECTOR 69825 HIGHWAY 111 RANCHO MIRAGE, CA 92270 Cities and Counties

C-2

STEVE SHANER MAYOR CITY OF IMPERIAL 420 SOUTH IMPERIAL AVENUE IMPERIAL, CA 92251 Cities and Counties

HAWTHORNE CITY CLERK CITY OF HAWTHORNE 4455 W. 126TH STREET HAWTHORNE, CA 90250 Cities and Counties

HEMET CITY ATTORNEY CITY OF HEMET 450 E. LATHAM AVE. HEMET, CA 92543 Cities and Counties

HEMET CITY CLERK CITY OF HEMET 450 E. LATHAM AVE. HEMET, CA 92543 Cities and Counties

HESPERIA CITY ATTORNEY CITY OF HESPERIA 15776 MAIN STREET, SUITE 213 HESPERIA , CA 92345 Cities and Counties

HESPERIA CITY CLERK CITY OF HESPERIA 15776 MAIN STREET, SUITE 213 HESPERIA, CA 92345 Cities and Counties

HIDDEN HILLS CITY ATTORNEY CITY OF HIDDEN HILLS 6165 SPRING VALLEY ROAD HIDDEN HILLS, CA 91302 Cities and Counties

HIDDEN HILLS CITY CLERK CITY OF HIDDEN HILLS 6165 SPRING VALLEY ROAD HIDDEN HILLS, CA 91302 Cities and Counties

HIGHLAND CITY ATTORNEY CITY OF HIGHLAND 27215 BASE LINE HIGHLAND, CA 92346 Cities and Counties

HUNTINGTON BEACH CITY ATTORNEY 2000 MAIN STREET HUNTINGTON BEACH, CA 92648 Cities and Counties

HUNTINGTON BEACH CITY CLERK 2000 MAIN STREET HUNTINGTON BEACH, CA 92648 Cities and Counties

HUNTINGTON PARK CITY ATTORNEY 6550 MILES AVENUE HUNGTINGON PARK, CA 90255 Cities and Counties

HUNTINGTON PARK CITY CLERK 6550 MILES AVENUE HUNTINGTON PARK, CA 90255 Cities and Counties

IMPERIAL COUNTY COUNTY ADMINISTRATION CENTER EL CENTRO, CA 92243 Cities and Counties

INDIAN WELLS CITY ATTORNEY CITY OF INDIAN WELLS 44-950 ELDORADO DRIVE INDIAN WELLS, CA 92210 Cities and Counties

INDIAN WELLS CITY CLERK CITY OF INDIAN WELLS 44-950 ELDORADO DRIVE INDIAN WELLS, CA 92210 Cities and Counties

IRVINE CITY ATTORNEY CITY OF IRVINE 1 CIVIC CENTER PLAZA po box 19575 IRVINE, CA 92623-9575 Cities and Counties

IRVINE CITY CLERK CITY OF IRVINE 1 CIVIC CENTER PLAZA P O BOX 19575 IRVINE, CA 92623-9575 Cities and Counties

C-3

KERN COUNTY COUNTY COUNSEL 1415 TRUXTON AVENUE BAKERSFIELD, CA 93301 Cities and Counties

KINGS COUNTY COUNTY CLERK RECORDER 1400 W. LACEY BLVD. HANFORD, CA 93230 Cities and Counties

LA HABRA CITY ATTORNEY CITY OF LA HABRA 201 E. LA HABRA BLVD. LA HABRA, CA 90633 Cities and Counties

LA HABRA CITY CLERK CITY OF LA HABRA 201 W. LA HABRA BLVD LA HABRA, CA 90633 Cities and Counties

LA HABRA HEIGHTS CITY ATTORNEY 1245 N. HACIENDA BLVD LA HABRA HEIGHTS, CA 90631 Cities and Counties

LA HABRA HEIGHTS CITY CLERK 1245 N. HACIENDA BLVD LA HABRA HEIGHTS, CA 90631 Cities and Counties

LA MIRADA CITY ATTORNEY 13700 LA MIRADA BLVD. LA MIRADA, CA 90638 Cities and Counties

LA MIRADA CITY CLERK 13700 LA MIRADA BLVD LA MIRADA, CA 90638 Cities and Counties

LA PALMA CITY ATTORNEY 7822 WALKER STREET LA PALMA, CA 90623 Cities and Counties

LA PALMA CITY CLERK 7822 WALKER STREET LA PALMA, CA 90623 Cities and Counties

LA PUENTE CITY CLERK 15900 EAST MAIN STREET LA PUENTE, CA 91744 Cities and Counties

LA VERNE CITY ATTORNEY 3600 D STREET LA VERNE, CA 91750 Cities and Counties

LA VERNE CITY CLERK 3660 D STREET LA VERNE, CA 91750 Cities and Counties

LAGUNA BEACH CITY ATTORNEY 505 FOREST AVENUE LAGUNA BEACH, CA 92651 Cities and Counties

LAGUNA BEACH CITY CLERK 505 FOREST AVENUE LAGUNA BEACH, CA 92651 Cities and Counties

LAGUNA NIGUEL CITY ATTORNEY CITY OF LAGUNA NIGUEL 27801 LA PAZ ROAD LAGUNA NIGUEL, CA 92677 Cities and Counties

LAGUNA NIGUEL CITY CLERK CITY OF LAGUNA NIGUEL 27801 LA PAZ ROAD LAGUNA NIGUEL, CA 92677 Cities and Counties

LAKE ELSINORE CITY ATTORNEY CITY OF LAKE ELSINORE 130 S. MAIN STREET LAKE ELSINORE, CA 92530 Cities and Counties

C-4

LAKE ELSINORE CITY CLERK CITY OF LAKE ELSINORE 130 S. MAIN STREET LAKE ELSINORE, CA 92530 Cities and Counties

LAKE FOREST CITY ATTORNEY CITY OF LAKE FOREST 25550 COMMERCENTRE DRIVE LAKE FOREST, CA 92630 Cities and Counties

LAKE FOREST CITY CLERK CITY OF LAKE FOREST 25550 COMMERCENTRE DRIVE LAKE FOREST, CA 92630 Cities and Counties

LAKEWOOD CITY ATTORNEY CITY OF LAKEWOOD 5000 CLARK AVENUE LAKEWOOD, CA 90712 Cities and Counties

LAKEWOOD CITY CLERK CITY OF LAKEWOOD 5000 CLARK AVENUE LAKEWOOD, CA 90712 Cities and Counties

LANCASTER CITY ATTORNEY CITY OF LANCASTER 44933 N. FERN AVE LANCASTER, CA 93534 Cities and Counties

LANCASTER CITY CLERK CITY OF LANCASTER 44933 N. FERN AVE LANCASTER, CA 93534 Cities and Counties

LAWNDALE CITY ATTORNEY 14717 BUNN AVENUE LAWNDALE, CA 90260 Cities and Counties

LAWNDALE CITY CLERK 14717 BUNN AVENUE LAWNDALE, CA 90260 Cities and Counties

LINDSAY CITY ATTORNEY 251 EAST HONOLULU STREET LINDSAY, CA 93247 Cities and Counties

LINDSAY CITY CLERK CITY OF LINDSAY 251 EAST HONOLULU STREET LINDSAY, CA 93247 Cities and Counties

LOMA LINDA CITY ATTORNEY CITY OF LOMA LINDA 25541 BARTON RD LOMA LINDA, CA 92354 Cities and Counties

LOMA LINDA CITY CLERK CITY OF LOMA LINDA 25541 BARTON RD LOMA LINDA, CA 92354 Cities and Counties

LOMITA CITY ATTORNEY CITY OF LOMITA 24300 NARGONNE AVE LOMITA, CA 90717 Cities and Counties

LOMITA CITY CLERK CITY OF LOMITA 24300 NARBONNE AVE LOMITA, CA 90717 Cities and Counties

LONG BEACH CITY ATTORNEY 333 WEST OCEAN BLVD LONG BEACH, CA 90802 Cities and Counties

LONG BEACH CITY CLERK 333 WEST OCEAN BLVD. LONG BEACH, CA 90802 Cities and Counties

LOS ALAMITOS CITY ATTORNEY CITY OF LOS ALAMITOS 3191 KATELLA AVENUE LOS ALAMITOS, CA 90720 Cities and Counties

C-5

LOS ALAMITOS CITY CLERK CITY OF LOS ALAMITOS 3191 KATELLA AVE LOS ALAMITOS, CA 90720 Cities and Counties

LOS ANGELES CITY ATTORNEY CITY OF LOS ANGELES 200 NORTH MAIN STREET 800 CITY HALL EAST LOS ANGELES, CA 90012 Cities and Counties

LOS ANGELES CITY CLERK CITY OF LOS ANGELES 200 N. SPRING ST RM 360 LOS ANGELES, CA 90012 Cities and Counties

LOS ANGELES COUNTY 500 W TEMPLE LOS ANGELES, CA 90012 Cities and Counties

LYNWOOD CITY ATTORNEY 11330 BULLIS ROAD LYNWOOD, CA 90262 Cities and Counties

LYNWOOD CITY CLERK 11330 BULLIS ROAD LYNWOOD, CA 90262 Cities and Counties

MALIBU CITY ATTORNEY CITY OF MALIBU 23815 STUART RANCH RD. CITY HALL MALIBU, CA 90265 Cities and Counties

MALIBU CITY CLERK CITY OF MAILBU 23815 STUART RANCH RD CITY HALL MALIBU, CA 90265 Cities and Counties

MAMMOTH LAKES TOWN CLERK TOWN OF MAMMOTH LAKES MINARET MALL. OLD MAMMOTH RD. P.O. BOX 1609 MAMMOTH LAKES, CA 93546 Cities and Counties

MAYWOOD CITY ATTORNEY 4319 SLAUSON AVENUE MAYWOOD, CA 90270 Cities and Counties

MAYWOOD CITY CLERK 4319 SLAUSON AVENUE MAYWOOD, CA 90270 Cities and Counties

MCFARLAND CITY ATTORNEY 401 KERN AVENUE MCFARLAND, CA 93250 Cities and Counties

MCFARLAND CITY CLERK 401 KERN AVENUE MCFARLAND, CA 93250 Cities and Counties

MONO COUNTY MONO COUNTY COURTHOUSE P.O. BOX 537 BRIDGEPORT, CA 93517 Cities and Counties

MONROVIA CITY ATTORNEY 415 SOUTH IVY AVENUE CITY HALL MONROVIA, CA 91016 Cities and Counties

MONROVIA CITY CLERK 415 SOUTH IVY AVENUE CITY HALL MONROVIA, CA 91016 Cities and Counties

MONTCLAIR CITY ATTORNEY 5111 BENITO STREET MONTCLAIR, CA 91763 Cities and Counties

MONTCLAIR CITY CLERK 5111 BENITO STREET MONTCLAIR, CA 91763 Cities and Counties

C-6

MONTEBELLO CITY ATTORNEY 1600 BEVERLY BLVD. MONTEBELLO, CA 90640 Cities and Counties

MONTEBELLO CITY CLERK 1600 BEVERLY BLVD. MONTEBELLO, CA 90640 Cities and Counties

MONTEREY PARK CITY ATTORNEY 320 WEST NEWMARK AVENUE CITY HALL MONTEREY PARK, CA 91754 Cities and Counties

MOORPARK CITY ATTORNEY CITY OF MOORPARK 799 MOORPARK AVENUE MOORPARK, CA 93021 Cities and Counties

MOORPARK CITY CLERK CITY OF MOORPARK 799 MOORPARK AVE MOORPARK, CA 93021 Cities and Counties

MORENO VALLEY CITY ATTORNEY CITY OF MORENO VALLEY 14177 Frederick Street City Hall MORENO VALLEY, CA 92552 Cities and Counties

MORENO VALLEY CITY CLERK CITY OF MORENO VALLEY 14177 FREDERICK STREET MORENO VALLEY, CA 92552-0805 Cities and Counties

MURRIETA CITY ATTORNEY CITY OF MURRIETA 26442 BECKMAN CT MURRIETA, CA 92562 Cities and Counties

MURRIETA CITY CLERK CITY OF MURRIETA 26442 BECKMAN CT MURRIETA, CA 92562 Cities and Counties

NEWPORT BEACH CITY ATTORNEY CITY OF NEWPORT BEACH 3300 NEWPORT BLVD NEWPORT BEACH, CA 92663 Cities and Counties

NEWPORT BEACH CITY CLERK CITY OF NEWPORT BEACH 3300 NEWPORT BLVD NEWPORT BEACH, CA 92663 Cities and Counties

NORWALK CITY ATTORNEY 12700 NORWALK BLVD NORWALK, CA 90650 Cities and Counties

ONTARIO CITY CLERK CITY OF ONTARIO 303 EAST B STREET ONTARIO, CA 91764 Cities and Counties

ORANGE CITY ATTORNEY 300 E. CHAPMAN AVENUE ORANGE, CA 92666 Cities and Counties

ORANGE CITY CLERK 300 E. CHAPMAN AVENUE ORANGE, CA 92666 Cities and Counties

OXNARD CITY CLERK 305 WEST THIRD STREET OXNARD, CA 93030 Cities and Counties

PALM DESERT CITY ATTORNEY CITY OF PALM DESERT 73-510 FRED WARING DR PALM DESERT, CA 92260 Cities and Counties

PALM DESERT CITY CLERK CITY OF PALM DESERT 73-510 FRED WARING DR PALM DESERT, CA 92260 Cities and Counties

C-7

PALM SPRINGS CITY ATTORNEY CITY OF PALM SPRINGS 3200 TAHQUITZ CANYON WAY PALM SPRINGS, CA 92263 Cities and Counties

PALM SPRINGS CITY CLERK CITY OF PALM SPRINGS 3200 TAHQUITZ CANYON WAY PALM SPRINGS, CA 92262 Cities and Counties

PALOS VERDES ESTATES CITY ATTORNEY 340 PALO VERDES DRIVE WEST PALOS VERDES ESTATES, CA 90274 Cities and Counties

PALOS VERDES ESTATES CITY CLERK 340 PALO VERDES DRIVE WEST PALOS VERDES ESTATES, CA 90274 Cities and Counties

PARAMOUNT CITY ATTORNEY CITY OF PARAMOUNT 16400 S. COLORADO AVE. PARAMOUNT, CA 90723 Cities and Counties

PARAMOUNT CITY CLERK CITY OF PARAMOUNT 16400 S. COLORADO AVE. PARAMOUNT, CA 90723 Cities and Counties

PASADENA CITY ATTORNEY CITY OF PASADENA 100 N. GARFIELD AVENUE PASADENA, CA 91109 Cities and Counties

PERRIS CITY ATTORNEY CITY OF PERRIS 101 N. D STREET PERRIS , CA 92370 Cities and Counties

PERRIS CITY CLERK CITY OF PERRIS 101 N. D STREET PERRIS, CA 92370 Cities and Counties

PICO RIVERA CITY CLERK 6615 PASSONS BLVD PICO RIVERA, CA 90660 Cities and Counties

PLACENTIA CITY ATTORNEY 401 E. CHAPMAN AVENUE PLACENTIA, CA 92670 Cities and Counties

PLACENTIA CITY CLERK 401 E. CHAPMAN AVENUE PLACENTIA, CA 92670 Cities and Counties

POMONA CITY ATTORNEY CITY OF POMONA 505 S. GAREY POMONA, CA 91766 Cities and Counties

TULARE CITY ATTORNEY CITY OF TULARE 411 E. KERN AVE CIVIC AFFAIRS BLDG TULARE, CA 93274 Cities and Counties

CLERK OF THE BOARD KERN COUNTY 1415 TRUSTUN AVENUE BAKERSFIELD, CA 93301 Cities and Counties

CHEIF EXECUTIVE OFFICE COUNTY OF LOS ANGELES 500 WEST TEMPLE STREET 713 KENNETH HAHN HALL OF ADMINISTRATION LOS ANGELES, CA 90012 Cities and Counties

POMONA CITY CLERK CITY OF POMONA 505 S. GAREY POMONA, CA 91766 Cities and Counties

DISTRICT ATTORNEY RIVERSIDE COUNTY 4075 MAIN STREET MAIN OFFICE-RIVERSIDE RIVERSIDE, CA 92501 Cities and Counties

C-8

SAN BERNARDINO COUNTY CLERK OF THE BOARD 385 N ARROWHEAD AVENUE SAN BERNARDINO, CA 92415-0110 Cities and Counties

CLERK OF THE COUNCIL CITY OF SANTA ANA 20 CIVIC CENTER PLAZA SANTA ANA, CA 92702 Cities and Counties

SANTA BARBARA COUNTY COUNTY CLERK-RECORDER 105 E ANAPAMU STREET SANTA BARBARA, CA 93102 Cities and Counties

SIGNAL HILL CITY ATTORNEY CITY OF SIGNAL HILL 2175 CHERRY AVE SIGNAL HILL , CA 90755 Cities and Counties

SIGNAL HILL CITY CLERK CITY OF SIGNAL HILL 2175 CHERRY AVE. SIGNAL HILL, CA 90755 Cities and Counties

SOUTH PASADENA CITY ATTORNEY 1414 MISSION STREET SOUTH PASADENA, CA 91030 Cities and Counties

CLERK OF THE BOARD TULARE COUNTY 2800 WEST BURREL AVENUE ADMINISTRATION BUILDING VISALIA, CA 93291-4582 Cities and Counties

YUCCA VALLEY TOWN CLERK CITY OF YUCCA VALLEY 57090 29 PALM HWY YUCCA VALLEY, CA 92284 Cities and Counties

BRADBURY CITY ATTORNEY CITY OF BRADBURY 600 WINSTON AVENUE CITY HALL BRADBURY, CA 91010 Cities and Counties

BREA CITY ATTORNEY CITY OF BREA NUMBER ONE CIVIC CENTER CIRCLE CITY HALL BREA, CA 92821 Cities and Counties

CANYON LAKE CITY ATTORNEY CITY OF CANYON LAKE 31516 RAILROAD CANYON ROAD CANYON LAKE, CA 92587 Cities and Counties

CERRITOS CITY ATTORNEY CITY OF CERRITOS 18125 BLOOMFIELD AVENUE CITY HALL CERRITOS, CA 90703 Cities and Counties

COMMERCE CITY ATTORNEY CITY OF COMMERCE 2535 COMMERCE WAY CITY HALL COMMERCE, CA 90040 Cities and Counties

CITY ATTORNEY CITY OF LAGUNA WOODS 24264 EL TORO ROAD CITY HALL LAGUNA WOODS, CA 92637 Cities and Counties

LAGUNA WOODS CITY CLERK CITY OF LAGUNA WOODS 24264 EL TORO ROAD CITY HALL LAGUNA WOODS, CA 92637 Cities and Counties

ANAHEIM CITY ATTORNEY CITY OF ANAHEIM 200 SOUTH ANAHEIM BLVD SUITE 356 CITY HALL EAST ANAHEIM, CA 92805 Cities and Counties

COUNTY CLERK FRESNO COUNTY 22211 KERN STREET FRESNO, CA 93721-2600 Cities and Counties

COUNTY COUNSEL FRESNO COUNTY 2221 KERN STREET FRESNO, CA 93721-2600 Cities and Counties

C-9

FULLERTON CITY ATTORNEY 303 WEST COMMONWEALTH AVENUE FULLERTON, CA 92832 Cities and Counties

OJAI CITY ATTORNEY CITY OF OJAI P O Box 1570 OJAI, CA 93024 Cities and Counties

CITY ATTORNEY CITY OF SAN BUENAVENTURA 501 POLI ST PO BOX VENTURA, CA 93002-0099 Cities and Counties

MANHATTAN BEACH CITY ATTORNEY 1400 HIGHLAND AVENUE CITY HALL MANHATTAN BEACH, CA 90266 Cities and Counties

CITY CLERK CITY OF ADELANTO 11600 AIR EXPRESSWAY CITY HALL ADELANTO, CA 92301 Cities and Counties

CITY CLERK CITY OF AGOURA HILLS 30001 LADYFACE CT. CITY HALL AGOURA HILLS, CA 91301 Cities and Counties

CITY ATTORNEY CITY OF ALHAMBRA 111 SOUTH 1ST STREET CITY HALL ALHAMBRA, CA 91801 Cities and Counties

CITY CLERK CITY OF ANAHEIM 200 SOUTH ANAHEIM BOULEVARD CITY HALL EAST 7TH FLOOR ANAHEIM, CA 92805 Cities and Counties

CITY MANAGER CITY OF ANAHEIM 200 SOUTH ANAHEIM BOULEVARD 7TH FLOOR CITY HALL EAST ANAHEIM, CA 92805 Cities and Counties

CITY CLERK CITY OF APPLE VALLEY 20440 US HIGHWAY 18 CITY HALL APPLE VALLEY, CA 92307 Cities and Counties

AVALON CITY ATTORNEY CITY OF AVALON 410 AVALON CANYON RD CITY HALL PO BOX 707 AVALON, CA 90704 Cities and Counties

CITY ATTORNEY CITY OF AZUSA 213 E FOOTHILL BLVD CITY HALL AZUSA, CA 91702-2550 Cities and Counties

CITY MANAGER CITY OF AZUSA 213 E. FOOTHILL BLVD CITY HALL AZUSA, CA 91702-2550 Cities and Counties

BARSTOW CITY CLERK CITY OF BARSTOW 220 EAST MT VIEW ST SUITE A CITY HALL BARSTOW, CA 92311 Cities and Counties

BLYTHE CITY CLERK CITY OF BLYTHE 220 NORTH BROADWAY CITY HALL BLYTHE , CA 92225 Cities and Counties

BREA CITY CLERK CITY OF BREA 1 CIVIC CENTER CIRCLE CITY HALL BREA, CA 92621 Cities and Counties

BUENA PARK CITY CLERK CITY OF BUENA PARK 6650 BEACH BLVD CITY HALL BUENA PARK, CA 90621 Cities and Counties

CITY CLERK CITY OF COACHELLA VALLEY 1515 6TH STREET COACHELLA, CA 92236 Cities and Counties

C-10

CITY CLERK CITY OF CORONA 400 S. VICENTIA AVE CITY HALL CORONA, CA 92234 Cities and Counties

CUDAHY CITY CLERK CITY OF CUDAHY 5220 SANTA ANA STREET CUDAHY, CA 90201 Cities and Counties

CITY CLERK CITY OF DUARTE 1600 HUNTINGTON DR. CITY HALL DUARTE, CA 91010 Cities and Counties

GARDEN GROVE CITY CLERK CITY OF GARDEN GROVE 11222 ACACIA PKWY CITY HALL GARDEN GROVE, CA 92840 Cities and Counties

CITY CLERK CITY OF GLENDORA 116 EAST FOOTHILL BLVD CITY HALL GLENDORA, CA 91741 Cities and Counties

CITY CLERK CITY OF GOLETA 130 Cremona Drive, Suite B CITY HALL GOLETA, CA 93117 Cities and Counties

CITY CLERK CITY OF GRAND TERRACE 22795 BARTON ROAD CITY HALL GRAND TERRACE, CA 92313 Cities and Counties

CITY CLERK CITY OF HIGHLAND 27215 BASE LINE HIGHLAND, CA 92346 Cities and Counties

CITY CLERK CITY OF HAWTHORNE 4455 W. 126TH ST HAWTHORNE, CA 90250 Cities and Counties

CITY CLERK CITY OF EL SEGUNDO 350 MAIN ST. CITY HALL EL SEGUNDO, CA 90245 Cities and Counties

CITY CLERK CITY OF FULLERTON 303 WEST COMMONWEALTH AVENUE CITY HALL FULLERTON, CA 92632 Cities and Counties

CITY CLERK CITY OF INDIO 150 CIVIC CENTER MALL CITY HALL INDIO, CA 92201 Cities and Counties

CITY OF MONTEREY PARK 320 WEST NEWMARK AVE CITY HALL MONTEREY PARK, CA 91754 Cities and Counties

CITY ATTORNEY 2870 CLARK AVE CITY HALL NORCO, CA 92860 Cities and Counties

CITY CLERK'S OFFICE CITY OF NORWALK 12700 NORWALK BLVD PO BOX 1030 NORWALK, CA 90651-1030 Cities and Counties

OJAI CITY CLERK CITY OF OJAI 401 S. VENTURA ST CITY HALL PO BOX 1570 OJAI, CA 93023 Cities and Counties

CITY ATTORNEY CITY OF OXNARD 300 WEST THIRD STREET, THIRD FLOOR OXNARD, CA 93030 Cities and Counties

CITY ATTORNEY CITY OF PALMDALE 38300 SIERRA HIGHWAY. CITY HALL PALMDALE, CA 93550 Cities and Counties

C-11

CITY CLERK CITY OF PALMDALE 38300 SIERRA HIGHWAY CITY HALL PALMDALE, CA 93550 Cities and Counties

CITY CLERK CITY OF PASADENA 117 E. COLORADO BLVD PASADENA, CA 91105 Cities and Counties

CITY ATTORNEY CITY OF RANCHO MIRAGE 69825 HIGHWAY 111 RANCHO MIRAGE, CA 92270 Cities and Counties

CITY ATTORNEY CITY OF RANCHO PALOS VERDES 30940 HAWTHORNE BLVD. CITY HALL RANCHO PALOS VERDES, CA 90275 Cities and Counties

CITY CLERK CITY OF REDLANDS 35 CAJON ST #4 REDLANDS, CA 92373-0629 Cities and Counties

CITY ATTORNEY CITY OF REDLANDS 35 CAJON ST. PO BOX 3005 REDLANDS, CA 92373 Cities and Counties

CITY ATTORNEY CITY OF SANTA BARBARA 740 STATE ST. STE 201 SANTA BARBARA, CA 93101 Cities and Counties

CITY CLERK CITY OF SANTA BARBARA 735 ANACAPA ST SANTA BARBARA, CA 93101 Cities and Counties

CITY OF SANTA FE SPRINGS 11710 TELEGRAPH RD CITY HALL SANTA FE SPRINGS, CA 90670 Cities and Counties

CITY ATTORNEY CITY OF STANTON 7800 KATELLA AVENUE CITY HALL STANTON, CA 90680 Cities and Counties

CITY CLERK CITY OF TEMPLE CITY 9701 LAS TUNAS CITY HALL TEMPLE CITY, CA 91780-2113 Cities and Counties

CITY CLERK CITY OF TULARE 411 E. KERN AVE TULARE, CA 93274 Cities and Counties

CITY CLERK CITY OF TUSTIN 300 CENTENNIAL WAY CITY HALL TUSTIN, CA 92780 Cities and Counties

CITY ATTORNEY CITY OF TUSTIN 300 CENTENIAL WAY CITY HALL TUSTIN, CA 92780 Cities and Counties

CITY OF VERNON 4305 SANTA FE AVENUE OFFICE OF THE CITY CLERK VERNON, CA 90058 Cities and Counties

CITY CLERK CITY OF VILLA PARK 17855 SANTIAGO BLVD CITY HALL VILLA PARK, CA 92861 Cities and Counties

CITY ATTORNEY CITY OF WEST HOLLYWOOD 8300 SANTA MONICA BLVD CITY HALL WEST HOLLYWOOD, CA 90063 Cities and Counties

CITY CLERK CITY OF WOODLAKE 350 N VALENCIA BLVD CITY HALL WOODLAKE, CA 93286 Cities and Counties

C-12

CITY ATTORNEY CITY OF WOODLAKE 350 N. VALENCIA BLVD CITY HALL WOODLAKE , CA 93286 Cities and Counties

CLERK OF THE BOARD OF SUPERVISORS IMPERIAL COUNTY 940 MAIN STREET, SUITE 209 EL CENTRO, CA 92243 Cities and Counties

COUNTY CLERK MADERA COUNTY 200 WEST 4TH STREET MADERA, CA 93637 Cities and Counties

CLERK/RECORDER COUNTY OF ORANGE 333 W. SANTA ANA BLVD BUILDING 10 SANTA ANA, CA 92702 Cities and Counties

COUNTY COUNSEL ORANGE COUNTY 333 W. SANTA ANA BLVD BUID 12 HALL OF ADMINISTRATION BUILDING SANTA ANA, CA 92701 Cities and Counties

BOARD OF SUPERVISORS-CEO'S OFFICE COUNTY OF ORANGE 333 W. SANTA ANA BLVD. BUILDING 12 HALL OF ADMINISTRATION BUILDING SANTA ANA, CA 92702 Cities and Counties

COUNTY CLERK-RECORDER COUNTY OF RIVERSIDE 4080 LEMON ST 1ST FLOOR RIVERSIDE , CA 93101 Cities and Counties

OFFICE OF THE DISTRICT ATTORNEY COUTNY OF SANTA BARBARA 1112 SANTA BARBARA ST MAIN OFFICE SANTA BARBARA, CA 93101 Cities and Counties

COUNTY COUNSEL/PERSONNEL BUILDING COUNTY OF TULARE 2900 WEST BURREL AVENUE COUNTY CIVIC CENTER VISALIA, CA 93291-4583 Cities and Counties

RANCHO CUCAMONGA CITY ATTORNEY 10500 CIVIC CENTER RANCHO CUCAMONGA, CA 91730 Cities and Counties

RANCHO MIRAGE CITY ATTORNEY 69-825 HIGHWAY 111 RANCHO CUCAMONGA, CA 92270 Cities and Counties

REDONDO BEACH CITY ATTORNEY 415 DIAMOND STREET REDONDO BEACH, CA 90277 Cities and Counties

RIALTO CITY ATTORNEY 150 SOUTH PALM RIALTO, CA 92376 Cities and Counties

RIDGECREST CITY ATTORNEY CITY OF RIDGECREST 100 W CALIFORNIA AVE RIDGECREST, CA 93555 Cities and Counties

RIDGECREST CITY CLERK CITY OF RIDGECREST 100 W CALIFORNIA AVENUE RIDGECREST, CA 93555 Cities and Counties

RIVERSIDE CITY CLERK CITY OF RIVERSIDE 3900 MAIN STREET, 7TH FLOOR RIVERSIDE, CA 92522 Cities and Counties

FURMAN B ROBERTS, ESQ. CITY OF ORANGE 300 EAST CHAOMAN AVENUE ORANGE, CA 92667 Cities and Counties

ROLLING HILLS CITY ATTORNEY CITY OF ROLLING HILLS 2 PORTUGUESE BEND ROAD ROLLING HILLS, CA 90274 Cities and Counties

C-13

ROLLING HILLS ESTATES CITY HALL 4045 PALOS VERDES DRIVE NORTH ROLLING HILLS ESTATES, CA 90274 Cities and Counties

ROSEMEAD CITY ATTORNEY 8838 EAST VALLEY BLVD ROSEMEAD, CA 91770 Cities and Counties

ROSEMEAD CITY CLERK 8838 EAST VALLEY BLVD. ROSEMEAD, CA 91770 Cities and Counties

SAN BUENAVENTURA CITY CLERK CITY OF SANTA BEUNAVENTURA 501 POLI ST SAN BERNARDINO, CA 93001 Cities and Counties

SAN DIMAS CITY ATTORNEY 245 EAST BONTIA AVENUE SAN DIMAS, CA 91773 Cities and Counties

SAN DIMAS CITY CLERK 245 EAST BONITA AVENUE SAN DIMAS, CA 91773 Cities and Counties

SAN FERNANDO CITY ATTORNEY 117 MACNEIL STREET SAN FERNANDO , CA 91340 Cities and Counties

SAN JACINTO ATTORNEY CITY OF SAN JACINTO 201 E MAIN ST SAN JACINTO, CA 92581 Cities and Counties

SAN JACINTO CITY CLERK CITY OF SAN JACINTO 201 E MAIN STREET PO BOX 488 SAN JACINTO, CA 92581 Cities and Counties

SAN MARINO CITY ATTORNEY 2200 HUNTINGTON DRIVE SAN MARINO, CA 91108 Cities and Counties

SANTA ANA CITY ATTORNEY CITY OF SANTA ANA 22 CIVIC CENTER PLAZA SANTA ANA, CA 92701 Cities and Counties

SANTA CLARITA CITY ATTORNEY CITY OF SANTA CLARITA 23920 VALENCIA BLVD. SUITE 301 SANTA CLARITA, CA 91355 Cities and Counties

SANTA CLARITA CITY CLERK CITY OF SANTA CLARITA 23920 VALENCIA BLVD., SUITE 301 SANTA CLARITA, CA 91355 Cities and Counties

SANTA FE SPRINGS CITY ATTORNEY CITY OF SANTA FE SPRINGS 11710 TELEGRAPH ROAD SANTA FE SPRINGS, CA 90670 Cities and Counties

SANTA MONICA CITY ATTORNEY 1685 MAIN STREET SANTA MONICA, CA 90401 Cities and Counties

SANTA PAULA CITY ATTORNEY 970 VENTURA STREET SANTA PAULA, CA 93060 Cities and Counties

SEAL BEACH CITY ATTORNEY 211 EIGHTH STREET SEAL BEACH, CA 90740 Cities and Counties

SIERRA MADRE CITY ATTORNEY CITY OF SIERRA MADRE 232 W SIERRA MADRE BLVD. SIERRA MADRE, CA 91024 Cities and Counties

C-14

SIERRA MADRE CITY CLERK CITY OF SIERRA MADRE 232 W SIERRA MADRE BLVD SIERRA MADRE, CA 91024 Cities and Counties

SIMI VALLEY CITY ATTORNEY CITY OF SIMI VALLEY 2929 TAPO CANTON RD. SIMI VALLEY, CA 93063 Cities and Counties

SOUTH EL MONTE CITY ATTORNEY 1415 SANTA ANITA AVENUE SOUTH EL MONTE, CA 91733 Cities and Counties

SOUTH GATE CITY ATTORNEY 8650 CALIFORNIA AVENUE SOUTH GATE, CA 90280 Cities and Counties

TEHACHAPI CITY ATTORNEY CITY OF TEHACHAPI 115 S ROBINSON ST TEHACHAPI, CA 93561 Cities and Counties

THOUSAND OAKS CITY ATTORNEY CITY OF THOUSAND OAKS 2100 EAST THOUSDAN OAKS BLVD THOUSAND OAKS, CA 91362 Cities and Counties

THOUSAND OAKS CITY CLERK CITY OF THOUSAND OAKS 2100 THOUSAND OAKS BLVD. THOUSAND OAKS, CA 91362 Cities and Counties

TORRANCE CITY ATTORNEY 3031 TORRANCE BLVD. TORRANCE, CA 90503 Cities and Counties

TUOLUMNE COUNTY CLERK COUNTY OF TUOLUMNE 2 S. GREEN STREET TUOLUMNE, CA 95370 Cities and Counties

TWENTYNINE PALMS CITY ATTORNEY CITY OF TWENTYNINE PALMS 6136 ADOVE RD. TWENTYNINE PALMS, CA 92277 Cities and Counties

TWENTYNINE PALMS CITY CLERK CITY OF TWENTYNINE PALMS 6136 ADOBE RD. TWENTYNINE PALMS, CA 92277 Cities and Counties

UPLAND CITY ATTORNEY CITY OF UPLAND 460 N EUCLID AVE UPLAND, CA 91786 Cities and Counties

VERNON CITY ATTORNEY CITY OF VERNON 4305 SANTA FE AVE VERNON, CA 90058 Cities and Counties

VICTORVILLE CITY ATTORNEY 14343 CIVIC DRIVE VICTORVILLE, CA 92392 Cities and Counties

VISALIA CITY ATTORNEY CITY OF VISALIA 707 W ACEQUIA ST VASALIA, CA 93291 Cities and Counties

VISALIA CITY CLERK CITY OF VISALIA 707 W ACEQUIA ST. VISALIA, CA 93291 Cities and Counties

WEST COVINA CITY ATTORNEY CITY OF WEST COVINA 1444 W GARVEY AVE WEST COVINA, CA 91790 Cities and Counties

WESTMINSTER CITY ATTORNEY 8200 WESTMINSTER AVE WESTMINSTER, CA 92683 Cities and Counties

C-15

WESTMINSTER CITY CLERK 8200 WESTMINSTER AVENUE WESTMINSTER, CA 92683 Cities and Counties

WHITTIER CITY ATTORNEY 13230 PENN STREET WHITTIER, CA 90602 Cities and Counties

YORBA LINDA CITY ATTORNEY 4845 CASA LOMA AVENUE YORBA LINDA, CA 92686 Cities and Counties

YORBA LINDA CITY CLERK 4845 CASA LOMA AVE YORBA LINDA, CA 92686 Cities and Counties

YUCAIPA CITY ATTORNEY CITY OF YUCAIPA 34272 YUCAIPA BLVD YUCAIPA, CA 92399 Cities and Counties

YUCCA VALLEY CITY ATTORNEY CITY OF YUCCA VALLEY 57090 29 PALM HWY. YUCCA VALLEY, CA 92284 Cities and Counties

ARTESIA CITY ATTORNEY CITY OF ARTESIA 18747 CLARKDALE AVENUE ARTESIA, CA 90701 Cities and Counties

AVALON CITY CLERK CITY OF AVALON 209 METROPOLE AVENUE CITY HALL AVALON, CA 90704 Cities and Counties

AZUSA CITY CLERK CITY OF AZUSA 213 E FOOTHILL BLVD. CITY HALL AZUSA, CA 91702 Cities and Counties

BALDWIM PARK CITY ATTORNEY CITY OF BALDWIN PARK 14403 EAST PACIFIC AVENUE CITY HALL VALDWIN PARK, CA 91706 Cities and Counties

BALDWIN PARK CITY CLERK CITY OF BALDWIN PARK 14403 EAST PACIFIC AVENUE CITY HALL BALDWIN PARK, CA 91706 Cities and Counties

BANNING CITY ATTORNEY CITY OF BANNING 99 E RAMSEY STREET CITY HALL BANNING , CA 92220 Cities and Counties

BARSTOW CITY ATTORNEY CITY OF BARSTOW 220 EAST MT VIEW AVENUE CITY HALL BARSTOW, CA 92311 Cities and Counties

BEAUMONT CITY ATTORNEY CITY OF BEAUMONT 550 E 6TH STREET CITY HALL BEAUMONT, VA 92223 Cities and Counties

BEAUMONT CITY CLERK CITY OF BEAUMONT 550 E 6TH STREET CITY HALL BEAUMONT , CA 92223 Cities and Counties

BELL CITY ATTORNEY CITY OF BELL 6330PINE AVENUE CITY HALL BELL, CA 90201 Cities and Counties

BELL CITY CLERK CITY OF BELL 6330 PINE AVENUE CITY HALL BELL , CA 90201 Cities and Counties

BELL GARDENS CITY ATTORNEY CITY OF BELL GARDENS 7100 S GARFIELD AVENUE CITY HALL BELL GARDENS, CA 90201 Cities and Counties

C-16

BELLFLOWER CITY CLERK CITY OF BELLFLOWER 16600 CIVIC CENTER SR CITY HALL BELLFLOWER, CA 90706 Cities and Counties

BEVERLY HILLS CITY ATTORNEY CITY OF BEVERLY HILLS 455 N REXFORD DR CITY HALL BEVERLY HILLS, CA 90210 Cities and Counties

BISHOP CITY ATTORNEY CITY OF BISHOP CITY HALL PO BOX 1236 BISHOP, CA 93514 Cities and Counties

BISHOP CITY CLERK CITY OF BISHOP 377 W LINE STREET CITY CLERK BISHOP, CA 93514 Cities and Counties

BLYHTE CITY ATTORENY CITY OF BLYTHE 220 NORTH SPRING STREET CITY HALL BLYTHE, CA 92225 Cities and Counties

DAVID B BREARLEY ESQ CITY OF VERNON 2440 S HACIENDA BLVD UNIT 223 HACIENDA HEIGHTS, CA 91745 Cities and Counties

BUENA PARK CITY ATTORNEY CITY OF BUENA PARK 6650 BEACH BLVD CITY HALL BUENA PARK, CA 90620 Cities and Counties

BURBANK CITY ATTORNEY CITY OF BURBANK 275 E OLIVE AVENUE CITY HALL BURBANK, CA 91502 Cities and Counties

CALABASAS CITY ATTORNEY CITY OF CALABASAS 26135 MUREAU ROAD CITY HALL CALABASAS, CA 91302 Cities and Counties

CALIFORNIA CITY ATTORNEY CITY OF CALIFORNIA 21000 HACIENDA BLVD CITY HALL CALIFORNIA CITY, CA 93505 Cities and Counties

CALIMESA CITY ATTORNEY CITY OF CALIMESA 908 PARK AVENUE CALIMESA, CA 92320 Cities and Counties

CAMARILLO CITY ATTORNEY CITY OF CAMARILLO 601 CARMEN DRIVE CITY HALL CAMARILLO, CA 93010 Cities and Counties

CAMARILLO CITY CLERK CITY OF CAMARILLO 601 CARMEN DR CITY HALL CAMARILLO, CA 93010 Cities and Counties

CARPINTERIA CITY ATTORNEY CITY OF CARPINTERIA 5775 CARPINTERIA CITY HALL CITY HALL, CA 93013 Cities and Counties

CARPINTERIA CITY CLERK CITY OF CARPINTERIA 5775 CARPINTERIA AVENUE CITY HALL CARPINTERIA, CA 93013 Cities and Counties

CARSON CITY ATTORNEY CITY OF CARSON 701 EAST CARSON STREET CITY HALL CARSON, CA 90745-2257 Cities and Counties

CARSON CITY CLERK CITY OF CARSON 701 E CARSON STREET CITY HALL CARSON, CA 90745-2257 Cities and Counties

CHINO CITY ATTORNEY CITY OF CHINO 13220 CENTRAL AVENUE CITY HALL CHINO, CA 91710 Cities and Counties

C-17

CHINO HILLS CITY ATTORNEY CITY OF CHINO HILLS 2001 GRAND AVENUE CHINO HILLS, CA 91709 Cities and Counties

CHINO HILLS CITY CLERK CITY OF CHINO HILLS 2001 GRAND AVENUE CHINO HILLS, CA 92656 Cities and Counties

CLAREMONT CITY ATTORNEY CITY OF CLAREMONT 207 HARVARD AVENUE CITY HALL CLAREMONT, CA 91711 Cities and Counties

COLTON CITY ATTORNEY CITY OF COLTON 650 N. LA CADENA DRIVE COLTON, CA 92324 Cities and Counties

COMPTON CITY ATTORNEY CITY OF COMPTON 205 S WILLOEBROOK COMPTON, CA 90220 Cities and Counties

COMPTON CITY CLERK CITY OF COMPTON 205 S WILLOWBROOK AVE COMPTON, CA 90220 Cities and Counties

COSTA MESA CITY ATTORNEY CITY OF COSTA MESA 77 FAIR DRIVE COSTA MESA, CA 92626 Cities and Counties

COVINA CITY ATTORNEY CITY OF COVINA 125 EAST COLLEGE STREET COVINA, CA 91723 Cities and Counties

CUDAHY CITY ATTORNEY CITY OF CUDAHY 5240 SANTA ANA STREET CUDAHY, CA 90201 Cities and Counties

CULVER CITY ATTORNEY CITY OF CULVER CITY 9770 CULVER BLVD CULVER CITY, CA 90232 Cities and Counties

CYPRESS CITY ATTORNEY CITY OF CYPRESS 5275 ORANGE AVENUE CYPRESS, CA 90630 Cities and Counties

DELANO CITY ATTORNEY CITY OF DELANO 1015 11TH AVENUE DELANO, CA 93215 Cities and Counties

DIAMOND BAR CITY ATTORNEY CITY OF DIAMOND BAR 21865 E COPLET DR DIAMOND BAR, CA 91765 Cities and Counties

DIAMOND BAR CITY CLERK CITY OF DIAMOND BAR 21865 E COPLEY DR DIAMOND BAR, CA 91765 Cities and Counties

DUARTE CITY ATTORNEY 1600 HUNTINGTON DRIVE DUARTE, CA 91010 Cities and Counties

EL MONTE CITY ATTORNEY CITY OF EL MONTE 11333 VALLEY BLVD EL MONTE, CA 91731 Cities and Counties

EL MONTE CITY CLERK CITY OF EL MONTE 11333 VALLEY BLVD. EL MONTE, CA 91731 Cities and Counties

EL SEGUNDO CITY ATTORNEY 350 MAIN STREET EL SEGUNDO, CA 90245 Cities and Counties

C-18

EXETER CITY ATTORNEY CITY OF EXETER PO BOX 237 EXETER, CA 93221 Cities and Counties

FARMERSVILLE CITY ATTORNEY 147 EAST FRONT STREET FARMERSVILLE, CA 93223 Cities and Counties

FILLMORE CITY ATTORNEY CITY OF FILLMORE 250 CENTRAL AVENUE FILLMORE, CA 93015 Cities and Counties

FONTANA CITY ATTORNEY 8353 SIERRA AVENUE FONTANA, CA 92335 Cities and Counties

FOUNTAIN VALLEY CITY ATTORNEY 10200 SLATER AVENUE FOUNTAIN VALLEY, CA 92708 Cities and Counties

GARDEN GROVE CITY ATTORNEY CITY OF GARDEN GROVE 11300 STANFORD AVENUE GARDEN GROVE, CA 92640 Cities and Counties

GARDENA CITY ATTORNEY 1700 WEST 162ND STREET GARDENA, CA 90247 Cities and Counties

GLENDALE CITY ATTORNEY CITY OF GLENDALE 613 E BROADWAY GLENDALE, CA 91206 Cities and Counties

GLENDORA CITY ATTORNEY 116 EAST FOOTHILL BLVD GLENDORA, CA 91740 Cities and Counties

GRAND TERRACE CITY ATTORNEY 22795 BARTON ROAD GRAND TERRACE , CA 92324 Cities and Counties

HANFORD CITY ATTORNEY 400 NORTH DOUTY STREET HANFORD, CA 93230 Cities and Counties

HARFORD CITY CLERK 400 NORTH COUTY STREET HANFORD, CA 93230 Cities and Counties

HAWAIIAN GARDENS CITY ATTORNEY CITY OF HAWAIIAN GARDENS 21815 PIONEER BLVD HAWAIIAN GARDENS, CA 90716 Cities and Counties

HAWTHORNE CITY ATTORNEY CITY OF HAWTHORNE 4455 W 126TH STREET HAWTHORNE, CA 90250 Cities and Counties

AGOURA HILLS CITY ATTORNEY CITY OF AGOURA HILLS 30101 AGOURA COURT CITY HALL AGOURA HILLS, CA 91301 Cities and Counties

ALHAMBRA CITY CLERK CITY OF ALHAMBRA 111 SOUTH FIRST STREET ALHAMBRA, CA 91801 Cities and Counties

ARCADIA CITY ATTORNEY CITY OF ARCADIA 240 WEST HUNGTINGTON DRIVE CITY HALL ARCADIA, CA 91007 Cities and Counties

ADELANTO CITY ATTORNEY CITY OF ADELANTO 11600 AIR BASE ROAD ADELANTO, CA 92301 Cities and Counties

C-19

MAMMOTH LAKES TOWN ATTORNEY TOWN OF MAMMOTH LAKES MINARET MALL, OLD MAMMOTH RD. P.O. BOX 1609 MAMMOTH LAKES, CA 93546 Cities and Counties

ALISO VIEJO CITY ATTORNEY 12 JOURNEY ALISO VIEJO, CA 92656 Cities and Counties

HERMOSA BEACH CITY ATTORNEY CITY OF HERMOSA BEACH 1315 VALLEY DRIVE HERMOSA BEACH, CA 90254 Cities and Counties

WALNUT CITY ATTORNEY CITY OF WALNUT 21201 LA PUENTE ROAD WALNUT, CA 91789 Cities and Counties

RANCHO MIRAGE CITY CLERK RANCHO MIRAGE 69-825 HIGHWAY 111 RANCHO MIRAGE, CA 92270 Cities and Counties

INDUSTRY CITY ATTORNEY CITY OF INDUSTRY 15651 STAFFORD STREET INDUSTRY, CA 91744 Cities and Counties

INGLEWOOD CITY CLERK CITY OF INGLEWOOD ONE MANCHESTER BLVD. INGLEWOOD, CA 90301 Cities and Counties

INGLEWOOD CITY ATTORNEY CITY OF INGLEWOOD ONE MANCHESTER BLVD. INGELWOOD, CA 90301 Cities and Counties

PORT HUENEME CITY ATTORNEY PORT HUENEME 250 NORTH VENTURA ROAD PORT HUENEME, CA 93041 Cities and Counties

IRWINDALE CITY ATTORNEY CITY OF IRWINDALE 5050 NORTH IRWINDALE AVENUE IRWINDALE, CA 91706 Cities and Counties

COUNTY COUNSEL KINGS COUNTY 1400 W. LACEY BLVD. HANFORD, CA 93230 Cities and Counties

VILLA PARK ATTORNEY VILLA PARK 17855 SANTIAGO BLVD VILLA PARK, CA 92667 Cities and Counties

OFFICE OF THE ATTORNEY GENERAL STATE OF CALIFORNIA 1300 "I" STREET DEPARTMENT OF JUSTICE SACRAMENTO, CA 94244-2550 Cities and Counties

MISSION VIEJO CITY ATTORNEY CITY OF MISSION VIEJO 200 CIVIC CENTER MISSION VIEJO, CA 92691 Cities and Counties

COUNTY CLERK INYO COUNTY PO Drawer R INDEPENDENCE, CA 93526 Cities and Counties

DEPARTMENT OF GENERAL SERVICES STATE OF CALIFORNIA 707 Third Street SACRAMENTO, CA 95605 Cities and Counties

WESTLAKE VILLAGE CITY ATTORNEY CITY OF WESTLAKE VILLAGE 31200 OAK CREST DR. CITY OF WESTLAKE VILLAGE CITY HALL WESTLAKE VILLAGE, CA 91361 Cities and Counties

DOWNEY CITY ATTORNEY CITY OF DOWNEY 11111 BROOKSHIRE AVE DOWNEY, CA 90241 Cities and Counties

C-20

DOWNEY CITY CLERK CITY OF DOWNEY 11111 BROOKSHIR4E AVE DOWNEY, CA 90241 Cities and Counties

COUNTY COUNSEL SANTA BARBARA COUNTY 105 EAST ANAPAMU STREET SANTA BARBARA, CA 93101 Cities and Counties

COUNTY GOVERNMENT CENTER VENTURA COUNTY 800 S VICTORIA AVENUE COUNTY COUNSEL VENTURA, CA 93009 Cities and Counties

LA CANADA FLINTRIDGE CITY ATTORNEY CITY OF LA CANADA FLINTRIDGE 1327 Foothill Blvd LA CANADA FLINTRIDGE, CA 91011 Cities and Counties

CATHEDRAL CITY ATTORNEY 68-700 AVENIDA LALO GUERRERO CATHEDRAL CITY , CA 92234 Cities and Counties

LAGUNA HILLS CITY ATTORNEY CITY OF LAGUNA HILLS 24035 EL TORO RD LAGUNA HILLS, CA 92653 Cities and Counties

SAN BERNARDINO CITY ATTORNEY CITY OF SAN BERNARDINO 300 N. "D" ST. SAN BERNARDINO, CA 92418 Cities and Counties

CITY CLERK CITY OF TEMECULA 43200 Business Park Dr. Temecula City Hall TEMECULA, CA 92590 Cities and Counties

TEMECULA CITY ATTORNEY CITY OF TEMECULA 43200 Business Park Dr. Temecula City Hall TEMECULA CITY , CA 91780 Cities and Counties

SAN GABRIEL CITY CLERK 425 S. MISSION DRIVE SAN GABRIEL, CA 91776 Cities and Counties

SAN GABRIEL CITY ATORNEY 425 S. MISSION DRIVE SAN GABRIEL, CA 91776 Cities and Counties

RANCHO SANTA MARGARITA CITY OF RANCHO SANTA MARGARITA/CITY CLERK 22112 EL PASEO RANCHO SANTA MARGARITA, CA 92688 Cities and Counties

RIVERSIDE CITY ATTORNEY CITY OF RIVERSIDE 3900 MAIN STREET, 5TH FLOOR RIVERSIDE, CA 92522 Cities and Counties

PORTERVILLE CITY ATTORNEY CITY OF PORTERVILLE 291 N MAIN STREET CITY HALL PORTERVILLE, CA 93257 Cities and Counties

TEMPLE CITY ATTORNEY CITY OF TEMPLE CITY 9701 Las Tunas TEMPLE CITY, CA 91780-2113 Cities and Counties

MISSION VIEJO CITY CLERK CITY OF MISSION VIEJO 200 CIVIC CENTER MISSION VIEJO, CA 92691 Cities and Counties

WEST HOLLYWOOD CITY CLERK 8300 SANTA MONICA BLVD. WEST HOLLYWOOD, CA 90069 Cities and Counties

CORONA CITY ATTORNEY CITY OF CORONA 400 SOUTH VICENTIA AVENUE CORONA, CA 92882 Cities and Counties

Appendix D

SCE 2009-2011 Energy Efficiency Program Plan

Abbreviations & Acronyms

D-1

SCE 2009-2011 ENERGY EFFICIENCY PROGRAM PLAN ABBREVIATIONS & ACRONYMS

Abbreviation/Acronym Definition

AB 32 Assembly Bill 32 (Nunez, 2006)

AB 1103 Assembly Bill 1103 (Saldena, 2007)

AC Alternating Current

ACCA Air Conditioning Contractors of America

ACEEE American Council for an Energy Efficient Economy

ACR Assigned Commissioner Ruling

AERS Automatic Energy Review for Schools

AESC Alternative Energy Systems Consulting

Ag MSP Agricultural and Water Systems Market Segment Plan

AgEE Agricultural Energy Efficiency Program

AGTAC Agriculture Technology Application Center

AHP Advanced Home Program

AHRI Air Conditioning, Heating & Refrigeration Institute

AH-SCP Advanced Home Component of Sustainable Communities Program

AHU Air Handling Unit

AIA American Institute for Architects

ALJ Administrative Law Judge

AMI Advanced Metering Infrastructure

ANSI American National Standards Institute

AQMD Air Quality Management District

ARCA an appliance recycling company

ARP Appliance Recycling Program

D-2



ASHRAE American Society of Heating, Refrigeration, & Air Conditioning Engineers

ATP Authorization To Proceed

BAS Building Automation System

BBEES Big Bold Energy Efficiency Strategies

BCEP Business and Consumer Electronics Program

BCS Building Control System

BELP Beaumont Energy Leader Partnership

BIE Business Incentive Element

BIG Build It Green

BIS Business Incentives Services

BMS Building Controls Management Systems

BOC Building Operator Certification

BOMA Building Owners Management Association

BOMI Building Owners and Management Institution

BPI Building Performance Institute

BSC Building Standards Commission

BSE Business Services Element

BTU™ Building Tune Up

C&S Codes & Standards

CAC Central Air Conditioning

CALBO California Building Code Officials

CALMAC California Measurement Advisory Council

D-3



CANHP California New Homes Program

CARB California Air Resources Board

CARE California Alternate Rates for Energy

CASE Codes And Standards Enhancement

CASH Coalition for Adequate School Housing

CBIA California Building Industry Association

CBO Community Based Organization

CBPCA California Building Performance Contractors' Association

CCC California Community College

CDCR California Department of Corrections & Rehabilitation

CDE California Department of Education

CEC California Energy Commission

CEE Consortium for Energy Efficiency

CEEA California Energy Efficiency Alliance

CEESP California Energy Efficiency Strategic Plan

CEP Community Energy Partnership

CER Carbon Emission Reduction

CFA Call for Abstracts

CFL Compact Fluorescent Lamps

CHA California Hospital Association

CHEERS California Home Energy Efficiency Rating System

C-HERS California Home Energy Rating System

D-4



CHP California Highway Patrol

CHPD Comprehensive Home Performance Delivery

CHPP Comprehensive Home Performance Program

CHPS™ Collaborative for High Performance Schools

CHSA California Head Start Association

CIRB California Industry Research Board

CLEO Community Language Efficiency Outreach

CMHP Comprehensive Mobile Home Program

CNCQA Commercial New Construction Quality Assurance

CO Carbon Monoxide

CO2 Carbon Dioxide

COG Councils of Government

CPEEP California Preschool Energy Efficiency Program

CPUC California Public Utilities Commission

CRA Community Reinvestment Act

CRT Cathode-Ray Tube

CSHE California Society of Healthcare Engineering

CSI California Solar Initiative

CSLB California State Licensing Board

CSR Customer Service Representative

CSU California State University

CTAC Customer Technology Application Center

D-5



CTE Governor’s Career Technical Education Initiative

CVAG Coachella Valley Council of Governments

Cx Commission

DA Design Assistance

DAA Design Assistance Agreement

DCEEP Data Centers Energy Efficiency Program

DCELP Desert Cities Energy Leader Partnership

DCOP Data Center Optimization Program

DCV Demand Control Ventilation

DDC Direct Digital Control

DEER Database for Energy Efficiency Resources

DG Direct Generation

DGS Department of General Services

DHW Domestic Hot Water

DMA Dominant Market Area

DMV Department of Motor Vehicles

DOE Department Of Energy

DOF Department of Finance

DR Demand Response

DRA Division of Ratepayer Advocates

DSA Department of State Architects

DSM Demand Side Management

D-6



DTI Design Team Incentive

E3 Energy and Environmental Economics, Inc.

EAP Emergency Action Plan

EARTH Educate Action Responsibility Teamwork Home

EDR Energy Design Resources

EE Energy Efficiency

EEM Energy Efficiency Measure

EEMIS Enterprise Energy Management Information System

EEPAM Energy Efficiency Programs Adjustment Mechanism

EL Energy Leader

ELP Energy Leader Partnership

EM&V Evaluation, Measurement & Verification

EMD Energy Management Division

EMS Energy Management System

EP Efficiency Partnership

EP&QA Engineering, Planning And Quality Assurance

EPA Environmental Protection Agency

ERP Enterprise Resource Planning

ERRA Energy Resource Recovery Account

ESCO Energy Services Company

ESELP Eastern Sierra Energy Leader Partnership

ESP Electrical Service Planning

D-7



ESPC Energy Savings Performance Contract

ET Emerging Technologies

ETCC Emerging Technology Coordinating Council

ETP Emerging Technologies Program

ETTC Energy Technology Test Centers

EUL Expected Useful Lives

FBO Faith Based Organization

FDD Fault Detection and Diagnostics

FERA Family Electric Rate Assistance

FSE Financial Solutions Element

FSTC Food Service Technology Center

FYP Flex Your Power™

G&I Government & Institutional

GBAP Green Building Action Plan

GBI Green Building Initiative

GDP Gross Domestic Product

GHG Greenhouse Gas

GWh Gigawatt Hour

HAN Home Area Network

HCD Housing and Community Development

HEEP Healthcare Energy Efficiency Program

HEER Home Energy Efficiency Rebates

D-8



HEERP Home Energy Efficiency Rebate Program

HEES Home Energy Efficiency Survey Program

HERS Home Energy Rating Scale

HID High-Intensity Discharge

HSEF High Sierra Energy Foundation

HSEI High Sierra Energy Initiative

HUD Housing and Urban Development

HVAC Heating, Ventilation and Air Conditioning

ICLEI Local Governments for Sustainability (formerly the International Council for Local Environmental Initiatives)

ICLS Integrated Classroom Lighting System

IDEEA Innovative Design for Energy Efficiency Activities

IDSM Integrated Demand Side Management

IEPR Integrated Energy Policy Report

IFMA International Facility Management Association

IGA Investment Grade Audits

IGREEN Institutional and Government Resource for Energy Efficiency Now

IHACI Institute for Heating & Air Conditioning Industries

IID Imperial Irrigation District

IndEE Innovative Designs for Energy Efficiency

IOU Investor-Owned Utility

ISD Internal Services Department

D-9



ISO Independent System Operator

ITP Industrial Technology Program

JACO an appliance recycling company

JLC Journey of Light Construction

KCEWP Kern County Energy Watch Partnership

KEEP Kern Environmental Education Program

KEMA Energy-efficiency consultant

kW kilowatt

kWh kilowatt hour

LACMTA Los Angeles County Metropolitan Transportation Authority

LACOE Los Angeles County Office of Education

LADWP Los Angeles Department of Water and Power

LAUSD Los Angeles Unified School District

LBELP Long Beach Energy Leader Partnership

LCD Liquid Crystal Display

LED Light Emitting Diode

LEED™ Leadership in Energy and Environmental Design

LGI Local Government Initiative

LGP Local Government Partnership

LIEE Low Income Energy Efficiency

M&V Measurement & Verification

MAP Management Affiliates Program

MBCx Monitoring-Based Commissioning

D-10



MBPCx Monitoring-Based Persistence Commissioning Program

MDx Measure Database

ME&O Marketing, Education & Outreach

MEU Mobile Energy Unit

MFEER Multi-Family Energy Efficiency Rebate Program

MOU Memorandum of Understanding

MPS Master Production Scheduling

MSP Market Segment Plans

MT Market Transformation

MW Megawatt

MWD Metropolitan Water District

MWh Megawatt Hour

NAHB National Association of Homebuilders

NAICS North American Industry Classification System

NARI National Association of the Remodeling Industry

NATE North American Technician Excellence

NCS New Construction Services

NEEP Northeast Energy Efficiency Partnerships

NGO Non-Government Organization

NOx Mono-Nitrogen Oxides (NO and NO2)

NR Non-Residential

NSHP New Solar Homes Partnership

D-11



NTG Net-to-Gross Ratios

O&M Operations & Maintenance

OBF On-Bill Financing

OCCELP Orange County Cities Energy Leader Partnership

OSHPD Office of Statewide Health Planning & Development

PAC Program Administrator Cost

PAG Program Advisory Group

PC Personal Computer

PCEESP Preliminary California Energy Efficiency Strategic Plan

PCHEER Private College Campus Housing Energy Efficiency Program

PD Peak Demand

PDA Personal Digital Assistant

PEAK Peak demand for energy usage

PEARL Program for Evaluation and Analysis of Residential Lighting

PEB Performance Earnings Basis

PEEBA Procurement Energy Efficiency Balancing Account

PEESP Preliminary Energy Efficiency Strategic Plan

PEPMA Proposal Evaluation and Proposal Management Application

PG&E Pacific Gas & Electric

PGC Public Goods Charge

PIER Public Interest Energy Research

PIP Program Implementation Plans

D-12



PLEP Plug Load Efficiency Program

PM10 Particulate Matter of 10 micrometers or less

PO Purchase Order

POS Point-of-Sale

PPPAM Public Purpose Programs Adjustment Mechanism

PPPC Public Purpose Programs Charge

PRG Peer Review Group

PTAC Packaged Terminal Air Conditioner

PU Public Utilities

PV Photovoltaic

QA Quality Assurance

QC Quality Control

QI Quality Installation

QM Quality Maintenance

R&D Research & Development

RCA Refrigerant Charge Adjustment

RCC Resource Conservation Commission

RCx Retro-commissioning

RD&D Research, Development and Demonstration (or Deployment)

RELP Ridgecrest Energy Leader Partnership

RETA Refrigeration And Technical Engineering

RFP Requests for Proposals

D-13



RFQ Request for Qualifications

RLW Roger L. Wright Analytics, a consulting firm

RMSP Residential Market Segmentation Plan

ROI Return On Investment

RP&A Regulatory Policy and Affairs

RS&E Runyon, Saltzman, & Einhorn

SA Systems Approach

SAELP Santa Ana Energy Leader Partnership

SAS Statistical Analysis System

SBCCOG South Bay Cities Council Of Governments

SBD Savings By Design

SBELP South Bay Energy Leader Partnership

SCE Southern California Edison

SCELP South County Energy Leader Partnership

SCG Southern California Gas

SCP Sustainable Communities Program

SDG&E San Diego Gas and Electric

SEAT Student Energy Audit Training

SEER Seasonal Energy Efficiency Rating

SEP Strategic Energy Plan

SGELP South Gate Energy Leader Partnership

SGIP Self Generation Incentive Program

D-14



SJVCEO San Joaquin Valley Clean Energy Coalition

SJVELP San Joaquin Valley Energy Leader Partnership

SM Energy $mart

SMART Subcontractor Management And Reporting Tool

SMUD Sacramento Municipal Utilities District

SOW Statement of Work

SPA Simplified Approach for Small Projects

SPB Simple Payback

SPC Standard Performance Contract

SPEED Statewide Partnership for Energy Efficiency Demonstrations

SVELP Simi Valley Energy Leader Partnership

SW Statewide

T5 CFL size

T8 CFL size

T12 CFL size

T&D Transmission & Distribution

T&E Training & Education

TA Technical Assistance

TBD To Be Determined

TDV Time Dependent Valuation

TI Technical Incentive

TRC Total Resource Cost

D-15



TRIO Technology Resource Incubator Outreach

TTC Technology and Test Center

UC University of California

UCOP University of California Office of the President

UESCO Utility Energy Services Contracts

UPS Uninterruptible Power Source

USA United States of America

USGBC United States Global Business Council

USGBC United States Green Building Council

VAC Volts-Alternating Current

VAV Variable Air Volume

VCELP Ventura County Energy Leader Partnership

VCREA Ventura County Regional Energy Alliance

VEA Voluntary Early Actions

VFD Variable Frequency Drive

VSD Variable Speed Drive

WBA Whole Building Approach

WE&T Workforce Education & Training

ZNE Zero Net Energy

CERTIFICATE OF SERVICE

I hereby certify that, pursuant to the Commission’s Rules of Practice and Procedure, I

have this day served a true copy of APPLICATION OF SOUTHERN CALIFORNIA EDISON

COMPANY (U 338-E) FOR APPROVAL OF ITS 2009-2011 ENERGY EFFICIENCY

PROGRAM PLANS AND PUBLIC GOODS CHARGE AND PROCUREMENT FUNDING

REQUESTS on all parties identified on the attached service list(s). Service was effected by one

or more means indicated below:

Transmitting the copies via e-mail to all parties who have provided an e-mail address.

First class mail will be used if electronic service cannot be effectuated.

Executed this 21st day of July, 2008, at Rosemead, California.

/s/ JENNIFER ALDERETE________________________ Jennifer Alderete Project Analyst SOUTHERN CALIFORNIA EDISON COMPANY

2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770

Documents

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE … · LAW-#1493051 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA ... 73 (10) Private College Campus Housing Energy