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CPUC Energy Efficiency Policies and Investor-Owned Utility (IOU)
Programs
Presentation for WHPA Executive CommitteeMarch 26, 2013
Simon BakerEnergy Division
California Public Utilities Commission (CPUC)
Presentation Outline• Overview of California EE Policy Framework• Overview of IOU programs• Cost-Effectiveness• Goals• EM&V• Ex-ante / ex-post• Shareholder incentives• Appendices
2
Overview of California EE Policy Framework
3
4
U.S. Energy Use Grows While California Usage Remains Flat
0
2,000
4,000
6,000
8,000
10,000
12,000
14,000
1960
1962
1964
1966
1968
1970
1972
1974
1976
1978
1980
1982
1984
1986
1988
1990
1992
1994
1996
1998
2000
2002
kWh/
pers
on
Per Capita Electricity Sales (not including self-generation)(kWh/person)
United States
California
California w/out stdsand programs
CA Power Plant Capacity Increased by only 2/3 the National Pace in the Past 20 Years
Location 1990 # of Generators
1990 Nameplate capacity (MW)
2010 # of generators
2010 Nameplate capacity (MW)
Percent capacity change
California 739 55,026 803 72,570 31.9%
United States
5318 783,012 6,417 1,138,638 45.4%
5Source: U.S. Energy Information Administration, see http://www.eia.gov/electricity/data/state/
California EE / Conservation “Wedges”
Decouplingfor gas
Deregulated market begins; CPUC contemplates independent administration
ElectricityCrisis
EAP / AB 57 makes EE a top IOU priority
SB 1037 requires CPUC to set targets for “all cost‐effective EE” IOU administration of EE
restored; new incentive mechanism; CPUC evaluation of IOU program accomplishments
Policy Influences EE Savings Among California Utilities
Decouplingfor electric
Source: Natural Resources Defense Council (NRDC), as modified by Energy Division 12/2012
IOU EE programs begin to decline due to over‐supply
ShareholderIncentives begin
CPUC administration of EE (“Summer Initiative” continues thru 2003)
CPUC‐evaluated
IOU‐reported
MT eraResource Acquisitions era
Energy Efficiency is California’s Preferred Resource
West Coast Green
8
“Loading Order” of Energy Resources:
• Energy efficiency and Demand response
• Distributed generation
• Renewable generation
• Cleanest available fossil resources
California Long-Term Energy Efficiency Strategic Plan• 2007: CPUC adopts Big Bold Energy
Efficiency Strategies:1. All new residential construction will be zero net energy
(ZNE) by 20202. All new commercial construction in California will be
zero net energy by 20303. HVAC market will be transformed to ensure that its
energy performance is optimal 4. All eligible low-income customers will be given the
opportunity to participate in ESAP by 2020.
• 2007: CPUC orders a Strategic Plan to achieve “all cost-effective energy efficiency.”
• 2008: CPUC adopts the Strategic Plan – A roadmap for EE through 2020 and beyond
• 2009: CPUC approves IOU programs shaped by the Strategic Plan
• Action Plans to engage non-utility entities 9
AB 32: California’s Greenhouse Gas Emission Reduction Strategies
10California Air Resources Board Scoping Plan, December 2008, Table 2.
CPUC Role in Governing IOU Energy Efficiency Programs
• CPUC– Regulates investor-owned utilities (IOUs)– Sets rates, determines revenue requirement– Oversees IOU EE budgets and plans
• Per 2005 decision, IOUs administer EE programs approved by CPUC– Beginning in 2006, Commission staff (Energy
Division) evaluate IOU programs
11
CPUC Statutory Mandates• Foundational mandates
– “Just and reasonable” rates – PU Code 451– “All practicable and cost-effective” conservation / EE – PU Code
701(b)• More recent provisions
– “All cost-effective EE” - PU Code Sections 454.5.(b)(9)(C) (“loading order” / electric EE procurement provision)
– Set EE goals based on “all cost-effective EE” - PU Code 454.55 (electric) and 454.56 (gas)
– Electric PGC surcharge – PU Code 381 and 399 (now expired)– Natural Gas PPP surcharge – PU Code 890-899 (no sunset)
12
CPUC policy emphasis focused on voluntary market
Historical Agency Emphasis / Mandates
ExampleIOU Programs
Funding Sources for Mainstream IOU Energy Efficiency Programs
Slide
- 200 400 600 800
EnergyProcurement
Electric PGC
Gas PPP
$ Millions
$175
$256
$576
17%
25%
57%
2010-2012 Avg Annual EE Budget by Funding Source (Total ~ $1 billion)
2013-14 Avg Annual BudgetTotal ~$950 million
$774
$-
$177
$- $200 $400 $600 $800
Energy Procurement
Electric PGC
Gas PPP
$ Million
17%
83%
Overview of IOU EE Programs
15
Key IOU Progam DesignRequirements / Incentives
16
“Sticks”: Legislative Requirements
• Portfolio budgets must be reviewed and approved by Commission
• IOUs must meet energy savings goals
• Portfolio must be cost effective
• Programs must meet the requirements of the portfolio guidance decision and pursue Strategic Plan objectives
• 20% of budget must be competitively bid by third party implementers
“Carrots”: Utility Benefits
• Shareholder incentives
• Customer satisfaction
• “Green” corporation
17
CPUC Process for Approval / Oversight of IOU EE Programs
• Multi-Year Budget Cycle
• Transition cycle: 2013-2014• Next cycle: Post-2014
Policy Guidance
•Savings Potential / Goals•Portfolio cost effectiveness•Shareholder Incentives•20% Third-party •Strategic Plan / programmatic guidance
IOU Portfolio Applications
•Must meet savings goals•Budgets / Cost-effectiveness
•Alignment withStrategic Plan
Portfolio Implementation
•IOU Administration•Energy Division EM&V/ program implementation oversight
CPUC Regulatory Proceedings*• Formal Proceedings
– Rulemakings (R.) – generally treat policy matters. Active EE rulemakings:
• R.09-11-014 – e.g. 2013-14 guidance decision• R.12- - Shareholder incentive reforms
– Applications (A.) – IOU requests for budget authorization and rate recovery.
• A.12-07-001 – 2013-14 EE portfolio decision• Program Implementation Plans (PIPs) contain program details
(incentive design, logic model, program targets, measure lists, etc.)• Informal Proceedings (advice letters) – “Implementation” filings
directed by CPUC decision (e.g., AL for Res upstream HVAC incentive program)
– Energy Division disposition– Commission disposition (resolution)
18*This is a selected list of Commission proceedings applicable to EE program administration, not intended to be a comprehensive description of CPUC practice and procedure.
Mid-cycle Implementation Oversight Processes• Utility reporting of expenditures / savings claims
– Monthly and annual reports – Available at Energy Efficiency Groupware Application (EEGA)
(www.eega.cpuc.ca.gov) • Program Implementation Plan (PIP) “addendum”
– IOUs may modify incentive design, measure lists, etc. – Must notify / report via PIP addendum upload on EEGA
• Fund-shifting rules– Fund-shifting in excess of 15% of approved budget category between
specified program categories (e.g., residential, commercial) must seek approval by AL
– Fund-shifting within program categories or between program categories under the 15% threshold is authorized without AL approval. Must report on EEGA.
• ALs implementing Commission orders (e.g., compliance filings, new pilots)
19
Post-2014 Planning Activities*
• Post-2014 portfolio guidance:– Various rulings / proposals for comment
• Goals study (est. Q2 2013)• CEC AB 758 action plan (est. Q2 2013)• Programmatic guidance ruling(s) / proposals (est. Q2 2013)• Cost-Effectiveness parameter / methodology update (est. mid
2013)• DEER update based on 2010-12 impact evaluations (est. Q3
2013)
– Guidance decision (est. Q4 2013)• IOU applications (est. Q1 2014)
20*Based on Energy Division estimates of anticipated Commission proceedings
“RecordDevelopment”
Of particular interest to HVAC programs
BY PROGRAM TYPE BY PROGRAM DELIVERYBY SECTOR
Budget($ M)
Savings (GWh)
Agricultural 79 248
Commercial 510 1,112
Industrial 211 487
Residential 328 571
Govt Partnerships 256 267
Cross Cutting 585 1,019
Budget ($ M)
Savings (GWh)
Statewide 1,166 2,027
Third Party 538 1,408
Gov't partnership 252 267
RENs/CCA 75 98
Local IOU 13 2
Slide 21
Budget ($M)
Savings (GWh)
Codes and Standards 28 870 Third Party Programs 304 679 Non‐Residential Custom Projects 265 647 Government Partnerships 256 267 Lighting Programs 228 890 Financing Programs 190 109 HVAC 140 221 Plug Load and Appliances 104 229 Energy Advisor Program 100 295 Whole House Program 80 25 Non‐Res Deemed Incentives 64 224 New Construction 35 6 Direct Install 21 41 Multi Family Rebates 17 62 RENs and CCAs 75 98 Workforce Education & Training 63 7 Emerging Technology Programs 39 0 Continuous Energy Improvement 14 0 Marketing, Outreach & Education 14 0 IDSM 8 0
EE Program Characteristics*
*Data from 2013-14 Portfolio Applications. Approved budget was reduced by $200 million
22
2013-14 EE Portfolio Organization
IOU StatewidePrograms
[62% of budget]
•Residential•Commercial•Industrial•Agricultural
•Lighting•Financing•Emerging Technologies•Codes & Standards
•ME&O*•WE&T•IDSM
Utility “Local” Programs [1%]
Third-Party Programs [25%]
State & Local Gov’t Programs [10%]
SDG&E (9) PG&E (40)
SCE (29)
SDG&E (13)
SCG (15)
PG&E (24)
SCE (30)
SDG&E (7)
SCG (20)
[%] = Percent of total budget ($1.9B Total)(#) = Number of individual programs* ME&O budgets are currently pending in an application before Commission
SoCalREN($44.8M)
BayREN($26.5M)
MEA($4M)
Community Choice Aggregator
Regional Energy Networks
IOU Portfolio[92% of budget]
Non-Utility Portfolio[4% of budget]
Evaluation[4% of budget]
23
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
Sum of Two Year Budget Sum of 2013-14 kWhTotal
Sum of 2013-14 thermTotal
Integrated Demand Side ManagementMarketing, Outreach and EducationContinuous Energy ImprovementEmerging Technology ProgramsWorkforce Education & TrainingRENs and CCAsMulti Family RebatesDirect InstallNew ConstructionNon-Res Deemed IncentivesWhole House ProgramEnergy Advisor ProgramPlug Load and AppliancesHeating, Ventilation & Air ConditioningFinancing ProgramsLighting ProgramsGovernment PartnershipsNon-Residential Custom ProjectsThird Party ProgramsCodes and Standards
2013-14 IOU Programs: Budget and Savings
Budget Electric (kWh)Savings
Gas (therm)Savings
New Strategic Program DirectionNew “Strategic” Programs• Financing (OBF, new pilots)• Whole-house retrofit• HVAC QI / QM• Behavior (OPower energy
reports)• Integrated (EE/DR/DG) on-line
audits• Retro-commissioning• Continuous Energy
Improvement• ZNE pilots• LGP SP pilots
Continuing Programs• “Widget” rebates ($/widget)• Calculated rebates ($/kwh,
$/them)• “Upstream” mfr / distributor
buy-down• New construction• Direct install• State & institutional
partnerships
24
2013-14 HVAC ProgramsHVAC Programs• Statewide “Core” Programs
– Commercial Upstream HVAC Equipment Incentive
– Commercial QI / QM– Residential QI / QM
• Third Party Programs– PG&E AirCare Plus– SDG&E Premium Efficiency
Programs (Silver, Gold and Platinum)
• New programs or “pilots”– Residential Upstream HVAC
Equipment Incentive – Residential “to Code” incentive
program.
Related Programs• Codes and standards (includes
standards advocacy, compliance enhancement)
• Whole-house retrofit (basic and advanced)
• Emerging technologies program (includes HVAC tech & diagnostics R&D)
• Workforce education and training (“sector strategies”)
25
Cost-Effectiveness
26
CPUC determines EE cost-effectiveness at the portfolio-level and on a “net” basis
• Portfolio approach allows for inclusion of individual programs or measures that do not past cost test (EUC, ETP, new construction, etc.)
• Prospective “dual test” showing examines both TRC and PAC• Commission determines actual TRC threshold deemed sufficient 27
Energy Efficiency PortfolioTRC = 2.0
ResidentialAppliance Program
TRC = 1.8
NewConstruction
ProgramTRC = 1.2
CommercialLightingProgram
TRC = 3.4
Mea
sure
s
TRC>1 TRC<1Legend:
Low-IncomeProgram
TRC = 0.8Pro
gram
sP
ortfo
lioEnergy Efficiency Portfolio
TRC = 2.0
ResidentialAppliance Program
TRC = 1.8
NewConstruction
ProgramTRC = 1.2
CommercialLightingProgram
TRC = 3.4
Mea
sure
s
TRC>1 TRC<1Legend:
Low-IncomeProgram
TRC = 0.8Pro
gram
sP
ortfo
lio
28
0
1
2
3
4
5
6
7
8
9
10
11
Benefit-Cost Ratios 2010-2011 EE Portfolio Savings Claims*
Cost Effective >1.0
*Source: 2010-11 Annual Energy Efficiency Progress Report**Total Resource Cost (TRC) test – See Appendix
TRC**(Gross)
Utility programs ranked by cost-effectiveness
Cost-effectiveness “frontiers”1. Market effects (a.k.a. “spill-over) - Savings that results when program participants
and/or nonparticipants adopt measures without obtaining any customer incentive as a result of some exposure to the incentive programs.
- Current methods generally do not quantify market effects (Note: 2013-14 portfolio decision approved a 5% portfolio-wide adder for spill-over)
– Difficult to quantify / demonstrate with certainty– Inclusion of market effects is well within statutory mandates
2. Non-energy benefits (NEBs)− Other than GHG benefits, current EE cost-effectiveness tests do not include the
value of societal NEBs (e.g., job creation, labor productivity, tax receipts growth, housing value, other env benefits)
− Participant NEBs (e.g., comfort, health, and safety) are accounted for in the NTG methodology, which allocated participant costs and benefits according to these influence factors.
– Difficult to quantify / demonstrate with certainty– Statutory mandates for authorizing ratepayer-funded EE programs address
energy savings, system reliability, and environmental benefits (not other societal NEBs).
29
EE Goals
30
31
IOUs must achieve All Cost-Effective EE:
•PUC Sec 454.5 requires that IOUs “meet unmet resource needs with all available EE and demand reduction that is cost-effective, reliable, and feasible.”
•PUC Sec 454.55 / 454.56 requires CPUC to establish targets for the IOUs to achieve all cost-effective electric / gas EE
EE is at the top of the “Loading Order”
How EE goals are set
Assessment of total energy savings
available by end use and sector, relative to the baseline of existing
energy uses
Potential Study
Assessment of cost‐effective EE potential available
Economic Potential
Technical Potential
2013‐14 Goals & Targets
Market Potential
DEER and non‐DEER work papers
Avoided Cost Calculator Outputs
Willingness/ Awareness
data
Goals StudyPotential study update (ET) + C&S savings update +Financing model +Strategic Plan initiatives
Attribution AnalysisScenario Analysis
C&S Savings model
for post-2014 planning…
IOU EE Program Goals and Results, 2002-09
Potential Study: Major Shift of Market Potential into Codes & Standards
0
5000
10000
15000
20000
25000
2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020
Residential Commercial Industrial Agricultural Behavioral Codes and Standards34
Source: Navigant, 2011 Potential Study
GW
h
Potential Study: CFL Market Potential, once available to IOU Programs, now transitioning into code
0
500
1,000
1,500
2,000
2,500
2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024
GWh
Food Service
Whole building
Water Heating
Building Envelope
Refrigeration
Laundry
Other
Outdoor Lighting
Low Income
Plug Loads
Ag/Ind Process
HVAC
Appliance
Indoor Lighting
35Source: Navigant, 2011 Potential Study
2013 Potential by Measure Type
- 50 100 150 200 250 300 350 400
Water Heating
Boiler
Whole Building
Building Envelope
Food Service
Appliance
Low Income
Plug Load
Other
Refrigeration
Outdoor Lighting
HVAC
Process
Indoor Lighting
Evaluation Measurement and Verification (EM&V)
37
38
Application of EM&V results to future portfolio design
•Updating program planning values in order to create more accurate ex‐ante projections of likely savings in the next program cycle
•Making procurement demand forecast estimates more accurate
Increasing reliability of future savings estimates
•Providing performance information to program administrators•Identifying measures that are not cost‐effective for removal or reduction in the portfolios
•Improving program processes and implementation so delivery inefficiencies are reduced or eliminated
•Developing feedback on new programs or measures for which good data does not yet exist
Improving program efficacy
•Assessing the potential for remaining energy savings•Monitoring changing market conditions to inform program design•Constructing trend data on target markets for use in strategic planning and guidance for the next cycle
Providing market feedback
38
39
EE Evaluation, Measurement and Verification (EM&V) “101”
• Impact Evaluation is used to verify energy savings through field research. Key aspects investigated are:
– Installation Rates (How many units got installed?)– Unit Energy Savings (What savings were achieved?) –Factors include
baseline, expected life, operating hours, peak time effects)– Program influence or Attribution (To what extent did the program cause
the action?) -- Compared to other motivating factors, such as natural market changes, vendor advertising, price effects, environmental effects, etc.?)
• Lessons Learned are applied to future program designs & implementation strategies, including:
– Updated energy savings expectations– Insight into customer segments with highest savings potential– Profiles of customers unlikely to take action without utility program
facilitation
40
Net To Gross (NTG) Ratio• Cost-effectiveness is determined on a “net” savings basis
– Net energy savings = gross savings * NTG
– Historical program average NTG = 0.7
• Key factors addressed include:
Free Riders “Market effects” / Spillover Underlying participant motivations (including non-energy benefits) Installation Rate
May also address (though current CPUC evaluations do not) Persistence/Failure Rebound / Take Back Effect
• Impact evaluations assess NTG ratios and inform planning parameter updates (DEER, etc.)
Ex Ante / Ex Post
41
Ex Ante vs. Ex post Savings Estimates
Ex Ante• Estimate of likely energy savings
before a measure is installed based on predictions of average operating conditions and baseline usage
• Basis for utility savings claims• Used as the basis for 2006-08/09
shareholder incentive payments, under revised CPUC policy
• Ex ante review (EAR) processes for (a) custom and (b) deemed (DEER and non-DEER)
Ex Post• Estimates of "actual" energy savings
based on onsite measurements, energy billing analysis, and other types of data collection.
• Energy Division evaluated values• Contemplated as the basis for 2006-08
shareholder incentives per original CPUC policy
• Evaluated values inform:– Assessments of program accomplishments
(evaluation reports)– Forecasts of savings potential for the next
program cycle (the new ex-ante)
42
***Both require counterfactual assumption of what would have happened in the absence of the program***
Ex Ante Review Process• Deemed
– DEER – Database “common measures” • Periodic updates by Commission decision to incorporate “best available
information” from evaluation research
– Non-DEER – Measures or tools not captured in DEER• Based on “best available information” and extrapolations from DEER values
and/or methods, as appropriate• IOUs submit work papers for Energy Division review • Energy Division selects some subset for review; releases “dispositions” with
adjusted values, as appropriate.
• Custom– IOUs post a list of projects for Energy Division to sample– Energy Division selects a subset of projects for review; modifies parameter
assumptions savings, as deemed reasonable– 0.9 Gross Realization Rate for any projects not selected for review– Dispositions may include adjustments to modeling tools (e.g., EnergyPro for
whole-house retrofit advanced path program) 43
Shareholder Incentives
44
Recent Shareholder Incentives• 2006-08 mechanism
– Shared savings rate based on goals accomplishment– Performance basis based on ex post net benefits
• 2006-08 / 09 payments based on ex ante• 2010-12 mechanism
– Management fee with performance bonus tied to ex ante review
• 2013-14 - Pending
45
Energy Division Organizational Chart and
Staffing
46
47
Energy Division Staffing of Demand-Side Management Group
Integrated Demand-Side Analysis(EE, ESAP, DR, DG)
Supervisor: Jaclyn Marks
Retail Rate Design
Supervisor: Paul Phillips
Demand-side Evaluation(EE, ESAP, DR, DG)
Supervisor: Carmen Best
Residential Programs(EE, ESAP, DR)
Supervisor: Hazlyn Fortune
Non-Residential Programs(EE, DR)
Supervisor: Bruce Kaneshiro
Customer Generation Programs(DG)
Supervisor: Melicia Charles
Demand-Side AnalysisBranch
Manager: Pete Skala
Demand-Side ProgramsBranch
Manager: Simon Baker
17 EE Positions
ESAP = Energy Savings Assistance ProgramDR = Demand ResponseDG = Distributed Generation (CSI Solar & SGIP)
EE-RelatedSections
Thank You
More information:http://www.cpuc.ca.gov/PUC/energy/Energy+Efficiency/
48
Appendices
• Evaluation Reports Available to the Public• Cost-Effectiveness Tests
49
Evaluation Reports Available to the Public
50
2010-2011 Energy Efficiency Progress and Evaluation Report Interim report on progress toward goals, savings, and cost effectiveness by sector on the energy efficiency portfolio. The data contained in the report is based on IOU reported savings not evaluation –verified savings. The report summarizes key findings from recent evaluations and links to full reports. Author: Energy Division (hereafter ED). Date: August 2012Link: http://www.cpuc.ca.gov/NR/rdonlyres/89718A1B-C3D5-4E30-9A82-74ED155D0485/0/EnergyEfficiencyEvaluationReport.pdf
2009 Energy Efficiency Evaluation Report Final report on achievement of goals, savings, and cost effectiveness statewide and by IOU for the 2009 bridge funding year. The data contained in the report is based on evaluation based values from the 2006-2008 evaluation work. Author: ED. Date: January 2011Link: http://www.cpuc.ca.gov/NR/rdonlyres/D66CCF63-5786-49C7-B250-
00675D91953C/0/EEEvaluationReportforthe2009BFPeriod.pdf
2006-2008 Energy Efficiency Evaluation Report Final report on achievement of goals, savings, and cost effectiveness statewide and by IOU for the 2006-2008 program cycle. The data contained in the report is based on data gathered from field based evaluations and review of the operating conditions for the portfolio. Author: ED. Date: July 2010Link: ftp://ftp.cpuc.ca.gov/gopher-data/energy%20efficiency/2006-2008%20Energy%20Efficiency%20Evaluation%20Report%20-%20Full.pdf
2002-2003 Meta Evaluation ReportFinal report the evaluation results and methods used in the 2002-2003 program cycle by the IOUs and their contractors. A summary of the total evaluation adjusted savings for the portfolio is included in the report and supporting data also summarizes the savings reported and evaluated for all programs that were evaluated. Author: TecMarket Works. Date: January 2006Link: http://www.calmac.org/publications/MECT02-03FinalReport.pdf
Cost-Effectiveness Tests
52
53
Standard Practice Manual (SPM) Cost TestsCost Test Key Question Answered Summary Approach
Total Resource Cost
TRC Will the total costs of energy in the utility service territory decrease?
Comparison of program administrator and customer costs to utility resource savings
Participant Cost Test
PCT Will the participants benefit over the measure life?
Comparison of costs and benefits of the customer installing the measure
Utility/Program Administrator Cost Test
UCT/PAC
Will utility bills increase? Comparison of program administrator costs to supply side resource costs
Ratepayer Impact Measure
RIM Will utility rates increase? Comparison of administrator costs and utility bill reductions to supply side resource costs
Societal Cost Test
SCT Is the utility, state, or nation better off as a whole?
Comparison of society’s costs of energy efficiency to resource savings and non-cash costs and benefits
54
Summary of Costs and BenefitsComponent TRC PCT PAC RIM
Energy and capacity Benefit - Benefit Benefit
Additional resource savings Benefit - - -
Non-monetized benefits - - -
Equipment and install costs Cost Cost - -
Program overhead costs Cost - Cost Cost
Incentive payments - Benefit Cost Cost
Bill Savings - Benefit Cost
Total Resource Cost Test
55
• Energy
• Capacity
• T&D
• GHG
• Losses
• RPS Purchases
• O&M Savings
• Other Resource Benefits
• Equipment Costs
• O&M Costs
• Admin & Overhead Costs
• EM&V
Benefits Costs
Net Benefits to Region as a Whole?
Incentives
Bill Savings
NOT INCLUDED
Program Administrator Cost Test
56
Incentives
Benefits Costs
• Energy
• Capacity
• T&D
• GHG
• Losses
• RPS Purchases
• Admin & Overhead Costs
• EM&V
Is Program Cheaper Than Other Sources of Energy?