Re: Case No. U-20365 – In the matter of the application of

October 23, 2019 Ms. Lisa Felice Executive Secretary Michigan Public Service Commission 7109 West Saginaw Highway Post Office Box 30221 Lansing, MI 48909 Re: Case No. U-20365 – In the matter of the application of CONSUMERS ENERGY

COMPANY for authority to reconcile its 2018 Energy Waste Reduction Plan costs associated with the Plan approved in Case No. U-18261.

Dear Ms. Felice: Enclosed for electronic filing in the above-captioned case is Consumers Energy Company’s Rebuttal Testimony and Exhibit of Company witness Joseph A. Forcillo. This is a paperless filing and is therefore being filed only in PDF. Also included is a Proof of Service showing service upon the parties. Sincerely, Gary A. Gensch cc: Hon. Sally L. Wallace, Administrative Law Judge

Parties per Attachment 1 to Proof of Service

General Offices: LEGAL DEPARTMENT One Energy Plaza Tel: (517) 788-0550 SHAUN M. JOHNSON

Senior Vice President and General Counsel

Robert W. Beach Ian F. Burgess Don A. D’Amato Robert A. Farr Gary A. Gensch, Jr. Matthew D. Hall Emerson J. Hilton Georgine R. Hyden Chantez P. Knowles Robert F. Marvin Jason M. Milstone Rhonda M. Morris Deborah A. Moss* Michael C. Rampe Scott J. Sinkwitts Theresa A.G. Staley Janae M. Thayer Anne M. Uitvlugt Aaron L. Vorce

Attorney

Jackson, MI 49201 Fax: (517) 768-3644 *Washington Office: 1730 Rhode Island Ave. N.W. Suite 1007

Tel: (202) 778-3340 MELISSA M. GLEESPEN Vice President, Corporate Secretary and Chief Compliance Officer

KELLY M. HALL Vice President and Deputy General Counsel

Eric V. Luoma Adam C. Smith Bret A. Totoraitis Assistant General Counsel

Washington, DC 20036 Fax: (202) 778-3355 Writer’s Direct Dial Number: (517) 788-0698 Writer’s E-mail Address: [email protected]

S T A T E OF M I C H I G A N BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION

In the matter of the application of ) CONSUMERS ENERGY COMPANY ) For Authority to Reconcile Its ) Case No. U-20365 2018 Energy Waste Reduction Plan Costs ) Associated With the Plan Approved in ) Case No. U-18261. ) )

REBUTTAL TESTIMONY

OF

JOSEPH A. FORCILLO

ON BEHALF OF

CONSUMERS ENERGY COMPANY

October 2019

JOSEPH A. FORCILLO REBUTTAL TESTIMONY

rte1019-jaf 1

Q. Please state your name and business address. 1

A. My name is Joseph A. Forcillo, and my business address is 4600 Coolidge Highway, Royal 2

Oak, Michigan 48068. 3

Q. Are you the same Joseph A. Forcillo who previously submitted direct testimony in 4

this case on behalf of Consumers Energy Company (“Consumers Energy” or the 5

“Company”)? 6

A. Yes. 7

Q. Are you sponsoring any exhibits with your rebuttal testimony. 8

A. Yes. I am sponsoring Exhibit A-22 (JAF-2), the Michigan Behavior Resources Manual 9

(“BRM”). 10

Q. What is the purpose of your rebuttal testimony? 11

A. The purpose of my testimony is to provide information that supports the 2018 savings 12

claimed by Consumers Energy in this filing and to respond to direct testimony provided by 13

David S. Walker of the Michigan Public Service Commission (“MPSC”) Staff (“Staff”). 14

Mr. Walker recommends adjusting the Company’s claimed 2018 Energy Waste Reduction 15

(“EWR”) savings based on a September 2019 analysis indicating that the Home Energy 16

Reports (“HER”) Program realized a lower percentage of energy savings than was reported 17

in this case. 18

Q. Do you agree with Mr. Walker’s recommendation? 19

A. No. Consumers Energy correctly followed all directions and requirements for calculating 20

and reporting 2018 program energy savings as outlined in the BRM. The savings reported 21

in the Company’s 2018 reconciliation in this proceeding were accurate within the context 22


rte1019-jaf 2

of its regulatory obligations and the direction provided by the BRM, MPSC, and EWR 1

Collaborative. Thus, the recommended reduction in savings is not appropriate. 2

Q. What topics will your rebuttal testimony address? 3

A. My rebuttal testimony will address the following topics: 4

• The purpose of the BRM and its protocols for calculating and reporting 5 behavioral program savings; 6

• The methods by which the Company calculates savings for the HER Program 7 in its annual reconciliation process; 8

• How realization rates are calculated and the different ways this term is used in 9 evaluation as well as the specific ways it is defined in this reconciliation 10 proceeding (Exhibit A-8) and the September 17, 2019 presentation to the EWR 11 Collaborative; 12

• The Company’s compliance with the rules and guidelines for claiming deemed 13 savings in the Michigan BRM; 14

• The BRM guidelines regarding annual savings verification and its stated uses 15 for verification results; 16

• The BRM guidelines for updating deemed savings values; 17

• Information presented to the EWR Collaborative on September 17, 2019; and 18

• The Company’s recommendations for prospectively addressing the variance 19 between the BRM deemed savings and evaluated savings. 20

Q. What is the purpose of the BRM? 21

A. As stated in the introduction to the BRM, the BRM “is a collection of tables and supporting 22

documentation that presents approved electric energy and demand savings values and 23

natural gas energy savings values for behavior energy waste reduction (EWR) measures in 24

the state of Michigan.” Developed by the EWR Collaborative’s Technical Subcommittee 25

comprising Staff, utility representatives, implementation contractors, third-party 26

evaluators, energy efficiency experts, and other interested stakeholders, the BRM contains 27

a Measure Definition for Behavior Measures, a list of approved behavioral measures with 28


rte1019-jaf 3

associated savings and guidelines for calculating savings for annual reporting through the 1

reconciliation process as well as for conducting annual verification analysis of actual 2

program savings associated with BRM measures. 3

Q. Did Consumers Energy act consistently with the BRM in its reporting of 2018 HER 4

Program savings? 5

A. Yes. Consumers Energy’s HER Program savings reported in this 2018 reconciliation was 6

consistent with the BRM processes, including: (i) the HER Program design and delivery 7

were consistent with the Measure Definition established in the BRM; (ii) the Company’s 8

2018 reconciliation presented HER savings values that were calculated based on the 9

guidelines outlined in the BRM and verified by its third-party evaluation contractor; and 10

(iii) the Company conducted annual verification of its actual program savings in 11

accordance with the approach directed in the BRM to determine whether a calibration study 12

is warranted. 13

Q. What are the BRM guidelines for calculating and reporting savings for the HER 14

Program? 15

A. Per the introduction to the BRM, page 2, “the BRM utilizes a Deem-but-Verify approach, 16

meaning the per-unit savings for all existing BRM measures are deemed, but must be 17

verified on an annual basis.” The deemed savings assumptions contained in the BRM are 18

called “per-unit savings for behavior measures” and are estimates of average per-household 19

percent savings – the average reduction in electricity or natural gas consumption that a 20

treated HER recipient is expected to achieve under a year of HER Program treatment. The 21

per-unit savings assumptions are differentiated by fuel type (electric, natural gas), average 22

per household energy usage (expressed as a range or “usage band”), and year of program 23


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treatment (e.g., customers in their first, second, third, etc. year of continued program 1

treatment). Table 5 of the BRM contains per-unit savings assumptions. 2

Consumers Energy uses the Michigan-specific savings values for approved 3

behavior measures, which fit the Behavior Measure Definition presented in Table 1 of the 4

BRM, to estimate and report savings for its HER Program in the Company’s EWR plan 5

and reconciliations proceedings. Specifically, Consumers Energy uses the deemed savings 6

values in Table 5, which are expressed as per-unit (i.e., per household) percentage savings 7

to calculate annual program energy savings. Per Table 3, the deemed savings values are, 8

“specific and fixed per-unit energy savings or demand reduction values which have been 9

accepted in the BRM by stakeholders.” 10

Q. How are the HER savings presented by the Company verified as part of the annual 11

reconciliation process? 12

A. In compliance with the BRM, the Company’s third-party evaluator applies a deemed 13

energy savings reduction value to each customer population (track) that receives treatment 14

in the HER Program, based on a matched control population’s average per-household 15

annual energy usage. The Company’s implementation contractor calculates average 16

per-household consumption for each track’s control population and categorizes each 17

treatment track based on usage bands provided in the BRM. Per-customer deemed savings 18

reduction values (percentage savings) are assigned to each customer track based on the 19

track’s energy usage band and year of treatment in the HER Program. Then the third-party 20

evaluation team calculates a verified gross savings value for each track as the product of 21

the deemed percentage savings value from the BRM, the control group’s average annual 22

energy consumption per household, and the number of customers treated in each track 23


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(treatment group). Additionally, the evaluation team applies an installation rate (i.e., 1

“verified gross adjustment factor”) to the treatment group to account for attrition (i.e., those 2

customers who opt out of the program, have inactive accounts, or have moved); the 3

resulting population represents the net number of active program participants. 4

No additional adjustment for Net-to-Gross is needed because HER programs are 5

designed as Randomized Control Trials, where the baseline for treatment is a matched 6

group of control customers whose energy use served as the baseline in the statistical models 7

on which deemed per-unit savings in the BRM are based. Summing verified net energy 8

savings for each track and fuel produces program-level net electricity and natural gas 9

savings. Each input to the verified net energy savings calculation (i.e., per-customer 10

savings per the BRM, the treated customer count, and the installation rate) are updated on 11

an annual basis for each HER Program track and then reviewed and certified by the 12

evaluation team. The evaluation team checks that the correct assumptions from the BRM, 13

and the correct customer counts, and average annual consumption values are being used in 14

calculations for each track. 15

Q. Was this verification process performed for this 2018 reconciliation proceeding? 16

A. Yes. Please see the results in Exhibit A-8 (ACE-1). 17

Q. How are realization rates calculated for the HER Program in Consumers Energy’s 18

reconciliation filing? 19

A. Realization rates in the Company’s reconciliation filing, as shown on Exhibit A-8 (ACE-1), 20

for the HER Program are calculated as net program savings (calculations are consistent 21

with the BRM using the per-unit deemed savings values adjusted by an installation rate to 22


rte1019-jaf 6

account for customer attrition), divided by reported gross program savings. This process 1

is consistent with the direction provided in the BRM for reporting annual program savings. 2

Q. Does the Company’s HER Program meet the Measure Definition for Behavior 3

Measures to warrant using the deemed savings values of the BRM to report program 4

savings? 5

A. Yes. Consumers Energy’s HER Program meets the Measure Definition for Behavior 6

Measures in Table 1 of the BRM and has met this definition in each year of the program 7

from 2011 through 2018. The HER Program is consistent with all guidelines associated 8

with the use of approved deemed savings values in the BRM. 9

Q. Does the BRM require the adjustment of annual reported program savings in EWR 10

reconciliation proceedings? 11

A. No. While the BRM states that “measures included in the BRM are deemed but must be 12

verified on an annual basis,” the BRM describes the annual verification results as an input 13

into a calibration needs assessment, rather than a basis for adjusting annual reported 14

savings in reconciliation cases. The BRM states at page 8: 15

Verification is utility-specific research typically performed 16 by a third-party evaluation team, and leverages data from 17 currently installed measures in Michigan. Third-party 18 evaluation teams will review verification results across 19 Michigan utilities, comparing to BRM savings values, and 20 complete a calibration needs assessment as part of the 21 ‘Existing Measure Review and Calibration Process’ outlined 22 in the Michigan Energy Measure Database Overview and 23 Maintenance Process Manual [Table 3, as part of the 24 definition of the “Deem but Verify” approach]. 25

Similarly, in the introduction at page 2, the BRM states, “Verification results will 26

be compared with existing deemed savings values to determine whether a calibration study 27

is warranted to update deemed savings values as part of the annual ‘Existing Measure 28


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Review and Calibration Process’ as outlined in the Michigan Energy Measure Database 1

Overview and Maintenance Process Manual.” These statements indicate that the purpose 2

of annual verification is to determine whether a calibration study is warranted (which may 3

result in updates to deemed savings values) rather than to retroactively adjust already 4

reported and verified savings values. 5

Q. How does the BRM address the need to update deemed savings values? 6

A. The BRM recognizes that energy savings achieved in the field by HER programs may 7

change over time and provides guidelines for the maintenance and update of deemed 8

savings values, including an update process for revision of an existing measure based upon 9

new research from secondary sources, correcting an error from a previous BRM version, 10

or removal of a measure from the BRM. Since HERs are a long-standing behavioral 11

measure, they must follow the “modified measure” update and review process in the 12

Michigan Energy Measures Database (“MEMD”), wherein measures may be modified to 13

account for three scenarios: (1) “Revision of an existing measure based upon Michigan-14

specific (calibration) research;” (2) “New application of an existing measure based upon 15

adding a new participant population, adding a new building type, or adding a new baseline 16

condition;” or (3) “New application of an existing measure based upon adding a new 17

participant population, adding a new building type, or adding a new baseline condition.” 18

The BRM allows several processes for proposing and approving updates. First, 19

page 2 of the BRM allows for “Interested parties and individuals [to] sponsor the addition 20

of new behavior measures or updates to existing measures annually. These requests are 21

reviewed by the BRM Technical Subcommittee1 and are included in the updated BRM, if 22

1 A specific group known as the BRM Technical Subcommittee has not been established; in practice, the EWR Technical Subcommittee serves this role.


rte1019-jaf 8

approved.” For example, a program implementer, utility, or evaluator may provide new 1

energy savings estimates (expressed in percentage savings terms) for one or multiple HER 2

treatment tracks (each with a specific fuel type, energy usage band, or program treatment 3

year) for the BRM Technical Subcommittee to consider integrating into the expected 4

average savings estimate (deemed savings value) for that fuel type, energy usage band, or 5

program treatment year. Most of the deemed savings values in Table 5 of the BRM are 6

based on energy savings estimates from multiple program tracks in each fuel type, energy 7

usage band, and program treatment year, from both Consumers Energy and DTE Energy, 8

and span multiple years of the HER Program (which started in 2011). As such, they could 9

be considered weighted averages of many years’ results for different treatment tracks, to 10

represent an expected statewide average. Any new information or savings estimates 11

typically consider the sources of existing energy savings estimates. 12

Second, the BRM establishes a protocol for updating the BRM through calibration, 13

specifically the Existing Measure Review and Calibration Process. Per Table 6, this 14

process begins with a calibration needs assessment that considers third-party evaluation 15

results. If through that process it is determined that a calibration study should be 16

conducted, the evaluation teams work with the utilities and EWR Technical Subcommittee 17

to plan for and execute calibration research in accordance with industry best practices. The 18

results of the calibration research are submitted as a draft workpaper with supporting 19

documentation for review by the BRM Technical Subcommittee. The BRM Technical 20

Subcommittee would then “[d]evelop a consensus as to which measures pass the BRM 21

Technical Subcommittee review and are recommended for inclusion into the BRM.” A 22

similar process of submitting a workpaper for review by the BRM Technical Subcommittee 23


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applies to any updates proposed outside of the calibration process. If the BRM Technical 1

Subcommittee recommends updates to the BRM, third-party evaluators would then draft 2

an updated BRM savings table and submit that draft and supporting documentation to the 3

BRM Technical Subcommittee for review and comment by measure sponsors and 4

stakeholders and revisions by the evaluation team. A final draft is then submitted for the 5

BRM Technical Subcommittee to approve and publish. These steps are outlined in Table 6 6

and Table 7 of the BRM. 7

Q. In addition to the annual deemed savings verification described above, did 8

Consumers Energy also conduct an annual savings evaluation process as described in 9

the “Deem but Verify” approach outlined in the BRM? 10

A. Yes. Consumers Energy’s third-party evaluator conducted annual verification of savings 11

through statistical billing analysis and presented the results to the EWR Collaborative on 12

September 17, 2019. The Consumers Energy and DTE Energy evaluation teams compared 13

evaluated adjusted net energy savings (calculated through billing analysis and adjusted to 14

remove energy savings that may be claimed by other parallel energy efficiency programs) 15

to the 2018 BRM per-unit (percentage savings) estimates and presented this comparison to 16

MPSC Staff and the EWR Collaborative on September 17, 2019. 17

Q. What was the purpose of the September 17, 2019 presentation to the EWR 18

Collaborative? 19

A. The purpose of the presentation, provided in this case as Staff Exhibit S-1, was to share 20

annual verification results from Consumers Energy’s and DTE Energy’s third-party 21

evaluations of their 2018 HER programs and inform discussions about: (i) the need to 22

calibrate HER savings under the “Existing Measure Review and Measure Calibration 23


rte1019-jaf 10

Process” as described in the MEMD and referenced in the BRM; (ii) potential options for 1

aligning future claimed savings with actual program savings beyond the current BRM 2

framework and calibration process; and (iii) a broader discussion about calibration and 3

recalibration priorities. 4

Q. Please provide a brief overview of the presentation on September 17, 2019. 5

A. The findings presented to the EWR Collaborative on September 17, 2019 focused on 6

third-party evaluators’ impact analyses of Consumers Energy’s and DTE Energy’s HER 7

programs for their 2018 program years. Staff Exhibit S-1, page 29, contains evaluated net 8

annual savings per household expressed in kWh, Mcf, and percentage savings terms for 9

Consumers Energy. 10

Staff Exhibit S-1, page 12, expresses the Company’s evaluated net percentage 11

savings findings as a “realization rate” of BRM percentage savings. Use of the term 12

“realization rate” on that slide of the presentation was intended to provide the EWR 13

Collaborative with a simplified metric for understanding the variation between evaluated 14

savings (less uplift savings) and the deemed per-unit savings values applicable to this 15

program period per the 2018 BRM and was solely for the purpose of informing the 16

discussion of a Calibration Needs Assessment. 17

The Company also shared plans to change program implementers and some aspects 18

of the program design in 2020 to try to improve savings. The new program implementer 19

will deliver print and electronic home energy reports (“eHERs”) using templates they have 20

tested and verified across the country and will deliver more frequent eHERs to customers 21

with email addresses. They will also provide quarterly performance (i.e., savings) 22

estimates starting three to six months after they launch the redesigned reports, so that the 23


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Company will have more frequent performance feedback that will facilitate adjusting the 1

program as needed to maintain savings. 2

Following the presentation of findings from 2018, the presentation (Staff Exhibit 3

S-1, page 19) describes the “Calibration Needs Assessment” process and its applicability 4

for the HER measures in the BRM and suggests that HER Program savings show a need 5

for calibration. However, the results from 2017 through 2019 are not likely representative 6

of what the HER Program will achieve under a new program implementer and design, and 7

therefore, any savings calibration that uses (and heavily weighs) these results may be out 8

of date by the time the calibration study is completed and results are integrated into the 9

2021 BRM. 10

Understanding that Staff and stakeholders may be interested in having utilities 11

report and claim savings that are more in line with evaluated savings values, the 12

presentation concludes with several options to consider for claiming HER savings in 2020, 13

2021, and subsequent periods (to cover the time until a calibration study is completed and 14

an updated BRM becomes available). 15

Q. How were realization rates calculated for the HER Program in the verification 16

analysis presented on September 17, 2019? 17

A. The realization rates were calculated as Evaluated Net Adjusted Percentage Savings 18

divided by the 2018 BRM assumption of deemed percentage savings appropriate to the fuel 19

type, energy usage band, and program treatment year of each HER track evaluated by the 20

Company’s third-party evaluators. Staff Exhibit S-1, page 7, shows this equation and 21

labels it as “Realization Rate on Percentage Savings versus BRM” to distinguish it from 22

other realization rates that could be calculated. Evaluated Net Adjusted Percentage Savings 23


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(the numerator) are based on monthly billing analysis performed by third-party evaluators, 1

using the Randomized Control Trial design of HER programs and regression-based 2

modeling approaches. The billing analysis itself does not account for double-counting of 3

program savings reported or claimed by other rebate programs, so these savings (also 4

known as “uplift savings”) are removed from the billing analysis results, yielding estimates 5

of average annual net savings per household. 6

The weighted average realization rates of evaluated electric and gas percentage 7

savings compared with BRM percentage savings for Consumers Energy (presented on Staff 8

Exhibit S-1, page 10) combine results from several tracks, weighted by their treatment 9

customer counts, to estimate a program-level average by fuel type. Staff Exhibit S-1, 10

page 12, shows that the realization rates of percentage savings versus 2018 BRM 11

percentage savings for individual tracks ranged from 63% to 83% for electric savings, and 12

24% to 73% for natural gas savings. 13

Q. Please explain why the term Realization Rate has different definitions in the 14

Company’s reconciliation filing and the September 17, 2019 presentation, and any 15

differences in what the rates represent. 16

A. The term “realization rate” generally refers to the proportion, in percentage terms, of 17

reported (or gross) energy savings and evaluated (or net) energy savings for a given 18

program; however, the term is not specifically defined in the MEMD or the BRM. 19

The Company acknowledges that uses of this term to represent different 20

calculations in different contexts may have created confusion around the accuracy of 21

savings reported in the Company’s 2018 reconciliation. In both realization rate 22

calculations, the denominator uses deemed per-unit savings assumptions from the BRM 23


rte1019-jaf 13

appropriate to the fuel type, energy usage band, and program treatment year. However, the 1

numerators represent different values: in the Company’s 2018 reconciliation in this case, 2

the numerator represents verified net program savings that are calculated in accordance 3

with BRM guidelines and adjusted by an “installation rate,” whereas in the September 17, 4

2019 EWR Collaborative presentation, the numerator represents evaluated percentage 5

savings estimated through billing analysis. The realization rates calculated for the 6

September 17, 2019 EWR Collaborative presentation were calculated expressly to inform 7

a discussion about HER measure savings calibration needs, in accordance with the BRM 8

directive and “Existing Measure Review and Calibration Process.” Going forward, the 9

Company proposes to use the term “ratio of verified to deemed savings” or another term 10

agreed to by the EWR Technical Subcommittee to refer to the comparison of evaluation 11

results from billing analysis to BRM savings values. 12

Q. How does Consumers Energy propose to address the variance in BRM savings values 13

and the billing analysis savings presented on September 17, 2019? 14

A. As described above, and in keeping with the “Deem but Verify” approach outlined in the 15

BRM, the Company provided its verification analysis results to facilitate a calibration 16

needs assessment and as part of that discussion recommended that calibration research is 17

warranted. Therefore, the Company recommends calibration research be planned and 18

executed as outlined in the BRM. However, as the Company also recognizes and shares 19

Staff’s concerns regarding claiming potentially overstated savings, the Company presented 20

possible approaches for more immediately addressing the discrepancy between actual 21

program savings and BRM deemed values in the September 17, 2019 presentation and is 22

working with stakeholders to develop a more detailed proposal. These include applying 23


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an adjustment factor to BRM savings based on the realization rates from prior year billing 1

analysis or conducting custom evaluations and applying estimated savings to the same year 2

or the following program year. However, it must be noted that these proposals refer to 3

forward-looking program years of 2020 and beyond. The Company recommends 4

continued discussions with the EWR Technical Subcommittee to identify a method for 5

adjusting future years’ HER savings to account for the discrepancy in savings until a 6

calibration study can be completed and new deemed values can be adopted into the BRM. 7

Q. Is there an established process or provision for retroactive application of post-year 8

HER evaluation results? 9

A. No. The BRM contains no provisions for adjusting program savings retrospectively after 10

that year’s savings have been reconciled, certified, and filed with the MPSC, nor for 11

adjusting savings rates of a program year that is already complete or in progress. As such, 12

adjustments to the verified electric and natural gas savings that the Company reported for 13

2018 in the reconciliation filing are not warranted, since that program was planned, 14

delivered, and reported in accordance with the BRM guidelines. 15

Q. Please explain why adjusting 2018 reported savings is not warranted. 16

A. A primary reason for adopting deemed savings values is to provide planning certainty to 17

the utilities delivering EWR programs. Such certainty allows the utilities to manage 18

program delivery and balance resource allocation across their EWR portfolios to ensure 19

cost-effective achievement of the multiple goals approved by the MPSC for each plan 20

period. The Company relied on this well-established process as part of its 2018-2021 EWR 21

Plan filed and approved in Case No. U-18261, in which the Company indicated that HER 22

savings would be deemed savings based on values from the EWR Collaborative’s BRM. 23


rte1019-jaf 15

In 2018, Consumers Energy relied on and complied with the peer-reviewed BRM 1

guidelines to plan for, deliver, and report on the performance of its HER Program. 2

Requiring retroactive savings adjustments to programs that have complied with all BRM 3

expectations is incompatible with the purpose of the BRM and sets a precedent that deemed 4

savings can no longer be relied upon by utilities to conduct efficient program planning. 5

One of the purposes of evaluation research is the ongoing assessment of programs 6

to maintain and improve program performance. This research identified that this program’s 7

evaluated savings in 2018 fell short of past savings levels. The Company has therefore 8

executed several steps to improve program savings, including selecting a new program 9

vendor that is planning several changes to the program’s design that are expected to 10

substantively increase program savings. 11

In the near term, the Company offered preliminary options to Staff and the 12

Technical Subcommittee to resolve the discrepancy between program performance and the 13

BRM values on September 17, 2019. Through the EWR Collaborative’s Technical 14

Subcommittee, the Company is working to refine those proposals with other stakeholders 15

to establish an alternative savings approach for HER programs in 2020. The EWR 16

Collaborative and its Technical Subcommittee have made substantial improvements to the 17

MEMD and BRM and are well positioned to develop a solution for this situation going 18

forward. This will ensure that evaluation results are appropriately incorporated into 19

regulatory databases like the MEMD and BRM to account for the ongoing stream of 20

evaluation research that keeps these databases as accurate as possible, while avoiding the 21

planning and budgeting uncertainty that would be created with unpredictable changes such 22

as Staff’s proposed retroactive adjustment. The Company’s concern is that Staff’s 23


rte1019-jaf 16

proposed adjustment may lead to all measures becoming at risk for retroactive adjustment 1

by the MPSC. 2

Development of deemed savings values requires a careful and painstaking process 3

to ensure those savings values reflect the actual performance of EWR programs in 4

Michigan. The BRM correctly includes provisions for updating behavior savings values 5

on a regular basis using the Deem but Verify approach to cost-effectively determine 6

whether a more resource intensive calibration process is warranted. As stated previously, 7

the Company and other Michigan utilities rely on the predictability of this process to cost-8

efficiently plan, allocate resources, and execute EWR programs. Establishing a precedent 9

by which utilities can no longer rely on deemed savings values could require that 10

Consumers Energy plan to exceed energy savings targets, potentially overspending EWR 11

resources, and resulting in increased costs to customers. 12

Q. Does this conclude your rebuttal testimony? 13

A. Yes. 14

S T A T E O F M I C H I G A N

BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION

In the Matter of the Application of ) CONSUMERS ENERGY COMPANY ) for Authority to Reconcile Its ) 2018 Energy Waste Reduction Plan Costs ) Case No. U-20365 Associated With the Plan Approved in ) Case No. U-18261. )

)

EXHIBIT

OF

JOSEPH A. FORCILLO

ON BEHALF OF

CONSUMERS ENERGY COMPANY

October 2019

Version 2.0

MICHIGAN BEHAVIOR RESOURCE MANUAL (BRM)

Michigan Energy Waste Reduction (EWR) Collaborative

Publication Date: December 17, 2018

MICHIGAN PUBLIC SERVICE COMMISSION Consumers Energy Company

Case No.: U-20365 Exhibit No.: A-22 (JAF-2)

Page: 1 of 19 Witness: JAForcillo Date: October 2019

TABLE OF CONTENTS

TABLE OF CONTENTS ..................................................................................................................................... 1

1. Michigan Behavior Resource Manual (BRM) Introduction .............................................................. 2

1.1 Purpose ......................................................................................................................................... 2

1.2 Structure ....................................................................................................................................... 3

2. Key Concepts .................................................................................................................................... 4

2.1 Measure Definition ....................................................................................................................... 4

2.2 BRM Stakeholders ......................................................................................................................... 4

2.3 BRM Terminology.......................................................................................................................... 7

2.4 Measure Classifications................................................................................................................. 8

3. BRM Measures ............................................................................................................................... 10

4. Maintenance & Update Process .................................................................................................... 14

4.1 New and Modified Measure Submission .................................................................................... 14

4.1.1 Measure Requirements................................................................................................... 14

4.1.2 Measure Submission Process and Timeline .................................................................... 15

4.2 BRM Review Process ................................................................................................................... 16

4.2.1 Review Process and Timeline .......................................................................................... 16

Appendix A. Approved Whitepapers .......................................................................................................... 18

Home Energy Report Model Calibration Results ........................................................................... 18

Home Energy Report Approved Whitepaper (Year 1 – Year 6) ..................................................... 18




1. Michigan Behavior Resource Manual (BRM) Introduction

The BRM is a collection of tables and supporting documentation that presents approved electric energy and demand savings values and natural gas energy savings values for behavior energy waste reduction (EWR) measures in the state of Michigan.

This manual is intended to provide an overview of BRM purpose, structure and supporting documentation, key concepts, the maintenance and update process, and communication protocols used to manage and maintain the measures herein.

The BRM is maintained by third-party evaluators and published by the Michigan Public Service Commission. Natural gas and electric providers in Michigan support the generation of the BRM and participate in the EWR Collaborative’s BRM Technical Subcommittee which manages the creation and maintenance process of the BRM throughout its lifecycle.

An updated BRM is published on an annual basis with supporting documentation updated on an ongoing basis, as available. Interested parties and individuals can sponsor the addition of new behavior measures or updates to existing measures annually. These requests are reviewed by the BRM Technical Subcommittee and are included in the updated BRM, if approved.

The BRM utilizes a Deem-but-Verify approach, meaning the per-unit savings for all existing BRM measures are deemed, but must be verified on an annual basis. Verification results will be compared with existing deemed savings values to determine whether a calibration study is warranted to update deemed savings values as part of the annual “Existing Measure Review and Calibration Process” as outlined in the Michigan Energy Measure Database Overview and Maintenance Process Manual.

1.1 Purpose This BRM is sponsored by natural gas and electric providers in Michigan and overseen by the Michigan Public Service Commission and the BRM Technical Subcommittee. The measures and values within this BRM are incorporated into the development of provider-specific Energy Waste Reduction (EWR) plans. The primary users of this BRM are program planners, regulatory reviewers and planners, utility and regulatory forecasters, and consultants supporting utility and regulatory research and evaluation efforts. Values published in the BRM represent statewide averages across various user groups, and do not reflect specific project applications.

The purpose of this BRM is to:

• Provide a common and consistent source of information for behavior energy waste reduction measures

• Facilitate demand and energy savings calculations for stakeholders

• Support standardization across Michigan, expedite evaluation measurement and verification (EM&V), and increase transparency in reporting, calibration, and reconciliation




• Provide accurate information on behavior energy waste reduction measures that could be used by Integrated Resource Planning (IRP) and EWR program planning teams

• Document the available best-practice assumptions regarding behavior measures and their evaluation, and how these assumptions are incorporated in adopting Michigan behavior measures.

• Document assumptions and Michigan-specific parameters (weather, load profiles, etc.) for measure savings calculations

1.2 Structure This BRM is comprised of:

• Section 2. Key Concepts, defines key concepts referenced in the document

• Section 3. BRM Measures, includes a table representing savings values for approved behavior energy waste reduction measures

• Section 4. Maintenance & Update Process, describes the process for new and modified measure submissions, and the review process

• Appendix A. Approved Workpapers, provides the workpapers for all approved behavior measures contained within this BRM

In addition to this manual, a repository of supporting documents can be found on the MPSC website. 1,2

1 Supporting documentation includes: approved workpapers, calibration study plans, calibration study reports, as well as other relevant reference materials (such as evaluation protocols for behavior measures). 2 Included in the online repository are the following evaluation protocols:

State and Local Energy Efficiency Action Network. 2012. Evaluation, Measurement, and Verification (EM&V) of Residential Behavior-Based Energy Efficiency Programs: Issues and Recommendations. Prepared by A. Todd, E. Stuart, S. Schiller, and C. Goldman, Lawrence Berkeley National Laboratory. http://eta-publications.lbl.gov/sites/default/files/behavior-based-emv.pdf

Stewart, J.; Todd, A. (2017). Chapter 17: Residential Behavior Protocol, The Uniform Methods Project: Methods for Determining Energy-Efficiency Savings for Specific Measures. Golden, CO; National Renewable Energy Laboratory. NREL/SR-7A40-68573. https://www.nrel.gov/docs/fy17osti/68573.pdf




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2. Key Concepts

The following key concepts are referenced in this document and supporting documentation, and are defined here for clarity and consistency of interpretation. These concepts are outlined in four categories: (1) Measure Definition, (2) BRM Stakeholders, (3) BRM Terminology, and (4) BRM Measure Update Classifications.

2.1 Measure Definition This BRM addresses behavior EWR measures, defined in Table 1.

Table 1. Measure Definition

MEASURE TYPE DEFINITION

Behavior Measure3

Measures (including tools or programs) characterized by various kinds of customer engagement designed to achieve energy savings by motivating them to adopt energy efficient behavior changes. To qualify as a behavior measure, the program intervention must meet the following criteria:

• Use one or more behavior-based approaches rooted in applied social science (e.g., feedback, social norms, goal setting, rewards)

• Encourage either the adoption of energy efficient equipment (e.g., weather-stripping, LED lighting) or the more efficient use of use existing technologies (e.g., adjusting thermostat settings, turning off lights).

• Adhere to a systematic design that allows for the reliable quantification of attributable energy savings (e.g., randomized control trials, normalized metered energy consumption analysis) by following industry best practice research designs and removing any energy savings that may be claimed by parallel EWR programs.

2.2 BRM Stakeholders Multiple stakeholders are involved in the BRM maintenance and update process. Key stakeholders are described below (Table 2), with an overview of their responsibilities as they relate to the BRM. Additional details on Stakeholder responsibilities are outlined in the Maintenance & Update Process section.

3 These measures were included in the Michigan Energy Measures Database 2013 through 2017.




Table 2. BRM Stakeholders

BRM STAKEHOLDER DEFINITION

Michigan Public Service Commission (MPSC)

The mission of the Michigan Public Service Commission is to protect the public by ensuring safe, reliable, and accessible energy and telecommunications services at reasonable rates for Michigan's residents, and provide regulatory oversight in a prudent and efficient manner while implementing legislative and constitutional requirements. The MPSC is composed of three members appointed by the Governor of Michigan with the advice and consent of the state Senate. Commissioners are appointed to serve staggered six-year terms. No more than two Commissioners may represent the same political party. One commissioner is designated as chairman by the Governor. The staff of the MPSC support the management and maintenance of the BRM.

Michigan Public Service Commission (MPSC) Staff

Staff hired by Commissioners to carry out the mission of the MPSC. Commission Staff serve as the chair of the EWR Collaborative and BRM Technical Subcommittee, and oversee the decision-making process of the groups.

Natural Gas and Electric Service Providers (Also known as “Utilities”)

Providers are entities which deliver energy to customers. This group can also include third-parties which perform planning and implementation for EWR programs on behalf of the utilities. Providers support the maintenance and updates of the BRM as members of the EWR Collaborative and BRM Technical Subcommittee.

Third-Party Evaluators

Independent third-party contractors that perform evaluation, measurement and verification (EM&V) services for Provider EWR programs. Evaluators are responsible for the overall maintenance of the BRM, and support the updates of the BRM as members of the BRM Technical Subcommittee.





Energy Waste Reduction (EWR) Collaborative (Formerly “Energy Optimization (EO) Collaborative”)

In October 2008, the Governor signed 2008 PA 295 into law, requiring providers of electric or natural gas service to establish the Energy Optimization (EO) (now EWR) Programs.4 In compliance with PA 295, the Commission issued U-15800 to implement the Act, to give guidelines for EO plans. Plans were required from retail rate-regulated electric utilities, retail rate-regulated rural electric cooperatives, member-regulated electric cooperatives, municipally-owned electric utilities and retail rate-regulated natural gas utilities. Included in Orders approving Consumers Energy (U-15805) and Detroit Edison (U-15806) EO plans were provisions for the establishment of a collaborative to: "include all electric and gas providers subject to the Commission’s jurisdiction under Act 295. In addition, energy efficiency experts, equipment installers, and other interested stakeholders should be encouraged to participate in the collaborative." The goals of the Collaborative include the following:

• Make recommendations for improving EO (now EWR) programs for all providers.

• Provide program evaluation support and develop any needed re-design and improvements to energy efficiency programs.

• Update and refine the MEMD and BRM. • Promote economic development and job creation in Michigan by providing

a forum to connect Michigan manufacturers, suppliers and vendors with utility EO (now EWR) programs.

The EWR Collaborative meets on the third Tuesday of every month from 9am -12pm EST.

Behavior Resource Manual (BRM) Technical Subcommittee

A selection of EWR Collaborative members focused on the review and approval of New and Modified measures for inclusion in the BRM. This group supports the general oversight and maintenance of the BRM. Like the EWR Collaborative, Technical Subcommittee members are comprised of Commission Staff, Utilities, Implementation Contractors, Third-Party Evaluators, energy efficiency experts, and other interested stakeholders. BRM Technical Subcommittee members are established on a volunteer basis, must be technically qualified, and approved by Commission Staff.

Behavior Resource Manual (BRM) Technical Subcommittee Chair

A single member of Commission Staff serves as the BRM Technical Subcommittee Chair who oversees the decision-making process of the group and BRM update process.

BRM Measure Sponsor A utility that submits a New Measure or Modified Measure for consideration for inclusion in the BRM.

4 On December 12, 2016, Governor Rick Snyder signed into law Public Act 342 of 2016 (Act 342), the “Clean and Renewable Energy and Energy Waste Reduction Act”, which amended Act 295 in several ways, most significantly “Energy Optimization” is changed to “energy waste reduction” (EWR) throughout. Act 342 had an effective date of April 20, 2017.





BRM Measure Proponent

Individual or non-utility who is seeking or has secured a BRM Measure Sponsor to submit a New Measure or Modified Measure for inclusion in the BRM. Measure Proponents may include implementation contractors, third-party evaluators, measure vendors or other stakeholders.

2.3 BRM Terminology Key terms used in this BRM and supporting documentation are defined in Table 3.

Table 3. BRM Terminology

TERM DEFINITION

Measure (Also known as “Energy Waste Reduction Measure”)

Specific, defined equipment and/or actions that are intended to reduce electric demand, electric energy consumption, and/or natural gas energy consumption.

Deemed Savings

Specific and fixed per-unit energy savings or demand reduction values which have been accepted in the BRM by stakeholders. These values are accepted because: measure definitions are consistent over time, locale, program, and/or customer type; and sound engineering practices and /or research support the savings calculation.

Workpaper Template

This document presents key details for an EWR measure, including but not limited to: measure description, savings summary, methodology, assumptions, and measure life. Measure Sponsors submitting a New or Modified measure for inclusion in the BRM must complete this template. This template ensures essential measure information is captured and consistently presented to the BRM Technical Subcommittee for review and will be distributed to the EWR Collaborative by the BRM Technical Subcommittee Chair.

Draft Workpapers These documents are completed Workpaper Templates, developed by Measure Sponsors, and to be reviewed for potential inclusion in the BRM.

Approved Workpapers

Once Draft Workpapers are submitted, they are revised by the measure sponsor based upon feedback by the BRM Technical Subcommittee and if approved, reclassified as Approved Workpapers. Approved Workpapers are available upon request from the BRM Technical Subcommittee Chair.

Draft Measure Summary Matrix

Summary of Draft Workpaper submissions for potential inclusion in the BRM. Once all measure submissions are received by the BRM Technical Subcommittee Chair, BRM Technical Subcommittee Chair combines all the key measure characteristics in a matrix which is then distributed to the BRM Technical Subcommittee for reference during the BRM update process.




TERM DEFINITION

Calibration

Michigan-specific research which analyzes the per-unit savings impacts from current BRM measures with the objective of updating the deemed savings value. This research is typically performed by third-party evaluation teams, and leverages data from all currently installed measures, by all utilities as applicable, in Michigan. Behavior measures are prioritized for Calibration based on the “Exiting Measure Review and Calibration Process” outlined in the Michigan Energy Measure Database Overview and Maintenance Process Manual.

Deem-But-Verify

Unlike deemed measures included in the MEMD, the per-unit savings for behavior measures included in the BRM are deemed but must be verified on an annual basis. Verification is utility-specific research typically performed by a third-party evaluation team, and leverages data from currently installed measures in Michigan. Third-party evaluation teams will review verification results across Michigan utilities, comparing to BRM savings values, and complete a calibration needs assessment as part of the “Existing Measure Review and Calibration Process” outlined in the Michigan Energy Measure Database Overview and Maintenance Process Manual.

2.4 Measure Classifications Measures submitted to the BRM Technical Subcommittee for potential inclusion in the BRM may be classified as (1) New Measures, or (2) Modified Measures. These measure classifications are defined in Table 4. Additional detail on measure requirements, review processes and timelines can be found in the Maintenance & Update Process section.




Table 4. BRM Measure Update Classification

TERM DEFINITION

New Measure

Measure which is proposed for review and addition to the BRM. New Measures should be based on one or more of the following: customer usage analysis, secondary research applicable to Michigan, and/or pilots conducted by Michigan natural gas and electric providers. Measure Sponsors are strongly encouraged to submit measures as a New Measure to ensure sufficient time to review for inclusion in the BRM.

Modified Measure

Measure which is proposed for review and/or addition to the BRM. Measures may be modified for the following reasons:

• Revision of an existing measure based upon Michigan-specific (calibration) research.

• Revision of an existing measure based upon new research from secondary sources, correcting an error from a previous BRM version, or removal of a measure from the BRM.

• New application of an existing measure based upon adding a new participant population, adding a new building type, or adding a new baseline condition.

Modified Measures have the potential to be viewed as New Measures, therefore Measure Sponsors are strongly encouraged to submit measures as a New Measure to ensure sufficient time to review for inclusion in the BRM.




3. BRM Measures

Table 5 identifies the behavior EWR measures approved by the EWR Collaborative.5 A customer may not contribute savings to a utility portfolio from more than one behavior measure in a program year.

Table 5. BRM Measures

MEASURE CODE6

ELECTRIC/ GAS SECTOR BEHAVIOR MEASURE

DESCRIPTION

ASSUMED HOURS OF

OPERATION CF

2018 ACTUAL (NON-

COINCIDENT) KW

2018 TARGET

KWH PERCUST

2018 TARGET (COINCIDENT) KW PERCUST

2018 TARGET THERMS PERCUST

MEASURE LIFE

INCREMENTAL COSTS

BASE EFFICIENCY

LEVEL

PROPOSED EFFICIENCY

LEVEL

SIZE BASIS

INSTALLATION COST

INSTALLATION COST SOURCE

B-RE-MS-000002-E-XX-XX-XX-XX-01

Electric Residential

Behavior Modification: Home Energy Reports, >11kWh Annual Usage (1st year)

8760 1 1.80% 1.20% 1.80% n/a 1 $6.77 No Reports Reports Per Home N/A



Behavior Modification: Home Energy Reports, 9k-11kWh Annual Usage (1st year)












Behavior Modification: Home Energy Reports, >11kWh Annual Usage (2nd year)




Behavior Modification: Home Energy Reports, 9k-11kWh Annual Usage (2nd year)










5 Refer to Appendix A. Approved Whitepapers for approved whitepapers and (online repository) for associated supporting documentation. 6 The measure code structure is consistent with the Michigan Energy Measures Database and uses the following structure: MeasureType-Sector-MeasureCategory-MeasureNumber-FuelType-Climate-BuildingType-System-Vintage-MeasureVersion. All measures included in this Behavior Resource Manual will be Measure Type “B”. The measure code, excluding the Measure Version, is assigned to each measure and does not change over time. The first five elements, MeasureType-Sector-MeasureCategory-MeasureNumber-FuelType, represent the parent portion of the measure code. The next four elements, Climate-BuildingType-System-Vintage, represent the child portion of the code and are only populated for weather sensitive measures.




MEASURE CODE6


DESCRIPTION

ASSUMED HOURS OF

OPERATION CF

2018 ACTUAL (NON-

COINCIDENT) KW

2018 TARGET

KWH PERCUST



MEASURE LIFE

INCREMENTAL COSTS

BASE EFFICIENCY

LEVEL

PROPOSED EFFICIENCY

LEVEL

SIZE BASIS

INSTALLATION COST




Behavior Modification: Home Energy Reports, 9k-11kWh Annual Usage (3rd year)




Behavior Modification: Home Energy Reports, 7k-9kWh Annual Usage (3rd year)




Behavior Modification: Home Energy Reports, 9k-11kWh Annual Usage (4th year)

























8760 1 n/a 2.73% 4.10% n/a 1 $6.77 No Reports Reports Per Home N/A




8760 1 n/a 2.20% 3.30% n/a 1 $6.77 No Reports Reports Per Home N/A

B-RE-MS-000020-G-XX-XX-XX-XX-01

Gas Residential

Behavior Modification: Home Energy Reports, 900-1200 Therms Annual Usage (1st year)

8760 1 n/a n/a n/a 0.34% 1 $6.77 No Reports Reports Per Home N/A




MEASURE CODE6


DESCRIPTION

ASSUMED HOURS OF

OPERATION CF

2018 ACTUAL (NON-

COINCIDENT) KW

2018 TARGET

KWH PERCUST



MEASURE LIFE

INCREMENTAL COSTS

BASE EFFICIENCY

LEVEL

PROPOSED EFFICIENCY

LEVEL

SIZE BASIS

INSTALLATION COST



Gas Residential

Behavior Modification: Home Energy Reports, >1200 Therms Annual Usage (1st year)



Gas Residential

Behavior Modification: Home Energy Reports, 900-1200 Therms Annual Usage (2nd year)



Gas Residential

Behavior Modification: Home Energy Reports, >1200 Therms Annual Usage (2nd year)



Gas Residential

Behavior Modification: Home Energy Reports, 900-1200 Therms Annual Usage (3rd year)



Gas Residential

Behavior Modification: Home Energy Reports, >1200 Therms Annual Usage (3rd year)



Gas Residential

Behavior Modification: Home Energy Reports, 900-1200 Therms Annual Usage (4th year)



Gas Residential

Behavior Modification: Home Energy Reports, >1200 Therms Annual Usage (4th year)



Gas Residential




Gas Residential




Gas Residential






MEASURE CODE6


DESCRIPTION

ASSUMED HOURS OF

OPERATION CF

2018 ACTUAL (NON-

COINCIDENT) KW

2018 TARGET

KWH PERCUST



MEASURE LIFE

INCREMENTAL COSTS

BASE EFFICIENCY

LEVEL

PROPOSED EFFICIENCY

LEVEL

SIZE BASIS

INSTALLATION COST



Gas Residential




Gas Residential




Gas Residential






4. Maintenance & Update Process

This section describes the following components of the BRM maintenance and update process: 1) New and Modified Measure Submission, and 2) BRM Review Process.

The BRM is published annually in October, reflecting that year’s updates, additions, and removals. All documents are maintained by the MPSC. Table 6 and Figure 1 present the details and flow chart for this process, respectively.

4.1 New and Modified Measure Submission Measure sponsors must adhere to a set of requirements and the BRM update process schedule to enable review and adoption of proposed measures.

4.1.1 Measure Requirements Measure Sponsors are required to fully complete a Workpaper Template and Measure Summary Matrix and submit a Draft Workpaper for all proposed measures. The Workpaper Template outlines all information needed for the BRM Technical Subcommittee to review the merits of each proposed measure for potential inclusion in the BRM. These details include but are not limited to:

a) Measure Description b) Measure Savings Summary c) Baseline and Proposed Condition Descriptions d) Calculation Methodology and Assumptions e) Relevant reference sources and attached documentation

The BRM Technical Subcommittee will use the following criteria to assess the proposed measures for approval and inclusion in the BRM:

• Complete Draft Workpaper. The submitted Draft Workpaper must include all required information, and a sufficient level of detail and support.

• Reasonable Savings Estimates. A reasonable savings estimate is one that relies on the best practical and reliable data collection and estimation methods. Savings estimates must be supported by sound evaluation results and/or engineering estimates. For measures that rely on primary research to develop key parameter assumptions, savings can be considered reasonable if the errors associated with sampling meet or exceed 10% precision at a 90% confidence level. For measures that rely on billing analysis, engineering analysis or simulation modeling, savings can be considered reasonable if the analysis and/or modeling approach follows industry best practices and passes the review of the BRM Technical Subcommittee.

• Representative Baseline. A satisfactory measure baseline should reflect typical choices by eligible customers of existing behavior, equipment, current codes and standards, and market conditions.

• Michigan Specific Parameters. Savings estimates may be based on primary or secondary data. Savings estimates must rely on parameters specific to the Michigan region and its climate zones, and be applicable to measures implemented in Michigan.

• Measure Interactions Considered. The savings from one measure may in part be determined by another measure that has already been implemented by the customer. Potential measure interactions should be considered in measure savings estimates.




• Reasonable Data Timeframe. When applicable, savings values should rely on a reasonable and sufficient timeframe for data collection to produce repeatable and consistent results (e.g., savings values established based on billing analysis typically require at least 12 months of post-installation customer data).

• Final Data Utilized. Savings estimates must be based on final, not preliminary, customer data.

The BRM Technical Subcommittee collectively will make the final determination of whether a Draft Workpaper meets the above criteria and is recommended for inclusion in the BRM.

4.1.2 Measure Submission Process and Timeline The BRM Measure Submission Process and Timeline is outlined in Table 6.

Table 6. BRM Measure Submission Process and Timeline7

STEP RESPONSIBLE

PARTY TASK DESCRIPTION NEW

MEASURE DUE DATE

MODIFIED MEASURE DUE DATE

MS-0 Third Party Evaluators

Complete Annual

Verification

Behavior measures included in the BRM must be verified on an annual basis. Third-party evaluation teams will review verification results across Michigan utilities, comparing to BRM savings values, and complete a calibration needs assessment as part of the “Existing Measure Review and Calibration Process” outlined in the Michigan Energy Measure Database Overview and Maintenance Process Manual.

N/A June 1

MS-1 Measure Sponsor

Submit Draft Workpapers

Measure Sponsors submit Draft Workpapers and Measure Summary List to the BRM Technical Subcommittee Chair. April 1 June 1

MS-2 BRM Technical Subcommittee

Chair

Distribute Draft

Workpapers

The BRM Technical Subcommittee Chair compiles a Draft Measure Summary Matrix; confirms all appropriate supporting documentation is aggregated; and sends out the Draft Measure Summary List and Draft Workpapers to BRM Technical Subcommittee for preliminary review.

Within 5 business

days following

the April 1 deadline

Within 5 business

days following the June 1 deadline

MS-3 BRM Technical Subcommittee

Review Draft Workpapers

The Subcommittee meets to discuss findings and hear reviewer comments. The committee then develops a consensus as to which measures pass the BRM Technical Subcommittee review and are recommended for inclusion into the BRM. Approved measures are returned to the BRM Technical Subcommittee Chair. Rejected measures are returned to the Measure Sponsor with comments or requested revisions (if applicable).

May 1 July 1

7 If a deadline falls on a weekend or holiday, the deadline moves to the prior business day.




4.2 BRM Review Process Third-party evaluators will incorporate New and Modified measure submissions and develop a Draft BRM for review by the EWR Collaborative. Once the review process is complete, Commission Staff will publish the Final BRM on the MPSC website8.

4.2.1 Review Process and Timeline The BRM Draft and Final Review Process and Timeline is outlined in Table 7.

Table 7. BRM Draft and Final Review Process and Timeline

STEP RESPONSIBLE

PARTY TASK DESCRIPTION DUE DATE

MR-1 Third-Party Evaluators

Submit Draft BRM &

Documentation

Third-party evaluators update the BRM savings table and compile supporting documentation, providing a draft of the BRM to the BRM Technical Subcommittee Chair.

August 1

MR-2 BRM Technical Subcommittee

Chair

Distribute Draft BRM &

Documentation

The BRM Technical Subcommittee Chair forwards these documents to the BRM Technical Subcommittee, the EWR Collaborative, and Measure Sponsors.

Within 5 business days following the August 1 deadline

MR-3 Measure Sponsor Review Draft BRM

Measure sponsors review the Draft BRM and Approved Workpapers for accuracy related to their submittal to assure workpaper calculations and data were interpreted and applied correctly. Reviewers (Measure Sponsors and Evaluators) are asked to send a confirmation email or an email detailing the discrepancies to the BRM Technical Subcommittee Chair.

August 15

MR-4 EWR Collaborative Review Draft BRM

The Draft BRM is received by all stakeholders (EWR Collaborative, BRM Technical Subcommittee, Measure Sponsors) in advance of an EWR Collaborative meeting. Stakeholders participate in the meeting and provide comment or request clarification (if appropriate).

August EWR Collaborative

Meeting

MR-5 EWR Collaborative Review Draft BRM

The EWR Collaborative completes a review of the Draft BRM, and members propose any desired changes by sending comments via email to the third-party evaluators and copying the BRM Technical Subcommittee Chair.

September 1

MR-6 Third-Party Evaluators

Submit Final BRM & Documentation

Third-party evaluators incorporate revisions into the Draft BRM based on received comments, clarifications, and recommended changes and then submits a Final Draft of the BRM and its supporting documentation to the BRM Technical Subcommittee Chair.

September 15

MR-7 BRM Technical Subcommittee

Chair Publish Final BRM

The BRM Technical Subcommittee Chair publishes the Final BRM and the supporting documentation on the Michigan Public Service Commission website, and alerts stakeholders (EWR Collaborative, BRM Technical Subcommittee, Measure Sponsors) via email.

On the 10th business day of

October

8 Final BRM documents will be posted on the MPSC website at the following URL: http://www.michigan.gov/mpsc/0,4639,7-159-52495_55129---,00.html.




Figure 1. BRM Update Process




Appendix A. Approved Whitepapers

This appendix contains the Home Energy Report model calibration results and approved whitepaper for the Home Energy Report measure. These and other related documents may be found on the MPSC website.

Home Energy Report Model Calibration Results

EOC Opower Model Calibration Study Pres

Home Energy Report Approved Whitepaper (Year 1 – Year 6)

MEMD_Whitepaper_Behavior Modification R

Home Energy Report Approved Whitepaper (Year 7)

BRM_Workpaper_Behavior Modification Re




ps1019-1-231

S T A T E O F M I C H I G A N

BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION In the Matter of the Application of ) CONSUMERS ENERGY COMPANY ) for Authority to Reconcile Its ) 2018 Energy Waste Reduction Plan Costs ) Case No. U-20365 Associated With the Plan Approved in ) Case No. U-18261. ) )

PROOF OF SERVICE

STATE OF MICHIGAN ) ) SS COUNTY OF JACKSON )

Jennifer Joy Yocum, being first duly sworn, deposes and says that she is employed in the Legal Department of Consumers Energy Company; that on October 23, 2019, she served an electronic copy of Consumers Energy Company’s Rebuttal Testimony and Exhibit of Company witness Joseph A. Forcillo upon the persons listed in Attachment 1 hereto, at the e-mail addresses listed therein. She further states that she also served a hard copy of the same document to the Hon. Sally L. Wallace at the address listed in Attachment 1 by depositing the same in the United States mail in the City of Jackson, Michigan, with first-class postage thereon fully paid.

__________________________________________ Jennifer Joy Yocum Subscribed and sworn to before me this 23rd day of October, 2019. _________________________________________ Crystal L. Chacon, Notary Public State of Michigan, County of Ingham My Commission Expires: 05/25/24 Acting in the County of Jackson

ATTACHMENT 1 TO CASE NO. U-20365

sl0519-1-235 Page 1 of 1

Administrative Law Judge Sally L. Wallace, ALJ Administrative Law Judge 7109 West Saginaw Highway Post Office Box 30221 Lansing, MI 48909 [email protected] Counsel for the Michigan Public Service Commission Staff Spencer A. Sattler Monica M. Stephens Daniel E. Sonneveldt Assistant Attorney General Public Service Division 7109 West Saginaw Highway Post Office Box 30221 Lansing, MI 48909 [email protected] [email protected] [email protected] Counsel for the Residential Customer Group (“RCG”) Don L. Keskey Brian W. Coyer Public Law Resource Center PLLC 333 Albert Avenue, Suite 425 East Lansing, MI 48823 [email protected] [email protected]

mailto:[email protected]






Documents

Re: Case No. U-20365 – In the matter of the application of