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Electric utilities

Southern California Edison Company's Reply Comments on Energy Efficiency Goals

Strategic Insights

— 2 min read

The California Public Utilities Commission (CPUC) has issued a document outlining proposed energy efficiency goals for 2022-2032. Southern California Edison Company (SCE) has submitted reply comments on the proposed decision, highlighting concerns with the current goals and recommendations for modification. The proposed decision aims to increase energy efficiency, but SCE argues that the current goals may not be achievable and that fuel substitution potential should be tracked separately.

Key Takeaways:

  • SCE agrees with PG&E's recommendation to create a separate fuel substitution goal, rather than including it as part of the energy efficiency (EE) goal.
  • The Commission should not adopt recommended changes to cost-effectiveness or requirements for PAs to modify contracts, as it may upset settled expectations and delay program implementation.
  • SCE recommends that the Commission include avoided gas infrastructure costs (AGIC) as being in effect during the 2022-2023 program years, to account for statewide residential and commercial new construction programs.
  • The Commission should collect additional information before establishing post-2026 goals for Energy Savings Assistance (ESA) programs, as new ESA program and pilots have recently been approved and there is a lack of actual data to determine impacts on future potential and goals.
  • SCE applauds the proposed decision and encourages the Commission to adopt it, with the modifications recommended by SCE.

Statistics:

  • The proposed decision aims to increase energy efficiency by 10% between 2022 and 2032 (Source: CPUC, D.21-05-031).
  • The cost-effectiveness threshold for EE portfolios for the 2022-2023 program years is proposed to be 0.85 Total Resource Cost (TRC) (Source: Council, Opening Comments).
  • The Commission has set cost-effectiveness at a TRC of 1.0 for the resource portion of the portfolio in a previous decision (D.21-05-031) (Source: CPUC, D.21-05-031).
  • The new ESA program and pilots were recently approved in June 2021 (Source: TURN, Opening Comments).
  • The program constraints ultimately in place in 2027 and beyond should inform the updated goals for that time period (Source: TURN, Opening Comments).

Sources:

  • CPUC, D.21-05-031: "Order Instituting Rulemaking Concerning Cost-Effectiveness for Energy Efficiency Program"
  • Council, Opening Comments: "California Efficiency + Demand Management Council Comments"
  • TURN, Opening Comments: "TURN Comments"
  • CPUC, Rulemaking 13-11-005: "Order Instituting Rulemaking Concerning Energy Efficiency Rolling Portfolios, Policies, Programs, Evaluation, and Related Issues"
  • SCE, Opening Comments: "Southern California Edison Company's (U 338-E) Opening Comments On Administrative Law Judge's Ruling Inviting Comments On Draft Potential And Goals Study"

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