Regulatory Filings
Energy Efficiency is a key issue for the LGSEC. Our participation in this area has been extensive. A document that has guided our work in this area is the 2007 White Paper we prepared on energy efficiency partnerships.
Energy Efficiency is a key issue for the LGSEC. Our participation in this area has been extensive. A document that has guided our work in this area is the 2007 White Paper we prepared on energy efficiency partnerships.
Final Comments of LGSEC – September 25, 2017
Final Business Plan – January 20, 2017
LGSEC Comments on Proposed Decision – August 8, 2016
LGSEC Motion to File Response to Reply Comments – July 14, 2016
LGSEC Response to Reply Comments – July 14, 2016
LGSEC Comments on Statewide Administration of EE Programs – June 17, 2016
For the 2013-2014 Energy Efficiency Transition Period, the California Public Utilities Commission directed the investor-owned utilities to significantly increase the amount of ratepayer funds directed to programs that help customers finance energy efficiency investments. The LGSEC is working to ensure that the energy efficiency financing programs started by local governments continue. The LGSEC’s comments on this issue are provided below.
Assembly Bill 758 (Skinner, 2009) requires the California Energy Commission to develop a program to achieve more comprehensive energy savings from existing buildings. Whole-building retrofits have been a priority for the LGSEC. We are participating in the CEC’s proceedings to ensure local governments are recognized in AB 758 programs.
On July 2, 2012, the investor-owned utilities submitted applications for the 2013-2014 energy efficiency transition period (A.12-07-001, et al). In aggregate, the utilities are requesting about $2 billion for the two-year cycle. The LGSEC is participating in this proceeding to ensure that local government energy efficiency partnerships continue at a robust level. The LGSEC also is interested in the development of local government Regional Energy Networks that complement the existing utility programs and partnerships.
SoCalREN Reply Comments: Proposed Decision – Nov. 5, 2012
BayREN Reply Comments: Proposed Decision – Nov. 5, 2012
Reply Comments: Proposed Decision – Nov. 5, 2012
Letter to Energy Division: Draft EE Research Plan for Government Sector – Oct. 30, 2012
BayREN Comments: Proposed Decision – Oct. 29, 2012
LA County Comments: Proposed Decision – Oct. 29, 2012
Comments: Proposed Decision – Oct. 29, 2012
SoCalREN, BayREN Notice of Grant of Ex Parte Meeting – Oct. 29, 2012
LA County Reply Comments: Response to Scoping Memo – Sep. 21, 2012
BayREN Reply Comments: Response to Scoping Memo – Sep. 21, 2012
LA County Comments: Supplemental Info – Sep. 14, 2012
BayREN Comments: Supplemental Info – Sep. 14, 2012
Government Parties Comments: Attachment D Questions – Sep. 14, 2012
Attachment B – Retrofit LA Final Report – June 19, 2012
Attachment A – Retrofit Bay Area Final Report – April 30, 2012
The CPUC in the spring of 2011 realized that it may not be ready to commence the next energy efficiency portfolio cycle by 2013. The CPUC is determining whether and how the current portfolio timeline might be extended. The LGSEC is advocating for a limited extension of one year, with streamlined administrative processes that allow local government partnerships to continue with no interruption.
Comments: EE Savings Goals and Other – Dec. 3, 2010
Reply Comments: EE Savings Goals and Other – Dec. 10, 2010
Reply Comments: Portfolio Extension – July 1, 2011
Comments: Portfolio Extension– June 16, 2011
Comments: Bridge Period and Post-Bridge Planning – Nov. 8, 2011
Reply Comments: Bridge Period and Post-Bridge Planning – Nov. 16, 2011
In 2007, the utilities filed applications for their 2009-2011 energy efficiency portfolios. During the extended proceeding, the LGSEC advocated for utility energy efficiency programs that would best allow local governments to design and implement programs that meet the goals of the California Strategic Plan for Energy Efficiency. The proceeding took much longer than expected, but when the program was adopted (for 2010-2012 instead of 2009-2011, which the LGSEC strongly recommended), it included $265 million for local government energy efficiency partnerships with the utilities. The program also includes programs that should increase information sharing between local governments, again a need identified by the LGSEC. And the program includes an opportunity for local governments to develop innovative energy efficiency programs – about $15 million has been awarded to local governments by the utilities as of October 2010 for this initiative.
Comments: Utility Implementation Advice Letters – Feb. 11, 2010
Comments: PG&E Unspent EE funds – July 21, 2009
Motion: Amend Bridge Funding – June 25, 2009
Reply Comments: Amended Utility Applications – May 9, 2009
Comments: Amended Applications – April 17, 2009
Comments: ARRA and Public Goods Funds – March 11, 2009
Joint Prehearing Conference Statement: – Oct. 6, 2008
Comments: Utility EE Applications – Aug. 28, 2008
Request: Extension on Supplemental Filings of EE Applications – Feb. 6, 2008
Reply Comments: Proposed Decision on EE Programs – Oct. 15, 2007
Comments: Proposed Decision on EE Programs – Oct. 9, 2007
In 2008, the California Public Utilities Commission began developing the California Energy Efficiency Strategic Plan. The LGSEC participated in months of workshops and submitted many sets of comments on the recommended priorities for local governments in terms of energy efficiency. We also emphasized the important role that local governments play in terms of other state goals, such as reducing greenhouse gas emissions. The adopted Energy Efficiency Strategic Plan includes an entire chapter on local government, and establishes aggressive goals for more energy savings from municipal facilities, broader and more leadership on energy issues from local government, and greater capability within local government to effectively manage energy use.
Comments: Proposed Decision on EE Strategic Plan – Sep.8, 2008
Comments: Draft EE Strategic Plan – July 31, 2008
Reply Comments: Draft EE Strategic Plan – Aug. 7, 2008
Comments: Proposed EE Strategic Plan and 09-11 EE Portfolio – March 24, 2008
Proposed Approach: Local Government Strategy Proposal – Nov. 3, 2007
In September 2011, the California Public Utilities Commission began revisiting whether utilities should continue to be eligible for incentives for realizing savings from energy efficiency programs.
In 2001, the Legislature directed the utilities to collect a public goods charge to fund electric and natural gas energy efficiency activities, incentives for renewable energy, and research and development. The charge was authorized for 10 years and expires 12/31/2011. Subsequently, the California Public Utilities Commission directed the utilities to additionally use money that would otherwise be used to build or purchase new electric generation for energy efficiency. For 2010-2012 the utilities have been authorized to spend $3 billion on energy efficiency, of which about $750 million comes from the public goods charge. The Governor has directed the CPUC to figure out how to maintain these programs when the legislative mandate expires.
The LGSEC supports programs that allow energy efficiency audits and retrofits to happen on a community-wide basis, usually in low-income neighborhoods. We have advocated that these programs also include moderate-income households, and that they be integrated with programs that local governments are developing on their own accord. Our advocacy has resulted in Southern California in an integrated program between the County of Los Angeles, which is launching a whole-building retrofit program for the 88 cities within its boundaries as well as the unincorporated areas, and Southern California Edison.
To develop climate action plans and focused energy efficiency programs, local governments need data on energy usage in buildings in their jurisdiction. The LGSEC has advocated before the California Public Utilities Commission and the Energy Commission on the format and timeline for this data to be exchanged between local governments and utilities. As a result of our advocacy, in 2011 the CPUC directed Southern California Edison and Southern California Gas to coordinate with leading local governments on how best to exchange this data. This has occurred with limited success. The CPUC in November 2012 began considering whether to establish a statewide Energy Usage Data Center. The LGSEC continues to put forward the immediate need of local governments for this data, in order to develop and implement energy and climate action plans.
Reply Comments: Ruling Pertaining to Closing of Proceeding re Smart Grid System – Aug. 15, 2014
Reply Comments: Proposed Decision Adopting Rules to Provide Access to Energy and Usage Related Data – April 1, 2014
Comments: Proposed Decision Adopting Rules to Provide Access to Energy and Usage-Related Data – March 27, 2014
CCSC, Energy Institute, LGSEC, CCSE Response: EFF Motion – September 3, 2013
Reply Comments: Data Working Group Report – August 5, 2013
Comments: Data Working Group Report – July 29, 2013
Comments: Utility Strawman Proposal – May 17, 2013
Proposed Discussion Framework: Energy Data Access Map – May 13, 2013
Comments: Energy Usage Data Center – Dec. 17, 2012
Comments: AB 1103 Guidelines – June 22, 2010
In 2009, as the American Recovery and Reinvestment Act (ARRA”) was rolled out, the LGSEC offered guidance to the California Public Utilities Commission and the Energy Commission on how best to integrate these Stimulus funds with the public goods charge funds that finance the utility energy efficiency programs. We helped shape the regulators’ understanding of how the criteria being used to evaluate whether ARRA funds are well-spent differ from those used for energy efficiency programs in California. We also argued that this money should be used to fund Resource Conservation Managers within regional government organizations, a position that would serve multiple jurisdictions and become in-house expertise for smaller local governments that cannot fund this type of position on their own. This concept has been funded by PG&E in a pilot program for the Alameda County Office of Education for 2010-2012.