Energy Efficiency Post 2011 Implementation Proposal
The following comments were submitted in response to the open comment period described below.
BPA committed to addressing numerous functions of the agency that are fundamentally impacted by the long-term contracts. Energy Efficiency is affected because tiered rates provide a financial incentive for utilities to acquire the least-cost resources to avoid paying Tier Two rates. Energy efficiency is a least-cost resource.
Other factors are drivers for EE as well, such as a region and a national focus on energy independence, climate change and green jobs. The updated BPA EE program addresses many issues that have been raised by large and small utilities alike. These issues enhance EE efforts to meet increased energy demand, reduce greenhouse gasses, support the economy and jobs and promote energy independence.
BPA has worked extensively with stakeholders to continue the region’s leadership in energy efficiency as part of the Regional Dialogue implementation. BPA has developed a proposal (the “Energy Efficiency Post-2011 Implementation Proposal”) on post-2011 energy efficiency program implementation details, which has been released and available at the Web site below.
After the public comment period closes, BPA will finalize the post-2011 implementation details and update the Implementation Manual accordingly on April 1, 2011 to allow six months notice before the program aspects of Phase 2 take effect on October 1, 2011.
For More Information:
http://www.bpa.gov/Energy/N/post-2011/
Comments are numbered consecutively as they are received. Breaks in the number sequence result when comments are deleted because they
were submitted in error or have inappropriate content (such as SPAM). If you do not see your comment two business days after
you submit it, please contact (800) 622-4519.
Close of comment: 2/18/2011
- EEIP10001 -
Martin/Longview FibreWe are a big customer utilizing this program, and by approving this proposal, our energy efficiency projects will definitely be reduced significantly. More than half of our projects get carried over because of the time consumed to plan, purchase, document and execute. I heavily disagree with this proposal
- EEIP10002 -
nostdalthe bpa should be using the lakes behind the dams as batterys. water should be pumped upstream when the windmills spike, or energy production is more than what is being used.the pump stations that do this could also cool water improving fish habitat. power companys that use bpa power should give all customers cheaper power late at night when there is less demand, i do not see this being offered by pacific powers new meters, why not?
- EEIP10004 -
Peterson/SelfWe have a small farm on the Tucannon River in Southeast Washington. We bear personal testimony to the damage and destruction caused by wind turbines. Please do not encourage wind energy projects that destroy viewscapes, property values, wildlife and harm human health. Wind energy is sporadic, unreliable, harmful and not cost effective. We have a beautiful Scenic Columbia Gorge. Please do not destroy and or damage that resource or any other natural beauty. Our nation simply must not consume itself with building asphalt jungles, parking lots, and amusement centers. Please contact us immediately if you want further direct personal testimony. Jim and Laura Peterson
- EEIP10005 -
Charlo/Milton-Freewater City Light and PowerI would urge Bonneville to revise the definition to actually include "rural" and "residential" instead of only "small". Milton-Freewater is too large to qualify as small under the current definition, but we are somewhat rural and are definitely residential. As one of the original Pilot Project Residential Weatherization utilities in 1980, Milton-Freewater has achieved almost all of the possible conservation in that sector at the previous lower incentive levels. We have seen recently that we will be penalized by the concept of the conservation adjustment to the High Water Mark because we have not been able to accomplish as much conservation as the utilities who have a higher percentage of commercial and industrial customers available for conservation efforts. Milton-Freewater has never considered ramping down on conservation to positively affect our High Water Mark, but still we are seeing a decrease to the value that we are actually entitled to. I would also recommend higher caps for payment for small/rural/residential utilities. This money can go towards paying for staff and for higher incentive to attract conservation cusrtomers.
- EEIP10007 -
Whitaker/Harney Electric cooperative incAccording to BPA size does count! The new energy efficiency plan for post 2011 proposes to set the amount of the performance payment to utilities based on the utilities TOCA size. The utilities size does cause more of a negative impact to the bottom line of small utilities another is the density of consumers. Sparse service areas like Harney electrics where there are fewer than 1.2 meters per mile make the cost of conservation very expensive. The remoteness from larger metropolitan areas also adds to the cost of getting contractor installed efficiency upgrades. For example to get a BPA approved heat pump installed requires bringing a contractor in from Bend, Boise or Elko (130 miles away) there are none qualified in the Burns or Winnemucca area. The contactor then has to travel to the site which can be another 1 to 2 hours away, making a no cost estimate impossible. We ask BPA to reconsider how a utility qualifies for the various performance payment percentages. We suggest that BPA use the working group’s proposal which was Small/Rural/Residential.
- EEIP10008 -
Schauer/Oregon Trail Electric Co-opI understood that BPA will continue to manage conservation contractors like ECOS or PECI. These contractors will conduct programs in our territory, with our permission, managed by BPA. The utility will pay the rebate that is quoted by the contractor. I'm ok with this except that if the contractor makes a mistake in the audit that results in an inappropriate rebate be paid to the member, then the utility would be on the hook for the rebate, and not be reimbursed by BPA. I believe if BPA manages these contractors, that it's fine that the utility pay the rebate, however if if a mistake is made resulting in an inappropriate rebate, the BPA must honor the mistake and rebate the utility in full. My case and point is ECOS and the PTCS heat pump program. Rules changed mid-stream regarding when a utility could pay a rebate from when we got certification papers in our hand to...the papers had to go to ECOS and they had to post an approval on their web site. The result was that utilities paid rebates under the first rule, then we were denied the rebate because an approval was not posted on a web site. We eventually got our reimbursements through a heated debate with BPA. Poor communication was a big factor in this case. Changes of rules for programs need to be clearly communicated in advance... grandfathering projects in progress, and identifing that future change deadline. Thank you for your understanding in this issue.
- EEIP10009 -
Measure/Northwest Power and Conservation Councilview attached document.
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- EEIP10010 -
Anneberg/North Pacific Paper CorporationView attached document.
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- EEIP10011 -
Schauer/Oregon Trail Electric Co-opFor the past several years BPA has held conservation dollars back from it's customers so BPA could doll out those dollars to utilities who request incentives available for large industrial projects. OTEC believes that all conservation dollars should be allocated to BPA's customers so we may see if we can utilize those conservation dollars in our service territory. If we feel we cannot utilize our entire allotment we can make arrangements with other utilities to share our conservation dollars. After all, our members paid through their electric bills, the dollars that fund conservation, so all conservation dollars should be allocated back to the utility where the funds came from. We can then spend those dollars locally.
- EEIP10012 -
Carpenter/Raft River Rural Elecric Co-op
- EEIP10013 -
Usibelli/Commerce, Energy Officeview attachment
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- EEIP10014 -
Dorran/Hermiston Energy ServicesIn Phase 1 of this process, utilities throughout the region, advocated for more flexibility and local control. While we agree there appears to be more flexibility through the Energy Efficiency Post-2011 Implementation Proposal, the final outcome still creates barriers for utilities to deliver effective energy conservation to our members. Below are comments that reflect some of the barriers and/or constraints this proposal creates for implementation of utility programs to deliver cost effective energy savings. 1. Regional Program Delivered By Third Parties – With the implementation proposal indicating that utility EEI dollars are now required to fund end use customer rebates for projects completed under regional programs delivered by a third party, coordination with the utility by the contractor is critical. Currently third party programs such as the Energy Smart Grocer (ESG) program are designed to allow the third party contractor to contact the end user, identify the projects, arrange for completion of those projects, and promise the incentive, without the prior knowledge or commitment of funding from the utility. While we understand that the intent of this approach is to provide consistent program delivery for all utility service territories across the region, this approach has the potential to over extend the utility budget and EEI dollars available at the local level. These design issues need to be addressed if regional program delivered by third party contractors is to continue in BPA’s EE portfolio Post 2011. A structure that would require coordination through the participating utilities would resolve this problem. 2. Conservation Potential Assessments (CPA) – It was the recommendation of Workgroup 3 that BPA should play more of an advisory/facilitator role by developing tools and helping to standardize the inputs for data collection. BPA should also be a repository for data collection tools, surveys, best practices and provide a CPA framework; all of which would make the development of a CPA easier and more useful at the local level. It was also recommended that BPA should not develop prescriptive standards and methodologies for CPAs. Neither of the two options identified in the proposal meet the intent of the workgroup recommendation. While Option 1 in the proposal represents most, but not all of the Workgroup 3 recommendation, Option 2 represent BPA’s interpretation of public power’s position during the Phase 1 dialog. HES strongly support implementation of the original recommendation of Workgroup 3. Hermiston Energy Services Cooperative appreciates the opportunity to participate in the process of the development of the Post 2011 BPA Energy Efficiency and Conservation Programs and the opportunity to comment on the proposal. Sincerely, Russell Dorran Superintendent Hermiston Energy Services
- EEIP10015 -
Vaughn/Ponderay Newsprint Co.I do not think it wise to change the incentive amount from 70% to 50%. Ponderay Newsprint Co.(PNC) is active in energy conservation but mostly due to BPAs incentive of 70%. This 70% figure moves projects that have a 3 or more years return on investment to in the 1 to 2 year return on investment. With out the 70% incentive these projecst would not be done. It is harder now to do energy conservation as the "low hanging fruit" has already been picked. Larger energy savings is possible but are more capital intensive to obtain. If the incentives are cut back to 50% most of these projects, especially the larger projects will not be done. (I know there is a proposal for local utilities to help with maybe a 20% addition but ours and others will not be able to participate in this.) Thank you for your consideration. Greg Vaughn Ponderay Newsprint Co.
- EEIP10016 -
Case/Fall River Rural Electric Coop.view attachment
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- EEIP10017 -
Dietrich/ If funding were available to upgrade existing commercial buildings & additional incentives for new commercial buildings, I think building owners would pay attention & start constructing improvements. "Because commercial buildings consume enormous amounts of energy — 40 percent of all electricity loads — and efficiency is the easiest, fastest and last expensive way to lower energy, it must play a central role in a regional energy strategy along with renewables," wrote R. Peter Wilcox, senior manager for the commercial sector of the Northwest Energy Efficiency Alliance.
- EEIP10018 -
/Northwest Food Processors AssociationView attachment
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- EEIP10019 -
Moore/Umatilla Electric CooperativeView attachment
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- EEIP10020 -
Davies/Central Lincoln PUDView attachment
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- EEIP10021 -
Coates/Tacoma PowerView attachment
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- EEIP10023 -
Peters/Columbia REAPlease disregard first comment and use this version. Sorry & thanks! February 14, 2008 Dear BPA Staff: First, we would like to express our sincere appreciation for the time and effort BPA’s Energy Efficiency staff has put into the Phase 2 effort. The workgroups were very effective at discussing issues and developing proposals that attempted to address various needs. We would even go so far as to suggest that this could be a good model for future policy development in areas so important to the customers as these programs. Especially helpful was the concerted attention given this effort by the BPA staff members who assisted us. The BPA proposal released on January 12, 2011, included a number of the recommendations the workgroups proposed, but altered some of the proposals recommended by the workgroup. Since the release of the proposal utility staff, NRU and BPA staffs have worked to address some of the issues we saw in the January 12 proposal. Recognizing that we are continuing to work on addressing these issues, these comments are submitted to clearly describe what Columbia REA strongly encourages BPA to include in its final post-2011 energy efficiency program. Small/Rural/Residential (SRR) Assistance Defining “SRR” Small/rural/residential customers face unique challenges in acquiring energy efficiency in their service territories. These utilities tend to have limited staff, significant “windshield time”, and increased administrative expense which tends to result in higher costs for obtaining the same amount of kWh savings. As such, the workgroup proposed that customers that are “small” (defined as load of 10 aMW or less), “rural” (defined using the Low Density Discount calculation for 10 consumers per mile of line or less), or “residential” (defined as 66% or more residential load) receive a higher performance payment allotment than non-SRR utilities. Higher performance payments will help offset the higher costs associated with achieving energy efficiency in small, rural or highly residential areas. In its proposal, BPA said it was concerned that the SRR criteria proposed by the workgroup were “based on data that is not as reliable or objectively referenced” as would not be the case if BPA simply used TOCAs to define different levels of performance payment. We disagree with this statement and believe there is adequate and readily available data for BPA to use to classify customers as “SRR” using the 10/10/66% definition. Calculations of customers’ loads and their eligibility for low density discount occur during each rate case, which provides the data necessary for classify customers as “small” or “rural.” If BPA is not comfortable with the vintage of the EIA data used to calculate “residential,” then the customers that are interested in being classified as “residential” should be responsible for submitting their most recent annual report data to BPA upon request. Additional Support We also encourage BPA to pursue the additional support efforts outlined in Section 6 of the BPA proposal, such as more deemed and easily implementable measures. Conservation Potential Assessments We support BPA providing standards and parameters for customers to use if they do a conservation potential assessment. This will help enable public power to aggregate data for regional purposes. Columbia REA also supports BPA continuing to work with customers in its development of the utility potential calculator. However, we do not support BPA requiring all customers to do conservation potential assessments. Utilities have sufficient motivation to do a conservation potential assessment and need the ability to adjust the level of detail and type of data collected based on their individual service territories and needs. Utility Transitional Projects Fund Columbia REA is very concerned with the retroactive cut-off date and the requirement that the project incentive level exceeds 20% of the customer’s energy efficiency incentive budget for transitional projects. The change between the current energy efficiency program to the post-2011 program is significant and customers need adequate time to adjust to the new structure. Understanding potential ripple effects on other customers, we would like to see data on the number and size of requests submitted both before and after the October 1, 2010 date, before we make a suggestion on possible changes. Large Project Funding The allocation of incentive dollars post-2011 differs significantly from the current distribution. Post-2011, BPA will allocate most of the money collected through the Tier 1 rate for energy efficiency back to customers in proportion to the amount they paid in. This is to help preserve equity among customers. Under tiered rates, a kWh of savings that is achieved in a service territory directly benefits that customer by reducing their exposure to above high water mark load. At the same time, it is important to realize that large projects (such as large commercial or industrial) are an important source of kWh savings and have complexities related to timing. Columbia REA believes there may be some approaches that resolve the issue of having funding available for large projects while still maintaining equity. We look forward to working with BPA and regional stakeholders on jointly developing a solution that addresses these needs. Pooling and Transferring of EEI Funds We appreciate BPA proposing various ways to customers to share EEI funds among one another, such as utility pools or bilateral funds transfers. This can be a useful tool particularly when balancing the “bumpiness” of conservation potential through time and in different service territories. However, it is important that pooling or bilateral transfers are not administratively or legally burdensome; otherwise, this will discourage pooling or bilateral transfers. Communication and Education We support BPA’s efforts to expand communication across the region. This will both help customers learn about new measures and programs and BPA hear feedback from customers. Given the substantial changes that are occurring post-2011, we continue to encourage BPA to provide timely information on the changes to customers so they can adapt their local utility programs as needed. Concluding Remarks In conclusion, we would like to reiterate our appreciation of BPA staff’s willingness to engage with customers and strongly encourage BPA to use the workgroup’s proposed definition of SRR utilities, work with the region to address the issue of funding large projects while maintaining equity, and ensuring there is sufficient transition between the current program and the post-2011 program. Regards, Scott Peters Manager of Marketing & Member Services
- EEIP10024 -
Drummond/Western Montana G and Tview attachment
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- EEIP10025 -
Owens/Columbia River PUDView attachment.
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- EEIP10026 -
Fulenwider/Northwest Energy Efficiency AllianceView attachment
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- EEIP10027 -
Early/ICNU
- EEIP10028 -
Sanders/Benton PUDComments are attached
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- EEIP10029 -
Dizes/Salmon River Electric Cooperative
Phase 1 Policy Framework
This comment might not be appropriate at this time but we are hoping it could be considered at some point. SREC understands why the TOCA method is used to allocate EEI dollars. However, SREC desires a mechanism be available that would allow it the option to declare how many EEI dollars it could spend prior to being allocated the costs for the EEI amounts available to us. SREC’s one large industrial customer will shortly run out of available energy efficiency projects and so it will be difficult for SREC to spend the EEI funds available. We understand the mechanisms to share those EEI funds but that does not address the costs we incur to have the EEI funds available to us. Implementation of Conservation Potential Assessment (CPA) We think that BPA can perform a role in regards to CPAs. Specifically, BPA should play the role of facilitator/enabler for utility-based CPAs by developing tools and facilitating standardized data collection processes. BPA should serve as a repository for data collection tools, surveys, and identify best practices by becoming the hub for regional data gathering. SREC does not believe in a mandated approach to CPA’s. Minimum Time for Negative Program Change We are dissatisfied with the Workgroups recommendation for a negative change notice of four times a year. Program measures should generally run continuously across multiple rate periods, but even a two- or one-year negative change notice would be an improvement. Financial Assistance for Small, Rural, and Residential Utilities We believe that consideration should be given to utilities like SREC who have 3.5 customers per mile of line but because of one large industrial load fall into the “medium” customer size and are eligible for a 20% performance cap as opposed to the 30% cap. The reality is that we are a small electric cooperative with a limited staff of 16 employees and no conservation department. We are geographically remote from anywhere which makes it difficult to pool expertise to perform and administer a conservation/efficiency program.
- EEIP10030 -
Saven/Northwest Requirements UtilitiesView attachment
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- EEIP10031 -
Nelson/Springfield Utility BoardPlease see SUB's attached comments
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- EEIP10032 -
Cauchy/Pend Oreille Public Utility DistrictSee the attachment.
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- EEIP10033 -
Ashton/Idaho Energy AuthorityView attachment
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- EEIP10034 -
Hagen/Clearwater Power CompanySee attached file.
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- EEIP10035 -
Brawley/PNGC PowerView attachment.
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- EEIP10036 -
Skeahan/Cowlitz PUDView attachment
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- EEIP10037 -
Francisco/Inland PowerView attachment
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- EEIP10038 -
Gosvener/Canby UtilityThe attached comments are submitted by Efficiency Services Group on behalf of Canby Utility Board. They represent CUB's input on the Energy Efficeincy Post-2011 Implementation Proposal. Contained within the attachment are input from Efficiency Services Group as well. If you have any comments or questions, please feel free to contact Matt Michel, Canby Utility General Manager at 503-266-1156 or Mark Gosvener, Efficiency Services Group at 1-888-883-9879. Thank you.
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- EEIP10039 -
Currier/Emerald PUDView attachment
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- EEIP10041 -
West/Snohomish PUDSee attached.
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- EEIP10042 -
Otto/Idaho Conservation LeagueView attachment
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- EEIP10043 -
Downen/Public Power CouncilView attachment
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- EEIP10044 -
Welch/EWEBPlease see attached document.
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- EEIP10045 -
Kern/City of Seattleview attachment.
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- EEIP10046 -
Clark/Franklin PUDView attachment
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- EEIP10047 -
Stull/PECIView attachment
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- EEIP10048 -
/Consumers Power, Inc.View attachment.
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- EEIP10049 -
Reynolds/Wells Rural Electric CompanyView attachment
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- EEIP10050 -
Funke/Fall River Rural Electric Coop.View attachment
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- EEIP10051 -
Etzel/Benton Rural Electric Associationview attachment
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- EEIP10052 -
Hirsh/Northwest Energy Coalitionview attachment
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- EEIP10053 -
Henderson/ConAgra Foods Lamb WestonView attachment
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Finance & Rates
