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Add comment re National Action Plan for Energy Efficiency
4 pages
English

Add comment re National Action Plan for Energy Efficiency

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September 10, 2007 Via e-mail Hon. Eleanor Stein Administrative Law Judge State of New York Public Service Commission Three Empire State Plaza Albany, NY 12223 RE: Case 07-M-0548 – Energy Efficiency Portfolio Standard Dear Judge Stein: In the August 24, 2007 letter to the parties, Your Honor established four working groups and stated (at 1) that parties choosing to submit proposals before the Working 1Groups meet should do so by September 10, 2007. The Joint Utilities hereby submit their initial proposal and comments for consideration for Working Group I, which will consider the overall EPS Structure (respective roles of NYSERDA, utilities, other energy services and efficiency providers). These initial comments are addressed principally to clarify the role of utilities in the delivery of energy efficiency programs. The Joint Utilities anticipate that they will have additional comments to provide during the working group meetings concerning the overall EPS structure and other aspects of the EPS. The Staff Report acknowledges (at 1), that the 15 by 15 goal “is the most ambitious energy reduction goal, in terms of total energy savings, of any program in the nation.” This goal cannot be achieved without capturing the savings that only the utilities are in a position to achieve for non-market transformation programs. In addition, there are activities that the utilities could undertake to enhance the success of ...

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September 10, 2007
Via e-mail
Hon. Eleanor Stein
Administrative Law Judge
State of New York Public
Service Commission
Three Empire State Plaza
Albany, NY
12223
RE:
Case 07-M-0548 – Energy Efficiency Portfolio Standard
Dear Judge Stein:
In the August 24, 2007 letter to the parties, Your Honor established four working
groups and stated (at 1) that parties choosing to submit proposals before the Working
Groups meet should do so by September 10, 2007.
The Joint Utilities
1
hereby submit
their initial proposal and comments for consideration for Working Group I, which will
consider the overall EPS Structure (respective roles of NYSERDA, utilities, other energy
services and efficiency providers).
These initial comments are addressed principally to
clarify the role of utilities in the delivery of energy efficiency programs.
The Joint
Utilities anticipate that they will have additional comments to provide during the working
group meetings concerning the overall EPS structure and other aspects of the EPS.
The Staff Report acknowledges (at 1), that the 15 by 15 goal “is the most
ambitious energy reduction goal, in terms of total energy savings, of any program in the
nation.”
This goal cannot be achieved without capturing the savings that only the utilities
are in a position to achieve for non-market transformation programs.
In addition, there
are activities that the utilities could undertake to enhance the success of planned market
transformation activities.
Underscoring the importance of these types of programs in
achieving the Commission’s goal, the Staff Report (at 122) projects that
more than half
of the savings necessary to achieve the 15 x 15 goal will come from these kind of
programs.
Thus, it is vital that the entity in the best position to offer these programs be
instrumental in their design, implementation and delivery.
1
The Joint Utilities are Central Hudson Gas & Electric Corporation, Consolidated Edison Company of New
York, Inc., KeySpan Energy Delivery New York and KeySpan Energy Delivery Long Island, New York
State Electric & Gas Corporation, Niagara Mohawk Power Corporation d/b/a National Grid, National Fuel
Gas Distribution Corporation, Orange and Rockland Utilities, Inc. and Rochester Gas & Electric
Corporation.
Hon. Eleanor Stein
September 10, 2007
Page 2 of 4
The Joint Utilities can be the successful and primary delivery entities for the non-
market transformation related programs for the following reasons because they have the
ability to leverage existing customer relationships to identify and encourage investment
in energy efficiency.
In addition, the utilities can use energy efficiency for both resource
acquisition and as a tool to defer capital expenditures associated with load relief projects.
See
Joint Utilities July 11, 2007 Responses to Staff Questions at 17-19.
Utilities have proven track records as the primary delivery entities for energy
efficiency programs.
S
ee
Staff Report at 21.
2
Under these programs, the utilities were
provided with sustained opportunities to achieve earnings that reflected the value of
energy savings to society in avoiding commitments of generating (and other) facilities
and the avoidance of environmental impacts and earn comparable returns for demand side
and supply side efforts.
3
The National Action Plan for Energy Efficiency recognizes that
utilities have
critical
roles in creating and delivering energy efficiency programs to their
communities.
4
Moreover, an EPS will seek to accomplish its goals through selling
relatively large numbers of small buyers of varying financial strength and sophistication
on the advantages of a diverse portfolio of complicated, alternative efficiency measures.
The keys to success in these markets are related to market knowledge, flexibility,
quickness and innovation. Finally, although not considered in the Staff Report, the Joint
Utilities believe that their customers generally prefer to deal with utilities.
Matters discussed in the Staff Report demonstrate that there are a number of other
reasons why the utilities should be the primary program delivery entities.
For example,
measurement and verification (“M&V”) should be performed by
independent
entities,
using identical protocols across the State, that are applied consistently to every instance
in which an entity receives public funding.
As the Staff Report states (at 15), “[i]t is
critical to ensure the measurability and persistence of energy efficiency measures that
New York State will count on as substitutes for new generation and delivery facilities.”
There is an alignment of interests here between the utilities and the EPS.
The Joint
Utilities, because of the functional necessity that reliable forecasts of energy efficiency be
included in their system planning efforts, are strongly committed to a rigorous M&V
effort.
2
While the Staff Report states (at 21) that the utilities’ efficiency expertise “has been seriously attenuated,”
which occurred as a result of the State’s decision to transfer responsibility to NYSERDA in 1998, utilities
continue to employ individuals with direct experience in energy efficiency programs the utilities developed
(many of which included significant innovations, and all of which produced lasting benefits to the State).
Moreover, there should be no question of the utilities’ ability to ramp-up to this new effort quickly, as they
did in the late 1980s and early 90s when called upon to do so by the Commission.
3
Utilities have been authorized to recover costs associated with the design, start-up, implementation and
administration of their programs.
The Joint Utilities assume that a similar mechanism for recovery would
be authorized here, in a rate plan or in a manner otherwise permitted by the Commission.
4
National Action Plan for Energy Efficiency, July 2006, pp. 1-10, available at
http://www.epa.gov/solar/pdf/napee/napee_report.pdf.
Hon. Eleanor Stein
September 10, 2007
Page 3 of 4
In addition, the Staff Report states that “[g]etting energy price signals better
aligned with the costs of providing services is a critical part of effectively developing
energy efficiency as a resource.”
The Joint Utilities agree that economically efficient
rate designs reflecting the underlying costs to serve are generally desirable.
The utilities
have already played a crucial role here with the introduction of mandatory hourly pricing
(“MHP”) for their full service customers and their outreach and education efforts in
support of MHP.
The Joint Utilities look forward to actively participating in this Working Group.
Respectfully submitted,
_______/s/_______________
Robert J. Glasser, Esq.
Thompson Hine LLP
335 Madison Ave.
New York, NY
10017
Direct: (212) 344-5680
Email:
Bob.Glasser@thompsonhine.com
Attorneys for Central Hudson Gas &
Electric Corporation
______/s/________________
Richard B. Miller, Esq.
Consolidated Edison Company of New
York, Inc.
4 Irving Place
New York, NY
10003
Direct: (212) 460-3762
Fax: (212) 677-5850
Email:
MILLERRICH@coned.com
Attorney for Consolidated Edison
Company of New York, Inc. and Orange
and Rockland Utilities, Inc.
______/s/________________
Catherine L. Nesser, Esq.
Debra H. Rednik, Esq.
KeySpan Corporation
One MetroTech Center
Brooklyn, NY
11201
Direct: (718) 403-3073
Fax: (718) 403-2698
Email:
cnesser@keyspanenergy.com
drednik@keyspanenergy.com
Attorneys for KeySpan Energy Delivery
New York and KeySpan Energy Delivery
Long Island
_________/s/____________
Amy A. Davis, Esq.
LeBoeuf, Lamb, Greene & MacRae
125 West 55
th
Street
New York, NY
10019
Direct: (212) 424-8575
Fax: (212) 649-0464
Email:
aadavis@llgm.com
Attorneys for New York State Electric &
Gas Corporation and Rochester Gas and
Electric Corporation
Hon. Eleanor Stein
September 10, 2007
Page 4 of 4
____/s/__________________
Janet M. Audunson, P.E., Esq.
Hiscock & Barclay LLP
c/o National Grid
300 Erie Boulevard West, A-3
Syracuse, NY 13202
Direct:
(315) 428-3411
Fax:
(315) 428-6407
Email:
janet.audunson@us.ngrid.com
Attorney for Niagara Mohawk Power
Corporation d/b/a National Grid
__/s/_________________________
Michael Reville, Esq.
National Fuel Gas Distribution Corporation
6363 Main Street
Buffalo, New York 14221
Direct: (716) 857-7313
Email:
RevilleM@NatFuel.com
cc:
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