Revised, final CEE comment letter to NAESB

September 25, 2009 Rae McQuade President North American Energy Standards Board 1301 Fannin, Suite 2350 Houston, TX 77002 Dear Ms. McQuade: I am writing on behalf of the CEE Evaluation Committee and the undersigned CEE members to comment on the wording of the proposed scope for NAESB 2009 Annual Plan Item 4(g), "Develop business practice standards for measurement and verification of energy reductions from energy efficiency." CEE is a consortium of efficiency program administrators from across the U.S. and Canada who work together on common approaches to advancing efficiency. CEE's 118 members administer ratepayer-funded energy efficiency programs in 37 states and 7 Canadian provinces. The CEE Evaluation Committee is composed of experienced energy efficiency program evaluation staff from across the CEE membership. We find the current wording of item 4(g) unclear from the perspective of administrators of "retail" energy efficiency programs. The current scope wording has made it impractical for the organizations participating in CEE's Evaluation Committee to determine the importance of attending to the work of the WEQ/REQ DSM-EE Subcommittee. Below we provide some further insight and suggestions related to this for NAESB's consideration. Observations The ambiguity we note hinges on the differing use and interpretation of certain key terms in the retail versus wholesale contexts: "project," "program," "product," and "M&V." This has ...