430R06900
 ational Action  Plan
or Energy  Efficiency
    A PLAN DEVELOPED BY MORE THAN 50 LEADING

       ORGANIZATIONS IN PURSUIT OF ENERGY SAVINGS

    AND ENVIRONMENTAL BENEFITS THROUGH

       ELECTRIC AND NATURAL GAS ENERGY EFFICIENCY

    JULY 2006

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Acknowledgements
The National Action  Plan for Energy Efficiency Report discusses policy, planning, and program issues based on a formal
work plan developed during the December 2005 and March 2006 Leadership Group meetings.  The Leadership Group is
led by co-chairs Diane Munns (Member of the Iowa Utilities Board and President of the National Association of Regulatory
Utility Commissioners) and  Jim Rogers (President and Chief  Executive Officer of Duke Energy). A full list of Leadership
Group members is provided in both the  Executive Summary (Table ES-1) and Chapter 1 (Table 1-2) of this report.  Rich
Scheer of Energetics  Inc. facilitated the Leadership Group discussions during both Leadership Group meetings.

Expert consultants, funded by the U.S.  Department of Energy (DOE) and the U.S. Environmental  Protection Agency
(EPA), drafted many chapters of the Action Plan Report. These consultants included:

•Regulatory Assistance Project: Chapter 2 and Appendix A

•Energy and Environmental Economics, Inc.: Chapters 3 through 5, Energy Efficiency Benefits Calculator,
 and Appendix B

•KEMA: Chapters

In  addition,  Rich Sedano of the Regulatory Assistance Project and  Alison Silverstein  of Alison  Silverstein Consulting
provided their expertise during review and editing of the overall report.

DOE and  EPA facilitated the work of the Leadership Group  and this report, including Larry Mansueti with DOE's Office
of Electricity Delivery and  Energy Reliability, Mark Ginsberg  with DOE's  Office of Energy  Efficiency and Renewable
Energy, and Kathleen Hogan,  Stacy Angel, Maureen McNamara,  Katrina Pielli, and Tom Kerr with  EPA's Climate
Protection Partnership Division.

Eastern Research Group, Inc.  provided technical review, copyediting, graphics, and production services.
To create a sustainable, aggressive national commitment to energy efficiency

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List of Figures

Figure ES-1. National Action Plan for Energy Efficiency Recommendations	ES-2
Figure ES-2. National Action Plan for Energy Efficiency Recommendations & Ootions	ES-8
Figure 1-1.   Energy Efficiency Spending Has Declined	1-5
Figure 1-2.   Energy Efficiency Has Been a Resource in the Pacific Northwest for the Past Two Decades.... 1-7
Figure 1-3.   National Action Plan for Energy Efficiency Report Addresses Actions to Encourage
             Greater Energy Efficiency	1-11
Figure 3-1.   Energy-Efficiency Supply Curve -  Potential in 2011	3-2
Figure 3-2.   California  Efficiency Structure Overview	3-10
Figure 3-3.   California  Investor-Owned Utility  Process	3-11
Figure 3-4.   BPA Transmission Planning Process	3-12
Figure 3-5.   New York Efficiency Structure Overview	3-13
Figure 4-1.   Comparison of Deferral Length with Low- and High-Growth	4-10
Figure 6-1.   Impacts of the Northeast  Lighting and  Appliance Initiative	6-33
Figure 7-1.   National Action Plan for Energy Efficiency Recommendations	7-1
Figure 7-2.   National Action Plan for Energy Efficiency Report Addresses Actions to Encourage
             Greater Energy Efficiency	7-2
 ii    National Action Plan for Energy Efficiency

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 List of Tables

Table ES-1. Members of the National Action Plan for Energy Efficiency	ES-10
Table 1-1.  Summary of Benefits for National Energy Efficiency Efforts	1-8
Table 1-2.  Members of the National Action Plan for Energy Efficiency	1-16
Table 2-1.  Options to Mitigate the Throughput Incentive: Pros and Cons	2-6
Table 2-2.  Examples of Decoupling	2-12
Table 2-3.  Examples of Incentives for Energy Efficiency Investments	2-15
Table 3-1.  Levelized Costs and Benefits From  Four  Regions	3-9
Table 3-2.  Incorporation of Energy Efficiency in California's Investor-Owned Utilities'
            Planning Processes	3-11
Table 3-3.  Incorporation of Energy Efficiency in BPA's Planning Processes	3-13
Table 3-4.  Incorporation of Energy Efficiency in NYSERDA's Planning Processes	3-14
Table 3-5.  Incorporation of Energy Efficiency in Minnesota's Planning Processes	3-15
Table 3-6.  Incorporation of Energy Efficiency in Texas' Planning Processes	3-16
Table 3-7.  Incorporation of Energy Efficiency in PacifiCorp's Planning Processes	3-17
Table 4-1.  Summary of Main Assumptions and Results for  Each Business Case Analyzed	4-3
Table 4-2.  High- and Low-Growth Results: Electric  Utility	4-6
Table 4-3.  High- and Low-Growth Results: Natural  Gas Utility	4-8
Table 4-4.  Power Plant Deferral Results	4-11
Table 4-5.  Vertically Integrated and Delivery Company Results	4-13
Table 4-6.  Publicly- and Cooperatively-Owned  Utility Results	4-15
Table 5-1.  Partial List of Utilities With Inclining Tier Residential Rates	5-6
Table 5-2.  Pros  and Cons of Rate Design Forms	5-9
Table 5-3.  Conditions That Assist Success	5-11
Table 6-1.  Overview of Energy  Efficiency Programs	6-4
Table 6-2.  Efficiency Measures of Natural Gas Savings Programs	6-6
Table 6-3.  Efficiency Measures  of Electric  and Combination Programs	6-8
Table 6-4.  Achievable Energy Efficiency Potential  From Recent Studies	6-16
Table 6-5.  NYSERDA 2004 Portfolio	6-20

To create a sustainable, aggressive national commitment to energy efficiency                                           iii

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List Of Tables (continued)

Table 6-6.  Nevada Resource Planning Programs	6-21
Table 6-7.  Overview of Cost-Effectiveness Tests	6-23
Table 6-8.  Research & Development (R&D) Activities of Select Organizations  	6-25
Table 6-9.  Emerging Technologies for Programs	6-27
Table 6-10. Key Stakeholders, Barriers, and Program Strategies by Customer Segment	6-31
Table 6-11. Types of Financial Incentives	6-40
Table 6-12. Sample Progression of Program Designs	6-42
Table 6-13. Program Examples for Key Customer Segments	6-44
Table 6-14. Evaluation Approaches	6-46
Table 7-1.  Leadership Group Recommendations and Options to Consider,  by Chapter	7-3
 iv   National Action Plan for Energy Efficiency

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 List of Acronyms
aMW

B
Bcf
BOMA
BPA
C/l
CEC
C02
CPP
CPUC

D

DEER

DOE
DSM
EE
EEPS
EERS
EPA
EPRI
ESCO
ETO
average megawatts
billion cubic feet
Building Owners & Managers
Association
Bonneville Power Administration
commercial and industrial
California Energy Commission
carbon dioxide
critical peak pricing
California Public Utility Commission
Database for Energy Efficiency
Resources
U.S. Department of Energy
demand-side management
energy efficiency
energy efficiency portfolio standard
energy efficiency resource standard
U.S. Environmental Protection Agency
Electric Power Research Institute
energy services company
Energy Trust of Oregon
F
FERC
GWh

H

HERS
HVAC
IOU
IPMVP

IRP
ISO
ISO-NE

K

kWh

L

LIHEAP

LI PA
Federal Energy Regulatory Commission
gigawatt-hour (1,000,000 kWh)
                                                            Home Energy Rating System
                                                            heating, ventilation, and air
                                                            conditioning
investor-owned utility
International Performance
Measurement and Verification
Protocol
integrated resource plan
independent system operator
ISO New England
                                                            kilowatt-hour (3,412 British thermal units)
Low-Income Home Energy Assistance
Program
Long Island Power Authority
To create a sustainable, aggressive national commitment to energy efficiency

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List Of Acronyms (continued)
M

M&V
Mcf
MMBtu
MW
MWh

N

NEEP
NERC

NOX
NPV
NSPC

NWPCC

NYSERDA
measurement and verification
one thousand cubic feet
million British thermal units
megawatt (1,000,000 watts)
megawatt-hour (1,000 kWh)
Northeast Energy Efficiency Partnerships
North American Electric Reliability
Council
nitrogen oxides
net present value
Non-Residential Standard
Performance Contract
Northwest Power and Conservation
Council
New York State Energy Research and
Development Authority
R

R&D
RARP

REAP

RFP
RGGI
RIM
ROE
RPC
RTO
RTP
SBC
SCE
SMUD
S02
research and development
Residential Appliance Recycling
Program
Residential Energy Affcrdability
Partnership Program
request for proposals
Regional Greenhouse Gas Initiative
rate impact measure
return on equity
revenue per customer
regional transmission organization
real-time pricing
system benefits charge
Southern California Edison
Sacramento Municipal Utility District
sulfur dioxide
PBL        Power Business Line
PG&E      Pacific Gas & Electric
PIER       Public Interest Energy Research
PSE        Puget Sound Energy
PUCT      Public Utility Commission of Texas
PURPA     Public Utility Regulatory Policies Act
                                     TOU
                                     TRC

                                     V

                                     VOLL
                                     VOS
           time of use
           total resource cost
                                                            value of lost load
                                                            value of service
                                                 w
                                                 WAP
                                                 Weatherization Assistance Program
vi   National Action Plan for Energy Efficiency

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Table of Contents

Acknowledgements	i
List of Figures	ii
List of Tables	iii
List of Acronyms	v
Executive Summary	ES-1
Chapter 1: Introduction and Background	1-1
Chapter 2: Utility Ratemakmg & Revenue Requirements	2-1
Chapter 3: Energy Resource Planning Processes	3-1
Chapter 4: Business Case for Energy Efficiency	4-1
Chapter 5: Rate Design	5-1
Chapter 6: Energy Efficiency Program Best Practices	6-1
Chapter 7: Report Summary	7-1
Appendix A: Additional  Guidance on Removing the Throughput Incentive	A-1
Appendix B: Business Case Details	B-1
To create a sustainable, aggressive national commitment to energy efficiency                                         vii

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Executive Summary
This National Action Plan for Energy Efficiency (Action Plan) presen ; policy recc  rm
a sustainable,  aggressive national commitment to energy efficie cy through  jas
utility regulators, and partner organizations. Such a commitment • ould save A.i-ierl
dollars  on energy bills  over the next  10 to 15 years, contribute to energy secun ,
environment. The Action Plan was developed by  more than 50 leading organizati;  v
stakeholder perspectives. These organizations pledge to take specific actions to make tht
                                                                                      represent -ny Key
                                                                                      tum Pkm <  reality.
A National Action Plan
for Energy Efficiency

We currently face a set of serious challenges with regard
to the U.S. energy system. Energy demand continues to
grow despite historically high energy prices and mount-
ing concerns over energy security and  independence as
well as air pollution and global climate change. The deci-
sions we make now  regarding our energy supply and
demand can either help  us  deal with  these  challenges
more effectively or complicate our ability to secure  a
more stable, economical energy future.

Improving the energy efficiency1 of our homes, business-
es,   schools,  governments,  and  industries—which
consume more than 70 percent of the natural gas and
electricity used in  the country—is one  of  the most
constructive, cost-effective ways  to address these chal-
lenges.2 Increased investment in energy efficiency in our
homes, buildings, and industries  can lower energy bills,
reduce demand for fossil fuels,  help  stabilize  energy
prices, enhance electric and  natural gas system reliabili-
ty, and help reduce air pollutants and greenhouse gases.

Despite these benefits and the success of energy effi-
ciency programs in some regions of the country,  energy
efficiency remains critically underutilized in the nation's
energy portfolio.3 Now we simultaneously face the chal-
lenges of high  prices, the need for large investments in
new energy infrastructure, environmental concerns, and
                                                     security issues.  It is time to i/-,\e a ••  int.-:' <>::• •• >•  "•!' •*'-: t^an
                                                     two decades of experience with  ..^.cev/u! energy e'fi
                                                     ciency programs, broaden and expand these efforts, ana
                                                     capture the savings that energy efficiency offers  Much
                                                     more can be achieved in concert with ongoing efforts to
                                                     advance building codes and appliance standards, provide
                                                     tax incentives for efficient products and buildings, and
                                                     promote savings opportunities through programs such
                                                     as ENERGY STARฎ. Efficiency of new buildings and those
                                                     already in place are both important. Many homeowners,
                                                     businesses, and others in buildings  and facilities already
                                                     standing today—which will  represent the vast majority
                                                     of the nation's buildings  and facilities  for  years  to
                                                     come—can realize significant savings from proven energy
                                                     efficiency programs.

                                                     Bringing more  energy efficiency into the nation's energy
                                                     mix to slow demand growth  in a  wise,  cost-effective
                                                     manner—one that balances energy  efficiency with new
                                                     generation  and supply options—will take  concerted
                                                     efforts  by all energy market participants: customers, util-
                                                     ities,  regulators,  states,  consumer advocates,  energy
                                                     service companies (ESCOs),  and  others. It will  reguire
                                                     education  on the opportunities, review of existing poli-
                                                     cies, identification of barriers and their solutions,  assess-
                                                     ment of new technologies,  and modification and  adop-
                                                     tion of policies, as appropriate. Utilities,4 regulators, and
                                                     partner organizations need  to improve customer access
                                                     to energy efficiency programs to help them control their
                                                     own  energy costs, provide the  funding necessary  to
To create a sustainable, aggressive national commitment to energy efficiency
                                                                                                   ES-1

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deliver these programs, and  examine policies governing
energy companies to ensure that these policies  facili-
tate—not impede—cost-effective  programs for energy
efficiency.  Historically,  the  regulatory structure has
rewarded utilities  for building infrastructure (e.g., power
plants, transmission lines,  pipelines) and selling energy,
while discouraging  energy  efficiency,  even  when the
energy-saving measures cost less than constructing new
infrastructure.5 And, it has been difficult to establish the
funding necessary to capture the potential benefits that
cost-effective energy efficiency offers.

This National Action Plan for  Energy Efficiency is a call to
action  to bring   diverse  stakeholders together at the
national,  regional, state, or  utility  level, as appropriate,
and foster the discussions, decision-making, and commit-
ments necessary to take investment in energy efficiency to
a new level. The  overall goal is to create a sustainable,
aggressive  national   commitment   to  energy  efficiency
through gas and  electric utilities,  utility regulators, and
partner organizations.

The Action Plan was developed by a Leadership Group
composed of more than 50 leading organizations repre-
senting diverse stakeholder perspectives. Based  upon the
policies,  practices,  and  efforts of many organizations
across the country,  the  Leadership  Group  offers five
                                          recommendations as ways  to  overcome  many of ~he
                                          barriers that have limited greater investment in programs
                                          to deliver energy efficiency to customers of electric and
                                          gas utilities (Figure ES-1).  These recommendations  may
                                          be  pursued  through a  number of different  options,
                                          depending upon state and utility circumstances.

                                          As part of the Action Plan,  leading organizations are com-
                                          mitting to aggressively pursue energy efficiency opportu-
                                          nities in their organizations and assist others who want to
                                          increase the use of energy  efficiency  in  their regions.
                                          Because greater investment  in  energy  efficiency cannot
                                          happen based on the work of one individual or organiza-
                                          tion alone, the Action Plan is a commitment to bring the
                                          appropriate  stakeholders  together—including  utilities,
                                          state  policy-makers,  consumers, consumer  advocates,
                                          businesses, ESCOs, and others—to be part of a collabora-
                                          tive effort  to take energy efficiency to a  new level. As
                                          energy experts, utilities may be in a unique position to play
                                          a leading role.

                                          The reasons  behind the National Action Plan  for Energy
                                          Efficiency,  the process for developing  the Action Plan,
                                          and  the final recommendations  are summarized  in
                                          greater detail as follows.
   Figure ES-1. National Action Plan for Energy Efficiency Recommendations
   • Recognize energy efficiency as a high-priority energy resource.

   • Make a strong, long-term commitment to implement cost-effective energy efficiency as a resource
    1 Broadly communicate the benefits of and opportunities 1
    1 Promote sufficient, timely, and stable program funding t> deliver energy efficiency where cost-effective
    • Modify policies to align utility incentives with the delive
     modify ratemaking practices to promote energy efficien
                                            or energy efficiency.
                                            •y of cost-effective energy efficiency and
                                            y investments.
 ES-2
National Action Plan for Energy Efficiency

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The United States Faces Large and
Complex  Energy  Challenges

Our expanding economy, growing population, and rising
standard of living all depend on energy services. Current
projections anticipate U.S. energy demands to increase
by more than  one-third by 2030, with electricity demand
alone rising by more than 40  percent (EIA, 2006). At
work and  at  home, we  continue to rely on more  and
more energy-consuming  devices. At the  same time, the
country has entered a period of higher energy costs and
limited supplies of natural gas, heating oil, and other
fuels. These issues present many challenges:

Growing  energy demand  stresses current systems,
drives up energy costs, and requires new investments.
Events  such  as  the Northeast electricity blackout of
August  2003  and Hurricanes Katrina and  Rita in 2005
increased  focus on  energy reliability and  its economic
and human impacts. Transmission and pipeline systems
are becoming overburdened in places.  Overburdened
systems limit  the availability of low-cost electricity  and
fossil fuels, raise  energy prices in  or near congested
areas, and potentially compromise energy system relia-
bility. High fuel prices also contribute to  higher electrici-
ty prices. In addition, our  demand for natural gas to heat
our homes, for  industrial  and  business use,  and for
power generation is straining the available  gas supply in
North America and putting upward pressure on natural
gas prices. Addressing these issues will require billions of
dollars  in  investments  in energy efficiency, new power
plants,  gas rigs, transmission lines, pipelines, and other
infrastructure, notwithstanding  the difficulty of building
new energy infrastructure in dense urban and suburban
areas. In the absence of  investments in new or expand-
ed capacity, existing facilities are being stretched to the
point where system reliability is steadily eroding, and the
ability to import lower cost energy into high-growth load
areas is inhibited, potentially limiting economic expansion.

High fuel  prices  increase financial burdens on house-
holds and businesses and  slow our economy.  Many
household budgets are being strained by higher energy
costs, leaving less money available for other household
purchases and needs. This burden is particularly harmful
for low-income  households.  Higher energy  bills  for
industry can reduce the nation's economic competitive-
ness and place U.S. jobs at risk.

Growing energy demand  challenges  attainment of
clean air and  other public health and  environmental
goals.  Energy  demand continues to  grow at the  same
time that national and state regulations are being imple-
mented to limit the emission of air pollutants, such as sul-
fur dioxide  (S02), nitrogen oxides (NOX), and mercury, to
protect public  health and the  environment. In addition,
emissions of greenhouse gases  continue to increase.

Uncertainties  in future prices  and regulations  raise
questions about new investments.  New infrastructure
is being planned in the face of uncertainties about future
energy prices.  For example, high natural gas prices and
uncertainty about  greenhouse gas  and  other environ-
mental regulations, impede investment decisions on new
energy supply options.

Our energy system is  vulnerable  to  disruptions in
energy supply and delivery.  Natural disasters such as
the hurricanes of 2005 exposed the vulnerability of the
U.S. energy system to major disruptions, which have sig-
nificant impacts on energy prices and service reliability. In
response,  national security concerns suggest  that we
should use fossil fuel energy  more efficiently, increase
supply diversity, and decrease the vulnerability of domes-
tic infrastructure to natural disasters.

Energy  Efficiency Can  Be a Beneficial
Resource  in Our Energy Systems

Greater investment in energy efficiency can help us tack-
le  these challenges. Energy efficiency is already a key
component in  the nation's energy resource mix in  many
parts of the country. Utilities,  states, and others across
the United States have decades of experience in deliver-
ing energy efficiency to their customers. These programs
can provide valuable models, upon  which  more states,
To create a sustainable, aggressive national commitment to energy efficiency
                                              ES-3

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 Benefits of Energy Efficiency
 Lower energy bills,  greater customer control,  and
 greater customer satisfaction. Well-designed energy
 efficiency programs can provide opportunities for  cus-
 tomers of all types to adopt energy savings measures
 that can improve their comfort and level of service,
 while reducing their energy bills.6 These programs can
 help  customers  make  sound energy  use  decisions,
 increase control over their energy bills, and empower
 them to manage their energy usage. Customers are
 experiencing  savings of 5, 10, 20, or  30 percent,
 depending upon the customer, program,  and average
 bill. Offering these programs can also lead to greater
 customer satisfaction with the service provider.

 Lower cost than supplying  new generation only
 from new  power  plants.  In  some states, well-
 designed energy efficiency programs are  saving ener-
 gy at an average cost of about one-half of the  typical
 cost of new power sources and about one-third of the
 cost of  natural gas  supply (EIA, 2006).7 When inte-
 grated into a long-term energy resource  plan, energy
 efficiency  programs  could help  defer  investments
 in new  plants and lower the total cost of delivering
 electricity.

 Modular and quick to deploy. Energy efficiency  pro-
 grams can be ramped up over a period of one to three
 years to deliver  sizable savings. These programs can
 also be targeted to  congested areas with high prices
 to bring relief where it might be difficult to  deliver
 new supply in the near term.

 Significant  energy  savings. Well-designed energy
 efficiency  programs  are delivering  annual energy sav-
 ings on the order of 1 percent of electricity and natu-
 ral gas sales.8 These programs are helping to offset 20
 to 50 percent of expected growth in energy demand
 in some areas without compromising  the end users'
 activities and economic well-being  (Nadel et al., 2004;
 EIA, 2006).
                                         Environmental benefits. While  reducing customers
                                         energy bills,  cost-effective  energy efficiency  offers
                                         environmental benefits related to reduced  demanc
                                         such as lower air pollution,  reduced  greenhouse gas
                                         emissions, lower water use, and less environments
                                         damage from fossil fuel extraction. Energy  efficiency
                                         can be an attractive option  for utilities in advance of
                                         requirements  to reduce greenhouse gas emissions.

                                         Economic development. Greater investment in ener-
                                         gy  efficiency  helps build  jobs   and  improve  state
                                         economies. Energy efficiency users often redirect their
                                         bill  savings toward  other activities that increase local
                                         and national employment, with a higher employment
                                         impact than if the money had been spent to purchase
                                         energy (Kushler et al.,  2005; NYSERDA,  2004). Many
                                         energy efficiency programs  create construction  and
                                         installation jobs,  with  multiplier  impacts on employ-
                                         ment and local economies. Local investments in ener-
                                         gy  efficiency  can offset imports from  out-of-state,
                                         improving the state balance of  trade. Lastly, energy
                                         efficiency investments usually   create   long-lasting
                                         infrastructure changes to building,  equipment  and
                                         appliance  stocks,  creating  long-term  property
                                         improvements that deliver long-term economic value
                                         (Innovest, 2002).

                                         Energy security. Energy efficiency reduces the level of
                                         U.S. per capita energy consumption, thus decreasing
                                         the vulnerability of the economy and individual con-
                                         sumers to energy price disruptions from  natural disas-
                                         ters and attacks on domestic and international energy
                                         supplies and  infrastructure.  In addition, energy  effi-
                                         ciency can be used to  reduce the overall system peak
                                         demand  or the peak demand in targeted load  areas
                                         with  limited  generating   or  transport capability.
                                         Reducing  peak demand  improves system reliability
                                         and reduces  the  potential for  unplanned  brown-
                                         outs or  black-outs, which  can  have large adverse
                                         economic consequences.
ES-4
National Action Plan for Enemy Efficiency

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 :;ntiex ana  vther  uruanvMaon-,  ;(.i'  i<;iid. Expeneni.e
 VIGW-.  li'iat  eneray  efU eiicy  ptoqidi-ib  c.an  io\vei
 Customer  energy bills, cost  less than, ,ind  help deter,
 new energy  infrastructure,  provide  energy savings  to
 consumers;  improve  the environment,  and spur local
 economic development  (see  box on  Benefits  of
 Energy  Efficiency). Significant  opportunities for energy
 efficiency  are likely to continue to  be available at low
 costs in the future. State and regional studies have found
 that adoption  of economically  attractive,  but as  yet
 untapped,  energy efficiency could yield more than 20
 percent savings in total electricity demand nationwide by
 2025. Depending on the underlying load growth, these
 savings  could help cut load growth by half or more com-
 pared to current  forecasts (Nadel et al.,  2004; SWEEP,
 2002;   NEEP,  2005;  NWPCC,  2005;  WGA, 2006).
 Similarly, savings  from direct use of natural gas could
 provide a 50  percent or greater reduction in  natural gas
 demand growth (Nadel et al., 2004).

 Capturing this  energy efficiency  resource would  offer
 substantial economic and environmental benefits across
 the country. Widespread application  of energy efficiency
 programs that already exist in some  regions could deliv-
 er a large part of  these potential savings.9  Extrapolating
 the results from existing programs to the entire country
 would yield annual energy bill savings of nearly $20  bil-
 lion, with net societal benefits of more than $250 billion
 over the next 10  to 15 years. This scenario could defer
 the need for  20,000 megawatts (MW), or 40 new 500-
 MW power plants, as well as reduce  U.S. emissions from
 energy  production and  use  by more  than  200 million
 tons of  carbon dioxide (CO.), 50,000 tons of  SO,,  and
 40,000  tons  of NO, annually.10  These significant eco-
 nomic and environmental benefits can be achieved rela-
 tively guickly  because energy efficiency programs can be
 developed and  implemented within several years.

Additional policies and  programs are reguired to help
capture  these potential  benefits  and address  our sub-
stantial underinvestment in energy efficiency as  a nation.
An important indicator of this underinvestment is that
the level of funding across the country for organized effi-
• iency piograms is uii'enrv !<-'>s 'aan $/' bii ion per yeai
while it would require about A time1-, tocay's funding lev-
els to  achieve the economic  ana environment benefits
presented above.' '• '•••'

The current underinvestment  >n energy efficiency is due
to a number of well-recognized barriers, including some
of the regulatory policies that govern electric and natu-
ral  gas utilities. These  barriers include:

• Market barriers, such as the well-known "split-
  incentive" barrier, which limits home builders' and
  commercial developers' motivation to invest in energy
  efficiency for new buildings  because they do not
  pay the energy bill; and the  transaction cost barrier,
  which chronically affects individual consumer and
  small business decision-making.

• Customer barriers, such as lack of information on
  energy saving opportunities, lack of awareness of
  how energy efficiency programs make investments
  easier, and lack of funding to invest in energy
  efficiency.

• Public policy barriers, which  can present prohibitive
  disincentives for utility support and investment in
  energy efficiency in  many cases.

• Utility, state, and regional planning barriers, which
  do not allow energy  efficiency to compete with
  supply-side resources in energy planning.

• Energy efficiency program  barriers, which limit
  investment due to lack of knowledge about the
  most effective and cost-effective energy efficiency
  program portfolios,  programs for overcoming
 common marketplace barriers to energy efficiency,
 or available technologies.

While  a number of energy efficiency policies and programs
contribute to addressing these barriers, such  as building
codes,  appliance standards, and state government lead-
ership programs, organized energy efficiency programs
To create a sustainable, aggressive national commitment to energy efficiency
                                               ES-5

-------
provide an  important  opportunity  to deliver greater
energy efficiency in the homes, buildings, and facilities
that already exist today and that will consume the major-
ity of the energy used in these sectors for years to come.

The Leadership Group and National
Action Plan for Energy Efficiency

Recognizing  that  energy  efficiency  remains a critically
underutilized resource in  the  nation's  energy  portfolio,
more than 50 leading electric and gas utilities,  state util-
ity commissioners, state air and energy agencies, energy
service providers,  energy consumers,  and energy effi-
ciency  and   consumer  advocates  have  formed  a
Leadership Group, together with the U.S. Department of
Energy (DOE)  and  the U.S.  Environmental Protection
Agency (EPA), to address the issue. The goal of  this
group is to create a sustainable, aggressive national com-
mitment to  energy efficiency through gas and electric
utilities, utility regulators, and partner organizations. The
Leadership Group recognizes that utilities and regulators
play critical roles in bringing energy efficiency  programs
to their communities and  that success  requires the joint
efforts of customers,  utilities, regulators, states, and
other partner organizations.

Under co-chairs Diane Munns (Member of  the Iowa
Utilities Board and  President of the National Association
of  Regulatory Utility Commissioners)  and Jim Rogers
(President and Chief Executive Officer  of Duke Energy),
the Leadership  Group members (see  Table  ES-1) have
developed the National  Action  Plan  for Energy  Efficiency
Report, which:

• Identifies key barriers limiting greater investment in
  energy efficiency.

• Reviews sound business  practices for removing these
  barriers and improving the acceptance and use of
  energy efficiency relative to energy supply options.

• Outlines recommendations and options for
  overcoming these barriers.
                                          The members of the Leadership Group have agreed to
                                          pursue  these  recommendations  and  consider these
                                          options through their own  actions, where appropriate,
                                          and to support energy efficiency initiatives  by other
                                          industry members and stakeholders.

                                          Recommendations

                                          The National Action Plan for Energy Efficiency is a call to
                                          action to utilities, state utility regulators, consumer advo-
                                          cates, consumers, businesses, other state officials,  and
                                          other  stakeholders to create an aggressive, sustainable
                                          national commitment to energy efficiency.1 The Action
                                          Plan offers the  following recommendations as ways to
                                          overcome barriers that have limited  greater investment
                                          in energy efficiency for customers of electric and gas util-
                                          ities in many parts of the country.  The following recom-
                                          mendations are based on  the  policies, practices,  and
                                          efforts of leading organizations across the country. For
                                          each recommendation, a number of options  are avail-
                                          able to be pursued  based on  regional, state, and utility
                                          circumstances (see also Figure ES-2).

                                          Recognize energy efficiency as a high-priority energy
                                          resource.  Energy efficiency has  not been  consistently
                                          viewed as  a meaningful or dependable resource corn-
                                          pared to new supply options, regardless of its demon-
                                          strated contributions to  meeting  load growth.13
                                          Recognizing energy efficiency as a high-priority energy
                                          resource  is an  important step in efforts to  capture the
                                          benefits it offers and lower the overall cost of energy
                                          services to customers. Based on jurisdictional objectives,
                                          energy efficiency can be incorporated into resource plans
                                          to account for the long-term  benefits from energy sav-
                                          ings, capacity savings, potential reductions of air pollu-
                                          tants and greenhouse gases,  as well as other benefits.
                                          The explicit integration of  energy efficiency  resources
                                          into the formalized resource planning processes  that
                                          exist at regional, state, and utility  levels can help estab-
                                          lish the rationale for energy efficiency funding levels and
                                          for properly valuing and balancing the benefits. In some
                                          jurisdictions, these  existing planning processes might
                                          need  to  be adapted  or even  created  to  meaningfully
ES-6
National Action Plan for Energy Efficiency

-------
incorporate energy  efficiency  resources  into resource
planning. Some states have recognized energy efficiency
as the resource of first priority due to its broad benefits.

Make  a strong, long-term commitment to implement
cost-effective energy  efficiency as  a resource.  Energy
efficiency programs are most successful and provide the
greatest benefits to stakeholders when appropriate poli-
cies are established and maintained over the long-term.
Confidence in  long-term stability  of the program will
help  maintain  energy  efficiency  as  a  dependable
resource compared to supply-side resources, deferring or
even avoiding the need  for other  infrastructure invest-
ments, and maintain customer awareness and support.
Some  steps might  include assessing  the  long-term
potential  for cost-effective  energy  efficiency within  a
region (i.e., the energy efficiency that can be delivered
cost-effectively through proven programs for each cus-
tomer  class within a planning  horizon);  examining the
role for cutting-edge initiatives and technologies; estab-
lishing the cost of supply-side options versus energy effi-
ciency; establishing robust measurement and verification
(M&V) procedures; and providing for routine updates to
information on energy efficiency potential and key costs.

Broadly communicate the benefits  of and opportuni-
ties for energy efficiency. Experience shows that ener-
gy efficiency programs help customers save money and
contribute to lower cost energy systems. But these ben-
efits are  not fully documented nor  recognized by cus-
tomers,  utilities,  regulators,  or  policy-makers.  More
effort is needed to establish the business case for ener-
gy efficiency for all decision-makers and to show how a
well-designed approach to energy efficiency can benefit
customers,  utilities,  and  society by  (1)  reducing  cus-
tomers' bills over time, (2) fostering  financially healthy
utilities (e.g., return  on equity, earnings per share, and
debt coverage ratios  unaffected), and (3) contributing to
positive societal net benefits overall. Effort is also neces-
sary to educate key  stakeholders that although energy
efficiency  can be an important low-cost resource to inte-
grate into the energy mix, it does require funding just as
a new  power plant requires funding.  Further, education
is necessary on the impact that  energy efficiency pro-
grams can have in  concert with other energy efficiency
policies such as building codes, appliance standards, and
tax incentives.

Promote sufficient, timely, and stable program fund-
ing to deliver energy efficiency where cost-effective.
Energy efficiency programs require consistent and long-
term funding to effectively compete with energy supply
options. Efforts are  necessary to establish this consistent
long-term funding.  A variety of mechanisms have been,
and can be, used based on state, utility, and other stake-
holder interests. It  is important to ensure that the effi-
ciency programs'  providers  have sufficient  long-term
funding to recover  program costs  and implement the
energy efficiency measures that have  been demonstrat-
ed to be available and cost effective. A number of states
are now linking program funding to the achievement of
energy savings.

Modify policies  to align  utility incentives with the
delivery of cost-effective energy efficiency and modify
ratemaking practices to promote  energy  efficiency
investments.  Successful energy  efficiency  programs
would be promoted by  aligning utility incentives in  a
manner that encourages the delivery of energy efficien-
cy as part of a balanced portfolio of supply, demand, and
transmission investments. Historically,  regulatory policies
governing utilities have  more commonly  compensated
utilities for building infrastructure (e.g., power  plants,
transmission lines,  pipelines) and selling energy,  while
discouraging energy efficiency,  even when the energy-
saving measures might cost less. Within the existing reg-
ulatory processes, utilities, regulators, and stakeholders
have a number of opportunities to create the incentives
for energy efficiency investments by  utilities  and cus-
tomers. A variety of mechanisms  have already been
used.  For example,  parties can decide to provide incen-
tives for energy efficiency similar to utility incentives for
new infrastructure investments,  provide rewards for pru-
dent management  of energy efficiency programs, and
incorporate energy  efficiency as an important area of
consideration within rate  design.  Rate design offers
To create a sustainable, aggressive national commitment to energy efficiency
                                                ES-7

-------
  Figure ES-2. National Action Plan for Energy Efficiency Recomiinendations & Options
  Recognize energy efficiency as a high priority
  energy resource.
  Options to consider:
  • Establishing policies to establish energy efficiency as
   a priority resource.
  • Integrating energy efficiency into utility, state, and
   regional resource planning activities.
  •Quantifying and establishing the value of energy
   efficiency, considering energy savings, capacity sav-
   ings, and environmental benefits, as appropriate.

  Make a strong, long-term commitment to implement
  cost-effective energy efficiency as a resource.
  Options to consider:
  • Establishing appropriate cost-effectiveness tests for
   a portfolio of programs to reflect the long-term
   benefits of energy  efficiency.
  • Establishing the potential for long-term, cost-
   effective energy efficiency savings by customer class
   through proven programs, innovative initiatives,
   and cutting-edge technologies.
  • Establishing funding requirements for delivering
   long-term, cost-effective energy efficiency.
  • Developing long-term energy saving goals as part
   of energy planning processes.
  • Developing robust measurement and verification
   (M&V) procedures.
  •Designating which organization(s) is responsible
   for administering the energy efficiency programs.
  • Providing for frequent updates to energy
   resource plans to accommodate new information
   and technology.

  Broadly communicate the benefits of and
  opportunities for energy efficiency.
  Options to consider:
  • Establishing and educating stakeholders on the
   business case for energy efficiency at the state, util-
   ity, and other appropriate level addressing relevant
   customer, utility, and societal  perspectives.
  • Communicating the role of energy efficiency in
                                            lowering customer energy bills and system costs
                                            and risks over time.
                                          • Communicating the role of building codes, appli-
                                            ance standards, and tax and other incentives.

                                          Provide sufficient, timely, and stable program funding
                                          to deliver energy efficiency where cost-effective.
                                          Options to consider:
                                          • Deciding on and committing to a consistent
                                            way for program administrators to recover energy
                                            efficiency costs in a timely manner.
                                          • Establishing funding mechanisms for energy
                                            efficiency from among the available options such
                                            as revenue requirement or resource  procurement
                                            funding, system benefits charges, rate-basing,
                                            shared-savings, incentive mechanisms, etc.
                                          • Establishing funding for multi-year periods.

                                          Modify  policies to align utility incentives with the
                                          delivery of  cost-effective  energy  efficiency and
                                          modify  ratemaking  practices  to promote  energy
                                          efficiency investments.
                                          Options to consider:
                                          •Addressing the typical utility throughput incentive
                                            and removing other regulatory and  management
                                            disincentives to energy efficiency.
                                          • Providing utility incentives for the successful
                                            management of energy efficiency programs.
                                          • Including the  impact on adoption of energy
                                            efficiency as one of the goals of retail rate design,
                                            recognizing that it must be balanced with other
                                            objectives.
                                          • Eliminating  rate designs that discourage energy
                                            efficiency by not increasing costs as customers
                                            consume more electricity or natural  gas.
                                          •Adopting rate designs that encourage energy
                                            efficiency by considering the unique characteristics
                                            of each customer class and including partnering
                                            tariffs with other mechanisms that encourage
                                            energy efficiency, such as benefit sharing programs
                                            and on-bill financing.
IES-8
National Action Plan for Energy Efficiency

-------
opportunities  to encourage customers to  invest in
efficiency  where they find it to be cost effective  and
participate in  new programs  that  provide  innovative
technologies  (e.g.,  smart meters) to  help  customers
control their energy costs

National Action Plan for Energy
Efficiency: Next Steps

In summer 2006, members of the Leadership Group of
the  National  Action  Plan  on   Energy Efficiency  are
announcing a number of specific activities and initiatives
to formalize and reinforce their commitments to energy
efficiency  as a resource.  To assist the Leadership Group
and others in making and fulfilling their commitments, a
number of tools  and resources have been developed:

National  Action Plan  for Energy  Efficiency Report.
This report details the key barriers to energy efficiency in
resource   planning,  utility incentive mechanisms,  rate
design, and the  design  and implementation of energy
efficiency  programs. It also reviews and presents a vari-
ety of policy and program solutions that have been used
to overcome these barriers as well as the pros and cons
for many of these approaches.

Energy  Efficiency Benefits  Calculator.  This calculator
can be used to help educate stakeholders on the broad
benefits of  energy efficiency.  It provides a simplified
framework to demonstrate the business case for energy
efficiency from the perspective of the consumer, the  util-
ity, and society. It has been used  to explore the benefits
of energy  efficiency program investments under a range
of utility  structures, policy  mechanisms,  and  energy
growth scenarios. The  calculator can  be adapted  and
applied to other  scenarios.

Experts and Resource Materials on Energy  Efficiency.
A number of educational presentations on the potential
for energy efficiency and  various policies available for
pursuing the recommendations of the Action Plan will be
developed. In addition,  lists of policy and program
experts in  energy efficiency and the various policies avail-
able  for pursuing the recommendations of the Action
Plan will  be developed.  These lists will be drawn  from
utilities, state  utility regulators, state energy offices,
third-party  energy  efficiency  program administrators,
consumer advocacy organizations,  ESCOs, and others.
These resources will be available in fall 2006.

DOE and  EPA are continuing to facilitate the work of the
Leadership  Group and  the  National  Action  Plan
for  Energy Efficiency.  During  winter  2006-2007, the
Leadership  Group  plans to report  on its  progress and
identify next steps for the Action Plan.
To create a sustainable, aggressive national commitment to energy efficiency
                                               ES-9

-------
 Table ES-1. Members of the National Action Plan for Energy efficiency
  Co-Chairs
  Diane Munns       Member
                    President
  Jim Rogers         President and Chief Executive Officer
Iowa Utilities Board
National Association of Regulatory Utility Commissioners
Duke Energy
  Leadership Group
  Barry Abramson     Senior Vice President
  Angela S. Beehler   Director of Energy Regulation
  Bruce Braine        Vice President, Strategic Policy Analysis
  Jeff Burks          Director of Environmental Sustainability
  Kateri Callahan      President
  Glenn Cannon      General Manager
  Jorge Carrasco      Superintendent
  Lonnie Carter       President and Chief Executive Officer
  Mark Case         Vice President for Business Performance
  Gary Connett       Manager of Resource Planning and
                    Member Services
  Larry Downes       Chairman and Chief Executive Officer

  Roger Duncan      Deputy General Manager, Distributed Energy Services
  Angelo Esposito     Senior Vice President, Energy Services and Technology
  William Flynn       Chairman
  Jeanne Fox         President
  Anne George       Commissioner
  Dian Grueneich     Commissioner
  Blair Hamilton      Policy Director
  Leonard  Haynes     Executive  Vice President, Supply Technologies,
                    Renewables, and Demand Side Planning
  Mary Healey        Consumer Counsel for the State of Connecticut
  Helen Howes       Vice President, Environment,  Health and Safety
  Chris James        Air Director
  Ruth Kinzey        Director of Corporate Communications
  Peter Lendrum      Vice President, Sales and Marketing
  Rick Leuthauser     Manager  of Energy Efficiency
  Mark McGahey     Manager
  Janine Migden-     Consumers' Counsel
  Ostrander
  Richard Morgan     Commissioner
  Brock Nicholson     Deputy Director, Division of Air Quality
  Pat  Oshie          Commissioner
  Douglas Petitt      Vice President, Government Affairs
Servidyne Systems, LLC
Wal-Mart Stores, Inc.
American Electric Power
PNM Resources
Alliance to Save Energy
Waverly Light and Power
Seattle City Light
Santee Cooper
Baltimore Gas and Electric
Great River Energy

New Jersey Natural Gas
(New Jersey Resources Corporation)
Austin Energy
New York Power Authority
New York State Public Service Commission
New Jersey Board of Public Utilities
Connecticut Department of Public Utility Control
California Public Utilities Commission
Vermont Energy Investment Corporation
Southern Company

Connecticut Consumer Counsel
Exelon
Connecticut Department of Environmental Protection
Food Lion
Entergy Corporation
MidAmerican Energy Company
Tristate Generation and Transmission Association, Inc.
Office of the Ohio Consumers' Counsel

District of Columbia  Public Service Commission
North Carolina Air Office
Washington Utilities and Transportation Commission
Vectren Corporation
ES-10

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Bill Prindle
Phyllis Reha
Roland Risser
Gene Rodrigues
Art Rosenfeld
Jan Schorl
Larry Shirley
Michael Shore
Gordon Slack
Deb Sundin
Dub Taylor
Paul von
Paumgartten
Brenna Walraven
Devra Wang
Steve Ward
Mike Weedall
Tom Welch
Jim West
Henry Yoshimura
Deputy Director
Commissioner
Director, Customer Energy Efficiency
Director, Energy Efficiency
Commissioner
General Manager
Division Director
Senior Air Policy Analyst
Energy Business Director
Director, Business Product Marketing
Director
Director, Energy and Environmental Affairs

Executive Director,  National Property Management
Director, California Energy Program
Public Advocate
Vice President, Energy Efficiency
Vice President, External Affairs
Manager of energy right & Green Power Switch
Manager, Demand Response
American Council for an Energy-Efficient Economy
Minnesota Public Utilities Commission
Pacific Gas and Electric
Southern California Edison
California Energy Commission
Sacramento Municipal Utility District
North Carolina Energy Office
Environmental Defense
The Dow Chemical Company
Xcel Energy
Texas State Energy Conservation Office
Johnson Controls

USAA Realty Company
Natural Resources Defense Council
State of Maine
Bonneville Power Administration
PJM  Interconnection
Tennessee Valley Authority
ISO New England Inc.
Observers
James W. (Jay)
Brew
Roger Cooper
Dan Delurey
Roger Fragua
Jeff Genzer
Donald Gilligan
Chuck Gray

John Holt
Joseph Mattingly
Kenneth Mentzer
Christina Mudd
Ellen Petrill
Alan Richardson
Steve Rosenstock
Diane Shea
Rick Tempchin
Mark Wolfe
Counsel

Executive Vice President, Policy and Planning
Executive Director
Deputy Director
General Counsel
President
Executive Director

Senior Manager of Generation and Fuel
Vice President, Secretary and General Counsel
President and Chief Executive Officer
Executive Director
Director, Public/Private Partnerships
President and Chief Executive Officer
Manager, Energy Solutions
Executive Director
Director, Retail Distribution Policy
Executive Director
Steel Manufacturers Association

American Gas Association
Demand Response Coordinating Committee
Council of Energy Resource Tribes
National Association of State Energy Officials
National Association of Energy Service Companies
National Association of Regulatory Utility
Commissioners
National Rural Electric Cooperative Association
Gas Appliance Manufacturers Association
North American Insulation Manufacturers Association
National Council on Electricity Policy
Electric Power Research Institute
American Public Power Association
Edison Electric Institute
National Association of State Energy Officials
Edison Electric Institute
Energy Programs Consortium
                                                                                                                   ES-11

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Notes
    Energy efficiency refers to using  less energy to pro-
    vide the same or improved level of  service  to the
    energy consumer in an economically efficient way.
    The term energy efficiency as used here includes
    using  less energy at any time, including at times  of
    peak demand through demand  response and peak
    shaving efforts.
    Addressing transportation-related energy use is also
    an important challenge as energy demand  in this
    sector continues to increase and  oil prices hit histor-
    ical highs. However, transportation issues are out-
    side the scope of this effort,  which is focused only
    on electricity and natural gas  systems.
    This effort is focused on energy  efficiency for regu-
    lated energy forms. Energy efficiency for unregulat-
    ed energy forms, such as fuel  oil for example, is
    closely related in terms of actions in buildings, but is
    quite different in terms of  how policy can promote
    investments.
    A utility is broadly defined as an organization that
    delivers electric and gas utility services to end users,
    including, but not limited to,  investor-owned, pub-
    licly-owned,  cooperatively-owned, and third-party
    energy efficiency utilities.
    Many energy efficiency programs  have an average
    life cycle cost of $0.03/kilowatt-hour (kWh) saved,
    which is 50 to 75 percent of the typical cost of new
    power sources (ACEEE, 2004; EIA, 2006). The cost
    of energy efficiency programs varies by program and
    can include higher cost programs and options with
    lower costs to a uti ity such as modifying rate designs.
    See  Chapter 6:  Energy  Efficiency  Program  Best
    Practices for more information on leading programs.
    Data refer to EIA 2006 new  power costs and gas
    prices in 2015 compared  to  electric  and  gas pro-
    gram  costs  based on leading energy efficiency pro-
    grams, many of  which are discussed in Chapter 6:
    Energy Efficiency Program Best Practices.
    Based on leading energy efficiency programs, many
    of which are  discussed  in  Chapter 6:  Energy
    Efficiency Program Best Practices.
    These estimates are based on assumptions of aver-
    age program spending levels by  utilities  or other
    program administrators,  with conservatively  high
    numbers for the  cost of energy efficiency programs.
                                              See highlights of some of these programs in Chapter
                                              6:  Energy Efficiency Program  Best Practices,  Tables
                                              6-1 and 6-2.
                                          10  These  economic anc  environmental savings esti-
                                              mates are extrapolations of the results from region-
                                              al program to a national scope. Actual savings at the
                                              regional level vary based on a number of factors. For
                                              these estimates, avoided capacity value  is based on
                                              peak load reductions de-rated  for reductions that do
                                              not  result in  savings   of  capital  investments.
                                              Emissions savings are based on a marginal on-peak
                                              generation fuel  of  natural gas and  marginal off-
                                              peak fuel of coal; with the on-peak period capacity
                                              requirement double that  of  the annual  average.
                                              These assumptions vary by region based upon situa-
                                              tion-specific variables. Reductions in  capped emis-
                                              sions might reduce the cost of comoliance.
                                          11  This estimate  of the  funding required  assumes 2
                                              percent of revenues across electric utilities and 0.5
                                              percent  across  gas  utilities. The  estimate aiso
                                              assumes that  energy efficiency is de ivered at  a total
                                              cost (utility and partic pant) of $0.04 per kWh and
                                              $3  per million British thermal  units (MMBtu),  which
                                              are higher than the costs of many of today's programs.
                                          12  This estimate  is provided as an indicator of under.n-
                                              vestment and is not intended  to establish a national
                                              funding target. Appropriate funding  levels for pro-
                                              grams  should  be established  at the regional, stare,
                                              or utility level. In addition,  energy efficiency  invest-
                                              ments  by customers, businesses,  .ndustry, and gov-
                                              ernment also  contribute to the larger  economic and
                                              environment benefits of energy efficiency.
                                          13  One example  of energy efficiency's ability to meet
                                              load growth  is the  Northwest  Power  Planning
                                              Council's  Fifth Power  Plan which  uses energy con-
                                              servation and efficiency to meet a targeted 700 MW
                                              of  forecasted capacity between  2005  and  2009
                                              (NWPCC, 2005).
ES-12
National Action Plan for Energy Efficiency

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References
For More Information
 • i <:PI;.,-IM COSMO! tor an L nergy-Etfit le "i! tf.onomy
    i,-V~rF.E] '2004). A Fedora' System Benefits Fund'
    Ar?':i',tiny States to ฃs7
Southwest Energy Efficiency Project [SWEEP] (2002,
    November). The New Mother Lode: The Potential
    for More Efficient Electricity Use in the Southwest.
    Report for the Hewlett Foundation Energy Series.
U.S. Energy Information Administration [EIA] (2006).
    Annual Energy Outlook 2006. Washington, DC.
Western Governors' Association [WGA] (2006, June).
    Clean Energy, a Strong Economy and a Healthy
    Environment. A Report of the Clean and Diversified
    Energy Advisory Committee.
Stacy Angel
U.S.  Environmental Protection Agency
Office of Air and Radiation
Climate Protection Partnerships Division
Tel: (202) 343-9606
E-mail: angel.stacy@epa.gov

Larry Mansueti
U.S.  Department of Energy
Office of Electricity Delivery and Energy Reliability
Tel: (202) 586-2588
E-mail: lawrence.mansueti@hq.doe.gov

Or visit www.epa.gov/cleanenergy/eeactionplan
To create a sustainable, aggressive national commitment to energy efficiency
                                             ES-13

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 1
   Introduction
I  and Background
 Overview

We currently face a  number  of challenges in securing
affordable, reliable, secure, and clean energy to meet
our nation's growing energy  demand. Demand  is out-
pacing supply, costs are rising,  and concerns for the envi-
ronment are growing.

Improving the energy efficiency1 of our homes, business-
es,  schools, governments, and industries - which con-
sume more than  70  percent of the energy  used  in the
country—is one of the most constructive, cost-effective
ways to address these challenges. Greater investment in
energy efficiency programs across the country could help
meet  our growing electricity  and natural  gas demand,
save customers billions of dollars on  their  energy bills,
reduce emissions of air pollutants and greenhouse gases,
and contribute to a more secure, reliable, and low-cost
energy system. Despite this opportunity, energy efficien-
cy remains an  under-utilized  resource in  the nation's
energy portfolio.

There are many ways  to increase  investment in cost-
effective energy efficiency including developing building
codes and  appliance standards, implementing govern-
ment  leadership  efforts,  and  educating  the  public
through  programs such as ENERGY  STARฎ.2 Another
important area is  greater investment in organized ener-
gy efficiency programs that are managed by electric and
natural gas providers, states,  or third-party  administra-
tors. Energy efficiency  programs  already contribute to
the energy mix  in many parts of the  country and have
delivered significant savings and other benefits. Despite
the benefits, these programs face hurdles in many areas
of the country. Identifying and  removing these barriers is
a focus of this effort.
                                                   October 2005
                                                   Excerpt from Letter FrDm Co-C-iairs ?.o rhซ
                                                   National Action Plan  for Energy Efficiency
                                                   Leadership Group

                                                   Energy efficiency is a critically under-utilized resource in
                                                   the  nation's energy  portfolio. Those states and utilities
                                                   that have made significant  investments in energy effi-
                                                   ciency have lowered the growth for energy demand and
                                                   moderated their energy costs. However, many hurdles
                                                   remain that block broader investments in  cost-effective
                                                   energy efficiency.
                                                   That is why we have agreed to chair the Energy Efficiency
                                                   Action  Plan. It is our hope that with the help of leading
                                                   organizations like yours, we will identify and overcome
                                                   these hurdles.
                                                   Through this Action Plan, we intend to identify the major
                                                   barriers currently limiting greater investment by utilities in
                                                   energy efficiency. We will develop a series of  business
                                                   cases that will demonstrate the value and  contributions
                                                   of energy efficiency and explain how to remove these
                                                   barriers  (including  regulatory and  market challenges).
                                                   These  business cases, along with descriptions of leading
                                                   energy efficiency programs,  will  build upon practices
                                                   already in place across the country.
                                                   Diane Munns
                                                   President, NARUC
                                                   Member, Iowa Utilities Board
Jim Rogers
President and CEO
Duke Energy
                                                To drive a sustainable, aggressive national commitment
                                                to energy efficiency through gas and electric utilities,
                                                utility regulators, and partner organizations, more than
                                                50 leading organizations joined together to develop this
                                                National  Action Plan for Energy Efficiency. The Action
                                                Plan is co-chaired by Diane Munns, Member of the Iowa
1 Energy efficiency refers to using less energy to provide the same or improved level of service to the energy consumer in an economically efficient way.
 The term energy efficiency as used here includes using less energy at any time, including at times of peak demand through demand response and peak
 shaving efforts.
2 See EPA 2006 for a description of a broad set of policies being used at the state level to advance energy efficiency.
To create a sustainable, aggressive national commitment to energy efficiency
                                                                                                1-1

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Utilities Board and President of the National Association
of Regulatory  Utility Commissioners, and  Jim  Rogers,
President and  Chief Executive Officer of Duke Energy.
The Leadership Group  includes  representatives from a
broad set of stakeholders, including electric and gas
utilities, state utility commissioners, state air and energy
agencies, energy service providers, energy consumers,
and energy efficiency  and consumer advocates.  This
effort is facilitated by the U.S.  Department  of Energy
(DOE) and  the U.S. Environmental  Protection  Agency
(EPA). The National Action  Plan for Energy Efficiency:

•Identifies  key barriers  limiting greater investment  in
  energy efficiency,

• Reviews sound business practices for  removing these
  barriers and improving the acceptance and use of ener-
  gy efficiency relative to energy  supply options, and

• Outlines recommendations and options for overcoming
  these barriers.

In addition, members of the Leadership Group are com-
mitting  to  act within  their  own  organizations  and
spheres  of  influence to increase attention and  invest-
ment  in energy efficiency. Greater investment in energy
efficiency cannot happen based on the work of one  indi-
vidual or  organization  alone.  The  Leadership  Group
recognizes that the joint efforts  of the customer, utility,
regulator, and  partner organizations are needed to  rein-
vigorate and increase the use  of energy  efficiency  in
America. As energy experts, utilities may be in a unigue
position to  play a leadership role.

The rest  of this introduction chapter establishes  why
now is the time to increase our investment in energy effi-
ciency, outlines the  approach  taken  in  the National
Action Plan for Energy Efficiency, and explains the struc-
ture of this report.
Why Focus on Energy Efficiency?
Energy Challenges

We currently  face  multiple  challenges  in  providing
affordable, clean, and reliable energy in today's complex
energy markets:

• Electricity demand continues  to rise.  Given current
 energy consumption  and demographic trends,  DOE
 projects that U.S. energy consumption will increase by
 more than one-third by the year 2025. Electric power-
 consumption is  expected to increase by almost 40
 percent,  and  total  fossil fuel  use  is  projected  to
 increase similarly (EIA, 2005). At work and at home,
 we  continue  to  rely  on  more energy-consum ng
 devices.  This  growth  in demand stresses  current
 systems and  requires substantial new investments in
 system expansions.

•High energy  prices.  Our demand "or natural  gas to
 heat our homes, for industrial and business uses, and
 for power plants is straining the available gas supply in
 North America and putting upward pressure on natu-
 ral  gas prices.  Many  household budgets  are  being
 strained by higher energy costs, leaving less  money
 available for  other household  purchases and  needs;
 this  situation is  particularly  harmful for low-income
 households. Consumers are looking for ways to man-
 age  their energy bills. Higher energy bills for industry
 are  reducing the  nation's economic competitiveness
 and  placing U.S. jobs at risk. Higher energy  prices also
 raise the financial risk  associated  with the develop-
 ment of new natural  gas-fired  power plants, which
 had  been expected to make  up more than 60 percent
 of capacity  additions  over  the next  20 years  (EIA,
 2005). Coal prices  are also increasing and contributing
 to higher electricity costs.

• Energy system reliability. Events such as the Northeast
 electricity  blackout of August  2003  and  Hurricanes
 Katrina and Rita in 2005 highlighted the vulnerability
 of our energy system to  disruptions. This  led  to  an
1 -2    National Action Plan for Energy Efficiency

-------
  increased focus on energy  reliability and its economic
  and human  impacts, as well  as national security con-
  cerns  using  fossil fuel  more efficiently and  increasing
  energy supply diversity.
             ' :;>•".(<-'•'/'<•: are overburdened in some places,
  limiting  the flow of  economical generation  and, in
  some cases, shrinking reserve margins of the electricity
  grid to inappropriately small  levels. This situation  can
  cause  reliability problems and high electricity prices in
  or near congested areas.

• i .'.v./'o/i/nen?.)/ co/KiVb Energy  demand continues to
  grow as national and state regulations are being imple-
  mented to significantly limit the emissions  of air pollu-
  tants, such as sulfur dioxide (S02), nitrogen oxides (NOX),
  and mercury, to protect public health and the environ-
  ment.  Many existing base load  generation plants are
  aging and significant retrofits  are needed to ensure old
  generating  units  meet these emissions  regulations.
  In addition, emissions  of  greenhouse  gases  continue
  to increase.

Addressing these issues will require billions of dollars in
investments in new power plants,  gas  rigs, transmission
lines,  pipelines, and  other  infrastructure, notwithstand-
ing the difficulty of building new energy infrastructure in
dense urban and suburban locations even with current
energy efficiency  investment.  The decisions we  make
now regarding our energy supply and demand can either
help us deal with these challenges  more effectively or
complicate our  ability to secure a more stable, economi-
cal energy future.

Benefits of Energy Efficiency

Greater investment in energy efficiency can help us tackle
these challenges. Energy efficiency is already a key compo-
nent in the nation's energy resource mix in many parts of
the country, and experience shows that energy efficiency
programs can lower customer energy bills; cost less than,
and help defer, new energy production;  provide environ-
mental benefits, and spur local economic development.
Some of the major benefits of energy efficiency include:

*<:')nv;  fv/ev'Qj- ,'
-------
 demand in some areas without compromising the end
 users' activities and economic well-being (Nadel, et al.,
 2004; EIA, 2006).

•Environmental benefits. Cost-effective energy efficien-
 cy offers environmental benefits related  to reduced
 demand, such as reduced air pollution and greenhouse
 gas emissions, lower water use, and less environmental
 damage from fossil fuel extraction. Energy efficiency is
 an attractive option for generation owners in advance
 of requirements to reduce greenhouse gas emissions.

•Economic development. Greater  investment in energy
 efficiency helps build jobs and improve state economies.
 Energy efficiency users often redirect their bill savings
 toward other activities that increase  local and national
 employment, with a higher employment impact than if
 the money had been spent to purchase energy  (York
 and Kushler, 2005; NYSERDA, 2004). Many energy effi-
 ciency programs create construction and  installation
 jobs, with multiplier impacts on other employment and
 local  economies (Sedano  et al., 2005).  Local invest-
 ments in energy efficiency can offset energy  imports
 from out-of-state, improving the state balance of trade.
 Lastly, energy efficiency investments usually create long-
 lasting infrastructure  changes to building, equipment
 and  appliance  stocks, creating  long-term  property
 improvements that deliver long-term economic  value
 (Innovest, 2002).

•Energy security. Energy efficiency reduces the level  of
 U.S. per capita energy consumption, thus decreasing
 the vulnerability of the economy and individual  con-
 sumers to energy price disruptions from natural disasters
 and  attacks upon  domestic and  international energy
 supplies and infrastructure.


Decades of  Experience With Energy
Efficiency
Utilities and  their  regulators began recognizing the
potential benefits of improving  efficiency and reducing
demand in the 1970s  and  1980s. These "demand-side
   Long Island Power Authority's (LIRA)
   Clean Energy Program Drives Economic
   Development, Customer Savings, and
   Environmental Quality Enhancements
   LIRA started its Clean Energy Initiative in 1999 and
   has  invested $229 million  over the past  6 years
   LIPA's portfolio of energy efficiency programs  from
   1999 to 2005 produced significant energy savings,
   emissions reductions  and stimulated economic:
   growth on Long Island:

   • 296 megawatts (MW) peak demand savings
   • 1,348 gigawatt-hours (GWh) cumulative savings
   • Emissions reductions of:
       • Greater than 937,402 tons of
        carbon dioxide (C02)
       • Greater than 1,334 tons of NOX
       • Greater than 4,298 tons of S02
   • $275 million  in customer bill savings and rebates
   • $234 million  increase in net economic output on
    Long Island
   •4,500 secondary jobs created
   Source: LIRA, 2006

management"  (DSM)  approaches  meet  increased
demands for electricity or natural gas by managing the
demand on  the customer's side of the meter rather  than
increasing or acquiring more supplies. Planning processes,
such as "least-cost planning" or  "integrated resource
planning," have been used to evaluate DSM programs
on par  with supply options  and  allow investment  in
DSM programs when they cost less than new supply
options.

DSM program spending  exceeded  $2 billion a  year Jin
2005  dollars) in   1993  and  1994  (York and  Kushler,
2005).  In the late 1990s, funding  for utility-sponsored
energy efficiency was reduced in about half of the states
due  to changed  regulatory  structures  and increased
political and regulatory pressures to hold down electrici-
ty prices. This funding  has partially recovered with  new
 1-4    National Action Plan for Energy Efficiency

-------
policies and funding mechanisms (see Figure 1-1) imple-
mented to ensure  that  some level of  cost-effective
energy efficiency was pursued.

Notwithstanding the policy and regulatory changes that
have affected energy efficiency program funding, wide
scale, organized energy efficiency programs have  now
been operating  for decades in certain parts of the coun-
try. These efforts have demonstrated the following:

•Energy efficiency programs deliver significant savings.
  In the mid-1990s, based on the high program funding
  levels of the early 1990s, electric utilities estimated pro-
  gram savings of 30 gigawatts (the output of about 100
  medium-sized  power plants) and more than 60  million
  megawatt-hours (MWh).

• Energy efficiency programs can be used to meet a sig-
  nificant portion of expected load growth. For example:

    — The Pacific Northwest region  has met 40 percent
       of its growth over the past two decades through
       energy efficiency programs (see Figure  1-2).
   Connecticut's Energy Efficiency Programs
   Generate Savings of $550 Million in 2005
   In  2005,  the  Connecticut  Energy  Efficiency
   Fund,  managed  by the  Energy  Conservation
   Management Board, invested $80 million in ener-
   gy efficiency.  This investment is expected to pro-
   duce $550 million of bill  savings to Connecticut
   electricity consumers. In addition, the 2005 pro-
   grams, administered by Northeast  Utilities and
   United Illuminating, resulted in:

   • 126 MW peak demand reduction
   •4,398 GWh  lifetime savings
   • Emissions reductions of:
       — Greater than 2.7 million tons of C02
       — Greater than 1,702 tons of NOX
       — Greater than 4,616 tons of S02
   •1,000 non-utility jobs in the energy efficiency
    industry
   Source: CECMB, 2006
       California's energy efficiency goals, adopted in
       2004 by the Public Utilities Commission, are to
 Figure 1-1: Energy Efficiency Spending Has Declined
   Puget Sound Energy's (PSE) Resource
   Plan  Includes Accelerated Conservation
   to Minimize Risks and Costs
   PSE's 2002 and 2005 Integrated  Resource  Plans
   (IRPs) found that the accelerated development of
   energy efficiency minimizes  both costs and  risks.
   As a result, PSE significantly  expanded its energy
   efficiency efforts. PSE is now  on track to save 279
   average MW (aMW) between 2006 and  2015,
   more than the company had  saved between  1980
   and 2004. The 279 aMW of energy efficiency rep-
   resents nearly 10  percent of its forecasted  2015
   sales.

   Source: Puget Sound Energy, 2005
 o
-o
LT>
8
c
g
15
c
•^
c
CD
                                                         $2.5-r
$2.0
       1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003
                           Year
Source: Data derived from ACEEE 2005 Scorecard (York and Kushler,
2005) adjusted for inflation using U.S. Department of Labor Bureau of
Labor Statistics Inflation Calculator
To create a sustainable, aggressive national commitment to energy efficiency
                                               1-5

-------
     use energy efficiency to displace more than half of
     future electricity load growth and avoid the  need
     to build three large (500 MW) power plants.

1 Encigy efficiency >5  neing delivered ros7-co/noe//?/i(-/V'
 with new supply.  Programs  across the country are
 demonstrating that  energy efficiency can be delivered
 at a cost of 2 to 4 cents per kilowatt-hour (kWh) and a
 cost of $1.30 to $2.00 per lifetime million British  ther-
 mal units (MMBtu) saved.

• Energy  efficiency can be  targeted to reduce  peak
 demand.  A variety  of  programs  address the  peak
 demand  of different  customer classes, lowering the
 strain on existing supply assets (e.g., pipeline capacity,
 transmission and distribution capacity, and  power  plant
 capability), allowing energy delivery companies to bet-
 ter  utilize  existing  assets  and deferring  new capital
 investments.

• Proven, cost-effective program models are available to
 build upon. These  program models are available for
 almost every customer class, both gas and electric.
  Southern California Edison's (SCE)
  Energy Efficiency Investments Provide
  Economic and Environmental Savings

  SCE's comprehensive portfolio of energy efficiency
  programs for 2006 through 2008 will produce:

  •3 percent average bill reduction by 2010

  • 3.5 billion kWh of energy savings

  • 888 MW of demand savings

  • 20.5 million tons of C02 emission reductions

  • 5.5 million tons of NOX emission reductions

  • Energy saved at a cost of less than 4.1 cents/kWh
  Source: Southern California Edison, 2006
                                                 New York State's Aggressive
                                                 Energy Efficiency Programs Help
                                                 Power the Economy As Well As Reduce
                                                 Energy Costs
                                                 New York State Energy Research and Development
                                                 Authority's (NYSERDA's) portfolio of energy efficiency
                                                 programs for the period from 1999 to 2005 pro-
                                                 duced significant energy savings, as well as stimu-
                                                 lated economic growth and jobs, and reduced energy
                                                 prices in the state:

                                                 • 19  billion kWh/year of energy savings
                                                 •4,166  added  jobs/year (created/retained) from
                                                  1999 to 2017
                                                 • $244 million/year in added total economic growth
                                                  from 1999 to 2017
                                                 *$94.5 million in energy price savings over three
                                                  years
                                                 Source: NYSERDA, 2006

                                               National Case for Energy Efficiency

                                               Improving the energy  efficiency  of  homes, businesses,
                                               schools,  governments,  and industries—which  consume
                                               more than 70 percent of the energy used in the country —
                                               is one  of the most constructive, cost-effective  ways to
                                               address the nation's energy challenges. Many of these
                                               buildings and facilities are decades old and will consume the
                                               majority of the energy to be used in these sectors for years
                                               to come. State and regional studies have found that adop-
                                               tion of economically attractive, but as yet untapped, energy
                                               efficiency could yield more than 20 percent savings in total
                                               electricity demand nationwide by 2025. Depending on the
                                               underlying load growth, these savings could help cut load
                                               growth by half or more  compared to current forecasts
                                               (Nadel et al.,  2004;  SWEER 2002; NEEP, 2005; NWPCC,
                                               2005; WGA, 2006).  Similarly, energy efficiency targeted at
                                               direct  natural gas use  could lower natural  gas demand
                                               growth by  50 percent (Nadel et al., 2004).  Furthermore,
                                               studies also show  that significant reductions  in energy
                                               consumption can be achieved quickly (Callahan, 2006)  and
                                               at low costs for many years to come.
1-6
National Action Plan for Energy Efficiency

-------
  •-tqure 1 /: Energy Efficiency H.v-> Keen ;< Resource ;?* the-  Pacifr: iMos tliwf>t for the  ^a< •'  >vw
Pacific Northwest Energy Efficiency
Achievements 1978  2004
 en
 01
 0>
 Ol
 ro
   1,500-
      0
           Since 1978, Bonneville Power
           Administration (BPA) & Utility
           Programs, Energy Codes & Federal
           Efficiency Standards Have Produced
           Nearly 3000 aMW of Savings.
                             j
             .....
Illlll
       1978    1982    1986    1990    1994    1998    2002
       BPA and Utility Programs
       Alliance Programs
             State Codes
             Federal Standards
                                        Enerqy Efficiency Met Nearly 40 Pen.ent of Pacifa
                                        Northwest Regional Firm Sales Growth Between 198C
                                        to 2003
                                                                             Generation
                                                                       Conservation
  Source: Eckman, 2005
  Capturing this  energy  efficiency resource  would offer
  substantial economic and environmental benefits across
  the country. Widespread application of energy efficiency
  programs that already exist in some regions6 could deliv-
  er  a large part of these potential savings. Extrapolating
  the results from existing programs to the entire country
  would yield over the next 10 to 15  years7:

  • Energy bill savings of nearly $20 billion annually.

  • Net societal  benefits of more than $250 billion.8

  •Avoided  need  for  20,000  MW  (40  new  500 MW-
   power plants).
                                        • Avoided annual air emissions of more than 200 million
                                          tons of C02, 50,000 tons of S02, and 40,000 tons of NOX.

                                        These benefits  illustrate the magnitude of the benefits
                                        cost-effective energy efficiency offers.  They are estimated
                                        based on (1) assumptions of average program spending
                                        levels  by utilities or other  program administrators that
                                        currently  sponsor energy efficiency  programs and
                                        (2) conservatively high estimates for the cost of the energy
                                        efficiency programs themselves (see Table 1 -1 ).9 They are
                                        not  meant  as  a prescription;  there  are differences  in
                                        opportunities and costs for energy efficiency that  need
                                        to be addressed at the regional, state, and utility level to
                                        design and operate effective programs.
  b  See highlights of some of these programs in Chapter 6: Energy Efficiency Program Best Practices, Tables 6-1 and 6-2.
  7  These economic and environmental savings estimates extrapolate the results from regional programs to a national scope. Actual savings at the region-
    al level vary based on a number of factors. For these estimates, avoided capacity value is based on peak load reductions de-rated for reductions that
    do not result in savings of capital investments. Emission savings are based on a marginal on-peak generation fuel of natural gas and marginal off-peak
    fuel of coal; with the on-peak period capacity reguirement double that of the annual average These assumptions vary by region based upon situation-
    specific variables. Reductions in capped emissions might reduce the cost of compliance.
  8  Net present value (NPV) assuming 5 percent discount rate.
  9  This estimate of the funding reguired assumes 2 percent of revenues across electric  utilities and 0.5 percent across gas utilities. The estimate also
    assumes that energy efficiency is delivered at a total cost (utility and participant) of $0.04 per kWh and $3 per MMBtu, which are higher than the costs
    of many of today's programs.
                                                                                                                    1-7

-------
Table 1 -1 . Summary of Benefits for National Energy Efficiency Efforts

Program Cost Electric Natural Gas
Utility Program Spending (% of utility revenue) 2.0% j 0.5%
Total Cost of Efficiency (customer & utility) $35/MWh $3/MMBti
Cost of Efficiency (customer) ; $1 5/MWh
i
Average Annual Cost of Efficiency ($MM) i $6,800
Total

$2/MMBtij
"suoo'T
Total Cost of Efficiency (NPV, $MM) | $140,OOoT $25,000 $165,000
Efficiency Spending - Customer (NPV, $MM) $60,000 $13,000 $73,000
Efficiency Program Spending - Utility (NPV, $MM) $80,000
Resulting Savings Electric
Net Customer Savings (NPV, $MM) $277,000
Annual Customer Savings $MM $18, 000
Net Societal Savings (NPV, $MM) j $270,000
Annual Net Societal Savings ($MM) $17,500
Decrease in Revenue Requirement (NPV, $MM) ! $336,000
Annual Decrease in Revenue Requirement ($MM) $22,000
Energy Savings Electric
Percent of Growth Saved, Year 15 61%
Percent of Consumption Saved, Year 15 12%
Peak Load Reduction, Year 1 5 (De-rated)' 34,000 MW
Energy Saved, Year 1 5 588,000 GWh
Energy Saved (cumulative) 9,400,000 GWh
Emission Reductions Electric
C02 Emission Reduction (1 ,000 Tons), Year 1 5 338,000
$13,000
Natural Gas
$76,500
$5,000
$93,000
Total
$353,500
$23,000
$74,000 $344,000
55,000
$89,000
56,000
Natural Gas
52%
$22,500
$425,000
525,000
Total

5%

UOOBcF
19,000 BcF .
Natural Gas
72,000
NOx Emission Reduction (Tons), Year 1 5 I 67,000 61,000
!
Other Assumptions Electric
Natural Gas
Load Growth (%) ! 2% ' 1%
Total
410,000
128,000


Utility NPV Discount Rate 5% 5%
Customer NPV Discount Rate 5%
EE Project Life Term (years) 1 5
5%
15
Source: Energy Efficiency Benefits Calculator developed for the National Action Plan for Energy Efficiency, 2006.
NPV = net present value; $MM = million dollars
'  De-rated peak load reduction based on the coincident peak load reduced multiplied by the percent of growth-related capital expenditures that are saved.
  Peak load reductions in unconstrained areas are not counted.
1-8     National Action Plan for Energy Efficiency

-------
As a nation we are passing up these savings by sub-
stantially underinvestmg in energy efficiency. One indi-
cator of this  underinvestment  is the level of  energy
efficiency program funding across the country.  Based
on the  effectiveness of current energy efficiency pro-
grams  operated  in certain parts of the country,  the
funding necessary to yield the economic and environ-
mental  benefits presented above is approximately four
times the funding  levels  for organized efficiency pro-
grams today (less than $2 billion per year). Again,  this
is one indicator of  underinvestment and not meant to
be a national funding target. Appropriate funding levels
need to be  established  at the regional, state, or utility
level based  on the cost-effective potential for  energy
efficiency as well  as other factors.

The current  underinvestment in energy efficiency is  due
to a  number of well-recognized  barriers. Some key bar-
riers arise from choices concerning regulation of  electric
and natural  gas utilities. These barriers include:

•Market barriers, such as the well-known  "split-incen-
 tive" barrier,  which limits home builders' and commer-
 cial developers'  motivation to  invest in new building
 energy efficiency because they do not pay the  energy
 bill, and the  transaction  cost barrier, which chronically
 affects individual consumer  and  small  business
 decision-making.

• Customer barriers, such as lack  of information on ener-
 gy  saving  opportunities, lack  of  awareness of how
 energy efficiency  programs make  investments  easier
 through low-interest loans, rebates, etc.,  lack of time
 and attention to  implementing efficiency  measures,
 and lack of availability of necessary funding to invest in
 energy efficiency.
•i 
-------
The National Action Plan for  Energy
Efficiency

To drive a sustainable, aggressive national commitment
to energy efficiency through  gas  and electric utilities,
utility regulators, and partner  organizations, more than
50 leading organizations joined together to develop this
National Action Plan for Energy Efficiency. The Leadership
Group members (Table 1-2) have developed this National
Action Plan for Energy Efficiency Report, which:

• Reviews the  barriers  limiting  greater  investment in
  energy efficiency by gas and electric utilities and part-
  ner organizations.

• Presents sound business strategies that are available to
  overcome these barriers.

• Documents  a set  of  business  cases  showing  the
  impacts on key stakeholders  as utilities under different
  circumstances increase energy efficiency programs.

• Presents best practices for energy efficiency program
  design and operation.

• Presents policy  recommendations  and  options for
  spurring greater investment in energy efficiency by util-
  ities and energy consumers.

The report chapters address four main policy and pro-
gram areas (see Figure 1-3):

•Utility  Ratemaking and Revenue  Requirement. Lost
  sales from the expanded use of energy efficiency have
  a negative effect on the financial performance of elec-
  tric and natural gas utilities,  particularly those that are
  investor-owned under conventional regulation. Cost-
  recovery strategies  have been designed and  imple-
  mented  to  successfully  "decouple" utility  financial
  health from electricity sales volumes to  remove finan-
  cial disincentives  to energy  efficiency, and  incentives
  have been developed and implemented  to make ener-
  gy  efficiency investments  as financially  rewarding as
  capital investments.
The goal  of the National Action  Plan for
Energy Efficiency is to create a sustain-
able, aggressive national commitment
to energy efficiency through gas and
electric utilities,  utility regulators, and
partner organizations.

The Leadership Group:
• Recognizes that utilities and regulators have criti-
  cal roles in creating and delivering energy efficien-
  cy programs to their communities.

ซ Recognizes that success requires the joint efforts
  of  the  customer,  utility,  regulator,  and partner
  organizations.

"Will work across their spheres  of  influence to
  remove barriers to energy efficiency.

• Commits  to take action within their own organi-
  zation to increase attention  and investment in
  energy efficiency.

Leadership Group Recommendations:
• Recognize energy efficiency  as  a  high-priority
  energy resource.

ป Make a strong, long-term commitment to  imple-
  ment cost-effective energy efficiency as a resource.

• Broadly communicate the benefits of and oppor-
  tunities for energy efficiency.

• Promote  sufficient, timely, and  stable  program
  funding to deliver energy efficiency where cost-
  effective.

• Modify policies to align utility incentives with the
  delivery of  cost-effective energy efficiency and
  modify ratemaking practices  to  promote energy
  efficiency investments.
1-10  National Action Plan for Energy Efficiency

-------
                    Energy efficiency, along with other
 customer-side resources, are not fully  integrated into
 state and utility planning  processes that identify the
 need to  acquire  new  electricity and  natural  gas
 resources.

 1 ;-',,v ,'j  -,/y;;  Some regions are successfully using rate
 designs such as time-of-use (TOU) or seasonal rates to
 more accurately reflect the cost of providing electricity
 and to encourage  customers to consume less energy.
             is a  lack of knowledge about the most effective and
             cost-effective  energy  efficiency program  options.
             However, many states and electricity and gas  providers
             are successfully operating energy efficiency programs
             across end-use sectors and customer classes,  including
             residential,  commercial, industrial,  low-income, and
             small business.  These programs employ a variety of
             approaches,  including  providing public information
             and  training,  offering financing and financial incen-
             tives, allowing energy  savings  bidding, and  offering
             performance contracting.
 One reason given for slow adoption of energy efficiency
Figure 1-3: National Action Plan for Energy Efficiency Report Addresses Actions to Encourage Greater Energy Efficiency
           Policy Structure

        Develop Utility Incentives
           for Energy Efficiency

         Develop Rate Designs to
       Encourage Energy Efficiency
   Utility Resource
       Planning
Include Energy Efficiency
  in Utility Resource Mix

Develop Effective Energy
  Efficiency Programs
          Program
      Implementation

     Program Roll-opt
Measurement & Evaluation
                                  Revise Plans and Policies Based on Results
 Action Plan Report Chapter Areas and Key Barriers
Utility Ratemaking planning Moctel
& Revenue Processes Rate Design Program
Requirements Documentation
Energy efficiency reduces
utility earnings

Planning does not
incorporate demand-
side resources

Rates do not
encourage energy
efficiency investments
Limited information on
existing best practices
                                                                                                       1-11

-------
Business Cases for Energy Efficiency
A key element of the  National Action Plan for Energy
Efficiency is exploring the benefits of energy efficiency
and the mechanisms and policies that might need to be
modified so that each of the key stakeholders can  bene-
fit from  energy efficiency investments.  A key issue is that
adoption of energy efficiency saves resources and utility
costs, but also reduces  utility sales. Therefore, the effect
on utility financial health must be carefully evaluated. To
that end,  the  Leadership  Group  offers   an  Energy
Efficiency Benefits Calculator (Calculator) that evaluates
the financial impact of energy efficiency on its  major
stakeholders—utilities,  customers,  and society. The
Calculator allows stakeholders to examine different effi-
ciency and utility cases with transparent input assump-
tions.

The business cases presented in Chapter 4 of this report
show the impact of energy efficiency investments upon
sample utility's financial health and earnings, upon cus-
tomer energy bills, and  upon social  resources such as
net efficiency costs and pollutant emissions.  In general,
the impacts of offering energy efficiency programs ver-
sus not offering  efficiency follow the trends and find-
ings illustrated  below from  the customer,  utility and
society perspectives.
 Utility Perspective. Energy efficiency affects utility revenues, <
 investments. The utility can be financially neutral to investm
 greater investment through the implementation of a varietly
 These policies can ensure that shareholder  returns  and earni igs
 in  infrastructure and contractual  obligations for  energy
 balance sheet impact.
  hareholder earnings, and costs associated with capital
  ?nts in energy efficiency, at a minimum, or encourage
    of decoupling, ratemaking, and incentives policies.
     could be the same or increased.  Utility investment
procurement could be reduced, providing a favorable
                           Utility Returns - No Change or Increase
                           Utility earnings remain stable or increase if decoupling or the use of shareholder incen-
                           tives accompanies an energy efficiency program. Without incentives, earnings might be
                           lower  because effective energy  efficiency will  reduce  the utility's sales volume and
                           reduce the utility's  rate base, and thus the scope of its earnings.
                           Change in Utility Earnings - Results Vary
                           Depending on the inclusion of decoupling and/or shareholder incentives, utility earn-
                           ings vary.  Utility earnings increase if decoupling or shareholder incentives are included.
                           If no incentives, earnings might be lower due to reduced utility investment.
                           Peak Load Growth and Associated Capital Investment - Decreases
                           Capital investments in new resources and energy delivery infrastructure are reduced
                           because peak capacity savings are captured due to energy efficiency measures.
 Customer Perspective. Customers' overall bills will decrease
 offsets potential rate increases to cover the cost of offering t
   with energy efficiency because lower energy  usage
   le efficiency program.
                           Customer Bills - Decrease
                           Total customer bills decline over time as a result of investment in cost-effective energy
                           efficiency programs as customers save due to lower energy consumption. This decline
                           follows an initial rise in customer bills reflecting the cost of energy efficiency programs,
                           which will then reduce costs over many years.
 1-12   National Action Plan for Energy Efficiency

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 Customer Perspective (continued)
                            Customer Rates - Mild Increase12
                            Rates might increase slightly to cover the cost of the energy efficiency program.
 Community or Society Perspective. From a broad community/society perspective, energy efficiency produces real sav-
 ings over time. While initially, energy efficiency can raise energy costs slightly to finance the new energy efficiency
 investment, the reduced bills (as well as price moderation effects) provide a  rapid payback on these investments,
 especially compared to the ongoing costs to cover the investments in new energy production and delivery infrastruc-
 ture costs. Moreover, the environmental benefits of energy efficiency continue to grow. The Calculator evaluates the
 net societal savings, utility savings, emissions reductions, and the avoided growth in energy demand associated with
 energy efficiency.
                            Net Resources Savings - Increases
                            Over time, as energy efficiency programs ramp up, cumulative energy efficiency sav-
                            ings lead to cost savings that exceed the energy efficiency program cost.
                            Total Resource Cost (TRC) per Unit - Declines
                            Total  cost of providing each  unit of energy (MWh, MMBtu gas)  declines over time
                            because  of  the impacts of energy savings,  decreased peak load  requirements,  and
                            decreased costs during peak  periods. Well-designed energy efficiency programs can
                            deliver energy at an average cost less than that of new power sources.
                            Emissions and Cost Savings - Increases
                            Efficiency prevents  or avoids producing many annual tons of emissions and emission
                            control costs.
                            Growth Offset by EE - Increases
                            As energy efficiency programs ramp up, the percent of growth that is offset by energy
                            efficiency climbs and then levels as cumulative savings as a percent of demand growth
                            stabilizes.
12 The changes shown in the business cases indicate a change from what would have otherwise occurred. This change does not include a one-time infra-
  structure investment in the assumptions, but it does include smooth capital expenditures. Energy efficiency will moderate prices of fossil fuels. The fuel
  price reductions from an aggressive energy efficiency program upon fuel prices have not been included and could result in an overall rate reduction.
To create a sustainable, aggressive national commitment to energy efficiency
1-13

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About This Report
                                                       Chapter 4:
The National Action  Plan for Energy Efficiency is struc-
tured  as follows:

Chapter 2: Utility Ratemakinq & Revenue Reqmienien!-,

• Reviews mechanisms for  removing disincentives  for
  utilities to consider  energy  efficiency.

• Reviews the pros and cons for different strategies to
  reward utility energy efficiency performance, including
  the  use of energy efficiency targets,  shared  savings
  approaches, and  shareholder/company  performance
  incentives.

• Reviews various funding options for energy efficiency
  programs.

• Presents recommendations and options for modifying
  policies to align utility incentives with the delivery of
  cost-effective energy efficiency and providing for suffi-
  cient and stable program funding to deliver energy effi-
  ciency where cost effective.

Chapter 3: Energy Resource Planning Processes

• Reviews state and  regional  planning   approaches,
  including   Portfolio  Management and  Integrated
  Resource Planning,  which are being used to evaluate a
  broad array of supply and  demand options on a  level
  playing field in terms of their ability to meet projected
  energy demand.

• Reviews methods to  quantify and simplify  the value
  streams that arise from energy efficiency investments—
  including reliability enhancement/congestion relief, peak
  demand  reductions,  and  greenhouse  gas  emissions
  reductions—for direct comparison to supply-side options.

• Presents recommendations and options  for making a
  strong, long-term commitment to cost-effective energy
  efficiency as a resource.
•ป Outlines the  business case approach used to examine
 the financial  implications of enhanced energy efficien-
 cy investment on utilities,  consumers, and society.

ปPresents case studies for eight different electric and
 natural gas utility situations, including different owner-
 ship structures, gas and electric utilities,  and different
 demand growth rates.

Chapter 5: Rate Design

• Reviews a  variety of  rate design structures and their
 effect  in promoting greater investment in energy effi-
 ciency by the end-user.

• Presents recommended  strategies that  encourage
 greater use of energy efficiency through  rate design.

Chapter 6: Energy Efficiency Program Best  Practices

• Reviews and  presents best practices for operating suc-
 cessful energy efficiency programs at a portfolio level,
 addressing issues such  as assessing energy efficiency
 potential,  screening  energy efficiency   programs  for
 cost-effectiveness, and  developing a  portfolio  of
 approaches.

• Provides best practices for successful energy efficiency
 programs across end-use sectors, customer classes, and
 a broad set of approaches.

• Documents the political and administrative factors that
 lead to program success.

Chapter 7: Report Summary

• Summarizes  the policy and program recommendations
 and options.
 1-14   National Action Plan for Energy Efficiency

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 f-or More Information

Visit the National Action Plan for Energy Efficiency
Web site: www.epa.gov/deanenergy/eeactionplan.htm
or contact:

Stacy Angel
U.S. Environmental Protection Agency
Office of Air and Radiation
Climate Protection Partnerships Division
Angel.Stacy@epa.gov

Larry Mansueti
U.S. Department of Energy
Office of Electricity Delivery and  Energy Reliability
Lawrence.Mansueti@hq.doe.gov
/r> create ,1 sustainable, aggressive national commitment to energy efficiency                                             1-15

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 Table 1 -2. Members of the National Action Plan for Energy Efficiency
 Co-Chairs
 Diane Munns      Member
                   President
 Jim Rogers         President and Chief Executive Officer

 Leadership Group
                                                  Iowa Utilities Board
                                                  National Association of Regulatory Utility Commissioners
                                                  Duke Energy
 Barry Abramson
 Angela S. Beehler
 Bruce Braine
 Jeff Burks
 Kateri Callahan
 Glenn Cannon
 Jorge Carrasco
 Lonnie Carter
 Mark Case
 Gary Connett

 Larry Downes

 Roger Duncan
 Angelo Esposito
 William Flynn
 Jeanne Fox
 Anne George
 Dian Grueneich
 Blair Hamilton
 Leonard Haynes

 Mary Healey
 Helen Howes
 Chris James
 Ruth Kinzey
 Peter Lendrum
 Rick Leuthauser
 Mark McGahey
 Janine Migden-
 Ostrander
 Richard Morgan
 Brock Nicholson
 Pat Oshie
 Douglas Petitt
Senior Vice President
Director of Energy Regulation
Vice President, Strategic Policy Analysis
Director of Environmental Sustainability
President
General Manager
Superintendent
President and Chief Executive Officer
Vice President for Business Performance
Manager of Resource Planning and
Member Services
Chairman and Chief Executive Officer

Deputy General  Manager, Distributed Energy Services
Senior Vice President, Energy Services and Technology
Chairman
President
Commissioner
Commissioner
Policy Director
Executive Vice President, Supply Technologies,
Renewables, and Demand Side Planning
Consumer Counsel  for the State of Connecticut
Vice President, Environment, Health and Safety
Air Director
Director of Corporate Communications
Vice President, Sales and Marketing
Manager of Energy Efficiency
Manager
Consumers' Counsel

Commissioner
Deputy Director, Division of Air Quality
Commissioner
Vice President, Government Affairs
Servidyne Systems, LLC
Wal-Mart Stores, Inc.
American Electric Power
PNM Resources
Alliance to Save Energy
Waverly Light and Power
Seattle City Light
Santee Cooper
Baltimore Gas and Electric
Great River Energy

New Jersey Natural Gas
(New Jersey Resources Corporation)
Austin Energy
New York Power Authority
New York State Public Service Commission
New Jersey Board of Public  Utilities
Connecticut Department of Public Utility Control
California Public Utilities Commission
Vermont Energy Investment Corporation
Southern Company

Connecticut Consumer Counsel
Exelon
Connecticut Department of Environmental Protection
Food Lion
Entergy Corporation
MidAmerican Energy Company
Tristate Generation and Transmission Association, Inc.
Office  of the Ohio Consumers' Counsel

District of Columbia  Public Service Commission
North  Carolina Air Office
Washington Utilities and Transportation Commission
Vectren Corporation
1 -16   National Action Plan for Energy Efficiency

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Bill Prindle
Phyllis Reha
Roland Risser
Gene Rodrigues
Art Rosenfeld
Jan Schori
Larry Shirley
Michael Shore
Gordon Slack
Deb Sundin
Dub Taylor
Paul von
Paumgartten
Brenna Walraven
Devra Wang
Steve Ward
Mike Weedall
Tom Welch
Jim West
Henry Yoshimura
Deputy Director
Commissioner
Director,  Customer Energy Efficiency
Director,  Energy Efficiency
Commissioner
General Manager
Division Director
Senior Air Policy Analyst
Energy Business Director
Director,  Business Product Marketing
Director
Director,  Energy and Environmental Affairs

Executive Director,  National Property Management
Director,  California Energy Program
Public Advocate
Vice President, Energy Efficiency
Vice President, External Affairs
Manager of energy right & Green Power Switch
Manager, Demand Response
American Council for an Energy-Efficient Economy
Minnesota Public Utilities Commission
Pacific Gas and Electric
Southern California Edison
California Energy Commission
Sacramento Municipal Utility District
North Carolina Energy Office
Environmental Defense
The Dow Chemical Company
Xcel Energy
Texas State Energy Conservation Office
Johnson  Controls

USAA Realty Company
Natural Resources Defense Council
State of Maine
Bonneville Power Administration
PJM  Interconnection
Tennessee Valley Authority
ISO New England Inc.
Observers
James W. (Jay)
Brew
Roger Cooper
Dan Delurey
Roger Fragua
Jeff Genzer
Donald Gilligan
Chuck Gray

John Holt
Joseph Mattingly
Kenneth Mentzer
Christina Mudd
Ellen Petrill
Alan Richardson
Steve Rosenstock
Diane Shea
Rick Tempchin
Mark Wolfe
Counsel

Executive Vice President, Policy and Planning
Executive Director
Deputy Director
General Counsel
President
Executive Director

Senior Manager of Generation and Fuel
Vice President, Secretary and General Counsel
President and Chief Executive Officer
Executive Director
Director, Public/Private Partnerships
President and Chief Executive Officer
Manager, Energy Solutions
Executive Director
Director, Retail Distribution Policy
Executive Director
Steel Manufacturers Association

American Gas Association
Demand Response Coordinating Committee
Council of Energy Resource Tribes
National Association of State Energy Officials
National Association of Energy Service Companies
National Association of Regulatory Utility
Commissioners
National Rural Electric Cooperative Association
Gas Appliance Manufacturers Association
North American Insulation  Manufacturers Association
National Council on Electricity Policy
Electric Power Research Institute
American Public Power Association
Edison Electric Institute
National Association of State Energy Officials
Edison Electric Institute
Energy Programs Consortium
                                                                                                                   1-17

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References

American Council for an Energy-Efficient Economy
    [ACEEE] (2004). A Federal System Benefits Fund:
    Assisting States to Establish Energy Efficiency and
    Other System Benefit Programs. Washington,  DC.
Callahan, K. Alliance to Save Energy (2006, January
    17). Energy Efficiency As a Cornerstone of National
    Energy Policy. Presented to United States Energy
    Association, Washington, DC.
Connecticut Energy Conservation Management Board
    [CECMB] (2006, March) Energy Efficiency:  Investing
    in Connecticut's Future: Report of The Energy
    Conservation Management Board Year 2005
    Programs and Operations.
    
Eckman, T. (2005, September 26). The Northwest
    Forecast: Energy Efficiency Dominates Resource
    Development. Paper presented at the ACEEE
    Energy Efficiency As a Resource Conference.
    
Innovest Strategic Value Advisors [Innovest] (2002,
    October). Energy Management &  Investor Returns:
    The Real Estate Sector.
Long Island Power Authority [LIRA] (2006). Clean
    Energy Initiative Annual Report 2005.
Nadel, S., Shipley, A., and Elliott, R.N. (2004). The
    Technical, Economic and Achievable Potential for
    Energy Efficiency in the U.S.—A Meta-Analysis of
    Recent Studies.  Washington, DC: American Council
    for an Energy-Efficient Economy [ACEEE].
New York State Energy Research and Development
    Authority [NYSERDA] (2006, May) New York Energy
    $martSM Program Evaluation and Status Report.
    Report to the System Benefits Charge Advisory
    Group, Draft Report.
New York State Energy Research and Development
    Authority [NYSERDA] (2004, May). New York
    Energy $martSM Program Evaluation and Status
    Report, Report to the System Benefits Charge
    Advisory Group, Final Report. Albany.
Northeast Energy Efficiency Partnerships [NEEP] (2005,
    May). Economically Achievable Energy Efficiency
    Potential in New England. Optimal Energy.
Northwest Power and Conservation Council [NWPCC]
    (2005, May). The 5th Northwest Electric Power and
    Conservation Plan, 
Puget Sound Energy (2005, April). Least Cost Plan.
    
Sedano R., Murray, C., and Steinhurst, W. R. (2005,
    May). Electric Energy Efficiency and Renewable
    Energy in New England: An Assessment of Existing
    Policies and Prospects for the Future. Montpelier,
    VT: The Regulatory Assistance Project.
Southern California Edison (2006, January 6) Advice
    Letter (1955-e) to the California Energy
    Commission.
Southwest Energy Efficiency Project [SWEEP] (2002,
    November).  The New Mother Lode: The Potential
    for More Efficient Electricity Use in the Southwest.
    Report for the Hewlett Foundation Energy Series.
U.S. Energy Information Administration [EIA] (2006).
    Annual Energy Outlook 2006. Washington, DC).
U.S. Energy Information Administration [EIA] (2005,
    January). Annual Energy Outlook  2005.
    Washington, DC), 
U.S. Environmental Protection Agency [EPA] (2006).
    Clean Energy-Environment Guide to Action:
    Policies, Best Practices, and Action Steps for States.
    Washington, DC.
Western Governors' Association [WGA] (2006, June).
    Clean Energy, a Strong Economy and a Healthy
    Environment. A Report of the Clean and Diversified
    Energy Advisory Committee.
York,  D. and Kushler, M. (2005, October). ACEEE's 3^
    National Scorecard on Utility and  Public Benefits
    Energy  Efficiency Programs: A National Review and
    Update of State Level Activity.
    http://www.aceee.org/pubs/u054.pdf
 1-18   National Action Plan for Energy Efficiency

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2
Utility  Ratemaking
&  Revenue Requirements
While some utilities manage aggressive energy efficiency programs as a strategy to diversify their portfolio,
lower costs, and  meet customer demand, many still face important financial disincentive: to implementing
such programs. Regulators working with utilities and other stakeholders, as well as boards working with
publicly owned utilities, can establish or reinforce several policies to help address these disincentives, includ-
ing overcoming  the  throughput incentive, ensuring  program cost recovery,  and  defining  shareholder
performance incentives.
Overview

The practice of utility regulation is,  in part,  a  choice
about how utilities make money and manage risk. These
regulatory choices can guide utilities toward  or  away
from investing in energy efficiency, demand response,
and distributed generation (DG). Traditional ratemaking
approaches  have  strongly linked  a utility's  financial
health to the volume of electricity or gas sold via the
ratemaking structure, creating a disincentive to  invest-
ment  in cost-effective  demand-side  resources that
reduce  sales. The  ratemaking  structure  and  process
establishes the rates that generate the revenues that gas
and electric utilities, both public and private, can recov-
er based on  the just and reasonable costs they incur to
operate  the  system and to procure and deliver energy
resources to  serve their customers.

Alternate financial incentive structures can be  designed
to encourage utilities to actively promote implementa-
tion of energy efficiency when it is cost effective to do
so. Aligning  utility and public interest aims  by discon-
necting  profits and fixed cost recovery  from sales vol-
umes, ensuring  program cost recovery,  and rewarding
shareholders can "level the playing  field" to  allow for a
fair, economically  based  comparison between supply-
and demand-side resource alternatives and can yield a
lower cost, cleaner, and reliable energy system.
                                             This  chapter explores the utility  regulatory approaches
                                             that  limit greater deployment of energy efficiency as a
                                             resource  in  U.S. electricity  and natural  gas systems.
                                             Generally,  it is within the power of utility commissions
                                             and  utilities to remove these barriers.1  Eliminating the
                                             throughput incentive is one way to remove a disincentive
                                             to invest in efficiency. Offering  shareholder  incentives
                                             will further encourage utility investment. Other disincen-
                                                Leadership Group Recommendations
                                                Applicable to Utility Ratemaking and
                                                Revenue Requirements
                                               • Modify policies to align utility incentives with the deliv-
                                                 ery  of cost-effective  energy efficiency  and  modify
                                                 ratemaking  practices  to promote energy  efficiency
                                                 investments.
                                               • Make  a strong, long-term commitment to  implement
                                                 cost-effective energy efficiency as a resource.
                                               • Broadly communicate the benefits of and opportunities
                                                 for energy efficiency.
                                               • Provide sufficient, timely, and stable program funding
                                                 to deliver energy efficiency where cost-effective.
                                               A more detailed list of options specific to the objective of
                                               promoting energy efficiency in ratemaking  and revenue
                                               requirements is provided at the end of this chapter.
 In some cases, state law limits the latitude of a commission to grant ratemaking or earnings flexibility. Removing barriers to energy efficiency in these
 states faces the added challenge of amending statutes.
To create a sustainable, aggressive national commitment to energy efficiency
                                                                                           2-1

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tives for energy efficiency include a short-term resource
acquisition horizon and wholesale market rules that do
not capture the system value of energy efficiency. After
an  introduction to  these barriers and  solutions, this
chapter will  report  on successful  efforts  in states  to
implement these solutions. The chapter closes with a set
of recommendations for pursuing the removal of these
barriers.

This chapter refers to utilities as integrated energy com-
panies selling electricity as well as delivering  it. Many of
these  concepts,  however,  also apply  to  states  that
removed retail  electricity sales responsibilities from utili-
ties—turning the utility into an electric transmission and
distribution company without a  retail  sales function.
 Barriers and  Solutions to  Effective
 Energy Efficiency Deployment

Common disincentives for utilities to invest more in cost-
effective  energy  efficiency  programs  include  the
"throughput incentive," the lack of a  mechanism for
utilities to recover the costs of and provide funding for
energy efficiency programs,  and a lack of shareholder
and other performance incentives to compete with those
for investments in new generation.

Traditional Regulation Motivates Utilities to
Sell More: The Throughput Incentive

Rates change with each major "rate case," the tradition-
al  and dominant  form of state-level utility ratemaking.2
Between rate cases, utilities have a financial incentive to
increase  retail sales of electricity (relative to forecast  or
historic levels, which set "base" rates) and to maximize
the "throughput" of electricity across  their wires. This
incentive exists because there is often a  significant incre-
mental profit margin  on incremental sales. When rates
                                                  are  reset,  the throughput  incentive resumes with the
                                                  new base. In jurisdictions where prices are capped for an
                                                  extended time, the  utility might be particularly anxious
                                                  to grow sales to add revenue to cover cost increases that
                                                  might occur during the freeze.

                                                  With traditional ratemaking, there are  few mechanisms
                                                  to prevent "over-recovery" of costs, which occurs if sales
                                                  are  higher than  projected,  and  no  way  to prevent
                                                  "under-recovery," which can happen if forecast sales are
                                                  too  optimistic (such as when weather or regional  eco-
                                                  nomic conditions deviate from  forecasted or  "normal"
                                                  conditions).3

                                                  This dynamic creates an automatic disincentive for  utili-
                                                  ties  to promote energy efficiency, because those actions
                                                  will  reduce the utility's net income—even if  energy effi-
                                                  ciency is  clearly established  and agreed-upon as a less
                                                  expensive means to  meet customer needs as a least-cost
                                                  resource and is valuable to the  utility  for risk manage-
                                                  ment, congestion reduction, and other reasons  (EPA,
                                                  2006).  The effect of this disincentive  is exacerbated  in
                                                  the  case  of distribution-only utilities,   because the rev-
                                                  enue impact of electricity sales  reduction is dispropor-
                                                  tionately larger for utilities without generation resources.
                                                  While some states have ordered util ties to implement
                                                  energy efficiency, others have questioned the practica ity
                                                  of asking  a utility to  implement  cost-effective energy
                                                  efficiency  when their  financial  self-interest is to have
                                                  greater sales.

                                                  Several options exist to help remove this financial barrier
                                                  to greater investment in energy efficiency:

                                                  Decouple Sales from  Profits and Fixed Cost Recovery
                                                  Utilities can be regulated or  managed  in a  manner that
                                                  allows them to receive their revenue requirement with less
                                                  linkage to sales volume. The point is to regulate utilities such
                                                  that  reductions in sales from consumer-funded energy
2 Public power utilities and cooperative utilities have their own processes to adjust rates that do not require state involvement.
3 Over-recovery means that more money is collected from consumers in rates than is needed to pay for allowed costs, including return on investment. This
 happens because average rates tend to collect more for sales in excess of projected demand than the marginal cost to produce and deliver the electric-
 ity for those increased sales. Likewise, under-recovery happens if sales are less than the amount used to set rates (Moskovitz, 2000).
2-2
National Action Plan for Energy Efficiency

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   Utility and Industry Structure and  Energy Efficiency
   Publicly and Cooperatively Owned Utilities
   Compared With Investor-Owned Utilities
   The throughput incentive affects municipal and coop-
   erative utilities  in a distinctive way. Public power and
   co-ops and their lenders are concerned with ensuring
   that income covers debt costs, while they are not con-
   cerned about  "profits." Available low-cost financing
   for co-ops  sometimes comes with  restrictions  that
   limit its use to power lines  and generation,  further
   diminishing interest in energy efficiency investments.

   Natural Gas vs. Electric Utilities
   Natural gas and electric utilities both experience  the
   throughput incentive under  traditional  ratemaking.
   Natural gas utilities operate  in  a more competitive
   environment than do electric utilities because of  the
   non-regulated alternative fuels, but this situation  can
   cut either way for energy efficiency. For some gas util-
   ities, energy efficiency is an important customer serv-
   ice tool, while in  other cases, it is  just seen as an
   imposed cost that competitors do not have. Natural
   gas companies in the United  States also generally see
   a decline in sales due to state-of-the-art efficiencies in
   gas end uses,  a  phenomenon not  seen by electric
   companies.  Yet cost-effective efficiency opportunities
   for local gas distribution companies remain available.
 Restructured vs. Traditional Markets
 The transition to retail electric competition threw open
 for reconsideration all assumptions about utility struc-
 ture. The effects  on  energy  efficiency have been
 strongly positive and negative.  The throughput incen-
 tive is stronger for distribution-only  companies with
 no generation and transmission rate  base. Price caps,
 which typically are imposed in a transition to retail
 competition, diminish utility incentive to reduce sales
 because added revenue helps cope  with new costs.
 Price caps also discourage utilities from  adding near-
 term costs that can produce a long-term  benefit, such
 as energy efficiency. As a result, energy efficiency is
 often disconnected from utility planning.  On the other
 hand, several states have provided stable funding for
 energy efficiency as part of the restructuring process.

 High-Cost vs.  Low-Cost States
 Energy efficiency has been  more popular in high-cost
 states. Low-cost states tend to see energy efficiency as
 more expensive than their supplies from  hydroelectric
 and coal sources,  though there are exceptions where
 efficiency is seen  as  a  low-cost incremental resource
 and a way to meet environmental goals. Looking for-
 ward, all states face similar, higher  cost options for
 new generation, suggesting that the  current resource
 mix will be less important than future  resource options
 in  considering the value  of new energy  efficiency
 investments.
efficiency, building codes, appliance standards, and distrib-
uted generation are welcomed, and not discouraged.

For example, if utility revenues were  connected to the
number of customers, instead of sales, the  utility would
experience different incentives and might behave guite dif-
ferently. Under this approach, at the conclusion of a con-
ventional revenue requirement proceeding, a utility's rev-
enues per customer could be fixed. An automatic adjust-
ment to the revenue reguirement would occur to account
for new or departing  customers  (a more reliable driver of
costs than sales). An alternative to the  revenue per cus-
tomer approach is  to use a simple escalation formula to
forecast the fixed cost revenue requirement over time.

Under this type of rate structure, a utility that is more effi-
cient and reduces its costs over time through energy effi-
ciency will be able to increase profits. Furthermore, if sales
are reduced by any means (e.g., efficiency, weather, or eco-
nomic swings) revenues  and profits will not be affected.
To create a sustainable, aggressive national commitment to energy efficiency
                                                 2-3

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This approach eliminates the throughput disincentive and
does not require a commission resolution of the amount
of lost revenues associated with  energy  efficiency (see
Table 2-1). A critical element of revenue decoupling is a
true-up of  actual results  to forecasted  results.  Rates
would vary up or down reflecting a balancing account for
total authorized revenue requirements and actual rev-
enues from  electricity  or gas consumed  by customers.
The true-up is  fundamental to accomplish  decoupling
profits  and  fixed  cost revenues  from sales  volumes.
Annual adjustments have been typical and can be mod-
eled  in the  Energy  Efficiency Benefits Calculator (see
Chapter 4:  Business  Case  for  Energy Efficiency),  but a
quarterly or  monthly adjustment might be preferred. The
plan may also include a deadband, meaning that modest
deviations from the forecast would produce no change in
rates, while  larger deviations will result  in a rate change.
The  plan might also  share some  of the  deviations
between customers and the utility.  The magnitude of rate
changes at any one time can be capped if the utility and
regulators agree  to  defer  the  balance of exceptional
changes to be  resolved later. Prudence reviews should be
unaffected  by  a  decoupling  plan.  A  decoupling plan
would typically  last a  few years and could  be changed to
reflect  new   circumstances   and  lessons  learned.
Decoupling has the potential to lower the risk of the util-
ity, and this feature  should lead  to  consumer benefits
through an overall lower cost of capital  to the utility.4

Decoupling  through  a revenue  per customer cap  is
presently more prevalent in natural gas companies, but
can be  a  sound tool for electric  companies  also. Rate
design need not be affected by decoupling (see Chapter
5: Rate Design for rate design  initiatives that promote
energy efficiency), and a shift of revenues from the vari-
able  portion of  rates to  the fixed  portion  does not
address the throughput incentive.  The initial revenue
requirement would be determined in a routine rate case,
the revenue per customer  calculation would  flow from
the same billing determinants used ::o set rates. Service
perfo"mance measures can be addec to  assure that cost
reductions  result from efficiency rather than  service
reductions. Some state laws  limit the use of balancing
accounts and  true-ups, so legislative action would  be
necessary to enable decoupling in those states.

A decoupling system can be simple or complex, depend-
ing on the  needs of regulators, the utility, or other par-
ties and the value of a broad stakeholder process leading
up to a decoupling system (Kantor,  2006).  As  the text
box addressing lessons learned suggests, it is important
to establish the priorities that the system is being creat-
ed to address so it can be as simple as possible wiile
avoiding unintended consequences. Additionally, r:  is
important to evaluate any decoupling system to ensure
it is performing as expected.5

Shifting More Utility Fixed Costs Into Fixed Customer
Charges
Traditionally, rates recover a portion of the utility's fixed
costs  through  volumetric  rates,  which  helps  service
remain  affordable.  To  better  assure  recovery of capita!
asset costs  with reduced dependence on sales, state util-
ity commissions could reduce variable rates and increase
the fixed rate component, often referred to  as the fixed
charge or customer charge. This option might be partic-
ularly relevant in retail competition states because wires-
only electric utilities have  relatively high proportions of
fixed costs. This shift is attractive to some  natural gas
systems experiencing  sales  volume attrition   due  to
improved furnace efficiency and other trends. This shift
reduces the throughput incentive for distribution  compa-
nies and is  an  alternative to decoupling. There are  some
limiting concerns, including the effect a  reduction in the
variable charge  might have on  consumption and con-
sumers' motivation  to practice energy efficiency, and the
potential for high using consumers to benefit from the
change while low-using customers pay more.
4 The lowering of a gas utility's cost of capital because of the reduced risk introduced by a revenue decoupling mechanism was recently affirmed by Barone
 (2006).
5 Two recent papers discuss decoupling in some detail: Costello, 2006 and NERA, 2006.
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   The First Wave of Decoupling and Lessons Learned
   In the early 1990s, several state commissions and util-
   ities responded to the throughput incentive by creat-
   ing decoupling systems. In  all  cases, decoupling was
   discontinued by the end of the decade. The reasons
   for discontinuation provide  guidance to those consid-
   ering decoupling today and indicate that the initial
   idea was good, but that the execution left important
   issues unaddressed.

   In the case of California, decoupling was functioning
   well,  using forecasted revenues and true-ups to actu-
   als, but the move to retail competition precipitated its
   end in 1996 (CPUC, 1996). Following the energy cri-
   sis of 2000-2001,  California recognized  the  impor-
   tance of long-term energy efficiency investments and
   reinstated  mechanisms  to  eliminate the throughput
   incentive.

   Puget Sound Energy in Washington adopted a decou-
   pling  plan in  1990. There were several problems. The
   split  between variable power  costs  (recovered via a
   true-up based on actual experience) and fixed costs
   (recovered  based on a revenue-per-customer calcula-
   tion)  was  wrong. While  customer  numbers (and
   revenue) were increasing, new investments in trans-
   mission were not needed so the fixed cost part of the
   plan  over-recovered. Meanwhile, new  generation
   from  independent generators was too expensive, and
   this added power cost (minus  a  prudence  disal-
   lowance, which  further complicated the  scene) was
   passed  to  ratepayers.  Unlike  the current California
   decoupling method, there was  no reasonable forecast
   over time for power costs. Risk of power cost increas-
   es was insufficiently shared.  The results were a big rate
   increase and anger among customers.  In retrospect,
   risk allocation and the split  of fixed and variable costs
   were  incompatible to the events that followed and
   offer  a  useful lesson to  future  attempts. The true-up
process and the  weather  normalization  process
worked well. The power costs that ignited the contro-
versy  over the  decoupling plan would have  been
recoverable in rates under the traditional system.  A
recent effort to  restore decoupling  with  Puget
foundered over  a dispute  about whether the allowed
return on  equity during a prior rate case should be
changed if decoupling was reinstated (Jim Lazar, per-
sonal  communication, October 21, 2005).

Central Maine Power also adopted a decoupling plan
at the beginning of the  1990s. The  plan  was ill-
equipped,  however, to account for  an ensuing steep
economic downturn that reduced sales by several per-
centage points.  Unfortunately,  this effect far out-
weighed  any benefits  from energy efficiency.  The
true-ups called for in the  plan  were onerous due to
the dip in sales, and authorities decided to delay them
in hopes that the economy would turn around. When
that did not happen, the rate change was quite large
and was  attributed to the  decoupling plan,  even
though most  of the rate increase was due to reduced
sales and would have occurred anyway. A lesson from
this experience is to not let the period between true-
ups go on too  long and  to consider more carefully
what  happens  if  market  prices, the economy, the
weather, or other significant drivers are well outside
expected ranges.

In both the Puget and Central Maine cases, responsibil-
ity for large  rate  increases was  misassigned  to the
decoupling  plan, when  high power costs from  inde-
pendent power producers (Puget) or  general economic
conditions  (Central  Maine) were primarily responsible.
That said,  serious but correctable flaws in the decou-
pling  plans left consumers exposed to more risk than
was necessary.
To create a sustainable, aggressive national commitment to energy efficiency
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Provide Utilities the Profit Lost Through Efficiency
Another way to address the  throughput incentive is  to
calculate the profits foregone to successful energy effi-
ciency. Lost Revenue  Adjustment  Mechanisms  (LRAM)
allow a utility to directly  recoup the "lost"  profits  and
contributions to fixed costs associated with not selling
additional   units of  energy because  of the success  of
energy efficiency programs in  reducing  electricity con-
sumption.  The amount of lost profit can be estimated  by
multiplying the  fixed portion  of the utility's prices by the
                                                          energy  savings from  energy efficiency programs or  the
                                                          energy  generated  from  DG, based on projected savings
                                                          or ex post impact evaluation studies. The amount of  ost
                                                          estimated profits  is then directly returned to the utility's
                                                          shareholders.  Some states  have adopted these mecha-
                                                          nisms either  through  rate cases or add-ons to  the fuel
                                                          adjustment clause calculations.


                                                          Experience has shown that LRAM can allow utilities to
                                                          recover more  profits than the energy efficiency program
    Table 2-1. Options to Mitigate the Throughput  Incentive:  Pros and  Cons
         Policy
                                        Pros
                                Cons
 Traditional cost of service
 plus return regulation
                     Familiar system for regulators and utilities.

                     Rate changes follow rate cases (except for fuel/
                     gas adjustment clause states).
                                                                    urchased
            Reduced sales reduce net income and contributions to
            fixed costs.

            Sales forecasts can be contentious.

            Harder to connect good utility performance to a financial
            consequence. Risks outside control of utility might be
            assigned to the utility.
 Decoupling (use of a forecast
 of revenue or revenue per
 customer, with true-ups to
 actual results during a
 defined timeframe)
                    Removes sales incentive and distributed resourcel disincen-
                    tives.

                    Authorized fixed costs covered by revenue.

                    All beneficial actions and policies that reduce sal ;s (distrib-
                    uted generation, energy efficiency programs, cod?s and
                    standards, voluntary actions by customers, dema
                    response) can be promoted by the utility without adversely
                    affecting net income or coverage of fixed costs.
                    Opportunity to easily reward or penalize utilities ased on
                    performance.

                    True-ups from balancing accounts or revenue per customer
                    are simple.

                    Easy to add productivity factors,  inflation adjustments, and
                    performance indicators with rewards and penalti s that
                    can be folded into the true-up process.

                    Reduces volatility of utility revenue resulting frorr  many
                    causes. Risks from abnormal weather, economic perform-
                    ance, or energy markets can be allocated explicit  between
                    customers and the utility.
         • Lack of experience. Viewed by some as a more complex
           process.

         • Quality of forecasts is very important.

         • Some consumer advocates are uncomfortable with rate
           adjustments outside rate case or familiar fuel adjustment
           clause.

         • Frequent rate adjustments from true-ups are objectionable
           to those favoring rate stability who worry about accounta-
           bility for rate increases.

         • Process of risk allocation can cause decoupling plan to
           break down. Connection between reconstituted risks and
           cost of capital can cause impasse.

         • Many issues to factor into the decoupling agreement. Past
           experience with decoupling indicates that it can be hard to
           "get it right," though these experiences suggest solutions.
 Lost revenue adjustment
                    Restores revenue to utility that would have gone
                    ings and coverage of fixed costs but is lost by en
                    ciency.

                    Diminishes the throughput disincentive for sped
                    ing programs.
o earn-
rgy effi-
                                                                     qualify-
Any sales reductions from efficiency initiatives outside qual-
ifying programs are not addressed, leaving the throughput
incentive in place.

Historically contentious, complex process to decide on lost
revenue adjustment. Potentially rewards under-performing
energy efficiency programs.
 Independent energy efficiency
 administration
                    Administration of energy efficiency is assigned to |an entity
                    without the conflict of the throughput incentive.
            Utility can still promote load building. Programs that would
            reduce sales outside the activities of the independent
            administrator might still be discouraged due to the
            throughput incentive.
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National Action Plan for Energy Efficiency

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actually saved because the lost profit is based on project-
ed, rather than  actual, energy savings. Resolving LRAM
in  rate cases  has been  contentious  in some  states.
Furthermore, because utilities still earn increased profits
on additional sales, this approach still discourages  utili-
ties from  implementing additional  energy efficiency or
supporting  independent  energy  efficiency  activities. A
comparison of decoupling and  the LRAM  approach is
provided in  Table 2-1.

A variation is to roughly estimate the amount of lost prof-
its and make a specified portion (50 to 100 percent) avail-
able to the  utility to collect based on its performance at
achieving  certain program goals. This approach is simpler
and more constructive than a commission docket to cal-
culate lost revenue. It provides a visible way  for the  utili-
ty to  earn back lost profits with  program performance
and achievements consistent with the public interest. This
system translates well into employee merit pay systems,
and the goals can fit nicely into management objectives
reported to  shareholders,  a utility's board of  directors, or
Governors. Public interest  groups appreciate  the connec-
tion to performance.

Non-Utility  Administration
Several states, such as Oregon, Vermont and New York,
have elected to  relieve utilities from the task of manag-
ing energy efficiency programs. In some cases, state  gov-
ernment has taken on this responsibility, and in others, a
third  party was  created or hired  for this purpose.  The
utility still has the throughput  incentive, so while  effi-
ciency administration might be without conflict, the util-
ity may still  engage in load-building efforts contrary to
the messages from the efficiency programs. Addressing
the throughput  incentive  remains desirable  even  where
non-utility administration  is  in place.  Non-utility energy
efficiency  administration can apply to either electricity or
natural gas.  Where non-utility energy efficiency adminis-
tration is  in place, cooperation with the utility remains
important to ensure that the customer receives good
service (Harrington, 2003).
Wholesale Power Markets and the Throughput
incentive
In recent years,  wholesale  electric power  prices have
increased, driven by increases in commodity fuel costs. In
many parts of the country, these increases have created
a  situation  in  which  utilities with  generation  or firm
power contracts that cost less than  clearing prices  might
make a  profit  if they can sell  excess energy into  the
wholesale market.  Some have  guestioned  whether or
not the situation of utilities seeing wholesale profits from
reduced  retail sales diminishes  or removes the through-
put incentive.

Empirically,  these conditions  do  not appear to have
moved utilities to accelerate energy efficiency program
deployment.  In  states in which generation  is divested
from the local  utility, the companies serving  retail cus-
tomers  see   no change to the  throughput  incentive.
There is  little to  suggest how  these market conditions
will persist or change. In the absence of a more defini-
tive course change,  evidence suggests that  the recent
trend should  not dissuade policymakers and market par-
ticipants  from addressing the throughput incentive.

Recovering Costs / Providing  Funding for
Energy  Efficiency Programs
Removing the throughput incentive  is a necessary step in
addressing the barriers many utilities face to investing more
in  energy efficiency. It is unlikely to be sufficient by itself in
promoting greater investment,  however, because under
traditional ratemaking,  utilities might be unable to cover
the costs of running  energy efficiency  programs.6 To
ensure  funds are available for  energy efficiency,  policy-
makers can utilize and establish the following mechanisms
with cooperation from stakeholders:

Revenue Requirement or Procurement Funding
Policy-makers and regulators can set clear expectations
that utilities  should  consider  energy efficiency  as a
resource  in  their resource planning processes, and it
should spend money to procure that resource as it would
(i See Chapter 3: Energy Resource Planning Processes for discussion of utility resource planning budgets being used to fund energy efficiency.
To create a sustainable, aggressive national commitment to energy efficiency
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for other resources. This spending would  be part of the
utility revenue requirement and would likely appear  as
part  of  the  resource procurement  spending for  all
resources  needed  to meet consumer demand  in  all
hours.  In  retail competition states, the default service
provider, the  distribution  company, or a third party can
handle  the   responsibility  of   acquiring efficiency
resources.

Spending Budgets
To reduce regulatory disputes and create an atmosphere
of stability among utility managers, trade allies, and cus-
tomers, the  legislature or regulator  can determine a
budget level for energy efficiency spending—generally a
percentage of utility revenue. This budget  level would  be
set to achieve some amount of the potentially available,
cost-effective, program  opportunities. The spending
budget allows administrator staff, trade allies, and con-
sumers to count on a baseline level of effort and reduces
the likelihood of spending disruptions that erode cus-
tomer expectations and destroy hard-to-replace market
infrastructure needed  to deliver energy efficiency.
Unfortunately, spending budgets are sometimes treated
as a maximum spending level even if more cost-effective
efficiency can be gained. Alternatively,  a spending budg-
et can be  treated  as a minimum if  policymakers also
declare efficiency to be a  resource. In that  event, addi-
tional cost-effective investments  would be  recovered  as
part of the utility revenue  requirement.

Savings Target
An alternative to  minimum spending levels is a mini-
mum energy savings target. This alternative could  be
policy-driven  (designed for consistency to obtain a cer-
tain percentage of existing sales or forecasted  growth,
or as an Energy  Efficiency Portfolio Standard [EEPS])  or
resource-driven  (changing as system needs  dictate).
Efficiency budgets can be devised  annually to achieve
the targets. The use of savings targets does not address
how money  is collected  from customers,  or how pro-
gram administration is organized. For  more information
on how investments are selected, see  Chapter 3: Energy
Resource Planning Processes.
Clear, Reliable, and Timely Energy Efficiency Cost
Recovery System
Utilities  value a clear and timely path to cost recovery,
and a well-functioning regulatory process should provide
that. Such a process contributes to a stable  regulatory
atmosphere  that  supports energy  efficiency  programs.
Cost recovery can be linked to program performance (as
discussed in the next section) so that utilities would be
responsible for prudent spending of efficiency funds.

The energy efficiency program cost recovery issue is elim-
inated from the utility perspective if a non-utility admin-
istrative structure is used; however, this approach does
not eliminate  the throughput  incentive.  Furthermore,
funding still needs to be established for the  non-uti ity
administrator.

Tariff Rider for Energy Efficiency
A tariff  rider for energy efficiency allows for  a periodic
rate adjustment to account for the difference between
planned costs (included in rates) and actual costs.

System  Benefits Charge
In implementing retail competition, several states added
a separate charge to customer  bills to collect funds for
energy  efficiency programs;  several other states have
adopted this idea as well. A system benefits charge (SBC)
is designed to provide a stable stream  of  funds for
public purposes,  like energy efficiency. SBCs do have
disadvantages.  If the funds enter the  purview of state
government, they can be vulnerable to decisions to use
the funds for  general government  purposes.  Also,  tne
charge appears to be an  add-on to bills, which can irri-
tate  some consumers. This distinct  funding stream  can
lead to  a  disconnection  in resource planning between
energy  efficiency and other  resources. Regulators and
utilities might need to take steps to ensure a comprehen-
sive  planning  process when  dealing  with this type of
funding.7
7 This device might also pool funds for other public benefit purposes, such as renewable energy system deployment and bill assistance for low-income
 consumers.
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Providing Incentives for Energy Efficiency
investment
Some suggest that if energy efficiency is a cost-effective
resource, utilities should invest in it for that reason, with no
reason for  added incentives. Others say that for effective
results,  incentives should be considered because  utilities
are not rewarded financially for energy efficiency resources
as they  are for supply-side resources. This section reviews
options  for utility incentives to promote energy efficiency.

When utilities invest in hard assets, they depreciate these
costs over the useful lives of the assets. Consumers pay
a return on investment for the un-depreciated balance of
costs not yet recovered, which spreads the rate effect of
the  asset  over  time.  Utilities  often  do  not have  any
opportunity to earn a return on energy efficiency spending,
as they  do with  hard assets. This lack of opportunity  for
profit can introduce a bias against efficiency investment.
Incentives  for energy efficiency  should be linked  to
achieving performance objectives to avoid unnecessary
expenditures, and be evaluated by regulators based  on
their ability to produce cost-effective program  perform-
ance. Performance objectives can also form the basis of
penalties  for inferior  program  performance.  Financial
incentives for utilities should  represent revenues above
those that would normally be  recovered  in a revenue
requirement  from a  rate case.

Energy  Efficiency Costs: Capitalize or Expense?
In  most  jurisdictions,  energy efficiency  costs  are
expensed, which means all  costs incurred for energy effi-
ciency  are placed  into  rates  during  the year of  the
expense. When  a  utility introduces an energy efficiency
program, or  makes a significant  increase  or decrease in
energy efficiency spending,  rates must change to collect
all annual costs. An increase in rates might be opposed
by consumer advocates and other stakeholders, especially
if  parties disagree  on  whether the  energy efficiency
programs are cost-effective.
To  moderate  the rate effect  of efficiency,  regulators
could  capitalize efficiency  costs,  at least in  part.8
Capitalizing helps the utility  by allowing for cost  recov-
ery over time but can cost consumers more than expens-
ing in the long run. Some efficiency programs can meet
short term rate-oriented cost-effectiveness tests if costs
are capitalized. However, if the  choice is made to capital-
ize,  the  regulator still has  to decide the appropriate
amortization period  for program costs, balancing con-
cern for  immediate  rate impacts and  long  term costs.9
Capitalizing energy efficiency investments may be limit-
ed  by the  magnitude of "regulatory assets" that  is
appropriate for a utility. Bond ratings might decline if the
utility asset account  has too many assets that are not
backed by physical capital. The limit on capitalized effi-
ciency investment varies depending on the rest of the
utility balance sheet.

Some argue that capitalizing energy efficiency is too costly
and that rate effects from expensing are modest. Others
note that in some places, capitalizing energy efficiency is
the only way to deal  with transitional rate effects and can
provide a match  over time between the costs and benefits
of the efficiency investments  (Arthur Rosenfeld, personal
communication,  February 20,  2006).

In some  cases,  it  might  be  appropriate  to consider
encouraging unregulated utility affiliates to invest in and
benefit from  energy  efficiency  and  other distributed
resources.

Bonus Return, Shared Savings
To encourage  energy efficiency investments over supply
investments, regulators can authorize a return on invest-
ment that is slightly higher (e.g., 5  percent) for energy
efficiency investments or offer  a bonus return on equity
investment for superior performance. Another approach
is to share a percentage of the energy savings value, per-
haps 5 to 20 percent, with the utility. A shared savings
system has  the  virtue of linking  the magnitude of the
8 Capitalizing energy efficiency also reinforces the idea of efficiency as a substitute to supply and transmission.
9 Iowa and Vermont initially capitalized energy efficiency spending, but transitioned to expense in the late 1990s.
To create a sustainable, aggressive national commitment to energy efficiency
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reward with the level of program performance A varia-
tion is to hold back some of the funds allocated to ener-
gy efficiency for award  to shareholders for  achieving
energy efficiency targets. Where this incentive is used,
the holdback can run between 3 and 8 percent of the
program budget. Some of these funds can be channeled
to employees to reward their efforts (Arthur Rosenfeld,
personal communication, February 20, 2006; Plunkett,
2005).


Bonus returns, shared savings, and other incentives can
raise the total cost of energy efficiency. However, if the
incentives are  well-designed  and   effective,  they  will
encourage the  utility to become proficient at achieving
energy efficiency savings. The utility might be motivated
to provide greater savings for consumers through more
cost-effective energy efficiency.

Energy  Efficiency Lowers Risk
Energy efficiency can help the financial ratings of utilities
if it reduces the risks associated with  regulatory uncer-
tainty, long-term investments in gas supply and transport
and electric power and transmission, and the risks associ-
ated with fossil fuel market  prices that are subject to
volatility and unpredicted price  increases. By controlling
usage and demand,  utilities can also control the need for
new infrastructure and exposure to commodity markets,
providing risk management benefits. To the extent that a
return on efficiency  investments is likely and the chance
of a  disallowance  of associated  costs  is minimized,
investors will be satisfied. Decoupling  tends to stabilize
actual utility revenues, providing a better match to actual
cost, which should further benefit utility bond ratings.

Reversing  a Short-Term Resource Acquisition
Focus:  Focus  on Bills, Not Just Rates

Policy-makers tend  to focus  on electric rates because
they can be  easily compared across states. They become
a measure for business-friendliness, and companies con-
sider rate levels in manufacturing siting and expansion
decisions. But rates  are not the only measure of service.
A short-term focus on low rates can lead to costly missed
 nvestment opportunities  and  higher  overall  costs  of
electricity service over the long run.

Over  the  long term,  energy  efficiency  benefits can
extend  to  all  consumers.  Eventually,  reduced  capital
commitments  and lower  energy costs resulting from
cost-effective  energy efficiency programs  benefit  all
consumers and lower overall costs to the economy, free-
ing customer income for more productive purposes, like
private   investment,  savings,  and  consumption.
Improved rate  stability and risk management from limit-
ed sales growth tends to improve the reputation of the
utility. Incentives and removing the throughput incen-
tive make  it easier  for utilities to  err.brace stable  or
declining sales.

A commitment to  energy  efficiency means accepting a
new cost in rates over the short-term to gain greater sys-
tem benefits and lower long-term costs, as is the case
with other utility investments.  State and  local  political
support with a measure of  public education might  be
needed  to maintain stable programs in the face of per-
sistent immediate pressure to lower  rates.

Related Issues With Wholesale Markets  and
Long-Term Planning

Regulatory factors can hinder greater investment in cost-
effective energy  efficiency  programs. These factors
include  the  demand-side of the wholesale market not
reacting to  supply events like  shortages  or wholesale
price  spikes, and,  for the electric sector,  a short-term
generation planning  horizon, especially in  retail compe-
tition  states. In addition, transmission  system  planning
by regional transmission organizations (RTOs) and utili-
ties tends to focus on wires and supply solutions, not
demand resources  like efficiency. The value of sustained
usage  reductions  through  energy  efficiency,   demand
response and distributed generation  is not generally con-
sidered, nor compensated  for in wholesale tariffs. These
are regulatory choices and are discussed further  in
Chapter 3: Energy  Resource  Planning Processes.10
10 Planning and rate design implications are more thoroughly discussed in Chapters 3: Energy Resource Planning Processes and Chapter 5: Rate Design.
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Energy Efficiency Makes Wholesale Energy Markets
Work Better
In the wholesale market venue, the value of energy effi-
ciency would  be revealed  by a  planning  process  that
treats customer load as a manageable resource like  sup-
ply  and transmission,  with investment in  demand-side
solutions in a way that is equivalent to (not necessarily
the same as) supply and transmission solutions. Demand
response and efficiency can be called forth that specifi-
cally reduces demand at peak times or in other strategic
ways, or that reduces demand year-round.

Declare Energy Efficiency a Resource
To underscore the importance of energy efficiency, states
can declare in statute or regulatory policy that energy
efficiency  is  a  resource and that  utilities should factor
energy efficiency into resource planning and acquisition.
States concerned with risks on the supply  side can  also
go one step further and designate that energy efficiency
is the preferred resource.

Link Energy and Environmental Regulation
Environmental policy-makers have observed that energy
efficiency  is an effective and comparatively inexpensive
way to meet tightening environmental  limits to electric
power generation, yet this attribute rarely factors  into
decisions by utility regulators about deployment of ener-
gy efficiency. This issue is  discussed further  in Chapter 3:
Energy Resource Planning Processes.
State and Regional Examples of
Successful Solutions to Energy
Efficiency Deployment


Numerous states have previously addressed or are cur-
rently exploring energy efficiency electric and gas incen-
tive  mechanisms.  Experiments in  incentive regulation
occurred through the mid-1990s  but generally were
overtaken by events leading to various forms of restruc-
turing. States are expressing renewed interest in incen-
tive  regulation  due to escalating  energy costs  and a
recognition that barriers  to energy efficiency still exist.
Many state experiences are highlighted in the following
text and Table 2-2.

Addressing the Throughput Disincentive
Direction Through Legislation
New Mexico offers a  bold statutory statement directing
regulation to remove  barriers to energy  efficiency: "It
serves the public interest  to support public utility invest-
ments in cost-effective energy efficiency and load man-
agement by removing any regulatory disincentives that
might exist and allowing recovery of costs for reasonable
and  prudently  incurred expenses of energy  efficiency
and load management programs" (New Mexico Efficient
Use of Energy Act of 2005).

Decoupling Net Income From Sales
California adopted decoupling for its investor-owned
companies as it restored  utility responsibility for acquir-
ing  all  cost-effective  resources.  The  state  has  also
required  these  companies to  pursue all  cost-effective
energy efficiency at or near  the  highest  levels  in the
United States. A  balancing account collects forecasted
revenues,  and rates are reset periodically to adjust for
the difference between actual  revenues and forecasts.
Because  some  utility  cost  changes  are  factored  into
most decoupling systems, rate cases can  become less
frequent, because revenues and costs track more  closely
over time.11
  See, for example, orders in California PUC docket A02-12-027. http://www.cpuc.ca.gov/proceedings/A0212027.htm. Oregon had used this method
  successfully for PacifiCorp, but when the utility was acquired by Scottish Power, the utility elected to return to the more familiar regulatory form.
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                                               2-11

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Maryland and Oregon have decoupling mechanisms in
place for natural gas. In  Maryland,  Baltimore Gas and
Electric has  operated with  decoupling for  more  than
seven  years,  and  Washington  Gas  recently  adopted
decoupling,  indicating  that  regulators view  decoupling
as a success.12 In Oregon, Northwest Natural Gas has a
similar decoupling mechanism in place.13

The inherently  cooperative nature   of decoupling  is
demonstrated by utilities  and public  interest advocates
agreeing  on a system that addresses  public and private
interests. In  all these instances, no rate design shift was
needed to implement decoupling—the change is invisible
                                     to customers. A new  proposal for New Jersey  Natural
                                     Gas would adopt  a  system  similar to  those  in  use1 in
                                     Oregon and Maryland.

                                     See Table 2-2 for additional examples of decoupling.

                                     Reducing Cost Recovery Through Volumetric Charges
                                     After New York moved to retail competition and seoa-
                                     rated energy commodity sales from the electricity deliv-
                                     ery utility, the distribution utilities'  rates were modified to
                                     increase  fixed  cost  recovery  through  per-customer
                                     charges, and  to decrease the magnitude of variable, vol-
                                     umetric rates. Removing fixed generation costs, as these
   Table 2-2.  Examples of Decoupling
      State
Type of Utility
Key Features
 Related Rate
Design Shifts?
Political/Administrative
         Factors
                  Investor-owned electric and gas
    California
                      Balancing account to collect
                      forecasted revenue; annual
                      true-up.
                   No
                   Driven by commission, outcome of
                   energy crisis; consensus oriented.
                                           http://www.epa.gov/cleanrgy/pdf/keystone/PrusnekPresentation.pdf
                                              http://www.cpuc.ca,gov/Published/Final_decision/15019.htm
                  Investor-owned gas only
    Maryland
                      Revenue per customer cap;
                      monthly true-up.
                   No
                   Revenue stability primary motive of
                   utility; frequent true-ups.
                                             http://www.energetics.com/madri/pdfs/timmerman_101105.pdf
                               http://www.bge.com/vcmfiles/BGE/Files/Rates%20and%20Tariffs/Gas%20Service%20Tariff/Brdr_3.doc
                  Investor-owned gas only at pres-
                  ent; investor-owned electric in the
                  past
                      Revenue per customers cap;
                      annual true-up.
                   No
                   Revenue stability primary motive of
                   utility; renewed in 2005.
     Oregon
                       http://www.raponline.org/Pubs/General/OregonPaper.pdf
                     http://www.advisorinsight.com/pub/indexes/600jrii/nwnjr.htrn
                     http://www.nwnatural.com/CMS300/uploadedFiles/24190ai.pdf
                        http://apps.puc.state.or.us/orders/2002ords/02-633.pdf
New Jersey
Vermont
Investor-owned gas (proposed)
Revenue per customer.
No
Explicit intent of utility to promote
energy efficiency and stabilize fixed
cost recovery.
http://www2.njresources.com/news/trans/newsrpt.asp?Year=2005 (see 1 2/05/05)
Investor-owned electric (proposed)
Forecast revenue cap and
costs; balancing account and
true-ups.
No
Legislative change promoted utility
proposal; small utility looking for
stability.
http://www.greenmountainpower.biz/atyourservice/2006ratefiling.shtml

12 BG&E's "Monthly Rate Adjustment" tariff rider is downloadable at http://www.bge.com/portal/site/bge/menuitem.6bOb255iJ3d65180159c031eOda
  6176aO/.
13 The full agreement can be found in Appendix A of Order 02-634, available at http://apps.puc.state.or.us/orders/2002ords/02-634.pdf. See also Hansen
  and Braithwait (2005) for an independent assessment of the Northwest Natural Gas decoupling plan prepared for the commission.
2-12   National Action Plan for Energy Efficiency

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assets  were divested,  dampened the  effects on con-
sumers. In combination with tracking and deferral mech-
anisms to protect the utility from unanticipated costs
and savings, the utilities have little incentive to increase
electric sales.

Using a Lost Revenue Adjustment
Minnesota  provided  Xcel  Energy with  lost revenue
adjustments for energy efficiency through 1999, and
then moved to  a performance-based  incentive.  Iowa
currently provides utilities with lost revenue adjustments
for energy efficiency.  Connecticut allows lost revenue
recovery for all electric energy efficiency. Massachusetts
allows  lost revenue recovery for all gas energy  efficiency,
requiring the accumulated lost revenues to be  recovered
within  three years to  prevent large accumulated bal-
ances.  Oregon allows lost revenue recovery  for  utility
efficiency  programs.  Lost  revenue adjustments  have
been removed in many states because of their cost  to
consumers. New Jersey is in the midst  of a transition  to
a state-run administrator and provides lost revenue for
utility-run programs in the meantime.

Non-Utility Administration
Several  states  have  taken  over  the administration  of
energy efficiency,  including Wisconsin (Focus  on
Energy),  Maine (Efficiency Maine), New Jersey, and
Ohio.  In other states, a third party has been  set  up  to
administer programs,  including  Vermont (Efficiency
Vermont)  and  Oregon (Energy  Trust  of  Oregon). The
New  York  State  Energy  Research and   Development
Authority  (NYSERDA), a public authority,  fits  into both
categories. There  is no retail competition  in Vermont  or
Wisconsin; this change was based entirely on  an expec-
tation  of  effectiveness.  Oregon combines natural gas
and electric efficiency programs,  but only for  the larger
companies in each sector. Statewide branding  of energy
efficiency  programs is a dividend of non-utility adminis-
tration. Connecticut introduced an aspect of non-utility
administration by  vesting its  Energy  Conservation
Management Board,  a state board including  state offi-
cials, utility managers, and others, with responsibility  to
approve energy efficiency plans and budgets.
Recovering Costs / Providing  Funding for
Energy  Efficiency Programs

Revenue Requirement
When energy efficiency programs first  began, they were
funded as part of a utility revenue requirement. In  many
states, like Iowa, this practice has continued uninterrupted.
In California, retail competition interrupted this method of
acquiring energy efficiency, but  since 2003, California is
again funding energy efficiency along with other resources
through the revenue requirement, a  practice known there
as "procurement funding."  California also  funds energy
efficiency through SBC funding.

Capitalizing Energy Efficiency Costs
Oregon  allows  capitalization  of costs, and the  small
electrics do so. Washington, Vermont,  and Iowa capital-
ized energy efficiency costs when programs began in the
1980s to moderate rate effects. Vermont, for example,
amortized  program  costs over five years. In  the late
1990s, however, as  program spending declined,  these
states ended the practice of capitalizing energy efficien-
cy costs, electing to  expense all  costs.  Currently,
Vermont stakeholders  are discussing how to further
increase efficiency spending beyond  the amount collected
by the  SBC, and they are reconsidering moderating new
rate effects through capitalizing costs.

Spending Budgets, Tariff Riders,
and System Benefits Charges
Several states  have specified percentages  of net  utility
revenue or a specific charge per energy unit to be spent for
energy efficiency resources. Massachusetts, for example,
specifies 2.5 mills per kilowatt-hour (kWh) (while spending
for natural gas energy efficiency is  determined case  by
case). In  Minnesota,  there is a  separate percentage
designated for  electric  (1.5 percent of gross  operating
revenues)  and  for  natural gas (0.5  percent) utilities.
Vermont adopted  a statewide  SBC  for its vertically  inte-
grated e ectric sector, while its gas energy efficiency costs
remain embedded  in the utility revenue  requirement.
Strong statutory protections guard funds from government
appropriation. Wisconsin requires a charge, but leaves the
commission to determine the appropriate  level for each
To create a sustainable, aggressive national commitment to energy efficiency
                                                2-13

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utility. There is a history of SBC funds being used for gen-
eral  government within the  state;  2005 legislation
apparently  intended to  make funding  more  secure
(Wisconsin Act 141 of 2005).

The New York commission chose to establish an  annual
spending budget for its statewide effort (exclusive of the
public authorities and utilities), increasing it to $1  50 mil-
lion in 2001 and to $175 million in 2006. Washington
tariffs include a rider that allows adjustment of rates to
recover energy efficiency costs that  diverge from
amounts included in rates, with annual true-ups.

Providing Incentives for Energy Efficiency
Investment

Performance Incentives
In Connecticut, the two electric utilities  managing ener-
gy efficiency  programs  are  eligible  for  "performance
management fees" tied to performance goals  approved
by the  regulators,  including  lifetime  energy savings,
demand  savings,  and  other  measures.  Incentives  are
available for a range of outcomes from 70 to 130 percent
of pre-determined  goals. In  2004,  the two  utilities
collectively reached 130  percent of their energy  savings
goals and 124  percent  of their demand savings goals.
They received  performance management fees totaling
$5.27 million.  The 2006 joint budget anticipates  $2.9
million in performance incentives.

In 1999, the Minnesota Commission adopted  perform-
ance incentives for the electric and natural gas investor-
owned utilities that began at 90 percent of performance
targets and are awarded for up to 1 50 percent of target
levels. Performance targets for Minnesota utilities  spend-
ing  more than the minimum spending requirement are
adjusted to the minimum spending level for purposes of
calculating the performance incentive.

Rhode Island and Massachusetts offer similarly struc
tured incentives. Rhode Island sets aside roughly 5 per-
cent of the  efficiency budget for performance incentives.
This  amount is less than the amount that would  proba-
bly be justified if a lost revenue adjustment were used. A
collaborative  group of stakeholders recommends per-
formance indicators and levels to qualify for incentives
In Massachusetts,  utilities achieving performance tar-
gets  earn  5 percent on  money  spent for efficiency (in
addition to being able to expense eff ciency costs).

Efficiency Vermont operates under a contract with  the
Vermont  Public Service  Board.  The original contract
called for roughly 3  percent of the budget for efficiency
programs to be held back and paid if Efficiency Vermont
meets a variety of performance objectives.

Shared Savings
Before retail competition, California used a shared sav-
ings  approach, in which the utilities received  revenue
equal to a portion of the savings value produced by the
energy efficiency programs. A similar mechanism  might
be  reinstated in   2006  (Arthur  Rosenfeld,  personal
communication, February 20, 2006).

Bonus Rate of Return
Nevada allows a bonus rate of  return for demand-side
management that  is 5 percent  higher than authorized
rates of return for supply investments. Regulations specify
programs  that qualify and the  process to account for
qualifying   investments (Nevada Regulation  of  Public
Utilities Generally,  2004).

Lower Risk of Disallowance Through Multi-
Stakeholder Collaborative
California,  Rhode Island, and  other  states employ
stakeholder collaboratives to resolve important program
and administrative  issues and to provide settlements to
the regulator.

See Table  2-3 for additional examples of incentives for
energy efficiency investments.
 2-14   National Action Plan for Energy Efficiency

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   Table 2-3.  Examples of Incentives for Energy  Efficiency Investments
       State
Type of Utility
Key Features
Political/Administrative Factors
     California
                     Investor-owned electric
                        Shared savings
                   Encouraged by energy commission and utilities.
                   Incentive proportionate to value of savings; no cap.
                                   http://www.raponline.org/Conferences/Minnesota/Presentations/PrusnekCAEEMinnesota.pdf
    Connecticut                                                            Part of retail competition bargain; incentive limited to a
                     Investor-owned electric               Performance incentives       percentage of program budget; simple to compare
                                                                            results to performance goals.

                                                    http://www.state.ct.us/dpuc/ecmb/index.html
  Massachusetts,                                                          Part of retail competition bargain; incentive limited to a
   Rhode Island    Investor-owned electric               Performance incentives       percentage of program budget; simple to compare
                                                                            results to performance goals.
                                            http://www.mass.gov/dte/electric/04-11/819order.pdf (Docket 04-11)

                                       http://www.ripuc.org/eventsactions/docket/3463^NEC-2004DSMSettle(9.12.03).pdf
     Minnesota                                                             Utility-specific plan arising to resolve other regulatory
                     .          j i   •    i      i      n -i       •              issues; incentive awarded on a sliding scale of perform-
                     Investor-owned electric and natural gas   Performance incentives       ance compared  wjth goa|s; decoup|in9g not authHorized
                                                                            by statute.
                                         http://www.raponline.org/Pubs/RatePayerFundedEE/RatePayerFundedMN.pdf
      Nevada      | Investor-owned electric               Bonus rate of return on equity  Process to establish bonus is statutory.
                                            See http://www.leg.state.nv.us/NAC/NAC-704.htmlttNAC704Sec9523
      Vermont                                                              Incentive structure set by contract; result of bargain
                     Efficiency utility                    Performance incentives       between commission and third-party efficiency
                                                                            provider.

                                                    http://www.state.vt.us/psb/eeucontract.html
Regulatory Drivers for Efficiency in  Resource
Planning  and Energy Markets

Declare Energy Efficiency a Resource
In New Mexico, the  legislature has  declared a goal of
"decreasing electricity  demand by  increasing energy  effi-
ciency and  demand response, and meeting new genera-
tion needs first with renewable and distributed generation
resources, and second with clean fossil-fueled generation."
(New Mexico Efficient Use of Energy Act of 2005)

In California, the state has made it very clear that energy
efficiency is the most  important resource (California SB
1037, 2005). After the crises of 2000 and 2001, state
leaders  used  energy   efficiency  to  dampen  demand
growth  and  market volatility. An  Energy  Action Plan,
adopted  in  2003  by  the  California  Public  Utilities
Commission (CPUC), the California Energy Commission
(CEC), and the  power authority, developed a  "loading
order" for new electric resources; the  Energy Action Plan
                                has  been  revised  but the  energy  efficiency preference
                                remains  firm.  The  intent  of the  loading  order is to
                                "decreas(e) electricity demand by increasing energy  effi-
                                ciency and  demand  response, and meeting new genera-
                                tion  needs first with renewable and distributed generation
                                resources, and second with clean fossil-fueled generation"
                                (CEC,  2005). As a  result,  utilities are  acquiring  energy
                                efficiency in amounts well in excess of those that would be
                                procured  with the SBC  alone.  Further, the utilities are
                                integrating  efficiency into their  resource plans and using
                                efficiency to solve resource problems.

                                Clarifying  the primary  regulatory  status  of  efficiency
                                makes  it clear  that sympathetic  regulation  and cost
                                recovery policies are important.  California has adopted
                                decoupling of net  income and sales  for its  investor-
                                owned utilities to remove  regulatory barriers  to a full
                                financial commitment to energy efficiency.
To create a sustainable, aggressive national commitment to energy efficiency
                                                                                    2-15

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One device for implementing this policy is an energy effi-
ciency supply curve. The CEC created such a curve based
on an assessment of energy efficiency potential to provide
guidance as it reintroduced energy efficiency procurement
expectations for the utilities in 2003.  Furthermore, the
CPUC cooperated  with the CEC  to set  energy savings
targets for  each  of the California  investor-owned utilities
based on an assessment of cost-effectiveness potential.

A  different approach  to declaring energy efficiency a
resource is  to establish a portfolio or performance stan-
dard for energy efficiency.  In 2005,  Pennsylvania and
Connecticut included energy efficiency in their resource
portfolio standards. Requiring  all  retail  sellers to acquire
sufficient certificates of energy savings will allocate rev-
enue to efficiency  providers in an economically efficient
way (Pennsylvania Alternative Energy Portfolio Standards
Act  of  2004;   Connecticut   Act Concerning  Energy
Independence of 2005).

As an outcome of its electric restructuring law, Texas is
using energy efficiency as a resource to reduce demand.
Texas' spending  for energy efficiency is intended to pro-
duce savings to meet 10% of forecasted electric demand
growth. Performance is exceeding this level.

Consider Energy Efficiency As a System  Reliability
Solution
In  New  England,  Independent  System  Operator New
England (ISO-NE) faced a reliability problem  in southwest
Connecticut. A transmission line  to solve  the problem
was under  development, but would not be ready in time.
New central station generation could not  be sited in this
congested area. Because the marketplace was not provid-
ing a solution, ISO-NE issued a  Request for Proposal (RFP)
for any  resources that would address the  reliability prob-
lem and be committed for four years. One  energy efficien-
cy bid was selected—a commercial office building lighting
project worth roughly 5 megawatts (MW). Conditions of
the  award  were  very  strict  about availability of the
capacity savings. This  project  will help to  demonstrate
how energy efficiency does deliver capacity. While ISO-NE
deemed the RFP an emergency  step that it would not
undertake routinely, this process demonstrates that energy
efficiency can be important to meeting reliability goals and
can be paid for through federal jurisdictional tariffs.

Other   states, including   Indiana,  Vermont,  and
Minnesota  direct that energy efficiency be considered
as an alternative  when utilities are proposing a  power
line  project  (Indiana  Resource  Assessment,  1995;
Vermont Section 248; Minnesota Certificate of need for
large energy facility, 2005.)
Key Findings

This chapter reviews opportunities to make energy effi-
ciency an attractive business prospect by modifying elec-
tric and gas utility  regulation, and by the  way  that
utilities  collect revenue and make a  profit. Key findings
of this chapter indicate:

• There  are real financial disincentives that hinder all util-
  ities in their pursuit of energy efficiency as a resource,
  even when it  is cost-effective and would lead to a
  lower  cost energy  system. Regulation,  which is a key
  source of these disincentives,  can  be  modified to
  remove these barriers.

• Many  states have  experience in  addressing  financial
  disincentives in the following areas:

—  Overcoming the throughput incentive.

—  Providing reliable means for utilities to recover energy
    efficiency costs.

—  Providing a return on investment for efficiency programs
    that is competitive with the return utilities earn on new
    generation.

—  Addressing the risk of program costs being disallowed
    and other risks.

—  Recognizing the full value of energy efficiency to the
    utility system.
2-16   National Action Plan for Energy Efficiency

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 Recommendations and Options

The National Action Plan for Energy Efficiency Leadership
Group offers the following  recommendations as ways to
overcome many of the barriers to energy efficiency in util-
ity ratemaking and revenue requirements, and provides a
number of options for consideration by utilities, regulators,
and stakeholders (as presented in the Executive Summary):

Recommendation:  Modify  policies  to  align  utility
incentives with  the delivery of cost-effective energy
efficiency and modify ratemaking practices to  promote
energy  efficiency  investments.  Successful   energy
efficiency programs would be promoted by aligning utility
incentives in a manner  that encourages the delivery of
energy efficiency as part  of a balanced portfolio of supply,
demand, and transmission  investments. Historically, reg-
ulatory policies governing utilities have more commonly
compensated  utilities for  building infrastructure  (e.g.,
power plants, transmission lines,  pipelines) and  selling
energy, while discouraging  energy efficiency, even when
the energy-saving measures might cost less. Within the
existing  regulatory processes,  utilities, regulators, and
stakeholders have a number of opportunities to create the
incentives for energy efficiency investments  by utilities and
customers. A variety of mechanisms have already been
used.  For example, parties can decide to provide incentives
for energy efficiency similar to  utility incentives  for new
infrastructure  investments, and   provide  rewards for
prudent management of energy efficiency programs.

Options To Consider:
•Addressing the typical  utility throughput incentive and
  removing other regulatory and management disincentives
  to energy efficiency.

•Providing utility incentives for the successful manage-
  ment of energy efficiency programs.

Recommendation: Make a strong, long-term  commit-
ment to  implement cost-effective energy efficiency as
a resource. Energy efficiency programs are most successful
and provide the greatest benefits to stakeholders when
appropriate policies are  established and maintained over
the long-term. Confidence in long-term stability of the pro-
gram will help maintain energy efficiency as a dependable
resource compared to supply-side resources,  deferring or
even avoiding the need for  other infrastructure invest-
ments, and maintain customer awareness and support.
•Establishing funding requirements for delivering long-
 term, cost-effective energy efficiency.

•Designating  which organization(s)  is responsible for
 administering the energy efficiency programs.

Recommendation: Broadly communicate the benefits
of and opportunities for energy efficiency.
Experience  shows that energy efficiency programs help
customers save money and contribute to lower cost ener-
gy systems. But these benefits are not fully documented
nor recognized by customers, utilities, regulators, or policy-
makers. More effort  is needed to establish the business
case for energy efficiency for all  decision-makers and to
show how a well-designed approach to energy efficiency
can benefit customers, utilities, and society by (1) reducing
customers'  bills over time, (2) fostering financially healthy
utilities (e.g., return on equity, earnings per share, and debt
coverage ratios unaffected), and (3) contributing to posi-
tive societal net benefits overall. Effort  is also necessary to
educate key stakeholders that although energy efficiency
can be an important low-cost resource to integrate into the
energy mix, it does require funding, just as a new power
plant requires funding.

Options to  Consider:
•Establishing and educating stakeholders on the busi-
 ness case for energy efficiency at the state, utility, other
 appropriate  level   addressing  customer, utility, and
 societal perspectives.

• Communicating the role of energy efficiency in lowering
 customer  energy  bills, and system costs  and  risks
 over time.
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                                                2-17

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Recommendation: Provide sufficient, timely, and stable
program funding  to  deliver energy efficiency where
cost-effective. Energy efficiency programs require consis-
tent and long-term funding to effectively compete with
energy supply options.  Efforts are necessary to establish
this consistent long-term funding. A variety of mecha-
nisms have been, and can be used, based on state,  utility,
and other stakeholder interests. It is important to ensure
that the efficiency program providers  have sufficient
long-term funding to recover program costs, and imple-
ment  the energy  efficiency measures  that  have  been
demonstrated to be available and cost-effective. A number
of  states are now  linking program  funding to the
achievement of energy savings.
 Deciding on, and committing to, 6  consistent way for
 program administrators  to  recover energy efficiency
 costs in a timely manner.

•Establishing funding mechanisms for energy efficiency
 from among the available  options, such  as  revenue
 requirement  or resource procurement funding,  SEiCs,
 rate-basing, shared-savings,  incentive mechanisms, etc.

•Establishing funding for multi-year periods.
 2-18   National Action Plan for Energy Efficiency

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References

Barone, R.J. (2006, May 23). Presentation to the
    Rethinking Natural Gas Utility Rate Design
    Conference, Columbus, Ohio.
California Energy Commission  [CEC]. (2005, July).
    Implementing California's Loading Order for
    Electricity Resources.
California Public Utility Commission [CPUC],
    (1996, December 20). Opinion on Cost Recovery
    Plans, CPUC D.96-12-077.
California SB 1037, California Statutes of 2005.
    Chapter 366. (2005)
    .
Connecticut, An Act Concerning Energy Independence,
    Public Act No. 05-1 (House Bill No. 7501) (2005).
    .
Costello, K. (2006, April). Revenue Decoupling  for
    Natural Gas Utilities. National Regulatory Research
    Institute, .
Hansen, D.G. and Braithwait, S.D. (2005, March 31).
    A Review of Distribution Margin Normalization as
    Approved by the Oregon Public Utility Commission
    for Northwest Natural. Madison, Wisconsin:
    Christensen Associates Consulting.
Harrington, C. (2003, May).  Who Should Deliver
    Ratepayer Funded Energy Efficiency?  Regulatory
    Assistance Project, .
Indiana Resource Assessment, Indiana Administrative
    Code [IAC].  170 IAC 4-7-6, Resource assessment.
    (1995) .
Kantor, G.  (2006, June 20). Presentation to the 2006
    Western Conference of Public Service
    Commissioners, Jackson, Wyoming.
Minnesota, Certificate of need for large energy facility,
    Minnesota Statutes. Chapter 2166.243(3) (2005).
    .
Moskovitz, D. (2000). Profits and Progress Through
    Distributed Resource. Regulatory Assistance Project.
    .
Nevada, Regulation of Public Utilities Generally. Nevada
    Administrative Code 704.9523: Costs of imple-
    menting programs for conservation and demand
    management: Accounting; recovery. (2004)
    .
NERA Economic Consulting. (2006, April 20).
    Distributed Resources: Incentives.
    .
New Mexico, Efficient Use of Energy Act, New Mexico
    Statutes. Chapt. 62-17-2 and Chapt. 62-17-3
    (2005).
Pennsylvania Alternative Energy Portfolio Standards Act,
    Pennsylvania Act No. 213 (SB 1030) (2004).
    .
Plunkett, J., Horowitz, P., Slote, S. (2005). Rewarding
    Successful Efficiency Investment in Three
    Neighboring States: The Sequel, the Re-make and
    the Next Generation (In Vermont, Massachusetts
    and Connecticut) A 2004 ACEEE Summer Study on
    Energy Efficiency in Buildings.
    .
U.S. Environmental Protection Agency [EPA] (2006).
    Clean Energy-Environment Guide to Action:
    Policies, Best Practices,  and Action Steps for States
    (Section 6.2). Washington, DC.
Vermont Section 248. 30 Vermont Statutes Annotated
    ง 248, 4 (A)(b). New gas and electric purchases,
    investments, and facilities; certificate of public
    good, .
2005 Wisconsin Act 141 (2005 Senate Bill 459).
    .
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                                               2-19

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3
Energy  Resource
Planning Processes
Including energy efficiency in the resource planning process is essential to real ,>::! ig its lull  alue -md v-t
ting resource savings and funding targets accordingly.  Many utilities, states, anil  regions ^re estimating
and verifying the wide range of benefits from energy efficiency and are successfully integrating energy
efficiency into the resource planning process. This chapter of the National Action Plan for Energy Efficiency
Report discusses the barriers that obstruct incorporating energy efficiency in resource planning and pres-
ents six regional approaches to demonstrate how those barriers have been successfully overcome.
 Overview

 Planning is a core function of all utilities: large and small,
 natural gas and electric, public and private. The decisions
 made in planning  affect customer costs,  reliability of
 service,  risk management, and  the environment. Many
 stakeholders are closely involved and participate in plan-
 ning processes and related decisions. Active participants
 often include utilities,  utility regulators,  city councils,
 state  and local policy-makers,  regional organizations,
 environmental groups, and customer  groups. Regional
 planning processes organized through regional transmis-
 sion organizations (RTOs) also occur with the collabora-
 tions of utilities and regional stakeholders.

 Different planning processes are employed within each util-
 ity, state, and region. Depending  on a utility's purpose and
 context (e.g., electric or gas utility, vertically  integrated or
 restructured), different planning decisions must be made.
 Local and regional needs also affect planning and resource
 reguirements and the scope of planning processes. Further,
 the role of states and regions in planning affects decisions
 and prescribes goals for energy portfolios, such as resource
 priority, fuel diversity, and emissions reduction.

Through different  types  of planning  processes,  utilities
 analyze how to meet customer demands for energy  and
 capacity using supply-side resource procurement (includ-
 ing natural gas supply contracts and building new gener-
 ation),  transmission,   distribution,  and  demand-side
 resources  (including  energy efficiency and demand
 response). Such planning often requires iteration and test-
 ing to find the combination of resources that offer maxi-
 mum value over a range of likely future scenarios,  for the
                                             short- and long-term. The value of each of these resources
                                             is determined at the utility, local, state and regional level,
                                             based on area-specific needs and policy direction. In order
                                             to fully integrate the value of all resources into planning—
                                             including energy efficiency—resource value and benefits
                                             must  be determined early  in  the  planning process and
                                             projected over the life of the resource plan.

                                             Planning processes focus on  two general areas: (1) energy-
                                             related  planning,  such  as electricity  generation  and
                                             wholesale energy procurement; and (2) capacity-related
                                             planning, such as construction of new pipelines,  power
                                             plants, or electric transmission and distribution projects.
                                             The value of energy  efficiency can be  integrated  into
                                             resource planning decisions for both of these areas.
                                                Leadership  Group Recommendations
                                                Applicable to  Energy Resource
                                                Planning Processes
                                                • Recognize energy efficiency as a high-priority energy
                                                  resource.
                                                • Make a strong, long-term commitment to implement
                                                  cost-effective energy efficiency as a resource.
                                                • Broadly communicate the benefits of, and opportuni-
                                                  ties for, energy efficiency.
                                                • Provide sufficient, timely, and stable program funding
                                                  to deliver energy efficiency where cost-effective.
                                                A more detailed list of options specific to the objective
                                                of promoting energy efficiency in resource planning
                                                processes is provided at the end of this chapter.
To create a sustainable, aggressive national commitment to energy efficiency
                                                                                            3-1

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This chapter identifies common challenges for integrat-
ing energy efficiency into existing planning  processes
and describes examples of successful energy efficiency
planning approaches that are used in six regions of the
country.  Finally,  this  chapter  summarizes  ways  to
address  barriers,  and  offers  recommendations  and
several  options  to consider for  specific  actions  that
would facilitate incorporation of energy efficiency into
resource planning.
Challenges to Incorporating Energy
Efficiency Into Planning
The  challenges  to incorporating  energy efficiency into
resource planning have  common  themes  for  a wide
range  of utilities and  markets. This section describes
these challenges in the  context of two central questions:
A) determining the  value  of energy  efficiency  in  the
resource planning, and B) setting energy efficiency targets
and  allocating budgets, which  are guided  by resource
planning, as well as regulatory and policy decisions.

Determining the Value of Energy Efficiency
It is generally accepted  that well-designed efficiency
measures provide measurable resource savings to utili-
ties.  However, there are no standard approaches  on
how to appropriately quantify and incorporate those
benefits into utility resource planning. Also,  there are
many different types of energy efficiency programs
with different characteristics and target customers.
Energy efficiency can include  utility programs (rebates,
audits,  education, and  outreach) as well as building
efficiency codes and standards improvements for new
construction.  Each type of program has different char-
acteristics that should be considered in the valuation
process. The program information gathered in an ener-
gy efficiency potential study can be used to create an
energy efficiency supply curve, as illustrated in Figure 3-1.
Figure 3-1. Energy Efficiency Supply Curve - Potential
in 2011 (l.evelized Cost in S/kilowatt-hours [kWh] Saved)
   $1.00
   $0,90
   $0.80
   $0.70
   $0.60
                                                             $0.50
   $0.40
   $0.00
        0      10,000    20,000   30,000    40,000   50,000   60,000
                            GWh

 Source: McAuliffe, 2003
     Common Challenges to Incorporating Energy Efficiency
                      Into Planning
       A. Determining the Value of Energy Efficiency
          Energy Procurement
              Estimating energy savings
              Valuing energy savings
          Capacity & Resource Adequacy
              Estimating capacity savings
              Valuing capacity benefits
              Factors in achieving benefits
           Other Benefits
              Incorporating non-energy benefits
       B. Setting Targets and Allocating Budget
           Quantity of EE to implement
           Estimating program effectiveness
           Institutional difficulty in reallocating budget
                                                                    Cost expenditure timing vs. benefits
                                                                    Ensuring program costs are recaptured
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The  analysis commonly used to value energy efficiency
compares the costs of energy efficiency resources to the
costs of the resources that are displaced by energy effi-
ciency. The  sidebar shows the categories of benefits for
electric and gas utilities  that are commonly evaluated.
The  approach is to forecast expected future costs with
and  without energy  efficiency resources and then esti-
mate the  level of savings that energy efficiency will pro-
vide. This analysis can  be conducted  with varying levels
of sophistication depending on the metrics used to com-
pare alternative resource plans. Typically, the evaluation
is made based on the expected cost difference; however,
"portfolio"  approaches also evaluate differences in cost
variance and reliability,  which can  provide  additional
rationale for including energy efficiency as a  resource.
The  resource benefits of energy efficiency fall into two
general categories:

(1) Energy-related benefits that affect the procurement
of wholesale  electric  energy and  natural  gas,  and
delivery losses.

(2) Capacity-related benefits that affect wholesale elec-
tric  capacity purchases,  construction  of  new facilities,
and  system  reliability.
Estimating Energy Benefits
Estimating energy benefits requires established methods
for estimating the quantity of energy savings and the
benefits of these savings to the energy system.
• I-'.limiting  (jt.i.:.intity of tncniy >/i//nr/v  Savings esti-
 mates for a wide  variety of efficiency  measures have
 been well  studied  and  documented.  Approaches to
 estimate the level of free-riders  and program  partici-
 pants who would have implemented the energy effi-
 ciency on their own have been  established. Similarly,
 the expected useful lives of energy efficiency measures
 and  their persistence  are commonly  evaluated and
 included in the analysis. Detailed databases of efficiency
 measures  have  been  developed for several regions,
 including   California  and  the  Pacific  Northwest.
 However, it is often necessary to investigate and vali-
 date  the methods and assumptions  behind those esti-
 mates to  build  consensus around  measured savings
 that  all  stakeholders find  credible.  Savings estimates
 can  be verified through  measurements  and  load
 research. Best practices for measurement and verifica-
 tion (M&V) are discussed in more detail in Chapter 6:
 Energy Efficiency Program Best Practices.
The energy-related benefits of energy efficiency are rela-
tively easy to forecast.  Because  utilities are constantly
adjusting the amount of energy  purchased, short-term
deviations in the amount of  energy efficiency achieved
can  be  accommodated. The capacity-related benefits
occur when construction of a facility needed  to reliably
serve customers can be  delayed or avoided  because the
need  has already been met. Therefore, achieving capacity
benefits  requires  much  more certainty  in the  future
success of energy  efficiency  programs (particularly the
measures targeting peak loads) and  might be harder to
achieve  in  practice.  However,  the  ability to  provide
capacity  benefits  has been a focus in  California,  the
Pacific Northwest, and  other regions,  and  it should
become  easier to assess capacity savings as more pro-
grams gain experience,  and capacity savings are meas-
ured and verified. Current methods for estimating energy
benefits  and capacity benefits are presented here.
      Benefits of Energy Efficiency in Resource Planning
 Energy-related
 benefits
 Capacity-
 related
 benefits
 Other benefits
                  Electricity
purchases

Reduced line losses
                          Natural Gas
Reduced wholesale energy  Reduced wholesale natural
                   | gas purchases
                               4-
                                 Reduced losses and
                                I unaccounted for gas
             Reduced air emissions    j Reduced air emissions
                    Production and liquified
                   | natural gas facilities
Generation capacity/
resource adequacy/
regional markets        j
Operating reserves and   j Pipeline capacity
other ancillary services
                   4
             Transmission and
             distribution capacity
                   ! Local storage and pressure
     Market price reductions (consumer surplus)
              Lower portfolio risk
              Local/in-state jobs
        Low-income assistance and others
Jo create 3 sustainable, aggressive national commitment to energy efficiency
                                                   3-3

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ซ Qu.intityinu V'<)/uo' o/ tn?r<:iv S-.rvin r,  The most readily
  available benchmark for the value of energy savings is
  the prevailing price of wholesale electricity and natural
  gas. Even for a vertically integrated utility with its own
  production, energy efficiency might decrease the need
  to make market purchases; or if the utility  has excess
  energy, energy efficiency can allow the  utility to sell
  more into the market. In cases when the market prices
  are not appropriate benchmarks (because of  contract
  limitations  on  reselling  energy  or  limited   market
  access),  contract  prices or production  costs can  be
  used. In addition, the value of losses and other variable
  costs associated with energy delivery can be  quantified
  and are well known.

The challenge that remains is  in  forecasting future energy
costs beyond the period when market data are available
or contracts are in place. Long-run forecasts vary in com-
plexity from  a  simple escalation  rate  to  market-based
approaches that forecast  the  cost of new resource addi-
tions, to models  that simulate the system of existing
resources (including transmission constraints)  and evalu-
ate the marginal  cost of operating the system as new
generation is added to meet the forecasted load growth.
Most utilities have an established  approach to forecast
long-term market prices,  and  the same forecasting tech-
nique and assumptions should  be used for energy effi-
ciency as are  used  to  evaluate  supply-side  resource
options. In addition to a forecast of energy prices, some
regions include the change in market prices as a result of
energy efficiency.  Estimating these effects  requires  mod-
eling  of complex interactions  in the  energy  market.
Furthermore, reduced market prices are not necessarily a
gain from a  societal perspective, because the  gains of
consumers result in an equal loss to producers; therefore,
whether to include these savings is a policy decision.

Estimating Capacity Benefits
Estimating capacity benefits requires estimating the level
of capacity savings and the associated benefits. If energy
efficiency's capacity  benefits  are  not  considered  in the
resource plan, the utility will  overinvest in capital assets,
such as power plants and transmission and distribution,
and underinvest in energy efficiency.

> r^t,rna'.ing Capacity Sav:,-iqs  In addition to energy sav-
  ings, electric efficiency  reduces peak demand and the
  need for new investments in generation, transmission,
  and distribution  infrastructure. Natural gas  efficiency
  can  reduce the  need  for  a  new  pipeline,  storage,
  liquefied  natural gas  (LNG) facility, or other invest-
  ments necessary to maintain pressure during  high-load
  periods. Because of the storage and pressure variation
  possible in the natural gas system,  capacity-related
  costs are  not as extreme in the natural gas system as
  they are for electricity.  In both cases, estimating reduc-
  tions of peak demand is more difficult for  electricity
  than it is for natural gas, and timing  is far more critical.
  For  peak  demand savings to actually be  realized, the
  targeted end-use load reductions must occur, and the
  efficiency  measure must provide savings coincident
  with the  utility's peak demand.  Therefore, different
  energy efficiency measures that reduce load at different
  times  of day (e.g.,  commercial vs. residential lighting)
  might have different capacity values.  Area- and  time-
  specific marginal costing approaches have been devel-
  oped  to  look  at the  value of coincident peak load
  reductions, which  have  significantly  higher  value
  during critical  hours and in constrained  areas of the
  system (see sidebar on  page 3-5).

  A critical component of the resource planning process,
  whether focused on demand- or supply-side resources,
  is accurate, unbiased  load forecasting. Inaccurate load
  forecasts  either cause excessive and expensive invest-
  ment  in resources  if too aggressive,  or  create  costly
  shortages  if too low.  Similarly, tracking and  validation
  of  energy efficiency  programs are  important  for
  increasing the accuracy of estimates of their effects in
  future resource plans.

  Estimating the capacity savings to apply to load growth
  forecasts  requires estimating two key factors. The first
  is determining  the amount  of  capacity  reduced by
  energy efficiency during critical  or  peak hours. The
3-4    National Action Plan for Energy Efficiency

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  second factor is estimating the "equivalent reliability"
  of the load  reduction. This measure captures  both the
  probability that the savings will actually occur, and that
  the savings will occur during system-constrained hours.
  Applying  estimates of equivalent reliability to various
  types of resources allows comparison on an equal basis
  with traditional capacity investments. This approach is
  similar  in concept  to  the equivalent  capacity factor
  used  to compare renewable resources such  as wind
 and  solar with traditional fossil-fueled generation.  In
 markets where capacity is purchased, "counting" rules
 for different  resource types  determine the equivalent
 reliability.  The  probability that  savings  will actually
 occur during peak  periods is easier to estimate with
 some certainty for a large number of distributed  effi-
 ciency measures (e.g., air conditioners) as opposed to a
 limited number  of  large,  centralized measures (e.g.,
 water treatment plants).
                        California Avoided Costs by Time and  Location
 California is a good example of the effect of area and
 time-differentiation for  efficiency measures that  have
 dramatically  different impact  profiles.  The  average
 avoided cost for efficiency (including energy and capacity
 cost components) in  California is $71/megawatt-hour
 (MWh). Applying avoided costs for each  of six time of
 use (TOU) periods (super-peak,  mid-peak and off-peak

   Comparison of Avoided Costs for
   Three Implementation Approaches
         $140
    o
    u
    QJ
    01
    r
    ~o
    OJ
    _
    01
    OJ
         $120
         $100
      B Hourly    D TOU Average   D Annual Average
 for summer and winter seasons) increases the value of
 air conditioning to $ 104/MWh or 45 percent and low-
 ers the value of outdoor lighting to $57/MWh or 20 per-
 cent.  Refrigeration,  with its  consistent  load  profile
 throughout the day and year, is unaffected. Applying
 avoided costs by hour captures the extreme summer
peak prices and increases the value of air conditioning
savings still further to $123/MWh. Incorporating hourly
avoided costs increases the total benefits of air condi-
tioning load  reduction  by more than  $50/MWh. This
type  of  hourly analysis  is currently  being  used  in
California's  avoided  cost  proceedings for energy
efficiency.

  Greater San  Francisco Bay Area Avoided
  Distribution  Costs
  $/MW
    $42.50

    S5.00
Avoided distribution capacity costs are also estimated by
region in California. The Greater San Francisco Bay Area
region is shown above  in detail. In San Francisco and
Oakland, avoided capacity costs are low because those
areas are experiencing little load growth and have little
need for  new  distribution investment. The  Stockton
area, on  the other  hand, is experiencing high growth
and  has  significant  new distribution infrastructure
requirements.
To create a sustainable, aggressive national commitment to energy efficiency
                                                3-5

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• Valuing Capacity Benefits. The value of capacity bene-
  fits lies in the savings of not having to build or purchase
  new infrastructure, or make payments to capacity mar-
  kets for  system reliability. Because reliability  of the
  nation's energy infrastructure is critical, it is  difficult to
  make  the decision  to defer these investments without
  some  degree  of certainty that  the  savings will  be
  achieved. Disregarding or undervaluing  the transmis-
  sion and generation capacity value of energy efficiency
  can, however,  lead to underinvestment in energy effi-
  ciency. Realizing energy efficiency's capacity savings
  requires  close  coordination  between efficiency and
  resource  planners1  to ensure that specific  planned
  investments can actually be  deferred as a result of
  energy efficiency programs.  In the  long term,  lower
  load levels  will naturally  lead  to lower levels of infra-
  structure requirements without a change  in existing
  planning  processes.

Targeted implementation of energy efficiency designed
to defer or eliminate traditional reliability investments in
the short term (whether generation, transmission, or dis-
tribution) requires that energy efficiency  ramp up in time
to provide sufficient peak  load savings  before the new
infrastructure is needed. States with  existing efficiency
programs can use previous experience to estimate future
adoption rates. In states that do not have previous expe-
rience with energy efficiency, however, the adoption rate
of efficiency  measures  is difficult to estimate, making it
hard  to precisely quantify the  savings  that will  be
achieved by  a certain  date. Therefore, if the infrastruc-
ture project is critical for reliability, it is difficult to rely on
energy  as an  alternative.  The value  of  the targeted
reductions and project deferrals can also be a challenge
to  quantify  because of the  uncertainty  in  the  future
investment needs and  costs. However,  there are  exam-
ples of how to  overcome this challenge, such as the
Bonneville  Power Administration  (BPA)  transmission
planning process (described later). Vermont Docket 7081
is another collaborative process—initiated at the direc-
tion of the legislature—that is working on a new trans-
mission planning process that will explicitly  incorporate
energy efficiency (Vermont  Public Service Board, 2005).
Both BPA and Vermont Docket 7081 stress the need to
start well in advance of the need for reductions to allow
the energy efficiency program to be developed and vali-
dated. In addition, by starting early, conventional alter-
natives can serve as a back-stop if needed. Starting early
is also easier organizationally if alternatives are initiated
before project proponents  are vested in  building  new
transmission lines.

The deferral of capacity expenditures can  produce  the
same reliability level  for customers. In  cases  when  an
energy efficiency program changes the expected reliability
level (either  higher or lower),  the value  to customers
must  be  introduced as either a benefit or cost. A typical
approach is  to use the customer's Value of  Lost Load
(VOLL) as determined  through Value of  Service (VOS)
studies and  multiply by the expected change in customer
outage hours.  However, VOS studies based on customer
surveys typically show wide-ranging results and are often
difficult to substantiate.

In regions with established capacity markets, the valua-
tion process is easier because the posted  market prices
are the value of capacity.  The approach to value these
benefits  is therefore similar to the market price forecasting
approach described to value energy  benefits. Regional
planning processes can also include energy efficiency in
their  resource  planning.  Regional electricity planning
processes primarily  focus on  developing  adequate
resources to meet regional reliability criteria as  defined in
each  of  the North American Electric  Reliability  Council
(NERC) regions. Establishing capacity  and ancillary serv-
ice market  rules  that allow  energy efficiency  and
customer load response to participate can bring energy
efficiency  into the  planning  process.  For  example,
Independent System  Operator  New  England (ISO-NE)
Demand Resources Working Group  will  be including
 1 The transmission planning process requires collaboration of regional stakeholders including transmission owners, utilities, and regulators. Distribution
  planning departments of electric utilities typically make the decisions for distribution-level and local transmission facilities. Planning and development of
  high-voltage transmission facilities on the bulk-supply system is done at the independent system operator (ISO)/RTO and  Norn American Elect'ic
  Reliability Council (NERC) regional levels. At a minimum, transmission adequacy must uphold the established NERC reliability standards.
 3-6    National Action Plan for Energy Efficiency

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energy  efficiency and demand  response  as qualifying
resources  for  the  New England Forward  Capacity
Market. Another example is PJM Interconnection (PJM),
which has recently made its Economic Load Response
Program a permanent feature  of  the  PJM  markets  (in
addition to the Emergency Load Response Program that
was permanently established in 2002)  and has recently
opened its Synchronized  and Non-Synchronized Reserve
markets to demand response providers.

Other Benefits
Energy  efficiency provides several  types of  non-energy
benefits not typically  included  in traditional resource
planning. These benefits include environmental improve-
ment,  support for  low-income customers,  economic
development,  customer  satisfaction and comfort, and
other potential factors such as reduced  costs for bill col-
lection and service shut-offs,  improvements in household
safety and  health, and increased property values. As  an
economic development tool, energy efficiency attracts
and retains businesses, creates local jobs, and helps busi-
ness competitiveness and area appeal.

Environmental  benefits,   predominantly  air  emissions
reductions, might or might not have specific economic
value, depending on the region and the pollutant. The
market  price of energy will include the producer's costs
of obtaining required emission allowances (e.g., nitrogen
oxides [NOX], sulfur dioxide [S02]), and emission reduc-
tion equipment.  Emissions of carbon dioxide (C02), also
are affected by planning decisions of whether to consider
the value  of unregulated emissions.  The costs of C02
were included in California's assessment of energy effi-
ciency on the basis that these costs might become priced
in the future and the expected value of future C02 prices
should  be  considered when  making energy efficiency
investments.2 Even without regulatory  policy guidance,
several utilities incorporate the estimated future costs of
emissions  such as  C02  into their resources  planning
process to control  the  financial  risks  associated with
future  regulatory changes.3  For example,  Idaho Power
Company includes an estimated future cost of C02 emis-
sions in  its  resource planning,  and in  determining the
cost-effectiveness of efficiency programs.

Many of these benefits do not accrue directly to the utility,
raising additional policy and budgeting issues regarding
whether,  and how,  to incorporate those  benefits for
planning purposes. Municipal utilities and governmental
agencies have a stronger mandate to include  a  wider
variety of non-energy benefits in energy efficiency plan-
ning than do investor-owned utilities (lOUs). Regulators
of lOUs might also determine that these benefits should
be  considered. Many  of  the benefits  are  difficult  to
quantify. However, non-energy benefits can  also be con-
sidered qualitatively when establishing the overall ener-
gy efficiency budget, and in developing guidelines for
targeting  appropriate customers (e.g.,  low income  or
other groups).

Setting Energy Efficiency Targets and
Allocating Budget

One of the biggest barriers to energy efficiency is devel-
oping a budget to fund energy efficiency, particularly at
utilities or in  states that  haven't  had significant pro-
grams, historically. This is a not strictly  a resource plan-
ning issue, but a regulatory,  policy, and organizational
issue as well. The  two main organizational approaches
for  funding  energy efficiency are resource planning
processes, which establish the energy efficiency budget
and  targets within the planning  process,  and public
goods-funded charges, which create a separate budget
to support energy efficiency through a  rate surcharge.
There are successful examples  of both  approaches,  as
well as examples that use  both mechanisms (California,
BPA, PacifiCorp, and  Minnesota).

Setting targets for energy efficiency resource savings and
budgets  is a  collaborative process between  resource
planning staff, which evaluates cost-effectiveness, and
other key stakeholders. Arguably,  all energy efficiency
 California established a cost of $8/ton of C02 in 2004, escalating at 5% per year (CPUC, 2005).
 For further discussion, see Bokenkamp, et al., 2005.
Jo create a sustainable, aggressive national commitment to energy efficiency
                                                3-7

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measures  identified  as  cost effective in an  integrated
resource plan (IRP) should be implemented.4 In practice,
a number of other factors must be considered. For example,
the achievable level of savings  and costs, expertise and
labor, and ability to  ramp up programs also affects the
size, scope, and mix of energy efficiency programs. All of
these considerations, plus the cost-effectiveness of ener-
gy efficiency, should  be taken into account when estab-
lishing the funding levels for energy efficiency. The fund-
ing process  might also require  an iterative process that
describes the alternative plans  to regulators and other
stakeholders. Some  jurisdictions  use a policy directive
such as "all cost-effective energy  efficiency" (California)
while others allocate a fixed budget amount (New York),
specify a fixed percentage of utility revenue (Minnesota
and Oregon), or a target load reduction amount (Texas).

Implementation  of a target for electric and gas energy
savings, or Energy Efficiency Resources  Standard (EERS)
or Energy Efficiency Portfolio Standard (EEPS), such as
the Energy Efficiency Goal adopted in Texas (PUCT Subst.
R. ง25.181), is an emerging policy tool adopted or being
considered in a  number  of states (ACEEE, 2006). Some
states have adopted  standards with  flexibility for how
utilities meet such targets, such as savings by end users,
improvements  in distribution  system  efficiency,  and
market-based trading systems.

Resource Planning Process
If energy efficiency is considered as a resource, then the
appropriate amount of  energy  efficient funding will be
allocated through the utility planning process, based on
cost-effectiveness, portfolio risk,  energy and  capacity
benefits, and other criteria. Many utilities  find that a
resource plan that includes energy  efficiency yields a
lower cost portfolio,  so overall procurement costs should
decline  more than  the  increase in energy  efficiency
program costs, and the established revenue requirement
of the utility will be sufficient to  fund the entire supply
and demand-side resource portfolio.
A  resource planning process that includes energy effi-
ciency must also include a  mechanism to ensure cost-
recovery of energy efficiency spending. Most resource
planning processes are collaborative forums  to ensure
that stakeholders  understand and support the overall
plan and  its  cost  recovery mechanism. In some cases,
utility costs might have to be  shifted between  utility
functions  (e.g., generation and  transmission)  to enable
cost recovery for energy  efficiency expenditures.  For
example, transmission owners might not see energy effi-
ciency as  a non-wires solution  to transmission system
deficiencies because it is unclear to what extent energy
efficiency  costs can  be collected in the Federal Energy
Regulatory Commission  (FERC)  transmission  tariff.
Therefore,  even if energy efficiency is less costly than the
transmission upgrade, it is unclear whether the transmis-
sion upgrade budget can be shifted to energy efficiency
and still collected in rates. Another challenge for collecting
efficiency  funding in the transmission tariff is  allocation
of energy  efficiency costs  across multiple transmisson
owners,  particularly  if energy  efficiency   costs  are
incurred by a single transmission owner, while transmis-
sion costs are shared among several owners.

These examples demonstrate that in order to implement
integrated resource planning,  the regulatory agency
responsible for  determining rates must allow  rates
designed to support transmission, distribution, or other
functions  to be  used for efficiency. The transmission
companies in Connecticut have  been allowed  to include
reliability-driven energy efficiency in tariffs, although this
is noted as an emergency situation not to be repeated as
a normal course of business. These interactions between
regulatory policy and  utility resource planning demon-
strate that utilities cannot be expected to act alone in
increasing energy efficiency through  their  planning
process.

Public Purpose- or System Benefits Charge-Funded
Programs
One way to fund energy efficiency is to develop a separate
funding mechanism,  collected in rates,  to support
4 Established cost-effectiveness tests, such as the total resource cost (TRC) test, are commonly used to determine the cost-effectiveness of energy efficiency
  programs. Material from Chapter 6: Energy Efficiency Program Best Practices describes these tests in more detail.
 3-8    National Action Plan for Energy Efficiency

-------
investment in energy efficiency.  In deregulated markets
with unbundled rates, this mechanism can appear as a
separate customer charge, often referred to as a system
benefits  charge (SBC). Establishing  a  public purpose
charge has the advantage of ensuring policy-makers that
there is an allocation of funding towards energy efficiency,
and  can be necessary in deregulated markets where the
delivery company cannot  capture the savings  of energy
efficiency. This approach separates the energy efficiency
budget from  the resource planning process, however.

Developing  a  new  rate  surcharge  or  expanding an
existing surcharge also  raises  many of the  questions
addressed in  Chapter  2: Utility Ratemaking & Revenue
Reguirements. For example, are the customer segments
paying into SBCs receiving a comparable level of energy
efficiency assistance in return, or are the increases a
cross-subsidy?  Often,  industrial  customers  prefer to
implement their own efficiency rather than contribute to
a pool.  Also, if the targets are used to set shareholder
incentives,  the incentives  should be appropriate for the
aggressiveness of the program. Additionally, because the
targeted budget  allocation  in public purpose-funded
programs is often set independently of the utility's overall
resource  planning  process (and  is not frequently
changed), utilities  might not have funding  available to
procure all cost-effective savings derived from  energy
efficiency measures.  This  type of scenario  can result in
potentially  higher costs for customers than would occur
if each cost-effective efficiency opportunity were pursued.
Overcoming  Challenges: Alternative
Approaches

Successful  incorporation of energy  efficiency  into the
resource planning  process  requires  utility executives,
resource planning staff, regulators, and other stakeholders
to value energy efficiency as a resource, and to be com-
mitted to making  it work within the utility or regional
resource portfolio. To illustrate approaches to overcoming
these barriers,  we highlight several  successful energy
efficiency  programs  by California, the New York State
Energy  Research and  Development Authority (NYSER-
DA), BPA, Minnesota, Texas, and PacifiCorp. The energy
efficiency programs in these six regions demonstrate sev-
eral different ways to incorporate energy efficiency into
planning processes; in each  example, the  economics
generally work well for efficiency programs.

The primary driver of energy efficiency in planning  is the
low levelized cost of energy savings. Table 3-1 shows the
reported levelized cost of electricity and natural gas effi-
ciency from three of the regions surveyed.  The reported
utility cost  of efficiency ranges between $0.01/kilowatt-
hour  (kWh) and $0.03/kWh for Pacific  Gas  & Electric
(PG&E),  NYSERDA,  and  the  Northwest Power  and
Conservation Council  (NWPCC).  When including  both
utility program costs and customer costs,  the range is
$0.03/kWh to $0.05/kWh. The range of reported benefits
for electric energy  efficiency is  from  $0.06/kWh  to
$0.08/kWh. For  natural gas, only P&GE reported specific
natural gas efficiency measures; these show similarly low
levelized costs relative to benefits.
Table 3-1: Levelized Costs and Benefits From Four Regions
__^_

PG&E1
NYSERDA *
Electric ($/kWh) Natural Gas ($/therm)
Utility
Cost
0.03
0.01
NWPCC 3 1 0.024
Texas " 0.025
Utility &
Customer
Cost
0.05
0.03
N/A
N/A
Benefit
0.08
0.06
0.060
Utility
Cost
0.28
N/A
N/A
0.0606 N/A
Utility &
Customer
Cost
0.56
N/A
N/A
N/A
Benefit
0.81
N/A
N/A
N/A
i PG&E, 2005
2 NYSERDA, 2005
3 NWPCC, 2005
4 Calculated based on Texas Utility Avoided Cost (PUCT Substantive Rule
 ง25.18 of 2000). $0.0268/kWh for energy and $78.50/kW-year for
 capacity converted to $/kWh based on assumption of 10-year measure
 life, load factor of 26.4 percent, which is calculated from Texas' 2004
 efficiency-based reductions of 193 MW of peak demand and 448 GWh
 of energy (Frontier Associates, 2005).
s Based on 2004 spending of $87 million, 448 GWh annual. Assumed life
 of 10 years (PUCT Substantive Rule ง25.181 of 2000).
6 Based on Public Utility Commission of Texas (PUCT) Deemed Avoided
 Costs of $0.0268/kWh for energy  and $78.50/kW-year for capacity;
 448GWh and 193MW of peak load reduction.
To create a sustainable, aggressive national commitment to energy efficiency
                                                  3-9

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California
California has had a continued commitment to energy
efficiency since the late 1970s. Two major efforts are cur-
rently being coordinated in the state that address energy
use in new buildings as well as efficiency upgrades  in
existing buildings. Figure 3-2 shows the policy structure,
with the California  Energy Commission  (CEC) leading
the building  codes  and  standards process, and the
California Public  Utility Commission (CPUC) leading the
IOU and third-party  administered efficiency programs.
Jointly, the agencies publish the Energy Action Plan that
explicitly states  a goal to  integrate "all  cost-effective
energy efficiency." Recently, the CPUC approved an effi-
ciency budget of $2 billion over the next three years to
serve  a population of approximately 35 million.
                 The process for designing and  implementing  efficiency
                 programs in California by the lOUs is to develop the pro-
                 grams (either by the utility or through third-party solici-
                 tation),  evaluate  cost-effectiveness, establish  and  gain
                 approval for the program funding, and evaluate the pro-
                 gram's success through  M&V. Figure 3-2 illustrates this
                 approach.

                 Table  3-2 describes how  California addresses barriers for
                 incorporating energy efficiency  in planning for the IOU
                 process.
 Figure 3-2. California Efficiency Structure Overview
           New Construction  	
        and Appliance Standards
  Title 24 Building Standards for
  New Construction
  Establish Codes
  Set Avoided Costs
    Time-Dependent Valuation
  Set Process for Compliance

   Architects and Building Designers
   Evaluate energy standard compliance
  Qty and County Building Inspectors
  Enforce compliance
 California
   Energy
 Commission
 California
Public Utility
Commission
Energy Action Plan II
Joint Agency Plan on Specific
Actions
KEY ACTIONS:
Require that all cost-effective
energy efficiency is integrated into
utilities' resource plans as the first
option in the resource loading
order on an equal basis with
supply-side resources.
Public Purpose Fund Program
  and Procurement Funding
                  CPUC Efficiency Program
                  Approval of Plans and Budget
                  (Public Purpose)
                     $2 Billion over the next 3 years
                  Establish Savings Targets
                     MWandMWh
                  Decoupling
                  Shareholder Incentives
                     (upcoming proceeding)
                  Avoided Costs
                     Establish cost-effectiveness
                                     Investor-Owned Utilities
                                     Develop and Administer Programs
                                     Third-Party Implementer Solicitation
                                     Measurement and Verification
                                       Solicitation
                                     Regulatory Reporting
                                                                            Third-Party Program Implementers
                                                                               and M&V Contractors
Source: Energy and Environmental Economics, Inc.
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 Figure  3-3. California investor Owned Utility (SOU) Process
                                         CPUC Avoided
                                              Costs
                                                                 Resources and
                                                                Ramp-up Limits

Energy
Efficiency
Programs
t
Evaluate Program
Cost Effectiveness
t
Rank and
Estimate Potential
for Cost Effective
Portfolios

Determine Target
Funding Level
(through CPUC
process)

Implement
Approved
Programs to
Approved Levels
                                                                                                                Perform M&V
                                                                                                                 and Adjust
                                                                                                                Programs for
                                                                                                                  Next Year
Source: Energy and Environmental Economics,  Inc.
                 Table 3-2. Incorporation of Energy Efficiency in California's Investor-Owned Utilities' Planning Processes
             Barriers
                                                                   California CPUC-Administered Programs
A. Determining the Value of Energy Efficiency
Energy Procurement
Estimated energy savings
                                  Customer adoption rates are forecast into the energy efficiency plans with monthly or quarterly reporting of program
                                  success for tracking.
Valuing energy savings
                                  Energy savings are based on market prices of future electricity and natural gas, adjusted by loss factors. Emission savings
                                  ! are based on expected emission rates of marginal generating plants in each hour (electricity) or emissions for natural gas.

Capacity & Resource Adequacy
Estimating capacity savings
Valuing capacity benefits
Factors in achieving benefits
Other Benefits


Capacity savings are evaluated using the load research data for each measure.
Each capacity-related value is estimated by climate zone of the state and incorporated into an "all-in" energy value.
Transmission and distribution capacity for electricity is allocated based on weather in each climate zone, and by season
for natural gas. California's energy market (currently) includes both energy and capacity so there is no explicit capacity
value for electric generation.
Capacity benefits are based on the best forecast of achieved savings. There is no explicit link between forecasted benefits of
energy efficiency and actual capacity savings.

Incorporating non-energy benefits    J Non-energy benefits are considered in the development of the portfolio of energy efficiency, but not explicitly quantified
                                  (in the avoided cost calculation.
B. Setting Targets and Allocating Budget

                                  iCPUC has approved budget and targets for the state's efficiency programs, which are funded through both a public purpose
Quantity of energy efficiency to
implement

Estimating program effectiveness
                                  charge and procurement funding.
                                  A portion of the public purpose funds are dedicated to evaluation, measurement, and verification with the goal of
                                  improving the understanding and quantification of savings and benefit estimates.
Institutional difficulty in
reallocating budget
                                  By using public purpose funds, budget doesn't have to be reallocated from other functions for energy efficiency.
Cost expenditure timing vs. benefits
                                  Capacity benefits are based on the best forecast of achieved savings.
Ensuring the program costs are
recaptured
                                  CPUC requires that the utilities integrate energy efficiency into their long-term procurement plans to address this issue.
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Bormeville Power Administration Transmission
Planning and Regional Roundtable

In the  Northwest,  BPA  has  been leading an  industry
roundtable to work with distribution utilities,  local and
state government,  environmental  interests, and  other
stakeholders to incorporate energy efficiency and  other
distributed  energy  resources  (DER) into  transmission
planning. DER includes energy efficiency as well as  distri-
bution generation and other nonwires  solutions. Figure
3-4  illustrates the analysis  approach and data sources.
Within  BPA, the Transmission Business  Line (TBL) works
with the energy efficiency group in Power Business Line
                   <'PBL) to  develop an  integrated transmission plan. The
                   process includes significant stakeholder contributions in
                   both input  data  assumptions (led by NWPCC) anc  in
                   reviewing the overall  analysis at the roundtable.5

                   Table 3-3 describes how BPA works with stakeholders to
                   address barriers for  incorporating energy  efficiency  in
                   planning processes.
 Figure 3-4. BPA Transmission Planning Process
               lOUs and Public Utilities
                           NWPCC: Regional Planning Process
                      Load
                     forecasts
                        I
                 BPA: Transmission
                   Business Line
                   Transmission
                     Planning

                 Transmission plans
                        I
                Revise transmission
              plan as appropriate, and
               fund transmission and
                 DER investments
       Transmission
        costs and
       required DER
        load relief
Distributed resource
 analysis results
                                                                                 i
                                 Publicly vetted energy
                                    price forecasts,
                                 conservation database
      BPA PBL Efficiency Group:
     Evaluate cost-effective DER
     based on transmission plan
         and other forecasts
                       Regional Stakeholder Group: BPA Roundtable
                     Utilities, interest groups, other stakeholders discuss
                            issues and provide analysis review
                                      Group
             Data
Decision
Source: Energy and Environmental Economics, Inc.
 1 NWPCC conducts regional energy efficiency planning. More information can be found at .
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                              Table 3-3. Incorporation of Energy Efficiency in BPA's Planning Processes
                                                                  BPA-Administered Programs
 A. Determining the Value of Energy Efficiency

 Energy Procurement

 Estimated energy savings
 The process uses the NWPCC database to define the measure impact and costs. NWPCC maintains a publicly available
 regional efficiency database that is well regarded and has its own process for stakeholder collaboration. Adoption rates
 are estimated based on a range of historical program success.
 Valuing energy savings
 Energy savings are valued based on the NWPCC long-run forecast of energy value for the region, plus marginal losses.
 Capacity & Resource Adequacy

 Estimating capacity savings

 Valuing capacity benefits
 Capacity savings are based on expected NWPCC efficiency measure coincident peak impacts.

 The deferral value of transmission investments is used to evaluate the transmission capacity value, which is the focus of
' these studies. The approach is to calculate the difference in present value revenue requirement before and after the
i energy efficiency investment (Present Worth Method).
 Factors in achieving benefits
 The BPA energy efficiency and transmission planning staff work together to ensure that the revised plan with Non-
 Construction Alternatives (NCAs) satisfies reliability criteria. Ultimately the decision to defer transmission and rely on
 NCAs will be approved by transmission planning.
 Other Benefits
 Incorporating non-energy benefits     The analysis includes an evaluation of the environmental externalities, but no other non-energy benefits.
 B. Setting Targets and Allocating Budget
 Quantity of energy efficiency to
: implement

 Estimating program effectiveness
 The target for NCAs is established by the amount of load that must be reduced to defer the transmission line and maintain
 reliability. This target is driven by the load growth forecasts of the utilities in the region.
 BPA has been doing demonstrations and pilots of high-potential NCAs to refine the estimates of program penetration,
 cost, necessary timeline for achieving load reductions, customer acceptance, and other factors. The results of these pilots
 will help to refine the estimates used in planning studies.
 Institutional difficulty in
 reallocating budget
i Cost expenditure timing vs. benefits
 Ensuring the program costs are
 recaptured
 If NCAs have lower cost than transmission, transmission capital budget will be reallocated to support NCA investments
 up to the transmission deferral value. Additional costs of NCAs that are justified based on energy value are supported by
 other sources (BPA energy efficiency, local utility programs, and customers).

 Both transmission and NCAs require upfront investments so there is no significant time lag between costs and benefits.
 The transmission savings benefit is achieved concurrently with the  decision to defer the transmission investment. Energy
 benefits, on the other hand, occur over a  longer timeframe and are funded like other energy efficiency programs.
 By developing an internal planning process to reallocate budget, it is easier to ensure that the savings occur.
New York State  Energy Research and
Development Authority (NYSERDA)

In the mid-1990s, New York restructured the electric util-
ities and  moved responsibility for implementing energy
efficiency  programs  to  the  NYSERDA.  The  following
figure shows an overview of the  NYSERDA process. The
programs  are funded through  the SBC  funds (approxi-
mately $175  million per year), and NYSERDA  reports  on
the  program  impact  and  cost-effectiveness to the  New
York  State  Public   Service  Commission  (NYS   PSC)
annually.


Table 3-4 describes how NYSERDA addresses the barriers
to implementing energy efficiency.
                                    Figure 3-5. New York Efficiency Structure Overview
                                      New York State Energy
                                      Research and
                                      Development
                                      Authority (NYSEROA)
                                      Develop and implement
                                      efficiency programs
                                      (~$175 million/year)
                                      Report on program
                                      cost-effectiveness
New York State Public
Service Commission
(NYS PSQ
Review and monitor
program performance
Establish system
benefits charge (SBC)
Set demand reduction
charges
                                                 New York Distribution Utilities
                                                 (Central Hudson, Con Edison,
                                                 NYSEG, Niagara Mohawk, Orange
                                                 and Rockland, and Rochester Gas
                                                 and Electric)
                                                 Collect system benefits charge (SBC)
                                                                  Source: Energy and Environmental Economics, Inc.
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           Barriers
                          Table 3-4. Incorporation of Energy Efficiency in NYSERDA's Planning Processes
                               NYSERDA-Administered Programs
A. Determining the Value of Energy Efficiency

Energy Procurement
Estimating energy savings
 Valuing energy savings
i NYSERDA internally develops estimates of savings for individual energy efficiency programs and the portfolio in aggre-
! gate. In addition, NYSERDA accounts for free-riders and spillover effects ("net to gross" ratio) when estimating energy
I savings. Savings estimates are verified and refined with an M&V program.
 A long-run forecast of electricity demand is developed using a production simulation model, which is then calibrated to
, market prices. An estimate of reduced market prices due to decreased demand is also included as a benefit.
 Capacity & Resource Adequacy
 Estimating capacity savings
i Similar to energy savings, capacity savings are estimated for individual energy efficiency programs and the portfolio in
| aggregate. Savings estimates are verified and refined with an M&V program.
 Valuing capacity benefits
 Factors in achieving benefits
 The value of generation capacity in New York is established by examining historical auction clearing prices in the
 NYlSO's unforced capacity market. The baseline values are then escalated over time using a growth rate derived from
 NYSERDA's electric system modeling results. These capacity costs are used to value those NYSERDA programs that effec-
 tively lower system peak demand.
 The capacity value is included as the best estimate of future capacity savings by New York utilities. There is no direct
 link, however, between the forecasted savings and the actual change in utility procurement budgets.
 Other Benefits
 Incorporating non-energy benefits
 The cost-effectiveness of NYSERDA programs is estimated using four scenarios of increasing NEB levels from (1) energy
 savings benefits, (2) adding market price effects, (3) adding non-energy benefits, and (4) adding macro-economic effects
 of program spending.
 B. Setting Energy Efficiency Targets
Quantity of energy efficiency to
implement
Estimating program effectiveness
Institutional difficulty in
reallocating budget
Cost expenditure timing vs. benefits
Ensuring the program costs are
recaptured
The overall size of the NYSERDA program is determined by the aggregate funding level established by the NYS PSC.
NYSERDA, with advice from the SBC Advisory Group, recommends specific sub-program funding levels for approval by
the staff at NYS PSC.
NYSERDA prepares an annual report on program effectiveness including estimated and verified impacts and cost effec-
tiveness, which is then reviewed by the SBC Advisory Group and submitted to the NYS PSC.
By establishing a separate state research and development authority to administer energy efficiency, the institutional
problems of determining and allocating budget towards energy efficiency are eliminated. NYSERDA is supported
primarily by SBCs collected by the utilities at the direction of NYS PSC.
Similarly, by funding the programs through an SBC, the customers are directly financing the program, thereby making
the timing of benefits less important.
Forecasts of savings are based on the best estimate of future savings. There is no direct link to ensure these savings
actually occur.
Minnesota
The  Minnesota  legislature  passed  the  Conservation
Improvement Program  (CIP) in 1982. State law requires
that  (1) electric  utilities that operate  nuclear-power
plants devote at least 2 percent of their gross operating
revenue to CIP, (2) other electric utilities devote  at  least
1.5 percent of their revenue, and (3)  natural  gas utilities
devote at least 0.5 percent. Energy is supplied predomi-
nantly by two utilities:  Xcel, which provides  49  percent
of the electricity and 25 percent of the natural gas, and
CenterPoint  Energy,  which  provides  45 percent  of the
natural gas. Facilities with a  peak electrical demand of at
least 20 megawatts  (MW) are permitted  to  opt  out of
CIP and avoid paying the program's  rate  adjustment in
                                  their electric and natural gas bills (10 facilities have done
                                  so).  While  the Minnesota  Department of  Commerce
                                  oversees the CIP programs of all utilities in the state, the
                                  department only  has the  authority to order changes  in
                                  the programs of the lOUs.

                                  Utilities  are required  to file  an IRP every 2  years, using
                                  5-,  10- and 15-year planning horizons to determine the
                                  need for additional resources. The statutory  emphasis is
                                  on  demand-side  management  (DSM)  and  renewable
                                  resources. A utility  must first show why these resources
                                  will  not meet future  needs  before proposing traditional
                                  utility investments. The plans are reviewed and approved
                                  by the Minnesota Public Utilities Commission. CIP is the
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                           Table 3-5. Incorporation of Energy Efficiency in Minnesota's Planning Processes
            Barriers
 A. Determining the Value of Energy Efficiency
 Energy Procurement
 Estimating energy savings
 Valuing energy savings
 Capacity & Resource Adequacy
 Estimating capacity savings
 Valuing capacity benefits
 Factors in achieving benefits
                               Minnesota-Administered Programs
i Energy savings and avoided costs are determined independently by each utility, resulting in a wide range of estimates
; that are not consistent. Energy costs are considered a trade secret and not disclosed publicly.
 Capacity savings and avoided costs are determined independently by each utility, resulting in a wide range of estimates
I that are not consistent. Power plant, transmission, and distribution costs are considered trade secrets and are not
i disclosed publicly.
 There is no direct link between the forecasted capacity savings and the actual change in utility procurement budgets.
 Other Benefits
 Incorporating non-energy benefits
 Differences in the utilities' valuation methods produce varying estimates. In addition, the Department of Commerce
 incorporates an externality avoided cost in the electric societal cost benefit test, providing utilities with values in $/ton
 for several emissions, which the utilities translate to amounts in $/MWh based on each utility's emissions profile.
 B. Setting Targets and Allocating Budget
 Quantity of energy efficiency to
 implement
 Estimating program effectiveness
 Institutional difficulty in
 reallocating budget
 Cost expenditure timing vs. benefits
 Ensuring the program costs are
 recaptured
 The Department of Commerce approves budget and targets for each utility. Funding levels are determined by state law,
 which requires 0.5 percent to 2 percent of utility revenues be dedicated to conservation programs, depending on the
 type of utility.
 Program effectiveness is handled by each utility. Minnesota's lOUs rely on the software tools DSManager and BENCOST
 to measure electric and gas savings respectively.
 Budget is not reallocated from other functions. Funding is obtained via a surcharge on customer bills.
 By using a percentage of revenue set-aside, utility customers are directly financing the program; therefore timing of
 benefits is not critical.
 State law requires that each utility file an IRP with the Public Utilities Commission. The conservation plans approved by
 the Department of Commerce are the primary mechanism by which utilities meet conservation targets included in their
 IRPs.
primary mechanism by which the electric utilities achieve
the conservation targets included  in their IRPs.

The  Department of  Commerce   conducts  a  biennial
review of the CIP  plan for each  investor-owned  utility.
Interested parties may file comments and suggest alter-
natives before the department issues a  decision approv-
ing or modifying the  utility's  plan. Utilities that meet or
exceed  the  energy  savings  goals established by  the
Department of  Commerce  receive  a  financial  bonus,
which  they  are  permitted  to  collect  through  a  rate
increase. Both electric utilities  have exceeded their goals
for the  last several  years.  Table 3-5  describes  how  the
Minnesota Department of Commerce addresses barriers
to implementing energy efficiency.
                                  Texas
                                  Texas Senate Bill 7  (1999),  enacted in the  1999 Texas
                                  legislature,  mandates  that  at  least 10 percent  of an
                                  investor-owned electric utility's annual growth in electricity
                                  demand be met  through  energy  efficiency  programs
                                  each year. The Public Utility Commission of Texas (PUCT)
                                  Substantive Rule establishes procedures for meeting this
                                  legislative mandate,  directing the transmission  and distri-
                                  bution (T&D) utilities to hire third-party energy efficiency
                                  providers to deliver energy  efficiency  services to every
                                  customer class,  using  "deemed  savings"  estimates  for
                                  each energy efficiency measure (PUCT,  2000).  Approved
                                  program costs are included in the lOU's transmission and
                                  distribution   rates,   and  expenditures  are  reported
                                  separately in the lOU's annual energy efficiency report to
                                  the PUCT. Actual energy and capacity savings are verified
                                  by independent experts chosen  by the  PUCT.  Incentives
                                  are based on  prescribed avoided costs, which  are  set by
To create a sustainable, aggressive national commitment to energy efficiency
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                             Table 3-6. Incorporation of Energy Efficiency in Texas' Planning Processes
I            Barriers
 A. Determining the Value of Energy Efficiency
                                                               Texas-Administered Programs
 Energy Procurement
 Estimating energy savings

 Valuing energy savings
                              Energy savings are based on either deemed savings or through M&V. All savings estimates are subject to verification by
                              a commission-appointed M&V expert.
                              Avoided costs shall be the estimated cost of new gas turbine, which for energy was initially set in PUCT section 25.181-
                              5 to be $0.0268 /kWh saved annually at the customer's meter.
Capacity & Resource Adequacy
Estimating capacity savings         [ Capacity savings are based on either deemed savings or through M&V. All savings estimates are subject to verification
                              ] by a commission-appointed M&V expert.
 Valuing capacity benefits
                              Avoided costs shall be the estimated cost of new gas turbine, which for capacity was initially set in PUCT section
                              125.181 -5 to be $78.5/kW saved annually at the customer's meter.
 Other Benefits
 Incorporating non-energy benefits   I Environmental benefits of up to 20 percent above the cost effectiveness standard can be applied for projects in an a^ea
                               that is not in attainment of ambient air quality standards.
 B. Setting Energy Efficiency Targets
 Quantity of energy efficiency to
 implement
: Estimating program effectiveness
i Institutional difficulty in
I reallocating budget
 Cost expenditure timing vs. benefits
: Ensuring the program costs are
 recaptured
                              Senate Bill 7 (SB7) mandates that, beginning in 2004, at least 10 percent of an investor-owned electric utility's annual
                              growth in electricity demand be met through energy efficiency programs each year (based on historic five-year growth
                              rate for the firm). Funding for additional programs is available if deemed cost-effective.
                              Each year, the utility submits to the PUCT an energy efficiency plan for the year ahead and an energy efficiency report
                              for the past year. The plan must be approved by the commission, and the year-end report must include information
                              regarding the energy and capacity saved. Also, independent M&V experts selected by the commission to verify the
                              achieved savings as reported in each utility's report.
                              Funds required for achieving the energy efficiency goal are included in transmission and distribution rates, and energy
                              efficiency expenditures are tracked separately from other expenditures.
                              By using a percentage of revenue set aside, utility customers directly finance the program; therefore timing of benefits is ]
                              not critical.
                              The annual energy efficiency report submitted by the IOU to the PUCT includes energy and capacity savings, program
                              | expenditures, and unspent funds. There is no verification that the estimated avoided costs are captured in utility savings.
the  PUCT. El  Paso  Electric Company will  be included in
the  program beginning with an efficiency target of 5 per-
cent of growth in 2007 and  10 percent of growth in 2008.
                                                                programs were voluntarily introduced  by the Texas utili-
                                                                ties." Table 3-6 describes how Texas utilities address bar-
                                                                riers to implementing energy efficiency.
The 2004 report on  Texas'  program  accomplishments
highlights the  level  of  savings  and  success  of  the
program: "In 2004, the investor-owned utilities in Texas
achieved their statewide goals for energy efficiency once
again.  193  MW  of  peak  demand  reduction  was
achieved, which was 36% above its goal of 142 MW.  In
addition,  448   gigawatt-hours  (GWh)  of   demand
eduction was achieved. These energy savings correspond
to  a reduction of  1,460,352 pounds of  nitrogen oxide
(NOx) emissions. Incentives or  rebates were provided to
project  sponsors to offset the costs of a variety of ener-
gy efficiency improvements.  Two new  energy  efficiency
                                                                PacifiCorp

                                                                PacifiCorp is  an investor-owned utility with more  than
                                                                8,400 MW of generation capacity that serves approxi-
                                                                mately 1.6  million  retail customers in  portions of Utah,
                                                                Oregon,  Wyoming, Washington,  Idaho, and California.
                                                                PacifiCorp primarily addresses its energy efficiency plan-
                                                                ning objectives as part of its IRP process. Efficiency-based
                                                                measures are evaluated  based on their  effect on the
                                                                overall cost of PacifiCorp's preferred  resource  portfolio,
                                                                defined as the overall supply portfolio with the best bal-
                                                                ance of cost and risk.
 3-16   National Action Plan for Energy Efficiency

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Additionally, some states that are in PacifiCorp's service terri-
tory, such as Oregon and  California, also mandate that the
company  allocate  funds  for  efficiency  under  related
statewide public  goods regulations.  "In  Oregon, SB  1149
requires that investor-owned electric companies collect from
all retail customers a public  purpose charge equal to 3%  of
revenues collected from customers. Of this amount,  57%
(1.7%  of revenues) goes toward Class  2  [energy efficiency-
based] demand side management (DSM). The Energy Trust
of Oregon  (ETO) was set up to determine the  manner  in
which  public  purpose  funds  will  be  spent"(PacifiCorp,
2005). Using the IRP model to determine investment in ener-
gy efficiency, however, PacifiCorp allocates more  money  to
efficiency than required  by state statute.
                                      As of  the 2004 IRP,  PacifiCorp planned to implement a
                                      base   of  250  average  megawatts  (aMW)  of  energy
                                      efficiency, and  to seek an  additional  200 aMW of  new
                                      efficiency programs if cost-effective options could  be
                                      identified.  PacifiCorp models the  impact of energy effi-
                                      ciency  as a  shaped  load  reduction  to their  forecasted
                                      load, and computes the change in supply costs with, and
                                      without, the impact of DSM. This approach allows differ-
                                      ent types of DSM to receive different values based on the
                                      alternative   supply  costs   in  different   parts  of   the
                                      PacifiCorp service  territory.  For example,  the  IRP  plan
                                      indicates that  "residential  air conditioning decrements
                                      produce the highest value  [in the  East and West].
           Barriers
                            Table 3-7. Incorporation of Energy Efficiency in PacifiCorp's Planning Processes
                                  PacifiCorp-Administered Programs
 A. Determining the Value of Energy Efficiency
 Energy Procurement
 Estimating energy savings
! The load forecast in the IRP is reduced by the amount of energy projected to be saved by existing programs, existing
 programs that are expanded to other states, and new cost-effective programs that resulted from the 2003 DSM request
I for proposals (RFPs). These load decrements have hourly shapes based on the types of measures installed for each program.
 Valuing energy savings
\ Efficiency-based (or Class 2) DSM programs are valued based on cost effectiveness from a utility cost test perspective,
! minimizing the present value revenue requirement. The IRP (using the preferred portfolio of supply-side resources) is run
| with and without these DSM decrements, and their value in terms of cost-savings is calculated as the difference in revenue
I requirements for that portfolio with and without these Class 2 load reductions.
 Capacity & Resource Adequacy
 Estimating capacity savings
 Valuing capacity benefits


 Other Benefits
 Incorporating non-energy benefits
 PacifiCorp explicitly evaluates the capacity value of dispatchable and price-based DSM, or 'Class 1' DSM, and the ability to
 hit target reserve margins in the system with these resources. The IRP resulted in a recommendation to defer three different
| supply-side projects. The capacity benefits of more traditional energy efficiency programs are not explicitly evaluated;
I however, the planned energy efficiency reductions are used to update the load forecast in the next year's IRP, which could
i result in additional deferrals.
 Capacity savings are valued at the forecasted costs of displaced generation projects. By integrating the evaluation of DSM
 into the overall portfolio, the value of energy efficiency is directly linked to specific generation projects. It does not appear
 that PacifiCorp evaluates the potential for avoided transmission and distribution capacity.
j Non-energy benefits are considered in the selection of a preferred portfolio of resources, but the non-energy benefits of
 efficiency are not explicitly used in the IRP.
 B. Setting Energy Efficiency Targets
 Quantity of energy efficiency to
 implement
 As part of the 2004 IRP, PacifiCorp determined that a base of 250 aMW of efficiency should be included in the goals for
 the next 10 years, and that an additional 200 aMW should be added if cost-effective programs could be identified.
 Estimating program effectiveness   I Measurement methodology for new projects is not explicitly identified in the IRP, but values from existing programs and
                              I the forecasted load shapes for PacifiCorp's customers will be used to predict benefits.
 Institutional difficulty in
 reallocating budget
 Funding is integrated into the overall process of allocating budget to resource options (both supply side and demand side), and
 faces only challenges associated with any resource option, namely proof of cost-effective benefit to the resource portfolio.
Cost expenditure timing vs. benefits ! The IRP process for PacifiCorp seeks to gain the best balance of cost and risk using the present value of revenue require-
                              ments, which accounts for timing issues associated with any type of resource evaluated, including efficiency.
 Ensuring the program costs are
 recaptured
 Successive IRPs will continue to evaluate the cost-effectiveness of energy efficiency programs to determine their effect on
i overall costs of the resource portfolio.
fo create a sustainable, aggressive national commitment to energy efficiency
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Programs  with this end use impact  provide the  most
value  to  PacifiCorp's  system  because  they  reduce
demand during the highest  use hours of the year,  sum-
mer heavy load hours. The commercial lighting  and sys-
tem  load  shapes  with the highest load factors provide
the lowest  avoided costs." It does not  appear that
PacifiCorp recomputes  the  overall  risk of its portfolio
with increased energy efficiency. Table 3-7 describes how
PacifiCorp addresses barriers  to  implementing  energy
efficiency.
•Energy,  Capacity,  and Nun-Energy  Benefit  CYM
 Justify Robust Energy Efficiency  Programs.  Energy
 savings alone are usually more than sufficient to justify
 and fund a wide range of efficiency measures for elec-
 tricity and natural gas. However, the capacity and non-
 energy benefits of energy efficiency are important factors
 to consider in  assessing energy efficiency measures on
 an equal basis with traditional utility investments. In
 practice,  policy,   budget,  expertise,  and  human
 resources are the more limiting constraints to effectively
 incorporating energy efficiency into planning.
Key Findings
This  section  describes the  common  themes  in  the
approaches used to navigate and overcome the barriers
to incorporating  energy  efficiency  in the  planning
process.  While there are  many approaches  to  solving
each issue, the following key findings stand out:

• Cosf and Savings Data for Energy Efficiency Measures
  Are Readily Available. Given the long history of energy
  efficiency   programs  in  several   regions,  existing
  resources to assist in the  design and  implementation of
  energy efficiency programs are  widely available. Both
  California and the Northwest maintain extensive, pub-
  licly available online  databases  of energy  efficiency
  measures  and  impacts:  the Database for  Energy
  Efficiency Resources (DEER) in California^  and NWPCC
  Database in the Northwest.7 DEER  includes both elec-
  tricity and natural gas measures while NWPCC contains
  only electricity measures. These databases incorporate a
  number of factors affecting savings estimates, including
  climate zones, building type, building vintage, and cus-
  tomer usage patterns. Energy efficiency and resource
  planning  studies containing  detailed information on
  efficiency measures are available for regions throughout
  the United  States. It is often possible to adjust existing
  data for use in a specific utility service area with relatively
  straightforward assumptions.
   Estimating the quantity and value of energy savings
   is relatively straightforward. Well-established methods
   for  estimating  the quantity and value of energy
   savings have been used in many regions and forums.
   All of the regional  examples for estimating energy
   and capacity savings for energy  efficiency evaluate
   the savings  for an  individual  measure  using either
   measurements or engineering simulation, and  then
   aggregate these by the expected  number of cus-
   tomers who will adopt the measure.  Both  historical
   and forward market prices are readily available, par-
   ticularly for natural gas where long-term  forward
   markets are more developed.

   Estimating capacity savings is  more difficult,  but
   challenges are being  overcome. Capacity savings
   depend more heavily on regional weather conditions
   and timing  of  the peak  loads  and,  therefore, are
   difficult to estimate. Results from one region do not
   readily transfer to  another. Also, publicly  available
   market data for capacity are not as readily available
   as for energy, even though  the timing and location
   of the savings are critical.  Because potential capacity
   savings  are larger  for electricity energy efficiency
   than natural gas, capturing capacity value is a  larger
   issue for electric utilities.  Production simulation can
   explicitly evaluate the change in power plant invest-
   ment and impact of such factors as re-dispatch due
   to transmission constraints, variation in load growth,
6 The DEER Web site, description, and history can be found at: http://www.energy.ca.gov/deer/. The DEER database of measures can be found at:
 http://eega.cpuc.ca.gov/deer/.
7 The NWPCC Web site, comments, and efficiency measure definition can be found at: http://www.nwcouncil.org/comments/default.asp.
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   and other factors.  But these  models are analytically
   complex  and  planning  must  be tightly integrated
   with other utility  planning functions to accurately
   assess savings. These challenges can and have been
   overcome in  different ways in regions  with  a  long
   track-record  of  energy  efficiency  programs (e.g.,
   California, BPA, New York).

   Estimating  non-energy benefits is  an emerging
   approach in  many jurisdictions. Depending  on the
   jurisdiction, legislation  and regulatory  commission
   policies might expressly permit, and even require, the
   consideration of non-energy benefits in cost-effec-
   tiveness determinations. However, specific guidelines
   regarding the quantification  and inclusion of  non-
   energy benefits are still  under discussion or in devel-
   opment  in most jurisdictions. The consideration of
   both  non-energy  and capacity benefits of  energy
   efficiency programs is relatively new, compared to
   the long  history of valuing energy savings.

•A  Clear  Path to Funding Is Needed to Establish  a
 Budget for Energy  Efficiency  Resources. There are
 three main  approaches to funding energy efficiency
 investments:  1) utility  resource planning processes,
 2) public purpose funding, and 3) a combination of
 both. In a utility resource planning process, such as the
 BPA  non-construction alternatives  process,  efficiency
 options for meeting  BPA's objectives are compared to
 potential supply-side investments on  an  equal basis
 when allocating the available budget. In  this type of
 resource planning process, budget is allocated  to effi-
 ciency measures from each functional area according
 to the benefits  provided by efficiency programs. The
 advantage of this approach is that the budget for effi-
 ciency is linked  directly to the savings it can achieve;
 however, particularly in  the  case of  capacity-related
 benefits, which have critical timing and load reduction
 targets to maintain reliability, it  is a difficult process.
  The public purpose funding and SBC approaches in
 New York, Minnesota, and other states are an alterna-
 tive to budget reallocation within the planning process.
 In  California,  funding  from both  planning  processes
 and  public purpose funding is  used.  Public purpose
 funds do not have the same direct link to energy sav-
 ings,  so programs might not  capture  all the savings
 attributed to the program.  Funding  targets might be
 set before  available efficiency  options have  been
 explored, so if other cost-effective efficiency measures
 are later identified, additional funding  might not be
 available. This situation can result  in customer costs
 being higher than they would have been if all cost-
 effective efficiency savings opportunities had been sup-
 ported.  Using  public purpose funding significantly sim-
 plifies the planning process, however, and puts more
 control  over the  amount of energy efficiency  in  the
 control of regulators or utility boards. As compared to
 resource planning, far less time and effort are required
 on  the  part  of  regulators or  legislators  to   direct
 a  specific  amount  of   funding  to  cost-effective
 efficiency programs.

•Integrate  Energy Efficiency Early in  the  Resource
 Planning Process. In order to capture the full value of
 deferring the  need for new investments in  capacity,
 energy efficiency  must be integrated early in the plan-
 ning process. This step will avoid sunk investment asso-
 ciated with longer lead-time projects. Efficiency should
 also be planned to target  investments far enough into
 the future so that energy efficiency programs have the
 opportunity  to ramp  up  and  provide  sufficient  load
 reduction. This timeline will allow the  utility to build
 expertise and  establish a track record for energy effi-
 ciency, as well as  be able to monitor peak load  reduc-
 tions. Starting  early also allows time to gain support of
 the traditional project proponents before they are vested
 in the outcome.
To create 3 sustainable, aggressive national commitment to energy efficiency
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Recommendations and Options

The National Action Plan for Energy Efficiency Leadership
Group offers the following recommendations as ways to
overcome many of the barriers to energy  efficiency in
resource planning, and provides a number of options for
consideration for consideration by utilities, regulators and
stakeholders (as presented in the Executive Summary).

Recommendation: Recognize energy efficiency as a high
priority  energy resource. Energy efficiency has not  been
consistently viewed  as  a  meaningful  or  dependable
resource compared to new supply options, regardless of
its demonstrated  contributions to meeting load  growth.
Recognizing energy efficiency as a high-priority energy
resource is an important step in efforts to capture the
benefits it  offers, and  lower  the overall cost  of energy
services to  customers. Based on jurisdictional objectives,
energy efficiency can be incorporated into resource plans
to account for  the  long-term  benefits from  energy
savings, capacity savings, potential  reductions of air pol-
lutants and greenhouse gases, as well as other benefits.
The  explicit integration  of energy efficiency resources
into  the formalized resource planning processes that
exist at  regional,  state, and utility levels can help estab-
lish the  rationale for energy efficiency funding levels and
for properly valuing and balancing the benefits.  In some
jurisdictions,  these existing  planning  processes  might
need to be adapted or even created to meaningfully
incorporate energy  efficiency resources into  resource
planning. Some states have recognized energy efficiency
as the resource of first priority due to its broad benefits.

Options to Consider:
• Establishing  policies to establish energy efficiency as a
  priority resource.

• Integrating  energy  efficiency into utility, state, and
  regional resource planning activities.

• Quantifying  and establishing the value of energy effi-
  ciency, considering  energy savings, capacity  savings,
  and environmental benefits, as appropriate.
Recommendation: Make a strong, long-term commitment
to  implement  cost-effective  energy  efficiency as  a
resource.  Energy efficiency programs are most success-
ful  and provide the greatest  benefits to  stakeholders
when  appropriate policies are established and  main-
tained over the long-term. Confidence  in long-term sta-
bility of the program will help maintain  energy efficiency
as  a  dependable resource compared to  supply-side
resources, deferring or even avoiding the need for other
infrastructure  investments,  and  maintain customer
awareness and support.  Some  steps  might include
assessing the long-term potential for cost-effective ener-
gy efficiency  within a region (i.e., the  energy efficiency
that can  be  delivered cost-effectively  through proven
programs for each customer class within a planning hori-
zon);  examining the  role for cutting-edge initiatives and
technologies; establishing the cost of supply-side options
versus energy efficiency; establishing robust M&V proce-
dures; and providing for routine updates to information
on energy efficiency potential and key  costs.

Options to Consider:
• Establishing appropriate cost-effectiveness  tests for a
  portfolio of programs to reflect the long-term benefits
  of energy efficiency.

• Establishing the potential for  long-term, cost-effective
  energy efficiency  savings by  customer class through
  proven  programs,  innovative initiatives,  and cutting-
  edge technologies.

• Establishing funding  requirements for delivering long-
  term, cost-effective energy efficiency.

• Developing long-term energy saving goals as part of
  energy planning processes.

• Developing robust  M&V procedures.

• Designating which organization(s) is responsible for
  administering the energy efficiency programs.

• Providing for frequent updates to energy resource plans
  to accommodate new information and technology.
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Recommendation: Broadly communicate the benefits of,
and  opportunities  for, energy efficiency.  Experience
shows that energy  efficiency programs help  customers
save money and contribute to lower  cost energy  sys-
tems. But these benefits are  not  fully  documented nor
recognized by customers,  utilities, regulators, or policy-
makers. More effort is needed to establish the business
case for energy efficiency for all decision-makers and to
show how a well-designed approach to energy efficiency
can benefit customers, utilities, and society by (1) reducing
customers'  bills  over time,  (2)  fostering  financially
healthy utilities  (e.g.,  return  on  equity,  earnings  per
share, and debt coverage ratios unaffected), and (3) con-
tributing to positive societal net benefits overall. Effort is
also necessary to educate key stakeholders that although
energy efficiency can be an important low-cost resource
to integrate  into the energy mix, it does require funding
just as a new power plant requires funding.

Options to Consider:
• Establishing and educating stakeholders on the business
  case for energy efficiency at the state, utility, and other
  appropriate  level  addressing  customer, utility,  and
  societal perspectives.

• Communicating the role of energy efficiency in lowering
  customer energy  bills and system costs and risks over
  time.
Recommendation: Provide sufficient, timely, and stable
program funding to  deliver energy efficiency where
cost-effective. Energy efficiency programs require consis-
tent and long-term funding to effectively compete with
energy supply options. Efforts are necessary to establish
this consistent long-term funding. A variety of mecha-
nisms has been and can be used  based on state, utility,
and other stakeholder interests. It is important to ensure
that the efficiency  program providers have sufficient
long-term funding to  recover program  costs and imple-
ment the energy efficiency measures  that  have been
demonstrated to be available and cost-effective. A number
of states are now  linking program  funding to  the
achievement of energy savings.

Options to Consider:
• Deciding on and committing to a  consistent  way for
  program administrators  to  recover energy efficiency
  costs in a timely manner.

• Establishing funding mechanisms for  energy efficiency
  from among the available options,  such as  revenue
  requirements or resource procurement funding, SBCs,
  rate-basing, shared-savings, incentive  mechanisms, etc.

• Establishing funding for multi-year periods.
To create a sustainable, aggressive national commitment to energy efficiency
                                                3-21

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References

American Council for an Energy Efficient Economy
    [ACEEE] (2006, February). Energy Efficiency Resource
    Standards: Experience and Recommendations.
    .
Bokenkamp, K., LaFlash, H., Singh V, and Wang, D.
    (2005, July). Hedging Carbon Risk: Protecting
    Customers and Shareholders from the Financial Risk
    Associated with Carbon Dioxide Emissions. The
    Electricity Journal. 10(6): 11-24.
California Public Utilities Commission [CPUC]. (2005,
    April 7). Interim Opinion On E3 Avoided Cost
    Methodology.  Order Instituting Rulemaking to
    Promote Consistency in Methodology and Input
    Assumptions in Commission Applications of Short-
    Run and Long-run Avoided Costs, Including Pricing
    for Qualifying Facilities. Rulemaking 04-04-025
    (Filed April 22, 2004).  .
Frontier Associates (2005,  November 1). Energy
    Efficiency Accomplishments on the Texas Investor
    Owned Utilities (Calendar Year 2004).
McAluliffe, P. (2003,  June  20). Presentation to the
    California Energy Commission.
New York State Energy Research and Development
    Authority [NYSERDA] (2005, May). New York
    Energy $martSM  Program Cost-Effectiveness
    Assessment. Albany, New York.
Northwest Power and Conservation Council [NWPCC]
    (2005, May). The 5th Northwest Electric Power and
    Conservation Plan,  
Pacific Gas & Electric Company [PG&E] (2005, June).
    2006-2008 Energy Efficiency Program Portfolio,
    Volume I, Prepared Testimony.
PacifiCorp. (2005, January). 2004 Integrated Resource
    Plan. 
Public Utilities Commission of Texas [PUCT]. (2000,
    March). Substantive Rule ง25.181. Energy Efficiency
    Goal, 
Texas Senate Bill 7, Section 39.905 (1999)
    
Vermont Public Service Board (2005, July 20). Docket
    7081: Investigation into Least-Cost Integrated
    Resource Planning  for Vermont Electric Power
    Company, Inc.'s Transmission System.
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        Business  Case for
        Energy  Efficiency
A well-designed approach to energy efficiency can benefit utilities, customers, and society by (1) fostering
financially healthy utilities, (2) reducing customers' bills over time, and (3) contributing to positive societal
net benefits overall. By establishing and communicating the business case for energy efficiency across utility,
customer, and societal perspectives, cost-effective energy efficiency can be better integrated into the energy
mix as an important low-cost resource.
 Overview

Energy efficiency programs  can save  resources, lower
utility costs, and reduce customer energy bills, but  they
also can reduce utility sales. Therefore, the effect on utility
financial health must be carefully evaluated, and policies
might need to be modified  to  keep utilities financially
healthy (return on equity [ROE], earnings per share,  debt
coverage ratios  unaffected)  as  they pursue efficiency.
The extent of the potential economic and environmental
benefits from  energy efficiency,  the impact on a utility's
financial results, and the importance of modifying exist-
ing policies to  support greater investment in these energy
efficiency programs depend on a number of market  con-
ditions that can vary from one  region of  the country
to another.
To explore the potential benefits from energy efficiency
programs and the importance of modifying existing poli-
cies,  a number of business cases have been developed.
These business cases show the impact of energy efficiency
investments on the utility's financial health and earnings,
customer energy bills, and social resources such as net
 Leadership Group Recommendation
 Applicable to the Business Case for
 Energy Efficiency
  • Broadly communicate the benefits of and
   opportunities for energy efficiency.
  A more detailed list of options specific to the
  objective of promoting the business case for energy
  efficiency is provided at the end of this chapter.
Key Findings From the Eight Business
Cases Examined

• For both electric and gas utilities, energy efficien-
 cy investments consistently lower costs over time
 for both utilities  and customers while providing
 positive net benefits to society.  When enhanced
 by ratemaking policies to address utility financial
 barriers to energy efficiency, such as  decoupling
 the  utility's  revenues  from  sales  volumes,
 utility financial health  can  be maintained while
 comprehensive, cost-effective energy efficiency
 programs are implemented.

• The costs of energy efficiency and reduced sales
 volume might initially raise gas  or electricity bills
 due to slightly higher rates from  efficiency invest-
 ment and reduced sales.  However,  as the  effi-
 ciency gains help participating  customers lower
 their energy consumption, the decreased energy
 use offsets higher rates to drive their total energy
 bills down. In the eight cases examined, average
 customer bills were reduced by 2  percent to
 9 percent over a ten year period, compared to the
 no-efficiency scenario.

• Investment  in cost-effective energy efficiency
 programs yield a net benefit to society—on the
 order of hundreds  of  millions of dollars in net
 present value (NPV)  for the illustrative case studies
 (small- to medium-sized utilities).
To create a sustainable, aggressive national commitment to energy efficiency
                                           4-t

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efficiency costs and pollutant emissions. The business
cases were developed using an Energy Efficiency Benefits
Calculator (Calculator) that facilitates evaluation of the
financial impact of energy efficiency on its major stake-
holders—utilities,  customers, and society. The Calculator
allows users to examine efficiency investment scenarios
across different types of utilities using transparent input
assumptions (see Appendix  B for detailed inputs and
results).1  Policies  evaluated  with  the  Calculator  are
discussed in more detail in Chapter 2: Utility Ratemaking
&  Revenue  Requirements  and  Chapter 3:  Energy
Resource Planning Processes.

Eight  business cases  are presented  to illustrate  the
impact of comprehensive energy efficiency programs on
utilities,  their  customers, and society. The eight cases
represent a range of utility types under different growth
and   investment  situations.  Each  case  compares  the
consequences of  three scenarios—no  energy efficiency
programs without a decoupling mechanism, energy effi-
ciency without decoupling, and energy  efficiency  with
decoupling. Energy efficiency spending was assumed to
be equal to 2 percent of electricity revenue and 0.5 per-
cent of natural gas revenue across cases,  regardless of
the decoupling assumption; these assumptions  are similar
to many of the programs being  managed  in regions of
the country  today.2  In  practice,  decoupling and share-
holder incentives often lead to increased energy efficiency
investments  by  utilities,  increasing  customer  and
societal benefits.
   Business Cases Evaluated

   Cases 1 and 2: Investor-Owned Electric and
   Natural Gas Utilities
   • Case 1: Low-Growth
   • Case 2: High-Growth

   Cases 3 and 4: Electric Power Plant Deferral
   • Case 3: Low-Growth
   • Case 4: High-Growth

   Cases 5 and 6: Investor-Owned Electric
   Utility Structure
   • Case 5: Vertically Integrated Utility
   • Case 6: Restructured  Delivery-Only Utility

   Cases 7 and 8: Publicly and Cooperatively
   Owned Electric Utilities
   • Case 7: Minimum  Debt Coverage Ratio
   • Case 8: Minimum  Cash Position

   Table  4-1  provides a summary  of main assump-
   tions and results of the business cases.
Table 4-1  summarizes assumptions about the utility size,
energy efficiency program,  and each business case. All
values shown  compare  the savings with  and  without
energy efficiency over a  15-year hcrizon. The present
value  calculations  are computed  over  30  years, to
account for the  lifetime  o:F  the energy efficiency invest-
ments over 15 years.
1 The Calculator was designed to assess a wide variety of utility types using easily obtainable input data. It was not designed for applications requiring
 detailed data for specific applications such as rate setting, comparing different types of energy efficiency policies, cost-effectiveness testing, energy
 efficiency resource planning, and consumer behavior analysis.
2 See Chapter 6: Energy Efficiency Program Best Practices for more information on existing programs.
3 Cumulative and NPV business case results are calculated using a 5 percent discount rate over 30 years to include the project life term for energy effi-
 ciency investments of 15 years. All values are in nominal dollars with NPV reported in 2007 dollars (year 1 = 2007). Consistent rates are assumed in year
 0 and then adjusted by the Calculator for case-specific assumptions. Reductions in utility revenue reguirement do not change with decoupling in the
 Calculator, but might in practice if decoupling motivates the utility to deliver additional energy efficiency. In these cases, societal benefits conservative-
 ly equals only the savings from reduced wholesale electricity purchases and capital expenditures minus utility and participant costs of energy efficiency.
 Energy efficiency program costs  given in $/megawatt-hour  (MWh) for electric  utilities and  $/million  British  thermal units  (MMBtu)
 for gas utilities.
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        Table 4-1. Summary of Main Assumptions and Results for Each Business Case Analyzed3

Utility Size
Annual Revenue ($MM) - Year 0
Peak Load (MW) or Sales (BcF) - Year 0
Parameter Tested
Assumptions That Differ Between
Cases
Load Growth Assumption
Average Rate - Year 1
EE Program
Cumulative Savings (EE vs No EE case)
Utility Spending as Percent of Revenue (%)
Annual Utility Spending (NPV in SMM)
EE Project Life Term (years)
Percent of Growth Saved
Total Cost of EE in Year 0 (S/MWh or S/MMBtu)
Utility Cost in Year 0 ($/MWh or $/MMBtu)
Customer Cost in Year 0 (S/MWh or S/MMBtu)
Business Case Results
(NPV in SMM)
Reduction in Revenue Requirement (SMM)
% of Total Revenue Requirement
Net Customer Savings - no decoupling (SMM)
% of Total Customer Bills
Net Customer Savings - decoupling (SMM)
% of Total Customer Bills
Net Societal Savings (SMM)
% of Total Societal Cost
Air Emission Savings
1000 Tons C02
Tons NOX
Case 1: Case 2:
Low Low
Growth Growth
Electric Electric
Utility Utility
$284 $284
600 MW 600 MW
Load Load
Growth Growth
1% 5%
$0.12/MWh $0.12/MWh
EE Program Results do not ch
8,105GWh 8,105GWh
2.0% 2.0%
$70 $70
15 15
142% 21%
$35.00 $35.00
$20.00 $20.00
$15.00 $15.00
Revenue Requirement and Ne
Business Case results are the
$396 $318
5.5% 3.0%
$504 $372
7.0% 3.5%
$344 $266
4.8% 2.5%
$289 $258
237.5% 211.9%
Air Emission Savings are the c
311 311
61 61
Case 3: Case 4:
Low Growth Low Growth
with 2009 with 2009
Power Power
Plant Plant
$284 $284
600 MW 600 MW
Load Growth Load Growth
1% 5%
$0.12/MWh $0.12/MWh
ange when decoupling is activated
8,105GWh 8,105GWh
2.0% 2.0%
$70 $70
15 15
142% 21%
$35.00 $35.00
$20.00 $20.00
$15.00 $15.00
Societal Savings do not change with dec
difference between the No EE and EE case
$476 $338
6.0% 3.0%
$608 $375
7.7% 3.3%
$424 $286
5.4% 2.5%
$332 $269
272.6% 221.0%
ifference between No EE and EE cases anc
311 311
61 61
Case 5: Case 6:
Vertical Delivery
Utility Utility
$284 $284
600 MW 600 MW
Vertical Delivery
Utility Utility
2% 2%
$0.12/MWh $0.12/MWh
8,105GWh 8,105GWh
2.0% 2.0%
$70 $70
15 15
66% 66%
$35.00 $35.00
$20.00 $20.00
$15.00 $15.00
oupling.
s.
$372 $348
4.1% 4.4%
$447 $437
6.4% 5.6%
$320 $296
4.5% 3.8%
$282 $271
6.7% 222.2%
do not change when decouplir
311 311
61 61
Case 7: Case 8:
Electric Electric
Public/Coop Public/Coop
Debt Coverage No Debt
Ratio
$237 $237
600 MW 600 MW
Debt Coverage Cash Position
Ratio
Case 1: Case 2:
High Low Growth
Growth Gas Utility
Gas Utility
$344 $344
33 BcF 33 BcF
Load Growth Load Growth
|
2% 2% 0% 2%
$0.10/MWh $0.10/MWh $1/therm $1/therm
6,754 GWh 6,754 GWh
2.0% 2.0%
$58 $58
15 15
55% 55%
$35.00 $35.00
$20.00 $20.00
$15.00 $15.00
$288 $270
4.0% 4.3%
$459 $266
6.4% 4.2%
$245 $226
43.4% 3.6%
$225 $225
222.2% 222.2%
ig is activated
259 259
51 51
31 BcF 31 BcF
0.5% 0.5%
$21 $21 ;
15 15
410% 18%
$3.00 $3.00
$1.50 $1.50
$1.50 $1.50
$211 $142
3.8% 2.2%
$258 $156
4.6% 2.4%
$1 58 $90 j
2.8% 1 .4% ,
$143 $119
338.0% 282.6%
128 128
107 107 !
o-

T5"
a
T!
     BcF = billion  cubic feet; CC^  = carbon dioxide; EE = energy efficiency;  GWh = gigawatt-hour; NOX = nitrous oxides; $MM = million dollars;  MMBtu = million British thermal units;


     MWh = megawatt-hour; NPV = net present value

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While these eight business cases are not comprehensive,
they allow some generalizations about the likely financial
implications of energy efficiency investments. These gen-
eralizations  depend  upon the three different perspec-
tives analyzed:

•Utility Perspective. The financial health of the utility is
  modestly impacted because the introduction of energy
  efficiency reduces sales.  If energy  efficiency is accom-
  panied  with mechanisms to  protect shareholders—
  such as a decoupling mechanism to buffer revenues
  and profits  from sales volumes—the utility's financial
  situation can remain neutral to the efficiency invest-
  ments.4 This effect holds true for both public and investor-
  owned utilities.

• Customer Perspective.   Access  to energy  efficiency
  drives customer bills down over time. Across the eight
  case studies, energy bills are reduced by 2 percent to 9
  percent over a  10 to 15-year period.  Even though the
  efficiency investment and  decreased sales drives rates
  slightly higher,  this  increase is more than  offset  in
  average customer bills due to a reduction in energy usage.

• Societal Perspective. The monetary benefits from energy
  efficiency exceed costs and are supplemented by other
  benefits such as lower air emissions.

Generalizations may also be made about the  impact of
policies  to  remove the throughput incentive, such as
decoupling  mechanisms,  across  these  business  cases.5
These generalizations include:

• Utility Perspective. Policies that remove the throughput
  incentive can provide utilities with financial protection
  from changes in throughput due to energy  efficiency,
  by smoothing the utility's  financial performance while
 lowering customer bills. Generally, the business case
 results  show that a  decoupling  mechanism  benefits
 utilities more if the energy savings from efficiency are a
 greater  percent  of load growth.  Also,  because  small
 reductions in throughput have a greater effect on the
 financial condition of distribution  utilities, decoupling
 generally benefits distribution utilities more than  verti-
 cally  integrated  utilities. A utility's actual results will
 depend on the structure of its efficiency program,  as
 well as the specific decoupling and  attrition mechanisms

• Customer Perspective. Decoupling generates more fre-
 quent,  but smaller, rate  adjustments over time because
 variations  in  throughput require  periodic rate  "true-
 ups." Decoupling leads  to modestly higher rates earlier
 for customers, when  efficiency account  for a high per-
 cent  of load growth.  In all  cases,  energy efficiency
 reduces average customer bills over time, with and
 without decoupling.

•Societal Perspective.  The societal benefits of energy
 efficiency are tied to the amount of energy efficiency
 implemented. Therefore, to the extent that decoupling
 encourages investment in energy efficiency, it is a positive
 from a societal  perspective. Decoupling itself does not
 change the societal benefits of energy efficiency.

While these cases are a good starting point, each  utility
will have some unique characteristics, such as differences
in  fuel and other costs,  growth  rates,  regulatory  struc-
ture, and required capital expenditures. These and  other
inputs can be customized in the Calculator so users can
consider  the  possible  impacts of  energy efficiency  on
their unique situations. The Calculator was developed to
aid users in promoting the adoption of energy efficiency
programs, and the results  are therefore  geared  for
education and outreach  purposes.6
4 Though not modeled in these business case scenarios, incentive mechanisms can also be used to let shareholders profit from achieving efficiency goals,
  further protecting shareholders. Such incentives can increase the utility and shareholder motivations for increased energy efficiency investment.
5 The decoupling mechanism assumed by the Calculator is a "generic" balancing account that adjusts rates annually to account for reduced sales
  volumes, thereby maintaining revenue at target projections. Differences in utility incentives that alternative decoupling mechanisms provide are discussed
  in Chapter 2: Utility Ratemaking & Revenue Requirements, but are not modeled. The  decoupling mechanism does not protect the utility from
  cost variations.
6 The Calculator was designed to assess a wide variety of utility types using easily obtainable input data. It was not designed for applications requiring
  detailed data for specific applications such as rate setting, comparing different types of energy efficiency policies, cost effectiveness testing, energy effi-
  ciency resource planning, and consumer behavior analysis.
 4-4    National Action Plan for Energy Efficiency

-------
 Business Case Results

The eight cases evaluated were designed to isolate the impact
of energy efficiency investments and decoupling mechanisms
in different utility contexts (e.g., low-growth and high-growth
utilities, vertically integrated and restructured utility, or cash-
only and  debt-financed  publicly and  cooperatively owned
utilities). For each case, three energy efficiency scenarios are
evaluated  (no efficiency without decoupling, efficiency with-
out decoupling, and efficiency with decoupling), while hold-
ing all other utility conditions and assumptions constant. The
eight scenarios are  divided into four sets of two cases each
with contrasting assumptions.

An explanation of  the key results of the business cases is
provided  below, with further details provided for each
case in Appendix B.

Cases 1  and 2: Low-Growth and High-Growth
Utilities

In this first  comparison, the  results of implementing
energy efficiency  on two  investor-owned  electric  and
natural gas  distribution utilities are contrasted.  These
utilities are spending the same percent of revenue on
energy efficiency and vary only by load growth. The low-
growth electric utility (Case 1)  has a 1  percent  sales
growth rate and the  low-growth gas utility has a 0  per-
cent sales growth  rate, while the  high-growth electric
utility (Case 2) has a 5 percent sales growth rate and the
high-growth  gas utility has a 2 percent sales growth rate.
Table 4-2  compares the results for electric utilities,  and
Table 4-3  compares the results for the natural gas utili-
ties.  In both  cases (and all other cases  examined), the
Calculator assumes a 'current  year'  test year for  rate-
setting. When rate adjustments are needed, the rates are
set based  on the  costs and  sales  in that same  year.
Therefore, differences  between  forecasted and actual
growth rates do not affect the results.

Both electric and natural gas utilities show similar trends.
With low load growth, the same  level of energy efficiency
investment offsets a high percentage  of load growth,  and
utility return on equity (ROE) falls below target until the next
rate case  unless decoupling is in place.7 In  contrast, the
high-growth utility has an ROE that exceeds the target rate
of return  until the rates are decreased to account for the
increasing sales. In both cases, energy efficiency reduces the
utility return from what it would  have been absent energy
efficiency.  Generally speaking, energy efficiency investments
that account for a higher percentage of load growth expose
an electric or natural  gas utility to a greater negative finan-
cial effect  unless decoupling is in  place.

These cases also look at the difference between the two
utilities with and without a decoupling mechanism. Both
utilities earn their target ROE in rate case years, with and
without the energy efficiency in place. (Note that in prac-
tice, decoupling does not guarantee achieving the target
ROE.) For  the low-growth utility, the decoupling mecha-
nism drives a rate adjustment to  reach the target ROE,
and the utility has higher ROE than without decoupling
(Case 1).  In the  high-growth case, decoupling decreases
ROE relative to  the  case  without decoupling  (Case  2),
and prevents the  utility from earning slightly  above its
target ROE from increased sales in between rate  cases,
allowing customer rates to decline sooner  in the high-
growth electric case  if decoupling is in place.

In both electric and natural gas Case  1  and Case 2,
average customer bills decline over time. The average bill
is lower beginning in year 3 in the electric utility with  no
decoupling comparison, and in  year 5 with decoupling.
A similar  pattern  is  found for the gas utility  example.
Average  bills  decrease  more when the efficiency is a
higher percent  of  load  growth, even  though  rates
slightly increase due to  efficiency  investments and
reduced sales. The average customer bill declines more
smoothly  when  a decoupling mechanism is  used due to
more frequent rate adjustments.

For  both electricity and natural gas energy efficiency, the net
societal benefit is computed as the difference of the total
benefits of energy efficiency, less the total costs. From a soci-
etal perspective,  the benefits include the  value of reduced
expenditure on energy (including market price  reductions—
1 In Cases 1 and 2, the electric utility invests 2 percent of revenue in energy efficiency and the gas utility invests 0.5 percent of revenue.

To create a sustainable, aggressive national commitment to energy efficiency                                               4-5

-------
  Table 4-2. High- and Low-Growth Results: Electric Utility
  Case 1: Low-Growth (1%)
  Return on Equity (ROE)
  Without efficiency and decoupling, the low sales drive
  ROE below the target return. Target ROE is achieved
  with energy efficiency (EE) and decoupling. Increasing
  energy efficiency without decoupling decreases ROE.
Case 2: High-Growth (5%)
Return on Equity (ROE)
With high load growth, without decoupling, the utili-
ty achieves greater than the target ROE until rates are
adjusted. With energy efficiency, sales and earnings
are reduced, reducing ROE.
   Investor-Owned Utility Comparison of Return on Equity

                           Case 1
                          Case 2
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 lase 2: High-Growth (5%)
  Rates
  Without  energy efficiency, the  utility  sells  higher
  volumes than in the  no efficiency scenarios and has
  slightly lower rates.  Rates in the energy efficiency
  scenario increase primarily due to lower throughput;
  rates are slightly higher in the decoupling scenario due to
  increase earnings to the target ROE.
   Comparison of Average Rate
                           Case 1
 tates
   the  high-growth  case,  rates are relatively flat.
 Vithout energy  efficiency,  the  utility  sells higher
 olumes and has slightly lower rates. Decoupling does
 ot have a great impact in this case because the ROE
 ; near target levels without any rate adjustments.
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4-6    National Action Plan for Energy Efficiency

-------
if any), reduced losses, reduced capital expenditures, and
reduced air emissions (if  emissions are  monetized).8 The
costs include both utility program and administration costs
as well as the participant costs of energy efficiency. If the net
      societal benefits are positive, the energy efficiency is cost-
      effective from a  societal perspective. In both Case  1 and
      Case 2 (and all other cases evaluated using the tool), the net
      societal benefits are positive for investments  in  energy
   Table 4-2.  High- and Low-Growth Results: Electric Utility (continued)
   Case 1: Low-Growth (1%)
      Case 2: High-Growth (5%)
   Bills
   Total customer bills with energy efficiency programs
   decline over time, indicating customer savings resulting
   from  lower  energy  consumption.  Rate  increases
   through the decoupling mechanism reduce the pace
   of bill savings in the decoupling case.
    Percent Change in Customer Bills
                             Casel
       Bills
       Total customer bills with energy efficiency decline over
       time, indicating customer savings resulting from lower
       energy consumption. There is little difference between
       the decoupling and no decoupling cases in the  high-
       growth scenario.
                                 Case 2
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  Case 1: Low-Growth (1%)
  Net Societal Benefits
  Over time, the savings from energy efficiency exceed
  the annual costs. The societal cost and societal savings
  are the same, with and without decoupling.

    Delivered Costs and Benefits of EE
                           Case 1
      Case 2: High-Growth (5%)
      Net Societal Benefits
      Over time, the savings from energy efficiency exceed
      the annual costs. The societal cost and societal savings
      are the same,  with and without decoupling.
       $400

       $300

       $200

       $100

         $0-
           $400-

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           $200-

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                                Case2
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                                 Year
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                                • Societal Cost ($/MWh saved)
             Societal Savings ($/MWh saved)
• The cases discussed in this document include conservative assumptions and do not include market price reductions or monetize air emissions in net
 societal benefits.
To create a sustainable, aggressive national commitment to energy efficiency
                                                        4-7

-------
efficiency. In the low-growth case, the savings exceed costs
within two years for both the electric and natural case cases.
In the high-growth case, the savings exceed costs within five
                                                    years for the electric utility cases and four years for the nat-
                                                    ural gas utility cases. Energy efficiency has a similar effect
                                                    upon natural gas utilities,  as shown in Table 4-3.
   Table 4-3. High- and Low-Growth Results: Natural Gas Utility
   Case 1: Low-Growth (0%)
                                                    Case 2: High-Growth (2%)
Return on Equity (ROE)
Without efficiency  and decoupling, the  low sales
result in ROE falling below the target return. Similarly,
energy  efficiency without decoupling drops  utility
return below target ROE. Target ROE is achieved with
decoupling.

  Investor-Owned Utility Comparison of Return on Equity
                          Case 1
                                                       Return on Equity (ROE)
                                                       With  high  load  growth, energy  efficiency has  less
                                                       impact on total sales and earnings. Thus, the utility
                                                       achieves close to its target ROE  in the early years,
                                                       although without decoupling, ROE falls slightly in later
                                                       years as energy efficiency reduces  sales over time.
                                                                                 Case 2
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Case

1: Low-Growth (0%) Case 2: High-Growth (2%)
   Rates
   Rates increase over time because of increasing rate base
   and low sales growth. Without energy efficiency, the util-
   ity sells higher volumes and has lower rates. Decoupling
   increases rates when sales volumes are below target.
    Comparison of Average Rate
                                                     lates
                                                     A/ithout energy efficiency, the utility sells higher volumes
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 Table 4-3.  High- and Low-Growth Results: Natural Gas Utility (continued)
Case 1: Low-Growth (0%)
Customer Bills
Total customer bills with energy efficiency decline over
time, indicating customer savings resulting from lower
energy  consumption.  Customer  utility bills  initially
increase slightly with decoupling as rates are increased to
hold ROE at  the  target level and spending increases
on efficiency.

  Percent Change in Customer Bills

                          Case 1
                                                     Case 2: High-Growth (2%)
                                                     Customer Bills
                                                     Customer utility bills with energy efficiency reflect the
                                                     more limited impact of efficiency programs on rate pro-
                                                     file. Total customer bills decline over time, indicating cus-
                                                     tomer savings resulting from lower energy consumption.
                                                       CO
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                                                            -8%

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                                                                                Case 2
                                                                                56
                                                                                Year
                                                                                            8    9
                                                                                                    10
               Change in Customer Bills (%) - EE no Decoupling
                                                         • Change in Customer Bills (%) - EE and Decoupling
 Case 1: Low-Growth (0%)
 Net Societal Benefits
 Over time, the savings from energy efficiency exceed
 the annual costs. The societal cost and societal savings
 are the same, with and without decoupling.
                                                     Case 2: High-Growth (2%)
                                                     Net Societal Benefits
                                                     Over time, the savings from energy efficiency exceed
                                                     the annual costs. The societal cost and societal savings
                                                     are the same, with and without decoupling.
  Delivered Costs and Benefits of EE
                         Case 1
      $0
                                                                               Case 2
                                                                                Year
                             • Societal Cost ($/therm saved)
                                                           Societal Savings ($/therm saved)
create a sustainable, aggressive national commitment to energy efficiency
                                                                                                     4-9

-------
Cases 3 and 4: Electric Power Plant Deferral

This case study examines an electric investor-owned utility
with a large capital project (modeled here as a 500-MW
combined-cycle  power plant, although the conclusions
are similar for other large capital projects),  planned for
construction in 2009.9  Again the effect of a  1 percent
growth  rate (Case 3) is compared with  a 5 percent
growth  rate (Case 4) with  identical  energy  efficiency
investments of 2 percent of electric utility revenues.

Figure 4-1 shows the capital expenditure for the project
with and without an aggressive energy efficiency plan
and a summary of the net benefits from each perspec-
tive. The length of investment deferral is based on the
percent of peak load reduced due to energy  efficiency
investments. The vertical axis shows how the  expendi-
ture in nominal dollars starts at  $500 million in  2009, or
slightly higher (due to inflation) after deferral. With Case
3,  energy efficiency investments account for  a  higher
percentage of peak load growth, and can defer the proj-
ect until 2013. With higher growth and the same level of
efficiency savings  (Case 4), the  same efficiency  invest-
ment only defers the project until 2010.

In  Case  3,  the  energy efficiency  program  causes  a
greater  reduction  in  revenue requirement—a 30-year
reduction of $476  million rather than a Case 4 reduction
of $338 million—providing benefits  from a  customer
perspective. From a societal perspective, the low-growth
case energy efficiency program yields higher net societal
benefit as well: $332 million versus $269 million.
   Figure 4-1. Comparison of Deferral Length with Low- and High-Growth
  Case 3: Low-Growth Investment Timing

   Comparison of Investment Timing - Electric Utility
                       Case3
 Case 4: High-Growth Investment Timing
                          Case 4
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Year Year
• Without Energy Efficiency o With Energy Efficiency
  30-year savings impact from EE
       Low-Growth Utility High-Growth Utility
  Decrease in Revenue Requirement (net present value [NPV], m
  Net Customer Savings - decoupling (NPV, $MM)
  Net Societal Benefit (NPV, $MM)
 Ilion dollars [$MM])
$476
$319
$332
$338
$275
$269
9 This illustration demonstrates how energy efficiency can be used, including efforts to reduce peak capacity requirements, to defer a single 500 MW
 combined cycle power plant. Energy efficiency can also be used to defer other, smaller investments.
4-10  National Action Plan for Energy Efficiency

-------
Table 4-4 compares the reduction in revenue requirement
due to the deferral of the power plant investment between
the two cases. In Case 3, the reduction in revenue require-
ment  due to the deferral to 2013 results in present value
savings of $36 million over the three years that the plant
was deferred. In Case 4, the deferral provides present value
savings of $11 million for the one-year deferral.

Although the project is deferred longer  in  the low-
growth case, fewer sales overall and higher installed cap-
ital costs result in higher rates over time relative  to the
                 high-growth case.  In both  cases, the increase  in rates
                 from energy efficiency  programs, starting in year  1, is
                 significantly less than the rate increase that occurs after
                 the new power  plant  investment  is made, leading  to
                 lower customer bills. Customer bill savings are greatest
                 during the years that the plant is deferred.10

                 Cases 5 and  6: Vertically Integrated Utility vs.
                 Restructured Delivery Company
                 In  this example,  a  vertically integrated  electric  utility
                 (Case 5) is compared with the restructured electric delivery
   Table 4-4. Power Plant Deferral Results
   Case 3: Low-Growth (1 %)
   Revenue Requirement
   2009 project deferred to 2013, resulting in a reduc-
   tion in  revenue  requirement due to deferring the
   power plant over three years of PV$36 million.
                 Case 4: High-Growth (5%)
                 Revenue Requirement
                 2009 project deferred to 2010, resulting in a reduc-
                 tion in revenue requirement from deferring the power
                 plant over a year of PV$11 million.
  Other Capital Expenditures
  The low-growth case leads to the savings of other cap-
  ital expenditures compared to the high-growth case.

  Retail Rates
  With  low  load growth, a given amount  of  energy
  efficiency  defers  so much  load growth  that  the
  new   power  plant  can  be  deferred   for  three
  years, allowing the utility to conserve capital and post-
  pone rate increases for several years.

    Comparison of Average Rate
                             Case3
                 Other Capital Expenditures
                 The low-growth case leads to the savings of other cap-
                 ital expenditures compared to the high-growth case.

                 Retail Rates
                 With high load growth, energy efficiency reduces load
                 growth enough to defer the new power plant invest-
                 ment by one year, slowing  implementation of a rela-
                 tively smaller rate increase.
                                                             $0.30
                                           Case 4
                                                                      234567
        - - Utility Average Rate - No EE
Utility Average Rate - EE no Decoupling
Utility Average Rate - EE and Decoupling
10 The Calculator assumes that a rate case occurs in the year following a large capital investment. When a decoupling mechanism is used, a higher rate
  adjustment (and immediate decrease in bill savings) occurs once a new major infrastructure investment is brought online. This charge is due to the new
  level of capital expenditures at the same time a positive decoupling rate adjustment is making up for previous deficiencies.
To create a sustainable, aggressive national commitment to energy efficiency
                                                                 4-11

-------
company (Case 6); both experiencing a 2 percent growth
rate and investing 2  percent of revenue in energy effi-
ciency. These cases assume that the vertically integrated
utility has more capital assets and larger annual capital
                                                expenditures   than  a  restructured   delivery   ut.lity.
                                                In  general,  the financial impact of  energy  efficiency on
                                                delivery utilities is more pronounced than on vertically
                                                integrated utilities with the same number of customers and
   Table 4-4.  Power Plant Deferral Results (continued)
  Case 3: Low-Growth (1%)
                                                Case 4: High-Growth (5%)
  Customer Bills
  Although rates rise with large capital expenditures, bills
  continue to fall over time as energy efficiency drives
  customer volume down to offset the higher rates.

    Percent Change in Customer Bills
                            Case3
                                                Customer Bills
                                                Although rates rise with large capital expenditures, bills
                                                continue  to fall over time as energy efficiency drives
                                                customer volume down to offset the higher rates.
                                                                        Case 4
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                 Change in Customer Bills (%) - EE no Decoupling
                                                    • Change in Customer Bills (%) - EE and Decoupling
   Case 3: Low-Growth (1%)
                                                Case 4: High-Growth (5%)
   Load Impact
   Energy  efficiency  significantly reduces  load  growth
   and reduces the need for new capital investment.
    Comparison of Peak Load Growth

                             Case3
                                                Load Impact
                                                With  high growth, energy  efficiency has  a  limited
                                                impact on peak load, and defers a modest amount of
                                                rew capital investment.
   160%-

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                                                              160%-
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                                                           ^  130%
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                                                           ฐ~  90%
                                                                          Case 4
                             5   6
                              Year
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                                                                      2    3
                                                                           5   6
                                                                           Year
                                                                                                   10
                           Forecasted Growth - EE and Decoupling
                                                               Forecasted Growth - No EE
4-12  National Action Plan for Energy Efficiency

-------
sales.  Once   divested  of  a  generation  plant,  the
distribution utility is a smaller company (in  terms of total
rate base and capitalization), and fluctuations in through-
put and earnings have a relatively larger impact on return.
                                                      Table 4-5 summarizes the comparison of ROE, rates, bills
                                                      and societal benefits. Without implementing energy effi-
                                                      ciency,  both  utilities are  relatively  financially  healthy,
                                                      achieving near their target rate of return in each year;
   Table 4-5. Vertically Integrated and Delivery Company Results
  Case 5: Vertically Integrated
                                                     Case 6: Delivery Utility
Return on  Equity (ROE)
Because the vertically integrated utility has a large rate
base, the impact of energy efficiency upon total earnings
is limited and it has little impact upon ROE (with or with-
out decoupling).

 Investor-Owned Utility Comparison of Return on Equity

                           CaseS
                                                        Return on Equity (ROE)
                                                        With a smaller rate base and revenues only from kWh
                                                        deliveries, energy efficiency has a larger impact on a
                                                        ROE without decoupling than a vertically integrated utility.
                                                                                  Case 6

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                                                                                                     4-13

-------
  Table 4-5. Vertically Integrated and Delivery Company Results (continued)
  Case 5: Vertically Integrated
  Bills
  Total customer bills with energy efficiency programs
  decline over time, indicating average customer savings
  resulting from lower energy consumption. Customer
  utility bills  decrease more smoothly with decoupling
  as a result of the more frequent rate adjustments.

    Percent Change in Customer Bills
                             CaseS
Case 6: Delivery Utility
Bills
Total customer bills  with  energy efficiency programs
decline over time, indicating average customer savings
resulting from lower energy consumption. Customer util-
ity bills decrease more slowly  in the decoupling case,
because rates are increased earlier to offset reduced sales.
                          Case 6
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                 Change in Customer Bills (%) - EE no Decoupling
    • Change in Customer Bills (%) - EE and Decoupling
  Case 5: Vertically Integrated
  Net Societal Benefits
  Over time, the savings from energy efficiency exceed
  the annual costs. The societal cost and societal savings
  are the same, with and without decoupling.
    Delivered Costs and Benefits of EE
                             Case 5
       $400
       $200
       $100
         $0
                  \
            1    2    3    4   5    6    7   8   9   10
                              Year
  sse 6: Delivery Utility
  et Societal Benefits
   with  the vertically integrated utility,  savings from
 nergy efficiency exceed  the costs over time. The
 istribution utility has a lower initial societal savings
 Because the distribution company  reduces fewer
<}apital  expenditures at  the outset  of the energy
efficiency investments. Over time, the societal costs
 nd savings are similar to the distribution company.
     $400
                           Case 6
                                                             $300
     $100
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                           Year
                              - Societal Cost ($/MWh saved)
      Societal Savings ($/MWh saved)
4-14  National Action Plan for Energy Efficiency

-------
however, introducing energy efficiency reduces ROE and
earnings for  both utilities unless a decoupling mecha-
nism  is  put  in  place.  Customer rates increases, bill
savings, and  societal benefits follow similar trends with
energy efficiency, as discussed in Cases 1 and 2.

Cases 7 and 8: Publicly and Cooperatively
Owned Electric Utilities
The first six cases used an investor-owned electric utility
to illustrate the business case for energy efficiency. The
Calculator also can  evaluate  the impact  of efficiency
programs on publicly and cooperatively owned electric
utilities.  Many of the  issues related  to  the  impact of
growth  rates and capital  deferral  discussed  in  the
investor-owned  utility examples apply  equally  to publicly
and  cooperatively owned utilities. From a net societal
benefit  perspective, the results  are identical for publicly,
cooperatively, and privately owned utilities. The ratemaking
and utility financing perspectives are different, however.
                                               The financial position of publicly owned utilities is evalu-
                                               ated primarily based  on  either the debt coverage ratio
                                               (which is critical to maintaining a high bond rating and
                                               low  cost  capital)  or the minimum cash  position (for
                                               utilities with no debt). Table 4-6 shows the results of a
                                               publicly or cooperatively owned  utility with an energy
                                               efficiency  program of 2 percent of revenue and load
                                               growth  of 2 percent. In  both cases, the assumption is
                                               made that the utility adjusts  rates whenever the debt
                                               coverage  ratio  or  minimum cash position falls below a
                                               threshold. This assumption  makes comparisons of differ-
                                               ent cases  more difficult, but the trends are similar to the
                                               investor-owned utilities on  a regular rate case cycle. The
                                               change in utility financial  health due to energy efficiency
                                               is relatively  modest because of the ability to adjust the
                                               retail rates to maintain financial health. The publicly and
                                               cooperatively owned utilities will  experience  similar
                                               financial health problems as investor-owned utilities if they
                                               do not adjust rates.
   Table 4-6. Publicly and Cooperatively Owned  Utility Results
   Case 7: Minimum Debt Coverage Ratio
   Utility Financial Health
   A decoupling mechanism stabilizes the utility's ability
   to  cover  debt  by adjusting  rates for variations in
   throughput.  Without decoupling, rates are adjusted
   whenever the debt coverage rate falls below a threshold
   (ratio  2 in  the example). The  rate  adjustment  is
   required earlier  in the energy efficiency scenario.
     Public Power/Cooperative Debt Coverage Ratio
                             Case?
                                               Case 8: Minimum Cash Position
     O)
     Ol
     rp
     CD
     ง
     u
     4-1
     _Q
     OJ
     O
        2.50
        2.00
1.50
         1.00
                                               Utility Financial Health
                                               In the  no decoupling cases (with and without energy
                                               efficiency), rates  are reset if the  cash  position falls
                                               below  a  minimum  threshold  ($70  million  in this
                                               example). With decoupling, the utility adjusts rates to
                                               hit the target cash level in each year. The results are
                                               similar as long as there is an ability to reset rates when
                                               needed to maintain a minimum cash position.
                                                 Cash Position at End of Year
                                                                         CaseS
                                                  ro
                                                  U
            >
            M—
            O
                                                              $70
                                                      $50
                                                      $40
        234567
                      Year
9   10
                                                                                  5   6
                                                                                  Year
                                                                                                    10
               • Debt Coverage Ratio - No EE
                Debt Coverage Ratio - EE no Decoupling
               • Debt Coverage Ratio - EE and Decoupling
                                                            Cash Position - No EE
                                                            Cash Position - EE no Decoupling
                                                            Cash Position - EE and Decoupling
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                                                                                               4-15

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   Table 4-6. Publicly and Cooperatively Owned Utility Results (continued)
  Case 7: Minimum Debt Coverage Ratio
  Customer Rates
  With or without decoupling,  rates are adjusted to
  maintain financial  health. Rates are lowest without
  energy efficiency and highest with  energy  efficiency
  and decoupling.

   Comparison of Average Rate
                            Case?
                 Case 8: Minimum Cash Position
                 Customer Rates
                 Once energy efficiency is implemented, retail rate levels
                 are similar, with or without decoupling in place. The
                 decoupling case is slightly  smoother  with  smaller,
                 more frequent rate adjustments.
                                          Cases
                                                            0.25
                                                            0.20
                                                            0.15
                                                            '.10 -F-
                                                                                5   6
                                                                                 Year
                                                               10
     -  - - Utility Average Rate - No EE
Utility Average Rate - EE no Decoupling
Utility Average Rate - EE and Decoupling
  Case 7: Minimum Debt Coverage Ratio
  Customer Bills
  Average customer bills decline with energy efficiency
  investments, with  and without  decoupling. The
  'randomness' in the bill change is due to different tim-
  ing of rate adjustments in the energy efficiency and
  no energy efficiency cases. However, overall the trend
  is downward.

    Percent Change in Customer Bills
                            Case 7
                 Case 8: Minimum Cash Position
                 Customer Bills
                 Average customer bills decline with energy efficiency
                 investments in both the decoupling and no decoupling
                 cases.
                                           CaseS
         -9%
        -12%
        -15%
        -18%
        -21%
                                                       CO
                                                       c
                            5   6
                             Year
           10
                      -12%
                      -15%
                      -18%
                      -21%
                Change in Customer Bills (%) - EE no Decoupling
                    • Change in Customer Bills (%) - EE and Decoupling
4-16  National Action Plan for Energy Efficiency

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Key Findings
Recommendations and Options
This chapter summarizes eight business cases for energy
efficiency  resulting from the Energy  Efficiency Benefits
Calculator. This  Calculator provides  simplified results
from a utility, customer, and societal perspective. As stated
on page  4-1, the key findings from the  eight cases
examined  include:

• For  both electric and gas utilities,  energy efficiency
  investments consistently lower costs over time for both
  utilities  and  customers,  while providing  positive
  net benefits to society. When enhanced by ratemaking
  policies  to  address  utility  financial  barriers  to
  energy  efficiency,  such  as  decoupling  the  utility's
  revenues from sales volumes, utility financial health can
  be  maintained  while comprehensive,  cost-effective
  energy efficiency programs are implemented.

•The costs  of energy efficiency and  reduced  sales
  volume might initially raise gas or electricity bills due to
  slightly higher  rates from  efficiency investment  and
  reduced  sales. However,  as the efficiency  gains help
  participating customers lower their energy consump-
  tion, the decreased energy use offsets higher rates to
  drive their total energy bills down. In the 8 cases exam-
  ined, average customer bills were reduced by 2 percent
  to 9 percent over a ten year period, compared to the
  no-efficiency scenario.

• Investment in cost-effective energy efficiency programs
  yields  a  net  benefit  to  society—on  the order of
  hundreds of millions of dollars in NPV for the illustrative
  case studies (small- to medium-sized utilities).
The National Action Plan for Energy Efficiency Leadership
Group offers the following recommendation as a way to
overcome many of the barriers to energy efficiency, and
provides the following options for consideration by utili-
ties,  regulators, and stakeholders (as presented  in  the
Executive Summary).

Recommendation: Broadly communicate  the  bene-
fits  of, and opportunities for,  energy  efficiency.
Experience shows that energy efficiency programs help
customers  save  money and  contribute to  lower cost
energy systems.  But these  impacts are not  fully docu-
mented nor recognized by customers, utilities, regulators
and policy-makers. More effort is needed to establish  the
business case for energy efficiency for  all decision-makers
and  to show how a well-designed approach to energy
efficiency can benefit customers, utilities, and society by
(1)  reducing  customers  bills over time, (2) fostering
financially healthy utilities (return on equity [ROE], earn-
ings  per share, debt coverage ratios unaffected), and (3)
contributing to  positive  societal net benefits overall.
Effort is also necessary to educate key stakeholders that,
although energy efficiency can be an important low-cost
resource to integrate into the energy mix, it does require
funding, just as a  new power plant requires funding.

Options to (onsidt r
• Establishing and educating stakeholders on the busi-
  ness case for energy efficiency at the state,  utility, and
  other appropriate level  addressing relevant customer,
  utility, and societal perspectives.

• Communicating the role of energy efficiency  in lowering
  customer energy  bills  and system costs  and risks
  over time.
                                                       Reference

                                                       National Action Plan for Energy Efficiency. (2006).
                                                          Energy Efficiency Benefits Calculator.
                                                          
To crc'ittp a sustainable, aggressive national commitment to energy efficiency
                                               4-17

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5
Rate  Design
 Retail electricity and natural gas utility rate structures and price levels influence customer consumption,
 and thus  are an important tool for encouraging the adoption of energy-efficient  technologies and
 practices. The rate design process typically involves balancing multiple objectives, among which energy
 efficiency  is often overlooked. Successful rate designs must balance the overall design goals of utilities,
 customers, regulators, and other stakeholders, including encouraging energy efficiency.
 Overview

 Retail  rate designs with clear and  meaningful price
 signals, coupled with good customer education,  can be
 powerful tools for encouraging energy efficiency. At the
 same time, rate design is a complex  process that must
 take into account multiple objectives (Bonbright, 1961;
 Philips,  1988). The  main priorities for rate design are
 recovery of utility revenue requirements and fair appor-
 tionment of costs among customers.

 Other important regulatory and legislative goals include:

 • Stable revenues for the utility.

 • Stable rates for customers.

 •Social equity in the form of lifeline rates for essential
  needs of households (PURPA of 1978).

 •Simplicity of understanding for customers and ease
  of implementation for utilities.

 • Economic efficiency to promote  cost-effective  load
  management.

 This chapter considers the additional goal of encouraging
 investment in  energy  efficiency.  While it is difficult to
 achieve every goal of rate design completely, considera-
 tion of a rate design's impact on adoption of energy effi-
 ciency and any necessary trade-offs can be included as
 part of the ratemaking process.
                                             Using  Rate Design to Pr  >mo:e Energy
                                             Efficiency
                                             In developing tariffs to encourage energy efficiency, the
                                             following questions arise: (1) What are the key rate
                                             design  issues, and how do they affect  rate designs for
                                             energy  efficiency? (2) What different rate design options
                                             are possible, and what are their pros and cons? (3) What
                                             other mechanisms can encourage efficiency that are not
                                             driven  by tariff  savings? and  (4)  What  are the most
                                             successful strategies for encouraging energy efficiency
                                             in different jurisdictions? These questions are addressed
                                             throughout this chapter.
                                                Leadership Group Recommendations
                                                Applicable to Rate Design
                                                • Modify ratemaking practices to promote energy
                                                 efficiency investments.
                                                •Broadly communicate  the benefits  of,  and
                                                 opportunities for, energy efficiency.
                                                A more detailed list of options specific to the
                                                objective of promoting energy efficiency in rate
                                                design is provided at the end of this chapter.

                                             Background: Revenues and Rates

                                             Utility rates are designed to collect a specific  revenue
                                             requirement based on natural gas or electricity sales. As
                                             rates are driven by sales and revenue requirements, these
                                             three aspects of regulation are tightly linked. (Revenue
                                             requirement issues are discussed in Chapter 2: Utility
                                             Ratemaking & Revenue Requirements.)
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                                                                                           5-1

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Until  the 1970s,  rate  structures  were  based on the
principle of  average-cost  pricing  in  which  customer
prices reflected the average costs  to utilities of serving
their customer class. Because so many of a utility's costs
were  fixed,  the  main goal of rate design up until the
1970s was to promote sales. Higher sales allowed fixed
costs  to  be spread over a larger base and helped push
rates down, keeping stakeholders content with average-
cost based  rates (Hyman et al., 2000).

This dynamic began to  change in  many jurisdictions  in
the 1970s,  with  rising oil prices and increased emphasis
on  conservation.  With the passage of the 1978  Public
Utility Regulatory Policies  Act (PURPA), declining block
rates were  replaced by flat rates or even inverted block
rates, as utilities began  to look  for ways to  defer new
plant  investment and reduce the environmental impact
of energy consumption.
Key Rate Design  Issues

Utilities  and regulators  must balance competing goals
in  designing  rates. Achieving this  balance is essential
for obtaining  regulatory  and  customer  acceptance.
The main rate design issues are described below.

Provide Recovery of Revenue  Requirements
and Stable Utility Revenues

A primary function of rates is to let utilities collect their
revenue requirements. Utilities often favor rate forms
that maximize stable revenues, such as declining block
rates. The declining block rate has two or more tiers of
usage, with the highest rates in the first tier. Tier 1  is
typically a relatively low monthly usage level that most
customers exceed. This rate gives utilities a high degree
of certainty regarding  the number of kilowatt-hours
(kWh) or therms that will be billed in Tier 1. By designing
Tier 1 rates to collect the utility's fixed  costs,  the utility
gains stability in the collection of those costs. At the
same time, the lower  Tier 2  rates encourage higher
energy  consumption rather than efficiency, which  is
detrimental to  energy efficiency impacts.1  Because
energy  efficiency measures are most likely to  change
customer usage  in Tier 2,  customers  will see  smaller
bill reductions under declining block rates than under
flat rates.  Although many utilities  have phased out
declining block rates, a number of utilities continue  to
offer them.2

Another rate  element  that provides revenue stability
but also detracts from the incentive to improve efficiency
is  collecting  a  portion of the  revenue  requirement
through a customer charge  that is  independent  of
usage. Because the majority of utility costs do not vary
with changes in customer usage level in the short run,
the customer charge also has a strong theoretical basis.
This approach has mixed  benefits for energy efficiency.
On one hand, a  larger customer charge  means a smaller
volumetric charge (per kWh or  therm), which lowers
the customer incentive for energy  efficiency.  On the
other hand, a larger customer charge  and lower volu-
metric charge reduces the utilities profit from increased
sales, reducing the utility disincentive to promote energy
efficiency.

Rate forms like  declining  block rates and  customer
charges  promote revenue stability for the utility, but
they create a  barrier to customer adoption of energy
efficiency because they reduce  the  savings  that cus-
tomers  can realize from reducing usage. In turn, elec-
tricity demand is more likely to  increase, which could
lead to long-term  higher rates  and bills where new
supply is more  costly than energy  efficiency.  To pro-
mote energy efficiency, a key challenge is to provide a
1 Brown and Sibley (1986) opine that a declining block structure can promote economic efficiency if the lowest tier rate can be set above marginal cost,
 while inducing additional consumption by some consumers. A rising marginal cost environment suggests, however, that a declining block rate structure
 with rates below the increasing marginal costs is economically inefficient.
2 A partial list of utilities with declining block residential rates includes: Dominion Virginia Power, VA; Appalachian Power Co, VA; Indianapolis Power and
 Light Co., IN; Kentucky Power Co., KY; Cleveland Electric Ilium Co., OH; Toledo Edison Co., OH; Rappahannock Electric Coop, VA; Lincoln Electric System,
 NE; Cuivre River Electric Coop Inc., MO; Otter Tail Power Co., ND; Wheeling Power Co., WV; Matanuska Electric Assn Inc., AK; Homer Electric Association
 Inc., AK; Lower Valley Energy, NE.
5-2    National Action Plan for Energy Efficiency

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level  of certainty  to  utilities for revenue collection
without dampening customer incentive to use energy
more efficiently.

Fairly Apportion Costs Among Customers

Revenue allocation is the process that determines the
share of the utility's total revenue requirement that will
be  recovered  from each customer class. In regulatory
proceedings,  this process  is often contentious, as each
customer  class seeks to pay less. This process  makes it
difficult for utilities to propose rate  designs that shift
revenues between different customer classes.


In redesigning rates to encourage energy efficiency, it is
important to avoid unnecessarily or inadvertently shifting
costs between customer classes.  Rate  design  changes
should instead focus on providing a good price signal for
customer consumption decisions.

Promote  Economic  Efficiency for Cost-
Effective Load Management

According  to economic theory, the most efficient out-
come occurs when prices are equal to marginal costs,
resulting  in the  maximum societal  net benefit  from
consumption.

Marginal Costs
Marginal costs are the  changes in costs required to pro-
duce one additional unit of energy. In a period of rising
marginal costs, rates based on marginal costs more real-
istically  reflect the cost of serving different customers,
and  provide  an  incentive for more  efficient  use  of
resources  (Bonbright,   1961;  Kahn,  1970;  Huntington,
1975; Joskow, 1976; Joskow, 1979).

A utility's marginal costs often include its costs of comply-
ing  with local, state, and federal regulations (e.g., Clean
Air Act), as well as any utility commission policies address-
ing  the environment (e.g., the use of the societal test for
benefit-cost assessments).  Rate design  based on the
utility's marginal costs that promotes cost-effective energy
efficiency will  further increase environmental protection
by reducing energy consumption.

Despite its theoretical attraction, there are significant bar-
riers to fully implementing  marginal-cost pricing in elec-
tricity,  especially at the retail level.  In contrast  to other
commodities, the necessity for generation to match  load
at all times means that outputs and production costs are
constantly changing, and conveying these  costs as real
time "price signals"  to customers,  especially residential
customers, can be complicated and  add  additional costs.
Currently, about half of the nation's electricity customers
are   served  by organized real-time  electricity  markets,
which  can help provide time-varying prices to customers
by regional or local area.

Notwithstanding  the recent price volatility, exacerbated
by the 2005 hurricane season and current market condi-
tions, wholesale  natural  gas prices  are generally more
stable  than wholesale  electricity prices,  largely because
of the ability to store natural gas.  As a  result, marginal
costs have been historically a less important issue for
natural gas pricing.

Short-Run Versus Long-Run Price Signals
There is a fundamental conflict between whether electricity
and  natural gas prices should reflect short-run or long-run
marginal costs. In simple terms, short-run costs reflect the
variable cost of  production and  delivery, while  long-run
costs also include the cost of capital expansion. For  pro-
grams  such as real-time pricing in  electricity,  short-run
marginal costs are used for the price signals so they can
induce efficient operating decisions  on a daily or hourly
basis.

Rates that reflect long-run marginal costs will promote
economically  efficient  investment  decisions in  energy
efficiency, because the  long-run perspective is consistent
with the long  expected useful lives  of most energy  effi-
ciency  measures,  and the potential for energy efficiency
to defer costly capital investments. For demand-response
and  other programs intended to  alter consumption on a
daily or hourly basis, however, rates based on short-run
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                                                 5-3

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  Applicability of  Rate Design Issues
  Implications  for Clean  Distributed Generation and
  Demand Response.  The rate  issues for energy effi-
  ciency also apply to clean distributed generation and
  demand response, with  two  exceptions.  Demand
  response is focused on reductions in usage that occur
  for only a limited number of hours in a year, and occur
  at times that are not known far in advance  (typically
  no more than one day notice, and often no more than
  a few hours notice).  Because of the limited  hours of
  operation,  the  revenue  erosion  from  demand
  response is small compared to  an  energy efficiency
  measure. In addition, it could be argued  that short-
  run,  rather than long-run, costs are the appropriate
  cost  metric to use  in valuing and  pricing  demand
  response programs.

  Public Versus Private Utilities. The rate issues are
  essentially the same  for both public and private utili-
  ties.  Revenue  stability might be a lesser concern for
  public utilities, as  they could  approach their city
  leaders for rate changes. Frequent  visits  to council
  chambers for  rate changes might be frowned upon,
  however, so revenue stability will likely remain  impor-
  tant  to many public utilities as well.
marginal cost might be more appropriate. Therefore, in
developing retail rates, the goals of short-run and long-
run marginal based pricing must be balanced.

Cost Causation
Using  long-run  marginal  costs  to design an  energy-
efficiency enhancing tariff can present another challenge
—potential inconsistency with the cost-causation princi-
ple that a tariff should reflect the utility's various costs of
serving a customer. This potential inconsistency diminishes
in the long run,  however,  because over the long run,
some costs that might be considered fixed in the near
term  (e.g.,  generation  or  transmission  capacity,  new
interstate pipeline capacity  or storage) are actually vari-
able.  Such costs can be reduced through sustained load
                                                Gas Versus Electric. As discussed above, gas marginal
                                                costs are less volatile than electricity marginal costs, so
                                                providing prices that reflect marginal costs is generally
                                                less of a concern for the gas utilities.  In addition, the
                                                nature of gas service does not lend itself to complicated
                                                rate forms such as those seen for some electricity cus-
                                                tomers.  Nevertheless,  gas utilities could  implement
                                                increasing tier block rates, and/or seasonally differen-
                                                tiated rates to stimulate energy efficiency.

                                                Restructured Versus Non-Restructured Markets.
                                                Restructuring  has had a  substantial  impact on  the
                                                funding, administration, and valuation of energy effi-
                                                ciency programs. It is no coincidence that areas with
                                                high  retail electricity  rates  have been more  apt to
                                                restructure their electricity markets. The higher rates
                                                increase the appeal of energy efficiency measures, and
                                                the entry of third-party energy service companies can
                                                increase customer interest and  education regarding
                                                energy efficiency options.  In a retail competition envi-
                                                ronment, however, there might be relatively little rate-
                                                making flexibility.  In several  states, restructuring has
                                                created transmission and distribution-only utilities, so
                                                the regulator's ability to  affect full  electricity rates
                                                might be limited to distribution costs and  rates for
                                                default service customers.

                                                reductions provided  by  energy  efficiency  investment,
                                                induced by  appropriately designed marginal cost-based
                                                rates.  Some costs of a utility do  not vary with a  cus-
                                                tomer's kWh usage (e.g., hookup and local distribution).
                                                As a  result, a  marginal  cost-based  rate design  may
                                                necessarily  include some  fixed  costs, which can be
                                                collected via a  volumetric adder or  a relatively  small
                                                customer charge. However,  utilities that set usage rates
                                                near long-run marginal costs will encourage energy effi-
                                                ciency and  promote  other  social  policy goals such as
                                                affordability  for  low-income and low-use  customers
                                                whose  bills might  increase with  larger, fixed  charges.
                                                Hence,  a  practical  implementation  of  marginal-cost
                                                based ratemaking  should balance the trade-offs and
                                                competing goals of rate design.
5-4
National Action Plan for Energy Efficiency

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Provide Stable Rates and Protect Low-Income Customers
Rate designs to promote energy efficiency must con-
sider whether or not the change will  lead to bill
increases. Mitigating large bill increases for individual
customers is a fundamental goal of rate design, and
in some jurisdictions low-income customers are also
afforded particular attention to ensure that they are
not adversely affected by rate changes. In some cases,
low-income customers are eligible for special rates or
rate riders that protect them from large  rate increases,
as exemplified by the lifeline rates provision in  Section
114 of the 1978 PURPA. Strategies to manage bill
impacts include phasing-in rate changes to reduce the
rate shock in any single year, creating exemptions for
certain at-risk customer groups, and disaggregating
customers into small customer groups to allow more
targeted rate forms.

Because of the concern over bill impacts,  new and inno-
vative rates  are often offered as voluntary rates. While
improving acceptance, voluntary rate structures generally
attract a relatively small  percentage of  customers (less
than 20 percent) unless marketed heavily by the utility.
Voluntary rates can lead to some "free riders," meaning
customers who achieve bill reductions without changing
their consumption behavior and providing any real  sav-
ings to the utility. Rates to promote energy efficiency can
be offered as voluntary,  but the  low participation  and
free rider issues  should be taken into account in  their
design to ensure that the benefits of the consumption
changes  they encourage  are at  least as great as the
resulting bill decreases.

Maintain Rate Simplicity
Economists and public policy analysts can become enam-
ored with efficient pricing schemes, but customers gen-
erally  prefer  simple  rate forms.  The  challenge for
promoting energy  efficiency  is  balancing the desire for
rates that provide the right signals to customers with the
need to have rates that customers can understand,  and
to which they can respond.  Rate designs that are too
complicated for  customers  to  understand will  not  be
effective at promoting efficient consumption decisions.
Particularly in the residential sector, customers might pay
more attention to  the total  bill than to the underlying
rate  design.


Addressing the Issues:
Alternative Approaches

The  prior sections  listed  the  issues that stakeholders
must balance  in  designing  new  rates.  This section
presents  some traditional  and  non-traditional  rate
designs and  discusses their merits for promoting energy
efficiency. The  alternatives  described below  vary  by
metering/billing reguirement,  information  complexity,
and  ability to reflect marginal cost.3

Rate Design Options
Inclining Tier Block
Inclining tier block rates, also  referred to as  inverted
block rates,  have per-unit prices that  increase for  each
successive block of energy consumed.  Inclining tiered
rates offer the advantages of being simple to understand
and  simple to  meter and bill.  Inclining rates can also
meet the policy goal of protecting small users, which
often include low-income customers. In fact, it was the
desire to protect small users that prompted the initiation
of increasing tiers in California. Termed "lifeline rates" at
the time, the intention was to provide a small base level
of electricity to all residential customers at a  low  rate,
and  charge  the higher rate only to usage  above that
base level. The concept of lifeline rates continues in var-
ious  forms for numerous services  such  as water and
sewer services, and  can be considered for delivery or
commodity rates for electricity and natural gas. However,
in many parts of the country, low-income customers are
not  necessarily low-usage customers, so a lifeline rate
might  not  protect  all  low-income  customers   from
energy bills.
3 As part of its business model, a utility may use innovative rate options for the purpose of product differentiation. For example, advanced metering that
 enables a design with continuously time-varying rates can apply to an end-use (e.g., air conditioning) that is the main contributor to the utility's system
 peak. Another example is the bundling of sale of electricity and consumer devices (e.g., a 10-year contract for a central air conditioner whose price
 includes operation cost).
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                                                 5-5

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Tiered  rates also  provide a good fit for  regions where
the long-run marginal cost of energy exceeds the cur-
rent average cost of energy. For example, regions with
extensive hydroelectric resources might have low aver-
age costs, but their marginal cost might be set by much
higher fossil plant costs or market prices (for purchase
or export).

See Table 5-1  for additional utilities that offer inclining
tier residential rates.

Time of Use (TOU)
TOU rates establish varying charges by season or time of
day.  Their designs can range from simple on- and off-
peak rates that are constant year-round to more compli-
cated rates with seasonally differentiated prices for sev-
eral  time-of-day periods (e.g., on-,  mid- and off-peak).
TOU rates have support from  many utilities because of
the flexibility to reflect marginal costs by time of delivery.

TOU rates are commonly offered as voluntary rates for
residential electric customers,4 and  as mandatory  rates
for larger commercial and industrial customers.  Part of
the  reason  for TOU  rates being applied  primarily to
larger users is the additional cost of TOU metering and
billing, as well as the assumed greater ability of larger
customers to shift their loads.

TOU rates are less applicable to gas rates, because the
natural storage capability of gas mains allows gas utilities
to procure  supplies on a  daily, rather than hourly, basis.
Additionally, seasonal variations are captured to a large
extent in costs for gas procurement, which are typically
passed through  to the  customer.  An  area  with con-
strained seasonal gas transportation capacity, however,
could merit a higher distribution cost during the con-
strained season.  Alternatively, a utility  could  recover a
higher share of its fixed  costs during the high demand
season, because  seasonal  peak  demand  drives the
sizing of the mains.

As  TOU  rates are typically  designed  to be revenue-
neutral with the  status quo rates,  a high on-peak price
will be accompanied by a low off-peak price. Numerous
studies in electricity have shown that while the high on-
peak  prices do cause a reduction  in usage  during that
period, the low off-peak prices lead to an increase  in
usage in the  low-cost period.  There has also been an
Table 5-1. Partial List of Utilities With Inclining Tier Residential Rates
^^^^^•••••••^^^•^^^•••••••^^^^^^•••^•^••••^^^^^^B
Utility Name
Florida Power and Light
Consolidated Edison
Pacific Gas & Electric

Southern California Edison
Arizona Public Service Co
Sacramento Municipal Util Dist
Indiana Michigan Power Co

Modesto Irrigation District
Turlock Irrigation District
Granite State Electric Co
Vermont Electric Cooperative, Inc
City of Boulder
State
FL
NY
CA

CA
AZ
CA
Ml

CA
CA
NH
VT
NV
Tariff UF
http://ww\
http://wwv
http://wwv
understant
http://wwv
https://ww
http://wwv
https://ww
Michigan/Pi
http://wwv
http://wwv
http://wwv
http://wwv
http://wwv
^
.fpl.com/access/contents/how_to_read_your_bill.shtml
.coned.com/documents/elec/201-210.pdf
*/.pge.com/res/financial_assistance/medicaLbaselineJife_support/
ing/index.html#topic4
/.sce.com/NR/rdonlyres/728FFC8C-91 FD-491 7-909B-
Maps.com/my_account/RateComparer.html
/.smud.org/residential/rates.html
/v.indianamichiganpower.com/global/utilities/tariffs/
1ISTD1-31-06.pdf
^.mid.org/services/tariffs/rates/ums-d-residential.pdf
^.tid.org/Pubiisher_PDFs/DE.pdf
mationalgridus.com/granitestate/home/rates/4_d.asp
^vtcoop.com/PageViewer.aspx?PageName=Rates%20Summary
'.bcnv.org/utilities.html#electric,waterandsewer
4 For a survey of optional rates with voluntary participation, see Horowitz and Woo (2006).

 5-6    National Action Plan for Energy Efficiency

-------
"income effect" observed where people buy more energy
as their overall bill goes down, due to  switching con-
sumption to lower price periods.  The net effect might
not be a significant decrease in total electricity usage,
but TOU rates do encourage reduced usage when that
reduction is the most valuable. Another  important con-
sideration with TOU prices is the environmental impact.
Depending  on generation mix and the diurnal emissions
profile of the region, shifting consumption from the on-
peak  period to off-peak period might provide environ-
mental net  benefits.

The Energy Policy Act of 2005 Section  7252 requires
states and non-regulated utilities, by August 8, 2007, to
consider adopting a standard requiring electric utilities to
offer a/I of their customers a time-based rate schedule
such as time-of-use pricing, critical peak pricing, real-
time pricing, or peak load reduction credits.

Dynamic Rates
Under a dynamic rate structure,  the utility has the ability
to change the cost or  availability of power with limited,
or no, notice.  Common forms of dynamic rates  include
the following:

•Real-time  pricing (RTP) rates  vary  continuously over
  time in a way that directly reflects the wholesale price
  of electricity.

• Critical  peak pricing (CPP) rates  have  higher  rates
  during periods designated  as  critical peak  periods by
  the utility. Unlike TOU blocks, the days in which critical
  peaks  occur  are not designated  in  the tariff, but are
  designated  on relatively short  notice  for  a  limited
  number of days during the year.

• Non-firm rates typically follow the  pricing form of the
  otherwise  applicable  rates,  but offer discounts  or
  incentive payments for customers to curtail usage during
  times of system need (Horowitz and Woo, 2006). Such
  periods of system need are not designated in advance
  through the tariff, and the customer might receive little
  notice before energy supply is  interrupted. In some
  cases, customers may be allowed to "buy through"
  periods when their supply will be interrupted by paying
  a higher energy charge (a non-compliance penalty). In
  those  cases, the non-firm rate  becomes  functionally
  identical to  CPP rates.

Dynamic rates are generally used to:  1)  promote load
shifting by large, sophisticated users, 2) give large users
access to low "surplus energy" prices, or 3) reduce peak
loads on the  utility system. Therefore, dynamic rates  are
complementary to energy efficiency,  but are  more useful
for  achieving demand  response  during  peak  periods
than reducing overall energy usage.

Two-Part Rates
Two-part rates refer to designs wherein  a base  level of
customer usage is priced at rates similar to the status
quo (Part 1) and deviations from the base level of usage
are billed at the alternative rates (Part 2). Two-part rates
are common  among RTP programs to minimize the free
rider  problem.  By implementing a  two-part  rate, cus-
tomers receive the real time price only for their  change
in usage relative to their base level of usage. Without  the
two-part rate form, most low load-factor customers on
rates  with demand charges would see large bill reduc-
tions for moving to an RTP rate.

A two-part rate form,  however, could also be combined
with  other rate forms that are more conducive to energy
efficiency program adoption. For example,  a two-part
rate could be structured like an increasing tiered block
rate,  with the Tier 1 allowance based on the customer's
historical usage. This structure would address many of
the  rate design barriers such as revenue stability.  Of
course, there would be implementation  issues,  such  as
determining what historical period is used to set Part 1,
and  how often  that  baseline is  updated  to  reflect
changes  in usage. Also, new customers would need  to
be assigned an interim baseline.
   ncate rt sustainable, aggmwvp national (oinrn/tment to energy
                                                 5-7

-------
Demand Charges
Demand charges bill customers based on their peak usage
rather than their total usage during the month. For electric-
ity, demand charges are based on usage during  particular
TOU periods (e.g., peak demand) or usage during any peri-
od  in  the month  (e.g.,  maximum demand).  Demand
charges can also use a percentage of the highest demand
over the prior year or prior season as a minimum demand
level used for billing. For natural gas, demand can be based
on the highest monthly usage over the past year or season.

For  both  gas  and electricity,  utilities prefer demand
charges over volumetric  charges because they provide
greater revenue certainty, and encourage more  consis-
tent asset utilization. In contrast to a demand  charge, a
customer charge that covers more of a utility's fixed costs
reduces  profits  from increased sales,  and the  utility
disincentive to promote energy efficiency.

For energy efficiency  programs,  demand charges could
help promote reductions in usage  for those  end uses
that cause the customer's  peak.5 In general,  however,
volumetric rates are more favorable for energy  efficiency
promotion.  Increasing   the  demand  charges  would
reduce the magnitude of the price signal that could be
sent through a  volumetric charge.

Mechanisms  Where Customer Benefits  Are
Not Driven by Tariff Savings
The  rate design forms discussed above allow customers
to benefit from energy efficiency through bill reductions;
however, other types of programs provide incentives that
are decoupled from the customer's retail rate.

Discount for Efficiency via Conservation Behavior
In some cases, energy efficiency benefits are  passed on to
customers through  mechanisms other than retail rates. For
example, in  California the "20/20"  program was imple-
mented in 2001, giving customers a 20 percent  rebate off
their summer bills if  they  could reduce  their  electricity
consumption by 20 percent compared to the summer peri-
od the prior year. The program's success was likely due to
a combination of aggressive customer education, energy
conservation behavior (reducing consumption through lim-
iting usage of appliances and end-uses) and investment in
energy efficiency. Pacific Gas & Electric  (PG&E) has just
implemented  a similar program for natural gas, wherein
customers can receive a rebate of 20 percent of their last
winter's bill if they can reduce natural gas usage by 10 per-
cent this winter season. The 20/20  program was popular
and effective.  It was easy for customers to understand, and
there might be a psychological  advantage to a program
that gives you a rebate (a received reward), as opposed to
one  that just allows you to  pay less than you  otherwise
would have (a lessened penalty).  Applying  this concept
might require some adjustments to account for changes in
weather or other factors.

Benefit Sharing
There are two types of benefit sharing with customers.5
Under the first type of shared savings,  a developer (utility
or third party) installs an energy-saving device. The  cus-
tomer shares the bill savings with the developer until the
customer's project load has been paid off. In the second
type of shared savings, the utility is typically the  developer
and  installs an energy efficiency or distributed genera-
tion device at the customer site. The customer  then pays
an amount comparable to what the bill would have been
without the device or measures installed, less  a  portion
of the savings of the device based  on utility avoided
costs. This approach  decouples the  customer benefits
from the utility rate,  but it  can be complicated to deter-
mine what the consumption would have been without
the device or energy efficiency.

PacifiCorp  in  Oregon tackled this  problem by  offering a
cash payment of 35 percent of the cost savings for residen-
tial weatherization measures, where the cost savings was
based on the measure's expected annual kWh savings and
a schedule of lifecycle savings per kWh (PacifiCorp, 2002).
5 Horowitz and Woo (2006) show that demand charges can be used to differentiate service reliability, thus implementing curtailable and interruptible seivice
  programs that are useful for meeting system resource adequacy.
6 Note that benefit sharing is not the same as "shared savings," used in the context of utility incentives for promoting energy efficiency programs.
 5-8    National Action Plan for Energy Efficiency

-------
Table 5-2. Pros and Cons of Rate Design Forms
Program Type
Increasing Tier Block
(Inverted block)
http://www.pge.com/
tariffs/pdf/E-1 .pdf
http://www.sdge.com/
tm2/pdf/DR.pdf
http://www.sdge.com/
tm2/pdf/GR.pdf
Time of Use (TOU)
http://www.nationalgridus
.com/masselectric/
home/rates/4_tou.asp
Criteria
Avoided Cost Benefits
and Utility incentives
Pro: Good match when
long-run marginal costs
are above average
costs.
Con: Might not be the
right price signal if long-
run marginal costs are
below average costs.
Pro: (1) Low implemen-
tation cost; (2) Tracks
expected marginal
costs.
Con: Unclear if marginal
costs should be short-
or long-run.
Energy anrl Peak
Reductions
- • -- 	 — 	 - - -
Pro: Can achieve annual
energy reductions.
Con: Does not encourage
reductions in any partic-
ular period (unless com-
bined with a time-based
rate like TOU).
Customer Incentive and
Bill impact
Pro: Provides strong
incentive to reduce
usage.
Con: Could result in
large bill increases for
users that cannot change
their usage level, and
could encourage more
usage by the smaller
customers.
Pro: Can achieve peak Pro: Provides customers
load relief. I with more control over
i their bills than flat rates,
Con: Might not achieve j and incentive to reduce
substantial energy peak usage.
reductions or produce
significant emissions Con: If mandatory,
benefits. could result in large bill
I increases for users that
: cannot change their
usage pattern.
Impact on Non-
Participants
Pro: If mandatory, little
impact on other customer
classes.
Con: Could not be
implemented on a
voluntary basis because
of free rider losses.
Pro: If mandatory, little
average impact, but
can be large on some
customers.
Con: If optional,
potentially large impact
due to free riders, which
can be mitigated by a
careful design.
Implementation and
Transition Issues
Pro: Simple to bill with
existing meters.
Con: Could require
phased transition to
mitigate bill impacts.
Pro: Extensive industry
experience with TOU
rate.
Con:(1) If mandatory,
likely opposed by
customers, but not
necessarily the utility;
(2) If optional, opposed
by non-participants and
possibly the utility.
Dynamic Rates: Real
Time Pricing (RTP)

http://www.exeloncorp.co
m/comed/library/pdfs/
advance_copy_tariff_
revision6.pdf

http://www.southern
company.com/
gulfpower/pricing/gulf_
rates.asp?mnuOpco=gulf
&mnuType=com&mnulte
m=er#rates

http://www.nationalgridus
.com/niagaramohawk/
non_html/rates_psc207
.pdf


Dynamic Rates:
Critical Peak Pricing
(CPP)

http://www.southerncom-
pany.com/gulfpower/
pricing/pdf/rsvp.pdf

http://www.idahopower.
com/aboutus/
regulatoryinfo/tariffPdf.
asp?id=263&.pdf

http://www.pge.com/
tariffs/pdf/E-3.pdf
                       -h
 Pro: (1) Tracks day-
j ahead or day-of short-
| run marginal cost for
 economically efficient
 daily consumption
 decisions; (2) RTP rates
 can be set to help
 allocate capacity in an
 economically efficient
 manner during
 emergencies.

 Con:  No long-run price
 signal for investment
 decisions.
! Pro: (1) Tracks short-run
i marginal cost shortly
! before emergency; (2) If
| the CPP rates are set at
I correctly predicted
j marginal cost during
j emergency, they ration
\ capacity efficiently.

| Con: High implementa-
i tion cost.
Pro: Can achieve peak
load relief.

Con: (1) Not applicable
to gas; (2) Might not
achieve substantial
annual energy reductions
or produce significant
emissions benefits.
I Same as above.
Same as above.
Pro: Likely to achieve
load relief.

Con: Unlikely to provide
significant annual energy
reductions.
 Same as above.
Pro: Little impact,
unless the utility heavily
discounts the rate for
the non-critical hours.
Con: (1) If mandatory,
likely opposed by
customers and the utility
due to complexity and
implementation cost;
(2) High implementation
cost for metering and
information system
costs.
Con: (1) If mandatory,
likely opposed by
customers and the
utility due to high
implementation cost;
(2) If optional, few would
object, unless the
implementation cost
spills over to other
customer classes.
                                                                                                                                           5-9

-------
Table 5-2. Pr
Program Type

Dynamic Rates
Nonfirm
http://www.pacificorp.com
/Regulatory_Rule_Schedul
e/Regulatory Rule Sched
ule2220.pdf
Two-Part Rates
http://www.aepcustomer.
com/tariffs/Michigan/pdf/
MISTD4-28-05.pdf:
Demand Charges
http://www.sce.eom/N R/
sc3/tm2/pdf/ce30-1 2.pdf
Discount for
Efficiency, Benefit
Sharing, etc.
http://www.cpuc.ca.gov/
PUBLISHED/NEWS
RELEASE/51 362.htm
http://www.pacificorp.
com/Regulatory_Rule_
Schedule/Regulatory Rule
_Schedule7794.pdf
Energy Efficiency
Customer Rebate
Programs (e.g., 20/20
program in California)
www.sce.com/Rebatesand
Savings/2020
www.sdge.com/tm2/pdf/
20-20-TOU.pdf
www.pge.com/tariffs/pdf/
EZ-2020.pdf
os and Cons of F

Avoided Cost Benefits
and Utility Incentives
Pro: (1 ) Provides
emergency load
relief to support
system reliability;
(2) Implements
efficient rationing.
Con: (1) Does not track
costs; (2) Potentially
high implementation
cost.
Pro: Allows rate to be
set at utility avoided
cost.
Con: Requires estab-
lishing customer base-
line, which is subject
to historical usage,
weather, and other
factors.
Pro: Reflects the cus-
tomer's usage of the
utility infrastructure.
Con: Does not con-
sider the duration of
the usage (beyond 1 5
minutes or one hour
for electric).
Pro: Incentive can be
tied directly to avoided
costs, without the
need to change
overall rate design.
Con: Only a portion
of the benefits are
reflected in the incen-
tive, as rate savings
will still be a factor
for most options.
Pro: Can avoid more
drastic rationing
mechanisms when
resources are signifi-
cantly constrained.
Con: Customer
discounts are not set
based on utility cost
savings, and therefore
these programs might
over-reward cutomers
who qualify.
?ate Design Forms

Energy and Peak
Reductions
Pro: (1) Can achieve
load reductions to meet
system needs;
(2) Applicable to both
gas and electric service.
Con: Unlikely to
encourage investment
in energy efficiency
measures.
Pro: Can be used to
encourage or discourage
peak usage depending
on characteristics of
"part two" rate form.
Pro: Can achieve load
reductions.
Con: Might not achieve
substantial annual
reductions.
Pro: Utilities generally
have control over what
measures are eligible for
| an incentive, so the mix
of peak and energy sav-
ings can be determined
during program design.
Con: Impacts might be
smaller than those
attainable through
mandatory rate
programs.
Pro: (1) Links payment
of incentive directly to
metered energy savings;
i (2) Easy to measure and
verify.
Con: Focused on
throughput and not
capacity savings.
ป (continued)
Criteria
Customer Incentive and
Bill Impact
Pro: Bill savings com-
pensate customer for
accepting lower
reliability.
Pro: Provides incentives
for changes in customer's
usage. Therefore, no
change in usage results
in the same bill.
Pro: Provides customers
with incentive to reduce
peak usage and flatten
their usage profile.
Con: If mandatory,
could result in large bill
increases for users who
cannot change their
usage pattern.
Pro: (1) Provides direct
incentive for program
participation, plus
ongoing bill reductions
(for most options);
(2) Does not require rate
changes.
Con: Existing rate forms
might impede adoption
because of overly low
bill savings.
Prq:(1) Provides a dear
incentive to customers to
reduce their energy usage,
motivates customers, and
i gets them thinking about
their energy usage;
(2) Can provide significant
bill savings; (3) Doesn't
require customers to sign
up for any program and
can be offered to
| everyone.


Impact on
Non-Partiepants
Pro: Little impact,
unless the utility offers a
curtailable rate discount
that exceeds the utility's
expected cost savings.
Pro: Non-participants
are held harmless.
Pro: If mandatory, little
average impact, but can
be large on some cus-
tomers.
Con: If optional, poten-
tially large impact due
to free riders, but this
can be mitigated by a
careful design.
Pro: Reflects the
characteristics of the
underlying rate form.
Con: Shifts costs to non-
participants to the
extent that the rebate
exceeds the change in
utility cost.
\ i

Implementation arid
Transition issues
Pro: (1) If optional, non-
participants would not
object unless discount is
"excessive"; (2) If man-
datory, different levels of
reliability (at increasing
cost) would need to be
offered.
Con: Complicated
notice and monitoring
requirements.
Pro: Complexity can
be controlled through
design of "part two"
rate form.
Con: (1) Customers
might not be accustomed
to the concept;
(2) Difficult to implement
for many smaller
customers.
Con: (1 ) If mandatory,
likely opposed by
customers and the utility
due to high implementa-
tion cost; (2) If optional,
few would object, unless
the implementation cost
spills over to other
customer classes.
Pro: Implementation
simplified by the ability
to keep status quo rates.
Con: Places burden for
action on the energy
efficiency implementer,
whereas a mandatory
rate change could
encourage customers to
seek out efficiency
options.
Pro: Very successful
during periods when
public interest is served
for short-term resource
savings, (e.g. energy
crisis.)
Con: Implementation
: and effectiveness might
be reduced after being
: in place for several
years.
5-10

-------
1 !•! B1': i-snaiK HHj

The primary function of on-bill financing  is to  remove the
barrier presented by the high first-time costs of many ener-
gy efficiency measures. On-bill financing allows the cus-
tomer to pay for energy efficiency equipment over time,
and fund those payments  through bill  savings.  On-bill
financing can also deliver financial  benefits to the partici-
pants  by providing  them access to low financing  costs
offered by the utility. An example of on-bill financing is the
"Pay  As You  Save"  (PAYS)   program,  which provides
upfront  funding in  return  for a monthly charge that is
always less than the savings.7


Pros and Cons of Various Designs

Rate  design  involves tradeoffs among numerous  goals.
Table  5-2 summarizes  the  pros and cons of  the various
rate design forms from various stakeholder perspectives,
considering implementation and transition issues. In most
cases, design elements  can  be combined  to mitigate
                                            weaknesses  of any single design  element,  so the table
                                            should be viewed as a reference and starting point.



                                            Successful Strategies


                                            Rate design is one of a number of factors that contribute
                                            to the success of energy efficiency programs. Along with
                                            rate design,  it is important to educate customers about
                                            their  rates so they understand the value of energy effi-
                                            ciency investment decisions.  Table 5-3 shows examples
                                            of four states with successful energy efficiency programs
                                            and complementary  rate  design approaches.  Certainly,
                                            one would expect higher rates to  spur energy efficiency
                                            adoption, and that appears to be the case for three of
                                            the four example states. However, Washington has  an
                                            active and  cost-effective  energy efficiency  program,
                                            despite an  average residential rate  far below the national
                                            average of 10.3 cents per kWh. (EIA, 2006)
   Table 5-3.  Conditions That Assist  Success
                           California
                                 Washington State
                              Massachusetts
                           New York
 Rate Forms
 and Cost
 Structures
Increasing tier block rates for residen-
tial (PG&E, SCE, and SDG&E).
Increasing block rate for residential
gas (SDG&E).

http://www.pge.com/tariffs/pdf/E-1.pdf

http://www.sce.com/NR/sc3/tm2/pdf/
ce12-12.pdf

http://www.sdge.com/tm2/pdf/DR.pdf

http://www.sdge.com/tm2/pdf/GR.pdf
Increasing tier block rates for resi-
dential electric (PacifiCorp). Gas
rates are flat volumetric (Puget
Sound Electric [PSE]). High export
value for electricity, especially in
the summer afternoon.

http://www.pacificorp.com/Regulat
ory_Rule_Schedule/Regulatory_
Rule_Schedule2205.pdf
Flat electricity rates per
kWh with voluntary TOU
rates for distribution service
(Massachusetts Electric).

http://www.nationalgridus.
com/masselectric/non_html/
rates_tariff.pdf
                                                  Increasing tier rates for
                                                  residential (Consolidated
                                                  Edison).

                                                  http://www.coned.com/
                                                  documents/elec/
                                                  201-210.pdf
 Resource and
 Load
 Characteristics
Summer electric peaks. Marginal
resources are fossil units. High mar-
ginal cost for electricity, especially in
the summer afternoon. Import transfer
capability can be constrained. Winter
gas peaks, although electric genera-
tion is flattening the difference.

http://www.ethree.com/CPUC/
E3_Avoided_Costs_Final.pdf
Winter peaking electric loads, but
summer export opportunities.
Heavily hydroelectric, so resource
availability can vary with precipita-
tion. Gas is winter peaking.

http://www.nwcouncil.org/energy/
powersupply/outlook.asp

http://www.nwcouncil.org/energy/
powerplan/plan/Default.htm

http://www.pse.com/energyEnviron
ment/supplyPDFs/ll"Summary%20
Charts%20and%20Graphs.pdf
                           | Part of Indpendant System
                           ' Operator New England
                            (ISO-NE), which is summer
                            peaking.

                           | http://www.nepool.com/
                            trans/celt/report/2005/2005
                           ! _celt_report.pdf
                      High summer energy costs
                      and capacity concerns in
                      the summer for the New
                      York City area.

                      http://www.eia.doe.gov/
                      cneaf/electricity/page/
                      fact_sheets/newyork.html
7 See http://www.paysamerica.org/.
                                                                                                                  5-11

-------
   Table  5-3. Conditions That Assist Success (continued)

Average
Residential
Electric Rates
Market and
Utility
Structure






Political and
Administrative
A ^A*KUซ
Actors














Demand-Side
Management
(DSM) Funding



California
13.7cents/kWh
(EIA, 2006)

Competitive electric generation and
gas procurement. Regulated wires
and pipes.

http://www.energy.ca.gov/electricity/
divestiture.html

http://www.cpuc.ca.gov/static/
energy/electric/ab57_briefing_
assembly_may_1 0.pdf
Environmental advocacy in the past
and desire to avoid another energy
capacity crisis. Energy efficiency
focuses on electricity.

http://www.energy.ca.gov/
2005publications/CEC-999-2005-
015/CEC-999-2005-015.PDF

http://www.energy.ca.gov/
2005publications/CEC-999-2005-
011/CEC-999-2005-011.PDF

http://www.cpuc.ca.gov/PUBLISHED/
NEWS_RELEASE/49757.htm
http://www.cpuc.ca.gov/static/
energy/electridenergy+effidency/
about.htm
System benefits charge (SBC) and
procurement payment.
http://www.cpuc.ca.gov/static/
energy/electric/energy+efficiency/
ee_funding.htm

Washington State
6.7 cents/kWh
(EIA, 2006)

Vertically integrated.
http://www.wutc.wa.gov/
webimage.nsf/6351 7e4423a08d
e988256576006a8(0bc/fe1 5f75d
7135a7e28825657e00710928!
OpenDocument



Strong environmental commit-
ment and desire to; reduce
susceptibility to mejrket risks.

http://www.nwenergy.org/news/
news/news_conservation.html












SBC.
http://www.wutc.wa.gov/
webimage.nsf/8d71 2cfdd4796c8
888256aaa007e94b4/0b2e3934
3cObe04a88256a3b007449fe!
OpenDocument
Massachusetts
17.6cents/kWh
(EIA, 2006)

Competitive generation.
Regulated wires.
http://www.eia.doe.gov/
cneaf/electridty/page/
fact_sheets/mass.html




DSM instituted as an
alternative to new plant
construction in the late
1980s and early 1990s
(integrated resource man-
agement). Energy efficiency
now under the oversight of
Division of Energy
Resources.

http://www.mass.gov/Eoca/
docs/doer/pub_info/
ee-long.pdf





SBC.
http://www.mass.gov/Eoca/
docs/doer/pubjnfo/
ee-long.pdf


New York
15.7cents/kWh
(EIA, 2006)

Competitive generation.
Regulated wires.
http://www.nyserda.org/sep/
sepsection2-1 .pdf





PSC established policy goals
to promote competitive energy
efficiency service and provide
direct benefits to the people
of New York.

On 1/16/06, Governor George
E. Pataki unveiled "a compre-
hensive, multi-faceted plan
that will help reduce New
York's dependence on
imported energy."

http://www.getenergysmart.
org/AboutNYES.asp
http://www.ny.goV/governor/p
ress/06/01 16062.html

SBC.
http://www.getenergysmart.
org/AboutNYES.asp



Part  of  Washington's energy efficiency  efforts  can be
explained  by  the high  value  for  power exports to
California, and partly  by the regional focus on promoting
energy efficiency. Washington and the rest of the Pacific
Northwest region place a high social value on environ-
mental  protection,  so Washington  might be  a case
where  the  success of energy efficiency is fostered by
high public awareness, and the willingness of the public
to look  beyond the short-term out-of-pocket  costs and
consider the longer term  impacts on the environment.
The other three states shown in Table 5-3 share the com-
mon characteristics of high residential rates, energy effi-
ciency funded through a system benefits surcharge, and
competitive electric markets. The formation of competi-
tive electric markets could have also encouraged energy
efficiency by: (1) establishing  secure funding sources or
energy efficiency agencies to promote energy efficiency,
(2)  increasing  awareness of energy  issues  and  risks
regarding future energy prices, and (3) the entrance of
new energy agents promoting energy efficiency.
5-12   National Action Plan for Energy Efficiency

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 Key Findings

This chapter summarizes the challenges and opportuni-
ties for employing  rate  designs  to encourage  utility
promotion and customer adoption of energy efficiency.
Key findings of this chapter include:

• Rate  design  is a  complex process that  balances
  numerous regulatory and  legislative goals. It is impor-
  tant to recognize the promotion of  energy efficiency in
  the balancing of objectives.

• Rate  design  offers opportunities to encourage cus-
  tomers to invest in efficiency where they find it to be
  cost-effective, and to participate  in  new programs that
  provide innovative technologies (e.g., smart meters) to
  help customers control their energy costs.

• Utility rates that are designed to promote sales or max-
  imize stable revenues tend to lower the  incentive for
  customers to adopt energy efficiency.

• Rate forms like declining block rates, or rates with large
  fixed  charges reduce the  savings that customers  can
  attain from adopting energy efficiency.

• Appropriate rate designs should  consider the unique
  characteristics of each customer class.  Some general
  rate design options by customer class are  listed below.

— Residential. Inclining  tier block  rates.  These rates
   can be quickly implemented for all residential and
   small commercial  and  industrial electric and  gas
   customers. At a minimum, eliminate declining  tier
   block rates. As metering costs  decline,  also explore
   dynamic rate options for residential customers.

  - Small Commercial. Time of use  rates.  While  these
   rates  might  not lead to  much  change  in annual
   usage, the price signals can encourage customers
   to consume  less energy when energy is the most
   expensive to produce, procure, and deliver.
                                              rates.
   These rates provide bill stability and can be established
   so that the change in consumption through adoption
   of energy efficiency is priced at  marginal cost. The
   complexity in establishing historical baseline quantities
   might limit the application of two-part rates to the
   larger customers on the system.

 - All Customer  Classes. Seasonal  price differentials.
   Higher prices  during  the higher  cost peak season
   encourage customer conservation during the peak
   and  can reduce  peak load  growth. For example,
   higher winter  rates can encourage the purchase of
   more efficient  space heating equipment.

• Energy efficiency can be promoted through non-tariff
 mechanisms that reach customers through their utility
 bill. Such mechanisms include:

 — Benefit Sharing Programs. Benefit sharing programs
   can  resolve situations where normal customer bill
   savings are smaller than the cost of energy efficiency
   programs.

 •- On-Bill Financing.  Financing  support can help cus-
   tomers  overcome the upfront costs  of efficiency
   devices.

—• Energy Efficiency Rebate Programs  Programs that
   offer discounts  to customers who reduce  their
   energy consumption, such as the 20/20 rebate pro-
   gram in  California, offer clear  incentives to  cus-
   tomers to focus on reducing their energy use.

• More effort is needed  to communicate the benefits
 and opportunities for energy efficiency to  customers,
 regulators, and utility decision-makers.
To create a sustainable, aggressive national commitment to energy efficiency
                                              5-13

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Recommendations and  Options

The National Action Plan for Energy Efficiency Leadership
Group offers the following recommendations as ways to
overcome many of the barriers to energy efficiency in
rate design, and provides a number of options for con-
sideration by utilities, regulators,  and stakeholders (as
presented in the Executive Summary):

Recommendation: Modify  ratemaking  practices  to
promote energy efficiency  investments.  Rate design
offers opportunities to encourage customers to invest in
efficiency where they find  it to be cost-effective, and to
participate in new programs that bring them  innovative
technologies (e.g., smart meters)  to help them  control
their energy costs.

Opt/ons to Com/der
• Including the  impact on adoption of energy efficiency
  as one of the goals of retail rate design, recognizing
  that it must be balanced  with other objectives.

• Eliminating  rate designs that discourage energy effi-
  ciency by not increasing costs as customers consume
  more electricity or natural gas.

• Adopting rate designs that encourage energy efficiency,
  considering the unique  characteristics  of  each cus-
  tomer class, and including partnering tariffs  with other
  mechanisms that encourage energy efficiency,  such as
  benefit sharing programs and on-bill financing.
Recoir.mond/itiOrr Broadly t omrnumc;.iU.- the hc-i efs rs
of. and opportunities for, energy efficiency.  Experience
shows that energy efficiency programs help customers
save money and  contribute to lower cost  energy sys-
tems. But these impacts are not fully documented nor
recognized by customers, utilities, regulators and policy-
makers. More effort  is needed to establish the business
case for energy efficiency for all decision-makers, and to
show how a well-designed approach to energy efficien-
cy can benefit  customers,  utilities,  and society  by (1)
reducing customers bills over time,  (2) fostering finan-
cially healthy utilities (return on equity [ROE], earnings
per share, debt  coverage ratios unaffected), and (3) con-
tributing to positive societal net benefits overall. Effort is
also  necessary to  educate  key   stakeholders  that,
although energy efficiency can be an important low-cost
resource  to integrate into the energy mix, it does require
funding just  as a new  power plant  requires funding.
Further, education is necessary on the impact that energy
efficiency programs can have in concert with other energy
efficiency policies such as  building  codes,  appliance
standards, and  tax incentives.
  Communicating on  the role  of  energy efficiency  in
  lowering  customer energy bills and system  costs and
  risks over time.
 5-14

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 References

 Baskette, C, Horii, B., Kollman, E., & Price, S. (2006).
    Avoided Cost Estimation and Post-Reform Funding
    Allocation for California's Energy Efficiency
    Programs. Energy, 31:6-7, 1084-1099.
 Bonbright, J.C. (1961). Principles of Public Utility Rates.
    New York: Columbia University Press.
 Brown, S.J. and Sibley, D.S. (1986). The Theory of
    Public Utility Pricing. New York: Cambridge
    University Press.
 Horowitz, I.  and  Woo, C.K. (2006). Designing Pareto-
    Superior Demand-Response Rate  Options. Energy,
    31:6-7,  1040-1051.
 Huntington, S. (1975). The Rapid Emergence of
    Marginal Cost Pricing in the Regulation of Electric
    Utility Rate Structures. Boston University Law
    Review,  55: 689-774.
 Hyman, L.S., Hyman, A.S., & Hyman,  R.C. (2000).
    America's Electric Utilities: Past, Present, and
    Future,  7th Edition. Arlington, VA: Public Utilities
    Reports.
Joskow, PL.  (1976).  Contributions to the Theory of
    Marginal Cost Pricing. Bell Journal of Economics,
    7(1):  197-206.
Joskow, P. (1979). Public Utility Regulatory Policy Act of
    1978: Electric Utility Rate Reform. Natural
    Resources Journal, 19: 787-809.
Kahn, A. (1970). The Economics of Regulation. New
    York: John Wiley & Sons.
PacifiCorp (2002, September 30). Oregon Schedule 9—
    Residential Energy Efficiency Rider Optional
    Weatherization Services. P.U.C. OR No. 35, Advice
    No. 02-027. 
Phillips, C.F. (1988). The Regulation of Public Utilities:
    Theory and Practice. Arlington, VA:  Public Utilities
    Reports.
Public Utility Regulatory Policies Act (PURPA) of 1978,
    Section 114.
U.S. Energy Information  Administration  [EIA]  (2006).
   Average Retail Price of Electricity to  Ultimate
    Customers by End-Use Sector,  by State. Electric
    Power Monthly.
                                                                                                      5-15

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6
   Energy Efficiency
!  Program  Best  Practices
Energy efficiency programs have been operating successfully in some parts of the country since the late
1980s. From the  experience of these successful  programs,  a  number of  best  practice strategies have
evolved for making energy efficiency a resource, developing a cost-effective portfolio of energy efficiency pro-
grams for all customer classes, designing and delivering energy efficiency programs that optimize budgets,
and ensuring that programs deliver results.
Overview

Cost-effective  energy efficiency  programs have  been
delivered by large and small utilities and third-party pro-
gram administrators in some parts of the country since
the late 1980s. The rationale for utility investment in effi-
ciency  programming is that within certain existing mar-
kets for energy-efficient products and services, there are
barriers that can be overcome to ensure that customers
from all sectors of the  economy  choose more  energy-
efficient  products  and  practices.  Successful  programs
have developed strategies to overcome these barriers,  in
many  cases partnering  with  industry and  voluntary
national and regional programs so that efficiency  pro-
gram spending is used not only to acquire demand-side
resources, but also to accelerate market-based purchases
by consumers.
 Leadership Group Recommendations
 Applicable to Energy Efficiency
 Program Best Practices
  • Recognize energy efficiency as a high priority
    energy resource.

  • Make a strong, long-term commitment to
    cost-effective energy efficiency as a resource.

  • Broadly communicate the benefits of, and oppor-
    tunities for, energy efficiency.

  • Provide sufficient and stable program funding to
    deliver energy efficiency where cost-effective.
  A list of options for promoting best practice energy
  efficiency programs is provided at the end of
  this chapter.
                                                   Challenges that limit greater utility
                                                   investment in energy efficiency include
                                                   the following:

                                                   • The majority of utilities recover fixed operating costs
                                                     and earn profits based on the volume of energy they
                                                     sell. Strategies for overcoming this throughput disin-
                                                     centive to greater investment in energy efficiency are
                                                     discussed in Chapter 2: Utility Ratemaking & Revenue
                                                     Requirements.

                                                   • Lack of standard approaches on how to quantify and
                                                     incorporate the benefits of energy efficiency into
                                                     resource planning efforts, and institutional barriers at
                                                     many utilities that stem from the historical business
                                                     model of acquiring generation assets and building
                                                     transmission and distribution systems. Strategies
                                                     for overcoming these challenges are addressed in
                                                     Chapter 3: Incorporating Energy Efficiency in
                                                     Resource Planning.

                                                   • Rate designs that are counterproductive to energy
                                                     efficiency might limit greater efficiency investment by
                                                     large customer groups, where many of the most
                                                     cost-effective opportunities for efficiency program-
                                                     ming exist. Strategies for encouraging rate designs
                                                     that are compatible with energy efficiency are dis-
                                                     cussed in Chapter 5: Rate Design.

                                                   • Efficiency programs need to address multiple cus-
                                                     tomer needs and stakeholder perspectives while
                                                     simultaneously addressing multiple system needs, in
                                                     many cases while competing for internal resources.
                                                     This chapter focuses on strategies  for making energy
                                                     efficiency a resource, developing a cost-effective port-
                                                     folio of energy efficiency programs for all customer
                                                     classes, designing and delivering efficiency programs
                                                     that optimize budgets, and ensuring that those pro-
                                                     grams deliver results are the focus of this chapter.
To create a sustainable, aggressive national commitment tu energy effiaei.: y

-------
Programs that  have  been  operating  over  the  past
decade, and longer,  have a history of proven  savings in
megawatts (MW), megawatt-hours (MWh), and therms,
as well as on customer bills. These programs show that
energy efficiency can compare very favorably to supply-
side options.

This chapter summarizes  key  findings  from a portfolio-
level1  review of  many of the energy efficiency programs
that  have been  operating successfully for a  number of
years. It  provides  an overview of best practices in the
following areas:

• Political and  human factors that have led to increased
  reliance on energy  efficiency as a resource.

• Key considerations used in identifying target measures2 for
  energy efficiency programming in the near- and long-term.

• Program design  and  delivery strategies that can maxi-
  mize program  impacts and increase cost-effectiveness.

• The role of monitoring and evaluation in ensuring that
  program dollars are optimized and that energy efficiency
  investments  deliver results.

Background

Best practice  strategies for program  planning, design
and  implementation, and evaluation were derived  from
a review of energy efficiency programs at the portfolio
level across a range of policy models (e.g., public benefit
charge  administration, integrated  resource  planning).
The  box on page 6-3 describes the policy models and
Table 6-1 provides  additional details  and examples of
programs operating under various policy models.  This
chapter is not intended as a comprehensive review of the
energy efficiency programs operating around the country,
but does highlight key factors that can help improve and
accelerate   energy   efficiency   program   success.
Organizations reviewed for this effort have a sustained
history of successful  energy efficiency program imple-
mentation  (See  Tables  6-2 and  6-3 for summaries of
these programs) and share the following characteristics:

•Significant  investment  in  energy  efficiency as  a
  resource within their policy context.

• Development of cost-effective programs that deliver
  results.

•Incorporation of program design strategies that work
  to remove near- and long-term market barriers to invest-
  ment in energy efficiency.

•Willingness to  devote the necessary resources to make
  programs successful.

Most of the organizations reviewed also have conducted
full-scale impact evaluations of their portfolio of energy
efficiency investments within the last few years.

The best practices gleaned from a review of these organ-
izations can assist utilities, their commissions, state energy
offices, and other stakeholders in overcoming barriers to
significant energy efficiency  programming, and begin
tapping  into energy efficiency as a valuable and clean
resource to effectively meet future supply needs.
 1 For the purpose of this chapter, portfolio refers to the collective set of energy efficiency programs offered by a utility or third-party energy efficiency
  program administrator.
 2 Measures refer to the specific technologies (e.g., efficient lighting fixture) and practices (e.g., duct sealing) that are used to achieve energy savings.
 6-2    National Action Plan for Energy Efficiency

-------
Energy Efficiency Programs Are Delivered Within Many Policy Models
 Systems Benefits Charge (SBC) Model
 In this model, funding for programs comes from an SBC
 that is either determined by legislation or a regulatory
 process.  The charge is  usually a fixed  amount  per
 kilowatt-hour (kWh) or  million British thermal units
 (MMBtu) and is set for a  number of years. Once funds
 are collected by the distribution or integrated utility,
 programs can  be administered  by the utility, a state
 agency,  or a third party. If the utility implements  the
 programs, it usually receives current cost recovery and
 a shareholder  incentive.  Regardless of administrative
 structure, there  is  usually  an opportunity  for stake-
 holder input.

 This model provides stable program design. In some
 cases, funding  has become  vulnerable  to raids by
 state agencies.  In areas aggressively pursuing energy
 efficiency as a resource, limits to additional funding
 have created a ceiling on the resource. While predom-
 inantly used in the electric sector, this model can, and
 is, being used to fund gas programs.

 integrated Resource Plan (iRP) Model
 In this model, energy efficiency is part of the utility's
 IRP. Energy efficiency, along with other demand-side
 options, is treated on an  equivalent basis  with supply.
 Cost recovery can either be in  base rates or through a
 separate charge. The utility might receive a sharehold-
 er incentive, recovery of lost  revenue (from reduced
 sales volume), or both. Programs are driven more by
the resource need than in the SBC models. This gen-
 erally is an electric-only model. The regional planning
 model used  by the  Pacific Northwest is a  variation on
this model.
 Request For Proposal (RFP) Model
 In this case, a utility or an independent system opera-
 tor  (ISO) puts out a competitive solicitation RFP to
 acquire energy efficiency from a third-party provider
 to meet demand, particularly in areas where there are
 transmission and distribution bottlenecks or a gener-
 ation need. Most examples of this model to date have
 been electric only. The focus of this type of program
 is typically on saving peak demand.

 Portfolio Standard
 In this model, the program adminstrator is subject to
 a portfolio standard expressed in terms of percentage
 of overall energy or demand.  This model can include
 gas as well as electric, and can be used independent-
 ly or in conjunction with an SBC or IRP requirement.

 Municipal Utility/Electric Cooperative Mode!
 In this model, programs are administered by a munic-
 ipal utility or electric cooperative. If the utility/cooper-
ative owns or is responsible for generation, the energy
efficiency resource can be part of an IRP. Cost recovery
 is most likely in base rates. This model can include gas
as well as electric.
                                                                                                   (3 :

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   Table 6-1. Overview of Energy Efficiency Programs
Policy Model/
Examples
SBC with utility
implementation:
• California
• Rhode Island
• Connecticut
• Massachusetts
SBC with state
or third-party
implementation:
•New York
• Vermont
• Wisconsin
IRP or gas
planning model:
• Nevada
• Arizona
• Minnesota
• Bonneville Power
Administration (BPA)
(regional planning
model as well)
• Vermont Gas
• Keyspan
RFP model
for full-scale
programs and
congestion relief
Portfolio standard
model (can be
combined with
SBC or IRP):
• Nevada
• California
• Connecticut
• Texas
Municipal
utility & electric
cooperative:
• Sacramento
Municipal Utility
District (CA)
• City of Austin (TX)
• Great River Energy
(MN)
Funding
Type
Separate charge

Separate charge


Varies: in rates,
capitalized, or
separate charge




Varies
Varies



In rates


Shareholder
Incentive1
Usually

No


In some cases




No
Varies



No


Lead
Administrator
Utility

State agency
Third party


Utility




Utility buys from
third party
Utility may
implement
programs or
buy to meet
standard



Utility


Role in
Resource
Acquisition
Depends on
whether utility
owns generation

None or limited


Integrated




Integrated - can
be T&D only
Standard portfolio



Depends on
whether utility
owns generation


Scope of
Programs
Programs for all
customer classes

Programs for all
customer classes


Program type
dictated by
resource need




Program type
dictated by
resource need
Programs for all
customer classes



Programs for all
customer classes


Political
Context
Most programs of
this type came out
of a restructuring
settlement in states
where there was an
existing infrastruc-
ture at the utilities

Most programs of
this type came out
of a restructuring
settlement


Part of IRP
requirement;
may be combined
with other models




Connecticut and
Con Edison going
out to bid to reduce
congestion
Generally used
in states with
existing programs
to increase program
activity



Based on customer
and resource needs;
can be similar to IRP
model


 1 A shareholder incentive is a financial incentive to a utility (above those that would normally be recovered in a rate case) for achieving set goals for
  energy efficiency program performance.
6-4
National Action Plan for Energy Efficiency

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Key Findings

Overviews of  the energy efficiency programs reviewed
for this chapter are provided in Table 6-2 and 6-3. Key
findings drawn from these programs include:

• Energy efficiency resources are being acquired on aver-
  age at about one-half the  cost  of the  typical  new
  power sources, and about one-third of the cost of nat-
  ural gas supply  in many cases—and contribute to an
  overall lower cost energy system for rate-payers (EIA,
  2006).

• Many energy efficiency programs are being delivered at
  a total program  cost of about $0.02 to $0.03  per life-
  time  kilowatt-hour (kWh)  saved  and $0.30 to $2.00
  per  lifetime  million  British  thermal units (MMBtu)
  saved. These costs are less than the avoided costs seen
  in most regions of the country. Funding for the  majority
  of programs  reviewed  ranges from about 1 to 3  per-
  cent of electric utility revenue and 0.5 to 1 percent  of
  gas utility revenue.

• Even low energy cost states, such as those in the Pacific
  Northwest, have reason to invest in energy efficiency,
  as  energy efficiency  provides  a  low-cost,  reliable
  resource that reduces customer utility bills. Energy effi-
  ciency also costs less than constructing new  genera-
  tion, and  provides a hedge against market, fuel,  and
  environmental risks (Northwest Power and Conservation
  Council, 2005).

•Well-designed programs provide opportunities  for  cus-
  tomers of all types  to adopt  energy savings measures
  and reduce their energy bills.  These programs can help
  customers make sound energy use decisions, increase
  control over  their energy bills, and empower them to
  manage their energy usage. Customers can experience
  significant savings depending on their own habits and
  the program  offered.

•  Consistently funded, well-designed efficiency programs
  are cutting electricity and  natural  gas load—providing
  annual savings for a given  program year of 0.15 to 1
  percent  of  energy sales. These savings typically will
  accrue at this level for 10 to 15 years. These programs
  are  helping to offset  20 to 50 percent of expected
  energy growth in some regions without compromising
  end-user activity or economic well  being.

• Research and development enables a continuing source
  of new technologies and methods for improving energy
  efficiency   and  helping  customers   control  their
  energy bills.

• Many state  and regional studies have found that pur-
  suing economically  attractive,  but  as  yet  untapped
  energy efficiency could yield more than 20 percent sav-
  ings in total electricity  demand nationwide by 2025.
  These savings could help cut load  growth by half or
  more, compared to current forecasts. Savings in direct
  use of natural gas could similarly provide a  50 percent
  or greater reduction  in  natural gas demand growth.
  Potential varies by customer segment, but there are
  cost-effective opportunities for all customer classes.

• Energy efficiency programs are being operated success-
  fully  across many  different contexts:  regulated  and
  unregulated  markets;  utility,  state,  or third-party
  administration; investor-owned,  public, and coopera-
  tives; and gas and electric utilities.

• Energy efficiency resources are being acquired through
  a  variety of  mechanisms including system  benefits
  charges  (SBCs),  energy efficiency  portfolio standards
  (EEPSs),  and  resource  planning (or cost of service)
  efforts.

• Cost-effective energy efficiency programs for electricity
  and  natural  gas can be specifically targeted to reduce
  peak load.

• Effective  models are available for  delivering gas  and
  electric energy efficiency programs to all customer classes.
  Models may vary based on whether a utility is in the ini-
  tial stages of  energy  efficiency programming,  or has
  been implementing programs for a number of years.
To create a sustainable, aggre^ive national commitment to encigy efficiency
                                                6-5

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Table 6-2. Efficiency Measures of Natural Gas Savings Programs
Keyspan
Program Administrator
(MA)
Policy Model Gas
Period 2004
Vermont Gas
(VT)
Gas
2004
SoCal Gas
(CA)
Gas
2004
Program Funding
Average Annual Budget ($MM) 12
I
% of Gas Revenue 1 .00%
1.1
1 .60%
21
0.53%
Benefits
Annual MMBtu Saved 1 (OOOs MMBtu) I 500
Lifetime MMBtu Saved 2 (OOOs MMBtu) 6,000
60
700
1,200
15,200
Cost-Effectiveness
i I
Cost of Energy Efficiency ($/lifetime MMBtu) 2 2
i
I !
Retail Gas Prices ($/thousand cubic feet [Mcf]) 1 1 9
Cost of Energy Efficiency (% Avoided Energy Cost) 1 9% 1 8%
Total Avoided Cost (2005 $/MMBtu) 3 12 11
j
1
8
18%
7
  1 SWEEP, 2006; Southern California Gas Company, 2004.
  2 Lifetime MMBtu calculated as 12 times annual MMBtu saved where not reported (not reported for Keyspan or Vermont Gas).
  3 VT and MA avoided cost (therms) represents all residential (not wholesale) cost considerations (ICF Consulting, 2005).
•Energy efficiency programs, projects, and policies ben-
 efit  from  established  and  stable  regulations,  clear
 goals, and comprehensive evaluation.

•Energy efficiency programs benefit from  committed
 program  administrators and  oversight authorities, as
 well as strong stakeholder support.

• Most large-scale programs have improved productivity,
 enabling job growth in the commercial and industrial sectors.

• Large-scale energy  efficiency programs  can  reduce
 wholesale market prices.

Lessons learned  from the  energy efficiency programs
operated since inception of utility programs in  the late
1980s are presented as follows, and cover key aspects of
energy efficiency program  planning,  design, implemen-
tation, and evaluation.
Summary of Best Practices

In this chapter, best practice strategies are organized and
explained under four  major groupings:

•Making  Energy Efficiency a Resource

•Developing an Energy Efficiency Plan

•Designing and Delivering Energy Efficiency Programs

•Ensuring Energy  Efficiency Investments Deliver Results

For the most part, the best practices are independent of
the policy model in which the programs operate. Where
policy context is important, it is discussed in relevant sec-
tions of this chapter.
6-6    Ndtiontil Action Plan for Energy Efficiency

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Making Energy Efficiency a Resource
Energy efficiency is a resource that can be acquired to
help utilities meet current and future energy demand. To
realize this potential requires leadership at multiple levels,
organizational alignment, and an understanding of the
nature and extent of the energy efficiency resource.

•Leadership at multiple levels is needed to establish the
  business case for energy efficiency, educate key stake-
  holders, and enact policy changes that increase invest-
  ment  in  energy efficiency  as  a resource.  Sustained
  leadership is needed from:

    Key individuals  in upper management at the utility
    who understand that energy efficiency is  a  resource
    alternative that can help manage risk, minimize long-
    term costs, and satisfy customers.

    State agencies, regulatory  commissions, local govern-
    ments and associated legislative bodies, and/or consumer
    advocates that expect to see energy efficiency considered
    as part of comprehensive utility management.

    Businesses that  value  energy  efficiency as a way to
    improve operations,  manage  energy  costs, and con-
    tribute to long-term energy price stability and availabili-
    ty, as well as trade associations and businesses, such as
    Energy Service Companies (ESCOs), that help members
    and customers achieve improved energy  performance.

—  Public interest groups that understand that  in order
    to achieve  energy  efficiency and  environmental
    objectives, they must  help educate  key stakeholders
    and find workable solutions to some of the financial
    challenges  that limit  acceptance  and  investment in
    energy efficiency by utilities.3

• Organizational alignment. With policies in place to sup-
  port energy efficiency programming, organizations need
  to institutionalize policies to ensure that energy efficiency
  goals are realized. Factors contributing to success include:
    Strong support from upper management and one or
    more  internal champions.

    A framework  appropriate  to the  organization that
    supports large-scale implementation of energy effi-
    ciency programs.

 —  Clear,  well-communicated program goals that are tied
    to organizational goals and  possibly compensation.

 —  Adequate staff resources to get the job done.

-	  A  commitment to continually  improve  business
    processes.

• Understanding of the efficiency resource is necessary
  to create a credible business case for energy efficiency.
  Best practices include the following:

  -  Conduct a "potential study" prior to starting programs
    to inform and shape program and portfolio design.

 —  Outline what can be accomplished at what costs.

•—  Review  measures for all  customer classes including
    those  appropriate for hard-to-reach customers, such
    as low income and very small business customers.

Developing an Energy Efficiency Plan
An energy efficiency plan should reflect a long-term per-
spective that  accounts  for  customer  needs,  program
cost-effectiveness,  the  interaction  of programs  with
other policies that increase energy efficiency, the oppor-
tunities for new  technology,  and  the importance  of
addressing  multiple  system needs including peak load
reduction  and congestion  relief. Best practices include
the following:

• Offer programs for all key customer classes.

• Align goals with funding.
3 Public interest groups include environmental organizations such as the National Resources Defense Council (NRDC), Alliance to Save Energy (ASE), and
  American Council for an Energy Efficient Economy (ACEEE) and regional market transformation entities such as the Northeast Energy Efficiency
  Partnerships (NEEP), Southwest Energy Efficiency Project (SWEEP), and Midwest Energy Efficiency Alliance (MEEA).
To create a sustainable, aggressive national commitment to energy efficiency
                                                  6-7

-------
   Table 6-3. Efficiency Measures of Electric and Combination Programs

Policy Model
Period
Program Funding
Spending on Electric Energy
Efficiency ($MM) 1
Budget as % of Electric Revenue 2
Avg Annual Budget Gas (SMM)
% of Gas Revenue
Benefits
Annual MWh Saved / MWh Sales *•*
Lifetime MWh Saved 5 (OOOs MWh)
Annual MW Reduction
Lifetime MMBtu Saved * (OOOs MMBtu)
Annual MMBtu Saved (OOOs MMBtu}


Non-Energy Benefits




Avoided Emissions (tons/yr for 1
program year)
(could include benefits from load response,
renewable, and DG programs)

Cost-Effectiveness
NYSERDA
(NY)
SBC w/State Admin
2005

138
1.3%
NR1ฐ
NRio

0.2%
6,216
172
17,124
1,427


$79M bill
reduction




NOX: 470
S02: 850
C02: 400,000


Efficiency
Vermont
(VT)
SBC w/3rd Party Admin
	 ... „ 	 __
2004

14
3.3%
NA
NA

0.9%
700
15
470
40
• •" ••" ' 	 	 -•- •

37,200 CCF of water




Unspecified pollutants:
460,000 over



MA Utilities
(MA)
SBC w/Utility Admin
2002

123
3.0%
i
- - .- 	 _ 	
311
NA

0.4%
3,428
48
850
70

$21 M bill
reduction
2,090 new jobs
created



NOX:135
S02: 395
C02: 161,205


Wl Department
of
Administration12
SBC w/State Admin
2005

63
1 .4%
NA
j
NA

0.1%
1,170
81
11,130
930
	 	 - 	 - 	 -
Value of
non-energy benefits:
Residential: $6M
C/l: $36M

- 	 " 	 " — • ~'~
NOX: 2,167
S02: 4,270
C02: 977,836
(annual savings from 5
program years)
!
CA Utilities
(CA)
SBC w/Utility Admin
& Portfolio Standard
2004

317
1.5%
NA
NA

1.0%
22,130
377
43,410
3,620
	 	

NR




NR



Cost of Energy Efficiency
S/lifetime (kWh) 6
$/lifetime (MMBtu)
Retail Electricity Prices (S/kWh)
Retail Gas Prices (S/mcf)
Avoided Costs (2005$) ',ซ
Energy ($/kWh)
Capacity ($/kW)9
On-Peak Energy ($/kWh)
Off-Peak Energy ($/kWh)
Cost of Energy Efficiency as % Avoided
Energy Cost
0.02
NA
0.13
NA
I
0.03
28.20


89%
0.02
NA
0.11
NA

0.07 ,
3.62


29%
0.03
0.32
0.11
L NR

0.07
6.64
0.08
0.06
10%
6.05 I
NA I
r _„ j_.
	 NA~ 	 " "[~~

f 0.02 to 0.06 " •


i
90%
i
0.01
NA
0.13
NA

0.06



23%
 C/l = Commercial and Industrial; C02 = Carbon Dioxide; SMM = Million Dollars; N/A = Not Applicable; NR = Not Reported; NOX = Nitrogen Oxides;
 S02 = Sulfur Dioxide
 1 NYSERDA 2005 spending derived from subtracting cumulative 2004 spending from cumulative 2005 spending; includes demand response and
  research and development (R&D).
 2 ACEEE, 2004; Seattle City Light, 2005.
 3 Annual MWh Saved averaged over program periods for Wisconsin and California Utilities. NYSERDA 2005 energy efficiency Sewings derived from
  subtracting cumulative 2004 savings from 2005 cumulative reported savings.
 4 EIA, 2006; Austin Energy, 2004; Seattle City Light, 2005. Total sales for California Utilities in 2003 and SMUD in 2004 were derived based on
  growth in total California retail sales as reported by EIA.
 5 Lifetime MWh savings based on 12 years effective  life of installed eguipment where not reported for NYSERDA, Wisconsin, Nevada, SMUD, BPA,
  and Minnesota. Lifetime MMBtu savings based on 12 years effective life of installed equipment.
6-8

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Table 6-3. Efficiency Measures of Electric and Combination Programs (continued)
Nevada
IRPwith
Portfolio
Standard
2003
CT Utilities
(CT)
SBC w/Utility Admin
& Portfolio Standard
2005
SMUD
(CA)
Municipal
Utility
2004 	 "
Seattle City
Light (WA)
Municipal Utility
2l)04"
Austin Energy
Municipal Utility
2005
Bonneville Power
Administration
(ID, MT, OR, WA)
Regional Planning
	
2004
MINI Electric and
Gas Investor-Owned
Utilities (MM)
IRP and Conservation
Improvement Program
"2"003
Program Funding
11 65
0.5% ! 3.1%
NA NA
NA """" "NA
30
___ 	 _.._..._
1.5%
NA
NA
20
.._ — 	 —
3.4%
NA
25
78
1.9% NR
NA NA
NA | NA ~[ NA
52
NR
$14
0.50%
Benefits
0.1%
420"
16
NA
NA
-
NR
. - . _
NR
1.0%
0.5%
4,4"00 I" 630
135
..- 	 _. 	
NA
NA
lifetime savings of
$550M on bills
NOX: 334
S02:123
C02: 198,586
14
NA
NA 	
NR
NOX:18
0.7%
1,000
	 7 	 - 	
NA
NA
lifetime savings of
S430M on bills
created
f
C02:353,100
(cummulative
annual savings for
1 3 years)
0.9%
930
50
10,777
1,268
Potentially over 900
jobs created
Residential: $6M
C/l: $36M
NOX: 640
S02:104
C02: 680,000
over lifetime
! 0.5%
3,080
3,940
47.2 ! 129
NA ; 22,010
NA , 1,830
NR NR
NR
NR
Cost-Effectiveness
01)3
NA
0.09
NA
36.06
0.01" 	
NA""
0.10
" 	 NA

0.03
NA
0.10
NA""

0.07
2033"" f '
| i 0.08
" ; " aoe
... . j. .1 	 	
Not calculated
, ,
21%
63%

0.02 j 0.03 T" 0.03 F 0.01
NA I 2-32 NA
0.06 I 0.12 Wholesaler - NA
NA NA | NA
0.06
0.06
5.80

NR
..._ 	 	 	
|
	 	
NR { Wholesaler - NA NR


I
I
	 ~ 	 	 	 - • -• 	 ~ •- •
Not calculated Not calculated
Not calculated
6 Calculated for all cases except SMUD; SMUD data provided by J.  Parks, Manager, Energy Efficiency and Customer R&D, Sacramento Municipal
  Utility District (personal communication, May 19, 2006).
7 Avoided cost reported as a consumption ($/kWh)  not a demand (kW) figure.
s Total NSTAR avoided cost for 2006.
9 Avoided capacity reported by NYSERDA as the three-year averaged hourly wholesale bid price per MWh.
'o NYSERDA does not separately track gas-related project budget, revenue, or benefits.
11 NSTAR Gas only.
12 Wisconsin has a portfolio that includes renewable distributed generation; some comparisons might not be appropriate.
13 Range based on credits given for renewable distributed  generation.
                                                                                                                               6-9

-------
 • Use  cost-effectiveness tests that are consistent with
 long-term planning.

 • Consider building codes and appliance standards when
 designing programs.

 1 Plan to incorporate new technologies.
    Keep funding (and other program characteristics) as
    consistent as possible.

    Invest in education, training, and outreach.

    Leverage customer contact to sell additional efficien-
    cy and conservation.
 •Consider efficiency investments to  alleviate transmis-    • Leverage  private sector expertise,  external  funding,
 sion and distribution constraints.                         and financing.

 • Create  a  roadmap  of  key  program  components,    —  Leverage  manufacturer  and  retailer  resources
 milestones, and explicit energy use reduction goals.           through cooperative promotions.
Designing and Delivering Energy Efficiency Programs
Program  administrators can reduce the time to market
and implement programs and  increase cost-effectiveness
by leveraging the wealth of knowledge and experience
gained by other program administrators throughout the
nation and working with industry to deliver energy effi-
ciency to market.  Best practices include the  following:

• Begin with the market in mind.

—  Conduct a market assessment.

—  Solicit stakeholder input.

—  Listen to customer and trade ally needs.

—  Use utility channels and brands.

—  Promote   both  energy  and  non-energy   (e.g.,
    improved comfort,  improved air quality) benefits of
    energy efficient products and practices to customers.

—  Coordinate with  other utilities and third-party pro-
    gram administrators.

—  Leverage the national ENERGY STAR program.

—  Keep participation simple.
—  Leverage state and federal tax credits and other tax
    incentives (e.g., accelerated  depreciation, first-year
    expensing, sales tax holidays) where available.

—  Build on ESCO and other financing program options.

—  Consider outsourcing some programs to private and
    not-for-profit  organizations  that   specialize  in
    program  design  and  implementation through a
    competitive bidding process.

•Stan  with  demonstrated program  models—build
 infrastructure for the future.

-—  Start with  successful  program  approaches  from
    other utilities and  program administrators and  adapt
    them  to  local  conditions to  accelerate  program
    design and effective implementation.

—  Determine the right incentives, and if incentives are finan-
    cial, make sure that they are set at appropriate levels.

—  Invest in educating and  training the  service  industry
    (e.g., home performance contractors, heating and cool-
    ing  technicians) to deliver increasingly sophisticated
    energy efficiency services.

—  Evolve to  more comprehensive  programs.
6-10   National Action Plan for Energy Efficiency

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    Change measures over time to adapt to changing
    markets and new technologies.

    Pilot test new program concepts.
Ensuring Energy Efficiency Investments Deliver Results
Program  evaluation helps optimize program efficiency
and  ensure that  energy efficiency  programs deliver
intended results. Best practices include the following:

•Budget,   plan  and  initiate  evaluation  from  the
 onset;  formalize and  document evaluation plans
 and processes.

• Develop program and  project tracking  systems  that
 support  evaluation  and  program  implementation
 needs.

• Conduct process evaluations to ensure that programs
 are working efficiently.

• Conduct impact  evaluations to ensure that mid- and
 long-term goals are being met.

• Communicate evaluation results to  key  stakeholders.
 Include case studies to make success more tangible.
Making Energy Efficiency a Resource

Energy efficiency programs are being successfully operated
across many different contexts including electric and gas
uti ities; regulated and unregulated markets; utility, state,
and third-party administrators; and investor-owned, pub-
lic, and cooperatively owned utilities. These programs are
reducing annual energy use by 0.15 to 1 percent at spend-
ing levels between 1  and 3 percent of electric, and 0.5 and
1.5 percent of gas revenues—and are poised to deliver
substantially greater reductions over time. These organi-
zations  were able to  make broader use  of the energy
efficiency resource in their portfolio by having:

• Leadership at multiple levels to enact policy change.

•Organizational  alignment  to  ensure that  efficiency
 goals are realized.
• A well-informed  understanding of  the  efficiency
  resource including, the potential for savings and the
  technologies for achieving them.

Examples  of  leadership, organizational alignment, and
the steps  that organizations have taken to understand
the nature and extent of the efficiency  resource are
provided in the next sections.

Leadership
Many energy  efficiency programs reviewed in this chapter
began in  the integrated resource plan (IRP) era of the
electric utilities  of the 1980s. As restructuring started  in
the late 1990s, some programs were suspended or halted.
In  some  cases (such   as  California,  New  York,
Massachusetts, Connecticut, and Rhode Island), however,
settlement agreements  were  reached  that allowed
restructuring  legislation to move forward if energy effi-
ciency programming was provided through the distribu-
tion utility or  other third-party  providers. In many cases,
environmental advocates,  energy service providers, and
state  agencies  played active  roles in the  settlement
process  to ensure energy efficiency was part of the
restructured electric utility  industry. Other states (such  as
Minnesota, Wisconsin,  and Vermont) developed legisla-
tion to address the need for stable energy efficiency pro-
gramming without  restructuring  their state  electricity
markets.  In addition, a few states (including California,
Minnesota,   New  Jersey,  Oregon,   Vermont,  and
Wisconsin) enacted  regulatory  reguirements for utilities
or other parties to  provide gas  energy efficiency pro-
grams (Kushler, et al., 2003). Over the past few years,
the mountain states have steadily  ramped  up energy
efficiency  programs.

In all  cases, to establish energy efficiency as a resource
reguired leadership at multiple  levels:

•Leadership is needed to establish the business case for
  energy efficiency, educate key stakeholders, and enact
  policy  changes  that  increase  investment  in energy
  efficiency as a resource. Sustained leadership  is
  needed from:
To create a sustainable, aggressive national commitment to energy efficiency
                                               6-11

-------
    Key individuals in  upper management at the utility
    who understand that energy efficiency is a resource
    alternative that can help manage risk, minimize long-
    term costs, and satisfy customers.

    State agencies,  regulatory commissions, local gov-
    ernments and associated legislative bodies, and/or
    consumer advocates that expect to see energy efficien-
    cy considered as part of comprehensive utility manage-
    ment.
 —  Businesses that value energy efficiency as a way to
    improve operations, manage energy costs, and con-
    tribute to long-term energy price stability and avail-
    ability, as well as trade associations and businesses,
    such as  ESCOs,  that help members and customers
    achieve improved energy performance.

-Public  interest groups that understand that in order to
 achieve energy efficiency and environmental objectives,
 they must help educate key stakeholders and find work-
 able solutions to some of the financial challenges that limit
 acceptance and investment in energy efficiency by utilities.

The following are examples of how leadership has resulted
in increased investment in energy efficiency:

• In Massachusetts, energy efficiency was an early con-
 sideration  as  restructuring  legislation was discussed.
 The Massachusetts  Department  of  Public Utilities
 issued an order  in D.P.U. 95-30 establishing  principles
 to "establish the essential underpinnings of an electric
 industry structure and regulatory framework designed
 to minimize long-term costs to customers while main-
 taining safe and reliable electric service with  minimum
 impact on the environment." Maintaining demand side
 management  (DSM)   programs  was  one of  the
 major  principles the  department identified during
 the  transition to  a  restructured electric   industry.
 The Conservation Law Foundation, the Massachusetts
 Energy Efficiency Council, the  National Consumer Law
 Center, the Division of Energy Resources, the Union of
 Concerned Scientists, and others took leadership roles
 in ensuring energy efficiency was part of a restructured
 industry (MDTE, 1995).
• Leadership  at  multiple levels  led to  significantly
 expanded programming of Nevada's energy efficiency
 program, from about $2  million in 2001 to an estimated
 $26 million to $33 million in 2006:

 "There are 'champions' for expanded energy efficiency
 efforts in Nevada, either in the state energy office or in
 the consumer advocate's office. Also, there have been
 very supportive  individuals in key positions within the
 Nevada utilities.  These  individuals  are  committed to
 developing and  implementing effective DSM  programs,
 along   with   a    supportive   policy   framework"
 (SWEEP, 2006).

 Public  interest  organizations, including  SWEEP,  also
 played an important role by promoting a supportive pol-
 icy framework (see box on  page 6-13, "Case  Study:
 Nevada Efficiency  Program Expansion" for additional
 information).

• Fort Collins City Council (Colorado) provides an example
 of local leadership. The council adopted the Electric
 Energy Supply Policy in March 2003. The  Energy Policy
 includes specific goals for city-wide energy consump-
 tion  reduction  (10 percent  per capita  reduction by
 2012)  and peak  demand reduction (15 percent oer
 capita by 2012). Fort Collins Utilities introduced a variety
 of new demand-side management (DSM)  programs
 and services in  the last  several years in pursuit of the
 energy policy objectives.

• Governor Huntsman's comprehensive policy on energy
 efficiency for the state of Utah, which was  unveiled in
 April 2006, is one of the most recent examples of lead-
 ership. The policy  sets a goal of increasing the state's
 energy efficiency by 20 percent by the year 2015. One
 key strategy of the policy is to collaborate with utilities,
 regulators, and the private sector  to expand energy
 efficiency programs, working to identify and remove
 barriers,  and assisting  the  utilities  in ensuring  that
 efficiency programs are effective, attainable, and feasible
 to implement.
6-12   National Action Plan for Energy Efficiency

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Organizational Alignment
 • Adequate staff resources to get the job done.
Once policies and processes are in place to spearhead
increased investment in energy efficiency, organizations
often institutionalize these policies to ensure that goals
are realized.  The most successful energy efficiency pro-
grams by utilities or third-party program administrators
share a number of attributes. They include:

•Clear  support from  upper management and one  or
  more internal champions.

• Clear, well-communicated program goals that are tied to
  organizational goals and, in some cases, compensation.

• A framework appropriate to the organization that sup-
  ports large-scale implementation of energy efficiency
  programs.
 •Strong regulatory support and policies.

 • A commitment to continually improve business processes.

 "Support of upper  management  is critical to program
 success" (Komor, 2005). In fact, it can make or break a
 program. If the  CEO of a company or  the lead  of an
 agency is an internal champion for  energy efficiency, it
 will be truly a part of how a utility or agency does busi-
 ness. Internal champions below the CEO or agency level
 are critica  as well.  These internal champions motivate
 their fellow employees and embody  energy efficiency as
 part of the corporate culture.
  Case Study: Nevada Efficiency Program Expansion
   Nevada investor-owned utilities (lOUs), Nevada Power, and
   Sierra Pacific Power Company phased-out DSM programs
   in the mid-1990s. After 2001, when the legislature
   refined the state's retail electric restructuring law to permit
   only large customers (>1 megawatt [MW]) to purchase
   power competitively, utilities returned to a vertically
   integrated structure and DSM programs were restarted, but
   with a budget of only about $2 million that year.

   As part of a 2001 IRP proceeding, a collaborative process
   was established for developing and analyzing a wider
   range of DSM program options. All parties reached an
   agreement to the IRP proceeding calling for $11.2 million
   per year in utility-funded  DSM programs with an emphasis
   on peak load reduction but also significant energy sav-
   ings. New programs were launched in March 2003.

   In 2004, the Nevada public utilities commission also
   approved a new policy concerning DSM cost recovery,
   allowing the utilities to earn their approved  rate of return
   plus 5 percent (e.g., a 15 percent return if the approved
   rate is  10 percent) on the equity-portion of their DSM
   program funding. This step gave the utilities a much
   greater financial incentive to expand their DSM programs.
In June 2005, legislation enacted in Nevada added energy
savings from DSM programs to the state's Renewable
Portfolio Standard. This innovative policy allows energy
savings from utility DSM programs  and efficiency meas-
ures acquired through contract to supply up to 25 percent
of the requirements under the renamed clean energy
portfolio standard. The clean energy standard is equal to
6 percent of electricity supply in 2005 and 2006 and
increases to 9 percent in 2007 and  2008, 12 percent from
2009 to 2010, 15 percent in  2011  and 2012, 18 percent
in 2013 and 2014, and 20 percent  in 2015 and there-
after. At least half of the energy savings credits  must
come from electricity savings in the residential sector.

Within  months of passage, the utilities proposed a large
expansion of DSM programs for 2006. In addition to the
existing estimated funding of $26 million, the Nevada util-
ities proposed adding another $7.5 million to 2006 DSM
programs. If funding is approved, the Nevada utilities esti-
mate the 2006 programs alone will yield gross energy sav-
ings of  153 gigawatt-hours/yr and 63 MW (Larry Holmes,
personal communication, February 28, 2006).

Source: Geller, 2006.
To create a sustainable, aggressive national commitment to energy efficiency
                                                  6-13

-------
Tying  energy efficiency to overall corporate  goals  and
compensation is important, particularly when the utility is
the administrator of energy efficiency programs.  Ties to
corporate goals make energy efficiency an integral part of
how the organization does business as exemplified below:

• Bonneville Power Administration (BPA) includes energy
  efficiency as a part of its overall corporate strategy, and
  its executive compensation is designed to reflect how
  well the organization meets its efficiency goals.  BPA's
  strategy map states,  "Development of all cost-effective
  energy  efficiency  in the loads BPA  serves facilitates
  development of  regional renewable resources,  and
  adopts  cost-effective non-construction alternatives to
  transmission expansion" (BPA, 2004).

• National Grid ties energy efficiency goals to staff and
  executive compensation (P. Arons, personnel communi-
  cation, June 15, 2006).

• Sacramento Municipal Utility District (SMUD) ties energy
  efficiency to its reliability goal: "To ensure a reliable energy
  supply for customers in 2005, the 2005 budget includes
  sufficient capacity reserves for the peak summer  season.
  We have funded all of the District's commercial and resi-
  dential load management programs, and on-going effi-
  ciency programs in Public Good to continue to contribute
  to peak load reduction" (SMUD, 2004a).

• Nevada  Power's  Conservation Department  had  a
  "Performance Dashboard" that tracks costs, participating
  customers, kWh  savings,  kW  savings, $/kWh,  $/kW,
  customer contribution to savings, and total customer
  costs on a real time basis, both by program and overall.

• Austin Energy's Mission  Statement  is  "to deliver clean,
  affordable, reliable energy and excellent customer serv-
  ices" (Austin Energy, 2004).

• Seattle  City Light has actively pursued conservation as
  an alternative to new generation  since 1977 and has
  tracked progress toward its goals  (Seattle City Light,
  2005). Its longstanding,  resolute policy direction estab-
  lishes energy conservation as the first choice resource.
  In more recent years, the utility has also been guided by
  the city's  policy to meet of all the utility's future load
  growth with conservation and renewable  resources
  (Steve Lush, personal communication, June 2006).
   From Pacific Gas and Electric's (PG&E's)
   Second Annual Corporate Responsibility
   Report (2004):

   "One of the areas on which PG&E puts a lot of
   emphasis is helping our customers use energy
   more efficiently."

   "For example, we plan to invest more than $2
   billion on energy efficiency  initiatives over the
   next 10 years. What's exciting is that the most
   recent regulatory approval we received on this
   was the result of collaboration by a large and
   broad group of parties, including manufacturers,
   customer groups, environmental groups, and the
   state's utilities."

   — Beverly Alexander, Vice President,
      Customer  Satisfaction, PG&E

Having an appropriate framework  within the organiza-
tion to ensure success is also important. In the case of
the utility, this would  include the regulatory framework
that supports the programs,  including cost recovery and
potentially shareholder incentives and/or decoupling. l:or
a third-party administrator,  an appropriate framework
might include a sound bidding  process by a state agency
to select  the vendor or vendors and an  appropriate reg-
ulatory arrangement with the  utilities  to  manage the
funding process.

Adequate resources also are critical to successful imple-
mentation  of programs.  Energy  efficiency programs
need to  be understood and supported  by departments
outside those that are immediately responsible for pro-
gram  delivery. If  information technology,  legal, power
supply,  transmission,  distribution, and other  depa't-
ments  do not share  and  support the energy efficiency
goals  and programs, it is  difficult  for energy efficiency
programs to succeed. When programs are initiated, the
need for support  from other  departments is greatest.
Support from other departments needs to be considered
in planning and budgeting processes.
6-14   National Action Plan for Energy Efficiency

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As noted in the Nevada case study, having a shareholder
incentive makes it easier for a utility to integrate effi-
ciency goals into its business because the incentive off-
sets some of the concerns related to financial treatment
of program expenses  and  potential lost revenue  from
decreased sales. For third-party program administrators,
goals might be built into the contract that governs the
overall implementation of  the  programs. For example,
Efficiency  Vermont's contract  with   the   Vermont
Department of  Public Service  Board  has specific per-
formance targets. An added shareholder return will not
motivate  publicly  and cooperatively  owned  utilities,
though they might appreciate reduced risks from expo-
sure to wholesale  markets, and  the  value  added  in
improved  customer service. SMUD, for  example,  cites
conservation  programs as  a  way  to  help  customers
lower  their utility bills (SMUD, 2004b).  These compa-
nies,  like  lOUs, can  link  employee compensation  to
achieving energy efficiency targets.

Business processes for delivering energy efficiency pro-
grams and services  to customers should be  developed
and treated like other business processes in an organiza-
tion  and reviewed on  a regular basis.  These processes
should include documenting clear plans built  on explicit
assumptions,  ongoing monitoring  of results and  plan
inputs (assumptions), and  regular  reassessment  to
improve  performance (using  improved  performance
itself as a metric).

Understanding the Efficiency Resource
Energy efficiency potential studies provide the initial jus-
tification (the business case) for utilities embarking on or
expanding  energy  efficiency  programs,  by  providing
information on (1) the overall potential  for energy effi-
ciency and (2) the technologies, practices, and  sectors
with the greatest or  most cost-effective opportunities for
achieving that potential. Potential studies illuminate the
nature of energy efficiency resource, and can be used  by
legislators and regulators to inform efficiency  policy and
programs. Potential  studies can usually  be completed in
three to eight months, depending on the level of detail,
availability of data,  and complexity. They range  in cost
from  $100,000 to $300,000 (exclusive of primary data
collection). Increasingly,  many  existing  studies can  be
drawn from to limit the extent and cost of such an effort.

The majority of organizations reviewed in developing this
chapter have  conducted potential studies in the past five
years. In addition, numerous other studies have been con-
ducted in  recent years by a variety of organizations inter-
ested in learning more about the efficiency resource in
their state or region. Table 6-4  summarizes key findings
for achievable potential  (i.e., what can  realistically  be
achieved from programs within identified funding param-
eters), by customer class, from a selection of these studies.
It  also illustrates  that this potential is  well represented
across the residential, commercial, and industrial sectors.
The achievable estimates  presented are for a future time
period, are based on realistic  program scenarios, and rep-
resent potential program impacts above and beyond nat-
urally occurring conservation. Energy efficiency potential
studies are based on currently available technologies. New
technologies such as those discussed  in Table 6-9 will con-
tinuously and significantly increase potential over time.

The studies show that achievable  potential for reducing
overall energy consumption ranges from 7 to 32 percent
for electricity and 5 to  19  percent for  gas, and that
demand for electricity and gas can be reduced by about
0.5 to 2 percent per year. For context,  national electricity
consumption  is  projected to grow  by 1.6 percent per
year, and  gas consumption  is growing 0.7 percent per
year (EIA,  2006a).

The box on page  6-17, "Overview  of  a Well-Designed
Potential Study" provides information on  key elements
of a potential study. Related  best practices for efficiency
programs  administrators include:

• Conducting a "potential study" prior to starting programs.

• Outlining what can be accomplished at what cost.

• Reviewing measures appropriate to all customer classes
 including those appropriate for  hard-to-reach customers,
 such as low income and very small  business customers.
Jo create a sustainable, aggressive national commitment to energy efficiency
                                                6-15

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         Table 6-4. Achievable Energy Efficiency Potential From  Recent Studies
State/Region

U.S. (Clean
Energy Future) '
Con Edison !
Pacific NW 3
Puget Sound '
Connecticut s
California '
Southwest'


Illinois9
Study
Length
(Years)

20
10
20
20
8
9
17
19
17
Achievable
Demand
Reduction (MW)
Residential
n/a
n/a
n/a
133
240
1,800
n/a
3,584
n/a
Commercial
n/a
n/a
n/a
148
575
2,600
n/a
8,180
n/a
Industrial
n/a
n/a
n/a
16
93
1,550
n/a
602
n/a
Achievable Gas
Consumption
Reduction (MMBtu)
Residential
500,000,000
11,396,700
n/a
n/a
n/a
27,500,000
n/a
"
n/a
n/a
Commercial
300,000,000
10,782,100
n/a
n/a
n/a
20,600,000
n/a
n/a
n/a

Industrial
1,400,000,000
231,000
n/a
n/a
n/a

n/a
n/a
n/a
Achievable
GWh Reduction
Residential
392,732
n/a
11,169
1,169
1,655
9,200
24,593
15,728

Commercial
281,360
n/a
9,715
1,293
2,088
11,900
50,291
2,948

Industrial
292,076
n/a
5,011
139
723
8,800
8,180
67,000
AVERAGE:
Demand
Savings as
% of 2004
State
Mameplate
Capacity 10
Annual
%MW
Savings
Electricity
n/a
n/a
n/a
9.3%
12.5%
9.6%
n/a
23.1%
n/a
n/a
n/a
n/a
0.5%
1 .6%
1.1%
n/a
1 .2%
n/a
1.1%
Electricity
Savings as
% of Total
2004 State
Usage "
Annual
% GWh
Savings
Electricity
24%
n/a
12.5%
9.5%
13.4%
11.8%
32.8%
14.3%
43.2%
1 .2%
n/a
0.6%
0.5%
1 .7%
1.3%
1 .9%
0.8%
2.5%
1.3%
Gas Savings
as % of Total
2004 State
Usage"
Annual %
MMBtu
Savings
Gas
10%
19%
n/a
n/a
n/a
10%
_
n/a
n/a
	 • •
n/a
0.5%
1 .9%
n/a
n/a
n/a
1.1%
n/a
n/a
n/a
1.2%
o
m
        MW = Megawatt; MMBtu = Million British thermal units.
       1 ORNL, 2000.
       ' NYSERDA/OE, 2006.
        NPCC, 2005.
       ; Puget Sound Fnerny; 2003.
        GDS Associates and Quantum Consulting, 2004.
       ' KEMA, 2002; KEMA & XENERGY, 2003a; KEMA & XENERGY, 2003b.
       ' SWEEP, 2002.
       • NYSERDA/OE, 2003.
       'ACEEE, 1998.
       "' EIA, 2005a.
       ' EIA, 2005b.
       '•' EIA, 2006b.

-------
 Overview of a Well-Designed Potential Study
 Well-designed potential studies assess the following types
 of potential:

 Technical potential assumes the complete penetration of
 all energy-conservation measures that are considered
 technically feasible from an engineering perspective.

 Economic potential refers to the technical potential of
 those measures that are cost-effective, when compared to
 supply-side alternatives. The economic potential is very
 large because it is summing up the potential in existing
 equipment, without accounting for the time period during
 which the potential would be realized.

 Maximum achievable potential describes the economic
 potential that could be achieved over a given time period
 under the most aggressive program scenario.

 Achievable potential refers to energy saved as a result
 of specific program funding levels and incentives. These
 savings are above and beyond those that would occur
 naturally in the absence of any market intervention.

 Naturally occurring potential refers to energy saved as
 a result of normal market forces,  that is,  in the absence of
 any  utility or governmental intervention.
                                                   The output of technical and economic potential is the size
                                                   of the energy efficiency resource in MW, MWh, MMBtu
                                                   and other resources. The potential is built up from savings
                                                   and cost data from hundreds of measures and is typically
                                                   summarized by sector using detailed demographic infor-
                                                   mation about the customer base and the base of appli-
                                                   ances, building stock, and other characteristics of the
                                                   relevant service area.

                                                   After  technical and economic potential is calculated, typi-
                                                   cally the  next phase of a well-designed potential study is
                                                   to create program scenarios to  estimate actual savings
                                                   that could be generated by programs or other forms of
                                                   intervention, such as changing  building codes or
                                                   appliance standards.

                                                   Program  scenarios developed to calculate achievable
                                                   potential are based on modeling example programs and
                                                   using  market models  to estimate the penetration of the
                                                   program. Program scenarios require making assumptions
                                                   about rebate or incentive levels, program staffing, and
                                                   marketing efforts.

                                                   Scenarios can also be developed for different price
                                                   assumptions and load growth scenarios, as shown below
                                                   in the figure of a sample benefit/cost output from a
                                                   potential study conducted for the state of California.
   Benefits and Costs of Eiectric Energy-
   Efficiency Savings, 2002-2011
$25

$20

$15

$10

 $5
               Net Benefits:
                S5.5B
                                             $11. 9B


                                             "
          Business-as-Usual    Advanced Efficiency
Source: KEMA, 2002
                                                                                                            6-1?

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• Ensuring that potential state and federal codes and stan-
  dards are modeled and included in evaluation scenarios

• Developing scenarios for relevant time periods.

In addition, an emerging best practice is  to  conduct
uncertainty analysis on savings  estimates,  as well as
other variables such as cost.

With  study results in hand, program administrators are
well positioned to develop energy efficiency  goals,  iden-
tify program  measures and strategies, and determine
funding requirements to  deliver energy efficiency pro-
grams to all  customers.  Information  from a  detailed
potential study can also be used as the basis for calculating
program  cost-effectiveness  and  determining  measures
for inclusion during the program planning  and design
phase. Detailed potential studies can  provide informa-
tion to help determine which technologies are replaced
most  frequently and are therefore candidates to deliver
early returns (e.g., an efficient light bulb), and how long
the savings from various technologies persist and there-
fore will continue to deliver energy savings. For example,
an energy efficient light bulb might last six years, where-
as an efficient residential boiler  might last 20 years.
(Additional information  on  measure savings  and  life-
times can be found  in Resources and Expertise, a forth-
coming product of the Action Plan Leadership Group.)
Developing an Energy Efficiency Plan

The majority of organizations reviewed for this chapter
are acquiring  energy  efficiency  resources for  about
$0.03/lifetime  kWh for electric programs  and  about
$1.30 to $2.00 per lifetime MMBtu for gas program (as
shown previously in Tables 6-1  and 6-2). In many cases,
energy efficiency is being delivered at a cost that is sub-
stantially less than the cost of new supply—on the order
of half the cost of new supply. In addition, in all cases
where information is available, the costs of saved energy
are less than the avoided costs of energy. These organi-
zations  operate in diverse locations  under different
administrative  and  regulatory structures. They do, how-
ever, share many similar best practices when it comes :o
program planning, including one or more of the following:

• Provide programs for all key customer classes.

•Align goals with funding.

•Use cost-effectiveness  tests that are consistent with
  long-term planning.

• Consider building codes and appliance standards when
  designing programs.

• Plan for developing and  incorporating new technology.

•Consider efficiency investments to alleviate transmis-
  sion and distribution constraints.

•Create a roadmap that  documents key program com-
  ponents, milestones, and explicit energy reduction goals.

Provide Programs for All Customer Classes

One concern sometimes raised  when  funding energy
efficiency programs is that all customers are required to
contribute to energy  efficiency  programming, though
not all customers will take advantage of programs once
they are available, raising  the issue that non-participants
subsidize the efficiency upgrades of participants.

While  it  is true  that program participants receive the
direct  benefits  that  accrue from energy efficiency
upgrades,  all customer  classes  benefit  from well-
managed  energy  efficiency programs,  regardless of
whether or not they participate directly. For example, an
evaluation of the New York State Energy Research and
Development Authority's  (NYSERDA's) program  portfolio
concluded that:  "total cost savings for all  customers,
including non participating customers  [in  the New York
Energy $mart Programs] is estimated to be $196 million
for program activities through year-end 2003, increasing
to $420 to $435 million at full implementation" (NYSER-
DA, 2004).
6-18   National Action Plan for Energy Efficiency

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In addition, particularly for programs that aim to accelerate
market adoption of energy efficiency products or services,
there is  often program  "spillover"  to  non-program
participants.  For  example, an  evaluation of  National
Grid's Energy Initiative, Design 2000plus, and other small
commercial  and  industrial  programs  found  energy
efficient measures were installed by non-participants due
to  program  influences  on design  professionals  and
vendors.  The analysis  indicated that "non-participant
spillover from the programs amounted to  12,323,174
kWh in the 2001  program year, which is  approximately
9.2 percent of the total savings produced in 2001  by the
Design  2000plus  and   Energy  Initiative  programs
combined" (National Grid, 2002).

Furthermore,  energy efficiency  programming can  help
contribute  to an overall  lower cost system for all  cus-
tomers over the longer term by helping avoid the need
to purchase energy,  or the need to build new infrastruc-
ture such  as  generation, transmission and distribution
lines. For example:

•The Northwest  Power  Planning  and  Conservation
 Council found in  its Portfolio Analysis that strategies
 that included more conservation had the least cost and
 the least risk (measured in dollars) relative to strategies
 that included less conservation.  The most aggressive
 conservation case had an expected system cost of $1.8
 billion lower and a risk  factor of $2.5 billion less than
 the strategy with the least conservation (NPPC, 2005).

• In its 2005 analysis of energy efficiency and renewable
 energy on natural  gas consumption and price, ACEEE
 states, "It is important  to note  that while the direct
 benefits of energy efficiency investment flow to partic-
 ipating customers, the benefits of falling prices accrue
 to all customers."  Based on their national scenario of
 cost-effective  energy  efficiency opportunities, ACEEE
 found that  total costs for energy efficiency would be
 $8 billion, and would result  in consumer benefits of
 $32 billion in 2010 (Elliot & Shipley,  2005).
'Through cost-effective energy efficiency investments in
  2004, Vermonters reduced their annual electricity use
  by 58 million kWh. These savings, which are expected
  to continue each year for an average of 14 years, met
  44 percent of the growth in the state's energy needs in
  2004 while costing ratepayers just 2.8 cents per kWh.
  That cost is only 37 percent of the cost of generating,
  transmitting,  and  distributing power  to  Vermont's
  homes and  businesses (Efficiency Vermont, 2004).

•The  Massachusetts  Division  of  Energy  noted that
  cumulative  impact on demand  from energy efficiency
  measures installed from 1998 to  2002  (excluding
  reductions from one-time interruptible  programs) was
  significant—reducing demand by 264  megawatt
  (MW). During the summer of 2002,  a reduction of this
  magnitude meant avoiding the need to purchase $19.4
  million worth  of electricity  from  the  spot  market
  (Massachusetts, 2004).

Despite evidence that  both program participants and
non-participants can benefit from energy efficiency pro-
gramming, it is a  best  practice to provide program
opportunities for all customer classes  and  income levels.
This approach is a best practice  because, in most cases,
funding for efficiency programs comes from all customer
classes,  and as mentioned above, program participants
will receive both the indirect benefits of system-wide
savings  and  reliability  enhancements  and  the direct
benefits of program participation.

All  program portfolios reviewed  for this chapter include
programs for  all customer classes.  Program administrators
usually strive to align program  funding  with spending
based on customer class contributions to funds.  It is not
uncommon, however, to have limited cross-subsidization
for  (1) low-income, agricultural, and other hard-to-reach
customers; (2) situations where budgets limit achievable
potential,  and the  most cost-effective energy efficiency
savings are not aligned with customer  class contributions
to energy efficiency funding; and (3) situations where
energy  efficiency savings  are  targeted  geographically
based on  system needs—for example, air conditioner
To create a sustainable, aggressive national commitment to energy efficiency
                                               6-19

-------
turn-ins or greater new construction  incentives that are
targeted to curtail load growth in an  area with a supply
or transmission and distribution need. For programs tar-
geting low-income or other hard-to-reach customers, it
is  not uncommon for them to be implemented  with a
lower benefit-cost threshold, as long as the overall energy
efficiency program portfolio for each customer class (i.e.,
residential,  commercial,  and industrial)  meets cost-
effectiveness criteria.

NYSERDA's program portfolio is a good example  of pro-
grams for all customer classes and segments (see Table 6-5).
   Table 6-5. NYSERDA 2004 Portfolio
Sector
Residential
Low Income
Business
Program
Small Homes
Keep Cool
ENERGY STAR Products
Program Marketing
Multifamily
Awareness/Other
Assisted Multifamily
Assisted Home Performance
Direct Install
All Other
Performance Contracting
Peak Load Reduction
Efficient Products
New Construction
Technical Assistance
All Other
% of Sector
Budget
23%
19%
20%
16%
10%
12%
59%
17%
8%
16%
36%
12%
9%
23%
10%
10%
Nevada Power/Sierra Pacific Power Company's portfolio
provides another example with notable expansion  of
program investments in efficient air conditioning, ENERGY
STAR appliances, refrigerator collection, and renewable
energy  investments  within  a  one-year  timeframe (see
Table 6-6).
Align Goals With Funding

Regardless of program administrative structure and policy
context, it  is a best  practice for organizations to align
funding to explicit goals for energy efficiency over the
near-term and long-term. How quickly an organization is
able to ramp up programs to capture  achievable poten-
tial can vary based on organizational history of running
DSM programs, and the sophistication of  the  market-
place in which a utility operates (e.g., whether there is a
network of home energy raters, ESCOs, or certified heating,
ventilation, and air conditioning [HVAC] contractors).

Utilities or  third-party administrators should set long-
term goals for energy efficiency designed to capture a
significant percentage of the achievable potential energy
savings identified through an energy efficiency potential
study. Setting  long-term  goals  is a  best  practice for
administrators of energy efficiency program  portfolios,
regardless of  policy  models and  whether  they  are  an
investor-owned or a municipal or cooperative  utility, or a
third-party  program administrator. Examples of  how
long-term goals are set are provided as follows:

• In states where  the utility  is  responsible for integrated
  resource planning (the IRP Model), energy efficiency must
  be incorporated  into  the  IRP  This  process generally
  requires a long-term forecast of both  spending and sav-
  ings for energy efficiency at an  aggregated level that is
  consistent with the time horizon of the IRP—generally at
  least 10 years. Five- and ten-year goals can then be devel-
  oped based on the resource need. In states without an
  SBC, the budget for energy efficiency is usually a revenue
  requirement  expense item,  but can be a capital invest-
  ment or a  combination  of the  two. (As  discussed in
  Chapter 2: Utility Ratemaking & Revenue Requirements,
  capitalizing  efficiency program investments rather than
  expensing them can reduce short-term rate  impacts.)

• Municipal or cooperative  utilities that  own  generation
  typically set efficiency goals as part of a resource plan-
  ning process. The budget for energy efficiency is usually
  a revenue requirement expense item, a capital expendi-
  ture, or a combination  of the two.
6-20   National Action Plan for Energy Efficiency

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   Table 6-6. Nevada Resource Planning Programs

Air Conditioning Load Management
High-Efficiency Air Conditioning
Commercial Incentives
Low-Income Support
Energy Education
ENERGY STAR Appliances
School Support
Refrigerator Collection
Commercial New Construction
Other - Miscellaneous & Technology
Total Nevada Resource Planning Programs
SolarGenerations
Company Renewable - PV
California Program
Sierra Natural Gas Programs
Total All Programs
2005 Budget
$3,450,000
2,600,000
2,300,000
1,361,000
1,205,000
1,200,000
850,000
700,000
600,000
225,000
$14,491,000
1,780,075
1,000,000
370,000
—
$17,641,075
2006 Budget
$3,600,000
15,625,000
2,800,000
1,216,000
1,243,000
2,050,000
850,000
1,915,000
600,000
725,000
$30,624,000
7,220,000
1,750,000
563,000
820,000
$40,977,000
•A resource portfolio standard  is typically set at a per-
 centage of overall  energy or  demand, with program
 plans and budgets developed  to achieve  goals at the
 portfolio level. The  original standard can be developed
 based on achievable potential from a potential study,
 or as a percentage  of growth from a base year.

1 In most SBC  models, the funding  is determined  by a
 small volumetric charge on each customer's utility bill.
 This  charge is then  used as a basis for determining the
 overall budget for energy efficiency programming—
 contributions by each  customer  class are used  to
 inform the proportion of funds that should  be targeted
 to each customer class. Annual goals are then based on
 these budgets and a  given program portfolio.  Over
 time, the goal of the program should be to capture a
 large percentage of achievable potential.
• In most gas programs, funding can be treated as an
  expense, in a  capital budget, or a  combination (as is
  the case in some of the electric examples shown previ-
  ously). Goals  are based on the budget  developed for
  the time period of the plan.

Once  actual program  implementation starts, program
experience is usually the best basis for developing future
budgets and goals for individual program years.

Use Cost-Effectiveness Tests That Are Consistent
With  Long-Term Planning

All  of the organizations reviewed  for this chapter  use
cost-effectiveness tests to ensure that measures and pro-
grams are consistent with valuing the benefits and costs
of  their  efficiency investments relative  to  long-term
To create a sustainable, aggressive national commitment to energy efficiency
                                              6-21

-------
supply options. Most of the organizations reviewed use
either the total resource cost (TRC), societal, or program
administrator test (utility test) to screen measures. None
of the organizations reviewed for this chapter used the
rate  impact measure  (RIM)  test as a primary decision-
making  test.5 The key  cost-effectiveness tests  are
described as follows, per Swisher, et al. (1997), with key
benefits and costs further  illustrated in Table 6-7.

• Total Resource  Cost CIRO Te^t   Compares  the total
  costs and benefits of  a  program, including costs  and
  benefits to the utility and the participant and the avoided
  costs of energy supply.

•Societal Test. Similar to the TRC Test, but includes the
  effects of other societal benefits and costs such as envi-
  ronmental impacts, water savings, and national security.

• Utility/Program  Administrator  Test  Assesses  benefits
  and costs from the program administrator's perspective
  (e.g., benefits of  avoided  fuel and  operating capacity
  costs compared to rebates and administrative costs).

• Participant Test. Assesses benefits and costs from a par-
  ticipant's perspective (e.g., the reduction in customers'
  bills, incentives paid  by  the  utility, and tax credits
  received as compared to out-of-pocket expenses such
  as  costs of equipment purchase,  operation, and main-
  tenance).

• Rate Impact Measure (RIM).  Assesses  the  effect  of
  changes in  revenues and operating costs caused by a
  program on  customers' bills and  rates.

Another metric  used  for  assessing cost-effectiveness  is
the cost of conserved energy, which is calculated in cents
per  kWh  or dollars per thousand  cubic feet (Mcf).  This
measure does not depend on a future projection of energy
prices and is easy to calculate; however, it does not fully
capture the future market price  of energy.
                                                       An overall energy  efficiency  portfolio  should pass the
                                                       cost-effectiveness test(s) of the jurisdiction. In an IRP sit-
                                                       uation, energy efficiency resources are compared to new
                                                       supply-side options-essentially the program  administra-
                                                       tor or utility  test. In cases where utilities have  divested
                                                       generation, a  calculated avoided  cost or a wholesale
                                                       market price projection is used to represent the genera-
                                                       tion benefits. Cost-effectiveness tests are appropriate to
                                                       screen  out poor program design,  and to identify pro-
                                                       grams in markets that have been transformed and might
                                                       need to be  redesigned  to continue. Cost-effectiveness
                                                       analysis is important but must be supplemented  by other
                                                       aspects of the planning process.

                                                       If the TRC or societa tests are used,  "other resource bene-
                                                       fits" can include environmental benefits, water  savings, and
                                                       other fuel savings. Costs include all program costs (admin-
                                                       istrative, marketing, incentives, and  evaluation) as well as
                                                       customer costs. Future benefits from emissions trading (or
                                                       other regulatory approaches that provide payment for emis-
                                                       sion credits) could be treated as additional benefits in any of
                                                       these models. Other benefits of programs can include job
                                                       impacts,  sales generated, gross  state product added,
                                                       impacts from  wholesale  price reductions,  and  personal
                                                       income (Wisconsin, 2006; Massachusetts, 2004).

                                                           Example of Other Benefits
                                                           The Massachusetts Division of  Energy Resources
                                                           estimates that  its 2002 DSM programs produced
                                                           2,093  jobs, increased disposable income by  $79
                                                        ;   million, and  provided savings to all customers of
                                                        '   $19.4 million due to lower wholesale energy clear-
                                                        •   ing prices (Massachusetts, 2004).
                                                        At a minimum, regulators require  programs to be cost-
                                                        effective at the sector level (residential, commercial, and
                                                        industrial) and typically at the  program  level as well.
                                                        Many program administrators bundle measures under a
                                                        single program umbrella when,  in reality, measures are
                                                        delivered to customers through  different strategies and
                                                        marketing channels. This process allows program admin-
5 The RIM test is viewed as less certain than the other tests because it is sensitive to the difference between long-term projections of marginal or mgrke~:
 costs and long-term projections of rates (CEC, 2001).
 6-22   National Action Plan for Energy Efficiency

-------
   Table 6-7. Overview of Cost-Effectiveness Tests
                           Benefits
                            Costs
                          Energy   Demand
               Externalities Benefits  Benefits
                          G.T&D   G.T&D
 lota! Resource
 Cost Test

 Societal Test

 Utility Test-'
 Administrator
 fest

 Rate Impact
 Test

 P.-irticipant Tost
    G, T&D = Generation, Transmission, and Distribution
X
x
.1
x
x
X
X
X

X
X
X
 Other
Resource
Benefits
   X

   X
Impact      Program     Program   rnซ*nmor
  On    Implementation  Evaluation  t-uซฐ'ner
Rates        Costs        Costs      Losts
X
X
X
X
X
	 V-
X
X
X
1 	 	 -
x


istrators to  adjust to market  realities during program
implementation. For example, within a customer class or
segment, if a high-performing and well-subscribed pro-
gram or measure is out-performing a program or meas-
ure that is  not meeting program targets, the program
administrator  can redirect resources without seeking
additional regulatory approval.

Individual programs should be screened on a regular basis,
consistent with the regulatory schedule—typically, once a
year.  Individual  programs in some customer segments,
such as low income, are not always required to be cost-
effective, as they provide other benefits  to society that
might not all be quantified  in the cost-effectiveness tests.
The same is true  of education-only programs that have
hard-to-quantify benefits in terms of energy impacts. (See
section on conducting impact evaluations for information
related to evaluating energy education programs.)

Existing measures should be screened by the program
administrator at  least every two years, and  new  meas-
ures should be screened annually to ensure they are per-
forming as anticipated.  Programs should  be reevaluated
and updated from time to time to reflect new methods,
  technologies, and systems. For example, many programs
  today include measures such as T-5 lighting that did not
  exist  five to ten years ago.

  Consider Building Codes and Appliance
  Standards When Designing Programs
  Enacting state and federal codes and standards for new
  products and buildings is often a cost-effective opportunity
  for energy savings. Changes to building codes and appli-
  ance  standards are often considered an intervention that
  could be deployed in  a cost-effective way to  achieve
  results.  Adoption of state codes and standards in many
  states requires an act of legislation beyond the scope of
  utility programming, but utilities  and other third-party
  program administrators can and do  interact with state
  and federal codes and standards in several ways:

  • In the  case of building codes, code compliance  and
   actual building performance can lag behind enactment
   of legislation. Some energy efficiency program admin-
   istrators  design  programs  with  a  central  goal of
   improving code  compliance.  Efficiency Vermont's
   ENERGY  STAR  Homes program (described in the box
   on  page 6-24) includes  increasing compliance with
   Vermont Building Code as a specific program objective.
                                                                                                     6-23

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 The California investor owned utilities also are working
 with the national  ENERGY STAR program to ensure
 availability  of ENERGY STARATitle  24 Building Code-
 compliant  residential lighting fixtures and to ensure
 overall compliance with their new residential building
 code through their ENERGY STAR Homes program.

• Some  efficiency  programs fund activities to advance
 codes and  standards. For  example, the California lOUs
 are funding a long-term initiative to contribute expertise,
 research, analysis, and other kinds of support to help the
 California Energy Commission (CEC) develop and adopt
 energy  efficiency  standards.  One  rationale  for utility
 investment  in advancing codes and standards is that util-
 ities can lock in a baseline of energy savings and free up
 program funds to work on efficiency  opportunities that
 could not otherwise be realized. In California's case, the
 lOUs also developed a method for estimating savings
 associated  with their codes and standards work. The
 method was accepted by the California  Public Utilities
 Commission, and  is formalized in the  California
 Energy  Efficiency  Evaluation  Protocols:   Technical,
 Methodological,  and Reporting  Require-ments   for
 Evaluation Professionals (CPUC, 2006).

Regardless of whether they are a component of an energy
efficiency  program, organizations have found that  it is
essential to coordinate across multiple states and regions
when pursuing state codes and standards, to ensure that
retailers and manufacturers can respond appropriately in
delivering products to market.

Program administrators must be aware  of codes and
standards. Changes in codes and standards affect the
baseline against  which  future program  impacts are
measured. Codes and standards should be explicitly con-
sidered  in planning to prevent double  counting. The
Northwest Power and Conservation Council (NWPCC)
explicitly models both state codes and federal standards
in its long-term plan (NWPCC, 2005).

Plan  for  Developing  and  Incorporating  New
Technology

Many of the organizations  reviewed have  a history  of
providing programs that change over time to accommo-
date changes in the market and the introduction of new
technologies. The  new technologies are  covered  using
one or more of the following approaches:

•They are included in research and development  (R&D)
  budgets  that  do not need to pass cost-effectiveness
  tests,  as they are, by  definition, addressing  new  or
  experimental  technologies. Sometimes R&D funding
  Efficiency Vermont ENERGY STAR Homes Prog
  In the residential new construction segment, Efficiency
  Vermont partners with the national ENERGY STAR pro-
  gram to deliver whole house performance to its cus-
  tomers and meet both resource acquisition and
  market transformation goals. Specific objectives of
  Efficiency Vermont's program are to:

  • Increase market recognition of superior construction

  • Increase compliance with the Vermont Building Code

  • Increase penetration of cost-effective energy
    efficiency measures
  • Improve occupant comfort, health, and safety
    (including improved indoor air quality)
 am
 • Institutionalize Home Energy Rating Systems (HERS)
 articipating homebuilders agree to build to the pro-
 gram's energy efficiency standards and allow homes
 o be inspected by an HERS rater. The home must
 core 86+ on the HERS inspection and include four
 energy efficient light fixtures, power-vented or sealed
 rombustion equipment, and an  efficient mechanical
 entilation system with automatic controls. When a
 iome passes, builders receive a  rebate check, pro-
 gram certificate, an ENERGY STAR Homes certificate,
 md gifts  Efficiency Vermont ENERGY STAR
 -lomes Program saved more than 700  MWh
 with program spending of $1.4 million in 2004.

 >ource: Efficiency Vermont, 2005
6-24   National Action Plan for Energy Efficiency

-------
  comes from  sources other  than  the utility  or  state
  agency. Table 6-8 summarizes R&D activities of several
  organizations reviewed.

• They are  included in pilot programs that are funded as
  part of an overall program portfolio  and are not indi-
  vidually subject to cost-effectiveness tests.

• They are tested in limited quantities under existing pro-
  grams  (such as commercial  and industrial  custom
  rebate programs).

Technology innovation in electricity use has been the cor-
nerstone of global economic progress for more than 50
years. In the future, advanced industrial processes, heating
and cooling, and  metering systems will play very impor-
tant roles  in supporting  customers' needs for  efficient
use of  energy. Continued development  of  new,  more
efficient technologies is critical for  future industrial and
commercial processes. Furthermore, technology innovation
that targets improved energy efficiency and energy man-
agement will enable society to advance and sustain ener-
gy efficiency in the absence of government-sponsored or
regulatory-mandated programs. Robust and competitive
consumer-driven markets are needed for energy efficient
devices and energy efficiency service.

The  Electric   Power  Research  Institute  (EPRI)/U.S.
Department of Energy (DOE) Gridwise collaborative and
the  Southern  California  Edison  (SCE)  Lighting Energy
Efficiency Demand Response Program are two examples
of research  and development activities:

• The EPRI IntelliGnd Consortium is an industry-wide ini-
  tiative and public/private  partnership  to develop  the
  technical  foundation  and  implementation tools to
  evolve the power delivery grid into an integrated energy
  and communications system on a continental scale. A
  key development by this consortium  is the IntelliGrid
  Architecture,  an  open-standards-based  architecture
   Table  6-8. Research & Development (R&D) Activities of Select Organizations
Program
Administrator
PG&E
NYSERDA
BPA
SCE
R&D Funding Mechanism(s)
CEC Public Interest Energy Research (PIER) performs research from
California SBC funding (PG&E does not have access to their bills'
SBC funds); other corporate funds support the California Clean
Energy Fund
SBC funding
In rates
CEC Public Interest Energy Research (PIER) performs research from
California SBC funding (SCE does not have access to their bills'
SBC funds). Procurement proceedings and other corporate funds
support Emerging Technologies and Innovative Design for Energy
Efficiency programs.
R&D as % of Energy
Efficiency Budget
1%a,b
13%c-d
6%e'f
5%9'h.'
Examples of R&D Technologies/
Initiatives Funded
California Clean Energy Fund - New
technologies and demonstration projects
Product development, demonstration
and evaluation, university research, tech-
nology market opportunities studies
PNL / DOE GridWise Collaborative,
Northwest Energy Efficiency Alliance,
university research
Introduction of emerging technologies
(second D of RD&D)
 a [Numerator] $4 million in 2005 for Californial Clean Energy Fund (CCEF, 2005).
 b [Denominator] $867 million to be spent 2006-2008 on energy efficiency projects not including evaluation, measurement, and validation (CPUC,
  2005). 1/3 of full budget used for single year budget ($289 million).
 c [Numerator] $17  million for annual energy efficiency R&D budget consists of "residential ($8 M), industrial ($6 M), and transportation ($3 M)"
  (G. Walmet, NYSERDA, personal communication, May 23, 2006).
 d [Denominator] $134 M for New York Energy $mart from 3/2004-3/2005 (NYSERDA, 2005b).
 e [Numerator] BPA funded the Northwest Energy Efficiency Alliance with $10 million in 2003. [Denominator] The total BPA energy efficiency alloca-
  tion was $138 million (Blumstein, et al., 2005).
 ' [Note]  BPA overall budgeting for energy efficiency increased in subsequent years (e.g., $170 million in 2004 with higher commitments going to an
  average of $245 million from 2006-2012) (Alliance to Save Energy, 2004).
 g Funding for the statewide Emerging Technologies program will increase in 2006 to $10 million [Numerator] out of a total budget of $581 million
  [Denominator] for utility energy-efficiency programs (Mills and Livingston, 2005).
 h [Note] Data from Mills and Livingston (2005) differs from $675 million 3-yr figure from CPUC (2005).
 i Additional 3% is spent on Innovative Design for Energy Efficiency (InDEE) (D. Arambula, SCE, personal communication, June 8, 2006).
To cieate a sustainable, aggressive national commitment to energy efficien
                                                  6-25

-------
 for integrating the data communication networks and
 smart equipment on the grid and on consumer prem-
 ises. Another key development is the consumer portal —
 essentially, a  two-way  communication link between
 utilities and their customers to  facilitate  information
 exchange (EPRI, 2006). Several efficiency program admin-
 istrators  are  pilot  testing GridWise/lntelligrid as
 presented in the box below.
• The Lighting Energy  Efficiency l)etn,:'ina  *?(-">/
  Program is  a program  proposed by  SCE.  It will use
  Westinghouse's two-way wireless dimmable energy effi-
  ciency T-5 fluorescent lighting  as a retrofit for existing
  T-12 lamps.  SCE will be able to dispatch these lighting
  systems using wireless technology. The technology will be
  piloted  in small  commercial buildings, the educational
  sector, office buildings, and industrial facilities and could
  give SCE the ability to reduce load by 50 percent on those
  installations. This is  an  excellent example of combining
  energy efficiency and direct load control technologies.

Both EPRI and ESource (a for-profit, membership-based
energy information service)  are exploring opportunities
to expand their efforts  in these areas. ESource is also
considering  developing  a  database of  new energy
efficiency  and load response technologies.  Leveraging
R&D resources through regional and national partnering
efforts has been successful in the past with energy effi-
ciency technologies. Examples include compact fluores-
cent lighting, high-efficiency ballasts and new washing
machine technologies.  Regional and  national  efforts
send a consistent signal to manufacturers, which can be
critical to increasing R&D activities.

Programs must be able to incorporate new technologies
over time. As new technologies are considered, the pro-
grams must  develop strategies to overcome the barriers
specific to these technologies to increase their acceptance.
Table 6-9 provides some examples of new technologies,
challenges, and possible strategies for overcoming these
challenges. A cross-cutting challenge for many of these
technologies is that average rate designs do not send a
price  signal  during periods of peak demand. A strategy
for overcoming this barrier would be to investigate time-
sensitive rates (see Chapter 5: Rate Design for additional
information).
   Pilot Tests of GridWise/lntelligrid
   GridWise Pacific Northwest Demonstration Projects
   These projects are designed to demonstrate how
   advanced, information-based technologies can be
   used to increase power grid efficiency, flexibility, and
   reliability while reducing the need to build additional
   transmission and distribution  infrastructure. These
   pilots are funded by DOE's Office of Electricity
   Delivery and Energy Reliability.
   Olympic Peninsula Distributed Resources
   Demonstration
   This project will integrate  demand response and dis-
   tributed resources to reduce congestion on the grid,
   including demand response with automated control
   technology, smart appliances, a virtual real-time
 market, Internet-based communications, contract
 options for customers, and the use of distributed
 (generation.
  rid-Friendly Appliance Demonstration
 n this project, appliance controllers will be used in
 Doth clothes dryers and water heaters to detect fluc-
 :uations in frequency that indicate there is stress in
 he grid, and will respond by reducing the load on
 that appliance.
 These pilots include: Pacific Northwest National
 Laboratory, Bonneville Power Administration,
 'adficCorp, Portland General Electric, Mason County
 3UD #3, Clallam County PUD, and  the city of Port
 Angeles.
6-26   National Action Plan for Energy Efficiency

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Table 6-9. Emerging Technologies for Programs
„ ™* Description Availability
Program r '

Smart Grid/
i
Smart grid technologies include both customer-side Available in pilot
GridWise and grid-side technologies that allow for more i situations
technologies efficient operation of the grid. i






Smart
appliances/
Smart Homes



Homes with gateways that would allow for control
of appliances and other end-uses via the Internet.




Load control of
A/C via smart
thermostat


A/C controlled via smart thermostat.

Communication can be via wireless, power line
carrier (PLC) or Internet.


i
i
Dynamic Providing customers with either real time or critical
pricing/critical
peak pricing/
thermostat
control with
enhanced
metering


Control of
lighting via
wireless, power
line carrier
or other
communication
technologies
peak pricing via a communication technology.
Communication can be via wireless, PLC, or
Internet. Customers can also be provided with
educational materials.




Using direct control to control commercial lighting
during high price periods.





.
T-5s j Relatively new lighting technology for certain






New generation
tankless water
heaters





applications.





Tankless water heaters do not have storage tanks
and do not have standby losses. They can save


Available





Widely available







Available








Recently available






Widely available






Widely available
energy relative to conventional water heaters in
some applications. Peak demand implications are
not yet known.

i
.
Key Key _ .
Challenges Strategies txampies

Cost Pilot programs

Customer R&D programs
Acceptance

Communication
Protocols

..
Cost Pilot programs

Customer Customer education
Acceptance

GridWise pilot
in Pacific NW







GridWise pilot
in Pacific NW


Communication
Protocols ;
Cost Used to control
loads in congested
Customer
acceptance




Cost

Customer
acceptance

Split incentives in
deregulated markets

Regulatory barriers
Cost

Customer
acceptance

Contractor
acceptance
Cost

Customer
acceptance
Contractor
acceptance

Cost
Customer
acceptance

Contractor

situation

Pilot and full-scale
programs

Customer education
Pilot and full-scale
Programs

Used in

Long Island Power
Authority (LIPA),
Austin Energy,
Utah Power and
Light, ISO New
England


Georgia (large
users) Niagara
Mohawk, California
Peak Pricing
congested areas j Experiment, Gulf
Power
Customer
education
j
R&D programs

Pilot programs




Add to existing
SCE pilot using
wireless

NYSERDA pilot
with power line
carrier control

Included in
programs as a most large-scale
new measure programs




Add to existing
programs as a

More common
in the EU
new measure


!

acceptance i
Some load control technologies will require  more than
R&D activities  to  become widespread.  To  fully capture
and  utilize some  of  these  technologies, the following
four building blocks are needed:
  •• ,;•  ; •   • ••   .,,'   •' •••   Interactive communica-
tions that allow for two-way flow of price information
and decisions would add  new  functionality to the
electricity system.
                                                                                                      6-27

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• Innovative rates ana requ/af/on  Regulations are needed
  to provide adequate incentives for energy efficiency
  investments to both suppliers and customers.

• Innovative markets Market design  must ensure that
  energy efficiency and load response measures that are
  advanced by regulation  become self-sustaining  in the
  marketplace.

• Smart end-use devices.  Smart  devices are needed to
  respond to price signals and facilitate the management of
  the energy use of individual and networked appliances.

In addition, the use of open  architecture systems is the
only long-term way to take existing non-communicating
equipment into an energy-efficient  future that can use
two-way communications to  monitor and diagnose
appliances  and equipment.

Consider  Efficiency Investments to Alleviate
Transmission and Distribution Constraints

Energy efficiency  has a history  of providing value by reduc-
ing  generation investments. It should also be considered
with other demand-side  resources,  such  as demand
response, as a potential resource to defer or avoid  invest-
ments in transmission and distribution systems. Pacific Gas
and Electric's (PG&E) Model Energy Communities Project (the
Delta Project) provides one of the first examples  of this
approach.  This  project was conceived to  test whether
demand resources could be used as a least cost resource to
defer the capital expansion of the transmission and distribu-
tion  system in a constrained area. In this case, efforts were
focused on the  constrained  area, and  customers  were
offered versions of existing  programs and additional meas-
ures to  achieve  a significant reduction  in the constrained
area (PG&E, 1993). A recently approved settlement at the
Federal Energy Regulatory Commission (FERC) allows energy
efficiency along with load response and distributed genera-
tion to participate in the Independent System Operator New
England (ISO-NE) Forward  Capacity Market (FERC, 2006;
FERC, 2005). In addition. Consolidated Edison has success-
fully used a Request For Proposals (RFP) approach to defer
distribution upgrades in four substation areas with contracts
totaling 45  MW. Con Ed is currently in a second round of
solicitations for 150 MW (NAESCO,  2005).  Recent  pilots
using  demand response, energy efficiency, and  intelligent
grid are proving promising as shown in the BPA example in
the box on page 6-29.

To evaluate strategies for deferring transmission and distribu-
tion investments, the benefits and costs of energy efficiency
and other demand resources are compared to the cost of
deferring or avoiding a distribution or transmission upgrade
(such  as a substation upgrade)  in a constrained  area. This
cost balance is influenced by  location-specific transmission
and distribution costs, which can vary greatly.

Create a Roadmap of Key Program Components,
Milestones, and Explicit Energy  Use Reduction
Goals
Decisions regarding the  key  considerations discussed
throughout this section are used to inform the develop-
ment of an energy efficiency plan,  which serves as a
roadmap with  key program  components, milestones,
and explicit energy reduction goals.

A well-designed plan includes  many of the elements dis-
cussed in this section  including:

• Budgets (see section titled  "Leverage  Private-Sector
 Expertise,  External  Funding, and Financing" for informa-
 tion  on  the  budgeting  processes  for the  most
 common policy models)

— Overall
— By program
• Kilowatt,  kWh,  and Mcf savings goals overall  and by
 program

— Annual savings
— Lifetime savings
• Benefits and costs overall and by program

• Description of any shareholder incentive mechanisms
 6-28   National Action Plan for Energy Efficiency

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   Bonneville Power Administration (BPA) Transmission  Planning
   BPA has embarked on a new era in transmission
   planning. As plans take shape to address load
   growth, constraints, and congestion on the transmis-
   sion system, BPA is considering measures other than
   building new lines, while maintaining  its commit-
   ment to provide reliable transmission service. The
   agency, along with others in the region, is exploring
   "non-wires solutions" as a way to defer large
   construction projects.

   BPA defines non-wires solutions as the broad array
   of alternatives including, but not limited to, demand
   response, distributed generation, conservation  meas-
   ures, generation siting, and pricing strategies that
   individually, or in combination, delay or eliminate the
need for upgrades to the transmission system. The
industry also refers to non-wires solutions as non-
construction alternatives or options.

BPA has reconfigured its transmission planning
process to include an initial screening of projects to
assess their potential for a non-wires solution. BPA is
now committed to using non-wires solutions screening
criteria for all capital transmission projects greater
than $2 million, so that it becomes an institutional-
ized part of  planning. BPA is currently sponsoring a
number of pilot projects to test technologies, resolve
institutional  barriers, and build confidence in using
non-wires solution.
For each program, the plan should include the following:

• Program design description

• Objectives

•Target market

• Eligible measures

• Marketing plan

• Implementation strategy

•Incentive strategy

• Evaluation plan

• Benefit/cost outputs

• Metrics for program success

• Milestones

The plan serves as  a road-map for programs. Most pro-
gram  plans, however, are modified over time  based  on
changing conditions (e.g., utility supply or market changes)
and  program  experience. Changes from the  original
roadmap should be both documented and justified. A plan
that includes all of these elements is an appropriate start-
ing point for a regulatory filing. A well-documented plan is
also a  good communications  vehicle for informing and
educating stakeholders. The plan should also include a
description of any pilot programs and R&D activities.
 Energy Efficiency Program  Design
 and Delivery

The organizations reviewed for this chapter have learned
that program success is built over time by understanding
the markets in which efficient products and services are
delivered,  by addressing the wants and needs of their
customers, by establishing relationships with customers
and suppliers, and by designing and delivering programs
accordingly.

• They have learned that it is essential to program suc-
 cess to coordinate with private market actors and other
 influential  stakeholders, to ensure that they  are well
 informed about  program  offerings  and  share  this
 information with their customers/constituents.
To create a sustainable, aggressive national commitment to energy efficiency
                                               6-29

-------
• Many  of the organizations  reviewed go well beyond
  merely informing businesses and  organizations,  by
  actually partnering with them in the design and delivery
  of one or more of their efficiency programs.

• Recognizing  that  markets are not defined  by  utility
  service territory,  many  utilities and  other third-party
  program administrators  actively  cooperate with one
  another and  with  national programs, such  as ENERGY
  STAR,  in the  design and delivery of their programs.

This  section discusses  key best practices that emerge
from  a  decade or  more of  experience designing and
implementing  energy efficiency programs.

Begin With the Market in Mind

Energy  efficiency  programs should complement, rather
than compete with, private and other existing markets
for energy efficient products  and services. The rationale
for utility or third-party investment in efficiency program-
ming is  usually based on the concept that within these
markets, there are barriers that need to be overcome to
ensure that an efficient product or service is chosen over
a  less efficient product  or standard  practice. Barriers
might include  higher initial cost to the consumer, lack of
knowledge on the part of the supplier or the customer,
split incentives between the tenant who pays the utility
bills  and the landlord  who owns  the  building, lack of
supply for a product or service, or lack of time (e.g., to
research efficient options, seek multiple bids—particularly
during emergency replacements).

Conduct a Market Assessment
Understanding how markets function is a key to successful
program implementation, regardless of whether a program
is designed  for resource acquisition, market  transforma-
tion, or  a hybrid approach. A market assessment can be a
valuable investment to  inform program design and  imple-
mentation. It helps establish  who  is part of the market
(e.g., manufacturers,  distributors,  retailers,  consumers),
what the key barriers are to greater energy efficiency from
the producer or consumer perspectives, who are the key
trend-setters in the business  and  the  key influencers in
consumer decision-making,  and what  approaches rright
work  best  to  overcome barriers to greater  supply  and
investment in energy efficient options, end/or  uptake  of a
program. A critical part of completing a market assessment
is  a  baseline measurement of  the goods and services
involved and the  practices,  attitudes, behaviors, factors,
and conditions of the  marketplace (Feldman,  1994). In
addition to  informing  program  design and implementa-
tion, the baseline assessment  also helps  inform program
evaluation metrics, and serves as a  basis for which future
program impacts  are measured. As such, market assess-
ments are usually conducted  by independent third-party
evaluation professionals. The extent and needs of a market
assessment can vary great y. For well-established program
models, market assessments are somewhat less involved,
and can rely on existing program experience and literature,
with the goal of understanding local differences and estab-
lishing the local or regional baseline for the targeted energy
efficiency product or service.

Table  6-10 illustrates some of the key  stakeholders,  bar-
riers to energy efficiency, and program strategies that are
explored in a  market assessment, and are useful for
considering when designing programs.

Solicit Stakeholder Input
Convening stakeholder advisory groups from the onset
as part  of the  design  process is valuable for  obtaining
multiple perspectives on the need and nature of planned
programs.  This process also serves to improve the  pro-
gram design,  and provides a base of program support
within the community

Once programs have been operational for a while, sta
-------
    Table 6-10.  Key Stakeholders, Barriers,  and  Program Strategies
    by Customer Segment
    Customer
    Segment

 Large
 Commercial
 (4 Industrial
 Retrofit
Sm.ili
Commercial
 Commercial &
 industrial New
 Construction
 Residential
 Lxisting Homes
 Residential
 New Homes
     i family
  ~>vu Income
           Key Stakeholders

 • Contractors
 > Building owners and operators
 i Distributors: lighting, HVAC, motors, other
 > Product manufacturers
 i Engineers
 ' Energy services companies
 > Distributors: lighting, HVAC, other
 • Building owners
 • Business owners
 • Local independent trades

 • Architects
 • Engineers
 > Building and energy code officials
 > Building owners
 > Potential occupants
 > Distributors: appliances, HVAC, lighting
 > Retailers: appliance, lighting, windows
 • Contractors: HVAC, insulation, remodeling
 > Homeowners
• Contractors: general and HVAC
• Architects
• Code officials
• Builders
• Home buyers
ป Real estate agents
• Financial institutions

ซ Owners and operators
• Contractors
• Code officials
• Tenants

• Service providers: Weatherization
  Assistance Program (WAP), Low-Income
  Home Energy Assistance Program (LIHEAP)
• Social service providers: state and local
  agencies
• NGOs and advocacy groups
• Credit counseling organizations
• Tenants
                                                              Key Program Barriers

                                                      • Access to capital
                                                      • Competing priorities
                                                      ซ Lack of information
                                                      • Short-term payback (<2 yr) mentality
                                                        > Access to capital
                                                        • Competing priorities
                                                        > Lack of information
                                                       > Project/program timing
                                                       • Competing priorities
                                                       > Split incentives (for rental property)
                                                       ' Lack of information
                                                       • Higher initial cost
                                                       • Higher initial cost
                                                       • Lack of information
                                                       • Competing priorities
                                                       > Inexperience or prior negative experience
                                                        w/technology (e.g., early compact
                                                        florescent lighting)
                                                       • Emergency replacements

                                                       ป Higher initial cost
                                                       • Split incentives: builder is not the
                                                        occupant
                                                      * Split incentives
                                                      * Lack of awareness
                                                        Program funding
                                                        Program awareness
                                                        Bureaucratic challenges
       Key Program Strategies

• Financial incentives (rebates)
• Performance contracting
• Performance benchmarking
• Partnership with ENERGY STAR
> Low interest financing
• Information from unbiased sources
• Technical assistance
• Operations and maintenance training

• Financial incentives (rebates)
• Information from unbiased sources
• Direct installation
• Partnership with ENERGY STAR

• Early intervention (ID requests for hook-up)
• Design assistance
• Performance targeting/benchmarking
• Partnership with ENERGY STAR
> Training of architects and engineers
• Visible and ongoing presence in design
 community
• Education on life cycle costs

> Financial incentives
. Partnership with ENERGY STAR
• Information on utility Web sites, bill inserts,
 and at retailers
• Coordination with retailers and contractors
> Partnership with ENERGY STAR
• Linking efficiency to quality
• Working with builders
• Building code education & compliance
• Energy efficient mortgages
 Financial incentives
 Marketing through owner and operator
 associations
i Consistent eligibility requirements with
 existing programs
• Direct installation
• Leveraging existing customer channels for
 promotion and delivery
• Fuel blind approach
To be successful, stakeholder groups should focus on the
big  picture, be well  organized,  and be representative.
Stakeholder groups usually provide  input  on  budgets,
allocation   of   budgets,  sectors  to  address,  program
design, evaluation, and incentives.
                                                  usu-;: to C.u-itoswt and  Trade Ally Needs
                                                  Successful energy efficiency programs do not exist without
                                                  customer and trade ally participation and  acceptance of
                                                  these technologies.  Program designs should be tested
                                                  with  customer market research before finalizing offerings.
                                                  Customer research could  include surveys,  focus groups,
                                                                                                                            6-31

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  Best Practice: Solicit Stakeholder Input

  Minnesota's Energy Efficiency Stakeholder Process
  exemplifies the best practice of engaging stake-
  holders in  program design. The Minnesota Public
  Utility Commission hosted a roundtable with the
  commission, utilities, and other stakeholders to
  review programs. Rate implications and changes to
  the programs  are worked out through this collabo-
  rative and  drive program design (MPUC, 2005).
  Successful stakeholder processes generally have the
  following attributes:
  • Neutral facilitation of meetings.

  • Clear objectives for the group overall and for each
   meeting.

  • Explicit definition of stakeholder  group's  role in
   program planning (usually advisory only).

  • Explicit and fair processes for  providing input.

  • A timeline for the stakeholder process.
forums, and in-depth interviews. Testing of incentive levels
and existing market conditions by surveying trade allies
is critical for good program design.

Use Utility Channels and Brand
Utilities have existing channels for providing information
and service offerings to their customers. These include
Web sites, call centers, bill stuffers, targeted newsletters,
as well  as public  media.  Using these channels takes
advantage of existing infrastructure and expertise,  and
provides customers with energy information in the way
that they are accustomed to obtaining it. These methods
reduce the time and expense of bringing information to
customers. In cases where  efficiency  programming  is
delivered by a third party, gaining access  to  customer
data and  leveraging existing  utility channels  has been
highly valuable for program design and implementation.
In cases  such as  Vermont (where the utilities are  not
responsible for running programs), it has been  helpful to
have linkages from the utility  Web sites  to  Efficiency
Vermont's programs, and to establish Efficiency Vermont
as a brand that the utilities leverage to deliver information
about efficiency to their customers.

Promote the Other Benefits of Energy Efficiency
and Energy Efficient Equipment
Most customers are interested in reducing energy con-
sumption  to  save  money. Many,  however, have other
motivations for replacing equipment or renovating space
that are consistent with energy efficiency improvements.
For example, homeowners  might replace their heating
system to  improve  the comfort of their home. A furnace
with a variable speed drive fan will further increase com-
fort (while saving energy) by providing better distribution
of both heating and  cooling throughout the home and
reducing fan motor noise. It is a best practice for  pro-
gram administrators  to highlight these features where
non-energy claims  can be substantiated.

Coordinate With Other Utilities and Third-Party
Program Administrators
Coordination with  other utilities and third-party program
administrators is also important. Both program allies and
customers prefer  programs  that are consistent  across
states and regions. This  approach  reduces transaction
costs for customers and trade allies and provides consis-
tent messages that avoid confusing the market. Some
programs  can be  coordinated at the  regional level by
entities  such  as Northeast Energy Efficiency Partnership
(NEEP), the Northwest Energy Efficiency Alliance, and the
Midwest Energy Efficiency Alliance. Figure 6-1 illustrates
the significant  impact that initiative  sponsors of the
Northeast Lighting and Appliance Initiative (coordinated
regionally by NEEP) have been able to have on the mar-
ket for  energy-efficient clothes washers by working  in
coordination over  a long time period. NEEP estimates
the program is saving an estimated  36 million kWh
per year, equivalent to the annual electricity needs
of 5,000 homes (NEEP, undated).

Similarly, low-income programs benefit from coordina-
tion with  and use of the same eligibility criteria as the
federal  Low-Income  Home  Energy  Assistance Program
(LIHEAP) or Weatherization  Assistance  Program (WAP).
These programs have existing delivery channels that can
 6-32   National Action Plan for Energy Efficiency

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            Figure 6-1. Impacts of the Northeast Lighting and Appliance Initiative
               0.6
             U
                         Sponsor states with initiative
                         National average
                         Sponsor states absent initiative
                                                                          lftiei.il Minimum rtfxtvr
                                Sponsor states
                                (with initiative)
                                              .2003: Nation;)! ttothes washers
                                                  (.smpdign kicks off
                   2004 More *trmqent ENERGY
                      STAR sp*c iaksn effect
                1998
                        1999
                                2000
2001
                                                 2002
2003
                                                                 2004
                                                                         2005
                                                                                 2006
                                                2007
be used to keep  program costs down while providing
substantial benefit to customers. On  average, weather-
ization reduces heating  bills by 31 percent and overall
energy bills by $274 per year for an average cost per
home of $2,672  per year.  Since 1999,  DOE has  been
encouraging the network of weatherization providers to
adopt a whole-house approach whereby they approach
residential energy efficiency as a system rather than as a
collection of unrelated pieces of equipment (DOE, 2006).
The Long Island Power Authority's (LIRA) program shown
at right provides an example.

Leverage the  National ENERGY STAR Program
Nationally, ENERGY STAR provides a platform for pro-
gram implementation  across  customer  classes and
defines voluntary  efficiency levels for homes, buildings,
and products. ENERGY STAR is a voluntary,  public-private
partnership designed to  reduce energy use and related
greenhouse gas emissions.  The program,  administered
by the U.S. Environmental Protection Agency (EPA) and
the DOE, has  an extensive network of partners including
equipment manufacturers, retailers, builders, ESCOs, pri-
vate businesses, and public sector organizations.

Since  the  late 1990s, EPA and DOE  have  worked with
utilities,  state energy offices, and  regional  nonprofit
organizations  to help leverage ENERGY STAR  messaging,
              tools, and  strategies to enhance local energy efficiency
              programs. Today more than 450 utilities (and other effi-
              ciency   program   administrators),   servicing   65
              percent of U.S. households, participate in the ENERGY
              STAR program.  (See box on  page 6-34 for  additional
              information.) New Jersey and Minnesota provide examples
              of states that have leveraged ENERGY STAR.
                 Long Island Power Authority (LIRA):
                 Residential Energy Affordability
                 Partnership Program (REAP)

                 This program provides installation of comprehen-
                 sive electric energy efficiency measures and energy
                 education and counseling. The program  targets
                 customers  who  qualify  for DOE's  Low-Income
                 Weatherization Assistance Program (WAP), as well
                 as electric space heating and cooling  customers
                 who do not qualify for WAP and have an  income
                 of no more than 60 percent of the median house-
                 hold income level. LIPA's REAP program has saved
                 2.5 MW and 21,520 MWh 1999  to 2004 with
                 spending of $12.4 million.
                 Source: LIPA, 2004
Jo create a sustainable, aggressive national commitment to energy efficiency
                                                             6-33

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          V'- C/i'j;; hn-rr.- /V<;i.". '••  The New Jersey
 Board of Public Utilities, Office of Clean Energy has incor-
 porated  ENERGY STAR tools  and strategies since the
 inception of its residential products and Warm Advantage
 (gas) programs. Both programs encourage customers to
 purchase qualified lighting, appliances, windows,  pro-
 grammable thermostats, furnaces, and boilers. The New
 Jersey Clean Energy Program also educates consumers,
 retailers, builders, contractors, and manufacturers about
 ENERGY STAR. In 2005, New  Jersey's Clean Energy
 Program saved an estimated 60 million kWh of elec-
 tricity, 1.6 million therms of gas, and 45,000 tons of
 carbon dioxide
  ENERGY STAR Program Investments

  In support of the ENERGY STAR program, EPA and
  DOE invest in a portfolio of energy efficiency efforts
  that utilities  and third-party program administrators
  can leverage to further their local programs including:

  • Education and Awareness Building.  ENERGY STAR
    sponsors broad-based public campaigns to educate
    consumers  on the link between energy use and air
    emissions, and to raise awareness about how products
    and services carrying the ENERGY STAR label can
    protect the environment while saving money.

  •Establishing   Performance   Specifications   and
    Performing Outreach  on Efficient Products.  More
    than 40 product categories include ENERGY STAR-
    qualifying models, which ENERGY STAR promotes
    through    education   campaigns,   information
    exchanges  on utility-retailer  program models, and
    extensive online resources. Online resources include
    qualifying product lists, a store locator, and information
    on product features.

  •Establishing Energy Efficiency  Delivery Models  to
    Existing Homes.  ENERGY STAR assistance includes
    an emphasis  on home diagnostics and evaluation,
    improvements by trained technicians/building pro-
    fessionals,  and sales training. It features  online
    consumer tools including the  Home Energy Yardstick
    and Home  Energy Advisor.
• Establishing   Performance   Specifications   and
  Performing  Outreach for New  Homes.  ENERGY
  STAR offers  builder recruitment materials,  sales
  toolkits,  consumer messaging, and  outreach  that
  help support builder training, consumer education,
  and verification of home performance.

• Improving the  Performance  of New and  Existing
  Commercial Buildings. EPA has designed an Energy
  Performance  Rating System to measure the energy
  performance  at the whole-building level, to help go
  beyond a component-by-component approach that
  misses  impacts of  design, sizing,  installation,
  controls,  operation, and maintenance. EPA uses this
  tool and other guidance to  help building  owners
  and utility programs maximize energy savings.

Additional  information  on strategies, tools,  and
resources by customer segment is provided in the fact
sheet  "ENERGY STAR—A  Powerful  Resource  for
Saving  Energy,"  which can be  downloaded  from
www.epa.gov/cleanenergy/pd f/napee_energystar-
factsheet.pdf.
6-34   National Action Plan for Energy Efficiency

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•.'.'!',).•  /-,'/!/(>/- I nmjy  Mima •%
-------
10 percent of the overall  energy efficiency budget, but
information, training,  and outreach might comprise a
larger portion of some programs that are designed to
affect long-term markets, when such activities are tied to
explicit uptake of efficiency measures and practices. This
approach  might  be particularly applicable in the early
years of implementation, when information and training
are most  critical for building supply and  demand for
products and services over the longer term. KeySpan and
Flex Your Power are examples of coordinating education,
training, and outreach activities with programs.

Leverage Customer Contact to Sell Additional Efficiency
and Conservation Measures
Program providers can take advantage of program contact
with customers to provide information  on other program

   KeySpan Example

   KeySpan uses training and certification as critical parts
   of its energy efficiency programs. KeySpan provides
   building operator  certification  training, provides
   training on the Massachusetts state building code,
   and trains more than 1,000 trade allies per year.

   Source: Johnson, 2006
    California: Flex Your Power Campaign

    The California Flex Your Power Campaign was ini-
    tiated  in 2001  in the wake of California's rolling
    black-outs. While  initially  focused  on immediate
    conservation measures, the campaign has transi-
    tioned to promoting energy efficiency and long-
    term  behavior  change.  The program coordinates
    with the national ENERGY STAR program as well as
    the California  investor-owned utilities to ensure
    that consumers are aware of energy efficiency
    options  and  the  incentives available  to them
    through their utilities.
offerings, as well as on no or low-cost opportunities to
reduce energy costs. Information might include proper use
or maintenance of newly purchased or installed equipment
or general practices around the  home or workplace for
efficiency improvements. Education  is often  included in
low-income  programs,  which  generally  include  direct
installation of equipment, and thus already include in-home
interaction between the program provider and customer.
The box below provides some additional considerations for
low-income programs.

Leverage Private-Sector Expertise, External Funding,
and Financing
Well-designed  energy efficiency  programs  leverage
external funding and financing to stretch available dollars
and to take advantage of transactions as they occur in

   Low-Income Programs
   Most utilities offer energy efficiency programs targeted
   to low-income customers for multiple reasons:
   •Low-income customers  are  less likely to take
    advantage  of rebate  and  other  programs,
    because  they  are  less likely  to  be  purchasing
    appliances or making home improvements.
   •The "energy burden" (percent of income spent
    on  energy) is substantially higher for low-income
    customers, making it more difficult  to pay bills.
    Programs that help reduce energy costs reduce
    the burden,  making it easier to maintain regular
    payments.
   • Energy efficiency improvements  often increase
    the comfort and safety of these homes.
   • Utilities have the opportunity to leverage federal
    programs, such as LIHEAP and WAP, to  provide
    comprehensive services to customers.
   • Low-income customers often live in  less efficient
    housing and have older,  less efficient appliances.
   •Low-income customers  often comprise a sub-
    stantial percentage (up  to one-third) of utility
    residential customers  and  represent a large
    potential for efficiency and demand  reduction.
   • Using  efficiency  education and  incentives  in
    conjunction  with credit  counseling  can  be very
    effective in this sector.
 6-36   National Action Plan for Energy Efficiency

-------
the marketplace. This approach offers greater financial
incentives to the consumer without substantially increas-
ing program costs. It also has some of the best practice
attributes discussed previously,  including use of existing
channels and infrastructure to reach customers. The fol-
lowing are  a few opportunities for leveraging  external
funding and financing:

• Leverage Manufacturer and Retailer Resources  Through
  Cooperative Promotions.  For example, for mass market
  lighting and  appliance  promotions, many  program
  administrators issue RFPs to retailers and manufacturers
  asking them to submit promotional ideas.  These RFPs
  usually require cost sharing or in-kind advertising and
  promotion, as well as requirements that sales data be
  provided as a condition of the contract. This approach
  allows  competitors  to  differentiate  themselves and
  market energy efficiency in a  way that is  compatible
  with their business model.

• Leverage State and Federal Tax Credits Where Available.
  Many  energy efficiency  program  administrators  are
  now pointing consumers and businesses to  the new
  federal tax credits and incorporating them in their pro-
  grams.  In addition, program  administrators can edu-
  cate their customers on existing tax strategies, such as
  accelerated depreciation and investment tax strategies,
  to  help them recoup the costs of  their  investments
  faster.  Some states offer  additional tax credits, and/or
  offer sales tax "holidays," where sales tax is waived at
  point of sale for a specified period  of time  ranging
  from  one  day to a year.  The North Carolina  Solar
  Center maintains a database of efficiency incentives,
  including   state  and   local  tax  incentives,  at
  www. dsireusa. org.

• Build on ESCO and Other Financing Program Options.
  This is especially  useful for  large  commercial and
  industrial  projects.

The  NYSERDA and California  programs presented at
right and on the following page are both good examples
of leveraging the energy services market and increasing
ESCO presence in the state.
    New York Energy Smart Commercial/
    Industrial Performance Program

    The New York Energy Smart Commercial/Industrial
    Performance  Program, which is administered  by
    NYSERDA,  is designed to promote energy savings
    and demand reduction  through capital  improve-
    ment projects and to support growth of the energy
    service industry  in New York state. Through the
    program,  ESCOs  and  other  energy  service
    providers receive cash incentives for completion of
    capital  projects yielding  verifiable  energy and
    demand savings. By providing $111 million in per-
    formance-based financial incentives, this nationally
    recognized program  has  leveraged more  than
    $550 million  in private capital investments.  M&V
    ensures that electrical energy savings are achieved.
    Since January 1999, more than 860  projects
    were completed in New York with an estimat-
    ed savings of 790 million kWh/yr.

    Sources:  Thorne-Amann and Mendelsohn, 2005;
    AESP, 2006
  Training  Opportunities.  Many organizations  provide
  education and  training to their members, sometimes
  on energy efficiency. Working with these organizations
  provides access to their members, and the opportunity
  to leverage funding or marketing opportunities provided
  by these organizations.

In addition, the  energy  efficiency contracting industry
has matured  to  the level that many proven programs
have been "commoditized." A number of private firms
and not-for-profit entities deliver energy  efficiency pro-
grams  throughout  the  United States  or  in  specific
regions of the country. "The energy efficiency industry is
now a  $5  billion to  $25 billion industry (depending on
how expansive one's definition) with a 30-year history of
developing and implementing all types of programs for
To create a sustainable, aggressive national commitment to energy efficiency
                                               6-37

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   California Non-Residential Standard
   Performance Contract (NSPC) Program

   The California  NSPC program  is targeted at  cus-
   tomer efficiency projects  and  is managed on a
   statewide basis by PG&E, SCE,  and San Diego Gas
   & Electric. Program administrators offer fixed-price
   incentives  (by  end use)  to  project  sponsors for
   measured  kilowatt-hour energy savings  achieved
   by the installation of energy efficiency measures.
   The fixed price per kWh, performance measurement
   protocols,  payment terms, and  other operating
   rules of  the program are  specified in a  standard
   contract. This program has helped to stimulate the
   energy services  market in the  state. In program
   year 2003, the California NSPC served  540  cus-
   tomers  and saved 336  gigawatt-hours  and
   6.54 million therms.

   Source: Quantum Consulting Inc., 2004
The Building Owners & Managers
Association  (BOMA) Energy Efficiency
Program

The BOMA Foundation, in  partnership  with  the
ENERGY STAR program, has created  an innovative
operational excellence program to teach property
owners and managers how to reduce energy con-
sumption and costs with proven no- and low-cost
strategies for optimizing equipment, people and
practices. The  BOMA Energy Efficiency Program
consists of six Web-assisted audio seminars (as well
as live  offerings at  the  BOMA  International
Convention). The courses are taught primarily by
real estate  professionals who speak  in business
vernacular  about  the  process of  improving
performance. The courses are as follows:

* Introduction to Energy Performance

* How to Benchmark  Energy Performance

8 Energy-Efficient  Audit Concepts  &  Economic
  Benefits
utilities and projects for all types of customers across the
country" (NAESCO, 2005). These firms can quickly get a
program up and running,  as they have the expertise,
processes,  and infrastructure to handle program activi-
ties.  New  program  administrators  can  contract  with
these organizations to deliver energy efficiency program
design, delivery, and/or implementation support in  their
service  territory.

Fort Collins Utilities was able to achieve early returns for
its Lighting with a Twist program (discussed on page 6-
39) by  hiring an experienced implementation  contractor
through a competitive solicitation process and negotiating
cooperative marketing agreements with national retail chains
and manufacturers, as well as local hardware stores.
* No- and Low-Cost Operational  Adjustments to
  Improve Energy Performance

"Valuing Energy Enhancement Projects & Financial
  Returns

* Building an Energy Awareness Program

The  commercial  real  estate industry  spends
approximately $24 billion annually on energy and
contributes 18 percent of the U.S. C02  emissions.
According  to  EPA  and ENERGY STAR  Partner
observations,  a  30  percent  reduction  is  readily
achievable simply by improving operating standards.
6-38  National Action Plan for Energy Efficiency

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    Fort Collins Utilities Lighting
    With a Twist

    Fort Collins Utilities estimates annual savings
    of 2,023 MWh  of electricity with significant
    winter peak demand savings of 1,850 kW at a
    total  resource  cost of $0.018/kWh  from  its
    Lighting with  a Twist program, which uses
    ENERGY STAR as a platform. The program was
    able to get off to quick and successful start by hiring
    an experienced  implementation contractor and
    negotiating  cooperative marketing  agreements
    with retailers and manufacturers—facilitating  the
    sale of 78,000 compact fluorescent  light bulbs
    through  six retail  outlets  from  October  to
    December 2005 (Fort Collins Utilities, et al., 2005).
Start Simply With Demonstrated Program Models:
Build Infrastructure for the Future

Utilities starting out or expanding programs should look to
other programs in their region and throughout the country
to leverage existing and emerging  best  programs. After
more than a decade of experience running energy efficiency
programs, many successful program  models have emerged
and are constantly being refined to achieve even more cost-
effective results.

While programs must be adapted to local realities, utilities
and state utility commissions can dramatically reduce their
learning curve by taking advantage  of the wealth of data
and  experience  from other  organizations  around  the
country. The energy efficiency and services community has
numerous resources and venues for sharing  information
and  formally recognizing  best practice programs.  The
Association of Energy Service Professionals (www.aesp.org),
the Association of Energy Engineers (www.aeecenter.org),
and the American Council for an Energy Efficient Economy
(www.aceee.org)  are   a   few  of   these  resources.
Opportunities for education and information  sharing are
also provided via national federal programs such as ENERGY
STAR (www.energystar.gov)  and  the  Federal  Energy
Management   Program   (www.eere.energy.gov/femp).
Additional resources will be provided  in Energy Efficiency
Best Practices  Resources and Expertise (a  forthcoming
product  of  the Leadership  Group).  Leveraging these
resources will reduce the time and expense of going to
market with new efficiency programs. This will also increase
the quality and value of the programs implemented.

Start With Demonstrated Program Approaches That Can
Easily Be Adapted to New Localities
Particularly for organizations that are  new to energy effi-
ciency programming or have  not  had substantial energy
efficiency programming for many years, it is best  to start
with tried and true  programs that can  easily be transferred
to new localities, and be up and running quickly to achieve
near term results. ENERGY STAR lighting and appliance pro-
grams that are coordinated and delivered through  retail
sales channels are a good example  of this approach on the
residential side. On  the commercial side, prescriptive incen-
tives for technologies  such as lighting,  packaged unitary
heating  and cooling equipment, commercial food service
equipment, and motors are good early targets. While issues
related to installation can emerge, such as design issues for
lighting, and proper sizing issues for packaged unitary  heat-
ing and  cooling equipment, these technologies can deliver
savings independent from how well the  building's overall
energy system  is managed and controlled.  In  the  early
phase of a program, offering prescriptive rebates is simple
and can garner supplier  interest  in  programs,  but as
programs progress, rebates might  need to be reduced or
transitioned to other types of  incentives (e.g., cooperative
marketing approaches, customer  referrals)  or  to  more
comprehensive approaches to  achieving energy savings. If
the utility or state is  in a tight supply situation, it might make
sense to start  with proven  larger scale programs  that
address  critical load growth drivers such as  increased air
conditioning load from  both  increased   central  air
conditioning in new  construction and  increased  use of
room air conditioners.

Determine the Right Incentives  and Levels
There are many types of incentives that can be used to
spur increased  investment  in energy-efficient  products
and services.  With the exception  of  education   and
To create a sustainable, aggressive national commitment to energy efficiency
                                                6-39

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   Table 6-11. Types  of Financial Incentives
               Financial Incentives
   Prescriptive Rebate
   Custom Rebate
                         Description
 Usually a predetermined incentive payment per item or per kW or kWh saved. Can be
 provided to the customer or a trade ally.
 A rebate that is customized by the type of measures installed. Can be tied to a specific
 payback criteria or energy savings. Typically given to the customer.
   Performance Contracting Incentive
   Low Interest Financing
 A program administrator provides an incentive to reduce the risk premium to the ESCO
 installing the measures.
 A reduced interest rate loan for efficiency projects. Typically provided to the customer.
   Cooperative Advertising
   Retailer Buy Down
 Involves providing co-funding for advertising or promoting a program or product. Often
 involves a written agreement.

 A payment to the retailer per item that reduces the price of the product.
   MW Auction
IA program administrator pays a third party per MW and/or per MWh for savings.
training programs,  most  programs offer some type of
financial  incentive. Table 6-11 shows some of the most
commonly used financial incentives.  Getting  incentives
right, and at the right levels,  ensures program success and
efficient use of resources by ensuring that programs do
not "overpay" to achieve results. The market assessment
and  stakeholder input process can  help inform  initial
incentives  and  levels. Ongoing process  and  impact
evaluation  (discussed below) and reassessment of cost-
effectiveness can help inform when incentives need to be
changed, reduced, or eliminated.

Invest in the Service Industry Infrastructure
Ultimately, energy efficiency is implemented by people—
home performance  contractors, plumbers,  electricians,
architects,  ESCOs, product manufacturers, and others—
who know how to plan for,  and deliver, energy efficiency
to market.

While it  is a best practice  to incorporate whole house
and  building  performance  into  programs, these  pro-
grams cannot  occur unless the program administrator
has  a skilled,  supportive community of energy service
professionals to call  upon  to  deliver these services to
market.  In areas of the  country lacking these  talents,
development of these markets  is a key goal and critical
part of the program design.
         In many markets—even those with well established effi-
         ciency programs—it is often this lack of infrastructure or
         supply of qualified workers that prevents wider deploy-
         ment  of  otherwise  cost-effective  energy  efficiency
         programs.  Energy  efficiency  program administrators
         often try to address this lack of infrastructure through
         various  program  strategies,  including pilot  testing
         programs that foster demand for these services and help
         create the business case for private sector infrastructure
         development, and vocational training and  outreach to
         universities, with incentives or business referrals to spur
         technician training and certification.

         Examples  of  programs  that have leveraged  the  ESCO
         industry were provided previously.  One program with an
         explicit goal of encouraging technical training for the
         residential  marketplace  is  Home  Performance  with
         ENERGY  STAR, which  is an emerging program model
         being  implemented  in a  number of  states including
         Wisconsin, New York, and Texas (see box on  page 6-41
         for an example). The program can be applied in the gas
         or electric  context,  and is effective at reducing  peak
         load, because the program captures improvements in
         heating  and cooling  performance.
6-40   National Action Plan for Energy Efficiency

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   Austin Energy: Home Performance
   with ENERGY STAR

   In Texas, Austin Energy's Home Performance with
   ENERGY STAR program focuses on educating cus-
   tomers, and providing advanced technical training
   for professional home performance contractors to
   identify energy efficiency opportunities,  with  an
   emphasis on safety, customer comfort, and energy
   savings. Participating Home Performance contrac-
   tors are given the opportunity to receive technical
   accreditation through the  Building Performance
   Institute.

   Qualified  contractors perform  a  top-to-bottom
   energy inspection of the  home and  make cus-
   tomized  recommendations for  improvements.
   These improvements might include measures such
   as  air-sealing,  duct sealing,  adding  insulation,
   installing energy efficient lighting, and installing
   new HVAC equipment or windows, if  needed. In
   2005,  Austin  Energy served more than  1,400
   homeowners,  with  an average savings per cus-
   tomer  of  $290 per year.  Collectively,  Austin
   Energy   customers  saved  an  estimated
   $410,000  and more than 3 MW through the
   Home Performance with ENERGY STAR program.

   Source: Austin Energy, 2006
Evolve to More Comprehensive Programs
A sample of how program approaches might evolve over
time is presented in Table 6-12. As this table illustrates,
programs typically start with proven models and  often
simpler  approaches,  such as  providing  prescriptive
rebates for multiple technologies  in commercial/industrial
existing  building programs. In addition, early  program
options are offered for all customer classes, and  all of the
programs deliver capacity benefits in addition to energy
efficiency.  Ultimately,  the  initial  approach taken  by a
program administrator will depend on how quickly the
program  needs  to  ramp up, and on  the  availability of
service industry professionals who know how to plan for,
and deliver, energy efficiency to market.

As program administrators gain internal experience and
a greater understanding of local market conditions, and
regulators and stakeholders gain greater confidence  in
the value of  the energy  efficiency  programs being
offered, program  administrators can add complexity  to
the programs provided and technologies addressed. The
early and  simpler programs will help establish  internal
relationships (across utility or program provider depart-
ments)  and  external  relationships (between  program
providers,  trade allies and other stakeholders).  Both the
program provider and trade allies will better understand
roles and  relationships, and  trade  allies will  develop
familiarity  with program processes and develop trust  in
the programs. Additional complexity can include alternative
financing  approaches  (e.g.,  performance contracting),
the inclusion of custom  measures,  bidding programs,
whole  buildings and whole home approaches, or addi-
tional  cutting  edge  technologies.  In addition,  once
programs  are  proven  within  one subsector, they can
often be offered with slight modification to other sectors;
for example, some proven residential program offerings
might be appropriate for multi-family or low-income cus-
tomers, and some large commercial and industrial offerings
might be appropriate for smaller customers or multifamily
applications.  Many of the  current ENERGY STAR market-
based  lighting and appliance  programs  that  exist  in
many parts of the country evolved  from customer-based
lighting rebates with some in-store promotion. Many  of
the more complex commercial and industrial programs,
such at NSTAR and National Grid's Energy Initiative program
evolved from lighting, HVAC, and motor rebate programs.

The Wisconsin and Xcel Energy programs discussed on
page 6-43 are also good examples of programs  that
have become more complex over time.

Change Measures Over Time
Program success,  changing market conditions, changes
in codes, and changes in technology require reassessing
the measures included in a program. High saturations  in
the market, lower incremental costs, more rigid codes,  or
To create a sustainable, aggressive national commitment to energy efficiency
                                              6-41

-------
Table 6-12. Sample Progression of Program Designs II
Sector
Program Ramp Up i Ener9y * ^i™™;1^86"6™5
3 r i (In Addition to kWh)
Early Midterm
(6 Months -2 YRS) (2-3 YRS)
Residential:
Existing Homes





Market-based
lighting & appliance
program
Home performance
with ENERGY STAR
pilot

Residential: [ENERGY STAR
New Homes pilot (in areas
Construction


without existing
infrastructure)




Low-Income





Multifamily

Commercial:
Existing
Buildings




Commercial:
New
Construction





Small Business




Education and
coordination with
weatherization
programs


Lighting, audits

Lighting, motors,
HVAC, pumps,
refrigeration, food
service equipment
prescriptive rebates
ESCO-type program

Lighting, motors,
HVAC, pumps,
refrigeration, food



Home performance
with ENERGY STAR

HVAC rebate
J.
ENERGY STAR
Homes










Direct install

Direct install





Custom measures





service equipment
prescriptive rebates

Custom measures
and design
assistance
J.
Lighting and
HVAC rebates
Direct install
Peak 1 II
Longer Term other Fuels K-Summpr Watcr Othsr II
(3 To 7 YRS) Other Fuels ^-jjger. Savjngs Other II
i i II
X





Add HVAC practices
X


X
X

j
Add ENERGY STAR

Advanced Lighting
Package






Add home repair




X



X

X
	 -_._.._._
S,W ' X


S,W


S
s,w


s,w



1 	
w



s,w






X










X

s,w
s,w ;

S,W :




Comprehensive



S,W X

approach




S,W





| S,W X


1





s,w

s,w
Bill savings and
reduced emissions





Bill savings and
reduced emissions






Bill savings and
reduced emissions

Improved bill
payment
Improved comfort
Bill savings and
reduced emissions

Bill savings and
reduced emissions





Bill savings and
reduced emissions






Bill savings and
reduced emissions

the availability of newer, more efficient technologies are
all reasons to reassess what measures are included in a
program.  Changes can be incremental, such as limiting
incentives for a specific measure to specific markets or
specific  applications.  As  barriers hindering  customer
investment in a measure are reduced, it might be appro-
priate to lower or eliminate financial incentives altogether.
It is not uncommon, however, for programs to continue
6-42   Nation,)! Action Pl.in for Energy Efficiency

-------
 Wisconsin Focus on Energy:
 Comprehensive Commercial Retrofit
 Program

 Wisconsin Focus on  Energy's Feasibility Study Grants
 and Custom Incentive Program encourages commer-
 cial customers to implement comprehensive,  multi-
 measure  retrofit  projects resulting in  the  long-term,
 in-depth  energy savings. Customers  implementing
 multi-measure projects designed to improve the whole
 building might be eligible for an additional  30 percent
 payment as a  comprehensive  bonus incentive. The
 Comprehensive Commercial  Retrofit Program
 saved 70,414,701  kWh, 16.4 MW,  and 2 million
 therms from 2001 through 2005.

 Sources:  Thorne-Amann  and Mendelsohn, 2005;
 Wisconsin, 2006.
monitoring product and measure uptake after programs
have ceased or to support other activities, such as con-
tinued education, to ensure that market share for products
and  services are not adversely affected  once financial
incentives are eliminated.
Pilot New Program Concepts
New program ideas and delivery approaches should be ini-
tially offered on a pilot basis. Pilot programs are often very
limited in duration, geographic area, sector or technology,
depending upon what is being tested. There should be a
specific set of questions and objectives that the pilot pro-
gram is designed to address. After the pilot period, a quick
assessment of the program should be conducted to deter-
mine successful aspects of the program and any problem
areas for improvement, which can then be addressed in a
more full-scale  program.  The  NSTAR program  shown
below is a recent example of an emerging program type
that was originally started as a pilot.
Xcel Energy Design Assistance

Energy Design Assistance offered by Xcel, targets
new construction and major renovation projects. The
program goal is to improve  the energy efficiency of
new construction projects by encouraging the design
team to implement an integrated package of energy
efficient strategies. The target markets for the pro-
gram are commercial customers and small business
customers, along with architectural and engineering
firms. The program targets  primarily big box  retail,
public government facilities, grocery stores, health-
care,  education, and  institutional  customers. The
program offers three levels of support depending on
project size. For projects greater than 50,000 square
feet, the program offers custom consulting. For proj-
ects  between 24,000  and  50,000 square feet, the
program offers  plan review. Smaller projects  get a
standard  offering. The  program covers  multiple
HVAC, lighting, and  building envelope measures.
The  program also addresses  industrial  process
motors and variable speed  drives. Statewide, the
Energy Design Assistance program saved  54.3
GWh and 15.3 MW at a cost of $5.3 million in 2003.

Source:  Minnesota Office  of  Legislative  Auditor,
2005; Quantum Consulting  Inc., 2004
Table  6-13  provides a summary of the examples pro-
vided  in this section.
   NSTAR Electric's ENERGY STAR
   Benchmarking Initiative

   NSTAR is using the ENERGY STAR benchmarking
   and portfolio manager to help its commercial cus-
   tomers identify and  prioritize energy efficiency
   upgrades. NSTAR staff assist the customer in using
   the ENERGY STAR tools to rate their building relative
   to other buildings of  the same type, and identify
   energy efficiency upgrades. Additional  support is
   provided through walk-through energy audits and
   assistance in applying  for NSTAR financial incentive
   programs to implement efficiency measures.

   Ongoing support is available as participants monitor
   the impact of the energy efficiency improvements
   on the building's performance.
                                                                                                  6-43

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Table 6-13. Program Examples for Key Customer Segments

Customer
Segment
Program
All | Training and
certification
I components
Commercial, Non-residential
Industrial j performance
j contracting
I program
Commercial, Energy design
Industrial, assistance
New
Construction
Commercial,
Industrial
Large
Commercial,
Industrial
Large
Commercial,
Industrial
Small
Commercial
Residential
Residential -
Low Income
Custom incentive
program
NY Performance
Contracting
Program
ENERGY STAR
Benchmarking
Smart business
Flex Your Power
Residential
affordability
program
Program
Administrator
KeySpan
California Utilities
XCEL
Wisconsin Focus on
Energy
NYSERDA
NSTAR
Seattle City Light
California lOU's
LIPA
Program Description/
Strategies
KeySpan's programs include a signifi-
cant certification and training compo-
nent. This includes building operator
certification, building code training and
training for HVAC installers. Strategies
include training and certification.
This program uses a standard contract
approach to provide incentives for
measured energy savings. The key
strategy is the provision of financial
incentives.
This program targets new construction
and major renovation projects. Key
strategies are incentives and design
assistance for electric saving end uses.
This program allows commercial and
industrial customers to implement a
wide array of measures. Strategies
include financial assistance and
technical assistance.
Comprehensive Performance
Contracting Program provides incen-
tives for measures and leverages the
energy services sector. The predomi-
nant strategies are providing incen-
tives and using the existing energy
services infrastructure.
Program Model
Proven Emerging
X
X

X
X Does allow for
technologies
to be added
over time
NSTAR uses EPA's ENERGY STAR X
benchmarking and Portfolio Manager
to assist customers in rating their
buildings.
This program has per unit incentives
for fixtures and is simple to participate
in. It also provides a list of pre-
qualified contractors.
This is an example of the CA utilities
working together on a coordinated cam-
paign to promote ENERGY STAR prod-
ucts. Lighting and appliances were
among the measures promoted.
Strategies include incentives and
advertising.
Comprehensive low-income program
that installs energy saving measures and
also provides education. Strategies are
incentives and education.
X
X
X



Key Best
Practices
Don't underinvest in
education, training, and
outreach. Solicit stake-
holder input. Use utilities
channels and brand.
Build upon ESCO and
other financing program
options. Add program
complexity over time.
Keep participation
simple.
Keep participation simple.
Add complexity over
time.
Keep participation simple.
Add complexity over
time.
Leverage customer con-
tact to sell additional
measures. Add program
complexity over time.
Keep participation simple.
Build upon ESCO and
other financing options.
Coordinate with other
programs. Keep partici-
pation simple. Use utility
channels and brand.
Leverage ENERGY STAR.
Use utility channels and
brand. Leverage cus-
tomer contact to sell
additional measures.
Keep funding consistent.
Don't underinvest in edu-
cation, training, and out-
reach. Solicit stakeholder
input. Use utilities chan-
nels and brand.
Coordinate with other
programs. Leverage man-
ufacturer and retailer
resources. Keep participa-
tion simple. Leverage
ENERGY STAR.
Coordinate with other
programs. Keep participa-
tion simple. Leverage
customer contact to sell
additional measures.
6-44    National Action Plan for Energy Efficiency

-------
Table 6-13. Program Examples for Key Customer Segments (continued)

Customer
Segment
Program
Program
Administrator
Program Description/
Strategies
Program Model
Proven Emerging
Key Best
Practices
Residential
Existing
Homes
Home
Performance with
ENERGY STAR
Residential ' ENERGY STAR
New i Homes
Construction
Residential Residential
Existing program
Homes
Residential
Existing
Homes
Commercial
Existing
New Jersey
Clean Energy
Program
Education and
training
Austin Energy | Whole house approach to existing ' X : Start with proven mod-
homes. Measures include: air sealing, [ : : els. Use utilities channels
insulation, lighting, duct-sealing, and : and brand. Coordinate
replacing HVAC. i '• with other programs.
Efficiency Vermont ! Comprehensive new construction pro- X ; Don't underinvest in
; gram based on a HERS rating system. : : education, training, and
Measures include HVAC, insulation ; ; outreach. Solicit stake-
! lighting, windows, and appliances. : holder input. Leverage
i ; state and federal tax
credits. Leverage
ENERGY STAR.
Great River Coop Provides rebates to qualifying appli-
1 ances and technologies. Also provides
training and education to customers
and trade allies. Is a true dual-fuel
program.
New Jersey BPU
BOMA
Provides rebates to qualifying appli-
ances and technologies. Also provides
training and education to customers
and trade allies. Is a true dual-fuel
program.
Designed to teach members how to
reduce energy consumption and costs
through no- and low-cost strategies.
*



X
Start with proven mod-
els. Use utilities chan-
nels and brand.
Coordinate with other
programs.
Start with proven mod-
els. Coordinate with
other programs.
Leverage organizations
and outside education
and training opportuni-
ties. Leverage ENERGY
STAR.
Ensuring Energy Efficiency
Investments Deliver Results

Program  evaluation  informs  ongoing decision-making,
improves program delivery, verifies energy savings claims,
and justifies future investment in  energy efficiency as  a
reliable energy  resource.  Engaging in  evaluation during
the early stages of program development can save time
and money by identifying program  inefficiencies, and sug-
gesting how program funding can be optimized. It also
helps ensure that critical data are not lost.

The majority of organizations reviewed for this paper have
formal evaluation plans  that  address  both  program
processes and impacts. The evaluation plans, in  general,
are developed consistent with the evaluation budget cycle
and allocate evaluation dollars to  specific programs and
activities. Process  and impact  evaluations are performed
for each  program early in program cycles. As programs
and  portfolios  mature,  process  evaluations  are less
frequent  than  impact evaluations. Over  the  maturation
period,  impact  evaluations tend  to focus  on  larger
programs  (or program components), and address more
complex impact issues.

Most programs have an evaluation reporting cycle that is
consistent with the program funding (or budgeting) cycle.
In general, savings are reported individually by sector and
totaled  for the  portfolio.  Organizations use evaluation
results from  both  process and  impact evaluations  to
improve programs moving forward, and adjust their port-
folio of energy efficiency offerings based on evaluation
findings and  other factors.  Several organizations have
adopted the International Performance Measurement and
Verification Protocol (IPMVP) to  provide  guidelines  for
evaluation approaches. California has its own set of for-
mal  protocols that  address specific  program types. Key
methods used by organizations vary based  on program
type and can  include billing analysis, engineering analysis,
metering,  sales data tracking, and market effects studies.

Table 6-14 summarizes the evaluation  practices of a
subset of the organizations reviewed for this study.
To create a sustainable, aggressive national commitment to energy efficiency
                                                6-45

-------
^H Table 6-14 Evaluation Approaches

Oj
5'
3'
rri
"^
ง'











Policy Model
Program Funding Source

Program Budgeting Cycle
Evaluation Funding Cycle
Evaluation Reporting
Cycle
Role of Deemed Savings
(i.e., pre-determined
savings)
Report Gross Savings
(usually kWh, kW)
Report Net Savings
(usually kWh, kW)
Net Savings Components
Installation Verification
Engineering Review
Free Ridership
Spillover or Market Effects
Retention
Non-Energy Benefits
Other Not Specified

NYSERDA !
(NY) i

; SBC w/state
administration
1 Annual appropriation, j
'• 8-year renewable
portfolio standard
program. 5-year
: public benefit i
• programs.
Annual
Annual
Quarterly and
annually
Estimate savings.
Program planning
and goals.
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes


Efficiency
Vermont
(VT)

SBC w/3" party
administration
Not available

3 years
Not available
Annually and as
needed
Estimate savings.
No
Yes


Yes
Yes
Yes



i Electric Utilities
NSTAR (MA)

SBC w/utility
administration
: SBC

Annual from SBC
Annual; evaluation is a
line item in budgeting
process.
Annually but not every
program every year
DOER for report to
legislature. Program
planning and design.
Yes
:Yes
Yes
Yes
Yes
Yes
Yes



Wl Department of j CA Utilities
Administration ! (CA)
(Wl) |

SBC w/state : SBC w/utility
: administration ; administration
SBC - electric ratepayers : Not available

Annual Current funding cycle
is 3 years. Previous
periods were only 2
years.
Annual Ongoing, every year.
Upcoming contracts
will be 3 year evaluation
with annual reporting.
Twice per year Annual
Estimate savings. Program Planning. Inputs for
planning and goals. TRC analysis. Adjusted
regularly based on
evaluation results.
Yes Yes
Yes ; Yes
Yes Yes
Yes Yes
Yes Yes
Yes Yes
Yes



MN Electric and
Gas Investor-
Owned Utilities
(MN)
IRP and Conservation
Improvement Program
Utilities, by order of state
legislature, to spend a
percent of revenues on
efficiency programs.

Currently a 2-year cycle,
but a 4-year cycle is rec-
ommended. Natural gas
submits plans 1 year;
electricity the next.
Funded as needed
Annual status reports
Not available
Not available
Not available
Yes

Yes
Yes

Bonneville Power
Administration
(ID, MT, OR , WA)

Regional Planning Model
Not available

Dependent upon rate case, can
be every 2 to 5 years. Generally
amortized annually.
Evaluation funded periodically
when necessary. Starting to do
more frequent evaluations than
in previous years.
Not available
Determine payment schedule
for efficiency measures with
established savings records.
Yes. Gross savings forms basis
for regional power plans.
Yes. Used to evaluate the effi-
ciency of measures and fine-
tune programs. Savings netted
out depends upon program.
Not available
Not available
Not available
Not available
Not available
Not available


-------

Table 6-14. Evaluation Approaches (continued) ^^^^^|

NYSERDA
(NY)
Education and Training in Yes
EE Budget
Education and Training Yes
Evaluated
Evaluation Funding as Not available
Efficiency
Vermont
(VT)
Not available
Not available
<1%
Electric Utilities
NSTAR (MA)
Yes
Depends on program
2%
Wl Department of CA Utilities
Administration (CA)
(Wl)
Not available Yes
Initial years only Yes
8% increase from 4.25% No more than 3% of
MN Electric and
Gas Investor-
Owned Utilities
(MN)
Not available
Not available
<1%
Bonneville Power
Administration
(ID, MT, OR , WA)
Yes
No

Percent of Program
Budget

Evaluation Budget
Financial Evaluation
Cost-Effectiveness
Analysis

Timing
Test Used (RIM, TRC, Utility,
Other)


Who Evaluates
Oversight of evaluation
Protocols
                             Not available
                                               Not available
Varies annually dependent   Not Available
upon project portfolio and
other demands.
minimum efficiency
spending requirement.

$160MM over 3 years.   Not available
                                                                                                                      $1MM
                             Internal           CPA
                             State Comptroller
                             CPA
                             Yes
                             Annually
                             TRC; Other
                             Independent
                             evaluators
                                               Yes
                                               Triennially
                                                                  Internal CPA
                                                                  Yes
                                                                                          CPA
                                                                                          Yes
                                                                                                                    Not avaiable
                                                                                                                    Yes
                                                                                           Internal. Reviewed by        Internal
                                                                                           Department of Commerce.
                                                                                           Reviewed by Legislature.
Varies annually dependent   Periodically (less frequent   Not available
upon project portfolio and   than funding cycle)
other demands.
                                                                                                                                          Yes
                      2 years
                                                                                                                                                                     Yes
                                                                                                                      Periodically
Utility Cost Test and  TRC
Societal Cost-
Benefit Test
                                                                                          Societal; also includes
                                                                                          economic impacts
                                                  TRCPAC (program
                                                  administrator test)
                      Societal; Utility; Participant;   TRC
                      Ratepayer
Independent        Utilities manage inde-      One independent team of   Independent evalua-    Department of              Independent evaluators
experts under con-   pendent evaluators        evaluators                tors hired for each pro-  Commerce Legislature Audit
tract to DPS         through RFP process                                gram via RFP process   Commission, if deemed
                                                                                           necessary
                             NYSERDA          Department of
                             provides ongoing   Public Service
                             oversight.
                             Public Utilities
                             Commission final
                             audience.
                   Evaluations are reviewed   Wl Department of
                   in collaborative and filed   Administration
                   with the Massachusetts
                   Department of
                   Telecommunications and
                   Energy
                                                                                                                    California Public
                                                                                                                    Utilities Commission
                                                                                                                    and CEC
                                                                        Department of Commerce    Power Council
                             IPMVP
                                               Not available
                                                                  Not available
                                                                                          None
                                                                                                                    Has had statewide pro-  Not available
                                                                                                                    tocols for many years.
                                                                                                                    New protocols were
                                                                                                                    recently adopted.
                                                                                                                                                                     IPMVP as reference

-------
Best practices for program evaluation that emerge from
review of these organizations include the following:

• Budget, plan, and initiate evaluation from the onset.

• Formalize and document evaluation plans.

• Develop program tracking systems that are compatible
  with needs identified in evaluation plans.

• Conduct process evaluations to ensure  that programs
  are working efficiently.

• Conduct impact evaluations to ensure  that mid- and
  long-term goals are being met.

• Communicate evaluation results.

Budget, Plan, and Initiate Evaluation From
the Onset
A well-designed  evaluation plan  addresses  program
process and impact  issues. Process evaluations address
issues associated with program delivery such as marketing,
staffing, paperwork flow, and customer interactions, to
understand how they can be improved to better meet
program objectives. Impact evaluations are designed to
determine the energy or  peak savings from the program.
Sometimes  evaluations address  other program benefits
such as non-energy benefits to consumers, water savings,
economic impacts, or emission reductions. Market research
is often  included in  evaluation budgets  to  assist  in
assessing program delivery options, and for establishing
baselines. An evaluation budget of 3 to 6 percent of pro-
gram budget is a reasonable spending range. Often eval-
uation spending is higher in the second or third year of

   "We should  measure the performance of DSM
   programs in much the same way  and with the
   same competence and diligence that we monitor
   the performance of power plants."

   —Eric Hirst  (1990), Independent  Consultant
   and Former  Corporate Fellow,  Oak  Ridge
   National Laboratory
a program. Certain evaluation activities such as estab-
lishing baselines are critical to undertake from the onset
to ensure that valuable data are not lost.

Develop Program and Project Tracking Systems
That Support Evaluation Needs
A well-designed tracking system should collect sufficiently
detailed information needed for  program evaluation and
implementation.  Data collection can vary by  program
type, technologies addressed,  and customer segment;
however, all program tracking systems should include:

•Participating customer information.  At a minimum,
 create an  unique customer identifier that can be linked
 to  the utility's  Customer  Information   System (CIS).
 Other customer or site specific information might  be
 valuable.

• Measure specific information. Record equipment type,
 equipment size or quantity, efficiency level  and estimated
 savings.

•Program tracking information. Track  rebates or other
 program services provided  (for each participant) and
 key program dates.

• All program cost information.  Include internal staffing
 and marketing  costs, subcontractor and  vendor costs,
 and program incentives.

Efficiency Vermont's tracking system incorporates all of
these features in  a comprehensive, easy-to-use  relational
database that includes all  program contacts  including,
program allies and customers, tracks ell project  savings
and  costs, shows the underlying engineering estimates
for all measures,  and includes billing data from all of the
Vermont utilities.
6-48  National Action Plan for Energy Efficiency

-------
Conduct Process Evaluations to Ensure Programs
Are Working Efficiently

Process evaluations are a tool to improve the design and
delivery of the program and are especially important for
newer programs. Often they can identify improvements
to program delivery that reduce program costs, expedite
program  delivery,  improve  customer satisfaction, and
better focus program objectives. Process evaluation can
also address what technologies get rebates or determine
rebate levels. Process evaluations use a variety of qualita-
tive and quantitative approaches including review of pro-
gram documents, in-depth interviews, focus groups, and
surveys. Customer  research in  general,  such  as  regular
customer and vendor surveys, provides program  admin-
istrators with continual feedback on how the program is
working and being received by the market.

Conduct Impact Evaluations to Ensure Goals
Are Being  Met

Impact evaluations  measure the change  in energy usage
(kWh, kW,  and therms) attributable to the program.
They use  a variety of approaches to quantify energy sav-
ings including  statistical comparisons, engineering esti-
mation, modeling,  metering, and  billing  analysis. The
impact evaluation  approach used  is a  function  of the
budget available,  the  technology(ies)  addressed, the
certainty of the original program estimates, and the level
of estimated savings.  The appliance recycling example
shown at right is an example of how process and  impact
evaluations have improved a program over time.
  Measurement and Verification (M&V)

  The term  "measurement and verification" is often
  used  in  regard  to  evaluating  energy efficiency
  programs. Sometimes this term  refers to ongoing
  M&V that is incorporated into program operations,
  such as telephone confirmation  of installations by
  third-party installers or measurement of savings for
  selected projects. Other times, it refers to external
  (program operations) evaluations to document savings.
   California Residential Appliance
   Recycling Program (RARP)

   The  California  RARP  was  initially  designed to
   remove older, inefficient second refrigerators from
   participant households. As the program matured,
   evaluations showed that the potential for removing
   old  second  refrigerators from  households  had
   decreased substantially as a result of the program.
   The program now focuses on  pick-up of  older
   refrigerators that are being replaced, to keep these
   refrigerators out of the secondary refrigerator market.

Organizations are beginning to explore the use of the EPA
Energy Performance Rating System to measure the energy
performance at  the  whole-building  level,  complement
traditional M&V  measures, and go  beyond component-
by-component approaches that miss the interactive impacts
of design, sizing, installation, controls,  and operation and
maintenance.

While most energy professionals see inherent  value in
providing energy education and training (lack of infor-
mation is often identified  as a barrier to customer and
market actor adoption of energy efficiency products and
practices), few programs  estimate savings  directly as a
result  of education  efforts.  Until  2004,  California
assigned a  savings  estimate to the Statewide Education
and Training Services  program based on expenditures.

Capturing the  energy impacts of energy education pro-
grams  has  proven to  be a challenge for evaluators for
several reasons. First, education  and training  efforts are
often integral to specific program offerings.  For example,
training of HVAC contractors on sizing air  conditioners
might be integrated  into  a residential appliance rebate
program. Second,  education  and training  are  often a
small part of a program in  terms of budget and estimated
savings. Third, impact evaluation efforts might be expensive
compared to the education and training  budget and
anticipated  savings.   Fourth, education and  training
efforts are not always  designed to achieve direct benefits.
They are often  designed to inform participants or market
actors of program opportunities, simply to  familiarize
them with energy efficiency options. Most evaluations of
To create a sustainable, aggressive national commitment to energy efficiency
                                               6-49

-------
   Best Practices in Evaluation

   • Incorporating an overall evaluation plan and budget
    into the program  plan.
   •Adopting a more  in-depth evaluation plan each
    program year.
   ซ Prioritizing evaluation resources where the risks are
    highest. This includes focusing impact evaluation
    activities on the most uncertain outcomes and highest
    potential savings. New and pilot programs have the
    most uncertain outcomes, as do newer technologies.
   • Allowing evaluation criteria to vary across some
    program types to allow for education, outreach,
    and innovation.
   • Conducting ongoing verification as part of the
    program process.

energy education and training  initiatives have focused
on process  issues. Recently, there have been impact eval-
uations of training programs, especially those designed
to produce direct  energy  savings, such  as Building
Operator Certification.

In the future, energy efficiency will  be part  of emissions
trading initiatives (such as  the Regional  Greenhouse Gas
Initiative [RGGI]) and is  likely to be eligible for payments for
reducing congestion and providing capacity value such as
in the ISO-NE capacity  market settlement. These emerging
opportunities will require that evaluation methods become
more  consistent  across states and regions, which might
necessitate  adopting consistent protocols for project-level
verification  for  large projects, and standardizing sampling
approaches for residential measures such as compact fluo-
rescent lighting. This is an emerging need and should be a
future area  of collaboration across states.

Communicate  Evaluation Results to Key
Stakeholders

Communicating  the  evaluation  results  to  program
administrators and stakeholders is essential to enhancing
program  effectiveness. Program administrators need to
understand evaluation approaches,  findings, and espe-
cially  recommendations to improve program processes
 • Establishing a program tracking system that
  includes necessary information for evaluation.
 • Matching evaluation techniques to the situation in
  regards to the costs to evaluate, the level of precision
  required, and feasibility.
 1 Maintaining separate staff for evaluation and for
  program implementation. Having outside review of
  evaluations (e.g., state utility commission), especially
  if conducted by internal utility staff.
 • Evaluating regularly to refine programs as needed
  (changing market conditions often require program
  changes).
and  increase  (or  maintain)  program  savings levels.
Stakeholders need to see that savings from energy effi-
ciency  programs  are realized and  have been verified
independently.

Evaluation reports  need to be geared toward  the audi-
ences  reviewing them. Program staff  and  regulators
often prefer reports that clearly describe methodologies,
limitations, and findings on a detailed and program level.
Outside stakeholders are more likely to read shorter eval-
uation  reports that  highlight  key findings at the cus-
tomer segment or  portfolio level. These reports must be
written  in a less technical  manner  and highlight  the
impacts of the program beyond energy or demand savings.
For example, summary reports of the Wisconsin  Focus
on  Energy  programs highlight  energy,  demand, and
therm  savings by sector, but  also discuss the environ-
mental benefits of the program and the impacts of energy
savings on the Wisconsin  economy.  Because the  public
benefits budget goes through the state  legislature,  the
summary  reports  include  maps  of  Wisconsin  showing
where   Focus  on  Energy projects  were  completed.
Examples of particularly successful investments, with the
customer's permission, should  be part of the evaluation.
These  case  studies can be  used to make the success
more tangible  to stakeholders.
6-50   National Action Plan for Energy Efficiency

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 Recommendations and Options

The National Action Plan for Energy Efficiency Leadership
Group offers the following recommendations as ways to
promote best  practice energy efficiency programs, and
provides a number of options for consideration by utili-
ties,  regulators, and stakeholders.

Recommendation: Recognize energy efficiency as a high-
priority energy resource.  Energy efficiency has not been
consistently  viewed  as a  meaningful  or  dependable
resource compared to new supply options, regardless of
its demonstrated contributions to meeting load growth.
Recognizing energy efficiency as a high priority energy
resource is an important step in efforts to capture the
benefits  it offers and lower the overall cost  of energy
services to customers. Based on jurisdictional objectives,
energy efficiency can be incorporated into resource plans
to account for the long-term benefits from energy sav-
ings, capacity  savings,  potential reductions  of  air pollu-
tants and greenhouse  gases, as well as other benefits.
The  explicit integration of energy efficiency  resources
into  the formalized  resource planning processes  that
exist at regional, state, and utility levels can help estab-
lish the rationale for energy efficiency funding levels and
for properly valuing and balancing the benefits. In some
jurisdictions, existing planning processes might need to
be adapted or new planning processes might need to be
created to meaningfully incorporate  energy efficiency
resources into resource planning. Some  states  have rec-
ognized energy efficiency as the resource of first priority
due to its broad benefits.
•Quantifying and establishing the value of energy effi-
  ciency,  considering energy  savings,  capacity savings,
  and environmenta benefits, as appropriate.

Recommendation:  Make a strong,  long-term commit-
ment to  cost-effective  energy efficiency as a resource.
Energy efficiency programs are most successful and provide
the greatest benefits to stakeholders when appropriate
policies are established  and maintained over the long-
term. Confidence in long-term  stability of the program
will help  maintain  energy efficiency  as  a  dependable
resource compared to supply-side resources, deferring or
even avoiding the need for other  infrastructure  invest-
ments, and maintains customer awareness and support.
Some  steps  might  include  assessing  the long-term
potential  for cost-effective energy efficiency  within a
region  (i.e., the energy efficiency that can be  delivered
cost-effectively through  proven  programs  for each
customer class within a planning horizon); examining the
role for cutting-edge initiatives and technologies; estab-
lishing  the cost of supply-side  options  versus  energy
efficiency; establishing  robust  M&V  procedures;  and
providing  for routine updates to information on  energy
efficiency  potential and key costs.
• Establishing appropriate cost-effectiveness tests for a
  portfolio of programs to reflect the long-term benefits
  of energy efficiency.

• Establishing the potential for long-term, cost-effective
  energy efficiency savings by customer class through
  proven programs,  innovative  initiatives,  and cutting-
  edge technologies.

•Establishing funding requirements for delivering long-
  term, cost-effective energy efficiency.

• Developing long-term  energy saving goals as part of
  energy planning processes.

• Developing robust M&V procedures.

• Designating which  organization(s) is  responsible  for
  administering the energy efficiency programs.

• Providing for frequent updates to energy resource plans
  to accommodate new  information and technology.

Recommendation: Broadly communicate the benefits of,
and  opportunities for,  energy  efficiency.  Experience
shows that energy efficiency programs help customers
save  money and contribute to  lower  cost  energy
systems.  But these impacts are not fully documented nor
                                                                                                       6-51

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recognized by customers, utilities, regulators, and policy-
makers. More effort is needed to establish the business
case for energy efficiency for all decision-makers, and to
show how a well-designed  approach to energy efficiency
can benefit customers, utilities, and society by (1) reducing
customers bills over time, (2) fostering financially healthy
utilities (return  on equity [ROE], earnings per share, debt
coverage ratios), and (3) contributing to positive societal
net benefits overall. Effort is  also  necessary to  educate
key stakeholders that, although energy efficiency can  be
an  important  low-cost resource to integrate into the
energy mix, it does require  funding, just as a new power
plan requires funding. Further, education is necessary on
the impact that energy efficiency programs can have in
concert with  other energy efficiency policies such  as
building codes, appliance standards, and tax incentives.

Options to Consider:

•Communicating the role of energy efficiency in lowering
 customer energy bills and system costs and risks over time.

•Communicating the role  of building codes, appliance
 standards, tax and other  incentives.

Recommendation: Provide  sufficient and stable program
funding  to deliver  energy efficiency  where  cost-
effective. Energy efficiency programs require consistent
and long-term funding to effectively compete with energy
supply options. Efforts are necessary to  establish this
consistent long-term funding. A variety of mechanisms
have been, and can be, used based on state,  utility, and
other stakeholder interests. It is important to ensure that
the efficiency  programs providers  have  sufficient pro-
gram funding to recover energy efficiency program costs
and  implement  the  energy  efficiency that has  been
demonstrated to be available and cost-effective. A number
of states are  now linking  program funding to the
achievement of energy savings.

Option to Consider:
•Establishing funding for multi-year periods.
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7:
Report Summary
This report presents a variety of policy, planning, and program approaches that tan be used to help natu-
ral gas and electric utilities, utility regulators, and partner organizations pursue the National Action Plan
for Energy Efficiency recommendations and meet their commitments to energy  efficiency. This chapter
summarizes these recommendations and the energy efficiency key findings discussed in this report.
Overview

This National Action Plan for Energy Efficiency (Action
Plan) is  a  call to action to  bring diverse stakeholders
together at the national, regional, state, or utility level,
as appropriate, to  foster  the  discussions,  decision-
making, and commitments necessary to take investment
in energy efficiency to a new level. The overall goal is to
create a sustainable, aggressive national commitment to
energy efficiency through gas and electric utilities, utility
regulators, and partner organizations.

Based on  the policies, practices, and efforts of many
organizations  previously discussed  in this report,  the
Leadership Group offers five recommendations as ways
to overcome many  of the  barriers that  have limited
greater  investment in programs to deliver energy effi-
ciency to customers of electric and gas utilities (Figure 7-1).
These recommendations  may  be pursued through  a
number of different options, depending on state and
utility circumstances.
                                            As  part of the Action  Plan,  leading organizations are
                                            committing  to  aggressively  pursue  energy  efficiency
                                            opportunities in their  organizations and to assist others
                                            who want to increase the use of energy efficiency in their
                                            regions. The commitments pursued under the Action Plan
                                            have the potential to save Americans many billions of dollars
                                            on energy bills over the next 10 to 15 years, contribute to
                                            energy security, and improve the environment.
                                             Recommendations and  Options
                                             to Consider

                                            The Action Plan Report provides information on the bar-
                                             riers that limit greater investment in programs to deliver
                                            energy efficiency to customers of  electric and gas utili-
                                            ties. Figure 7-2 illustrates the key barriers and how they
                                             relate to policy structure, utility resource planning, and
                                            program implementation.
   Figure 7-1. National Action Plan for Energy Efficiency Recommendations
   • Recognize energy efficiency as a high-priority energy resource.


   • Make a strong, long-term commitment to implement cost-effective energy efficiency as a resource.


   • Broadly communicate the benefits of and opportunities for energy efficiency.


   • Promote sufficient, timely, and stable program funding to deliver energy efficiency where cost-effective.


   • Modify policies to align utility incentives with the delivery of cost-effective energy efficiency and
    modify ratemaking practices to promote energy efficiency investments.
To create a sustainable, aggressive national commitment to energy efficiency
                                                                                          7-1

-------
Several options exist for utilities, regulators, and partner
organizations to overcome these barriers and pursue the
Action Plan recommendations. Different state and utility
circumstances affect which options are pursued. Table 7-1
provides a list of the Leadership Group recommendations
along with sample options  to  consider. The table also
provides  a cross reference to supporting  discussions  in
Chapters 2 through 6 of this  report.
Key Findings

The key finding of the Action Plan Report is that energy
efficiency can be a cost-effective resource and can  pro-
vide multiple benefits to utilities, customers, and society.
These benefits, also discussed in more detail in Chapter
1: Introduction and Background,1 include:
                  • Lower  energy bills,  greater  customer control,  and
                   greater customer satisfaction.

                  • Lower cost than  only supplying new generation from
                   new power plants.

                  • Advantages from being modular and quick to deploy.

                  • Significant energy savings.

                  • Environmental benefits.

                  • Economic development: opportunities.

                  • Energy security.
Figure 7-2: National Action Plan for Energy Efficiency Report Addresses Actions to Encourage Greater Energy Efficiency
Timeline: Actions to Encourage Greater Energy Efficiency


          Policy Structure
        Develop Utility Incentives
           for Energy Efficiency

         Develop Rate Designs to
       Encourage Energy Efficiency
                                               Utility Resource
                                                   Planning
      Include Energy Efficiency
        in Utility Resource Mix
                                                Program
                                             Implementation
                                  Revise Plans and Policies Based on Results
 Action Plan Report Chapter Areas and Key Barriers
        Utility Ratemaking
            & Revenue
           Requirements
Planning
Processes
                                                              Rate Design
Energy efficiency reduces
utility earnings

Planning does not
incorporate demand-
side resources

Rates do not
encourage energy
efficiency investments
Limited information on
existing best practices
  Chapter 6: Energy Efficiency Program Best Practices also provides more information on these benefits.
7-2    National Action Plan for Energy Efficiency

-------
I Table 7-1 . Leadership Group Recommendations and Options to Consider, by Chapter
Leadership Group Chapter 2: Chapter 3:
Recommendations utility Energy
(With Options To ConsideO Ratemaking & Resource
Revenue Planning
Requirements Processes
Recognize energy efficiency as a high X
priority energy resource.
Establishing policies to establish energy ; ; X
efficiency as a priority resource. '.
• - - — 	 - j - - -- 	
Integrating energy efficiency into utility, state, • X
and regional resource planning activities. i
Quantifying and establishing the value of energy ! X
efficiency, considering energy savings, capacity j
savings, and environmental benefits, as \
appropriate. j
Make a strong, long-term commitment ! X X
to cost effective energy efficiency as a
resource.
Establishing appropriate cost-effectiveness X
tests for a portfolio of programs to reflect the
long-term benefits of energy efficiency.
Establishing the potential for long-term, cost ; X
effective energy efficiency savings by customer
class through proven programs, innovative '
initiatives, and cutting-edge technologies. i
Establishing funding requirements for delivering X ; X
long-term, cost-effective energy efficiency.
Developing long-term energy saving goals as ! X
part of energy planning processes.
Developing robust measurement and X
verification (M&V) procedures.
Designating which organization(s) is responsi- X X
ble for administering the energy efficiency
programs. \
Providing for frequent updates to energy \ X
resource plans to accommodate new ;
information and technology.
Broadly communicate the benefits of, X X
and opportunities for, energy efficiency.
Establishing and educating stakeholders on the X , X
business case for energy efficiency at the state, :
utility, and other appropriate level addressing rele-
vant customer, utility, and societal perspectives. :
Communicating the role of energy efficiency X ! X
in lowering customer energy bills and system | '
costs and risks over time. i :
Communicating the role of building codes, !
appliance standards, and tax and other :
incentives. !
Chapter 4: j Chapter 5: Chapter 6:
Business Case : Rate Design j Energy
for Energy Efficiency
Efficiency Program Best
Practices
i X
j |
1 ... - t- - - - ....
X
X
X
] I
! i
i
	 ! ' "x 	
X
X
X
I 	 -
X
i . . .
< X
XXX
X !
X [ X | X
X
7-3

-------
  Table 7-1. Leadership Group Recommendations and Options to Consider, by Chapter (continued)
        Leadership Group
        Recommendations
      (With Options To Consider)
  Chapter 2:
     Utility
Ratemaking &
   Revenue
Requirements
Chapter 3:
  Energy
 Resource
 Plcinning
 Processes
  Chapter 4:
Business Case
  for Energy
  Efficiency
 Chapter 5:
Rate Design
  Chapter 6:
    Energy
  Efficiency
Program Best
   Practices
Provide sufficient, timely, and stable
program funding to deliver energy
efficiency where cost-effective.

Deciding on and committing to a consistent
way for program administrators to recover
energy efficiency costs in a timely manner.

Establishing funding mechanisms for energy
efficiency from among the available options
such as revenue requirement or resource
procurement funding, system benefits charges,
rate-basing, shared-savings, incentive
mechanisms, etc.
Establishing funding for multi-year periods.
Modify policies to align utility incentives
with the delivery of cost-effective energy
efficiency and modify ratemaking
practices to promote energy efficiency
investments.
Addressing the typical utility throughput
incentive and removing other regulatory and
management disincentives to energy efficiency.

Providing utility incentives for the successful
management of energy efficiency programs.

Including the impact on adoption of energy
efficiency as one of the goals of retail rate
design, recognizing that it must be balanced
with other objectives.
Eliminating rate designs that discourage energy j
efficiency by not increasing costs as customers
consume more electricity or natural gas.
Adopting rate designs that encourage energy
efficiency by considering the unique character-
istics of each customer class and including
partnering tariffs with other mechanisms that
encourage energy efficiency, such as benefit
sharing programs and on-bill financing.
7-4     National Action Plan for Energy Efficiency

-------
As discussed  in Chapter 2: Utility Ratemaking &  Revenue
Requirements, financial disincentives exist that hinder utilities
from pursuing energy efficiency, even when cost-effective.
Many states have experience in addressing utility financial
disincentives in the following areas:

•Overcoming the throughput  incentive.

• Providing reliable  means for utilities to recover energy
  efficiency costs.

• Providing a  return  on  investment for efficiency programs
  that is competitive with the return utilities earn on new
  generation.

• Addressing the risk of program costs  being disallowed,
  along with other risks.

• Recognizing the full  value of energy efficiency to the
  utility system.

Chapter 3: Energy Resource Planning Processes found that
there are many approaches to navigate and overcome the
barriers to incorporating  energy efficiency  in planning
processes. Common themes across approaches include:

• Cost  and savings  data for energy  efficiency measures
  are readily available.

• Energy, capacity, and non-energy  benefits can justify
  robust energy efficiency programs.

•A clear path to funding  is needed to establish a budg-
  et for energy efficiency resources.

• Parties  should  integrate energy efficiency early in the
  resource planning process.

Based  on the eight cases examined using  the Energy
Efficiency Benefits  Calculator in  Chapter  4: Business
Case for Energy Efficiency, energy efficiency investments
were found to provide  consistently lower costs over time
for both  utilities and customers, while providing positive
net benefits to society. Key findings include:

• Ratemaking policies to address utility financial barriers
  to energy efficiency maintain utility health  while com-
  prehensive, cost-effective energy efficiency programs
  are implemented.
• The costs of energy efficiency and the reduction in utility
  sales volume initially raise gas or electricity  bills due to
  slightly higher rates, but efficiency gains will reduce aver-
  age customer bills by 2 to 9 percent over a 10-year period.

• Energy efficiency investments yielded net societal benefits
  on the order of hundreds of millions of dollars for each of
  the eight small- to medium-sized utility cases examined.

Chapter 5:  Rate  Design  found that  recognizing  the
promotion of energy efficiency is an important factor to
balance along with the numerous regulatory and legislative
goals addressed during the complex rate design  process.
Additional key findings include:

• Several rate design options exist to encourage customers
  to invest in efficiency and to participate in new programs
  that provide innovative technologies (e.g., smart  meters).

• Utility rates that are designed to promote sales  or maxi-
  mize stable revenues tend to lower customer incentives
  to adopt energy efficiency.

• Some rate forms, like declining block rates or rates with
  large fixed  charges,  reduce the  savings that customers
  can attain from adopting energy efficiency.

•Appropriate rate designs should  consider  the unique
  characteristics of each customer class.

• Energy efficiency can be promoted  through non-tariff
  mechanisms that reach customers through their utility bill.

• More effort is  needed to  communicate the  benefits
  and opportunities for energy efficiency to customers,
  regulators, and utility decision-makers.

Chapter 6:  Energy  Efficiency Program  Best  Practices
provided a summary of best practices, as well as general
program key findings. The best  practice strategies for
program planning, design, implementation, and evalua-
tion  are found to be independent of the policy model in
which the  program  operates.  These  best practices,
organized by four major groupings, are provided below:

• Making Energy Efficiency A Resource

--  Require leadership at multiple levels.
To create a sustainable, aggressive national commitment to energy efficiency
                                                  7-5

-------
—-  Align organizational goals.

—  Understand the efficiency resource.

• Developing An Energy Efficiency Plan

—  Offer programs for all key customer classes.

—  Align goals with funding.

—  Use cost-effectiveness tests that are consistent with
    long-term planning.

—  Consider building  codes and appliance standards
    when designing programs.

—  Plan to incorporate new technologies.

—  Consider efficiency investments to alleviate transmis-
    sion and distribution constraints.

—  Create  a  roadmap of  key program components,
    milestones, and explicit energy use reduction goals.

• Designing and Delivering Energy Efficiency Programs

—  Begin with the market in mind.

—  Leverage private sector  expertise, external  funding,
    and financing.

—  Start with demonstrated  program  models—build
    infrastructure for the future.

• Ensuring  Energy Efficiency Investments Deliver Results

—  Budget, plan, and initiate evaluation.

—  Develop program and project tracking systems.

—  Conduct process evaluations.
 -   Conduct impact evaluations.

    Communicate evaluation results to key stakeholcers.

The key program findings in Chapter 6 are drawn from the
programs reviewed for this  report.2 These findings include:

• Energy efficiency resources are being acquired on average
  at  about  one-half  the   cost  of  typical  new  power
  sources and about one-third of the cost of natural gas
  supply in many cases—contributing  to  an  overall
  lower-cost energy system for rate-payers (EIA, 2006).

• Many energy efficiency programs are being delivered at a
  total  program cost of about $0.02 to $0.03 per lifetime
  kilowatt-hour  (kWh)  saved and $1,30 to $2.00 per life-
  time  million British thermal units (MMBtu) saved. These
  costs are less than the avoided costs  seen in most  regions
  of the country. Funding  for the  majority of programs
  reviewed ranges from about 1 to 3 percent of electric
  utility revenue and 0.5 to  1 percent of gas utility revenue.

• Even  low energy  cost states, such as those in the Pacific
  Northwest, have reason  to invest  in energy  efficiency
  because  energy efficiency  provides  a low-cost,  reliable
  resource that reduces customer utility bills. Energy efficien-
  cy also costs  less than  constructing  new generation  and
  provides a hedge against  market, fuel, and environmental
  risks (NWPCC, 2005).

• Well-designed  energy  efficiency  programs  provide
  opportunities for customers of all types to  adopt energy
  saving measures and  reduce  their energy bills. These
  programs can  help customers make sound energy-use
  decisions, increase control over their energy  bills,  and
  empower them  to  manage  their  energy  usage.
  Customers can experience significant savings depending
  on their own  habits and the program offered.

• Consistently funded, well-designed efficiency  programs
  are cutting electricity and natural gas load—providing
  annual savings for a given program year of 0.15 to 1
  percent  of  energy  sales.  These savings  typically  will
  See Chapter 6: Energy Efficiency Program Best Practices, Tables 6-2 and 6-3, for more information on energy efficiency programs reviewed.
 7-6    National Action Plan for Energy Efficiency

-------
  accrue at this level for 10 to 15 years. These programs
  are  helping  to  offset 20  to  50 percent of expected
  energy growth in  some regions without compromising
  end-user activity or economic well being.

• Research and development enables a continuing source of
  new  technologies  and  methods for  improving  energy
  efficiency and helping customers control their energy bills.

• Many state and regional studies have found that pursuing
  economically attractive, but  as  yet  untapped,  energy
  efficiency could yield more than 20 percent savings in total
  electricity demand  nationwide by  2025. These  savings
  could help cut load growth by  half or more compared to
  current forecasts. Savings in direct use of natural gas could
  similarly  provide a  50 percent or  greater reduction in
  natural gas demand  growth.  Energy savings  potential
  varies  by customer segment, but there are cost-effective
  opportunities for all customer classes.

• Energy efficiency programs are being operated successfully
  across many different contexts: regulated and unregulated
  markets;  utility, state,  or third-party  administration;
  investor-, publicly-,  and cooperatively-owned utilities; and
  gas and electric utilities.

• Energy efficiency resources are  being acquired through a
  variety of mechanisms including system benefits charges
  (SBC), energy efficiency portfolio standards (EEPS), and
  resource  planning (or cost-of-service) efforts.

> Cost-effective  energy  efficiency  programs exist  for
  electricity and natural gas, including programs that can
  be specifically targeted  to reduce peak load.
 • Effective models exist for delivering gas and electric energy
  efficiency programs to all customer classes. Models might
  vary for some programs based on whether a utility is in the
  initial stages of energy efficiency programming or has been
  implementing programs for years.

 • Energy efficiency programs, projects, and policies benefit
  from established and stable regulations, clear goals, and
  comprehensive evaluation.

 • Energy efficiency programs benefit from  committed
  program  administrators and oversight  authorities,  as
  well as strong stakeholder support.

 • Most  large-scale  energy efficiency  programs   have
  improved  productivity,  enabling  job   growth in the
  commercial and industrial sectors.

 • Large-scale energy efficiency  programs  can reduce
  wholesale market prices.
References

Northwest Power and Conservation Council [NWPCC]
    (2005, May). The 5th Northwest Electric Power and
    Conservation Plan, 
-------

-------
            Additional  Guidance
Appendix  on  Removing the
     A:  Throughput  Incentive
The National Action Plan for Energy Efficiency provides policy recommendations and options to support a
strong commitment to cost-effective energy efficiency in the United States. One policy that receives a
great deal of attention is reducing or eliminating the financial incentive for a  utility to  sell  more
energy—the throughput incentive. Options exist to address the throughput incentive, as discussed in more
detail in this  appendix.
 Overview

In order to eliminate  the conflict between the  public
service objectives of least-cost service on the one hand,
and a utility's profitability objectives on the other hand,
it is necessary to remove the throughput incentive. Some
options for removing the throughput incentive are gen-
erally called decoupling  because these options "decouple"
profits from sales volume. In its simplest form,  decou-
pling  is  accomplished  by  periodically  adjusting  tariff
prices so that the utility's revenues (and hence its profits)
are, on a total company basis, held relatively constant in
the face of changes in  customer consumption.

This appendix explains options to address the throughput
incentive by changing  regulations and the  way  utilities
make  money, to ensure that utility net income and cover-
age of fixed costs are not affected solely by sales volume.

Types of Decoupling

Utilities and regulators have implemented  a  variety of
different approaches to remove the throughput  incen-
tive. Regardless of  which approach is used, a frame of
reference  is created, and used to compare with  actual
results. Periodic tariff price adjustments true  up  actual
results to the expected results  and are critical  to the
decoupling approach.

•Average revenue-per-customer. This approach is often
 considered for utilities, where their underlying costs
 during the period between rate adjustments do not
 vary  with consumption.  Such  can  be the case for a
  wires-only distribution company, where the majority of
  investments are in the wires and transformers used to
  deliver the commodity.

• forecast revenues over a ;. eriod of nmc ind u-iC ,) /w/-
  ancing account. This approach is often considered for
  utilities where a significant portion of the costs (primarily
  fuel) vary with  consumption.  For these cases, it might
  be best to use a price-based decoupling mechanism for
  the commodity portion of electric service (which gives
  the utility the incentive to  reduce fuel and other vari-
  able  costs), while  using  a revenue-per-customer
  approach for the "wires" costs. Alternatively,  regula-
  tors can use traditional tariffs for the commodity por-
  tion and apply decoupling only to the wires portion of
  the business.
Sample Approach to Removing the
Throughput Incentive1
Implementing decoupling normally begins with a tradi-
tional revenue requirement  rate case. Decoupling can
also be overlaid on existing tariffs where there is a high
confidence that those tariffs continue to represent the
utility's underlying revenue requirements.

Under traditional rate of return regulation:

      Price (Rates) = Revenue Requirement/Sales
              (test year or forecasted)
 In this section, the revenue per customer approach is discussed, but can be easily adapted to a revenue forecast approach.
To create a sustainable, aggressive national commitment to energy efficiency
                                    Appendix A-1

-------
The revenue requirement as found in the rate case will not
change again until the next rate case. Note that the rev-
enue  requirement contains  an  allowance  for profit and
debt coverage. Despite all the effort in the rate case to cal-
culate the revenue requirement, what really matters after
the rate case is the price the consumer pays for electricity.

After the rate case:
           Actual revenues = Price * Actual Sales
And
        Actual Profit = Actual Revenue -Actual Costs
Based on the rate case "test year" data, an average revenue-
per-customer value  can  then be  calculated for each
rate class.

      Revenue Requirement t0 /number of customers t0 =
               revenue per customer (RPC)

Thus, at time "zero"(t0),  the company's revenues equal
its number of customers  multiplied by the revenues per
customer, while the prices paid by  customers equal the
revenues to be  collected divided  by  customers' con-
sumption  units (usually expressed as  $/kW for metered
demand and $/kWh for metered energy). Looking for-
ward, as the number of customers changes, the  revenue
to be collected changes.

   Revenue Requirement tn = RPC * number of customers tn

For each future period  (t1( t2..., tn), the new revenue to
be collected is then  divided  by the expected  consump-
tion to periodically derive a new price, the true-up.

      Price (Rates) tn = Revenue Requirement tn / Sales tn

               True up = Price tn - Price t0

Prices can also be trued-up based on deviations between
revenue and cost forecasts and actual results, where a
forecast approach is used. Note that no redesign of rates
is necessary as part of decoupling. Rate redesign might
be desirable for other reasons (for more information on
changes that  promote energy efficiency, see Chapter 5:
Rate Design), and decoupling does  not interfere with
those reasons.

The process can be augmented by various features that,
for  example,  explicitly factor  in  utility productivity,
exogenous events (events of financial significance, out
of control of the utility), or factors that might change
RPC over time.
Timing of Adjustments

Rates can be  adjusted  monthly, quarterly, or annually
(magnitude of any tn). By making the adjustments more
often, the magnitude of any price change is minimized.
However, frequent adjustments will impose some addi-
tional administrative expense. A plan that distinguishes
commodity cost from other costs could have more fre-
quent  adjustments for  more  volatile  commodities  (if
these are not already being dealt with by an adjustment
clause). Because the inputs used for these adjustments
are relatively straight-forward, coming directly from the
utility's billing  information, each filing should be largely
administrative and not subject to a significant controversy
or litigation.  This  process  can  be  further streamlined
through the use of  "deadbands," which allow for small
changes in either direction in revenue or profits  with no
adjustment in  rates.
Changes to Utility Incentives

With decoupling in place, a prudently managed utility will
receive revenue from customers that will cover  its fixed
costs, including profits. If routine costs go up, the utility will
absorb those costs. A reduction in costs  produces  the
opportunity for additional earnings. The primary driver for
profitability growth, however, will be the  addition of new
customers, and the greatest contribution to profits will be
from customers who are more efficient—that is, whose
incremental costs are the lowest.
Appendix A-2    National Action Plan for Energy Efficiency

-------
An effective decoupling plan should lower utility risk to
some degree. Reduced risk should  be reflected in the
cost of  capital and, for investor-owned utilities, can be
realized through  either an increase in the debt/equity
ratio, or a decrease in  the return on equity investment.
For all utilities, these changes will flow through to debt
ratings and credit requirements.

In addition, decoupling can be combined with perform-
ance  indicators to ensure that service quality  is main-
tained, and that cost reductions are the result of gains in
efficiency and not a decline in the level of service. Other
exogenous factors, such as inflation, taxes,  and economic
conditions, can also be  combined with  decoupling; how-
ever, these factors do not address the primary purpose of
removing the disincentive to efficiency. Also, if there is a
distinct  productivity for the electric  utility as compared
with the general economy, a factor accounting for it can
be  woven into the revenue per customer  calculations
over time.
Allocation of Weather Risk

One specific factor  that is  implicit  in any  regulatory
approach (whether it be traditional regulation or decou-
pling) is the allocation of weather risk between utilities
and their customers. Depending on the policy position of
the regulatory agency, the risk of weather changes can
be allocated to either customers or the utility. This deci-
sion  is inherent to the rate structure, even if the regula-
tory  body makes no cognizant choice.

Under traditional  regulation,  weather risk  is  usually
largely borne by  the  utility, which means that the utility
can suffer shortfalls if the weather is milder than normal.
At the same time, it can enjoy windfalls if the weather is
more extreme than  normal.  These  scenarios  result
because, while revenues will change with weather, the
underlying cost structure typically does not. These situa-
tions translate directly into greater earnings  variability,
which implies a higher required cost of capital.  In order
to allocate the weather risk to the utility, the "test year"
information  used to compute the base revenue-per-cus-
tomer values should be weather normalized. Thereafter,
with each adjustment to prices, the consumption data
would weather normalize as well.
 Potential Triggers and
 Special Considerations in
 Decoupling Mechanisms

Because decoupling is a different way of doing business
for regulators and utilities, it is prudent to consider off-
ramps  or triggers that can  avoid unpleasant surprises.
The following are some of the approaches that might be
appropriate to consider:

•Banding of rate adjustments. To minimize the magni-
 tude of adjustments, the decoupling mechanism could
 be premised on a "dead band" within which no adjust-
 ment would be made.  The effect would be to reduce
 the number  of tariff changes  and  possibly,  but not
 necessarily, the associated  periodic filings.

 The plan can also  cap  the amount of any single rate
 adjustment. To the extent it is based on reasonable
 costs  otherwise recoverable under the plan, the excess
 could be  set aside in  a regulatory  account for later
 recovery.

• Banding of earnings. To control the profit  level of the
 regulated entity within  some bounds, earnings greater
 and/or less than certain limits can be shared with cus-
 tomers.  For example, consider a scenario in which the
 earnings band is 1  percent on  return on  equity (either
 way) compared to the allowed return found in the most
 recent rate case. If  the plan would share results outside
 the band 50-50, then if the utility earns +1.5 percent of
 the target, an amount equal to 0.25 percent of earnings
 (half the excess) is returned to consumers through a price
 adjustment. If the utility  earns -1.3 percent of the target,
 however, an amount equal 0.15 percent of earnings (half
 the deficiency) is added to the price. Designing this band
To dilate a sustainable, aggressive national commitment to energy efficiency
                                       Appendix A-3

-------
 should  leave the utility with ample incentive to make
 and benefit  from process engineering improvements
 during  the plan, recognizing that a  subsequent rate
 case might result in the benefits accruing  in the long
 run to consumers. While the illustration is  "symmetri-
 cal,"  in practice, the band can be asymmetrical in size
 and sharing  proportion to assure the proper balance
 between consumer and utility interests.

1 Course corrections for customer count changes, major
 changes  for unique  major customers,  and large
 changes  in  revenues-per-customer.  Industrial  con-
 sumers might experience more volatility in average use
 per customer calculations because there are typically a
 small number of these customers and they can be quite
 varied.  For example, the addition  or deletion of one
 large customer (or of a work shift for a large customer)
 might make  a significant difference in the revenue per
 customer values for that class, or  result in  appropriate
 shifting of revenues among customers.  To address this
 problem, some trigger or off-ramp might be appropriate
 to review  such unexpected  and  significant changes,
 and to modify the decoupling  calculation  to account
 for them.  In  some cases, a  new rate  case  might  be
 warranted from such a change.
'Accounting tor utilities whose marginal a?ซ"Me.-> /<(
 customer are significantly different than their embedded
 average revenue per customer If a utility's revenue per
 customer has been changing rapidly over time, imposi-
 tion of a revenue-per-customer decoupling mechanism
 will have the effect of changing its profit growth path.
 For example, if incremental revenues per customer are
 growing rapidly, decoupling will have the effect of low-
 ering future  earnings,  although  not  necessarily below
 the company's allowed rate of  return. On the other
 hand, if incremental  revenues per customer are declin-
 ing, decoupling will have the effect of increasing future
 earnings. Where these trends are strong and there is a
 desire to make decoupling "earnings neutral," vis-a-vis
 the status quo  earning path, the revenue-per-customer
 value can be tied to an upward  or downward growth
 rate. This type  of adjustment is more oriented toward
 maintaining  neutrality than reflecting any  underlying
 economic principle.  Care should be  taken  to exclude
 recent growth in revenues per customer that are driven
 by inefficient consumption (usually tied to the utility
 having a pro-consumption marketing program).
Appendix A-4   National Action Plan for Energy Efficiency

-------
                                                                                                     TT KX 'Y
 Appendix  Business  Case
      B:   Details
 To help natural  gas and electric utilities,  utility regulators, and partner organi. tior   :c Mimunitdte thf>
 business case for energy efficiency, the National Action Plan for Energy Effici- icy . r  i\ides an Energy
 Efficiency Benefits Calculator (Calculator available at www.epa.gov/cleanenergyeea< ?/ tnplan.htm). This
 Calculator examines the financial impact of energy  efficiency on major  stakeholders  and was  used to
 develop the eight cases discussed in Chapter 4: Business Case for Energy  Efficiency. Additional details on
 these eight cases are described in this appendix.
Overview

A business case is an analysis that shows the benefits of
energy efficiency to the utility, customers, and  society
within an approach that can lead to actions by utilities,
regulators, and other stakeholders. Making the business
case for energy efficiency  programs requires a different
type of analysis than that required for traditional supply-
side  resources.  Because adoption  of energy efficiency
reduces  utility  sales and utility size, traditional metrics
such as impact  on  rates  and total earnings  do  not
measure the benefits  of energy efficiency.  However,  by
examining other metrics, such as customer bills and utility
earnings  per share, the benefits to ,111 stakeholders of
adopting  energy efficiency can be demonstrated.  These
benefits include reduced customer bills,  decreased cost
per unit of energy provided, increased net resource sav-
ings, decreased emissions, and  decreased  reliance on
energy supplies.

This appendix provides more detailed summary and inter-
pretation  of results for  the  eight  cases discussed  in
Chapter  4:  Business Case  for  Energy  Efficiency.  All
results are from the Energy Efficiency Benefits Calculator's
interpretation tab.
To create a sustainable, aggressive national commitment to energy efficiency
                                      Appendix B-1

-------
Case 1: Low-Growth Electric and  Gas Utility
Utility Perspective

Utility Financial Health - Small Changes
The change in utility financial health depends on whether or not there are decoupling mechanisms in place, if there are share-
holder incentives in place (for investor-owned utilities), the frequency of rate adjustments, and other factors. Depending on
the type of utility,  the measure of financial health changes. Investor-owned utility health is measured by return on equity
(ROE), while publicly or cooperatively owned utility health is measured by cash position or debt coverage ratio.
                        Electric
Gas
Investor-Owned Utility Comparison of
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ROE% - EE no Decoupling
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— - • Target ROE%





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-------
Customer Perspective

Customer Bills - Decrease
In the first year, customer utility bills increase because the cost of the EE program has not yet produced savings. Total cus-
tomer bills decline over time, usually within the first three years, indicating customer savings resulting from lower energy
consumption.
                        Electric
Gas
Percent Change in Customer Bills

3% -
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1 1 1 ! 1 1 1 1
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•^^™ Change in Customer Bills (%) - EE and Decoupling


Utility Rates - Mild Increase
The rates customers pay ($/kWh, $/therm) increase when avoided costs are less than retail rates, which is typically the case
for most EE programs. Rates increase because revenue requirements increase more quickly than sales.
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Utility Average Rate - EE no Decoupling
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To create a sustainable, aggressive national commitment to energy efficiency
                Appendix B-3

-------
Societal Perspective
Societal Net Savings - Increase
The net savings are the difference of total utility costs, including EE program costs, with EE and without EE. In the firs~ year,
the cost of the EE program is a cost to society. Over time, cumulative EE savings lead to a utility production cost savings
that is greater than the EE program  cost.  The graph shape is therefore  upward sloping.  Total Societal Net Savings is the
same with and without decoupling; therefore, only one line is shown.
                         Electric
                                                                               Gas
     Annual Total Societal Net Savings
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              Total Societal Net Savings ($M)
                                                          Annual Total Societal Net Savings
                                                                Ol
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                                                                m
                                                                    -510

                                                                    -$15
                                                                    Total Societal Net Savings ($M)
Total Societal Cost Per Unit - Declines
Total cost of providing each  unit of energy (MWh, therm) declines over time because of the impacts of energy savings,
decreased  peak load requirements, and decreased  costs during peak  periods. Well-designed EE  programs can  deliver
energy at an average cost less than  that of new power sources. When the two lines cross, the annual cost of EE equals the
annual savings resulting from EE. The  Societal Cost and Societal Savings are the same with and without decoupling.
     Delivered Costs and Benefits of EE
        $400
        $300
        $200
        $100
                 2    3
                                             9   10
                             Year
              • Societal Cost ($/MWh saved)

               Societal Savings ($/MWh saved)
Delivered Costs and Benefits of EE
S5

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^~^~ Societal Cost ($/therm saved)
Societal Savings ($/therm saved)


 Appendix B-4    National Action Plan for Energy Efficiency

-------
Emissions and Cost Savings   Increase
Annual tons of emissions saved increases. Emissions cost savings increases when emissions cost is monetized. Emissions
costs and savings are the same with and without decoupling.
                         Electric
     Annual Emissions Savings
          50
•-—Tons N0_ Saved
  Tons PM-10 Saved
ซ• - Tons SO Saved
*—Tons CO Saved
—Tons VOC Saved
.—1000 Tons CO, Saved
                                              O
                                              u
                                              O
                                              O
                                              O
                                        10
                                                                     Gas
                                                Annual Emissions Savings
                                                                                       Year
Growth Offset by EE - Increase
As EE programs ramp up, energy consumption declines. This comparison shows the growth with and without EE, and illus-
trates the amount of EE relative to load growth.  Load growth and energy savings are not impacted by decoupling. With
load growth assumed at zero, no load or percent growth offset shown.
     Percent Growth Offset by Energy Efficiency
                                             160%
                          Year
               1 Energy Savings - EE (GWh)

               • Load Growth - No EE (GWh)

                Growth Offset by EE (%)
                                                Percent Growth Offset by Energy Efficiency

                                                  7,000-
                                                                                                        — 15%
                                                                                                          25%
                                                                                                          10%
                                                                                                        — 5%
                                                                      5   6
                                                                      Year
                                                                                                        10
                                                    - - -  -  Energy Savings - EE (Mcf)

                                                    ——— —  Load Growth - No EE (Mcf)

                                                             Growth Offset by Et (%)
To create a sustainable, aggressive national commitment to energy efficiency
                                                                                      Appendix B-5

-------
Peak Load Growth - Decrease
Peak load requirements decrease because peak capacity savings are captured due to EE measures. Peak load is not impacted
by decoupling.
                        Electric
Gas
Comparison of Peak Load Growth
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Forecasted Growth - No EE
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Comparison of Peak Load Growth

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2 3 4 5 6 7 8 9 10
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" - Forecasted Growth - No EE
-^— — Forecasted Growth - EE and Decoupling


Appendix B-6   National Action Plan for Energy Efficiency

-------
Case 2: High-Growth  Electric and Gas  Utility

Utility Perspective

Utility Financial Health - Small Changes
The change in utility financial health depends on whether or not there are decoupling mechanisms in place, if there are share-
holder incentives in place (for investor-owned utilities), the frequency of rate adjustments, and other factors. Depending on
the type of utility, the measure of financial health changes. Investor-owned utility health is measured by ROE, while publicly
or cooperatively owned  uti ity health is measured by cash position or debt coverage ratio.
                        Electric
Gas
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ROE% - No EE
ROE% - EE no Decoupling
— — ROE% - EE and Decoupling
	 - - Target ROE%

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Return on
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2 3 4 5 6 7 8 9 10
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	 - - Target ROE%




Utility Earnings - Results Vary
Utility earnings depend on growth rate, capital investment, frequency of rate adjustments, and other factors. If EE reduces
capital investment, the earnings will be lower in the EE case, unless shareholder incentives for EE are introduced. However,
utility return (ROE or earnings per share) may not be affected.
U1
i
5
Vs
u-
C
C
C
re
u_



ility E<
$100-
$80-
$60-
1
$40-
$20-
$0 -
1
arnings

. , - • ,



1 I I I I I I I
234567891
Year
Earnings SMM - No EE
Earnings $MM - EE no Decoupling
^^— ^^_ Earnings $MM - EE and Decoupling

)



U1
i
2
t>ฐ
U"
C
C
C
a:
u_
ility Earnings


i


-------
Customer Perspective
Customer Bills - Decrease
In the first year, customer utility bills increase because the cost of the EE program has not yet produced savings. Total cus-
tomer bills decline over time, usually within the first three years, indicating customer savings resulting from lower energy
consumption.
                        Electric
Gas
Percent Change in Customer Bills


—
on j /o
C
oj -y /o -
cn
H3




S*^^
^S*Ss^^^xx^*^ป_







2 3 4 5 6 7 8 9 10
Year
Change in Customer Bills (%) - EE no Decoupling
~™~ Change in Customer Bills (%) - EE and Decoupling


Percent Change in Customer Bills
4%
2% -
cฃ 0% -
00
— -7%
CQ i!ฐ
c
• - _4



xnpariso
$0.30 -
$0.25 -
$0.20 -
$0.15-
$0.10-
1
n of Average Rate





23456789
Year
Utility Average Rate - No EE
Utility Average Rate - EE no Decoupling
"~~^^^~ Utility Average Rate - EE and Decoupling



10



Comparison of Average Rate
1
CD
JZ
ta=
CD
rt
Cฃ

-------
Societal Perspective

Societal Net Savings - Increase
The net savings are the difference of total utility costs, including EE program costs, with EE and without EE. In the first year,
the cost of the EE program is a cost to society. Over time,  cumulative EE savings lead to a utility production cost savings
that is greater than the EE  program cost. The graph shape is  therefore  upward sloping. Total Societal Net Savings  is the
same with and without decoupling; therefore, only one line is  shown.
                        Electric
Gas
Annual Total Societal Net Savings
i
v=
'a
c
a
or:
"it
a
X
C

V



ffr

-------
Emissions and Cost Savings - Increase
Annual tons of emissions saved increases. Emissions cost savings increases when emissions cost is monetized.  Emissions
costs and savings are the same with and without decoupling.
                       Electric
Annual E
70 y
60-
1
I/")
L/l
o iu
\—
10-
0 i
missions Savings
— • — Tons N0i Saved
Tons PM-10 Saved
— x— Tons S02 Saved
	 * — Tons CO Saved
	 Tons VOC Saved
ป 1000 Tons C0; Saved
/
-inn
/-
//
^ A
/f^^^
^/*^-*^
y^^"^
^^
- 180
-160 -a
L 140 g
LO
- 120 0~
- 100 ^
- 80 ^0
-60 ง
-40 ฐ
• 20
2 3 4 5 6 7 8 9 10
Year
Gas
Annual Emissions Savings
90 -i


70 -
OJ
S 50 -
i/i
c 40-
o

10 -
0ป
— " — Tens NO^ Saved
Tons PM-10 Saved
— *— Tons SO, Saved

* Tons CO Saved
— •— 1000 Tons CO, Saved





s
/ ^

jS ~/^

jr 	 •
jf ^p

•S'.s'
sฃSr
sjr
^













1 2 3 4 5 6 7 8 9 10
Year
Growth Offset by EE - Increase
As EE programs ramp up, energy consumption declines. This comparison shows the growth with and without EE, and illus-
trates the amount of EE relative to load growth. Load growth and energy savings are not impacted by decoupling. With
load growth assumed at zero, no load or percent growth offset shown.
Percent Growth Offset by Energy Efficiency
_c
C3







./
/ -
/
/
/
/ . . - - •
_S- * ~ *
^ - ' '•
^<* ' '
- 140%
- 120%
- 100%
- 80%
- 60%
- 40%
- 20%
u T 1 1 1 1 1 1 1 1 u/0
1 2 3 4 5 6 7 8 9 10
Year
- - - - Energy Savings - EE (GWh)
— — Load Growth - No EE (GWh)
Growth Offset by EE {%)
Percent Growth Offset by Energy Efficiency
7,000
6,000
5,000
M_ 4,000
u
3,000
2,000
1,000
0 i
/
/
/ -
/
/
/ J
/?.'-'"'"
/57o
- 20%
- 15%
- 10%
- 5%
234 5 6 7 8 9 10
Year
- - - • Energy Savings - EE (Mcf)
— — — Load Growth - No EE (Mcf)
Growth Offset by EE (%)

Appendix B-10   National Action Plan for Energy Efficiency

-------
Peak Load Growth - Decrease
Peak load requirements decrease because peak capacity savings are captured due to EE measures. Peak load is not impacted
by decoupling.
                        Electric
Gas
Cc
>mparison
160%'
> 1 50%
ii 140% -
ฐ 130%
~0 120%-
03
O
— ' 110%-
CO
ai 1 00% "
90% H
of Peak Load Growth

Jx
,^s^
^^X"^^
jx"x'^
^^^


2 3 4 5 6 7 8 9 10
Year
Forecasted Growth - No EE
— — • — Forecasted Growth - EE and Decoupling

Comparison of Peak Load Growth
>
V
u_
'c
^
~c
fT
C
-^
rc
a
Q_





100%-









2 3 4 5 6 7 8 9 10
Year
Forecasted Growth - No EE
— - -^™ Forecasted Growth - EE and Decoupling


To creafe a sustainable, aggressive national commitment to energy efficiency
               Appendix B-11

-------
Case 3: Low-Growth with Power Plant  Deferral
Utility Perspective

Utility Financial Health - Small Changes
The change in uti ity financial health depends on whether or
not there are decoupling mechanisms in  place, if there  are
shareholder incentives in place (for investor-owned utilities),
the frequency of rate adjustments,  and  other  factors.
Depending on the type of utility, the measure of financial
health changes. Investor-owned utility health  is measured by
ROE, while publicly or cooperatively owned  utility health is
measured by cash position or debt coverage  ratio.
Utility Earnings - Results Vary
Utility earnings depend on growth rate, capital investment,
frequency of rate adjustments, and other factors. If EE reduces
capital investment, the earnings will be lower in the EE case,
unless shareholder incentives for EE are introduced.  However,
utility return (ROE or earnings per share) may not be affected.
In
Re
i
LLJ
0
X
ro
1—
1




i/estor-C
turn on
15%T
12%-
9%-
6%-
3% -
wned Utility Comparison of
Equity


i i
* *
f *
\ i
'


1 1 1 1 1 1 1 1
2 3 4 5 6 7 8 9 10
Year
• • " ' ROE% - No EE
ROE% - EE no Decoupling
—— — ROE% - EE and Decoupling
— - - Target ROE%





Utility Earnings

-------
Customer  Perspective

Customer Bills -  Decrease
In the first year, customer utility bills increase because the
cost of the EE program has not yet produced savings.  Total
customer bills  decline  over  time,  usually within the first
three  years,  indicating  customer  savings  resulting  from
lower energy consumption.
     Percent Change in Customer Bills
      OJ
      CTi
             Change in Customer Bills (%) - EE no Decoupling

             Change in Customer Bills (%) - EE and Decoupling
Utility Rates - Mild Increase
The  rates customers pay ($/kWh)  increase when avoided
costs are less than retail rates, which is typically the case for
most EE programs. Rates increase because revenue require-
ments increase more quickly than sales.
     Comparison of Average Rate


         $0.30


     €   $0.25
                Utility Average Rate - No EE

                Utility Average Rate - EE no Decoupling
                • Utility Average Rate - EE and Decoupling
Societal Perspective

Societal Net Savings - Increase
The  net savings  are the difference  of  total utility costs,
including EE program costs, with EE and without EE. In the
first  year, the  cost of the EE program is a cost to society.
Over time, cumulative EE savings lead to a utility production
cost  savings that is greater than the  EE program cost. The
graph shape is therefore upward sloping. Total Societal Net
Savings is the same with and  without decoupling; there-
fore, only one ine is shown.
                                                                Annual Total Societal Net Savings
                                                                 OJ
                                                                 C
                                                                 o
                                                                un
                                                                     -$400
                                                                    -$600
                              Year
                                                                         Total Societal Net Savings ($M)
To create a sustainable, aggressive national commitment to energy efficiency
                                         Appendix B-13

-------
Total Societal Cost Per Unit - Declines
Total cost of providing each unit of energy (MWh) declines
over time  because of the  impacts  of  energy savings,
decreased peak load requirements, and  decreased costs
during  peak periods. Well-designed  EE programs can
deliver  energy at  an average cost less than that  of new
power  sources. Societal  savings increase when an infra-
structure project is delayed and then decrease when built.
When the two lines cross, the annual cost of EE equals the
annual savings resulting from EE.
Growth Offset by EE - Increase
As EE programs ramp  up, energy consumption declines.
This comparison shows the growth with and without EE,
and illustrates  the amount of EE relative to load  growth.
Load  growth and  energy savings  are  not impacted  by
decoupling. With load growth assumed at zero,  no load or
percent growth offset shown.
Delivered Costs and Benefits of EE
_C
^




$o -








23456789
Year
— — Societal Cost ($/MWh saved)
Societal Savings ($/MWh saved)


10
    Percent Growth Offset by Energy Efficiency

      1,400 -
                                                              1,200
                                                               600
                                                                                                   10
                                                                 •  - • - Energy Savings - EE (GWh)

                                                                 ——— Load Growth - No EE (GWh I

                                                                        Growth Offset by EE (%)
Emissions and Cost Savings - Increase
Annual tons of emissions saved increases. Emissions cost
savings increases when emissions cost is monetized.
Emissions costs and savings are the same with and with-
out decoupling.
Peak Load Growth - Decrease
Peak  load  requirements decrease because peak  capacity
savings are captured due to EE measures.  Peak load is not
impacted by decoupling.
Annual 1
60-
50-
T3
> 40
LO
0
10-
Oi
•
Emissions Savings
— • — Tons NO, Saved
Tons PM-10 Saved
— x— Tons SO, Saved
. * Tons CO Saved
	 Tons VOC Saved
	 •— 1000 Tons C0; Saved
/

y
S^
'/ S-

x^X^"'
y^^
^^
- 200
- 180
-160 -o
- 140 TO
- 120 o"
U
- 100 un
-80 ฃ
-60 8
o
- 40 <-
- 20
\ I I I I 1 1 1 u
2 3 4 5 6 7 8 9 10
Year
Comparison of Peak Load Growth
>
1/1
in
*o
S?
"D

-------
Case 4 High-Growth  With  Power Plant Deferral
Utility Perspective

Utility Financial Health - Small Changes
The change in utility financial health depends on whether or
not there are decoupling mechanisms in place, if there are
shareholder incentives in place (for investor-owned utilities),
the frequency of  rate adjustments, and other factors.
Depending  on  the  type of utility, the measure of financial
health changes. Investor-owned utility health is measured by
ROE, while  publicly or cooperatively owned utility health  is
measured by cash position or debt coverage ratio.
Utility Earnings - Results Vary
Utility earnings depend on growth rate, capita  investment,
frequency of rate  adjustments, and  other  factors.  If  EE
reduces capital intvestment, the earnings will  be lower in
the EE case, unless shareholder incentives for EE are intro-
duced. However, utility return (ROE or earnings per share)
may not be affected.
    Investor-Owned Utility Comparison of
    Return on Equity
     O
     Ol
     <
         15%
         12%
         9%
                           ~T	1	T~
                            5    6    7
                            Year
               ROE% -NoEE

               ROE% - EE no Decoupling

               ROE% - EE and Decoupling

               Target ROE%
Ut
i
5
s
<~r
c
c
c
n:
LL



ility Ea
$100 n
$80-
$60-
i
$40-
$20-
$0-
rnings
/-*-*-—•
J ^~~~




1 1 1 1 1 1 1 1
234567891
Year
Earnings $MM - No EE
Earnings $MM - EE no Decoupling
— — — Earnings $MM - EE and Decoupling


3



To create a sustainable, aggressive national commitment to energy efficiency
                                       Appendix B-15

-------
Customer Perspective
Societal Perspective
Customer Bills - Decrease
In the first year,  customer utility bills increase because the
cost of the EE program has not yet produced savings. Total
customer bills decline  over time, usually within the first
three  years,  indicating  customer savings resulting from
lower energy consumption.
Percent Change in Customer Bills
v —
l/1
(E
c
a
c
c
ft
_c
L-





n no/ -





NSfc^
^^^"^^^Ssv^ x^-^
^Ss*^/^^*^x







2 3 4 5 6 7 8 9 10
Year
Change in Customer Bills (%) - EE no Decoupling
— •— Change in Customer Bills (%) - EE and Decoupling


Societal Net Savings - Increase
The  net savings are the difference of total  utility costs,
including EE program costs, with EE and without EE. In the
first  year, the cost of the EE program is a cost to  society.
Over time, cumulative EE savings lead to a utility production
cost  savings that is greater than  the EE program cost.  The
graph shape is therefore upward  sloping. Total Societal  Net
Savings is the same with and  without decoupling; there-
fore, only one line is shown.
Utility Rates - Mild Increase
The rates customers pay ($/kWh) increase when avoided
costs are less than retail rates, which is typically the case for
most EE programs. Rates increase because revenue require-
ments increase more quickly than sales.
                                                              Annual Total Societal Net Savings
                                                                       Total Societal Net Savings ($M)
Comparison of Average Rate
fn ^n
ฃ
_^
&
OJ
'S
en
OJ
0
2
OJ
3


1


As

- / - ,. - . .


JIV. IV | | | | | | | |
1 2 3 4 5 6 7 8 9 10
Year

- - - ' Utility Average Rate - No EE
Utility Average Rate - EE no Decoupling
^ — Utility Average Rate - EE and Decoupling


Appendix B-16  National Action Plan for Energy Efficiency

-------
Total Societal Cost Per Unit - Declines
Total cost of providing each unit of energy (MWh) declines
over  time  because  of  the impacts  of  energy  savings,
decreased peak  load requirements, and  decreased costs
during  peak  periods.  Well-designed  EE programs  can
deliver energy at an average cost less than that of new
power sources. Societal savings increase when  an infra-
 tructure project is delayed and then decrease when built.
When the two lines cross, the annual cost of EE equals the
annual savings resulting  from EE.
Growth Offset by EE - Increase
As EE programs ramp up, energy consumption declines. This
comparison shows the growth with and without EE, and
illustrates the amount of EE relative to load growth. Load
growth and energy savings are not impacted by decoupling.
With load growth assumed at zero,  no load or percent
growth offset shown.
     Delivered Costs and Benefits of EE
        $10,000-

         $7,500-

         $5,000-

         $2,500-

           $o-

        -$2,500-

        -$5,000-
             1   2
                             5    6
                             Year
             • Societal Cost ($/MWh saved)

              Societal Savings ($/MWh saved)
Percent Growth Offset by Energy Efficiency
_C
13






200 -
X
/.
/
/
/
/ 	
^ 	
- 140%
- 120%
- 100%
- 80%
- 60%
r 40%
- 20%
r i i i i i i i i u/o
1 2 3 4 5 6 7 8 9 10
Year
" " " " Energy Savings - EE (GWh)
— — — Load Growth - No EE  40-
CD
un
O
1—
10-
0'
1
missions Savings
— • — Tons NO, Saved
Tons PM- 10 Saved
—*— Tons S02 Saved
	 -• Tons VOC Saved

y

A
//'
f S-
/^^^
^^^ '.
J$-^
^^
23456
Year
'- 180
-160 -a
r 140 ง
l/l
- 120 cT1
u
- 100 w
-80 ^
- 60 o
o
- 40 ^
- 20
7 8 9 10

                                                        Peak Load Growth - Decrease
                                                        Peak load requirements decrease because peak capacity sav-
                                                        ings are captured due to EE measures.  Peak load  is not
                                                        impacted by decoupling.
Comparison of Peak Load Growth
>
LL.
"o
^
-0
TO
O
J*;
01
ฃ
ibuyo
1 50% "
140% "
130% "
120% "
110% "
100%-

.X
^x^^
^s^
^^^^
^•^^


au% i i i i i i i i
1 2 3 4 5 6 7 8 9 10
Year
Forecasted Growth - No EE
^~^~" Forecasted Growth - EE and Decoupling

To create a sustainable, aggressive national commitment to energy efficiency
                                        Appendix B-17

-------
Case 5: Vertically  Integrated Utility
Utility Perspective

Utility Financial Health - Small Changes
The change in uti ity financial health depends on whether or
not there are decoupling mechanisms in place, if there are
shareholder incentives  in place (for investor-owned utilities),
the frequency  of  rate adjustments, and other factors.
Depending  on the  type of uti ity, the measure of financial
health changes. Investor-owned utility health is measured by
ROE, while  publicly or  cooperatively owned utility health is
measured by cash position or debt coverage ratio.
Utility Earnings - Results Vary
Utility earnings depend on growth rate, capital investment,
frequency of rate  adjustments, and other factors.  If EE
reduces capital investment, the earnings will be lower in the
EE case, unless shareholder incentives for EE are introduced.
However, utility return (ROE or earnings per share) may not
be affected.
Investor-Owned Utility Comparison of
Re
i
LLJ
0
OL
X
CO
h-
a
<




turn on
15% -
12% -
9%-
6% -
3%-
Equity








2 3 4 5 6 7 8 9 10
Year
- - - • RQE% - No EE
ROE% - EE no Decoupling
— "— ROE% - EE and Decoupling
— • • Target ROE%





ut
fL
ฃ
b
L
ility Earnings
nnn
$80
>
- \ts\
/i
^n
~ t40
T3
JJ
Of} _

-------
Customer Perspective
Societal Perspective
Customer Bills - Decrease
In the first year,  customer utility bills increase  because the
cost of the EE program has not yet produced savings. Total
customer bills decline over time,  usually within the first
three  years,  indicating customer  savings resulting from
lower energy consumption.
    Percent Change in Customer Bills
    CO
    c
    O)
    en
        -15%

        -18%
        -21%
                             Year
            Change in Customer Bills (%) - EE no Decoupling

            Change in Customer Bills (%) - EE and Decoupling
Societal Net Savings - Increase
The  net savings  are the  difference of total utility costs,
including EE program costs, with EE and without EE. In the
first  year, the cost of the  EE program  is a  cost to society.
Over time, cumulative EE savings lead to a utility production
cost  savings that is greater than the EE program cost.  The
graph shape is therefore upward sloping. Total Societal Net
Savings is the same with  and without  decoupling; there-
fore, only one line is shown.
Utility Rates - Mild Increase
The rates customers pay ($/kWh) increase when avoided
costs are less than retail rates, which is typically the case for
most EE programs. Rates increase because revenue require-
ments increase more quickly than sales.
Annual Total Societal Net Savings


+-. $15
c $10

-------
Total Societal Cost Per Unit - Declines
Total cost of providing each unit of energy (MWh) declines
over time  because of  the  impacts of energy  savings,
decreased peak  load  requirements,  and decreased costs
during peak periods.  Well-designed  EE  programs  can
deliver energy at an average cost less than  that of new
power sources. When the two lines cross, the annual cost
of EE equals the annual savings resulting from  EE.  The
Societal Cost and Societal  Savings are the same with  and
without decoupling.
    Delivered Costs and Benefits of EE
       $400-
       $300-
       $200-
       $100-
         $0-
                 \
              ~T	1	1	1	1	l~
               234567

                           Year
 10
             • Societal Cost ($/MWh saved)

             Societal Savings ($/MWh saved)
Emissions and Cost Savings - Increase
Annual tons of emissions saved increases. Emissions cost
savings increases  when  emissions  cost is  monetized.
Emissions costs and savings are the same with and  with-
out decoupling.
            Growth Offset by tiE - Increase
            As EE  programs ramp  up,  energy consumption  declines.
            This comparison shows the growth  with and without EE,
            and illustrates the amount  of EE  relative to  load growth.
            Load  growth  and  energy  savings  are not  impacted by
            decoupling. With load growth assumed at zero, no load or
            percent growth offset shown.
Percent Growth Offset by Energy (Efficiency





-C

























	 ..
.^^*~^~^~
^^^^^
- 140%
- 120%
,- 100%

- 80%

- 60%
- 40%
- 20%
rw_
1 2 3 4 5 6 7 8 9 10
Year
- - - - Energy Savings - EE (GWh)
— — Load Growth - No EE (GWh)
Growth Offset by EE (%)

             Peak Load Growth - Decrease
             Peak  load  requirements  decrease  because peak capacity
             savings are captured due to EE  measures. Peak load is not
             impacted by decoupling.
     Annual Emissions Savings
                 Tons N0x Saved
                 Tons PM-10 Saved
                 Tons S02 Saved
                 Tons CO Saved
                 Tons VOC Saved
                 1000 Tons CO, Saved
T3
OJ
                                             o
                                             u
                                             1/1
                                             c
                                             o
                                             t—
                                             o
                                             o
                                             o
                                       -- 20
                                       10
Comparison of Peak Load Growth

1 DU7o
> 1 50%
u. 1 40% ~
ฐ 130%
~o 1 20% "I
03
o
^ 110%"
St 100%-




ป* ~ *
^^-*-*-^~' 	


aU7o ; i i i i i i i
1 2 3 4 5 6 7 8 9 10
Year

- - - Forecasted Growth - No EE
"~~ ^^ Forecasted Growth - EE and Decoupling

 Appendix B-20   National Action Plan for Energy Efficiency

-------
    Case 6:  Restructured Delivery-Only  Utility
    Utility Perspective

    Utility Financial Health - Small Changes
    The change in utility financial health depends on whether or
    not there are decoupling mechanisms in  place, if there are
    shareholder incentives in place (for investor-owned utilities),
    the frequency  of  rate adjustments,  and  other  factors.
    Depending on the type of utility, the measure of financial
    health changes. Investor-owned utility health  is  measured by
    ROE,  while publicly or cooperatively owned  utility health is
    measured by  cash position or debt coverage  ratio.
Utility Earnings - Results Vary
Utility earnings depend on growth rate, capital investment,
frequency of rate adjustments, and  other factors. If  EE
reduces capital investment, the earnings will be lower in the
EE case, unless shareholder incentives for EE are introduced.
However, utility return (ROE or earnings per share) may not
be affected.
Investor-Owned Utility Comparison of
Re
i
LLJ
O
X
ra
I—
turn on
15%-
12%-
aj






Equity






i i i i i ii
234567891
Year
- - ' ROE% - No EE
ROE% - EE no Decoupling
— — '^^ ROE% - EE and Decoupling
— - • Target ROE%


0




Utility Earnings
ttnn
s~~
2
55
tn
D
C
'c
0]
LU
ton
$60-
i
on
tn


n""-" '" " • ' 	 !•,„<•



*u 1 1 1 1 1 1 1 1
1 2 3 4 5 6 7 8 9 10
Year

- • - Earnings $MM - No EE
Earnings $MM - EE no Decoupling
— —"~^— Earnings $MM - EE and Decoupling


To create a sustainable, aggressive national commitment to energy efficiency
                                   Appendix B-21

-------
Customer Perspective
Societal Perspective
Customer Bills - Decrease
In the first year, customer utility bills increase because the
cost of the EE program has not yet produced savings.  Total
customer bills decline over time, usually within  the first
three  years,  indicating  customer savings  resulting  from
lower energy consumption.
Percent Change in Customer Bills
i
ui
m
c
OJ
0
c
re
_c
O



-3% -

"* 1}%

1QO/ __
TIOA _


—
*^^.
^^






i i i i i i i i
2 3 4 5 6 7 8 9 10
Year
Change in Customer Bills (%) - EE no Decoupling
^^— • Change in Customer Bills (%) - EE and Decoupling


Societal Net Savings - Increase
The net savings are the  difference of total utility costs,
including EE program costs, with EE and without EE. In the
first year, the cost of the EE program is a cost to society.
Over time, cumulative EE savings lead to a utility production
cost savings that is greater than the EE program cost.  The
graph shape is therefore upward sloping. Total Societal Net
Savings is the same with and  without  decoupling; there-
fore, only one line is shown.
Utility Rates - Mild Increase
The  rates customers pay ($/kWh) increase when avoided
costs are less than retail rates, which is typically the case for
most EE programs. Rates increase because revenue require-
ments increase more quickly than sales.
Annual Total Societal Net Savings
trie
S2
QJ
C
OJ
CO
"re
"a
c
on

-------
Total Societal Cost Per Unit - Declines
Total cost of providing each unit of energy (MWh) declines
over time  because of the impacts of energy  savings,
decreased peak  load  requirements,  and decreased costs
during   peak periods.  Well-designed  EE  programs  can
deliver energy at an average cost less  than  that of new
power  sources. When the two lines cross, the annual cost
of EE equals the annual savings  resulting from  EE. The
Societal Cost and Societal  Savings are the same with and
without decoupling.
Delivered Costs and Benefits of EE

> onn
$100
$0


\
V
^ 	

2 3 4 5 6 7 8 9 10
Year
— Societal Cost ($/MWh saved)
Societal Savings ($/MWh saved)


Emissions and Cost Savings - Increase
Annual tons of emissions saved increases. Emissions cost
savings  increases  when emissions  cost  is  monetized.
Emissions costs and savings are the same with and with-
out decoupling.
    Annual Emissions Savings
         70 -p

         60--

         50--
-•—Tons NQf Saved
   Tons PM-10 Saved
-*— Tons SO, Saved
-*—Tons CO Saved
	Tons VOC Saved
-ป—1000 Tons CO. Saved
                                        200
                                            o
                                            u
                                             !/!

                                            (2

                                            8
                                            o
                                      10
                                           Growth Offset by EE - increase
                                           As EE programs ramp  up, energy consumption declines.
                                           This comparison shows the growth with and without EE,
                                           and illustrates  the amount of EE relative to load growth.
                                           Load  growth  and  energy savings  are  not impacted  by
                                           decoupling. With load growth assumed at zero,  no load or
                                           percent growth offset shown.
Percent Growth Offset by Energy Efficiency
_C
5
(5











	 ;
^.^
^^^^^^
- 140%
- 120%
- 100%
- 80%
- 60%
- 40%
- 20%
no/..
r 1 i I 1 1 i I IT"'"
1 2 3 4 5 6 7 8 9 10
Year
- - - - Energy Savings - EE (GWh)
— — Load Growth - No EE (GWh)
Growth Offset by EE (%)

                                           Peak Load Growth - Decrease
                                           Peak load requirements decrease because peak  capacity
                                           savings are captured due to EE measures.  Peak load is not
                                           impacted by decoupling.
                                               Comparison of Peak Load Growth
                                                                      5   6
                                                                       Year
                                                                                         10
                                                                        Forecasted Growth - No EE
                                                                        Forecasted Growth - EE and Decoupling
To create a sustainable, aggressive national commitment to energy efficiency
                                                                                  Appendix B-23

-------
Case  7:  Electric Publicly and Cooperatively Owned Debt Coverage Ratio
Utility Perspective

Utility Financial Health - Small Changes
The change in utility financial health depends on whether or
not there are decoupling mechanisms in place, if there are
shareholder incentives in place (for investor-owned utilities),
the frequency of rate  adjustments, and  other  factors.
Depending on the type of utility, the measure of financial
health changes. Investor-owned utility health is measured by
ROE, while publicly or cooperatively owned  utility health is
measured by cash position or debt coverage ratio.
Utility Earnings - Results Vary
Utility earnings depend on growth rate, capital investment,
frequency  of  rate adjustments, and  other factors. If EE
reduces capital investment, the earnings will be lower in the
EE case, unless shareholder incentives for EE are introduced.
However, utility return (ROE or earnings per share) may not
be affected.
Pu
Oe
c
1
QJ
O
ro
Ol
blic Pow
;bt Cove
2.50 -i
T 2.00 -

o
~ 1.50 -i
Q




1.00 -1
er/Cooperative
rage Ratio


• * ..


23456789
Year
Debt Coverage Ratio - No EE
Debt Coverage Ratio - EE no Decoupling
^— ^^ Debt Coverage Ratio - EE and Decoupling


1



0



Utility Earnings
I


Si
c t/in -
03
LLJ

tn _

_ 	 —
-rr- — ^ • • . .'



123456789 10
Year

Earnings $MM - No EE
Earnings $MM - EE no Decoupling
^___^— Earnings $MM - EE and Decoupling

Appendix B-24   National Action Plan for Energy Efficiency

-------
Customer Perspective

Customer Bills - Decrease
In the first year,  customer utility bills increase because the
cost of the EE program has not yet produced savings.  Total
customer bills decline over  time, usually within  the first
three  years,  indicating customer savings  resulting  from
lower energy consumption.
   Percent Change in Customer Bills
    CO
    c

    0)
    01
    c
        -21%
            Change in Customer Bills (%) - EE no Decoupling

            Change in Customer Bills (%) - EE and Decoupling
Societal Perspective

Societal Net Savings - Increase
The  net savings are the difference  of  total  utility costs,
including EE program costs, with EE and without EE. In the
first  year, the cost of the EE  program is a cost to society.
Over time, cumulative EE savings lead to a utility production
cost  savings that is greater than the  EE  program cost. The
graph shape is therefore upward sloping. Total Societal Net
Savings is the same with and without decoupling; there-
fore, only one line is shown.
Utility Rates - Mild Increase
The rates customers pay ($/kWh)  increase when avoided
costs are less than retail rates, which is typically the case for
most EE programs. Rates increase because revenue require-
ments increase more quickly than sales.
Annual Total Societal Net Savings
v=
.ป—
'a
c
a
QC
ฃ
"a
'i~
c



tr;

tc
+->
mpariso
$0.30 -|
$0.25 -
$0.20 -
$0.15-
$0.10 -
n of Average Rate



^*^
	 x-^-^
1 I I I I I I I
234567891
Year
Utility Average Rate - No EE
Utility Average Rate - EE no Decoupling
•^— — — Utility Average Rate - EE and Decoupling


0



Jo create a sustainable, aggressive national commitment to energy efficiency
                                        Appendix B-25

-------
Total Societal Cost Per Unit - Declines
Total cost of providing each unit of energy (MWh) declines
over time  because  of  the impacts of energy  savings,
decreased  peak load requirements,  and decreased costs
during  peak  periods.  Well-designed EE  programs can
deliver  energy at an average cost less than that of new
power sources. When the two lines cross, the annual cost
of EE equals the  annual  savings resulting from  EE. The
Societal Cost and  Societal Savings are the same with and
without decoupling.
Delivered Costs and Benefits of EE

-C
t^
fn


\
V
^-— — __

1 1 1 1 1 1 1 1
2 3 4 5 6 7 8 9 10
Year
— — Societal Cost {$/MWh saved)
Societal Savings ($/MWh saved)


Emissions and Cost Savings - Increase
Annual tons of emissions saved increases. Emissions cost
savings  increases when  emissions  cost  is  monetized.
Emissions costs and  savings are the same with and with-
out decoupling.
Annual
60-
•o
il 40
ro
in
r3 30
O
I—
10-
1
Emissions Savings
— • — Tons N0i Saved
Tons PM- 10 Saved
— x— Tons SO, Saved
	 *— Tons CO Saved
	 Tons VOC Saved



/•
//
// ,/-
^.^^]
^/'^ :
^^^
^ i
- 180
-160 -o
r 140 ro
- 120 o"
- 100 ^
c
on O
- OU | 	
[ 60 o
O
• 40 ^
- 20
2 3 4 5 6 7 8 9 10
Year
Growth Offset by EE - Increase
As EE programs  ramp up, energy consumption declines.
This comparison  shows  the growth with and without EE,
and illustrates the amount of  EE  relative to load growth.
Load growth and energy savings are not impacted  by
decoupling. With load growth assumed at zero, no load or
percent growth offset shown.
Percent Growth Offset by Energy Efficiency
-C
u
I,1UU
1,200
1,000
800


o-




^J
^<^' '
	 ^' '
- 140%
- 120%
- 100%
- 80%
- 60%
- 40%
- 20%
r i ii ii ii i u/ฐ
2 3 4 5 6 7 8 9 10
Year
- - - - Energy Savings - EE (GWh)
— — — Load Growth - No EE (GWh)
Growth Offset by EE (%)

Peak Load Growth - Decrease
Peak load requirements  decrease because  peak capacity
savings are captured due to EE measures.  Peak load is not
impacted by decoupling.
Comparison of Peak Load Growth
ic no/
>
'LL.
"o
ฃ
-o
03
O
_i
-ฑฃ

-------
Case 8: Electric Publicly and Cooperatively Owned Cash Position
Utility Perspective

Utility Financial Health - Small Changes
The change in utility financial health depends on whether or
not there are decoupling mechanisms in place, if there are
shareholder incentives in place (for investor-owned utilities),
the frequency of rate adjustments,  and other factors.
Depending  on the type of utility, the measure of financial
health changes. Investor-owned utility health is measured by
ROE, while  publicly or cooperatively owned utility health is
measured by cash position or debt coverage ratio.
Utility Earnings ~ Results Vary
Utility earnings depend on growth rate, capital investment,
frequency of  rate  adjustments, and other factors.   If  EE
reduces capital investment, the earnings will be lower in the
EE case, unless shareholder incentives for EE are introduced.
However, utility return (ROE or earnings per share) may not
be affected.
Cash Position at End of Year
i
2
v3
^^
-C
ft
o
!5
OJ
"o
T3
C
LLJ



J8U
$60-
$50-
$40~




iii i i i i i
234567891
0
Year
Cash Position - No EE
Cash Position - EE no Decoupling
""•""•™ • Cash Position - EE and Decoupling

U1
i
2
tฐ
i/-
c
c
c
n:
u_
ility Earnings

-------
Customer Perspective
Societal Perspective
Customer Bills - Decrease
In the first year,  customer utility bills increase because the
cost of the EE program has not yet produced savings.  Total
customer bills decline over  time, usually within the first
three  years,  indicating  customer savings resulting  from
lower energy consumption.
Percent Change in Customer Bills
i
jฃ
m
c
a
a
c
TC
30A


•i% -

"> i™

5 ~'-"ฐ~



NS^-**~^-,
""* ^^\
N-— "^^x**— v
>





<• ' '" -i i i i i i i i i
1 2 3 4 5 6 7 8 9 10
Year

Change in Customer Bills (%) - EE no Decoupling
— •—— Change in Customer Bills (%) - EE and Decoupling


Societal Net Savings - Increase
The  net savings are the difference of  total  utility costs,
including EE program costs, with EE and without EE. In the
first  year, the cost of the EE program is a cost to  society.
Over time, cumulative EE savings lead to a utility production
cost  savings that is greater than the EE program cost.  The
graph shape is therefore upward sloping. Total Societal Net
Savings is the same with and without decoupling; there-
fore, only one line is shown.
Utility Rates - Mild Increase
The rates customers pay ($/kWh) increase when avoided
costs are less than retail rates, which is typically the case for
most EE programs. Rates increase because revenue require-
ments increase more quickly than sales.
                                                             Annual Total Societal Met Savings
                                                              0)
                                                              c
                                                              OJ
                                                              CQ
                                                              0>
                                                              "u
                                                              o
         $25

         $20

         $15

         $10

          $5

          $0

         •$5

         -$10

         -$15
                                                                                     5   6

                                                                                     Year
                                                                                                         10
                                                                      Total Societal Net Savings ($M)
Comparison of Average Rate
I



-------
Total Societal Cost Per Unit - Declines
Total cost of providing each unit of energy (MWh) declines
over time  because of  the impacts of energy  savings,
decreased peak  load  requirements, and decreased costs
during  peak periods.  Well-designed EE  programs  can
deliver energy at an average cost  less than  that of new
power sources. When  the two lines cross, the annual cost
of EE equals the annual savings resulting from  EE.  The
Societal Cost and Societal  Savings are the same with  and
without decoupling.
Growth Offset by EE - Increase
As EE  programs ramp  up,  energy  consumption declines.
This  comparison shows the growth with and without EE,
and  illustrates the amount  of EE relative to load growth.
Load growth  and  energy  savings  are not impacted  by
decoupling. With load growth assumed at zero,  no load or
percent growth offset shown.
     Delivered Costs and Benefits of EE
        $400
        $300
        $200
        $100
         $0
                           5   6
                            Year
                                              10
             • Societal Cost ($/MWh saved)

              Societal Savings ($/MWh saved)
Percent Growth Offset by Energy Efficiency
_C
5
e;












^^.
	 — *^*^
-~*^*^~*^
- 140%
- 120%
- 100%
- 80%
- 60%
L 40%
- 20%
i i i i ii i ii u™
2 3 4 5 6 7 8 9 10
Year
" " • " Energy Savings - EE (GWh)
*^^^^^™ Load Growth - No EE (GWh)
Growth Offset by EE (%)

Emissions and Cost Savings - Increase
Annual tons of emissions saved increases. Emissions cost sav-
ings increases when  emissions cost is monetized.  Emissions
costs and savings are the same with and without decoupling.
Peak Load Growth - Decrease
Peak load requirements decrease  because peak capacity
savings are captured due to EE measures.  Peak load is not
impacted by decoupling.
Annual Emissions Savings



T3
> 40.
 Saved
Tons PM-10 Saved
— x— Tons S0; Saved
	 Tons VOC Saved

/

/
/A
f A
/TSs*

<&^'
^
234567891
Year
• 180
'l60 -g
-140 5.
•120 cT
- 100 w
c
on O
- OU | 	
-60 8
o
- 40 -
20
0
0
Comparison of Peak Load Growth
4-
V
1_
II
M"
c
^
"C
s





_v
ฃ 100% -




- -__!_r— 	
- - -— — • — — •


1 2 3 4 5 6 7 8 9 10
Year

Forecasted Growth - No EE
^~~^~ Forecasted Growth - EE and Decoupling


To create a sustainable, aggressive national commitment to energy efficiency
                                       Appendix B-29

-------

-------

-------

-------

-------

-------