AG's Position. The AG states that in each of the plan years, Ameren proposes to reduce the statutory efficiency savings goals to below the statutory requirements, as well as having the total savings amount decrease from year to year. The AG notes that the energy efficiency statute directs the Commission to review utilities’ Plans every three years, and enter an order, after public comment, within three months. The AG also notes the seven standards for review which were previously mentioned.
AG's Position. While Ameren is requesting the Commission approve a reduction of the electric energy savings goals, the AG believes that Ameren could revise its portfolio to sufficiently meet PY4 and PY5 statutory goals. Additionally, the AG notes that the PY6 goals can be revisited after the legislature has an opportunity to consider the statutory reports and whether modifications to the Act are appropriate. The AG notes that many jurisdictions are striving to increase the acquisition of cost- effective efficiency resources, including using new and innovative approaches that leverage outside capital, develop public-private partnerships, access federal grants, and other alternatives, and it appears that the Commission should direct Ameren to do the same. Even without leveraging additional outside funds, the AG believes that Ameren has taken a modest approach to designing its Plan 2 electric programs, arguing that Ameren’s portfolio does not fully incorporate a number of alternatives that could increase the rate of savings starting in PY4. The AG argues that Ameren should ensure that it maximizes appropriate contributions from gas ratepayers in all joint programs, as gas ratepayers could fund a greater portion of incentives for those measures that save both electricity and gas, so long as the total benefits accruing to gas ratepayers exceed its contributions. Additionally, the AG suggests that Ameren reduce administrative, marketing and research and development ("R&D") funds from the full 3% of budget limit for marketing and R&D, as this spending should be a lower priority until it is clear whether the rate impacts will be modified. The AG also urges a greater use of either on-bill or off-bill financing to support its programs while lowering the amount of rebate funds necessary to meet participation goals The AG suggests there should also be a shifting of resources from higher cost programs to lower cost programs, as Ameren’s current proposal allows flexibility to undertake these shifts as a way to meet goals if needed. In particular, the AG argues that Ameren should significantly increase its efforts at promoting specialty CFLs, which are not affected by federal standards and still offer large and very inexpensive savings. The AG further proposes that Ameren aggressively pursue grant funds, partnerships, and other leveraged resources, as appropriate and available, as well as consider upstream program models that can reduce total costs per kWh saved for future portfolio mo...
AG's Position. The AG notes that the gas energy efficiency portfolio is entering its first mandatory 3- year plan period under the Act, and thus lags the electric efforts by 3 years.4 As a result, the AG states that electric statutory goals reflect 0.8%, 1.0% and 1.4% per year incremental savings, respectively; while gas goals are much lower at 0.2%, 0.4% and 0.6%, respectively. In addition, the AG claims that Ameren is allowed to meet its gas goals by simply ensuring that cumulative 3-year plan savings meet the sum of each individual year’s goals. Another significant difference the AG notes is that Ameren’s gas spending cap is set at the ultimate maximum of 2% of revenue for each year, even during the first 3-year plan. The AG acknowledges that Ameren has already been implementing a voluntary gas program prior to the start of the first EEP 3-year plan, and should thus be well-positioned to capture savings in PY4 that exceed its statutory 0.2% goal. The AG supports Ameren’s intent not to pull back its gas program efforts, which would result in disruption to the market and abandonment of cost-effective savings the Ameren companies are well positioned to capture in PY4. However, because of the cumulative goals, the AG states that Ameren proposes to effectively hold its gas programs at a relatively constant level throughout the three years and not ramp up over time. The AG asserts that Ameren does not plan to meet PY5 and PY6 goals, while spending less than half the money available to it. Although such an approach technically meet the requirements of Section 8-104(c), the AG does not believe that this tactic is in the best interests of ratepayers. If Ameren pursues this strategy, the AG claims it will end the period with no greater depth of savings than it started with, however, the PY7 goal will be significantly higher, more than twice the amount of savings Ameren plans to capture in PY6. As a result, the AG does not believe that Ameren will be well-positioned to meet these more difficult PY7 goals, let alone maintain a ramp up through the PY7 through PY9 period, wherein goals will grow to roughly 12.6 million therms, or about four times Ameren’s planned depth of savings for PY6. To correct this "short-sighted" gas savings planning approach, the AG recommends that the Commission, at a minimum, approve Ameren’s first year gas goal and budget, but direct Ameren to significantly ramp up its savings and spending goals in PY5 and PY6 to at least ensure that Ameren captures an i...
AG's Position. The AG argues that the spending limitation provided in Section 8-104(d) of the Act should not tie a utility’s hands in its attempts to achieve statutory savings goals. The AG asserts that the Act simply limits the amount of annual collections for efficiency from ratepayers to no more than 2% of rates. The AG notes that program administrators in other jurisdictions are now actively considering an array of financing and other options to increase the funds available for energy efficiency without increasing rates. The AG opines that there is a significant difference between a rate cap and a spending cap, where non-ratepayer funds can be utilized. The AG submits that Ameren should be ordered to submit a plan that leverages outside resources in its attempt to cost-effectively deliver energy efficiency programs to its qualifying ratepayers and achieve the annual statutory goals.
AG's Position. The AG notes that Ameren bases its calculations of the gas savings requirements using forecast of gas delivery excluding self-directed customers ("SDC") and electric generation uses for each plan year, and thereby has proposed therm savings goals of 1,788,394; 3,576,788 and 5,363,183 for PY4, PY5 and PY6 respectively. The AG asserts that Ameren is calculating its annual gas goals as the appropriate percentage of only the gas commodity it sells, removing the gas load of those transport customers that purchase commodity from a third party. As a result, the AG claims that Ameren has excluded and underestimated the appropriate gas goals by roughly 45%. The AG notes that Staff also concluded that Ameren excluded from the calculation of the natural gas therm savings goals all gas sold by certified and other alternative gas suppliers. The XX xxxxx that Staff sponsored an alternative calculation of the gas savings goals consistent with Section 8-104(m) that included the gas sold to all transportation customers except for those customers who satisfied the requirements of Section 8-104(m), and those revised calculations resulted in gas savings goals of 2,351,808; 4,703,615 and 7,055,423 for PY4 through PY6, respectively. The AG claims that Ameren’s specific exclusion of the gas sold by alternative gas suppliers for purposes of calculating the savings goals presented in its direct testimony is inconsistent with the statute, which specifically states that only those transportation customers who satisfy the specific requirements of subsection (m) shall be excluded from the calculation of the statutory gas savings requirements. The AG recommends that the Commission order Ameren to revise its calculation of the gas savings goals consistent with the recommendations of Staff.
AG's Position. The AG believes a three-year EM&V plan is premature because it is too proscriptive and could result in a poor allocation of limited EM&V funds. According to the AG, limited EM&V funds should be allocated where and when they are most useful. The AG believes this determination should consider things such as, but not limited to: • How new is the program? • How much of Ameren’s resources are being expended on a given program? • When did the program start? • Is the program expected to be continued for a long time or phased out? • What share of the portfolio impacts come from the program? • How uncertain are a particular program’s impacts, and how big is that uncertainty relative to the overall portfolio savings? • Is the program a new, complex delivery system, such that an early process evaluation is warranted? • Are the market and program well understood, and are reasonable values such as NTG ratios known with reasonable certainty from other jurisdictions? • Is the market very dynamic and changing rapidly enough to warrant two evaluations during a single plan period? The AG asserts that these factors are consistent with the SAG NTG framework, which the AG recommends be utilized in these EEPs. The AG says that Exhibit A to its Brief was the basis for the Settlement Stipulation agreed to in the ComEd case, Docket No. 10-0570, Joint Exhibit 1.0. The AG believes that framework should likewise be adopted for Ameren.
AG's Position. The AG recommends the Commission reject the Ameren approach and instead direct Ameren that: • Only “prescriptive” or standard measures should be deemed; • There should be an ongoing SAG process to review and adjust values following the provisional deeming, and SAG members as well as Ameren, its implementers, and evaluators should be able to propose modifications; • Ongoing modifications should be adopted no later than 3 months from establishment of new values in the SAG, rather than at the beginning of the following plan year; and • The utilities should establish and maintain a TRM that documents in a transparent way how savings are estimated, and supports on-going effective modification and version control. Additionally, the AG recommends that the Fixed Values be consistent with the SAG NTG framework. AG Exhibit 1.0 and the Settlement Stipulation agreed to in the ComEd EE case, Docket No. 10-0570. The AG recommends that the evaluation cycle be consistent with the SAG NTG framework, AG Exhibit 1.0 and the Settlement Stipulation agreed to in the ComEd EE case, Docket No. 10-0570. The AG states that for standard measures, this would include provisionally deemed gross measure savings, which would be revisited annually and periodically updated with new information, and then used prospectively beginning with the next plan year start (June 1) following the development of new values.
AG's Position. The AG recommends that no deeming be permitted for “non-standard” measures. The AG argues that these are by definition site-specific “custom” measures, and as such should be developed by Ameren or its contractors on a customized basis relying on standard engineering approaches, and subject to verification through evaluations. The AG believes that AG Exhibit 1.0 and the Settlement Stipulation agreed to in the ComEd case, Docket No. 10-0570, should be considered as an appropriate model for retroactive treatment of any assumed savings for non- standard measures.
