Alternative Approaches to Infrastructure Solutions. In response to a question posed by the Department regarding the role of PA-administered energy efficiency and demand reduction programs in alternative approaches to infrastructure solutions, the PAs state that “The targeting of a specific infrastructure project is not the focus of the statewide deployment of energy efficiency.” NEEC-Common 2-8. The PAs continue: “Nonetheless, statewide program design and incentive levels help set a baseline condition to incrementally build upon as specific alternative approaches to infrastructure solutions are considered. The determination of whether an alternative is feasible would necessarily include a comparison of possible alternatives and their costs. If it were determined that an alternative approach may be feasible, the utilities would then have to evaluate the most appropriate funding source separately, through other dockets before the Department, building off of statewide programs incrementally, as necessary.” This stated willingness to iterate upon the statewide programs to help avoid infrastructure upgrades in a specific area is heartening. See, e.g., Petition of Boston Gas Company d/b/a National Grid for Approval of a Firm Transportation Agreement with Tennessee Gas Pipeline Company, LLC, pursuant to X.X. x. 164, § 94A, D.P.U. 15-34, at 37 (2015) (“The Company also considered energy efficiency in determining its load requirements. In Three-Year Energy Efficiency Plan for 2013 through 2015, D.P.U.12-100 through D.P.U.12- 111, at 161 (2013), the Department found that the energy savings expected to be generated through the Company’s energy efficiency programs are consistent with the achievement of all available cost-effective energy efficiency. Once these energy efficiency savings are netted out from the demand side, there is no requirement that the Company model energy efficiency as a supply resource because there are no Department-approved energy efficiency or demand reduction measures on which the Company can rely to meet its design-day or design-season requirements.”). CLF looks forward to working with other stakeholders, the PAs’ distribution utility colleagues, and the Department to assess the feasibility of a territory-specific alternative approach the next time an infrastructure upgrade is proposed by a PA.
