Ameren's Position. Ameren states that it calculated the natural gas savings targets by applying the percentage reductions in the Act to sales volumes consumed by customers served under Rider S - System Gas Service. Ameren notes that therms sold to customers under Rider T, transportation customers, were not included in the therm savings targets. Ameren asserts that customers served under Rider T are those non-residential customers who purchase gas from a supplier other than Ameren. Ameren notes that it excluded transportation customers from its calculation of the natural gas savings goals, as it interprets that Act as requiring that natural gas savings requirements be based upon the total amount of gas delivered to retail customers, and that according to the Act, transportation customers should not be considered retail customers. Ameren avers that it as it does not sell the gas to transportation customers, transportation customers are not retail customers, and Ameren properly excluded transportation customers from its calculation of the natural gas savings targets. Ameren notes that the other gas utilities filing energy efficiency plans pursuant to 8-104 all appear to have used the same basic approach, therefore the Commission should approve Plan 2’s natural gas savings goals as reasonable.
Ameren's Position. Ameren indicates it originally proposed one impact and one process evaluation per program per plan cycle. In response to Intervenors’ concerns, Ameren has proposed a modified three-year evaluation cycle that explicitly allows the independent evaluator to conduct less than one impact evaluation and less than one process evaluation every year, with a general goal of conducting one impact evaluation and one process evaluation for each program during each Plan cycle. Further, Ameren says the independent evaluator shall be responsible for developing a 3- year evaluation plan at the beginning of the Plan cycle, for updating this 3-year evaluation plan as necessary to take into account changing market conditions, and for developing evaluation plans for each program. In so doing, Ameren indicates that the independent evaluator should seek advice from Staff, stakeholders and from Ameren, but final plans shall be developed solely at the discretion of the independent evaluator who Ameren claims will also be responsible for managing evaluations to ensure they meet the Commission’s approved policies and to ensure that they stay within the Act’s spending limitation of 3% of total portfolio costs. Ameren asserts that under its proposal, the independent evaluator will continue to gather on-the-ground measurements for each program within each 3-year plan cycle, including annual measurements to verify participation. By varying the frequency of impact evaluations, Ameren contends it is allowing the independent evaluator to increase the quality of individual evaluations, for example, by allowing the evaluator to increase sample sizes or make use of mini-studies or other ad hoc approaches as requested by AG witness Xxxxxxxxx. Ameren claims the proposal also frees up resources for the independent evaluator to use in conducting additional, more sophisticated process evaluations, which will provide confidence to the Commission and other parties that Ameren is using the best delivery approaches. Ameren believes this should increase confidence in evaluation results and ameliorate Intervenors’ concerns.
Ameren's Position. Ameren says it proposes to be held accountable through a verified participation process where annual plan savings and cost-effectiveness calculations will be made using participation values that are verified by the independent evaluator and updated each year.
