Commission Analysis and Conclusion. No evidence was adduced to suggest that this amendment fails to meet the federal or state standards for interconnection agreements. The Commission’s review of the amendment reveals no such deficiencies. The Commission Staff analysis reported nothing in this amendment that appears to discriminate against any telecommunications carrier not a party to the agreement; nothing in the implementation of any portion of the amendment that appears inconsistent with the public interest, convenience, and necessity, in violation of Section 252(e)(2) of the federal Telecommunications Act; and nothing inconsistent with state law or other Commission telecommunications orders.
Commission Analysis and Conclusion. The Commission first notes that Ameren acknowledges that the initial plan which it proposed will require the Commission to modify the statutory savings targets for energy savings in Section 8-103 of the Act in light of the rate impact limitations contained in the legislation. Ameren explains that the rate impact limitations contained in the legislation prevent it from meeting the statutory savings requirements and, in fact, the Commission notes the proposed energy savings by Ameren go down each plan year. Following the submission of this plan, Staff and the various Intervenors made various suggestions on how Ameren could achieve greater savings, while still complying with the rate impact provisions of the statute. It appears to the Commission that most parties acknowledge that Ameren will be unable to meet the required savings, at least in PY5 and PY6, due in part to the expected spending staying virtually flat, while the required savings continue to increase. Based in part on these various suggested changes, Ameren has proposed a modified plan, which the Commission must now consider. The Commission notes that its options in this proceeding by statute are to either accept Ameren's modified plan which incorporates reduced energy efficiency savings; or reject the modified plan, and within 30 days describe in detail the reasons for the disapproval and describe a path by which the utility may file a revised draft of the plan to address the Commission's concerns. A third path, which Ameren and some other parties suggest, would be for the Commission to direct Ameren to make a compliance filing incorporating the provisions of this Order. The Commission begins its analysis by looking at what the statute requires of Ameren in its energy efficiency plans for the years in question. The statute in question calls for energy savings of 0.8% of energy delivered in the year commencing June 1, 2011 ("PY4"); 1% of energy delivered in the year commencing June 1, 2012 ("PY5"); and 1.4% of energy delivered in the year commencing June 1, 2013 ("PY6"). Ameren indicates that this would translate into required electric energy efficiency savings of 309,732 MWh in PY4, 392,640 MWh in PY5, and 557,787 MWh in PY6, while it appears that Ameren proposes that the total savings standard be modified to 250,551 MWh in PY4; 238,372 MWh in PY5; and 223,540 MWh in PY6. Before analyzing the various proposed changes suggested for Ameren's modified plan, the Commission would like to express its c...
Commission Analysis and Conclusion. The Commission notes that Ameren indicates it has calculated its therm savings energy efficiency goals by applying the percentage reductions in the statute to sales volumes consumed by customers served under Rider S, which corresponds to approximately 1.8, 3.6 and 5.3 million therms for PY4, PY5 and PY6, respectively. Ameren is responsible for 80% of the gas savings, or 1.4, 2.8 and 4.2 million therms, and its Plan 2 proposes savings of 3.0 million therm savings for PY4, and 3.1 million therms for PY5 and PY6. The Commission acknowledges that the gas savings goals in Section 8-104 of the Act are cumulative, and that Ameren's projected savings over the three years exceed the required savings over those same three years. Staff disagrees with Ameren’s calculation of its savings goal, noting that Ameren chose to base its calculation only on retail customers who purchase their gas directly from Ameren, while Staff believes that the calculation should be based on the total amount of gas delivered to retail customers. Staff indicates that based on its calculations, the gas savings goals should be set at 2.35 million therms for PY4, 4.7 million therms for PY5, and 7.06 million therms for PY6. The Commission notes that CUB indicates in its brief that Ameren proposes to spend $9.49 Million in PY4, $10.26 Million in PY5, and $10.9 Million in PY6. CUB indicates it supports Ameren’s plan to spend less than the maximum allowed under the Act to achieve its required gas savings, and supports granting Ameren the flexibility it has requested on the spending cap, provided Ameren provides the SAG information on any major changes to its programs that result in spending more of its natural gas budget. The AG is concerned that if Ameren pursues a strategy that just meets the requirements of Section 8-104, Ameren will end PY6 with no greater savings than it started with, and will be required in PY7 to more than double the savings from PY6. The AG recommends that the Commission approve Ameren’s plan for PY4, but require Ameren to significantly ramp up its savings and spending goals so that Ameren captures incremental savings of at least 0.6% of load in PY6. The AG argues this will allow Ameren to not spend all its available funds, while still ensuring a reasonable ramp up to future years. The Commission believes that the parties are in agreement on Ameren's natural gas spending limit for the three years of the plan, $56,641,420. Staff and Ameren both agree with this amount, althou...
