NRDC-ELPC's Position. NRDC-ELPC notes that Ameren’s energy efficiency plan falls short of the statutory target for PY4 by 59,000 MWh of potential savings, which represents roughly 20% of the savings that would be realized under the statutory target, falls even further short of the statutory target for PY5 by 154,000 MWh, or nearly 40%, and by PY6 Ameren proposes to achieve less than half of the statutory goal, falling short by 334,000 MWh or 60% of the target. While Ameren argues that it cannot reach the statutory target without exceeding the spending limit, NRDC-ELPC asserts that, Ameren fails to present sufficient evidence that its portfolio is maximized to achieve the highest level of savings achievable with the available funds. While Ameren presents a benchmarking analysis to show that it cannot meet the Act's unmodified savings goals, NRDC-ELPC suggests that the analysis shows that utilities have been known to achieve savings targets in the same range as the statutory targets Ameren faces, at costs that are consistent with the amounts Ameren may spend under the rate impact caps. NRDC-ELPC opines that Ameren has substantially underestimated the level of savings it could achieve within the limited budgets, and notes that various witnesses have offered no fewer than nine distinct programmatic changes, each of which would increase Ameren’s total savings within its allowed budget. Given the sheer number and variety of strategies that Ameren failed to consider before concluding that the targets were out of reach, NRDC-ELPC suggests the only appropriate response from the Commission would be to send the plan back to Ameren and required it to redesign its portfolio to achieve greater levels of savings. NRDC-ELPC suggests that a closer look at Ameren's benchmarking analysis shows not only that the statutory goals are achievable, but that similar goals are being achieved by utilities at roughly the same cost per first-year kWh savings that Ameren has to spend within its rate impact caps. NRDC-ELPC argues it is not appropriate to compare the cost per unit savings for utilities that are achieving a substantially higher savings target as a percentage of sales, because the higher savings goals would tend to drive a different mix of programs that could increase their cost of first-year kWh savings. If, instead, one compares only those portfolios analyzed in the benchmarking study that are achieving savings at levels closer to Ameren’s PY4 statutory goal (i.e., between 0.8 percent of sales...
NRDC-ELPC's Position. According to NRDC-ELPC, Ameren witness Xxxxxx suggests that only one process evaluation and one impact evaluation should be conducted for each program during the 3-year plan cycle. While NRDC-ELPC agree that limited evaluation dollars should be used conservatively and prioritized, NRDC-ELPC oppose what they describe as arbitrarily deciding that every program should be evaluated only once over a three year period. NRDC-ELPC suggest for example, a program that Ameren relies upon for a large amount of savings, the impacts of which are not well understood or is subject to changing market conditions may warrant more frequent evaluation. They urge Ameren to engage stakeholders through the SAG to develop a well-reasoned evaluation schedule for each program within the limitations of the evaluation budget. NRDC-ELPC believe this recommendation is consistent with the views expressed by both NRDC witness Xxxxxxx and AG witness Xxxxxxxxx.
NRDC-ELPC's Position. NRDC-ELPC indicate they agree with Ameren that some deeming of gross measure savings is appropriate, and urge the Commission to adopt some reasonable limitations on doing so. Specifically, NRDC-ELPC believe there is substantial evidence in the record to support a conclusion that it is appropriate to deem the gross measure savings values for a set of standard measures where the unit savings are not large, do not vary significantly between installations and where the number of installations is large enough that the average savings values can be reasonably accurate in aggregate. However, NRDC-ELPC urge that the Commission require that the actual deemed values for these measures should be determined through a separate proceeding. NRDC-ELPC assert that Ameren has not made available the detailed assumptions behind the deemed measure savings values in its current plan, and the expedited nature of this proceeding does not afford adequate time for assessment of those values. NRDC-ELPC generally agree with the recommendations of both witness Xxxxxxx and witness Xxxxxxxxx, who each urge a separate proceeding for the purpose of reaching agreement on deemed gross savings values, which may include an ongoing effort within the Stakeholder Advisory Process, and the development of a TRM which would document all of the assumptions underlying deemed savings values. They add that ELPC witness Xxxxxxxx also argues for creating a statewide TRM, and describes both the purpose and content of the Manual, including allowing a transparent and well-vetted set of deemed savings values. NRDC-ELPC state that Ameren agrees that a TRM is warranted, although it sees no role for the SAG in developing it. NRDC-ELPC urge that the Commission acknowledge that it is important for the credibility of these programs that stakeholders have been engaged in the development of the assumptions which are relied upon to ensure that savings are real. NRDC-ELPC provide a table, reproduced below, that provides the specific measures that they believe are appropriate for deeming the gross savings values. PROGRAMS Measures Appropriate for Deemed Savings Values Residential Lighting All Residential Energy Efficient Products All Residential HVAC All listed Residential Appliance Recycling All Residential Home Energy Performance CFLs, Showerheads, faucet aerators, smart strips, water heater insulation water heater setback Residential ENERGY STAR New Homes All Residential Multifamily CFLs, showerheads and faucet aera...
NRDC-ELPC's Position. NRDC-ELPC believe that for measures that are fewer in number, that will produce substantial changes and where the variations between installations will lead to very different results, the use of deemed savings values is inappropriate. Specific programs for which NRDC- ELPC believe the measure savings should be measured rather than deemed include those listed below. PROGRAMS Measures Inappropriate for Deemed Savings Values Residential Home Energy Performance all measures not listed in above table Residential Multifamily all measures not listed in above table Residential Moderate Income all measures not listed in above table Business Standard Incentive all measures not listed in above table Business Custom Incentive No deemed savings Business Retro-commissioning No deemed savings Business New Construction all measures not listed in above table
