Application No. A.14-11-011

Exhibit No:_________________

Witness:_Aguirre, Mark / Yao, Hugh

Application of Southern California Edison Company (U 338E) for Approval of its Energy Savings Assistance and California Alternate Rates for Energy Programs and Budgets for Program Years 2015-2017.

Application 14-11-007

(Filed November 18, 2014)

And Related Matters.

Application 14-11-009 Application 14-11-010 Application 14-11-011

PREPARED REBUTTAL TESTIMONY OF MARK AGUIRRE AND HUGH YAO ON BEHALF OF SOUTHERN CALIFORNIA GAS COMPANY

BEFORE THE PUBLIC UTILITIES COMMISSION

OF THE STATE OF CALIFORNIA

May 22, 2015

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OCALGASUNOPPOSE

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as requests th

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MA/HY-2

• Approval of the mix of measures reflected in Application Attachment A-5. 1

• Approval to add new measures as proposed in Section II.E.1.b. of the Direct 2

Testimony of Mark Aguirre and Hugh Yao. 3

• Approval of the marketing and outreach elements requested in the Direct Testimony 4

of Mark Aguirre and Hugh Yao. 5

• Approval to use the methodology adopted for the eligible population as revised in 6

Mark Aguirre and Hugh Yao, pending resolution of the “unwillingness” factor 7

contested by some parties. 8

• Approval to relax the modified 3 Measure Minimum (“3MM”) Rule in the cases of 9

multifamily units and measures installed in anticipation of a third measure as 10

proposed in the Direct Testimony of Mark Aguirre and Hugh Yao, which was 11

unopposed by any party.1 12

• Approval to offer Energy Education to income qualified customers that do not meet 13

the 3MM Rule. 14

• Approval to continue integration and leveraging efforts. 15

• Approval of statewide impact evaluation, low income needs assessment, energy 16

education (Phase 2) and cost-effectiveness studies for the 2015-2017 program cycle. 17

1 Direct Testimony of Southern California Edison (“SCE”), November 18, 2014, pp.99-100; Report of The Office of Ratepayer Advocates on The Consolidated Proceedings Regarding Energy Saving Assistance Program , April 27, 2015, K.C. Watts-Zagha and Louis Irwin, witnesses, p.42; Direct Testimony of Pacific Gas and Electric Company (“PG&E”), p.2-13; Prepared Testimony of Allan Rago on behalf the Energy Efficiency Council , p.5; Testimony of James Hodges on Behalf of The East Los Angeles Community Union (“TELACU”), the Maravilla Foundation, and the Association of California Community and Energy Services, p. 14; Testimony of Marin Clean Energy, pp.9-10.

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proposal

proposal,

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Daniel Rend

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ORA in its te

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provements i

which was av

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TIES’ SPEC

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o provide custof using 8 year Advocates oApril 27, 201

MA/HY-3

CIFIC TES

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address in th

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nrollments ar

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ties concerns

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ear Go-Back Rewer technolo

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Gas proposed

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Rule because ogies and serv

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ce, studies an

High Efficien

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home improvles for go-baceedings RegarLouis Irwin,

002 Re-

ork (“TURN

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MA/HY-4

SoCalGas’ proposal to target high energy users for the HE Furnace.5 SoCalGas also proposes in 1

the early stages of implementing the 10-Year Go-Back Rule, to target customers considered high 2

energy users.6 This element is particularly important because, while it is projected to involve a 3

relatively small number of units, it will provide SoCalGas with practical experience in targeting 4

measures based on usage – an element not currently part of the program, and which will require 5

development of new procedures and system enhancements. 6

Similarly, the proposed gradual ramp up of go-back units side by side with an achievable 7

number of 2020-goal units provides the opportunity to develop needed procedures and systems 8

to manage the program under a scenario that is inevitable as 2020 goal units are eventually 9

depleted. The modest number of go-backs proposed would be sufficient to begin to gauge 10

response to the program among go-back customers, and to adapt the marketing message 11

accordingly. While there will be transitional challenges to any new programmatic initiatives, 12

waiting for every 2020 goal unit to be treated before beginning to seek out go-backs will 13

exacerbate these challenges, an issue that will be felt most directly by SoCalGas’ contractors, 14

and acknowledged by ORA.7 15

ORA states “the Commission should deny the ESA II proposals, and the associated 16

budgets of PG&E and SoCalGas.”8 It is important to clarify that if the Commission adopts 17

SoCalGas’ recommended annual unit goal of 110,000 treated homes, there should not be a 18

separate, incremental budget reduction associated with denial of the 10-year Go-Back Rule 19

5 “SoCalGas plans to limit HE Furnaces only to those dwellings that have furnaces at or below AFUE. Furthermore, SoCalGas ensures that HE Furnaces will go to those most in need and also those with the greatest potential to save energy.” Id. at p. 13. 6 “SoCalGas also proposes, in the early stages of implementing the Rule, to target customers considered high energy users, based on energy burden, and based on health, comfort and safety criteria.” Direct Testimony of Daniel Rendler, at p.23. 7 K.C. Watts-Zagha and Louis Irwin, at p. 41. 8 Id. p. 40.

MA/HY-5

proposal. As stated in Direct Prepared Testimony, “SoCalGas does not expect a significantly 1

different cost per treated unit whether the Commission approves, denies or alters SoCalGas’ 2

proposal to include 10-year go-back units already treated since 2002. . . Removing the 10-year 3

go-back proposal altogether would not impact SoCalGas’ proposed budget, as long as total 4

treated units are maintained at 110,000 per year.”9 Thus, in the event the Commission does not 5

adopt the 10-year go-back proposal, but adopts SoCalGas’ proposed 110,000 treated homes goal, 6

there should be no adjustment from the proposed budget. 7

Although TURN supports SoCalGas’ go-back proposal, it identified a concern that go-8

backs could result in inadequate priority to the most difficult 2020-goal units (not previously 9

treated since 2002). While noting that SoCalGas has committed to, and proposed a plan for 10

achieving the 2020 goal, these concerns and the necessary controls were also identified by 11

SoCalGas, “SoCalGas proposes to prioritize units not yet treated since 2002. In order to do so, 12

SoCalGas will need to control the outreach and enrollment activities of contractors. SoCalGas 13

believes that it can develop the needed systems and controls during 2015. These consist of 14

system enhancements to track and limit authorization of contractors to work leads on post-2002 15

re-enrollments, as well as some new program rules and contract provisions that can be designed 16

and rolled out as early as mid-2015.”10 17

The referenced contract provisions specifically will include separate goals and dollars for 18

each contractor allocated re-enrollments under the 10-year Go-Back Rule. System enhancements 19

will include providing contractors the ability to distinguish eligible previously-enrolled leads 20

from never-enrolled and ineligible customers, providing SoCalGas the ability to separately track 21

contractor production within the re-enrollment and never-enrolled categories, and providing 22

9 Prepared Direct Testimony of Mark Aguirre and Hugh Yao, dated November 18, 2014, at p. 130. 10 Prepared Direct Testimony of Mark Aguirre and Hugh Yao, dated November 18, 2014, at p. 30.

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years, the pr

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uct 24% “Uf Setting 202

detail its pro

Needs Asse

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MA/HY-7

& Electric Company (PG&E), Southern California Edison (SCE), and San Diego Gas & Electric 1

(SDG&E) also proposed similar revisions to willingness.14 2

In its testimony, EEC advises against making any adjustments at this time: “before the 3

IOUs lower their estimated eligible population; the Commission should wait to see if the 4

recommendations put forth in the applications for increasing participation through policy 5

changes and increased efforts actually work.”15 6

Despite minor variations among the IOUs,16 all generally support immediate adjustments 7

in program expectations based on the LINA results. Other than EEC, no party has argued that 8

the unwillingness assumption should not be revised upward. The Commission itself, in 9

maintaining the previously adopted 5% unwillingness assumption in D.12-08-044, anticipated 10

modifying this assumption for 2015-2017, “at this time the Commission still does not have 11

adequate data to modify this figure. However, the new Needs Assessment being conducted 12

pursuant to this decision in the upcoming months should inform the Commission on this issue for 13

the upcoming 2015-2017 program cycle.”17 14

Maintaining the status quo as proposed by EEC will have negative consequences. In 15

calculating remaining untreated customers in its application, SoCalGas relied on the 2013 Athens 16

14 SDG&E proposes 19% unwillingness (See Prepared Direct Testimony of Alex Kim p.AYK-18 “The calculation for the percentage of total eligible that are unwilling to participate was based on the research conducted in the LINA Study. The LINA Study estimated that 48% of the eligible, non-treated homes would be unwilling to participate in the ESA Program. For 2013, the year in which the research was conducted, this is analogous to 19% of the total eligible population in SDG&E’s service territory.”) PG&E proposes 48% unwilling among the untreated population, which is not converted to a percent of all eligible (see Landry/O’Drain/Smith Table 2-3 p.2-18.) This is equivalent to SoCalGas’ approach as pointed out at Aguirre/Yao p.15 “24% of the eligible population … corresponds to the conclusion in the LINA Study that 52% of current program non-participantes were willing.” SCE proposes 21.5% unwillingness (See “Energy Savings Assistance (ESA) Program Plan and Budget Proposal for the 2015-2017 Program Cycle”, Lim/Samiullah/Weber, at p.19 Table II-3. 15 EEC Prepared Testimony of Allan Rago, at p.5 16 The IOUs are SoCalGas, SDG&E, SCE, and PG&E. 17 LINA Study, stating at p. 264.

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h estimate to

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5% (from th

INA study, i

73,000 addi

ave led to an

ng for 10-ye

would be roug

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SoCaC.Upgra

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lds than they

appropriate s

rojection is baed at Aguirre/065/unit in 20have resulted

n 2017, for a tremoved, all

nwillingness aed Testimony

project that

territory.18

he program c

t would resu

tional custom

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ar go-back r

ghly $230 m

rs and little c

nwilling to p

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the Center f

rate data col

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y have had to

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ased on 1% an/Yao p.130, in016, and $1,0d in incrementtotal of $230 m else equal thassumption, cof Dmitri Be

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re-enrollmen

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participate.

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for Accessib

llected throu

ing persons w

argues that “

a much broa

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ouseholds wi

nnual growthncremental un

089/unit in 20tal budget of million. Even

he 3-year ESAcompared withelser, Submitt

MA/HY-8

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mission inste

ning in 2012)

itional 19%,

ar for the rem

Gas of at leas

nts. The incr

three years,1

ng benefit to

t Should Bestomers wit

ble Technolo

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with disabili

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ader informa

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ith disabled m

as adopted innits would res17. Treating $73 million inn if the re-enr

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8

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or 437,000

maining 6 ye

st 153,000 un

remental imp

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SoCalGas’

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llment of cus

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ely maintain

ation base ab

going forwa

members.” 2

n D.08-11-03sult in prosed73,000 additn 2015, $78 mrollment unitsposal would bon as currentlyf of The Cente

3 million inc

retain the un

n a 24% unw

customers to

ears. Such a

nits per year

pact on SoC

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low-income

To Ensure Nes Can Be C

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stomers in th

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bout disabled

ard as the ut

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1, at p.110. d budget impational customemillion in 201s, totaling $37

be roughly $56y proposed. er for Accessi

come-eligibl

nwillingness

willingness ba

o be treated

an assumptio

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CalGas’ prop

uences for

customers w

Needed IT Completed

mends the IOU

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customer

ributing data

d customer

ilities seek t

agrees that

act of $998/uners per year w16, and $79 7 million over68 million us

ible Technolo

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by

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incorpora

Applicati

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disability

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prescript

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tems. As sta

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customers th

esignation.”2

ral Administ

SoCaD.When

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when required

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mpact Evalu

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Hodges, opp

ive duct seal

ive duct seal

ed Direct Tested Direct Testestimony (W

CU Testimony

ta is benefic

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as’ main cus

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number of te

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timony of Matimony of Maatts-Zagha), ay,at p. 2.

ial, and as p

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s of ESA Pro

stomer datab

ram disabilit

ication and n

e, SoCalGas

et proposal t

osal To Elimired For Co

hat duct testi

4.22 The prim

ests relative

ORA suppor

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les Commun

on of Califor

ation of this

al.24 Witness

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ark Aguirre anark Aguirre anat p.14.

MA/HY-9

art of its 201

cements to fa

oCalGas is p

ogram custom

base (“CIS”)

ty records in

notification b

respectfully

to ensure the

minate Ductompliance S

ing and seali

mary reason

to seals, wh

rts SoCalGas

rable saving

nity Union (“

rnia Commu

measure and

s Hodges do

ppropriate or

nd Hugh Yaond Hugh Yao

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15 – 2017 L

acilitate this

proposing IT

mers who ar

that also tra

n CIS, will m

benefits asso

y requests th

ese planned u

t Testing anhould Be A

ing be retire

cited for eli

hich reduces

s’ proposal s

gs for Duct T

“TELACU”)

unity and Ene

d offers supp

oes not offer

r preferable r

, at p. 97. , dated Novem

ow Income P

transfer of i

enhancemen

re identified

acks special h

make it possib

ociated with

hat the Comm

upgrades can

nd Sealing AAdopted

d as a Progr

imination of

the cost effe

stating that “

Testing and S

), the Marav

ergy Service

port for SDG

any details w

relative to th

mber 18, 201

Programs

information

nts, so that t

as having a

handle

ble to offer E

the special

mission appr

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As A Measur

am measure

f this measur

ectiveness fo

“[t]he recent

Sealing.”23 T

villa Foundat

es (“ACCES

G&E’s

why the

he SoCalGas

4, at p. 105.

from

the

ESA

rove

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re

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or

The

tion

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proposal

effectiven

SoCalGa

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standards

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common

SoCa

discussio

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variation

necessita

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25 Testimo26 Testimo

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ness challen

as proposal.

The CE.All IOThoro

The testimony

measures be a

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core set of m

alGas is gene

on, but does n

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ns, the housin

ates an IOU-

ness criteria

While propos

ps or other m

and linear flu

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zation, pipe

offers throug

ony of Amy Dony of Amy D

would still p

nges in other

CommissionOUs, Or Reqough Vettin

y of NRDC,

adopted for

nology where

ource of each

measures.

erally not op

not believe t

on to the afo

ng stock acro

specific mea

.

sing that the

methods,”26 w

uorescents; i

, faucet aera

insulation an

gh the ESA p

Dryden on behDryden on beh

provide this

installation

n Should Noquire Utiliti

ng Through

NCLC, and

all utilities,

e possible.”2

h IOU fuel w

pposed to sta

that establish

orementione

oss the state

asure mix tha

set of core m

witness Dryd

interior LED

ators, HVAC

nd Tier 2 po

program all o

half of NRDChalf of NRDC

MA/HY-10

measure wh

circumstanc

ot Impose A ies to Offer Regulatory

d CHPC witn

stating that t

5 She goes o

would need to

andardizing t

hing a core s

d climate zo

and across i

at takes into

measures to b

den suggests

Ds; low flow

C tune up, wa

ower strips.”

of witness D

C, NCLC, andC, NCLC, and

0

hen required

ces, the Com

Common SOr Elimina

y Process

ness Dryden

the intent is

on to state th

o be conside

terminology

set of measu

one variation

individual IO

o account me

be adopted “

s for conside

showerhead

ater heater re

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Dryden’s sug

d CHPC, at pd CHPC, at p

by code. G

mmission sho

Set of ESA Mate Measure

n proposes th

to “create co

hat variation

ered before e

for ease of c

ures is necess

ns and IOU f

OU service t

easure feasib

“could be de

eration, “Inte

ds; thermosta

epair/ replac

e noted that

gested meas

.11.

.11.

Given the cos

ould approve

Measures foes Without

hat a common

onsistency in

ns in climate

establishing

comparison

sary or

fuel source

territories

bility and cos

efined throug

erior CFL

atic

cement,

SoCalGas

sures that are

st-

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or

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a

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st-

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e

MA/HY-11

appropriate to a gas utility: low flow showerheads, thermostatic shower valves, faucet aerators, 1

HVAC (furnace) tune up, water heater repair/replacement, weatherization, and pipe 2

insulation.Furthermore, SoCalGas routinely reviews and evaluates offerings of other utilities and 3

newly available technology, and shares its information with other ESA Program providers. The 4

Commission is not overly burdened by reviewing the proposals of each of the various IOUs 5

separately, to the extent their measure proposals and justifications vary. Thus, establishing a 6

common set of core measures is unnecessary. 7

Witness Dryden also proposes that a “new process be developed to allow submission of 8

new measures by stakeholders in addition to utilities for consideration and retirement of 9

measures” incorporating “some clear criteria for measure approval” to be developed by the 10

Commission. 11

SoCalGas agrees that clarity of the measure approval criteria is valuable for purposes of 12

planning, assessing measures, and developing proper showings. However, SoCalGas does not 13

agree that the current process is necessarily inadequate or that stakeholders’ proposals are not 14

given every consideration in that process. IOUs regularly hold public meetings in advance of 15

developing measure proposal as part of their budget applications, and SoCalGas evaluates the 16

merit of such proposals to the extent they are applicable to a gas-only utility. Furthermore, 17

interested parties and members of the public have direct access to the regulatory process. Parties 18

are free in this proceeding, as NRDC/NCLC/CHPC has done, to propose consideration of 19

measures.27 Such proposals receive their due weight. SoCalGas is not opposed to improvements 20

27 Witness Dryden states, “[w]e recommend the Commission evaluate the following measures as part of this proceeding or through the measure evaluation stakeholder process described above: Package terminal air conditioners and heat pumps, Energy Star Qualified cooling fans, refrigerant charge verification, bathroom exhaust fans, bathroom exhaust fan controls, window film, tub diverter with thermostatic function, LED lighting.” ibid. p.12. Of the measures listed, the tub diverter with thermostatic function or

1

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measure portf

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MA/HY-12

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MA/HY-13

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SoCaH.FAU

TURN “stron

as.”35 SoCal

ed Testimony

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g detailed ev

outside of th

done by prog

ke additional

ns on measur

h production

ic criteria, or

, in contrast

ake changes

troducing ne

ndition the la

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valuation and

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l time, and li

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n of their pro

r that the cur

to ORA’s re

s mid-cycle.

ew measures

atter step can

referable app

est. Informa

to be conduc

ussed in the

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ed at this tim

ipates Very

s the additio

ates TURN

K. Mitchell, Su

K. Mitchell, Su

MA/HY-14

d PIPs, a pra

me environm

development

ikely add a le

rs and suppli

oducts. ORA

rrent approac

ecommendat

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after confer

n be done in

proach for tim

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testimony of

sal to require

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n of HE FAU

and other pa

ubmitted on B

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actice more i

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ch ought to b

tion, made p

e, TURN req

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a timely ma

mely measu

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f witness Re

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dard” FAU

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arty support

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in line with

cally not don

n and approv

ertainty, whic

ust decide wh

monstrated th

be changed.

proposals to a

quested a Ti

Mid-Cycle W

anner (e.g., w

ure introducti

asures will a

ycle. SoCalG

endler.

pment of PIP

Installation

as a measure

for this prop

e Utility Refo

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ch can have

hether and h

hat SDG&E

accommodat

er 2 Advice

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within 30 day

ion, and can

also be availa

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e

at p.

at p.

MA/HY-15

acknowledging there are instances that the HE FAU is not feasible, but a new standard FAU 1

furnace is still desirable, TURN asks that SoCalGas be required “to provide a specific 2

justification for each instance in which a standard FAU furnace is installed for health, safety, and 3

comfort reasons, instead of a HE furnace.”36 4

HE FAU furnaces have specific technical installation requirements that cannot always be 5

met. In particular, these relate to venting and condensate drain. SoCalGas anticipates these 6

cases will be very few. In general, the location of an existing FAU can be such that the PVC 7

venting or condensate drain, required for HE but not for standard FAUs, cannot be physically 8

accommodated either at all, or without incurring substantial additional costs. In such cases the 9

only way of moving forward with a new HE FAU would be to install it in a different location 10

than the existing FAU, or incur additional parts and labor costs which in most cases would be 11

prohibitively expensive. SoCalGas does not intend to offer the measure in such instances. 12

Instances involving these particular technical issues, which may be uncommon, are the only ones 13

SoCalGas foresees in which a “standard” FAU would be installed in lieu of an HE FAU. Such 14

instances would be recorded by SoCalGas with justification details, and are subject to audit by 15

the CPUC. Other than in these cases, SoCalGas’ proposal is to no longer replace furnaces with 16

standard FAUs. 17

SoCalGas believes the above discussion of the specific scenarios where a standard FAU 18

replacement would be necessary responds to TURN’s interest in justification, and provides the 19

Commission useful additional detail. If TURN’s testimony is meant to propose an ongoing 20

reporting requirement for each individual case encountered, SoCalGas opposes this proposal. 21

Such a requirement would be burdensome and unnecessary because SoCalGas’ regular monthly 22

36 Id. at pp. 3 – 4.

1

2

3

4

5 6 7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

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and annu

because,

audit. Fo

in SoCalG

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thermost

interprets

previousl

that have

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ten years

thermost

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return to

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2020 pro

37 Testimo38 Prepare39 Prepare

ual reports w

as mentione

or these reas

Gas’ Applic

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The testimony

atic tub spou

s the Joint Pa

ly treated ho

e never recei

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k Rule so as t

s (but were tr

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to treat hom

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enefits of this

ner than wha

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Dryden on behtimony of Dantimony of Ma

iate HE FAU

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stimony.

d Not Be Reted Homes O

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s measure in

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the cost effe

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half of the NRniel J. Rendle

ark Aguirre an

MA/HY-16

U as a new m

ses will be r

U measure p

equired To IOther Than

s Dryden sta

opted for “n

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et to be treat

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lication, SoC

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38 This mean

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SoCalGas ha

n its Applicat

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ectiveness of

vert resource

RDC, NCLC,er dated Novend Hugh Yao

6

measure from

recorded by

proposal shou

Install the Tn As Allowed

ates that SoC

new and exist

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CalGas prop

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as outlined t

tion,39 SoCa

ws solely to

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, and the CHPember 18, 201 dates Novem

m other furna

SoCalGas an

uld be adopt

Thermostatd Under Pr

CalGas’ prop

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PC, at p. 26. 14, at pp. 10-

mber 18, 2014

ace activity,

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posed

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for all

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MARIN CLTOMER TAFUL INFOR

thesizes that

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nities. Many

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Clean Energy

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LEAN ENEARGET IS NRMATION

t many “low

esident or ow

nd safety cod

s. The reside

als...”40

Pilot does not

y of the chall

so identified.

ar providing

as requested

mmigration s

rom existing

nity. Commu

xisting and c

ss of Natural

us, the recogn

ing outreach

on how to im

“rule that a

y, at p. i.

y, at p. 15.

MA/HY-17

ERGY PILONOT UNIQ

w-income sing

wner anticipa

de violations

ents and own

t offer uniqu

lenges that th

. For exampl

any persona

funding to s

status as a ba

g CBOs...”42

unity-Based

current outre

l Gas and El

nition and d

h approach.

mprove com

single measu

7

OT APPROAQUE AND U

gle-family a

ating negativ

s, privacy in

ners of these

ue solutions

he MCE Pilo

le, Menten s

al or income

study this pa

arrier to outr

Yet SoCalG

Organizatio

each. Moreo

lectricity Ser

deployment o

mmunity outre

ure cannot b

ACH TO RUNLIKELY

and multifam

ve consequen

nfringements

e homes are

for outreach

ot purported

suggests that

information

articular issu

reach. The M

Gas also dep

ons (“CBOs”

over, the CH

rvices) demo

of “local trus

each, Mente

be revised un

REACHINGY TO REND

mily homes a

nces, such a

s, and

members of

h to hard-to-r

dly addresses

t an

n...”41 In the

e in greater

MCE Pilot w

ploys trusted

”) represent a

HANGES pil

onstrates the

sted messeng

en argues tha

ntil ten years

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are

s

f a

reach

s are

e

would

d

a

lot

gers”

at the

s

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15 16 17

18

19

20

21

22

after it w

concern,

recomme

T

program

example,

by levera

eligibility

would be

savings a

suggest a

T

testimony

in achiev

K

T

(“NCLC”

parties”)

the Energ

LINC Ho

43 I44 I45 I46 T

was installed”

the MCE pi

ended a simi

The MCE Pil

and do not d

, the MCE p

aging “additi

y exists”,45 b

e scalable an

account for “

a large-scale

The rationale

y, but the pr

ving its objec

UTILK.PROPMUL

The natural re

”) and califo

submitted te

gy and Clim

ousing; Lind

Id., p. 10. Id., p. 10. Id., p. 17. Testimony of

” can “creat

lot would us

lar tactic in

lot also prop

demonstrate

ilot propose

ional funding

but the testim

nd workable

“matching” a

implementa

that Menten

oposed pilot

ctives.

LITIES SHOPERTY OWTIFAMILY

esources def

ornia housing

estimony fro

ate program

dsay Robbins

Marin Clean

e barriers to

se “an owner

its applicatio

oses ideas th

a feasible w

s “to alleviat

g sources fo

mony provid

on a statewi

and “incentiv

ation.

n provides fo

t, as presente

OULD BE FWNER ANDY PROPERT

fense counci

g partnership

om the follow

m of the NRD

s, an indepen

Energy, at p.

MA/HY-18

accessing p

r or manager

on.

hat are widel

way to expan

te” the landl

r health and

es no reason

de level. Li

vizing the fa

or the MCE

ed, does not

FREE TO WD TENANT TIES

l (“NRDC”)

p (“CHPC”)

wing witness

DC; Samara L

ndent consul

21.

8

program serv

r affidavit.”4

ly divergent

nd to a large-

lord’s fear of

d safety upgra

nable expecta

ikewise, the

amily’s own

Pilot reinfor

lend itself to

WORK WITTO ACHIE

), national co

together (he

ses: Maria S

Larson, Dire

ltant to the N

vices.”43 To

44 SoCalGas

from the ex

-scale implem

f health and

ades where m

ation that su

proposal to

energy savi

rces much of

o assisting th

TH BOTH TEVE ENRO

onsumer law

ereafter refer

Stamas, Proje

ector of Sust

NRDC; Davi

address this

s has also

xisting ESA

mentation. F

safety viola

mutual prog

uch a solution

establish a

ngs”46 does

f SoCalGas’

he ESA prog

THE OLLMENT I

w center

rred to as “jo

ect Attorney

tainability fo

id Hepinstal

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IN

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or

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MA/HY-19

Executive Director of the Association for Energy Affordability (AEA); and John Wells, Vice 1

President of Real Estate & Energy Services at Action for Boston Community Development 2

(ABCD). Their testimony addressed different topics that impact aspects of SoCalGas’ 3

Application regarding the ESA Program. 4

Joint Parties witness Stamas presented policy overview testimony. Larson testified 5

regarding multi-family enrollment and the Single Point of Contact (“SPOC”). Robbins testified 6

regarding best practices and specific ideas from the Program Design Guide: Energy Efficiency 7

Programs in Multifamily Affordable Housing; Hepinstall testified on “New York’s federal, state, 8

and utility efficiency programs . . .”,47 and Wells testified on his work in Boston, Massachusetts 9

and the surrounding region. 10

Taken in the aggregate, SoCalGas welcomes case studies and best practices. 11

Nevertheless, SoCalGas does not believe the Joint Parties’ testimony successfully argues for any 12

radical departure from SoCalGas’ marketing outreach for the ESA Program. Where states or 13

studies have identified intriguing approaches, these can be studied by a Working Group if the 14

Commission finds value in further exploration. 15

SoCalGas diverges with Stamas’ testimony’s support for working “directly with building 16

owners as the program participant and only directly solicit tenants for in-unit measures if 17

building owners are unresponsive”.48 Even if one were to be inclined towards Stamas’ approach, 18

she does not demonstrate that there is an existing infrastructure to market to building owners 19

exclusively. It would be needlessly disruptive to eliminate outreach to the individual tenants 20

without a demonstrated channel and capacity to reach the building owner. 21

47 Direct Testimony of NRDC (Robbins), Exhibit 6, at p. 3. 48 Direct Testimony of NRDC (Stamas), at p. 23.

MA/HY-20

Although SoCalGas objects to Stamas’ restriction of outreach, SoCalGas welcomes 1

increased outreach; thus, SoCalGas supports Stamas’ emphasis on marketing directly to the 2

building owner. SoCalGas is requesting resources to fund the Single Point of Contact (SPOC) 3

role to enhance outreach to building owners. The SPOC has support in Larson’s testimony, 4

where he points out, “The energy efficiency programs have different administrators and different 5

rules . . . We need the SPOC to help us sort this out, and coordinate program delivery so the 6

energy efficiency systems work together properly. An effective SPOC will maximize the energy 7

efficiency gains, and minimize the service delivery visits experienced by multifamily owners and 8

tenants” (p. 8). In addition, the SPOC will coordinate and facilitate ESA Program contractor 9

visits to minimize disruptions to building owners and tenants. SoCalGas will also leverage the 10

lessons learned and best practices from a demonstration project 49 utilizing SPOC for multifamily 11

buildings. 12

Currently, the ESA Program is promoted to both single-family and multifamily residents. 13

Currently, SoCalGas markets to both the tenant and the building owner. In its application, 14

SoCalGas proposes to enhance marketing to the building owner by implementing a single point 15

of contact program for the building owner while also continuing its marketing to individual 16

tenants. Thus, Stamas’ testimony suggests an unnecessarily restrictive approach. Even if one 17

favors outreach to the building owner, the testimony does not prove why such outreach should be 18

to the exclusion of outreach to the individual tenant. 19

49 Low-Income Oversight Board in July 10, 2012 presentation on Integrated Multifamily Demonstration Project.

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