Virginia State Corporation Commission eFiling CASE Document Cover Sheet

Case Number (if already assigned) PUE-2014-00071

Case Name (if known) Petition of Virginia Electric and Power Company for approval to implement new demand-side management programs and for approval of two updated rate adjustment clauses

Document Type

Document Description Summary

Total Number of Pages

Submission ID

EXTE

Direct Testimony of Jeffrey Loiter on Behalf of Environmental Respondents

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eFiling Date Stamp 1/22/2015 3:14:30PM

f7l~ Southern Environmental

t-Y Law Center

January 22, 2015

VIA ELECTRONIC FILING

Mr. Joel H. Peck, Clerk c/o Document Control Center State Corporation Commission Tyler Building - First Floor 1300 East Main Street Richmond, Virginia 23219

201 West- Main Street, Suite 14 Charlottesville, VA 22902-5065 434-977-4090 Fax 434-977-1483 SouthernEnvironment .org

RE : Petition of Virginia Electric and Power Company for approval to implement new demand-side management programs andfor approval of two updated rate adjustment clauses pursuant to § 56-585.1 A 5 of the Code of Virginia

Case No. PUE-2014-00071

Dear Mr. Peck :

Enclosed for filing in the above-captioned proceeding is the pre-filed direct testimony and attachments of Jeffrey Loiter on behalf of Appalachian Voices and the Chesapeake Climate Action Network (collectively, "Environmental Respondents"). This filing is being completed electronically, pursuant to the Commission's electronic document filing system .

If you should have any questions regarding this filing, please call me at (434) 977-4090 .

Sincerely,

C~ N4v-)L, fWAA~

Angela Navarro

cc : Parties on Service List Commission Staff

PA

Charlottesville * Chapel Hill - Atlanta - Asheville - Birmingham - Charleston - Nashville - Richmond - Washington, DC

10096 recycledpaper

COMMONWEALTH OF VIRGINIA

STATE CORPORATION COMMISSION

PETITION OF VIRGINIA ELECTRIC AND POWER COMPANY

For approval to implement new demand-side management programs and for approval of two updated rate adjustment clauses pursuant to § 56-585 .1 A 5 of the Code of Virginia

Case No. PUE-2014-00071

Direct Testimony of

Jeffrey Loiter On Behalf of

Environmental Respondents

January 22, 2015

I Q. Please state your name and business address.

2 A. My name is Jeffrey Loiter and my business address is Optimal Energy,

3 Incorporated, 10600 Route 116, Hinesburg, Vermont, 05461 .

4 Q. On whose behalf are you testifying?

5 A. I am testifying on behalf of Appalachian Voices and the Chesapeake

6 Climate Action Network (collectively, "Environmental Respondents"), who are

7 being represented by the Southem Environmental Law Center C'SELC") .

8 Q. Mr. Loiter, by whom are you employed and in what capacity?

9 A. I am employed as a Managing Consultant by Optimal Energy, Inc., a

10 consultancy specializing in energy efficiency and utility planning. In this capacity,

I I I direct and perform analyses, author reports and presentations, manage staff, and

12 interact with clients to serve their consulting needs. My clients include state

13 energy offices and efficiency councils, utilities and third-party program

14 administrators, and non-governmental organizations . For example, I participate on

15 the consultant team supporting the work of the Massachusetts Energy Efficiency

16 Advisory Council, which guides the development of energy efficiency plans by

17 the state's investor-owned gas and electric utilities and energy providers and

18 monitors the implementation of these plans. I have recently begun providing

19 similar services to the newly-formed Delaware Energy Efficiency Advisory

20 Council .

21 Q. Please summarize your work experience and educational background.

22 A. I have 16 years of experience in environmental and economic consulting .

23 For the past 8 years, I have been engaged in a variety of work at Optimal Energy

24 related to energy efficiency program design and analysis . For example, I prepared

25 two documents for inclusion in EPA's National Action Planfor Energy Efficiency

26 (NAPEE'): a guidebook on conducting efficiency potential studies, and a

27 handbook describing the funding and administration of clean energy funds.'

28 In my capacity as a Managing Consultant at Optimal, I also advise clients

29 on efficiency program design and implementation . I have assisted with the design

1 These documents can be found at http://www.epa.gov/cleanenergy/documents/suca/potential_guide .pdf and http ://epa.gov/cleanenergy/documents/clean-energy_fijnd-manual .pdf, respectively .

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I and development of statewide and utility-specific efficiency programs in Maine,

2 Maryland, New York, Massachusetts, and Tennessee. I currently support program

3 implementation and on-going program design and development for Orange and

4 Rockland Utilities in New York and the Connecticut Municipal Electric Energy

5 Cooperative . I have submitted written testimony to and/or testified before public

6 utility commissions in Arkansas, Kansas, Kentucky, Maryland, Ohio, Virginia,

7 and West Virginia on topics such as demand-side management, integrated

8 resource planning, and efficiency as a resource in state energy plans.

9 Prior to joining Optimal Energy in 2006, 1 was a Senior Associate at

10 Iridustrial Economics, Inc . in Cambridge, Massachusetts, where I supported state,

I I federal, and international governmental clients with analysis on topics of

12 environmental policy and natural resources damages . I have a B.& with distinction

13 in Civil and Environmental Engineering from Cornell University and an MS. in

14 Technology and Policy from the Massachusetts Institute of Technology .

15 Q. Have you previously testified before the Virginia State Corporation

16 Commission ("the Commission" or "SCC")?

17 A. Yes. I have testified before the SCC or provided prefiled direct testimony

18 on behalf of the Environmental Respondents in the following cases: PUE 2009-

19 00023, PUE-2011-00092, PUE-2011-00093, PUE-2012-001 00, PUE-2012-00128,

20 PUE-2013-00072, and PUE-2013-00097 .

21 1 also have provided SELC with technical advice on several issues under

22 consideration by Dominion Virginia Power's ("Dominion" or the "Company")

23 Stakeholder Review Process ("SRP") and directly participated in one SRP

24 meeting on June 4, 2013, at the Company's offices.

25 Q: What is the purpose of your testimony in this proceeding?

26 A: The purpose of my testimony is to present the conclusions of my review of

27 Dominion's application and testimony filed in this docket . Specifically, I focus on

28 the design of the proposed Phase IV programs and the projected costs and cost-

29 effectiveness of the programs .

30 Q: How is your testimony organized?

31 A : My testimony is organized into the following three sections :

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1 . The design of the Company's proposed Phase IV programs

2. The cost-effectiveness of the Company's proposed Phase IV programs

3 . The use of the levelized cost-of-energy as a too] for assessing the

Company's proposed Phase IV programs

Are you submitting exhibits along with your testimony?

Yes. I have attached my resume as Attachment JML-l . In addition, there

are the following:

Attachment JML-2 - ES Attachment Staff Set 1-8(2) [REDACTED]

Attachment JML-3 - Response to Staff Set I - I I

Attachment JML-4 - Response to Staff Set 3-21

Attachment JML-5 - Attachment ER Set 1-20

What are your main conclusions?

I have four main conclusions :

1 . The three Phase IV programs are, to varying degrees, reasonably

designed, but there are some ways in which the programs could be

improved .

2. The Company's assumed levels of penetration over five years do not

realistically represent "saturation" of the market for those programs .

3 . The Company's proposed Income and Age Qualifying Home

Improvement Program is an important and reliable tool for providing

energy savings to low-income and elderly customers .

4 . The Company's proposed Appliance Recycling Program and

Qualifying Small Business Program are cost-effective from the

Participant, Total Resource Cost, and Utility Cost test perspectives .

5. The levelized cost of energy from both the Appliance Recycling

Program and Qualifying Small Business Program is less than the cost

of the least expensive traditional central generation (combined cycle

natural gas) .

What actions do you recommend the SCC take in this proceeding?

I recommend that the SCC approve the programs as filed by the Company.

Furthermore,I recommend that the SCC direct the Company to, in future DSM

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I program approval filings, provide: 1) cost-effectiveness results for each program

2 assessed on the basis of program activity solely over the period of time being

3 presented for approval and cost-recovery, and 2) the levelized cost of energy over

4 that same time period for each energy efficiency program for which cost-

5 effectiveness is the primary consideration .

6 1. THE DESIGN OF THE COMPANY'S PROPOSED PHASE IV

7 DSM PROGRAMS

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Q: Please describe the Company's proposed Phase IV Programs.

A: The Company proposes three new energy efficiency programs :

1 . Income and Age Qualifying Home Improvement Program, targeting

certain residential customers.

2. Residential Appliance Recycling Program, targeting residential

customers .

3. Qualifying Small Business Improvement Program, targeting certain

commercial customers.

Q: What is your view of the overall design of these programs?

A: These programs represent commonly implemented approaches to

delivering energy efficiency services in many, many jurisdictions . They address

the needs of two traditionally difficult-to-reach populations, namely low-income

customers and small businesses . They are essential components of a

comprehensive efficiency portfolio, which must be assembled in order to reach

the 10% energy reduction goal affirmed by the Company and the Commission .

Q: Do you have any comments on the design of any specific program in the

Company's proposal?

A : Yes, I have comments on the design of each of the Phase IV programs .

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I A. INCOME AND AGE QUALIFYING HOME IMPROVEMENT

2 PROGRAM

3 Q: What is your view of the Company's proposed Income and Age Qualifying 4 Home Improvement program?

5 A : The program is an important part of a portfolio of energy efficiency

6 services, is generally reasonable in terms of design and approach, and should be

7 approved .

8 Q: Has the Company previously offered a program targeting low income

9 customers?

10 A: Yes, the Company's Residential Low-Income Program was approved

I I under the Company's DSM Phase I petition, PUE-2009-0008 1, and extended for

12 an additional two years in PUE-2012-001 00 . As of June 30, 2014, it had served

13 over 10,500 customers . 2 The program expired on December 31, 2014. The

14 program was designed to offer qualifying low-income residential customers a free

15 energy audit to identify ways they could save money on their monthly electric

16 bill . Additionally, auditors would directly install certain measures if the

17 participant approved . These measures included : envelope sealing, switching to

18 CFLs (up to 6 lamps per home), adjusting electric domestic water heater

19 temperature down to 120 degrees Fahrenheit, changing central air conditioner

20 filter and leaving behind 6 filters, refrigerator coil cleaning, and duct sealing for

21 any exposed, accessible and reasonably repairable duct work. The program was

22 available to homeowners (or authorized renters) earning less than 60% of Area

23 Median Income ("AMI"). Mobile homes and apartments were not eligible to

24 participate.

25 Q: Please explain how the proposed Income and Age Qualifying Home

26 Improvement Program differs from the Phase I Low-Income Program.

27 A Although the Company suggests the Income and Age Qualifying Home

28 Improvement Program is a new program, the design of the program is largely

29 similar to the Phase I program. The new Income and Age Qualifying Home

2 Schedule 3 to the Direct Testimony of Michael T. Hubbard on Behalf of Virginia Electric and Power Company (filed Aug. 29,2014) .

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I Improvement Program will include energy assessments as well as direct install

2 measures . The biggest difference between the programs is that the Company has

3 expanded eligibility to include elderly customers, as provided for in the definition

4 of the term "in the public interest" in § 56-576 of the Code of Virginia . These

5 customers will qualify if they are over 65 years of age and have income up to

6 120% of the state median income, as opposed to 60% of median income for

7 customers under age 65 . The proposed program also expands the eligible home

8 types to include single-family, multi-family, manufactured housing and mobile

9 homes. The direct install measures are a similar mix of lighting (now focused on

10 LED lamps rather than CFLs), water-saving measures for homes with electric

I I domestic hot water (low flow showerhead, pipe wrap, and faucet aerators), and

12 insulation measures such as attic insulation .

13 Q: Do you have any concerns regarding the proposed program?

14 A: Yes, I am concerned that offering the Phase IN program under a different

15 name than the Phase I program, despite the similarities in eligible customers and

16 delivery mechanism, may create confusion and fail to take advantage of the

17 Company's prior investments in customer awareness . Further, it may signal to

18 customers that they must be both low income AND of a particular age to be

19 eligible .

20 Q: Do you agree that the program targeting low income and elderly customers

21 should be offered under a different name than the previous program?

22 A: Given the overlap between low income and elderly customers as well as

23 the similarities in program design and measures offered between the previous

24 Low-Income Program and the proposed Income and Age Qualifying Home

25 Improvement Program, I am concerned that customer confusion could result . On

26 the one hand, maintaining the original name of the program would provide

27 consistency for the market . As I have discussed in prior testimony, it takes time to

28 build an effective efficiency program infrastructure and even more time to build

29 the customer awareness and relationships that help realize long-lasting and

30 pervasive savings in the marketplace . Using the existing Low-Income Program

31 name, rather than implementing the proposed program under a new name, the

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I Company can assure consistency for customers, market partners, and

2 implementation staff as it looks for ways to further improve the program over the

3 next five years. On the other hand, the old program name does not signal to

4 newly-eligible customers (i .e ., those based on age) that the new program is

5 available to them . While it may seem like a small change, I suggest that the name

6 "Low Income OR Age Qualifying Home Improvement Program," or something

7 similar, might be a reasonable compromise .

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Q: Do you have any other concerns about the Company's marketing approach

for this program?

As I noted above, the existing Low-income Program expired on December

31, 2014, creating a funding gap between two very similar programs . This type of

discontinuity should be avoided in the future, because consistency of funding is

critical to success. If programs have to stop serving customers for a period of

time, we should expect greater difficulty with future implementation as the

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Company tries to re-engage the marketplace and its customers . On-again, off-

again programs do not help customer satisfaction or understanding, nor do they

encourage investment by the trade allies who often help promote efficiency

programs in understanding and tracking current program status .

Please summarize your recommendations for the Income and Age Qualifying

20 Home Improvement Program.

21 A : First, the Company should strive for consistency and continuity in delivery

22 and marketing the program to maintain momentum from the previous Low

23 Income program. Second, I encourage the Company to strive for greater

24 participation than forecast and report back to the Commission with early

25 successes reaching or exceeding the projected participation rates, with the hope

26 that the program could be expanded or extended once underway. It might also be

27 instructive to benchmark this program against programs in other jurisdictions that

28 have achieved greater penetration and to consider how those successes can be

29 translated into programs for the Company's customers .

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I B. RESIDENTIAL APPLIANCE RECYCLING PROGRAM

2 Q: What is your view of the Company's proposed residential appliance recycling

3 program?

4 A: Appliance recycling programs such as this are common components of

5 DSM portfolios . This program should generate reliable and cost-effective savings

6 and should be approved . On the other hand, the proposed level of spending and

7 savings represents a very small fraction of the program's potential .

8 Q: Do you have any concerns about the program as proposed by the Company?

9 A : I do want to address the issues raised by the Commission when it denied a

10 similar program in the Company's DSM Phase I petition, PUE-2009-00081 . In

I I the Commission's Order in that case, it determined that the Refrigerator Turn-In

12 program was not in the public interest, in part because "Consumer Counsel and

13 Staff note[d] the low RIM score[] of [this] program[], which also [did] not have

14 significant offsetting and reliable TRC scores ." 3 In this case, I believe that the

15 cost-effectiveness of the proposed program is reliable and indicates a real benefit 4 16 to both ratepayers and the Company. The TRC benefit-to-cost ratio is 2.3 . More

17 importantly, as the Company notes, similar programs are offered by neighboring

18 utilities, and indeed, utilities and program administrators in jurisdictions around

19 the country. These programs are typically implemented as turn-key efforts by

20 companies with extensive experience delivering these services . The costs of such

21 services are typically well-known. With respect to the projected benefits, the

22 Company's projections of per-unit savings are not unreasonable . Furthermore,

23 these savings are amenable to robust evaluation efforts, as there is a clear

24 opportunity to measure the actual consumption of a sample of units being retired

25 and thereby develop savings estimates with a high degree of confidence .

3 Order Approving Demand-Side Management Programs at 7, Application of Virginia Electric and Power Companyfor approval to implement new demand-side management programs, Case No . PUE-2009-00081 (Mar. 24, 20 10). 4 Schedule 2 to the Direct Testimony of Ripley C. Newcomb on Behalf of Virginia Electric and Power Company (filed Aug. 29, 2014).

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I Q : How would you recommend the Company modify the program to meet any

2 concerns?

3 A : As noted above, evaluating such a program requires forethought, so that

4 measurements of actual energy consumption of the units being retired can be

5 taken in-situ and in advance of their removal . I encourage the Company and its

6 contractors to plan for this ahead of time, so that they can begin collecting

7 evaluation data as soon as the program begins .

8 Q: Do you have any other concerns?

9 A : Yes. The projected 5-year cumulative penetration for the program is

10 approximately 47 '900.5 Because the Company's estimate of the eligible

I I population is 1,300,85 0,6 the program is therefore reaching about 3.7% of the

12 eligible population over 5 years. I am concerned that participant uptake could

13 greatly exceed the projected participation, resulting in either early termination of

14 the program or annual limits on participation, resulting in on-again, off-again

15 program delivery . Given that this type of program is implemented in a "turn-key"

16 fashion by the implementation contractor, it would be fairly easy to increase the

17 size of the program to capture additional savings .

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Q: What do you recommend to remedy this concern?

A : As I previously noted, the Company should report back to the Commission

with early successes reaching or exceeding the projected participation rates, with

the hope that the program could be expanded or extended once underway . Short

of that, it would be preferable for the program to run without interruption until the

budget is expended, rather than starting and stopping each year in an effort to

stretch the budget over the entire five years.

C. QUALIFYING SMALL BUSINESS IMPROVEMENT PROGRAM.

Q: What is your view of the Company's proposed qualifying small business

improvement program?

' See Schedule 5 to the Direct Testimony of Ripley C. Newcomb on Behalf of Virginia Electric and Power Company (filed Aug. 29, 2014). 6 See Attachment JML-2.

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I A : Again, this is an important component of the Company's efficiency

2 portfolio, and I have seen similar programs effectively implemented throughout

3 the country. In the Company's 2013 SR-P, I raised this program as an example of a

4 type program that the Company should consider pursuing . However, I do have

5 some concerns about the design, and I believe the proposed level of spending and

6 savings is far below what is likely to be feasible .

7 Q: What are your concerns about the design of the program?

8 A : First, the eligibility criteria for this program have not yet been determined .

9 The Company's response to Staff Set I -I I indicates that customers with up to 30

10 kW of demand will be eligible, and additional customers may be eligible subject

I I to a maximum demand limitation . 7 Similar programs in other jurisdictions have

12 typically started with customers below 100 M Because implementation

13 contractors and trade allies tend to focus their efforts on the largest eligible

14 customers, keeping the initial demand cap low will ensure that program funds are

15 in fact directed to the small businesses that are in most need of efficiency

16 assistance . As the Company makes final decisions on program eligibility, f

17 believe it would be prudent to set the eligibility limit no higher than 100 kW, and

18 closer to the preliminary criterion of 30 M Staff Set I -I I also notes the potential

19 to identify a subset of businesses that may be subject to different eligibility

20 criteria, such as those in Historically Underutilized Business ("RUB") zones. 8

21 While this is certainly a reasonable policy objective, care should be taken to

22 ensure that eligibility criteria are not too difficult to understand, for either the

23 customer or the trade ally .

24 Second, the Company's description of the program seems to indicate that

25 various aspects of the program may be delivered by different trade allies . For

26 example, the Company's response to Staff Set 1 -11 states that trade allies will

27 conduct an audit focusing on potential operations and maintenance ("O&M")

28 improvements to the facility.9 To the extent that this audit is conducted by a

29 different party and potentially at a different time than the initial audit focused on

' See Attachment JML-3. 8 See id. ' See id.

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I direct install lighting measures, participants will be inconvenienced with auditors

2 in their facilities at least twice.

3 Q: What is your opinion about the penetration rates of this program?

4 A : As with other programs and per my previous comments, I am skeptical of

5 the Company's assertion that the program wi I I reach saturation in five years. The

6 cumulative penetration over 5 years is a little less than 7,900 participants . 10 As

7 shown in Attachment Staff Set 3-2 1, the Company has approximately 180,000

8 commercial customers on the GS-I rate schedule, defined as non-residential

9 customers who exceed 30 M demand no more than twice per year. 11 Thus, the

10 total penetration into this market will be just 4.4% of eligible customers over the

t I 5-year program, and potentially lower if the eligibility limit is higher than 30 M

12 It should be possible to achieve a higher penetration rate . Attachment EP,

13 Set 1-20 indicates that the program will provide a high percentage of costs to

14 customers (60 to 80% for direct install lighting, 50% of other measures), 12 which

15 should make the program quite attractive . Additionally, there are many examples

16 of programs that achieve greater levels of participation . National Grid's small

17 business program in Rhode Island reached about 10% of eligible customers in 6

18 years, roughly double the rate proposed by the Company. Commonwealth Edison

19 performed even better, reaching 3% of eligible customers annually . ' 3

20 Q: How would you recommend the Company modify the program to meet your

21 concerns?

22 A : I encourage the Company to work with its implementation contractor to

23 ensure an easy route to participation in all aspects of the program . Important

24 factors in this include limiting the number of times the customer must contact

25 program staff or trade allies, the number of different individuals the customer

26 deals with, and the number of separate facility visits . Furthermore, I believe this

27 program can reach a far greater number of customers than the Company assumes,

'0 See Schedule 5 to the Direct Testimony of Ripley C. Newcomb on Behalf of Virginia Electric and Power Company (filed Aug. 29,2014) . 1 1 See Attachment JML-4, https://www.dom.com/library/domcom/pdfs/virginia-power/ratesibusiness-rates/schedule-gs Lpdf. '2 See Attachment JML-5. 13 See York, D. et al, Expanding the Energy Efficiency Pie: Serving More Customers, Saving More Energy Through High Program Participation . ACEEE Report U 150 1, Jan. 2015 .

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I and therefore could play a larger role in reaching the 10% efficiency savings goals

2 supported by the Company. Again, I encourage the Company to report back on

3 early program activity with the goal of potentially expanding the program if

4 participation rates exceed projections.

5 H. THE COST-EFFECTIVENESS OF THE PROPOSED PHASE IV

6 PROGRAMS

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Q: Have you reviewed the information on program cost-effectiveness presented

by the Company?

A: Yes . I have reviewed the materials presented in the filing and in the

Company's responses to discovery requests .

Q : Do you have any opinion about the Company's cost-effectiveness results?

A: Yes, I have comments regarding the cost-effectiveness results for each of

the Phase IV programs .

A. INCOME AND AGE QUALIFYING HOME IMPROVEMENT

PROGRAM

Q: What is your assessment of the cost-effectiveness of the proposed Income and

Age Qualifying Home Improvement Program?

A : The Income and Age Qualifying Home Improvement Program raises

distinct issues, because it seeks to help at-risk customers under a special provision

of Virginia law. As discussed below, I have identified some problems with the

Company's cost-effectiveness tests for this program. Nonetheless, I believe that it

should be approved because the program provides measurable and verifiable

energy savings to low-income and elderly customers, and is therefore in the

public interest .

Q: What problems have you identified regarding the cost-effectiveness of the

Income and Age Qualifying Home Improvement Program?

A: Based on my review of the information provided by Company Witness

Newcomb, I believe the TRC benefit-to-cost ratio for the program should be

significantly lower than is reported . Specifically, I believe the TRC ratio should

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I be the same or nearly the same as the utility cost test ratio, which is presented in

2 Company Witness Newcomb's Schedule 2 . This would change the score from

3 2. 10 to 0.39, on an individual program basis.

4 Q: What is your basis for this conclusion?

5 A: The Company's TRC calculation for the Income and Age Qualifying

6 Home Improvement Program is inconsistent with my understanding of how this

7 calculation is typically performed. Specifically, I am concerned about the relative

8 amount of net present value ("NPV") costs the Company includes in its TRC

9 calculation. Company Witness Newcomb's Schedule 2 reports that the total NPV

10 costs of the Income and Age Qualifying Home Improvement Program are

I I approximately $34.5 million from the utility cost test perspective, but less than

12 $6.5 million from the TRC perspective. 14 The Company's share of the measure

13 costs do not appear to be included in the Company's costs estimate from the TRC 14 perspective . This would constitute the bulk of the total program costs, because the

15 Income and Age Qualifying Home Improvement Program is a direct install

16 program in which Dominion pays contractors and suppliers for the efficient

17 equipment and materials (e.g ., insulation, LEDs) and the labor to install this

18 equipment .

19 Q: Why do you think the Company did not include these costs in its TRC cost

20 calculation?

21 A: In Case No. PUE-2012-00 100, 1 raised a similar issue regarding the 22 Company's TRC calculation for the Low Income Program, and Witness

23 Newcomb explained that the Company had "assume[d] that the cost of the

24 measures installed as part of the Program was an incentive to the customer." 15 He

25 acknowledged that "[a] better approach to modeling this Program, because it is a

26 direct install program, would be to include the cost of the measures in the utility

27 costs and not account for it as an incentive payment." 16 Witness Newcomb stated

14 Schedule 2 to the Direct Testimony of Ripley C. Newcomb on Behalf of Virginia Electric and Power Company (filed Aug . 29, 2014) " Rebuttal Testimony of Ripley C . Newcomb on Behalf of Virginia Electric and Power Company before the State Corporation Commission of Virginia, Case No . PUE-2012-00 100 (filed Feb . 19, 2013 ; admitted Mar . 5, 2013, as Exhibit 16) . 16 Id.

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that the Company would "evaluate changing its modeling approach for the Low

Income Program going forward and make necessary changes at its soonest

opportunity." 17 The Company appears to be using its prior approach in this

proceeding .

Q: Why would treating direct install measures as incentive payments skew the

TRC test results?

A: As Witness Newcomb notes on page 8 of his testimony in this proceeding,

the TRC test views customer incentives as a transfer payment from the utility to

the participant . But to properly analyze direct install measures, this spending

should be considered somewhere in the cost formulation so it does not disappear

from TRC cost accounting .

Q : Have you identified any other problems with the Company's cost-

effectiveness calculation for this program?

Yes. While I stated above that I believe that the TRC ratio is lower than

the Company presented, I also believe that the Company's assumptions regarding

the Net-to-Gross ("NTG") ratio are flawed, such that the reported Utility Cost

Test ("UCT") benefit-to-cost ratio and the corrected TRC benefit-to-cost ratio are

lower than they should be .

Q : What is the Net-to-Gross ratio, and what assumption does the Company

make?

A: The NTG ratio assumed for a program can significantly impact cost-

effectiveness results. The NTG ratio is intended to account for customers who

would have implemented efficiency measures even in the absence of the

efficiency program. These customers are referred to as "free-riders ." In some

cases, savings are increased as a result of "spillover," or energy savings outside of

the program that would not have occurred in the absence of the program . After

applying a NTG ratio, the remaining savings are intended to reflect energy

savings that are a direct result of program implementation .

17 Rebuttal Testimony of Ripley C . Newcomb on Behalf of Virginia Electric and Power Company before the State Corporation Commission of Virginia, Case No . PUE-2012-001 00 (filed Feb . 19, 2013 ; admitted Mar . 5, 2013, as Exhibit 16) .

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I For the Income and Age Qualifying Home Improvement Program, the

2 Company has assumed a NTG of 0.80, suggesting that 20% of program

3 participants would have implemented efficiency measures even without the

4 program. 1 8 This seems high, given that participants of the program are least able

5 to afford the upfront costs required to implement efficiency measures . In fact, an

6 evaluation of the Company's previous Low Income program found a free-rider

7 percentage of just 6.4%, which resulted in the use of this value for the 2013

8 evaluation report . 19 Other jurisdictions have also assumed lower free-ridership

9 and a higher NTG ratio for low-income programs . For example, a recent filing by

10 PECO to the Pennsylvania Public Utility Commission includes an NTG ratio of

I 1 1 .0, "because low-income customers typically do not have the resources to install

12 energy efficiency measures ." 20

13 Q: What impact would a higher NTG ratio have on cost-effectiveness results?

14 A: A higher NTG ratio would result in higher savings and therefore higher

15 benefits and a higher UCT and TRC benefit-to-cost ratio .

16 Q. Do you still support the approval of the Income and Age Qualifying Home

17 Improvement Program?

18 A: I do.

19 Q: Please explain why.

20 A: First, there are public policy reasons to implement energy efficiency

21 programs targeted at low-income and elderly customers. The Income and Age

22 Qualifying Home Improvement Program provides services to those customers

23 who are likely to suffer the most hardship from high electric bi I Is, whether by

24 virtue of their limited income or the fact that low income residences are typically

25 less efficient than the average residence .

's See Schedule 12 to the Direct Testimony of Ripley C. Newcomb on Behalf of Virginia Electric and Power Company (filed Aug. 29, 2014). 19 See Evaluation, Measurement and Verification Report for Dominion Virginia Power prepared by KEMA, Inc., Case No . PUE-2011-00093 (Apr . 1, 2013). 20 See Final Annual Report for the Pennsylvania Public Utility Commission For the Period June 2012 through May 2013 Program Year 4, available at https://www.peco.conVCustomerService/RatesandPricing/Ratelnformation/Documents/PDFINew~/~2OFilin gs/PECO~/`2OAct~/~20129~/`20PY4~/~2OAnnual~/~2OReport~/~2OFin~/~2011`/`20 15~/~202013 .pdf.

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1 By reducing the amount of electricity required for the same end uses,

2 energy efficiency programs lower electricity bills and save customers money.

3 However, investing in energy efficiency typically requires an up-front expenditure

4 in order to reap future bill savings. This "first-cost" barrier is highest for low-

5 income and elderly customers, who may not have the necessary capital, whether

6 from savings or the ability to borrow at reasonable interest rates . Thus, the

7 Income and Age Qualifying Home Improvement Program will play a critical role

8 in helping low income and elderly customers install measures that will lower their

9 energy bills. Additionally, it is important that a comprehensive efficiency

10 portfolio offer all customers, including low-income and elderly customers, a

I I means to reduce their energy consumption in ways that are financially feasible .

12 Second, although I am not a lawyer and am not offering a legal opinion, 1

13 understand that Va . Code § 56-5 76 now provides that "an energy efficiency

14 program may be deemed to be 'in the public interest' if the program provides

15 measurable and verifiable energy savings to low-income customers or elderly

16 customers." I believe that this program will provide measurable and verifiable

17 savings as required by the statute. Many of the measures will be directly installed

18 into customer homes and are of types that have been well-studied, generating

19 confidence in the resulting savings estimates.

20 Q: Are there other actions the Company could take to demonstrate the value of

21 the Income and Age Qualifying program?

22 A: Yes. First the Company should ensure that its assumptions regarding the

23 savings from direct install measures, particularly LED lighting, are not being

24 under-counted . To the extent that the preliminary savings estimates are based on

25 assumptions that LEDs will replace CFLs rather than EISA-compliant

26 incandescent lamps, actual program experience should allow for a more accurate

27 baseline and potentially greater savings per install .

28 On the program design side, the Company should revisit the overall costs

29 of reaching and treating each customer with the objective of reducing cost per

30 customer and increasing the savings that can be realized from each visit. For

31 example, although the energy assessment should identify opportunities for energy

17

I savings, there is currently no mechanism in place to follow up with customers

2 about making improvements beyond the direct install measures. Following up

3 with customers to encourage them to participate in other residential programs

4 offered by the Company, including programs that are not specifically for income-

5 or age-qualifying customers, should be included as part of this effort . Even if

6 these savings are counted elsewhere, they would serve to increase the benefits

7 generated from engaging with these customers .

8 Last, plans should be generated to re-evaluate the Income and Age

9 Qualifying Home Improvement Program, particularly with respect to the NTG

10 ratio, to ensure that reported savings and cost-effectiveness accurately reflect

I I customer behavior .

12 B. COST-EFFECTIVFNESS OF REMAINING PRASE IV

13 PROGRAMS

14 Q. Please summarize the reported cost-effectiveness of the proposed Appliance

15 Recycling Program .

16 A: The Appliance Recycling Program is cost-effective from the participant,

17 utility ("UCT"), and total resource ("TRC") perspectives . These results are typical

18 of similar programs, and I believe they support approval of the program.

19 Q: Please summarize the reported cost-effectiveness of the proposed Small

20 Business Program.

21 A : The Small Business Program is cost-effective from the participant, utility

22 ("UCT"), and total resource ("TRC") perspectives . Within the bounds of

23 uncertainty, the Small Business program is also likely cost-effective from the

24

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28 A :

29

ratepayer impact measure perspective ("RIM"). Again, these results are typical of

similar programs, and I believe they support Commission approval .

You state that the Small Business program is "likely" to be cost-effective on

the R11M test. Can you please explain?

The RIM as reported on an individual program basis is 0 .96, and ranges

from 0 .91 to 1 .04 across the various sensitivity analyses conducted by the

~-a LM

18

I Company. Therefore, within the range of uncertainty for these analyses, I would

2 consider this program to be cost-effective from the perspective of the RIM test .

3 Although the cost per annual unit of energy saved is high compared to

4 some other existing and proposed programs in the Company's portfolio, the

5 proposed measures have moderate to long measure lives, which increases total

6 benefits and therefore the cost-effectiveness of this program. In my experience, a

7 substantial portion of the total benefits in programs such as this are derived from

8 deferred capacity costs, both generation capacity and transmission and

9 distribution capacity . This is to be expected, as commercial measures of the types

10 envisioned for this program have very good coincidence with peak energy

11 periods, both summer and winter .

12 Q: Do you have any other concerns regarding the Company's use of cost-

13 effectiveness tests?

14 A : Yes. I would also like to advocate for using a more realistic approach to

15 assessing program costs and benefits with respect to time . The Company is

16 requesting approval to deliver programs for five years and to recover costs related

17 to those five years of program delivery . Yet the reported cost-effectiveness

18 analyses are based on 25 years of program delivery and the associated costs and

19 benefits over that time . I believe that the Commission and other interveners

20 should have a clearer picture of the actual magnitude of the costs and benefits

21 likely to result from the programs as proposed .

22 Q: Are you saying that the cost-effectiveness analysis should only consider a

23 five-year period?

24 A : No, the analysis must consider a longer time horizon. The nature of

25 efficiency measures, which have useful lives of many years, requires that the

26 Company count benefits that accrue many years after the investment . For

27 example, the 14 year measure life assumed for the small business program means

28 that measures installed in 2019 will still be generating benefits through 2033 .

29 Even if the analysis is limited to the effects of just five years of program activity,

30 it should be feasible for the analysis to consider the costs of only five years of

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program delivery, after which benefits continue to accrue until all measures are

expired. In fact, it is desirable to do the calculation this way.

Q: How might the cost-effectiveness of the programs change if analyzed in this

manner?

A : It is difficult to state with certainty. I did a rough analysis of the small

business program using the information available in the filing and discovery

responses, and found small increases in the BCRs for the four tests (roughly 0 .1

points) . On the other hand, the actual gross benefits and costs, and net benefits, in

dollar terms, were roughly two-thirds of the Company's reported values . I believe

that the Commission should consider these values in evaluating a five-year

program budget, because they more accurately represent the outcomes from that

decision .

Q: Does the Company support such an approach?

A: I cannot say with certainty, but Company Witness Newcomb does note in

his pre-filed testimony (at 13-14) the importance of considering the relative

magnitude of the costs and benefits of the programs, notjust the benefit-cost

ratios . However, he references the 25-year planning period in his statements .

While I certainly understand the importance of a long-term view in conducting

overall utility planning such as an IRP, the five-year period I suggest is more

relevant for the purposes of this proceeding where the Company is seeking

approval for a five-year period .

H1. T14E USE OF LEVELIZED COST-OF-ENERGY AS A TOOL FOR

ASSESSING THE COMPANY'S PROPOSED PHASE IV DSM PROGRAMS

Q: Are there other potential metrics that can be used to assess the Company's

proposed DSM programs?

A: Yes . As has been discussed previously before this Commission, the cost of

saved energy or levelized cost of energy saved is an alternative metric that can be

used .

Q: Please explain the term "cost of saved energy."

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20

I A : The cost of saved energy is simply the cost of taking an action to reduce

2 energy usage divided by some measure of the energy saved . It is typically

3 considered from the utility or program administrator point of view, because that is

4 the entity with the responsibility of procuring energy for its customers. It can be

5 expressed either in terms of cost per first-year energy savings or cost per life-time

6 energy savings.

7 For example, program costs in 2019 for the Company's proposed

8 Qualifying Small Business Improvement Program are $12.1 million . 21 In that

9 year, the program will generate incremental annual savings of 24,334 MWh,

10 giving a cost of saved energy of approximately $0.50 per annual kWh. Using the

I I assumed lifetime of 14 years, the cost per lifetime kWh is about 3 .6 cents/kWh,

12 but this calculation does not take into account differences in timing of costs and

13 savings, nor any discount rates for these.

14 Q: What does the term "levelized" refer to?

15 A : The term "levelized" refers to accounting for differences in the timing of

16 both the costs and energy impacts resulting from efficiency or other energy

17 resources. Levelized cost of energy ("LCOE") is a common metric for comparing

18 various supply side generating options . It represents, in real dollars, the cost of

19 building and operating a generating plant over an assumed financial life and duty

20 cycle. For example, a widely cited periodic report by the investment advisory firm

21 Lazard compares the unsubsidized levelized cost of energy from a wide variety of

22 alternative and conventional energy sources; not surprisingly, energy efficiency is

23 the lowest cost resource of al 1.22

24 Q: What methodology should be employed to evaluate the levelized cost of

25 energy saved?

26 A : There are a variety of methods. For example, a report prepared by the

27 Lawrence Berkeley Laboratories for the U.S . Department of Energy presents a

28 simple and straightforward approach to calculate the levelized cost of energy

21 Schedule 9 to the Direct Testimony of Ripley C. Newcomb on Behalf of Virginia Electric and Power Company (filed Aug. 29, 2014). 22 Lazard's Levelized Cost of Energy Analysis - Version 8. 0 (Sept. 2014), available at http://www.lazard.com/PDF/Levelized~/~20Cost~/`2OoP/~2OEnergy~/~20-~/~2OVersion`/~208 .0.pdf

~A ~M

21

I saved by an efficiency program in a particular year, using the standard capital

2 recovery factor calculated based on the measure life of the savings. 23

3 Q: What role can the levelized cost analysis provide in evaluating the cost-

4 effectiveness of the Company's proposed programs?

5 A: The levelized cost of energy for efficiency programs provides a simple

6 comparison to the Company's overall generating portfolio, specific generating

7 assets, and market power purchases . If the levelized cost of energy from an

8 efficiency program is less than the Company's average marginal costs of power

9 available through market purchases, then the Company's revenue requirement

10 will be reduced, thus lowering overall bills for customers. In this way, it is similar

I I to, but simpler than, the utility cost test .

12 Q: Have you applied this methodology to the Company's programs, and if so,

13 what is the result?

14 A: Yes, I used this methodology to assess the levelized cost of energy from

15 the proposed Phase IV programs for each calendar year of the proposed five year

16 approval period . The costs for the first year of each program were substantially

17 higher than for subsequent years as a result of initial program costs and part-year

18 operation . The average levelized costs for the second through fifth year of

19 program delivery were 4.7 cents/kWh for the Appliance Recycling Program, and

20 5 .6 cents/kWh for the Qualifying Small Business Program. The average levelized

21 costs for the second through fifth year of the Income and Age Qualifying Home

22 Improvement Program was 21 .7 cents/kWh ; however, this program should not be

23 evaluated based on levelized cost but, as discussed in more detail above, should

24 be approved based on public interest factors.

25 Q: How do these costs compare with the cost of energy from other sources?

26 A: The previously referenced report by Lazard give a range of 6 .1 to 8.7 cents

27 per kWh for energy from a gas combined cycle generator, the least expensive

28 conventional source of electricity . Importantly, those values assume no cost

29 associated with potential regulation of carbon emissions . The cost rises to 12.7

Billingsley et al . The Program Administrator Cost of Saved Energyfor Utility Customer-FundedEnersy ,Efficiency Programs, Prepared for the U.S . Department of Energy by Ernest Orlando Lawrence Berkeley National Laboratory (Mar . 2014).

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cents/kWh with carbon capture, exclusive of any transportation or storage of the

captured carbon .

IV. CONCLUSION

Q: Please summarize your testimony.

A: I have reviewed the Company's filing in this proceeding and related materials including discovery responses . I find that the proposed programs represent important components of a comprehensive efficiency portfolio, are cost- effective where expected to be (i.e ., with the exception of the Income and Age Qualifying Program), and should be approved . I also suggest some additional items for the Company's and the Commission's consideration with respect to the projected penetration of these programs and methods for assessing their cost-effectiveness .

Q : Does this conclude your testimony? A: Yes.

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23

Environmental Respondents Exhibit No . Attachment JfZ-1

Page 1 of 3 iZOPnmal E R G Y Integrated Energy Resources

JEFFREY M. LOITER

MANAGING CONSULTANT Mr. Loiter has over 14 years of consulting experience in energy and natural resource

issues . FEs energy experience includes policy, planning and program design, research on renewable and efficiency technologies, electricity transmission systems, integrated resource planning and savings verification . As a Managing Consultant, Mr. Loiter manages projects, oversees staff development, and contributes to firm management in the areas of hiring and business development.

PROFESSIONAL EXPERIENCE Optimal Energy, Inc . Hinesburg, VT Managing Consultant, 2006-present

" Leads Optimal's energy efficiency consulting services to the Connecticut Municipal Electric Energy Cooperative (CMEEC). These services include program planning, program savings analysis and reportin& developing incentive and delivery strategies, and managing CMEEC's participation in the ISO-NE Forward Capacity Market. The latter has included drafting M&V plans specifying procedures for meeting all ISO-specified M&V rules, including data management calculation of demand reduction values for monthly submission . Mr. Loiter also manages CMEEC's participation in new FCM auctions and arranges for annual certification reviews.

" Submitted expert testimony on behalf of environmental interveners or state agencies in cases related to utility Integrated Resource Plan and Demand Side Management Plan filings. Cases typically involve filing review, developing alternative analyses, drafting pre-filed testimony, and appearing before public service commissions for cross-examination. Cases have included utility filings in Virginia, Ohio, West Virginia, Kentucky, Kansas, and Arkansas .

" Supporting program implementation and on-going program design and development for Orange and Rockland Utilities . Previously managed the preparation of a DSM plan and Commission filings for this client . The project included on-site customer audits and residential surveys, efficiency program designs, and an efficiency potential study.

" Led Optimal's participation in preparing a Technical Resource Manual for the Mid-Atlantic States (Maryland, Delaware, District of Columbia), for the Northeast Energy Efficiency Partnerships' Regional EM&V Forum.

Optimal Energy, tnc. e 10600 Route 116, Suite 3, Hinesburg, VT 05461 a 802-482-5600 www.oDtener2v .com

Environmental Respondents Exhibit No . -Attachment JML-1

Page 2 of 3

" Managed Optimal's participation in a team developing a Five-Year Energy Efficiency and Demand Response Plan for the Tennessee Valley Authority. Optimal's role focused on programs for the commercial sector in TVA's service territory, encompassing efforts to reach a va-riety of markets and end-uses, including specific offerings for both very large and small commercial entities .

" Supporting Efficiency Vermont with technical analysis, market research, and program design consultation . Recent projects include market characterization studies of refrigeration, lodging establishments, and food service entities ; and developing several Technical Resource Manual entries.

" Prepared two documents for inclusion with EPA's National Action Plan for Energy Efficiency : a guidebook on conducting efficiency potential studies and a handbook describing the funding and administration of clean energy funds.

" Led or contributed to several studies of efficiency potential, ranging from meta-analyses to detailed sector-specific assessments. Assessments have included both the residential sector and the commercial/industrial sectors, in locations including New York, Vermont, New England, Texas, and a Canadian Atlantic province .

Independent Consultant 2005-2006

Cambridge, MA

" For the Massachusetts Renewable Energy Trust SEED Initiative, evaluated renewable energy technology companies' applications for early-stage funding. Responsibilities included leading due diligence efforts on three applications and contributing to several others . Awards recommended for approval totaled $1 .4 million .

" Led an effort to draft a whitepaper on policies to encourage investment in electricity transmission facilities .

" Prepared two articles describing the potential impact of proposed federal legislation to increase domestic oil refining capacity, published in Petroleum Technology Quarterly (1Q 2006) and BCC Research/Energy Magazine (2006) .

Industrial Economics, Incorporated Cambridge, MA Associate, 1997-2000 ; Senior Associate, 2001-2004

Managed multi-disciplinary qualitative and quantitative assessments of natural resource damages and environmental policy for clients such as NOAA, USFWS, USEPA, USDOJ, the National Park Service, the State of Indiana, and the United Nations.

Jeffrey M. Loiter Page 2

Environmental Respondents Exhibit No . -

1_~ Attachment JIVIL-1 U11

Page 3 of 3

URS Consultants, Incorporated New Orleans & Boston M P

1991-1996

Prepared water, air, and solid and hazardous waste permit applications for state and federal agencies on behalf of industry clients.

EDUCATION

M.S ., Technology & Policy, Massachusetts Institute of Technology, Cambridge, MA, 1997

B.S . with distinction, Civil and Environmental Engineering, Cornell University, Ithaca, NY, 1991

PUBLICATIONS & PRESENTATIONS "Collaboration that Counts : The Role of State Energy Efficiency Stakeholder Councils," (with D. Sostand, M. Guerard, and J . Schlegel), 2012 ACEEE Summer Study on Energy Efficiency in Buildings, Pacific Grove, CA, August 2012 .

"Persistence and Cost of Behavioral Programs," presented at National Association of State Utility Consumer Advocates Mid-Year Meeting, Charleston, SC, June 2012 . "Impending EISA Lighting Standards: Impacts on Consumers and Energy Efficiency Lighting Programs," presented at National Association of Regulatory Utility Commissioners Annual Meeting (with M. DiMascio), Atlanta, GA, November 2010 .

"From Resource Acquisition to Relationships : How Energy Efficiency Initiatives Can Work Effectively with Large Commercial & Industrial Customers," (with E . Belliveau, J . Klein-man, D. Gaherty, and G. Eaton), 2008 ACEEE Summer Study on Energy Efficiency in Buildings, Pacific Grove, CA, August 2008 .

National Action Plan for Energy Efficiency (2007) . Guidefor Conducting Energy Efficiency Potential Studies . Prepared by Philip Mosenthal and Jeff Loiter, Optimal Energy, Inc . December . Loiter J.M and V . Norberg-Bohm (1999), "Technology policy and renewable energy : public roles in the development of new technologies," Energy Policy Vol.27 no.85-97

Jeffrey M. Loiter Page 3

Environmental Respondents Exhibit No . -Attachment JML-2

Page 1 of 3

Virginia Electric and Power Company, Case No. PUE-2014-00071

Vilt-Kinia State Corporation Commission Staff First Set

The following response to Question No. 8 of the First Set of Interrogatories and Requests for Production of Documents propounded by the Virginia State Corporation Commission Staff received on October 15, 2014 has been prepared under my supervision as it relates to -non-cost-related matters .

Michael T. Hubbard Manager - Energy Conservation Virginia Electric and Power Company

The following response to Question No, 8 of the First Set of Interrogatories and Requests for Production of Documents propounded by the Virginia State Corporation Commission Staff received on October 15, 2014 has been prepared under my supervision as it reJates to cost-related matters .

David L. Turner Energy Conservation Compliance Manager Virginia Electric and Power Company

Question No. 8

Please provide all assumptions, including those provided to the Compwiy by outside consulting entities, that support the cost/benefit analysis of the proposed Phase IV energy efficiency programs .

Response :

The system program costs for the Company's proposed Phase IV DSM programs were based upon the proposals received by the vendor selected for program implementation . These are provided in the following thme program spreadsheets : Extraordinarily Sensitive Attachments Staff Set I - 8 (1) through (3).

Costs and program operating metrics (such as program life, load shapes, and energy savings) are detailed in these three extraordinarily sensitive attachments . Some data was adjusted for consistency with model input requirements (for example, participants are not fractional) . Five

DOM A514 0008

Environmental Respondents Exhibit No . Attachment A~-L-2

Page 2 of 3

percent was added to vendor projected costs fbr contingencies (no contract has been signed to date and discussions are continuing) . Also added to vendor projected costs are (1) EM&V costs, (2) Energy Conservation program manager costs, and (3) DSM Phase IV design costs . Details for these additional cost categories are provided in Extraordinarily Sensitive Attachment Staff Set I - 8 (4) .

Extraordinarily Sensitive Attachments Staff Set I - 8 (1) through (4) contain extraordinarily sensitive information (extraordinarily sensitive commercial and financial information), as marked by green shading, and are being produced to the Staff subject to the conditions set forth in 5 VAC 5-20-170, the Company's Motion for Entry of a Protective Order and Additional Protective Treatment filed on August 29, 2014 in Case No. PUB-2014-00071, and any additional Protective Rulings that are issued for confidential or extraordinarily sensitive information in Case No. PUE-2014-0007 1 .

DOM A514 0009

Environmental Respormlents Exl~tbft No. _ AftsChment JML-2

Page 3 of 3

Residential Appliance RecydinglEffideryt Products Program Extraordinarily Sensitive Attachment Staff Set 1-8 (2)

a PW-to-r~s RaW (NTGR) 77% ZNJ Free RWers b Measure 1: Appliance Recycling 8 c Progriun Life 5 "' .

-d Average trKremeittal Measure Cost (one-time) S - per participant e A"e Incentive Pnment (One-time. if PaW 5 53 per participant paid by Dominion, excluding fecferal irXentives f Average Incentive Payment (annual, It paW on annual basis) NA per participant paid by DomWw, exclucling federal Irwentives

0 Non-tw-entive Program Costs (one-time, If Paid on a one-time bash) $ 143 per participant b Nm4nmnW program Costs as % of Incentive Cost (one-time) 272% of (e), hx*tdes switches and instaUation, marketim coordination vAth m&v contractor and other rwkncentive costs

i Non-Incentive Program Costs (annug, If paid on an annual basis) NA

i Nort-Incentive, Program Costs as % Incentive Paymern (annual) 0% Of (f) k Total Number of Customers with Baseline Technology 1,3w,850

1 m Average Measure Level Savings at Meter (colnocklent peak kW per gross participant) 0.14 kW per participant

n Average Measure Level Savings at Meter (annual kWh per gross participant) I,ODO kWh per participant

* Fwe-yew program lives have historically been assumed by Dominion. Ifan afternative program life Is appropriate, please explain.

* Represents costs for June through December of this year.

huraflations by Ildeancre 2025 * 2016 2017 2018 2019 IMeasure I Appr- RecycrnA 7,229 10.8431 10,843 1 10,

* Represmts cogs for June through December of this year .

NOTE: AlthouO not terwired as pan of this data sheet, backup calculations including measure-speafic participation wW energy savings prooctions wifl be reqtdred as part of the firwrl dew informatWL

isaazlosl

Environmental Respondents Exhibit No . _ Attachment JML-3

Page 1 of 3

Virginia Electric and Power Conil)anV Case No. PUE-2014-00071

Virginia State Corl3oration Commission Staff First Set

The following response to Question No. I I of the First Set of Interrogatories and Requests for Production of Documents propounded by the Virginia State Corporation Commission Staff received on October 15, 2014 has been prepared under my supervision.

74A-~- /P'ZZ~~

Michael T. Hubbard Manager - Energy Conservation Virginia Electric and Power Company

Question No. 11

Please, provide a detailed description of the proposed QL181[ifying Small Business Improvement Program, including, but not Hmited to, the information requested below:

(a) What are the proposed "size and nced-based" requirements for customer eligibility?

(b) Describe the operational details of the program, For example, if a qualifying customer elects to participate, wil I Company contractors visit the customer's premises? Will Company contractors undertake all iniprovements/installations or will the customer be responsible for undertaking recommended improvements/installations . Will incentives be offered on a measure by measure basis or a total cost basis? Will any goods or services be provided gratis?

(c) Will any recommended equipment be available through the Company or its contractors? Will customers be eligible for financing through the Company or its contractors? If so, will there be monetary limits to the financing on a per customer basis?

Response :

The following information is provided based on the latest program design information available, and represents the Company's current plan for implementation of the Phase IV Qualifying Small Business Improvement Program. Upon approval of the Program, the Company will develop, in consultation with its program implementation contractor and appropriate state and local agencies, a detailed program implementation plan which is expected to be substantially consistent with the details below.

DOM A514 0014

Environmental Respondents Exhibit No . Attachment Jli-L-3

Page 2 of 3

(a) It is expected that customers classified under Rate Schedule GS- I (under 30 kW of demand), and possibly a portion of customers under Rate Schedule GS-2 (between 30 kW and 500 kW), subject to a maximum demand limitation will be eligible to participate in the Program. The Company is currently defining applicable criteria that will help identify and target disadvantaged businesses classified under these rate schedules . The use of Historically Underutilized Business ("RUB") and Enterprise Zones is also being considered. If this Program is approved, the Company expects to utilize with the Virginia Department of Small Business and Supplier Diversity to better define the appropriate eligibility criteria as the detailed implementation plan for this Program is developed .

(b) The Company's program implementation contractor will qualify and manage a pool of regional contractors ("trade allies") to visit customer sites, perform audits, and undertake improvements and installations . Specific program participation paths are expected 10 include the following :

Direct Install Lighting :

Upon completion of the audit, trade allies will provide customers with all audit report summarizing the fuidings, estimated energy savings, and economics, including available Program rebates . Once the CLIStonler decides on the eligible lighting measures to install, the trade ally will complete the installation and assist the customer ill obtaining the rebate . Direct Install trade-allies will be trained to perform their own marketing and outreach effbits, which the Program will support through marketing materials such as brochures and case shiclies (if/when available), and continuous training. When Direct Install trade allies identify potentially eligible customers, they will verify eligibility with the customer and conduct the no-cost lighting assessment of the facility .

Prescriptive Non-Lighting Incentives :

For the nori-lighting measures included in the Small Business Improvement Program, customers, with support from Program trade allies, are responsible for installing qualifying equipment, and completing and submitting a Program application along with necessary documentation . The Company's implementation contractor staff will be available to guide customers and trade allies in selecting qualifying equipment and clarifying their minimum eligibility requirements, Incentives will be offered oil a measure-by-measure basis.

Prescriptive Recommissioning:

The Prescriptive Recommissioning offering will help small business customers by offering services through qualified trade allies to identif~, and implement low-cost energy efficiency measures that will be Operations and Maintenance C'O&W) in nature . Similar to the Direct Install Lighting approach above, participation paths include customers requesting an audit through the Program, as well as trade ally-initiated projects, Upon identi-fication of an eligible custorner, trade allies will conduct an audit focusing on the O&M improvements at the facility . The Program will subsidize a portion

DOM A514 0015

Environmental Respondents Exhibit No . -Attachment JML-3

Page 3 of 3

of the audit cost, but the customer will be responsible for the remaining cost. Upon identificatio,n of eligible improvements, the customer will select improvements for the trade ally to implement, and the Program will offer incentives targeting approximately 50% of the total project cost, including the audit cost (tip to a designated cost cap per project, consistent with approved Program funding) .

(c) Recommended equipment will not be available through the Company or its contractors, arid customers will not be eligible for financing through the Company or its contractors .

DOM A514 0016

Environmental Respondents Exhibit No . Attachment JIZ~

Page I of 13

C Viryinia Electric and Power Company

Case No. PUE-2014-00071 Virojpia State Corporation Commission Staff

Third Set

Ile following response to Question No. 21 of the Third Set of Interrogatories and Requests for Production of Documents propounded by the Virginia State Corporation Commission Staff received on December 19, 2014 has been prepared under my supervision.

Debra A. Stephens Regulatory Analyst IR Virginia Electric and Power Company

Question No. 21

Please provide the following information, in Microsoft Excel format with formulas intact, by tariff schedule and by month, for May 2013 through December 2014:

a) Number of customers;

b) Billed kWh sales; and

c) Unbilled kWh sales.

Response :

See Attachment Staff Set 3 - 21 for an electronic copy of the requested information.

DOM A514 00106

Environmental Respondents Exhibit No . -Attachment JML-4

Page 2 of 13

Source : Rates By States Report Attachment Staff Set 3-21

SCHEDULE YEAR MONTH DUPLICATE CUSTOMERS CUSTOMERS BILLED KWH UNBILLED KWH TOTAL KWH

DPR 2013 5 - 648 445,000 (9,000) 436,000 DPR 2013 6 - 641 569,000 99,000 668,000 DPR 2013 7 - 635 727,000 7,000 734,000 DPR 2013 8 - 626 677,000 (41,000) 636,000 DPR 2013 9 - 617 593,000 (72,000) 521,000 DPR 2013 10 - 609 440,000 (17,000) 423,000 DPR 2013 11 - 605 477,000 198,000 675,000 DPR 2013 12 - 622 734,000 36,000 770,000 DPR 2014 1 - 651 934,000 11,000 945,000 DPR 2014 2 - 651 1,004,000 (24,000) 980,000 DPR 2014 3 - 649 826,000 (77,000) 749,000 DPR 2014 4 - 646 630,000 (95,000) 535,000 DPR 2014 5 - 644 476,000 2,000 478,000 DPR 2014 6 - 645 571,000 74,000 645,000 DPR 2014 7 639 729,000 (22,000) 707,000 DPR 2014 8 - 635 599,000 12,000 611,000 DPR 2014 9 - 626 608,000 (102,000) 506,000 DPR 2014 10 622 428,000 (26,000) 402,000 DPR 2014 11 622 437,000 235,000 672,000 DPR 2014 12 613 765,000 22,000 787,000 DP1 2013 5 34 49,000 (8,000) 41,000 DPI 2013 6 34 65,000 13,000 78,000 DPI 2013 7 34 74,000 (2,000) 72,000 DP1 2013 8 33 69,000 (3,000) 66,000 DP1 2013 9 30 58,000 (8,000) 50,000 DP1 2013 10 32 57,000 5,000 62,000 DP1 2013 11 32 47,000 6,000 53,000 DPI 2013 12 34 74,000 10,000 84,000 DP1 2014 1 - 34 82,000 (3,000) 79,000 DP1 2014 2 - 35 89,000 89,000 DPI 2014 3 3S 79,000 (4,000) 75,000 DP1 2014 4 - 35 73,000 (4,000) 69,000 DP1 2014 5 - 35 64,000 (1,000) 63,000 DP1 2014 6 - 34 69,000 4,000 73,000 DP1 2014 7 32 87,000 - 87,000 DP1 2014 8 - 32 65,000 (3,000) 62,000 DP1 2014 9 - 31 66,000 (7,000) 59,000 DP1 2014 10 - 40 53,000 (3,000) 50,000 DP1 2014 11 47 60,000 24,000 84,000 DP1 2014 12 - 65 162,000 36,000 198,000 DP2 2013 5 - 70 1,914,000 6,000 1,920,000 DP2 2013 6 - 70 2,082,000 195,000 2,277,000 DP2 2013 7 - 70 2,476,000 (3,000) 2,473,000

0a

Environmental Respondents Exhibit No . --AttaGhment Xvit-4

Page 3 of 13

DP2 2013 8 - 69 2,203,000 (143,000) 2,060,000 DP2 2013 9 - 68 2,151,000 (87,000) 2,064,000 DP2 2013 10 - 69 1,966,000 49,000 2,015,000 DP2 2013 11 - 68 1,969,000 489,000 2,458,000 DP2 2013 12 - 72 2,247,000 (131,000) 2,116,000 DP2 2014 1 - 75 2,762,000 59,000 2,821,000 DP2 2014 2 - 75 2,858,000 (76,000) 2,782,000 DP2 2014 3 - 75 2,798,000 41,000 2,839,000 DP2 2014 4 - 75 2,375,000 (276,000) 2,099,000 DP2 2014 5 - 75 2,203,000 71,000 2,274,000 DP2 2014 6 - 75 2,475,000 190,000 2,665,000 DP2 2014 7 - 74 2,700,000 (210,000) 2,490,000 DP2 2014 8 - 74 2,482,000 166,000 2,648,000 DP2 2014 9 - 77 2,620,000 (187,000) 2,433,000 DP2 2014 10 - 77 2,318,000 (19,000) 2,299,000 DP2 2014 11 - 77 2,084,000 605,000 2,689,000 DP2 2014 12 - 77 2,832,000 (330,000) 2,502,000 EV 2013 5 32 - 8,000 2,000 10,000 EV 2013 6 33 - 9,000 1,000 10,000 EV 2013 7 35 - 10,000 (1,000) 9,000 EV 2013 9 40 - 12,000 1,000 13,000 EV 2013 9 42 - 12,000 (1,000) 11,000 EV 2013 10 47 16,000 4,000 20,000 EV 2013 11 54 - 15,000 5,000 20,000 EV 2013 12 60 - 18,000 (2,000) 16,000 EV 2014 1 62 - 21,000 (1,000) 20,000 EV 2014 2 66 - 20,000 (1,000) 19,000 EV 2014 3 67 - 20,000 20,000 EV 2014 4 68 - 20,000 - 20,000 EV 1 2014 5 69 - 21,000 3,000 24,000 EV 2014 6 71 - 22,000 2,000 24,000 EV 2014 7 78 - 22,000 (4,000) 18,000 EV 2014 8 79 - 20,000 1,000 21,000 EV 2014 9 81 - 25,000 (1,000) 24,000 EV 2014 10 84 - 27,000 4,000 31,000 EV 2014 11 86 - 26,000 13,000 39,000 EV 2014 12 89 - 33,000 (6,000) 27,000 GS1 2013 5 179,065 252,983,000 6,997,000 259,980,000 GS1 2013 6 - 178,894 273,680,000 24,823,000 298,503,000 GSI 2013 7 - 179,525 337,720,000 5,721,000 343,441,000 GSI 2013 8 - 179,479 322,821,000 (7,441,000) 315,380,000 GS1 2013 9 - .179,349 296,460,000 (22,464,000) 273,996,000 G51 2013 10 - 179,495 265,678,000 4,371,000 270,049,000 G51 2013 11 - 179,518 227,797,000 36,145,000 263,942,000 GS1 2013 12 - 179,485 306,000,000 14,496,000 320,496,000 GS1 2014 1 179,316 343,049,000 (10,620,000)1 332,429,00 O GS1 2014 2 179,129 327,063,000 (25,077,000)1

d 301,986,000

Environmental Respondents Exhibit No . _ Attachment JML-4

Page 4 of 13

GSI 2014 3 179,011 310,088,000 (1,198,001) 308,889,999 GSI 2014 4 178,994 264,976,000 (29,320,000) 235,656,000 GSI 2014 5 179,180 249,380,000 10,172,000 259,552,000 GSI 2014 6 179,410 283,046,000 23,399,000 306,445,000 GSI 2014 7 179,544 336,431,000 (10,833,000) 325,598,000 G51 2014 8 179,746 297,279,000 14,400,000 311,679,000 GSI 2014 9 - 179,787 309,044,000 (26,053,000) 282,991,000 GSI 2014 10 - 179,942 260,968,000 (8,732,000) 252,236,000 GSI 1 2014 11 - 180,154 213,066,000 49,607,000 262,673,000 GSI 2014 12 - 180,215 313,135,000 (21,223,000) 291,912,000 GS2 2013 5 - 30,583 688,827,000 49,690,001 738,517,001 GS2 2013 6 - 30,559 735,507,000 61,452,000 796,959,000 GS2 2013 7 - 30,482 899,480,000 11,241,000

_ 910,721,000

GS2 2013 8 - 30,373 851,552,000 (24,240,000) 827,312,000 GS2 2013 9 - 30,275 790,878,000 (54,709,000) 736,169,000 GS2 2013 10 - 30,216 718,663,000 16,518,000 735,181,000 GS2 2013 11 - 30,194 599,613,000 82,442,000 682,055,000 GS2 2013 12 - 30,257 73S,164,000 (7,974,999) 727,189,001 GS2 2014 1 - 30,486 822,060,000 (26,943,999) 795,116,001 GS2 2014 2 - 30,705 741,859,000 (80,864,001) 660,994,999 GS2 2014 3 - 30,982 728,613,000 11,338,999 739,951,999 GS2 1 2014 4 31,082 673,108,000 (42,488,000) 630,620,000 GS2 2014 5 - 31,071 679,856,000 53,689,000 733,545,000 GS2 2014 6 - 31,043 773,385,000 64,713,999 838,098,999 GS2 2014 7 - 31,022 907,196,000 (35,238,999) 871,957,001 GS2 2014 8 - 30,980 802,830,000 38,604,000 841,434,000 GS2 2014 9 - 30,991 826,213,000 (73,195,001) 753,017,999 GS2 2014 10 - 30,897 711,179,000 (16,236,999) 694,942,001 GS2 2014 11 - 30,858 575,180,000 129,546,000

_ 704,726,000

GS2 2014 12 - 30,928 777,733,000 (94,135,000) 683,598,000 GS2T 2013 5 4,771 191,499,000 18,868,000 210,367,000 GS2T 2013 6 - 4,871 208,116,000 19,401,000 227,517,000 G52T 2013 7 - 4,881 252,380,000 .2,034,000 254,414,000 GS2T 2013 8 - 4,888 243,198,000 (4,507,000) 238,691,000 GS2T 2013 9 - 4,893 220,145,000 (18,549,000) 201,596,000 GS2T 2013 10 - 4,905 206,166,000 8,282,000 214,448,000 GS2T 2013 11 - 4,943 171,624,000 23,422,000 195,046,000 GS2T 2013 12 - 4,959 203,537,000 (7,000,001) 196,536,999 GS2T 2014 1 - 4,984 224,482,000 (9,178,000) 215,304,000 GS2T 2014 2 - 5,016 201,003,000 (23,047,000) 177,956,000 GS2T 2014 3 - 5,020 198,253,000 3,509,000 201,762,000 GS2T 2014 4 - 5,034 188,833,000 (8,533,000) 180,300,000 GS2T 2014 5 - 1 5,055 197,260,000 19,003,000 216,263,000 GS2T 2014 6 - 5,102 223,456,000 18,217,000 241,673,000 GS2T 2014 7 - 5,109 259,258,000 (11,583,000) 247,675,000 GS2T 2014 8 - 5,108 231,614,000 12,434,000

- 244,048,000

GS2T 1 2014 9 1 - 5,106 239,911,000~ - (20,497,000) 1 219,414,

Pa

Environmental Respondents Exhibit No . -Attachment JIVIL-4

Page 5 of 13

GS2T 2014 10 - 5,126 210,235,000 (2,651,000) 207,S84,000 GS2T 2014 11 - S,132 166,558,000 35,224,000 201,782,000 GS2T 2014 12 - 5,131 217,765,000 (31,303,000) 186,462,000 GS3 2013 5 - 1,654 767,751,000 54,180,999 821,931,999 GS3 2013 6 - 1,657 822,462,000 70,855,000 893,317,000 GS3 2013 7 - 1,658 924,901,000 (28,478,001) 896,422,999 GS3 2013 8 - 1,639 907,679,000 (7,420,001) 900,258,999 GS3 2013 9 - 1,632 852,975,000 (52,842,000) 800,133,000 GS3 2013 10 - 1,638 810,447,000 29,763,000 840,210,000 GS3 2013 11 - 1,635 706,666,000 109,106,999 815,772,999 GS3 2013 12 - 1,631 829,493,000 (24,048,000) 805,445,000 G53 2014 1 - 1,630 886,894,000 (56,603,000) 830,291,000 GS3 2014 2 - 1,621 765,482,000 (95,333,000) 670,149,000 GS3 2014 3 - 1,625 814,801,000 47,989,000 862,790,000 GS3 2014 4 - 1,645 768,795,000 (41,966,001) 726,828,999 GS3 2014 5 - 1,632 785,060,000 65,071,000 850,131,000 GS3 2014 6 - 1,623 844,137,000 43,560,000 887,697,000 GS3 2014 7 - 1,632 937,641,000 (62,167,000) 875,474,000 GS3 2014 8 - 1,642 873,171,000 56,129,000 929,300,000 GS3 2014 9 - 1,647 908,309,000 (62,027,000) 846,282,000 GS3 2014 10 - 1,653 849,610,000 16,089,999 865,699,999 GS3 2014 11 1,655 699,320,000 160,748,999 860,068,999 GS3 2014 12 1,654 902,371,000 (138,957,999) 763,413,001 GS4 2013 5 149 510,195,000 43,858,999 554,053,999 GS4 2013 6 147 506,125,000 22,672,999 528,797,999 GS4 2013 7 148 659,285,000 36,768,000 695,053,000- GS4 2013 8 150 576,838,000 (39,893,000) 536,945,000 GS4 2013 9 152 573,652,000 (15,994,001) 557,657,999 GS4 2013 10 148 548,387,000 (15,551,000) 532,836,000 GS4 2013 11 145 500,942,000 44,144,000 545,086,000 GS4 2013 12 144 530,473,000 (2,872,000) 527,601,000 GS4 2014 1 144 583,870,000 (35,250,000) 548,620,000_ GS4 2014 2 144 498,728,000 (27,540,000) 471,188,000 GS4 2014 3 143 505,537,000 25,769,000 531,306,000 GS4 2014 4 143 515,286,000 (17,743,999) 497,542,001 GS4 2014 5 143 541,352,000 47,708,000 589,060,000 GS4 2014 6 144 537,948,000 939,001 538,887,001 GS4 2014 7 144 609,882,000 (28,544,000) 581,338,000 GS4 2014 8 - 145 567,296,000 1,341,001 568,637,001 GS4 2014 9 - 145 580,605,000 1,804,001 582,409,001_ GS4 2014 10 - 145 581,197,000 21,399,999 602,596,999 GS4 2014 11 - 145 482,036,000 89,071,000 571,107,000 GS4 2014 12 - 145 720,856,000 (56,435,000) 664,421,000 Sp 2013 9 11 - - - Sp 2013 10 1 16 Sp 2013 11 22

2013 12 31

OA LM

Environmental Respondents Exhibit No . -Attachment JML-4

Page 6 of 13

SP 2014 1 36 - - - Sp 2014 2 40 - - -

Sp 2014 3 44 - - - SP 2014 4 46 - - - SP 2014 5 48 - - - SP 2014 6 52 - - - Sp 2014 7 56 - - - Sp 2014 8 61 - - - Sp 2014 9 63 - - - Sp 2014 10 67 - - - Sp 2014 11 69 - - - Sp 2014 12 76 - - -

1 2013 5 - 2,092,477 1,712,979,000 73,688,000 1,796,667,000 1 2013 6 - 2,093,886 2,071,502,000 303,898,000 2,375,400,000 1 2013 7 - 2,095,429 2,844,019,000 132,136,000 2,976,155,000 1 2013 8 - 2,097,283 2,682,49S,000 (142,092,000) 2,540,403,000 1 2013 9 - 2,098,408 2,318,245,000 (300,379,000) 2,017,866,000 1 2013 10 - 2,100,689 1,779,875,000 (31,026,000) 1,748,849,000 1 2013 11 - 2,103,899 1,646,239,000 529,548,000 2,175,787,000 1 2013 12 - 2,108,007 2,653,490,000 203,806,000 2,857,296,000 1 2014 1 - 2,111,268 3,362,960,000 32,788,000 3,395,748,000 1 2014 2 - 2,112,733 3,222,820,000 (270,753,000) 2,952,067,000 1 2014 3 - 2,112,571 2,818,047,000 (168,530,000) 2,649,517,000 1 2014 4 - 2,112,850 2,136,915,000 (328,434,000) 1,808,481,000 1 2014 5 - 2,113,812 1,739,824,000 88,299,000 1,828,123,000 1 2014 6 - 2,115,782 2,124,897,000 296,875,000 2,421,772,000 1 2014 7 - 2,118,951 2,855,505,000 (14,700,000) 2,840,805,000 1 2014 8 - 2,121,600 2,384,239,000 72,562,000 2,456,801,000 1 2014 9 - 2,122,228 2,447,905,000 (394,815,000) 2,053,090,000 1 2014 10 - 2,124,627 1,742,652,000 (95,666,000) 1,646,986,000 1 2014 11 - 2,128,140 1,519,422,000 674,508,000 2,193,930,000 1 2014 12 - 2,131,238 2,738,104,000 126,223,000 2,864,327,000

IEV 2013 5 135 170,000 28,000 198,000 1EV 2013 6 - 147 209,000 32,000 241,000 1EV 2013 7 - 151 307,000 24,000 331,000 IEV 2013 8 - 165 294,000 (13,000) 281,000 IEV 2013 9 173 270,000 (26,000) 244,000 1EV 2013 10 - 183 241,000 16,000 257,000 IEV 2013 11 - 195 218,000 68,000 286,000 1EV 2013 12 - 202 349,000 25,000 374,000 1EV 2014 1 - 210 440,000 3,000 443,000 1EV 2014 2 - 1 213 409,000 (41,000) 368,000 IEV 2014 3 - 222 375,000 (14,000) 361,000 1EV 2014 4 - 227 321,000 (25,000) 296,000 1EV 2014 5 - 235 291,000 32,000 323,000 1EV 2014 6 - 248 369,000 59,000 428,000 1EV 2014 7 - 1 263 498,000 (2,000)1 496,000

H 4M 0 1.4

Environmental Respondents Exhibit No . -Attachment JML-4

Page 7 of 13

1EV 2014 8 - 272 455,000 38,000 493,000 1EV 2014 9 - 281 467,000 (76,000)

_ 391,000

1EV 2014 10 - 298 390,000 14,000 404,000 1EV 2014 11 - 298 316,000 125,000 441,000 1EV 2014 12 - 306 574,000 29,000 603,000 ip 2013 5 - 1,040 2,004,000 43,000 2,047,000 IP 2013 6 1,035 2,448,000 372,000 2,820,000 IP 2013 7 1,030 3,370,000 162,000 3,532,000 ip 2013 8 1-- 1,021 3,309,000 (103,000) 3,206,000 ip 2013 9 - 1,020 2,570,000 (504,000) 2,066,000 ip 2013 10 - 1,019 2,329,000 173,000 2,502,000 - ip 2013 11 - 1,015 1,852,000 405,000 2,257,000 IP 2013 12 - 1,011 2,981,000 227,000 3,208,000 IP 2014 1 - 1,005 3,783,000 39,000 3,822,000 ip 2014 2 - 998 3,512,000 (358,000) 3,154,000 ip 2014 3 - 991 3,157,000 (142,000) 3,015,000 ip 2014 4 - 989 2,471,000 (331,000) 2,140,000 ip 2014 5 - 981 2,015,000 105,000 2,120,000 IP 2014 6 - 978 2,435,000 326,000 2,761,000 ip 2014 7 - 973 3,246,000 (29,000) 3,217,000 ip 2014 8 - 1 968 2,757,000 111,000 2,868,000 IP 2014 9 - 961 2,741,000 (496,000) 2,245,000 IP 2014 10 - 957 2,124,000 (9,000) 2,115,000 IP 2014 11 - 956 1,631,000 580,000 2,211,000 ip 2014 12 - 953 3,001,000 176,000 3,177,000 15 2013 5 - 6,979 12,342,000 453,000 12,795,000 is 2013 6 - 6,965 15,434,000 2,529,000 17,963,000 is 2013 7 - 6,944 20,906,000 833,000 21,739,000 is 2013 8 - 6,922 20,371,000 (712,000) 19,659,000 is 2013 9 - 6,915 15,961,000 (3,038,000) 12,923,000 is 2013 10 - 6,907 14,847,000 1,297,000 16,144,000 is 2013 11 - 6,901 11,263,000 2,068,000 13,331,000 is 2013 12 - 6,899 17,819,000 1,169,000 18,988,000 is 2014 1 - 6,888 23,232,000 569,000 23,801,000 is 2014 2 - 6,881 23,101,000 (1,472,000) 21,629,000 - is 2014 3 6,885 19,784,000 (1,409,000) 18,375,000 is 2014 4 6,877 14,960,000 (2,326,000) 12,634,000 is 2014 5 6,867 12,278,000 681,000 12,959,000 is 2014 6 6,843 15,365,000 2,342,000 17,707,000 - is 2014 7 6,822 20,352,000 (252,000) 20,100,000 is 2014 8 6,806 17,570,000 875,000 18,445,000 is 2014 9 6,800 18,408,000 (2,746,000) 15,662,000 is 2014 10 - 6,806 13,201,000 (665,000) 12,536,000 is 2014 11 - 6,799 10,234,000 3,714,000 13,948,000 is 2014 12 - 6,782 18,708,000 1 1,024,000 1 19,732,000 1T 2013 5 683 828,000 (20,000) 808, 0 1T 2013 6 - 680 841,000 40,000 881,nnn

Environmental Respondents Exhibit No . -Attachment JML-4

Page 8 of 13

IT 2013 7 - 674 1,223,000 90,000 1,313,000 IT 2013 8 - 671 1,200,000 (38,000) 1,162,000 IT 2013 9 - 667 854,000 (218,000) 636,000 IT 2013 10 - 666 788,000 64,000 852,000 IT 2013 11 - 663 692,000 200,000 892,000

u IT 2013 12 - 662 1,296,000 207,000 1,503,OOtO IT 2014 1 - 659 1,750,000 74,000 1,824,000 IT 2014 2 - 656 1,732,000 (116,000)

_ 1 616,000

IT 2014 3 - 654 1,530,000 (83,000) 1,447,000 IT 2014 4 - 651 1,087,000 (213,000) 874 000 IT 2014 5 - 651 739,000 (50,000) 689,000 IT 2014 6 - 649 838,000 83,000 921,000 IT 2014 7 644 1,112,000 (12,000) 1,100,000 IT 2014 8 - 645 935,000 32,000 967,000 IT 2014 9 - 642 933,000 (167,000) 766,000 IT 2014 10 - 643 723,000 (3,000) 720,000 IT 2014 11 - 641 587,000 233,000 820,000 IT 2014 12 - 645 1,400,000 272,000 1,672,000 1w 2013 5 140 - 27,000 3,000 30,000 1w 2013 6 140 27,000 1,000 28,000~ 1w 2013 7 139 29,000 (3,000) 26,000 1w 2013 8 136 27,000 (2,000) 25,000 1w 2013 9 136 - 24,000 (2,000) 22,000 Iw 2013 10 137 - 30,000 6,000 36,000 1w 2013 11 135 - 14,000 (3,000) 11,000 1w 2013 12 134 - 32,000 8,000 40,000 1w 2014 1 132 - 37,000 (2,000) 35,000 1w 2014 2 131 - 34,000 (4,000) 30,000 1w 2014 3 131 - 33,000 33,000 1w 2014 4 131 - 30,000 (2,000)

. 28,000

1w 2014 5 129 - 25,000 2,000 27,000 1w 2014 6 128 - 24,000 - 24,000 1w 2014 7 127 - 26,000 (3,000) 23,000 1w 2014 8 127 - 23,000 2,000 25,000_ 1w 2014 9 127 - 24,000 (4,000) 20,000 1w 2014 10 127 - 21,000 1,000 22,000 1w 2014 11 127 - 20,000 10,000 30,000_ 1w 2014 12 127 - 35,000 1,000 36,000 10 2013 5 - 580 220,907,000 19,231,000 240,138,000 10 2013 6 - 580 224,493,000 12,601,000 237,094,000 10 2013 7 - 590 252,318,000 (5,538,000) 246,780,000 10 2013 8 - 591 256,680,000 2,894,000 259,574,000 10 2013 9 - 595 228,983,000 (21,329,000) 207,654,000 10 2013 10 - 598 243,769,000 11,270,000 255,039,000

2013 11 - 603 201,555,000 15,686,000 217,241,000 2013 12 607 238,040,000 4,904,000 242,944,000 2014 1 613 255,686,000 (16,572,000) 239,114,000

H

Environmental Respondents Exhibit No . -Attachment JML-4

Page 9 of 13

10 2014 2 - 625 242,446,000 (7,689,000) 234,758,000 10 2014 3 - 625 246,857,000 10,992,000 257,849,000 10 2014 4 - 624 224,984,000 (19,396,000) 205,588,000 10 2014 5 - 626 242,355,000 24,432,000 266,787,000 10 1 2014 6 - 629 252,100,000 8,417,000 260,517,000 10 2014 7 - 624 282,534,000 (15,961,000) 266,573,000 10 2014 8 - 624 256,808,000 5,133,000 261,941,000 10 2014 9 - 624 259,935,000 (10,698,000) 249,237,000 10 2014 10 - 626 259,919,000 9,746,000 269,665,000 10 2014 11 - 627 192,964,000 26,425,000 219,389,000 10 2014 12 - 626 266,217,000 (30,319,000) 235,898,000 25 2013 5 - 7 77,000 21,000 98,000 25 2013 6 - 7 17,000 (35,000) (18,000) 25 2013 7 - 7 40,000 11,000 51,000 25 2013 8 - 7 26,000 (8,000) 18,000 25 2013 9 - 7 67,000 20,000 87,000 25 2013 10 - 7 47,000 (6,000) 41,000 25 2013 11 - 7 19,000 (12,000) 7,000 25 2013 12 - 7 69,000 31,000 100,000 25 2014 1 - 7 39,000 (25,000) 14,000 25 2014 2 - 7 21,000 (11,000) 10,000 25 2014 3 - 7 43,000 13,000 56,0 25 2014 4 - 7 56,000 5,000 61,000 25 2014 5 - 7 50,000 1,000 51,0nn 25 2014 6 - 7 28,000 (13,000) 15,000 25 2014 7 - 7 31,000 (2,000) 29,000 25 2014 8 - 7 12,000 (8,000) 4,000 25 2014 9 - 7 61,000 23,000 84,000 25 2014 10 - 5 54,000 - 54,000 25 2014 11 - 5 20,000 (12,000) 8,000 25 2014 12 - 5 74,000 23,000 97,000 27 2013 5 39,801 - 4,958,000 691,000 5,649,000 27 2013 6 39,822 - 4,533,000 (60,000) 4,473,000 27 2013 7 39,846 - 4,958,000 (294,000) 4,664,000 27 2013 8 39,906 - 4,949,000 (34,000) 4,915,000 27 2013 9 40,029 - 4,606,000 (344,000) 4,262,000 27 2013 10 40,074 4,974,000 629,000 5,603,000 27 2013 11 40,113 4,410,000 964,000 5,374,000 27 2013 12 40,173 - 4,799,000 (647,000) 4,152,000 27 2014 1 40,275 - 4,970,000 (452,000) 4,518,000 27 2014 2 40,313 - 4,627,000 (427,000) 4,200,000 27 2014 3 40,388 - 4,829,000 197,000 5,026,000 27 2014 4 40,415 - 4,814,000 (67,000) 4,747,000 27 2014 5 40,434 - 4,837,000 516,000 5,353,000 27 2014 6 40,467 - 4,868,000 92,000 4,960,000 27 2014 7 40,500 - 5,104,000 (594,000) 4,510,000 27 2014 8 40,522 - 4,850,000 441,000 5,291,000

Environmental Respondents Exhibit No . Attachment A~-L-4

Page 10 of 13

27 2014 9 40,558 4,885,000 (614,000) 4,271,000 27 2014 10 40,640 5,093,000 507,000 5,600,000 27 2014 11 40,733 4,152,000 1,200,000 5,352,000 27 2014 12 40,831 5,174,000 (1,005,000) 4,169,000 28 1 2013 5 15,294 1 2,883,000 356,000 3,239,000 28 2013 6 15,235 2,602,000 (55,000) 2,547,000 28 2013 7 15,168 2,855,000 (152,000) 2,703,000 28 2013 8 15,092 2,796,000 (41,000) 2,755,000 28 2013 9 15,035 2,618,000 (180,000) 2,438,000 28 2013 10 14,954 2,776,000 311,000 3,087,000 28 2013 11 14,880 2,474,000 508,000 2,982,000 28 2013 12 14,816 2,670,000 (337,000) 2,333,000 28 2014 1 14,764 2,771,000 (237,000) 2,534,000 28 2014 2 14,716 2,543,000 (252,000) 2,291,000 28 2014 3 14,652 2,641,000 107,000 2,748,000 28 2014 4 14,579 2,640,000 (38,000) 2,602,000 28 2014 5 14,517 2,617,000 229,000 2,846,000 28 2014 6 14,452 2,600,000 26,000 2,626,000 28 2014 7 14,400 2,730,000 (298,000) 2,432,000 28 2014 8 14,337 2,602,000 231,000 2,833,000 28 2014 9 14,265 2,589,000 (316,000) 1 2,273,000 28 2014 10 14,212 2,659,000 221,000 2,880,000 28 2014 11 14,149 2,206,000 611,000 2,817,000 28 2014 12 14,094 2,726,000 (529,000) 2,197,000 29 2013 5 - 945 398,000 23,000 421,000 29 2013 6 - 945 369,000 (2,000) 366,000 29 2013 7 - 944 383,000 (31,000) 352,000 29 2013 8 - 945 376,000 (2,000) 374,000 29 2013 9 - 946 394,000 (1,000) 393,000 29 2013 10 - 946 420,000 45,000 465,000 29 2013 11 - 945 441,000 126,000 567,000 29 2013 12 - 948 552,000 (2,000) 550,000 29 2014 1 - 947 567,000 (48,000) 519,000 29 2014 2 - 947 473,000 (76,000) 397,000 29 2014 3 - 947 433,000 (10,000) 423,000 29 2014 4 - 947 401,000 (25,000) 376,000 29 2014 5 - 948 385,000 20,000 405,000 29 2014 6 - 949 358,000 (11,000) 347,000 29 2014 7 - 959 376,000 (38,000) 338,000 29 2014 8 - 959 361,000 33,000 394,000 29 2014 9 - 959 398,000 (21,000) 377,000 29 2014 10 - 961 421,000 35,000 456,000 29 2014 11 - 961 413,000 142,000 555,000 29 2014 12 - 964 543,000 (75,000) 468,000 5 2013 5 - 662 2,757,999 184,000 2,941,999 5 2013 6 - 660 3,105,000 348,000 3,453,000 5 2013 7 - 658 3,909,999 107,000 4,016,999

I-A

Environmental Respondents Exhibit No . _ Attachment JML-4

Page 11 of 13

5 2013 8 657 3,725,000 (91,000) 3,634,000 5 2013 9 - 657 3,295,000 (323,999) 2,971,001 5 2013 10 - 655 2,839,000 (19,000) 2,820,000 5 2013 11 - 655 2,284,000 259,000 2,543,000 5 1 2013 12 - 652 2,938,000 56,000 2,994,000 5 2014 1 - 651 3,225,000 (141,000) 3,084,000 5 2014 2 - 650 4,665,000 597,000 5,262,000 5 2014 3 - 649 3,333,000 (612,000) 2,721,000 5 2014 4 - 648 2,530,000 (484,000) 2,046,000 5 2014 5 - 648 2,607,000 233,000 2,840,000 5 2014 6 - 646 3,205,000 394,000 3,599,000 5 2014 7 - 644 3,992,000 (33,000) 3,959,000 5 2014 8 - 644 3,453,001 124,000 3,577,001 5 2014 9 - 644 3,421,000 (382,000) 3,039,000 5 2014 10 - 644 2,699,000 (200,000) 2,499,000 5 2014 11 - 642 2,051,000 375,000 2,426,000 5 2014 12 - 642 2,922,000 (257,000) 2,665,000

5C 1 2013 5 - 2,796 10,447,000 (457,000) 9,990,000 5c 2013 6 -

. 2,796 12,703,000 1,924,000 14,627,000

5C 2013 7 - 2,795 18,600,000 1,835,000 20,435,000 5C 2013 8 - 2,795 17,481,000 (570,000) 16,911,000 5c 2013 9 - 2,791 14,631,000 (1,944,000) 12,687,000 5C 2013 10 - 2,790 11,544,000 (700,000) 10,844,000 5C 2013 11 - 2,790 9,535,000 1,263,000 10,798,000 5C 2013 12 - 2,789 14,194,000 1,542,000 15,736,000 5C 2014 1 - 2,791 17,215,000 250,000 17,465,000 5C 2014 2 - 2,790 17,140,000 (880,001) 16,259,999 5C 2014 3 - 2,788 15,137,000 (670,000) 14,467,000 5C 2014 4 - 2,790 12,030,000 (1,910,000) 10,120,000 5C 2014 5 2,786 10,530,000 (18,000) 10,512,000 5C 2014 6 - 2,789 13,349,000 1,848,000 15,197,000 5C 2014 7 - 2,783 18,644,000 833,001 19,477,001 5c 2014 8 - 2,788 15,530,000 235,999 15,765,999 5c 2014 9 - 2,788 15,806,000 (1,528,000) 14,278,000 5C 2014 10 - 2,785 11,509,000 (1,448,000) 10,061,000 5C 2014 11 - 2,784 8,652,000 1,516,999 10,168,999 5C 2014 12 - 2,782 15,208,000 497,000 15,705,000 5P 2013 5 - 257 4,567,000 281,000 4,848,000 51? 2013 6 - 257 5,606,000 875,000 6,481,000 5P 2013 7 - 257 6,933,000 125,000 7,058,000 5p 2013 8 - 255 6,684,000 (121,999)

_ 6,562,001

SP 2013 9 - 254 5,856,000 (610,000) 5,246,000 5P 2013 10 - 254 5,393,000 173,000 5,566,000 SP 2013 11 - 254 4,288,000 450,000 4,738,000 So 2013 12 - 253 5,016,000 (228,000) 4,788,000 51p 2014 1 - 252 5,722,000 (118,001) 5,603,999 5P _2014 2 - 1 252 5,552,000 (367,999) ~ 5,184,001

Environmental Respondents Exhibit No . _ Attachment JML-4

Page 12 of 13

5P 2014 3 - 251 5,087,000 (118,000) 4,969,000 5P 2014 4 - 251 4,491,000 (405,000) 4,086,000 5P 2014 5 - 252 4,620,000 410,000 5,030,000 5P 2014 6 - 253 5,723,000 729,000 6,452,000 5P 2014 7 - 1 253 61694,000 (272,000) 6,422,000 5P 2014 8 - 251 6,437,000 597,999 7,034,999 5P 2014 9 - 252 6,101,000 (853,000) 5,249,000 5P 2014 10 - 255 5,313,000 (86,000) 5,227,000 5P 2014 11 25S 3,901,000 615,000 4,516,000 SP 2014 12 254 5,242,000 (654,000) 4,588,000

56-235 .2 2013 5 1 37,185,000 1,252,000 38,437,000 56-235 .2 2013 6 1 44,485,000 6,065,000 50,550,000 56-235 .2 2013 7 1 34,961,000 (7,612,000) 27,349,000 56-235 .2 2013 8 1 33,438,000 (653,000) 32,785,000 56-235 .2 2013 9 1 36,036,000 348,000 36,384,000 56-235 .2 2013 10 - 1 28,698,000 (4,965,000) 23,733,000 56-235.2 2013 11 - 1 32,613,000 3,686,000 36,299,000 56-235.2 2013 12 - 1 6,457,000 (12,512,000) (6,055,000) 56-235.2 2014 1 - 1 65,782,000 22,784,000 88,566,000 56-235.2 2014 2 28,001,000 (12,966,000) 15,035,000 56-235.2 2014 3 25,256,000 115,000 25,371,000 56-235 .2 2014 4 32,216,000 1,746,000 33,962,000 56-235.2 2014 5 35,408,000 3,536,000 38,944,000 56-235.2 2014 6 38,968,000 1,889,000 40,857,000 56-235 .2 2014 7 21,962,000 (11,155,000) 10,807,000 56-235 .2 2014 8 34,607,000 5,084,000 39,691,000 56-235.2 2014 9 33,577,000 1,235,000 34,812,000 56-235 .2 2014 10 - 1 17,401,000 (7,182,000) 10,219,000 56-235.2 2014 11 - 1 53,232,000 30,248,000 83,480,000 56-235.2 2014 12 - 1 21,307,000 (30,027,000) (8,720,000)

6 2013 5 - 7 6,326,000 474,000 6,800,000 6 2013 6 - 7 7,411,000 950,000 8,361,000 6 2013 7 - 6 6,940,000 (782,000) 6,158,000 6 2013 8 - 6 6,583,000 (171,000) 6,412,000 6 2013 9 - 6 7,367,000 195,000 7,562,000 6 2013 10 6 6,063,000 (756,000) 5,307,000 6 2013 11 - 6 6,287,000 752,000 7,039,000 6 2013 12 - 6 6,601,000 80,000 6,681,000 6 2014 1 - 6 . 5,951,000 (1,003,000) 4,948,000 6 2014 2 - 6 6,725,000 607,000 7,332,000 6 2014 3 - 6 5,922,000 (96,000) 5,826,000 6 2014 4 - 6 5,895,000 (307,000) 5,588,000 6 2014 5 - 6 6,094,000 465,000 6,559,000 6 2014 6 - 6 6,978,000 493,000 7,471,000

2014 7 - 6 1 6,599,000 1 (907,000) 5,69 , 0 2014 8 - 6 6,467,000 69,000 6,536,000 2014 9 - 6 7,236,000 446,000 7,682,000

C)

Environmental Respondents Exhibit No . -Attachment JML-4

Page 13 of 13

6 2014 10 6 6,023,000 (402,000) 5,621,000 6 2014 11 6 6,298,000 1,802,000 8,100,000 6 2014 12 - 6 6,284,000 (2,054,000) 4,230,000

6TS 2013 5 - 29 21,410,000 2,965,000 24,375,000 ISTS 2013 6 - 28 16,603,000 (2,037,000) 14,566,000 ISTS 2013 7 - 28 23,224,000 1,792,000 25,016,000 6TS 2013 8 - 28 19,030,000 (2,191,000) 16,839,000 6TS 2013 9 - 27 19,871,000 (112,000) 19,759,000_ 6TS 1 2013 10 - 29 16,905,000 (310,000) 16,595,000 6TS 2013 11 - 29 13,247,000 1,305,000 14,552,000 6TS 2013 12 - 29 17,874,000 821,000 18,695,000 6TS 2014 1 - 29 21,212,000 (12,000) 21,200,000 6TS 2014 2 - 29 14,683,000 (4,264,000) 10,419,000 6TS 2014 3 - 29 16,969,000 1,610,000 18,579,000 6TS 2014 4 - 29 16,348,000 (654,000) 15,694,000 ISTS 2014 5 - 29 17,180,000 1,692,000 18,872,000 6TS 2014 6 - 29 18,643,000 1,074,000 19,717,000 6TS 2014 7 - 28 19,628,000 (1,942,000) 17,686,000 6TS 2014 8 - 28 22,257,000 3,715,000 25,972,000 ISTS 2014 9 - 27 18,728,000 (4,003,000) 14,725,000 6TS 2014 10 - 28 15,539,000 (703,000) 14,836,000 6TS 2014 11 - 27 10,818,000 1,382,000 12,200,000 6TS 2014 12 - 28 16,588,000 (864,000) 15,724,000

7 2013 5 501 - 496,000 (177,000) 319,000 7 2013 6 501 - 629,000 108,000 737,000 7 2013 7 499 - 892,000 76,000 968,000 7 2013 8 499 - 879,000 (6,000) 873,000 7 2013 9 497 - 736,000 (97,000) 639,000_ 7 2013 10 495 - 544,000 (57,000) 487,000 7 2013 11 491 - 509,000 110,000 619,000 7 2013 12 488 - 1,022,000 260,000 1,282,000 7 2014 1 482 - 1,380,000 99,000 1,479,000 7 2014 2 482 - 1,561,000 26,000 1,587,000 7 2014 3 481 - 1,257,000 (127,000) 1,130,000 7 2014 4 479 - 829,000 (249,000) 580,000 7 2014 5 478 - 495,000 (140,000) 355,000 7 2014 6 476 - 644,000 97,000 741,000 7 2014 7 474 - 839,000 11,000 850,000 7 2014 8 470 - 746,000 39,000 785,000 7 2014 9 469 - 753,000 (77,000) 676,000 7 2014 10 468

1

- 487,000 (102,000) 1 385,000 7 2014 11 466 - 1 449,000 138,000 587,000

-7 2014 12 466 - 1 -1,038,000 162,000 1,200,000

Environmental Respondents Exhibit No . Xttachment JM-L-5

Page I of 2

Virginin Electric gnd Power Conillany Case No. PUE-2014-00071

Environmental Resnondents Fi*rst Set

The following response to Question No. 20 of the First Set of Interrogatories and Requests for Production of Documents propounded by the Environmental Respondents received on December 12, 2014 has been prepared under my supervision.

Michael.T . Hubbard Manager, Energy Conservation Virginia Electric and Power Company

Question No. 20

Please provide the incentive structures for eligible participants for each of the Phase IV -Programs . Will the incentives for each of ft Phase IV Programs be identical for all eligible participants?

Response ;

The incentive structures will be finalized with the Company's selected implementation vendor(s) upon Program approval . However, based on information provided by the Company's program planning consultant, Attachment ER Set I - 20 provides an indication of the incentive le~vels for each Phase IV Program, as currently planned . Incentives may vary by participant based on the measures that each participant installs .

~A LM

DOM A514 0087

Environmental Respondents Exhibit No. Attachment Jl~-L-5

Page 2 of 2 Attachment ER Set 1-20

Program Measure Incentive Summary

E 2 CO 2 LED Lamp Installation Incentives will cover 100% of the installed costs of up to a. 6 LED lamps

Z W W Cf

Low Flow Showerhead (for Electric W/H) Incentives will cover 100% of the installed costs of up to two (2) showerheads

IM 4) C

Pipe Wrap Insulation (for Electric W/H) Incentives will cover 100% of the installed costs of up to C six (6) linear feet of pipe wrap insulation

a: IM .S

CY Faucet Aerators (for Electric W/H) Incentives will cover 100% of the installed costs of up to

4) two (2) faucet aerators E

Attic Insulation Incentives will cover 1 00% of the installed costs

C Appliance Recycling $50 per qualifying refrigerator or freezer CL

Direct Install Lighting Incentives will vary per project and will target 60-80% of

' >% the total project s eligible costs

C W Z E Z T C 0) 4) Prescriptive RCx Incentives Ml vary per project and will target 50% of

' -0 2 the total project s eligible costs CL

0 Z Prescriptive Non-Lighting (High Efficiency Unitary Incentives will target 50% of the incremental measure Heat Pumps, AC, and VFD) costs

E U)

0A I.M 0

CERTIFICATE OF SERVICE

1 hereby certify that the following have been served with a true and accurate copy of the foregoing via first-class mail, postage pre-paid :

Vishwa B. Link Lisa Crabtree McGuireWoods LLP One James Center 901 E. Cary Street Richmond, VA 23219

William H. Baxter, 11 Lisa S . Booth Dominion Resources Services, Inc . 120 Tredegar Street Richmond, VA 23219

K . Beth Clowers Office of the General Counsel State Corporation Commission P.O . Box 1197 Richmond, VA 23218

DATED: January 22,2015

C. Meade Browder, Jr. Kiva Bland Pierce William Reisinger C. Mitch Burton, Jr. Office of the Attorney General Division of Consumer Counsel 900 East Main Street, 2 nd Floor Richmond, VA 23219

Edward L. Petrini James G. Ritter Christian & Barton LLP 909 E. Main Street, Suite 1200 Richmond, VA 23219

Angela Navarro, SouthA Environmental Law Center