Pacific Gas and Electric Company Retail Plug- Load Portfolio (RPP) Trial: Evaluation Report ET Project Number: ET13PGE8052
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Erik Jacobson Pacific Gas and Electric Company Director 77 Beale St. Regulatory Relations P.O. Box 770000 San Francisco, CA 94177 Fax: 415-973-7226 December 24, 2015 Advice 3668-G/4765-E (Pacific Gas and Electric Company ID U 39 M) Public Utilities Commission of the State of California Subject: Request For Authority for Retail Products Platform (RPP) Pilot within PG&E's Residential Energy Efficiency Plug-Load and Appliances Sub-Program Purpose Pacific Gas and Electric Company (PG&E) requests approval of a Retail Products Platform (RPP) pilot, a strategic market transformation effort designed to create long- lasting, sustainable changes in the functioning of product-specific markets by reducing barriers to the adoption of energy efficient plug-load and appliances. PG&E designed this pilot to conform to the guidance provided by two key whitepapers commissioned by the CPUC.1 This advice letter (AL) requests authority to conduct a four-year RPP pilot under the PG&E Residential Energy Efficiency (EE) Plug-Load and Appliances (PLA) sub-program using existing budget. PG&E anticipates the four-year pilot to transition into a ten-year subprogram. The proposed RPP pilot is part of a wider effort, the ENERGY STAR Retail Products Platform (ESRPP), undertaken in conjunction with program administrators (PAs)2 across the country and sponsored by the U.S. Environmental Protection Agency (EPA), to address plug load growth. The ESRPP makes it possible to gain the scale needed to attract national retailers to participate and effect market transformation in the consumer electronics and appliance markets. The effort will benefit California rate payers by curtailing the growth of plug load within the state. In the long-term, the RPP design is 1 Keating, Ken (2014): Guidance on Designing and Implementing Energy Efficiency Market Transformation Initiatives. Prahl, Ralph and Keating, Ken (2014): Guidance on Designing and Implementing Energy Efficiency Market Transformation Initiatives. 2 Program Administrators interested in participating in the ENERGY STAR Retail Products Platform include Pacific Gas and Electric Company, Southern California Edison, Southern California Gas Company, San Diego Gas & Electric Company, Sacramento Municipal Utility District, Xcel Energy, Eversource Connecticut, UIL Holdings, DC Sustainable Energy Utility, Northwest Energy Efficiency Alliance, Baltimore Gas and Electric Company, Southern Maryland Electric Cooperative, Pepco, DTE Energy, Con Ed, Efficiency Vermont and Focus on Energy. Advice 3668-G/4765-E - 2 - December 24, 2015 expected to increase the cost effectiveness of the EE PLA portfolio for selected product categories where sales can be influenced significantly by retailer decisions regarding the merchandise they stock and promote. The success of ESRPP depends upon simultaneous engagement by multiple PAs in multiple states representing a significant retail customer base. PG&E’s participation at program launch, slated for March 1, 2016, is critical to demonstrate the potential for a multi-state effort to address plug-loads. Therefore, PG&E is seeking expedited approval for this pilot in order to launch March 1, 2016. The four-year pilot period is proposed as it is a sufficient period to evaluate market impacts to determine if the RPP should be extended for a longer timeframe. Evaluation of the pilot will occur on a yearly basis to mitigate risk. PG&E proposes to claim ex ante savings for those RPP measures approved by the Energy Division’s ex ante review team in the RPP workpaper at the time of the RPP pilot launch, March 1, 2016. PG&E is in the process of responding to requests for further information contained in the RPP workpaper disposition and is revising the workpaper.3 For any RPP measures not approved for ex-ante savings by the time of pilot launch, PG&E requests authority to include these measures as part of the pilot, and claim savings subject to an ex post evaluation, or ex-ante starting at the point any additional measures are approved. PG&E requests that all RPP measures be added to the deemed “Uncertain Measure List,” so that all ex ante values will be verified on an annual basis. Background Savings Potential and Challenges for the Plug Load and Appliance Markets One of the goals of the California Long-term Energy Efficiency Strategic Plan is to “develop comprehensive, innovative initiatives to reverse the growth of plug load energy consumption” in California4. The RPP pilot will help meet this challenge. The pilot design includes working collaboratively with utilities across the U.S. to address plug load growth in the residential sector nationally. The U.S. Department of Energy’s Energy Information Administration (DOE/EIA) estimated that “other” or “miscellaneous plug load” electricity consumption, when combined with consumption by televisions and office equipment, will represent 29% of U.S. residential annual electricity consumption in 2006 and will grow to approximately 36% in 2020. DOE/EIA forecasted that the “plug load” annual consumption will increase by 31% over the same period, on a per household basis (DOE Study, 2008). 3 See PGECOAPP128r0_RetailProductsPlatform_15Dec2015. The disposition calls for PG&E to propose research for estimating baseline energy use and usage profiles for room air cleaners and soundbars, and baseline assumptions for clothes dryers. In a follow-on conversation with the Energy Division ex ante review team on December 22, 2015, additional documentation was requested to support the use of incentives for measures with zero incremental cost. 4 California Energy Efficinecy Strategic Plan, January 2011 Update, Section 2, page 21 Advice 3668-G/4765-E - 3 - December 24, 2015 Because plug loads represent a significant proportion of residential electricity consumption, reducing plug load energy consumption is a critical step to achieve California’s residential Zero Net Energy (ZNE) goals. The 2012 ZNE Technical Feasibility Report stated that “minimizing plug loads will be critical to meeting ZNE goals”5, and recommended that utilities “continue equipment efficiency incentive programs” and “aggressively promote equipment efficiency regulations at the state and federal level6.” RPP addresses specific opportunities and challenges at the national, state and programmatic level. Energy savings opportunities in many plug load categories cannot be addressed effectively by traditional downstream rebate programs. First, the energy savings per unit are relatively small, though energy savings across the entire category can be significant. Hence, the incentive per unit will typically be relatively small. Second, new plug-load products are introduced on a rapid development basis, requiring quicker and more nimble intervention strategies to address new products. Third, due to modest per-unit energy savings, typical downstream incentives increasingly are not cost effective and therefore are not offered for most appliances. Fourth, downstream incentives for appliances and electronics can be time consuming and confusing for end- use customers, and the redemption processes can present a barrier to purchasing energy efficient appliances.7 Since the costs of the RPP pilot are front-loaded, PG&E forecasts costs will decline over time while energy savings will grow over time. Consequently, cost effectiveness of the longer-term market transformation effort is forecast to improve over time. Using the ED- approved net-to-gross ratios8, the cumulative TRC for the four-year pilot is estimated by the E3 Calculator to be 0.57. Assuming that the program runs for ten years, the cumulative TRC is estimated to reach 1.75. This difference between the estimated shorter- and longer-term TRCs is consistent with the principles that underlie market transformation programs: the TRC is based on the cumulative lifecycle benefits and the cumulative program costs over the life of the program. The pilot’s TRC and other key measure parameters will be re-estimated using the most recent data on a yearly basis. RPP Pilot Program Model Theory and Rationale A detailed RPP Pilot Program Theory and Logic Model is provided in Appendix A, attached. In short, the RPP model focuses on a portfolio of consumer energy efficient products with relatively small incentives paid to the retailer for each unit sold. This 5 The Technical Feasibility of Zero Net Energy Buildings in California, Final Report | December 31, 2012 | Arup North America Ltd, page 8 6 IBID, page 51 7 “End of Perspective Rebate Forms? Massachusetts Moves Upstream,” Rishi Sondhi and Nathan Strong, Northeast Utilities and Gabe Arnold, Optimal Energy. 2014 ACEEE Summer Study on Energy Efficiency in Buildings. 8 See WORKPAPER DISPOSITION FOR PGECOAPP128 Revision 0 Retail Products Platform California Public Utilities Commission, Energy Division December 15, 2015 Advice 3668-G/4765-E - 4 - December 24, 2015 model is intended to incentivize retailers to participate by reducing market barriers to stocking and selling more energy efficient electronics and appliances and to mitigate the significant costs associated with changing appliance product mixes in stores, providing more sales floor space for energy efficient models, revising marketing to reflect new energy efficient electronics and appliances, updating pricing strategies and training staff to sell the most efficient models. The retail channel is ideally suited to reduce plug load by transforming the consumer electronics and appliances markets and leveraging the influential ENERGY STAR brand. The RPP logic model theorizes