Take a look at the proposed rule changes!
When the Energy Efficiency rules were reinstated at the June 26th Louisiana Public Service Commission monthly meeting, Comm. Scott Angelle raised several potential modifications to the existing rules and asked that the public be given one final opportunity for input prior to implementation. Commission staff have subsequently issued recommended rule changes that address some, though not all, of the suggestions made by Comm. Angelle. As an intervenor in this docket, the Alliance will be submitting formal comments addressing the proposed changes point-by-point. While we prepare our submission, we are inviting our members to share your thoughts, recommendations, and concerns by posting your comments on this blog. With the comment submission deadline just around the corner, your feedback will be most helpful by this Friday, July 12th.
Here is a summary of the proposed rule changes by LPSC staff:
(read full proposed rule changes at 2013 07 03 R31106 LPSC, ex parte. Notice of Proposed Modification To Energy Efficiency Rules and Request for Specific Comments (2) )
1. Energy efficiency programs will be optional for the Utilities because of a one word change in the revised rules. This is very concerning and by far the most surprising change to the proposed rules. There was no mention of this at the June meeting; not one Commissioner directed the staff to make this change. Where the original language began with a directive to utilities, stating that the Energy Efficiency Rules “shall” be used, the revised language instead says “may” – thereby giving the utilities discretion to ignore the rules entirely and thus excluding their customers from the benefits of efficiency enjoyed by the rest of the state. This change is bad for the public and represents another absolutely unnecessary step backward for Louisiana – one that directly harms customers while protecting utility profits.
2. Administrative costs will be capped and the cost effectiveness test has been made more explicit. The changes include in the new proposed rules indicate that “administration and planning, promotion and advertising” for efficiency programs would be capped at 15%. Additionally, only efficiency measures that have a TRC cost effectiveness score greater than 1.0 would be allowed – which ensures that efficiency program investments are guaranteed to reduce bills for all customers, regardless of whether or not they participate in the efficiency programs themselves.
3. Program costs per customer would be capped at $75; a change that benefits only a small segment of customers whose energy use exceeds $15,000 per month. The cost of the efficiency programs are less than 0.5% of a typical bill and it is the customers who use the most energy that stand to gain the most from the new efficiency programs (whether they choose to participate or not). If the intent of this rule change was to help small and medium sized Louisiana businesses, this approach undeniably has the opposite affect. With this change, small businesses are carrying their fair share, while big companies reap the most benefits and pay the least share. This is not how power plants are paid for and should not be used for efficiency programs.
4. Incentives would be available retroactively for customers that installed eligible efficiency measures in the preceding 24 months with proper documentation.
Some of the specific topics Comm. Angelle asked staff to address that were not covered in the proposed modifications include:
Important progress is once again being made on the energy efficiency rules, but as you can see the struggle is not yet over. After a process that has already dragged on for four years, it is time to finalize the rulemaking and move ahead with implementation. If you have feedback or suggestions that you would like to share with us in advance of our comment filing deadline, please let us know by this Friday, July 12th. Thank you for your ongoing support of energy efficiency in Louisiana!
Read the proposed rule changes here: 2013 07 03 R31106 LPSC, ex parte. Notice of Proposed Modification To Energy Efficiency Rules and Request for Specific Comments (2)