CAPHCC Action Alert – Your Comments Needed

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Administrative Law Judge (ALJ) Kao has issued a ruling in the consolidated Energy Efficiency (EE) Business Plan and Portfolio Plan application proceeding, presenting Energy Division’s staff proposal for party comment regarding a phased transition to provide fewer ratepayer-funded incentives for gas EE measures.  The ruling also seeks party comments on modifications to the Codes and Standards Advocacy programs as well as budget considerations for other Codes and Standards sub-programs.  A copy of the ruling and staff proposal are attached.

  1. 03 A.22-02-005_ALJ Ruling on Gas EE Incentives Staff Proposal and CS Programs
  2. 04 A.22-02-005_EE Natural Gas Incentive Staff Proposal

Next Steps

Party comments are due August 26.  Reply comments are due September 5.

As YOUR VOICE for the plumbing-heating-cooling industry, The PHCC of California (CAPHCC) has filed a motion for party status in order to provide comment on behalf of CAPHCC members.  Therefore, we need YOUR COMMENTS on the above ruling and proposals provided to our office no later than August 24, 2022.


In response to Sierra Club’s motion in the EE proceeding (R.13-11-005) to cease funding non-cost effective natural gas appliances, Energy Division developed the “Natural Gas Incentive Phase Out Staff Proposal” which recommends an orderly phase out of ratepayer-funded EE incentives for most natural gas measures over the next 10 years (non-cost effective and/or non-exempt gas measures without a viable electric alternative).  Included as part of the proposal are separately proposed timelines for phase out and policies for new construction, retrofits, and custom projects.  The ruling presents specific questions regarding the staff proposal for party comment.  The ruling also invites parties to comment on whether and how Codes and Standards Advocacy programs should be modified given the increased focus on decarbonization, and on related budget considerations for other Codes and Standards sub-programs.

The following questions for party comment were included in the ruling:

Staff proposal for Gas Energy Efficiency Incentives

  1. Are there additional criteria that should be taken into account in the staff proposal?
    1. Is the existing criteria cited in Section 2.4.1 of the staff proposal sufficient to justify using energy efficiency ratepayer funds collected from natural gas utility customers for electric energy efficiency measures?
    2. What other information should be taken into account in supporting the claim that there are adverse public health impacts from natural gas appliances (Section 2.4.2 of staff proposal)?
  2. How should “viable electric alternative” be defined?
    1. How should infrastructure costs, such as electric panel upgrades, be included in determining what constitutes a viable electric alternative?
    2. What would be the fastest and most accurate way to gather accurate data on infrastructure costs for electrification measures statewide?
  3. How should “exempt measures” be defined?
  4. Do you agree with the proposed steps and associated timeframes included in the staff proposal? If not, what should the transition timeline away from natural gas energy efficiency incentives be?
  5. Which assessment metric (total resource cost, total system benefit, others) should be used to assess cost effectiveness in the relevant steps in this proposal in determining the eligibility of gas measures for receiving incentives?
  6. Do gas appliances serve a market support and/or equity function given the state’s goals and progress towards electrification?
  7. What are the other options for uses of the gas incentives that staff proposes to phase out?
    1. Decrease gas energy efficiency collections?
    2. Use for other measures?
    3. Provide to gas ratepayers for fuel substitution?
    4. Use the gas incentives for electric measures? If you recommend this option, explain any legal implications.
  8. What other options should the Commission examine for promoting electrification through the staff proposal, beyond redirecting incentives from gas measures?
  9. Custom Projects
    1. How should the CPUC determine what aspects of custom projects are feasible for electrification? Is it more appropriate to make this determination at a more overarching equipment/process level (i.e., instead of on a case-by-case basis)?
    2. What should the difference in incentives between gas and electric custom measures be? Over what duration should that difference be phased in?
    3. What more can be done to encourage electrification and decarbonization in custom projects?
  10. How does the transition and timeline to phase out energy efficiency gas incentives align with other related proceedings?
  11. How does the transition to phase out energy efficiency gas incentives align with the nine objectives of the CPUC’s Environmental and Social Justice Action Plan?
  12. How does the transition to phase out energy efficiency gas incentives align with the vision and benefits of the CPUC’s Distributed Energy Action Plan?
  13. Are there any legal implications of phasing out energy efficiency gas incentives?

Codes and Standards Sub-programs and Budgets

  1. Describe how the Codes and Standards Advocacy programs should expand their scope to address additional clean energy goals, such as transportation electrification and decarbonization.
  2. The Codes and Standards program consists of additional sub-programs that do not claim savings, such as Planning and Coordination, Code Readiness, and Reach Codes. The budgets for these ‘non-resource’ sub-programs have increased over the years, while the advocacy portion has remained more consistent. Should the non-resource Codes and Standards sub-program budgets increase commensurate with increases in the advocacy budget, or vice versa? Should the non-resource Codes and Standards budgets be limited to a maximum percentage of a program administrator’s portfolio budget, or in some other way?
  3. For non-resource Codes and Standards sub-programs, describe what milestones or minimum performance requirements should be met in order to increase or substantiate the proposed budget allocations.