LIOB 11/21/03
Excerpt From: Low-Income Energy Efficiency Standardization Project: Phase 4
Report on Naural Gas Appliance Testing Study Results1
Applicability to Combustion Fuels other than IOU Natural Gas
There are two key questions relating to the applicability of combustion appliance
assessments. The first question relates to the fuel used by the appliances in question: Should
assessments be done only on natural gas appliances using IOU natural gas, or on all
combustion appliances (e.g., propane and wood)? The Standardization Team considered four
program options in this regard:
1

First, assessments could be restricted to IOU natural gas appliances, but infiltration
reduction measures could still be installed in homes with other combustion
appliances. This option was rejected because it would violate one of the rationales
for conducting appliance tests, namely the potential for affecting ambient CO
levels through weatherization.

Second, assessments could be conducted for other combustion appliances prior to
weatherization, and infiltration reduction measures could be deemed non-feasible
for homes with CO levels above some threshold (say, the ambient action level of
10 ppm). Under this option, homeowners and/or tenants would be advised when
appliances exceeded the threshold. This option would avoid the aggravation of
CO in homes with pre-weatherization readings that were above the threshold, but
would not provide a safeguard against the creation of CO problems through major
infiltration reductions. Further, this option would entail the expenditure of IOU
ratepayer funds for testing appliances that do not use IOU natural gas.

Third, assessments could be conducted for other combustion appliances prior to or
after weatherization, and appliances with CO related problems could be repaired or
replaced. This would provide the same level of service to these homes as for
homes with IOU natural gas, but would use IOU ratepayer funds for both
assessment and appliance repair and replacement.

Fourth, assessments could be restricted to IOU natural gas appliances, and LIEE
Program infiltration reduction measures could be deemed non-feasible for all
homes using other combustion fuels (e.g., kerosene or propane). This would avoid
situations in which major reductions in infiltration could affect ambient CO levels.
It is true that it would prohibit homes with other combustion appliances from
receiving a full range of LIEE measures, and that many of these homes (those in
IOU electric service areas) would be contributing to the funding of the LIEE
Program through their electricity bills.
Submitted jointly, on May 5, 2003, by Pacific Gas and Electric Company, San Diego Gas & Electric
Company, Southern California Edison Company and Southern California Gas Company.
3
The Standardization Team recommends that this fourth option be adopted by the
Commission. The Team also proposes that homes for which infiltration reduction measures
are deemed non-feasible under this provision be referred to the State’s Low Income Home
Energy Assistance Program (LIHEAP), or, in the case of homes with non-IOU natural gas
appliances, the relevant natural gas utility for full treatment. The Team also proposes to
request that LIHEAP contractors and non-IOU natural gas utilities report back to the
involved IOU to verify that service was provided.
PG&E concurs with the Standardization Team recommendation on natural gas appliance
testing in the interest of reaching a Team consensus. The Standardization Team recommends
that electricity customers should be deemed to be ineligible for infiltration reduction
weatherization measures, which would otherwise reduce the amount of electricity consumed
for heating and air conditioning, if they have a non-natural gas combustion appliance.
However, PG&E wishes to make it clear that implementation of this recommendation will
have an adverse effect on its ability to serve its rural customers.
PG&E contractors have set goals in all counties in an effort to reach equitable penetration
levels for both rural and urban customers. Rural and urban statistics are supplied quarterly in
the utilities’ Rapid Deployment Reports. PG&E’s service territory is large and
geographically diverse, and consequently PG&E serves many homes in rural communities
where natural gas is not available. For example, over fifty percent of PG&E’s customers in
Alpine, Amador, Calaveras, El Dorado, Lake, Lassen, Mariposa, Plumas, Sierra, Trinity and
Tuolumne Counties are on an electric heat rate. Many of these electric customers use
propane and other non-natural gas equipment. Based on its LIEE program field experience
in these counties over the last several years, PG&E estimates that approximately fifty percent
of these customers have propane or other non-natural gas appliances in addition to electric
heat. This totals over 20,000 low income rural PG&E customers in just these eleven counties
who would not be eligible for full program participation, but who are nevertheless included
in PG&E’s demographic estimate of customers who are eligible for the program.
Currently, PG&E performs CO tests on propane and other non-natural gas combustion
appliances in these customer homes that qualify for non-infiltration measures (i.e., that utilize
electric heat) so that these customers can receive all of the weatherization measures for which
they qualify. These appliances are not adjusted, repaired or replaced. If a CO-problem
associated with a non-natural gas appliance is identified, the customer is referred to their
supplier and receives only non-infiltration LIEE Program measures until the problem is
corrected.