This document serves as the Department of Public Service comments on the "Eligible
Services and Initiatives" included in Section VI.1.B.f of the Draft Recommendation for a
New Energy Efficiency Utility Structure. It provides comment only on whether eligible
services should be included in a cost-of-service compensation mechanism. The
appropriate time for comments on a specific form of compensation mechanism will be
after one is further developed.
The “Eligible Services” envisioned in the Draft Recommendation are listed below in bold
font, followed by Department remarks.
(i)
Technical assistance and educational support for energy code activities as
further described in Part I section O.
This area is currently described in Part I.2.J. The Department supports inclusion of these
services.
(ii)
Contribution and support to DPS potential studies, forecasts and plans as
further described in Part I section H.
The Department supports inclusion of any material costs related to services in support of
DPS potential studies, forecasts, and plans in a cost-of-service compensation mechanism.
(iii)
Support for DPS Evaluation activities as further described in Part II section
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These services are described in Part II Section 9. Specific evaluation activities are
outlined in the Draft Recommendation; comments below are to those activities for which
the EEU is designated as responsible:
Measure Savings Characterization – The Department would support inclusion of
these services.
Market Characterization Baseline Studies – DPS market characterizations provide
a basis for program planning; the DPS consults and coordinates with the EEU in
conducting this work. These market characterizations support program
development and planning to reach long-range resource acquisition targets. It is
in the best interests of the EEU(s) to support this work to inform incentive levels
and program design. The Department would support the inclusion of material
costs incurred by the EEU in relation to these baseline studies in a cost-of-service
compensation mechanism.
Part II, Section 9B notes that additional market characterization work can be
carried out as an EEU deems necessary to plan services and initiatives. This work
would be in addition to DPS evaluations and will specifically inform program
design and implementation – resource acquisition. The Department does not
support inclusion of additional market characterization work as an eligible service
for cost-of-service compensation.
Implementation Tracking
Measurement, Including Metering
The Department would support these two services inclusion in cost-of-service
based compensation at this time.
Process Evaluation
The Department would not support this services inclusion. Process evaluation
evaluates the design and implementation of EEU operations. This is an internal
mechanism that leads to greater effectiveness in resource acquisition.
Additionally, the DPS reserves the right to complete an independent process
evaluation with reasonable support from an EEU.
(iv)
DUP and transmission planning activities as further described in Part I
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Generally, the Department supports inclusion of these services at this time. Enhancing
capabilities to allow for end-use forecasting, participation in the VSPC, and development
of databases to support DUP and transmission planning activities is an important aspect
of the EEU and does not relate well to resource acquisition targets. However, the
Department feels that costs for specific Non-Transmission Alternative (NTA) analysis
should be supported by the affected utility or utilities on a case by case basis, and not be
included in cost-of-service type of compensation. A cost allocation mechanism could be
developed in a number of different ways in order to determine each Party’s obligation for
the cost of a NTA analysis.
(v)
VSPC participation as further described in Part I section 1.GError! Reference
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Costs of general participation in the VSPC should be allowed as an “eligible service.”
Similar to DUP and transmission planning, significant efforts regarding provision of
some efficiency services may need to fall under a cost-allocation mechanism separate
from cost-of-service or resource acquisition compensation.
(vi)
ISO-NE Forward Capacity Market participation as further described in Part
I section 1.I.
The Department does not support ISO-NE Forward Capacity Market participation as an
eligible service at this time. Costs of participation can and should be compensated
through revenues received as a result of participation.
(vii)
Applied R&D activities as further described in Part I section 1.N.
(viii) Training and workforce development activities as further described in Part I
section 1.P.
The Department at this time supports inclusion of the activities listed directly above in
(vii), (viii).
(ix)
Energy education activities as further described in section 1.O.
Energy Education in Schools and Colleges is discussed in section 1.Q. The Department
supports inclusion of section 1.Q as an “Eligible Service.” Provision (ix) refers to section
1.O, which along with education includes marketing and consumer information strategies
to “promote customer participation in and market awareness of EEU services and
initiatives….” The Department feels these particular services should fall under resource
acquisition compensation.