Exhibits for Testimony of Natalie A. Mims May 10, 2013 Docket Nos & 36499

Transcription

1 Exhibits for Testimony of Natalie A. Mims May 10, 2013 Docket Nos & Exhibit No. Description SACE-NAM-1 Resume of Natalie A. Mims SACE-NAM-2 Enhanced DSM Portfolio SACE-NAM-3 DSM Working Group Minutes (Dec. 7, 2011) SACE-NAM-4 Letter to Georgia Power and Commission Staff from Several DSM Working Group Members (May 25, 2012) SACE-NAM-5 Memorandum from Synapse Energy Economics, Inc. to SACE re: Georgia Power DSM Program Participants Analysis SACE-NAM-6 Summary of North Carolina Annual DSM/Energy Efficiency Cost Recovery Filing Requirements (NCUC Rule R8-69(f)(1)) SACE-NAM-7 National Performance Incentive Comparison SACE-NAM-8 Flexibility Guidelines Reference Documentation for Duke Energy Carolinas, LLC

2 Exhibit SACE-NAM-1 NATALIE A. MIMS P.O. Box Knoxville, TN RELEVANT WORK EXPERIENCE SOUTHERN ALLIANCE FOR CLEAN ENERGY Energy Efficiency Director, January current Earlier position: Energy Policy Manager, October 2010 December 2012 Responsible for ongoing energy efficiency portfolio and program level quantitative and qualitative research and analysis of major utilities in the Southeast Track and participate in energy efficiency regulatory proceedings Current regulatory proceedings include IRP, cost-recovery filings, energy efficiency program pilots and existing program modifications Responsible for reviewing and writing comments for all major energy efficiency regulatory proceedings for utilities in Tennessee, North and South Carolina, Georgia and Florida Lead participant for SACE at TVA, Duke Energy and Georgia Power DSM working groups ROCKY MOUNTAIN INSTITUTE Senior Consultant, July 2009 October 2010 Earlier positions: Intern, Fellow, Analyst, and Consultant October July 2009 Project manager for nine-person team creating energy efficiency component of national energy analysis Project manager for company-wide energy efficiency strategy and development Lead on energy efficiency analysis for major southeastern IOU low-carbon strategy Lead author on published national analysis on electric productivity Member of senior leadership of Energy and Resources Team at the organization. Contributed to team strategy, resource planning and staffing for person team and hiring as well as organizational professional development strategy Contributed to writing Hawaii Energy Strategy 2007 and planning Hawaii Biofuels Summit Contributed to RMI filings in Energy Efficiency docket before Hawaii Public Utility Commission Participated in Hawaii Energy Policy Forum Energy Efficiency working group Significant contributor to consulting and research projects including: national and state energy policies, utility revenue adjustment mechanisms, utility regulatory structures, private sector investment in energy efficiency, corporate carbon management strategy, renewable energy market assessments, large and small scale sustainable development projects, Hawaii agricultural sustainability barriers and solutions PUBLICATIONS Legislative Options to Improve Transportation Efficiency. November 2005, RMI. Feebates: A Legislative Option to Encourage Continuous Improvements to Automobile Efficiency. February 2008, RMI. Plug-In Hybrid Electric Vehicles and Environmentally Beneficial Load Building: Implications on California s Revenue Adjustment Mechanism, Presented at Association of Energy Service Professionals Conference, January Industrial Electric Productivity: Myths, Barriers, & Solutions. Presented at ACEEE Industrial Summer Study, July Assessing the Electric Productivity Gap and the U.S. Efficiency Opportunity. Presented at IEPEC, August MASTER OF ENVIRONMENTAL LAW & POLICY Vermont Law School, South Royalton, Vermont EDUCATION

3 Exhibit SACE-NAM-1 August 2004 Relevant coursework includes: Environmental Justice, Environmental Law, Land Use, Water Law, Federal Natural Resource Law, Comparative Methods of Dispute Resolution, Environmental Law Principles, Extinction: The Endangered Species Act, Legal Research & Writing, Ecology Activities: Solutions Conference 2004 B.A. ENGLISH & B.A POLITICAL SCIENCE The Pennsylvania State University, State College, Pennsylvania May 2002 Honors: Blue & White Scholarship; Dean s List five semesters; National Collegiate Honor Scholar Relevant coursework includes: Economics, Social & Developmental Psychology Activities: Shaver s Creek Outdoor School Camp Counselor, May 2001

4 Exhibit SACE- NAM- 2 Dockets No and DSM Portfolio RePlanner Enhanced DSM Portfolio Summary Data Enhanced DSM Portfolio Incremental Energy Savings (MWh) Residential Programs RES Behavioral Redacted Redacted Low Income Redacted Redacted Codes and Stds Redacted Redacted HVAC Service Redacted Redacted RES New Home Redacted Redacted RES HEIP Redacted Redacted Refrig Recyc Redacted Redacted RES Appliances Redacted Redacted RES Lighting Redacted Redacted Residential Subtotal Redacted Redacted Commercial Programs Small Commercial Redacted Redacted COM New Construction Redacted Redacted Com RCx Redacted Redacted COM Prescriptive Redacted Redacted COM Custom Redacted Redacted Commercial Subtotal Redacted Redacted Industrial Programs IND Custom Redacted Redacted Industrial Subtotal Redacted Redacted Total Redacted Redacted Public Disclosure Page 1

5 Exhibit SACE- NAM- 2 Dockets No and DSM Portfolio RePlanner Enhanced DSM Portfolio Summary Data Public Disclosure Page 2

6 Exhibit SACE- NAM- 2 Dockets No and DSM Portfolio RePlanner Enhanced DSM Portfolio Summary Data Total Cost Residential Programs RES Behavioral 715,010 1,632,458 2,607,356 3,864,186 5,385,631 5,685,720 Low Income 1,835,406 3,772,074 5,701,850 7,812,928 10,036,170 10,115,535 Codes and Stds 72, , , , , ,496 HVAC Service 550,566 1,513,478 2,619,313 3,842,710 5,120,736 5,165,970 RES New Home 2,744,553 3,936,610 4,626,213 5,370,290 6,084,599 6,011,612 RES HEIP 10,539,059 21,025,818 32,107,133 42,991,418 53,566,627 54,722,146 Refrig Recyc 5,303,844 6,046,155 6,706,254 7,275,221 7,797,039 7,967,708 RES Appliances 3,465,114 6,503,765 9,894,870 13,611,842 17,196,277 17,806,591 RES Lighting 1,120,159 1,557,590 1,835,069 2,245,125 2,752,492 2,648,717 Residential Subtotal 26,346,079 46,129,698 66,351,397 87,451, ,474, ,686,495 Commercial Programs Small Commercial 3,465,223 5,116,529 5,988,813 6,884,487 7,702,560 7,601,866 COM New Construction 1,055,022 3,058,882 5,187,567 7,631,871 10,317,093 10,193,823 Com RCx 1,521,795 4,342,253 7,482,568 10,999,219 14,649,963 14,636,671 COM Prescriptive 5,144,630 10,701,021 16,613,758 22,706,396 28,819,702 29,305,636 COM Custom 39,657,859 48,346,232 54,922,490 60,493,751 65,486,755 66,702,236 Commercial Subtotal 50,844,529 71,564,917 90,195, ,715, ,976, ,440,231 Industrial Programs IND Custom 3,866,640 10,645,784 18,176,356 26,362,905 35,120,096 35,247,952 Industrial Subtotal 3,866,640 10,645,784 18,176,356 26,362,905 35,120,096 35,247,952 Total 81,057, ,340, ,722, ,530, ,570, ,374,678 Cost of Saved Energy ($/kwh) Residential Redacted Redacted Commercial Redacted Redacted Industrial Redacted Redacted Total Redacted Redacted Public Disclosure Page 3

7 Exhibit SACE- NAM- 2 Dockets No and DSM Portfolio RePlanner Enhanced DSM Portfolio Summary Data Public Disclosure 6,219,180 6,827,899 7,166,879 7,753,194 10,396,211 10,684,313 10,770,788 11,070, , , , ,827 5,348,864 5,568,335 5,572,271 5,750,858 6,238,576 6,545,818 6,422,232 6,645,475 56,116,331 57,592,969 58,312,586 59,603,558 8,128,742 8,287,947 8,448,373 8,611,213 18,468,335 19,107,665 19,279,404 19,787,833 2,747,091 2,932,765 2,819,009 2,921, ,306, ,206, ,398, ,763,235 7,897,746 8,299,252 8,125,661 8,414,127 10,559,645 11,140,253 10,916,724 11,270,028 15,142,518 15,741,688 15,589,494 16,072,529 30,174,846 31,173,192 31,434,143 32,263,553 68,366,868 70,251,273 71,240,228 72,899, ,141, ,605, ,306, ,919,802 36,211,722 37,730,593 37,565,084 38,472,228 36,211,722 37,730,593 37,565,084 38,472, ,660, ,542, ,269, ,155, Page 4

8 Exhibit SACE- NAM- 2 Dockets No and DSM Portfolio RePlanner Enhanced DSM Portfolio Summary Data Program Costs (Admin/Mgmt/Eval) Residential Programs RES Behavioral 715,010 1,632,458 2,607,356 3,864,186 5,385,631 5,685,720 Low Income 545,086 1,142,402 1,682,396 2,351,830 3,080,096 3,027,296 Codes and Stds 64, , , , , ,213 HVAC Service 293, ,632 1,295,790 1,914,764 2,597,593 2,568,582 RES New Home 1,295,542 1,722,234 1,789,784 2,081,426 2,442,264 2,262,101 RES HEIP 1,322,973 2,521,349 3,456,863 4,675,178 6,072,603 5,852,302 Refrig Recyc 4,270,298 4,871,832 5,406,275 5,866,348 6,287,894 6,426,031 RES Appliances 2,169,731 3,997,138 5,912,704 8,101,786 10,268,742 10,525,770 RES Lighting 395, , , ,469 1,031, ,028 Residential Subtotal 11,072,775 17,365,457 22,933,780 29,905,276 37,454,672 37,533,043 Commercial Programs Small Commercial 897,292 1,282,414 1,178,994 1,411,408 1,743,802 1,467,770 COM New Construction 308, ,477 1,341,686 2,029,664 2,985,367 2,646,358 Com RCx 367,766 1,045,525 1,536,783 2,338,130 3,315,013 2,968,187 COM Prescriptive 1,782,091 3,491,807 5,052,422 6,914,638 8,976,700 8,878,748 COM Custom 9,271,636 11,719,818 13,119,561 14,665,737 16,268,044 16,308,953 Commercial Subtotal 12,627,352 18,466,041 22,229,445 27,359,576 33,288,926 32,270,016 Industrial Programs IND Custom 1,233,381 3,123,324 4,609,288 6,600,066 9,256,054 8,622,853 Industrial Subtotal 1,233,381 3,123,324 4,609,288 6,600,066 9,256,054 8,622,853 Total 24,933,508 38,954,822 49,772,513 63,864,918 79,999,652 78,425,911 Incentive Cost Commercial Programs RES Behavioral Low Income 1,290,320 2,629,672 4,019,454 5,461,098 6,956,074 7,088,239 Codes and Stds 7,561 32,598 86, , , ,283 HVAC Service 256, ,847 1,323,523 1,927,946 2,523,143 2,597,388 RES New Home 1,449,011 2,214,376 2,836,430 3,288,864 3,642,335 3,749,511 RES HEIP 9,216,086 18,504,469 28,650,270 38,316,240 47,494,024 48,869,844 Refrig Recyc 1,033,546 1,174,323 1,299,978 1,408,874 1,509,145 1,541,678 RES Appliances 1,295,383 2,506,627 3,982,167 5,510,057 6,927,535 7,280,821 RES Lighting 724, ,328 1,219,292 1,469,656 1,721,369 1,757,690 Residential Subtotal 15,273,304 28,764,241 43,417,617 57,546,692 71,019,445 73,153,452 Commercial Programs Small Commercial 2,567,931 3,834,115 4,809,819 5,473,079 5,958,758 6,134,096 COM New Construction 746,455 2,132,405 3,845,881 5,602,207 7,331,726 7,547,465 Com RCx 1,154,029 3,296,728 5,945,785 8,661,089 11,334,950 11,668,484 COM Prescriptive 3,362,539 7,209,215 11,561,337 15,791,758 19,843,002 20,426,888 COM Custom 30,386,223 36,626,414 41,802,930 45,828,014 49,218,711 50,393,283 Commercial Subtotal 38,217,176 53,098,876 67,965,752 81,356,148 93,687,147 96,170,215 Industrial Programs IND Custom 2,633,259 7,522,460 13,567,069 19,762,838 25,864,042 26,625,099 Industrial Subtotal 2,633,259 7,522,460 13,567,069 19,762,838 25,864,042 26,625,099 Public Disclosure Page 5

9 Exhibit SACE- NAM- 2 Dockets No and DSM Portfolio RePlanner Enhanced DSM Portfolio Summary Data Public Disclosure 6,219,180 6,827,899 7,166,879 7,753,194 3,173,295 3,324,162 3,270,794 3,427, , , , ,219 2,692,117 2,857,336 2,808,346 2,933,887 2,403,375 2,632,301 2,432,312 2,578,979 6,139,751 6,596,955 6,324,774 6,616,493 6,556,304 6,685,079 6,814,843 6,946,568 10,958,721 11,420,316 11,432,693 11,787, ,626 1,105, ,062 1,024,516 39,460,147 41,819,445 41,519,007 43,385,748 1,623,463 1,896,847 1,598,263 1,761,453 2,839,693 3,262,659 2,885,337 3,084,500 3,207,367 3,562,819 3,172,859 3,417,589 9,281,129 9,852,822 9,697,540 10,109,772 16,925,010 17,797,679 17,777,115 18,415,815 33,876,662 36,372,826 35,131,114 36,789,129 8,978,142 9,940,899 9,232,857 9,596,239 8,978,142 9,940,899 9,232,857 9,596,239 82,314,951 88,133,170 85,882,978 89,771, ,222,916 7,360,151 7,499,994 7,642, , , , ,609 2,656,748 2,710,999 2,763,925 2,816,971 3,835,201 3,913,517 3,989,919 4,066,496 49,976,580 50,996,014 51,987,812 52,987,066 1,572,438 1,602,868 1,633,530 1,664,645 7,509,614 7,687,349 7,846,711 8,000,809 1,792,466 1,827,039 1,861,946 1,897,398 74,846,735 76,386,927 77,879,416 79,377,487 6,274,283 6,402,405 6,527,398 6,652,674 7,719,952 7,877,594 8,031,387 8,185,528 11,935,151 12,178,869 12,416,635 12,654,940 20,893,717 21,320,370 21,736,604 22,153,781 51,441,858 52,453,594 53,463,113 54,483,751 98,264, ,232, ,175, ,130,673 27,233,579 27,789,694 28,332,227 28,875,989 27,233,579 27,789,694 28,332,227 28,875,989 Page 6

10 Exhibit SACE- NAM- 2 Dockets No and DSM Portfolio RePlanner Enhanced DSM Portfolio Summary Data Public Disclosure Total 56,123,739 89,385, ,950, ,665, ,570, ,948,767 Page 7

11 Exhibit SACE- NAM- 2 Dockets No and DSM Portfolio RePlanner Enhanced DSM Portfolio Summary Data Public Disclosure 200,345, ,409, ,386, ,384,149 Page 8

12 Exhibit SACE- NAM- 2 Dockets No and DSM Portfolio RePlanner Enhanced DSM Portfolio Summary Data Enhanced Portfolio Cumulative Savings (MWh) Residential Programs RES Behavioral Redacted Redacted Low Income Redacted Redacted Codes and Stds Redacted Redacted HVAC Service Redacted Redacted RES New Home Redacted Redacted RES HEIP Redacted Redacted Refrig Recyc Redacted Redacted RES Appliances Redacted Redacted RES Lighting Redacted Redacted Residential Subtotal Redacted Redacted Commercial Programs Small Commercial Redacted Redacted COM New Construction Redacted Redacted Com RCx Redacted Redacted COM Prescriptive Redacted Redacted COM Custom Redacted Redacted Commercial Subtotal Redacted Redacted Industrial Programs IND Custom Redacted Redacted Industrial Subtotal Redacted Redacted Total Redacted Redacted Public Disclosure Page 9

13 Exhibit SACE- NAM- 2 Dockets No and DSM Portfolio RePlanner Enhanced DSM Portfolio Summary Data Public Disclosure Page 10

14 EXHIBIT SACE-NAM-3 DSM Working Group Meeting Minutes (Dec. 7, 2011)

15 Demand Side Management Working Group (DSMWG) Meeting Minutes December 7, 2011 If you have any clarifying comments to submit on the meeting minutes, please them by December 22, 2011 to both contacts listed below: Shemetha Jones of GPSC (sjones@psc.state.ga.us) Jamie Barber of GPSC (jamieb@psc.state.ga.us) Please be sure to reference the page and line number that you are submitting a comment on. All comments will be ed to all attendees on Tuesday, January 3 rd. COMMENTS: In the Action Item(s) section of the notes, any names in blue indicate the individual/group who requested the specified information and any names in red indicate the individual/group that is responsible for completing the action item. For any comments and/or request for additional information regarding the meeting minutes or DSMWG, please contact Shemetha Jones or Jamie Barber of the Georgia Public Service Commission at the addresses listed above. Shemetha Jones can be reached by phone at (404) , and Jamie Barber can be reached at (404)

16 ATTENDEES GEFA: Kris Anderson Georgia Watch: Clare McGuire Georgia Watch: Hale Powell GPC: Dave Ball GPC: Dean Harless GPC: Angela Strickland GPC: Larry Legg GPC: Neil Pickard GPC: Jeff Smith GPC: Bret Giles GPC: Tony Castro GPC: Audrey Gies GPC: Eddie Kelly GPC/Troutman Sanders: Drew Woolridge GPSC: Jamie Barber GPSC: Shemetha Jones GPSC: Julia Truss GPSC: Jeff Stair GDS: Dick Spellman GDS: Andrea Jester Nexant: Patrick Burns Nexant: Jim Herndon NRDC: Brian Henderson SEEA: Mandy Mahoney SELC: Jill Tauber SELC: Steve Bower (on phone) SACE: Rita Kilpatrick SACE: Natalie Mims Southface: John Sibley Southface: Dennis Creech EDS: Pam Davidson

17 I. Welcome & Safety Briefing DISCUSSION Eddie Kelley gave the welcome and did the safety briefing for attendees. A sign-in sheet was passed around to attendees (Attachment A) REQUESTED ACTION ITEM (s) n/a II. INTRODUCTIONS DISCUSSION All attendees introduced themselves. REQUESTED ACTION ITEM (s) n/a III. Review of Agenda DISCUSSION Shemetha Jones briefly discussed the agenda. REQUESTED ACTION ITEM (s) n/a IV. December 8 th Workshop DISCUSSION Jamie Barber discusses the details of the workshop. She states that the workshop will be at the Commission hearing room from 9am-4pm. She reviewed the agenda for the workshop. REQUESTED ACTION ITEM (s) n/a

18 V. Comments from DSMWG members DISCUSSION There were no comments from DSMWG members. REQUESTED ACTION ITEM (s) n/a VI. September Meeting Follow-up Items DISCUSSION Confidentiality Agreement o Jamie Barber stated that the intervention notices are filed in Docket No and so far five parties have filed them. o Drew Woolridge mentioned that the confidentiality agreements could be signed at the December 7 th DSMWG meeting. Percentage of BPI certified contractors Neil Pickard stated that at least one employee for all of the contractors in the HEIP (Home Energy Improvement Program) are BPI certified for the whole house portion. Dollar size of custom projects Neil Pickard said the average cost of the custom projects through Nov 15 is $38,000, the average incentive payment is $3,400, and the average energy savings is 150,000 kwh. Hale Powell stated that the cap was $5,000 for taxpayer and $10,000 for non-taxpayer. He said that he does not have as many concerns about free-ridership with such low incentive levels. Neil responded that the $5,000 and $10,000 caps were approved by Commission; free ridership will be looked at as part of the evaluation process by Nexant. Dean stated the net to gross ratio will be looked into further in the 2013 filing [IRP]. Dean mentioned that the written documentation and findings from the free ridership studies will be a part of publically available documents as approved by the Commission. Hale Powell replied that there is ambiguity regarding the parties involved in the analysis of the evaluation plan. Dean Harless stated that it is a public document, and we discussed the results in a prior DSMWG meeting. Dick Spellman reminded the working group that DSMWG members looked at and commented on the evaluation plan. There were changes

19 and updates made by Nexant based on comments from Staff so there was an opportunity to provide feedback. Brian Henderson asked if results will be given periodically to the working group. Dean responded yes. Georgia Power will give results on an interim basis (especially because of the large savings target increase after the first year). An update, however, may be needed and the evaluation will be finalized in the 3 rd or 4 th quarter of Quarterly report format Dean Harless said the issue of formatting has been addressed and that the report has been modified so that it is easier to read the spreadsheets. Georgia Power has also added budgets for Year to date and Program Year to date. The TRC did not change from what was in the filing and Georgia Power is using avoided cost and program cost numbers that were filed in 2010 IRP. The TRC value will get adjusted after evaluation is completed. Natalie Mims expressed concerns about inconsistencies in the numbers on the report. For example, she stated that the numbers in the report do not match(taking numbers from the quarterly reports, adding them up and comparing them to Georgia Power s IRP and third quarter final numbers and they do not match). She also had concerns about the pending commercial versus actual in the quarterly report. Dean responded that the actual and pending labels on projects has to do with the rebates being paid- anything that is pending has actually been completed, it is just in the pipeline of being processed. Dean is not sure why numbers would not total the same but savings are always rolling through time so you will never be able to match the things you are trying to match, things come in each quarter that move the paid and pending numbers up. Natalie responded that this is a question of accountability and transparencies it doesn t seem to be very transparent the way Georgia Power is presenting things to the Commission. Hale Powell recommended that this group look at the reporting standards in other jurisdiction such as Arkansas. End uses classification and lifetime savings are two areas where the reporting could be improved. Dean responded that the reporting standards that are followed are out of the IRP order. If improvements need to be made, that would come as part of the IRP process for Micro CHP Hale Powell stated that (in regards to CHP) incentives drive achievability. He further stated that Georgia Power is in reactive mode, meaning if a customer comes forward wanting to use this measure, than Georgia

20 Power will consider it as part of the plan instead of a proactive mode where incentives are set to entice customers to use the measure. Since there are no rules that explicitly exclude a measure, it could be included in the study. Dean clarified that it sounds like the efficiency side of CHP is the heat recovery side because customers use less heat from other sources to heat space and water. Georgia Power could potentially include this heat recovery measure as part of DSM planning. But Georgia Power will not consider the co-generation as a measure because it is explicitly stated in the IRP rules that it is a supply side resource. Natalie Mims said that Georgia Power can provide incentives to customers and see what happens. Dean repeated that the heat recovery portion of CHP can be considered as an energy efficiency measure in the commercial custom program but not cogeneration. Mandy Mahoney inquired about the heat recovery portion as an energy efficiency measure. Dean stated that it can reduce the hot water heat load as well as space heat reduction. The challenge is to find out the value of cogeneration from the customer s perspective. CHP might not pass the TRC and RIM tests. Jim Herndon stated that you are not reducing demand but just heating from natural gas. Is this an energy efficiency improvement? Dean stated that Georgia Power is not in the business of fuel switching, but we want to reduce energy efficiency through behavioral improvements. Jim Herndon gave presentation slides to describe CHP and minor CHP. John Sibley said that this is a resource that is getting lost in the shuffle. The work that ACEEE recently published included CHP as an energy efficiency resource. In this ACEEE study (in TX) it was found that 11% off of the base case could be reduced using only CHP. Because it is essentially a fuel switching measure, Georgia Power does not want to look at it. The micros are not very cost effective. If you do it at the larger units they are not addressed as a demand side resource. There is a significant potential for energy savings that is falling through the crack. Dave Ball said CHP is captured in the supply side as a reduction in the forecast. John Sibley responded that using CHP as only a supply side resource never shows the Commission what the potential might be. Natalie Mims said CHP should be considered in the aggressive case scenario for energy efficiency.

21 Dave Ball responded that it is in the IRP that CHP is a supply side resource so it does not make sense for it to be considered as a demand side resource in the aggressive DSM case. Aggressive DSM case scenario Jill: stakeholders see the aggressive case as a place where they can contribute. Consensus is that we need to ensure that there is enough time in future meetings or in a separate workshop for stakeholders to really dig in to the aggressive case. Natalie Mims thought it would be useful to start thinking about how the aggressive case will fit into the IRP. The working group would like to have a more active role in developing the aggressive case. Hale Powell reviewed the stipulation in the Commission order; the ninestep process specifically laid out that the working group will have input. Brain Henderson inquired about the percentage of the aggressive case. Dean answered 1% for the achievable. Dean stated that Georgia Power will combine the water heating program into the HEIP and that he wants to form a small subcommittee in the DSMWG to discuss program modifications and new concepts. This will provide an opportunity to take on concepts and reach an agreement. Then, the group will talk to the larger group, which is the rest of the DSMWG members. The small subcommittee would meet sometime in mid-february after the TEAPOT study is filed. After this process, market penetration will be addressed. Hale Powell stated that members need a diagnostic about how the programs are performing (i.e.-small C/I sector). Rita Kilpatrick asked how is this different from what the working group did last time? Dean answered that the smaller subcommittee would have much more involvement in advising on rebate levels, program design, etc. Dean: let s see if we can reach an agreement on program discussion and economic analysis. He stated that small group can plan to meet in February Afterwards, the aggressive case scenario discussion can be addressed. Dick Spellman said it was his recollection that there was disappointment in the working group last time because there was not adequate time to discuss the programs and other items/measures that the working group thought should be in the portfolio that did not end up in the portfolio. It is not just about penetration but a combination of high penetration and additional measures. We need a steady dialogue to get what the company is proposing. Dean stated that we can address these points through the subcommittee. If members suggest measures, we can look at putting them in the prescriptive program if they are cost effective.

22 Hale: typically New England custom programs that I am involved in don t have list of measures that are included or not in a program- it is on a site specific basis. Dean stated due to the large number of participants, this method may be challenging to implement. Dennis asked about the role and/or function of the subcommittee. Dean stated the subgroup will go over rebates, program levels, program plans and measures. The group will consist of Georgia Power representatives, Commission Staff, and advocates. He believes the group will consist of about ten people. Dean wants the group to meet for a day and a half at the end of February and then meet with the working group in the March, April, May timeframe to go over the economics. Dennis Creech wanted to meet earlier than the dates Dean mentioned to begin the subcommittee. Dean stated that we can possibly meet in January if Georgia Power Staff is available. Dave Ball: do you want to talk about program design before the potential study results? Dennis stated that he is concerned about not having enough time to discuss the aggressive case. We should not push the meeting to February. Dean: I am willing to look at meeting in January when the year end results are available. In addition to Georgia Power and Commission Staff, Dean stated that about three people from the DSMWG would participate in the small subgroup. Participants for this sub-committee: Dean Harless, Audrey Gies, Dick Spellman, Jamie Barber, Shemetha Jones, Jim Herndon, Dennis Creech, Brian Henderson, Natalie Mims, Jeff Smith, Tony Castro, Neil Pickard. Hale Powell: can the group agree on a date to meet? Dean: sure, let s look at our calendars. We will set aside two days in early January. 3 rd Quarter 2012 meeting date Jamie Barber informed the group that next DSMWG meetings in 2012 are as follows: March 13th, June 4 th, and September 6 th. She stated that if any members had a conflict to let her know as soon as they could. REQUESTED ACTION ITEM (s) Georgia Power/Nexant will evaluate how heat recovery from CHP can fit into energy efficiency programs (but not as a part of the TEAPOT study). Shemetha and Jamie will follow-up on the meeting date(s) for the subcommittee.

23 VII. Interim Results of Process Evaluations DISCUSSION Patrick Burns from Nexant gave a presentation giving an overview of the process evaluation. Natalie Mims remarked that the presentation was very high level and asked will the evaluation report be more detailed? She asked if measurement and verification were separate reports. Patrick responded that the reports will be much more detailed. The evaluation plan has information on a measure, program, and portfolio level. The full evaluation plan will be filed with the Commission at the end of Hale Powell remarked that there is a potential value of program evaluation results influencing an enhanced portfolio. The process evaluation results can assist with the subcommittee. How will these be used? Carol Mulholland responded that Nexant gave a very detailed presentation to Georgia Power; they have all the information that they need to make adjustments based on process evaluation. Hale Powell mentioned that this information will be valuable to the subgroup. Dean Harless: in the interim we will look to see if there are hurdles, but the process continues on. As we design program plans in the 3 rd quarter, we should have good data. Hale Powell asked for clarification because he did not understand Georgia Power s response. Patrick Burns stated that they are collecting quality information, which is not available in context. There will not be sufficient data available to provide until the 3 rd quarter (2012). Dick Spellman asked when will the working group have information on measures that should be included and have not yet been. Patrick responded that the Nexant/Cadmus Team does plan to assess for each program whether there are additional measures that should be added to a program in order to attain deeper savings. Carol Mulholland gave a presentation on Interim Results of Process Evaluations. Hale Powell asked what training programs are being done for trade allies? Carol answered that Georgia Power does training on appliance programs and lighting programs for trade allies such as big box stores. The vendors receive training on the programs that Georgia Power offers and the equipment that is associated with the programs. Dean added that this is one of the reasons we did the ramp up process. Brian Henderson said it seems as though this evaluation was focused on internal Georgia Power process and marketing aspects, not so much on customer or implementation strategy. Carol disagreed and responded that Cadmus did customer surveys (people loved the program) and discovered the marketing was inconsistent (people knew about individual measure piece but not whole house piece for HEIP). They have

24 not yet completed surveys on every program but have talked to all implementation staff at Georgia Power. John Sibley asked that Carol expand on what Georgia Power will do to make sure it has the staff it needs in order to ramp up the programs? Dean answered that Georgia Power monitors and tries to adjust to staffing needs. We are comfortable where we are now. Although we are all busy, we expect that we will grow in the future. Dennis Creech had concerns regarding the accuracy of customers savings. He believes that ground-truthing may need to be done. He also had concerns about evaluating the effectiveness of the marketing on energy savings. Carol stated that Cadmus has no data on that piece yet (concerning the accuracy of customer savings), but ground-truthing will be done with site visits. In regards to marketing, she stated that they look to see if people saw messaging, what motivates action, and why there was no action. Timing is important as well as the price tag. It is too early to draw a conclusion about marketing. Dean stated that we can t tie the success of a program to marketing; energy savings are important. Carol stated that they monitor online activity and found good feedback on Georgia Power s programs. Hale Powell cited an AEP Ohio best practices survey regarding staffing levels. There can be a choke point if a utility does not have enough staff. Brian Henderson asked how the 90% penetration on CFLs was determined. Carol answered this was done through phone surveys of participants and nonparticipants. Savings will not be calculated based on the survey. Dean: we only looked at the CFL giveaway portion in the lighting and appliance program. Dennis Creech asked a question about the life of the CFL. Carol states that CFLs are more affordable because the hours of its life was reduced from 10,000 to 5,000 hours. Dennis stated that it would be helpful if Georgia Power collected CFL data to further the energy efficiency knowledge of the state. Dean replied that most customers don t know how many hours they kept a bulb on. Carol reaffirms Dean s point by stating that most people do not remember when they bought their last light bulb. Dean stated that persistence is an issue. Nexant stated in the refrigerator recycling (RR) program, a metering study is being done regarding this issue. REQUESTED ACTION ITEM (s) In regards to Dick Spellman s question about additional measures, Shemetha Jones and Jamie Barber will follow-up on this issue.

25 VIII. Quarterly Report Update (3 rd Quarter and YTD) DISCUSSION Neil gave a presentation on Georgia Power s third quarter report and year to date. Neil stated that the HEIP has exceeded its energy savings goal. Furthermore, the multi-family segment has been mostly whole house (versus individual measure option). John Sibley asked about the split of single family/multi-family homes participating in the home energy improvement program. Neil responded there were much more multi-family participants than projected (with an additional 3,000 participants expected in 2012). What measures are being done individually? Neil said that attic insulation is a measure that many people do if they only do one measure. Dean remarked that the 90/10 split between individual measures and whole home participants does not surprise him. Neil stated that Georgia Power will keep marketing after one measure was installed by a participant in the program. Dennis stated that Georgia Power needs to target single family more to increase participation. Dean agreed that there should be more focus on single family. He stated that property managers prefer the whole house approach. Dennis stated that multi-family program needs a more customized program. John Sibley: what is the penetration of single family participants as compared to what you projected? Dean answered probably 50% on whole house. Although, Georgia Power is over target for the program due to multifamily. Brian Henderson stated that he would like to see a breakout of the single family and multi-family goals. Hale Powell asked if it is too late to address in the evaluation plan. Patrick Burns stated that Nexant will check into this. Hale Powell inquired as to why single family participated at a lower level than multi-family. Patrick stated that he does not think that single family is underperforming; multifamily is just over performing. Dick Spellman: for the single family individual measure option, does the contractor suggest additional measures while he/she is in the house? Neil stated that this issue can be addressed. However, it depends on the contractor; some are better than others. Dennis Creech: does Georgia Power upsell individual measurements when they perform whole house improvements?

26 Neil Pickard responded that Georgia Power does ongoing webinars on a monthly basis with trade allies to make sure that the expectation is that contractors sell the whole program. Georgia Power will look into best practices of contractors and see which are having success in selling customers on whole home improvements. Dean stated that contactors are not required to be BPI certified under the individual measure option in the HEIP program. We don t know all of the information. Neil stated that the water heating program is behind in goals, but they hope to get close to the goal. Georgia Power will roll the water heating program into the HEIP. Hale Powell asked if Georgia Power accounts for leakage in the savings calculations. (Leakage occurs when people buy the buy-down bulbs and then install them in non-georgia Power service territories). Neil stated that Georgia Power accounts for gross savings. Leakage will be addressed in the impact evaluation. Brian Henderson asked if there was any exchange of information on rebates between Georgia Power and GEFA. Kris Anderson said that GEFA and Georgia Power will discuss this matter further. Hale Powell asked what percentage of incremental cost is the rebate on energy efficient clothes washers. Dean answered the rebate is about 50% of incremental cost. Dennis Creech asked if Georgia Power tried to target military housing as a niche market. Dean answered that military bases are classified as industrial customers by Georgia Power (by the customer s choice). Jamie Barber asked about the incremental cost to build an Earth Cents New Home. Dean responded that it is in the $3,000-$5,000 range. Dennis said that people typically finance this cost in their mortgage. Dean stated that builders are pleased with using Earth Cents as a way to differentiate themselves in the market. However, builders plan to pass the costs of the energy efficiency improvements to buyers. Hale Powell asked whether the program differentiates between burnout and retrofits. Dean stated retrofits are in custom program and burnout is in the prescriptive. Hale Powell assumes that there will be higher free-ridership with retrofits. Dennis: does participation match the density of customers? Program participation may be high in some areas and low in other areas. Neil stated that they look at mapping at regional levels. Brian Henderson asked what will happen in August/September [2012] if Georgia Power exceeds goals (energy savings in DSM programs).

27 Neil stated that Georgia Power will work with the Commission Staff to discuss the next steps. Dean states that in regards to year end costs, Georgia Power is over budget on the residential side and under budget on the commercial side. They added money to HEIP which is responsible for driving the residential budget over (due to Energy Star). Georgia Power is not over on the rider due to the Power Credit program. However, he states that budgets and targets will be tight next year. REQUESTED ACTION ITEM (s) Shemetha and Jamie will follow-up with Georgia Power about Brian Henderson request to see a breakout of the single family and multi-family goals. IX. Recap of 2013 IRP Timeline DISCUSSION Dave Ball gave a presentation to recap the 2013 IRP Timeline. Dave stated that there would be a delay in sharing results of TRC passing measures, however, the results would be made available to the DSMWG no later than end of the year. Dean stated that customer data feedback step in the nine step plan will occur in 1 st quarter of Georgia Power will work with the subcommittee and do focus groups with new programs. Dick Spellman asked if Georgia Power would consider not screening out measures that have good potential and pass the TRC test and then evaluate the RIM test at the portfolio level. Dean does not recall this instance. The whole house measure captures a lot of these measures that might not pass individually. Georgia Power is not concerned the economics at that point of the screening, they are more concerned with what the customers are interested in and what has been effective and successful around the country. Dick Spellman replied that in prior working group meetings, there were measures screened out because they did not pass RIM. These measures were cost-effective based on TRC. Dick offered to provide more information regarding this. Dean stated that he would like to review this information. Dick stated that this information was included in the GDS report, Exhibit 15 of his testimony. Natalie Mims stated that she would like to review. Dick stated that he would get Staff to forward it to the DSMWG. REQUESTED ACTION ITEM (s)

28 Shemetha and Jamie will provide a list of measures to interested parties that were cost effective according to the TRC and had significant savings but were screened out during the process of bundling measures into programs because they did not pass the RIM test. Shemetha and Jamie will share results of the TRC passing measures to DSMWG members when it becomes available. X. TEAPOT STUDY UPDATE (Georgia Power) DISCUSSION Jim Herndon, Nexant, presented Georgia Power s 2012 Energy Efficiency Potential Study. Hale Powell: how are industrial baselines assessed? Jim: similar to other markets, on a national level. Hale Powell stated that Georgia Power probably had lower baselines due to low energy prices. Dean stated that they use load forecasts. Dennis Creech recommended that Nexant speak with Georgia Tech to see if Georgia Power can use their data on the industrial sector potential. This would help to narrow the range of the data rather than use national data that includes places where rates are much different than Georgia. Jim stated there is not much of a regional difference. He does not know if they can use Georgia Tech s data. Hale Powell commented that most states set their own baselines. The key is to estimate savings and potential. Dean: I believe that we are basing things on the right basis. We will confirm with Nexant. Dennis Creech remarked that he hears very different things from Georgia Tech about opportunities for energy efficiency than what was sent in the working group from Clay Jones (an industrial sector advocate). Jamie Barber informed the working group that Clay s perspective (that industrial customers do not want EE programs) is echoed at the Georgia Commission. She also stated that the Commission may have to address the issue of allowing Commercial customers to opt out of DSM programs as well in the 2013 IRP. Nexant passed out a sheet on industrial measure descriptions. Brian Henderson asked if government wastewater is included as a measure. Jim: there is no specific type included. Dean stated that they are industrial customers. Dennis: you are not able to help local governments with a major problem. Dean: we can look at including it as an industrial measure. If no restrictions, it won t be cost-effective. We will work with the Commission to see who is eligible.

29 Mandy: GE does analysis of this type and connects individual measures applicable to waste water programs. Dick Spellman had a question about R value on the graph in Jim s presentation? Jim Herndon will get the R^2 value for the penetration on the relationship between incentives and savings curve from Cadmus. Jim Herndon said that it is best to pay about 50% of the incremental cost as the incentive for a measure. Hale Powell stated that it is best to pay about 15% of incremental costs. Otherwise, you can bring up attribution issues. Jim stated that early replacement measures are not cost-effective. Hale Powell stated that the majority of savings are from retrofit opportunities. Dean stated that it depends on the measure and end-use. Dick Spellman stated that 50% incentive level is best practice. Dennis Creech asked if Georgia Power will consider a program for mobile homes. Dean responded that Georgia Power is looking into this. It is a much harder market segment to reach. Hale Powell asked what percentage of residential homes use resistance heat? Jeff Smith responded less than 10% REQUESTED ACTION ITEM (s) Shemetha and Jamie will follow-up with Georgia Power on Dick Spellman s request Jim to get the R^2 value for the penetration on the relationship between incentives and savings curve from Cadmus. XI. Program Concept Development DISCUSSION Discussed topic in the aggressive case scenario under September meeting followup section. REQUESTED ACTION ITEM (s) n/a XII. CFL and incandescent bulb discussion DISCUSSION Dick stated that on January 1 st 2012 the lighting standards will change due to EISA standards and asked that the working group discuss how this might affect the potential study. Dick Spellman suggested that members can write a memo similar to his work on the PA potential study, which addresses the baselines and savings.

30 Patrick discussed how the changing baselines will affect commercial programs. Mandy asked if LED lighting factors are considered in commercial lighting programs? Patrick responded that yes, while there is uncertainty in the market with these lighting changes, LED lighting will still be looked at as a measure. (ie- What if LEDs become more cost effective than CFLs?) REQUESTED ACTION ITEM (s) Shemetha and Jamie will follow-up with Dick Spellman regarding his suggestion of a memo on CFL baselines. XIII. Meeting summary/wrap-up DISCUSSION Shemetha Jones closed the meeting. REQUESTED ACTION ITEM (s) n/a

31 EXHIBIT SACE-NAM-4 Letter to Georgia Power and Commission Staff from Several DSM Working Group Members (May 25, 2012)

32 May 25, 2012 W. Cofield Widner Georgia Power Company Jamie Barber and Shemetha Jones Georgia Public Service Commission Dear Cofield, Jamie and Shemetha: We, the undersigned members of the 2013 IRP Demand Side Management Working Group ( DSMWG ), submit the following comments to Georgia Power Company ( Georgia Power or the Company ), Commission Staff, and the rest of the DSMWG regarding the development of the aggressive DSM change case scenario. Through this letter, we seek to provide feedback on the Company s plan for the aggressive case as quickly as possible to facilitate the planning process and discussion at the upcoming DSMWG meeting on June 4th. We may provide additional comments by the June 15, 2012 deadline. We also believe that an aggressive case subcommittee meeting, similar to the program concept subcommittee meeting that occurred in January, could be helpful and should be discussed at the upcoming DSMWG meeting. We maintain a strong interest in continuing to work with Georgia Power, Commission staff and other working group members to enhance the Company s DSM planning process and program portfolio. I. The Aggressive DSM Change Case Scenario as Part of the Nine Step Process. Based on the Nine Step Top-Down Approach for Developing DSM Programs ( Nine-Step Process ) approved in the 2010 Commission proceedings on Georgia Power s 2010 IRP and DSM certification application, the Company must analyze at least one aggressive DSM change case developed with the assistance of the Working Group. Final Order in GPSC Docket Nos and at 13 (July 6, 2010). Georgia Power has shared with the DSMWG its plans for analyzing the DSM change case. Specifically, the Company has provided: Georgia Power plans to evaluate the aggressive scenario using the program concepts from the January 2012 subgroup meeting and a 10 year cumulative energy savings potential target of 12.5% similar to what was achieved in the TEAPOT study achievable high incentive scenario. Incentive levels will not exceed 100% of incremental cost. Any additional feedback or input by the DSM Working Group members is welcomed and will be reviewed for inclusion in the scenario analysis. As shown above, feedback is requested by May 15, 2012.

33 Georgia Power Company Program Concept Economic Analysis Timeline (circulated to DSMWG on March 30, 2012). 1 Before delving into our comments on the Company s plan, we note at the outset, that we are pleased that the Company is interested in modeling an aggressive scenario that anticipates increased levels of energy savings, currently planned for 12.5% over ten years. 2 We are also generally satisfied with the program offerings the Company plans to use in its analysis. Finally, we appreciate the Company s responsiveness to our information requests, which were submitted to facilitate the development of the aggressive case. Specifically, over the past three months, the Company has provided the following data: TRC, PCT, RIM benefit/cost ratios for measures that passed TRC Ramp rates by measure, for measures that passed TRC Percentage of achievable potential savings by new and existing building type, and by sector Measures that could be included in programs Discount rate used in potential study Energy savings by measure, for all sectors, and all permutations of savings This data has allowed us to better understand how the Company developed its TEAPOT study, and, at a high level, the Company s proposed inputs to the aggressive case scenario. However, based on the Company s timeline, Georgia Power seeks feedback on its planned inputs to the aggressive case before the inputs to the DSM change case scenario are finalized. It is difficult to develop an aggressive case when the baseline change case to which the aggressive scenario is compared is unknown. Going forward, we recommend that the aggressive case be developed after information on the baseline DSM change case is available to the DSMWG. II. Aggressive DSM Change Case Scenario Inputs. Based on the Company s plans and the information provided, we have several concerns about the development of the aggressive case, which we hope to address during the next DSMWG meeting on June 4th and, possibly, in a subcommittee meeting on aggressive case scenario development. As detailed below, our concerns involve the following five inputs: (i) energy savings levels, both on a cumulative and annual basis; (ii) incentive levels for measures, as a percentage of incremental cost; (iii) incentive cost as a percentage of total cost; (iv) total cost of the aggressive case; and (v) participation rates. Each of these inputs is critical to the Company s development and evaluation of the aggressive DSM change 1 On May 10, 2012, the due date for DSMWG feedback/input on the aggressive case was moved to June 15, The aggressive DSM change case is intended to result in greater energy savings as compared to the DSM change case. However, because the Company has not yet finalized the DSM change case, it is unclear how exactly the proposed aggressive scenario would compare in terms of energy savings. 2

34 case. For each, we provide our understanding of the Company s planned input, where possible, and our feedback and recommendations. A. Input 1: Cumulative & Annual Energy Efficiency Savings Target The Company has indicated that it plans to use a 10 year cumulative energy savings potential target of 12.5%, which is similar to the 15.1% savings level in the TEAPOT study achievable high incentive scenario. However, it is unclear how the Company proposes to ramp up savings to achieve this target. A steady state annual rate of savings over the 10-year period would be 1.25% per year. We recommend that the Company considers using energy savings ramp up rates of 0.65% of retail sales in 2014, 0.85% in 2015, and 1.0% in 2016 and thereafter, as illustrated by Table 1. This would result in 9.5% savings on a cumulative basis by These recommended levels, while more aggressive than the Company s previous and current levels, are quite reasonable and achievable. 3 Indeed, they are informed by the TEAPOT study, the efficiency goal set in Arkansas in 2007, 4 the proposed efficiency goal that is being discussed in Mississippi, 5 and the efficiency savings of other peer utilities in the Southeast region. Table 1: Savings as a Percentage of 2023 Sales Year GPC Savings as a % of Sales in 2023, as planned 6 Recommended Savings as a % of Sales in % 0.65% % 0.85% % annually 1.0% annually Cumulative Total 12.5% 9.5% B. Input 2: Incentive Levels for Measures as a Percentage of Incremental Cost The Company plans to use incentive levels that will not exceed 100% of incremental cost in the aggressive case. In the TEAPOT study, the Company used an incentive level of 100% of incremental cost across all measures for the achievable high incentive scenario. It is unclear whether the Company plans to use 100% of incremental cost as it did in the TEAPOT study. 3 In fact, we view these savings levels as appropriate for the DSM change case. 4 Order No. 17, In the Matter of a Notice of Inquiry Regarding the Expanded Development of Sustainable Energy resources in Arkansas, Arkansas Public Service Commission, Docket No U (Dec. 10, 2010). 5 See generally In re Order Establishing Docket to Investigate the Development and Implementation of Energy Efficiency Programs and Standards, Mississippi Public Service Commission, Docket No AD-2. 6 Assumes a steady state of savings. 3

35 We believe that an across-the-board incentive level equal to 100% of incremental cost is unreasonable. Many measures and programs do not require this high of a level of incentives to overcome barriers to adoption, and 100% of incremental cost will drive up program costs significantly. Table 2 provides incentives as a percentage of incremental cost for the total portfolio, and for residential, commercial and industrial sectors, for two utilities, BC Hydro and Efficiency Vermont. Both of these utilities have achieved much higher levels of energy efficiency savings on an annual basis than has Georgia Power. As the table illustrates, these utilities use incentive levels that are significantly less than 100% of incremental cost. Table 2: Utility Examples of Incentives as a Percentage of Measure Incremental Cost, by Portfolio and Sector Utility BC Hydro Total 24% 34% 40% Portfolio Residential 16% 31% 34% Commercial 35% 36% 42% & Industrial Efficiency Total 43% 53% 65% Vermont Portfolio Residential 29% 49% 66% Commercial & Industrial 53% 55% 65% We therefore recommend that the Company use more reasonable incentive levels in the development of its aggressive case, as identified in Table We note that the Company will need to assess how to determine customer response rates based on these incentive levels. 4

36 Table 3: Incentive Payment as a Percentage of Incremental Measure Cost Sector Program GPC incentive as percentage of incremental cost, as planned 8 Residential Appliance Recycling 100% 60% HVAC Servicing 100% 77% 9 Home Energy 100% 85% 10 Improvement Lighting 100% 25% New Construction 100% 75% Commercial 11 Custom 100% 50% Prescriptive 100% 30% Retro 100% 75% Commissioning Small Business 100% 75% New Construction 100% 50% Industrial Custom 100% 50% Recommended incentive as percentage of incremental cost Higher incentive levels are but one means of increasing participation and ultimately the energy savings impact of a program and, as Table 2 illustrates, do not necessarily translate to greater savings. Better program design, marketing, and processing efficiencies can attract customer involvement without increasing incentive payments and driving up costs. C. Input 3: Incentive Cost as a Percentage of Total Portfolio and Program Cost Leading energy efficiency programs spend between 50-80% of the total portfolio budget on incentives, as shown in Table 4. Tables 5 and 6 provide a more granular look at incentives as a percentage of overall program budgets. We do not yet know the Company s planned portfolio or program budgets for the aggressive case scenario. When this information is available to the DSMWG, we would like to compare the Company s planned aggressive case incentive costs as a percentage of total costs to those of utilities leading in energy efficiency. 8 Although this percentage is unknown, we use the 100% level that was used in the TEAPOT achievable high incentive scenario. 9 This level of incentive is recommended for an HVAC program that offers incentives for energy efficiency HVAC units, contractor training and consumer education to promote the proper installation and maintenance of the HVAC systems. 10 This level of incentive is recommended for a Home Performance with Energy Star program model. 11 This table contains programs that the Company identified in the Economic Measures Considered in Program Analysis handout, which the Company provided at the March 13, 2012 DSMWG meeting. We excluded the Education program from the Commercial sector because we understand that the program would not include an incentive payment for a measure. We support an education component to most, if not all, energy efficiency programs. 5

37 Table 4: Incentives as a Percentage of 2011 Total EE Portfolio Cost Utility Incentive as a Percentage of Portfolio Cost BC Hydro 59% Energy Trust of Oregon 56% Efficiency Vermont 68% Mid American 78% Interstate Power & Light 80% APS 51% GPC 2011 Portfolio 12 24% GPC 2012 TEAPOT Study - low 50% incentive 13 GPC 2012 TEAPOT Study - 67% moderate incentive 14 GPC 2012 TEAPOT Study - high 80% incentive 15 Table 5: Residential Efficiency Incentives as a Percentage of Program Costs Program Type Utility Program Name Incentive Cost as % of Total Program Cost Appliance BC Hydro Appliance Buy Back 26% Recycling Georgia Refrigerator 20% Power 16 Recycling HVAC Arizona Public Service HVAC Servicing 77% Existing Homes Energy Trust of Existing Homes 51% Oregon Efficiency Existing Homes 56% Vermont Georgia Power 17 Home Energy Improvement 61% 12 See GPC Certified Demand-Side Management Programs Fourth Quarter 2011 Status Report, GPSC Docket No (Feb. 15, 2012). 13 Achievable Energy-Efficiency Potentials Assessment, Public Disclosure Version,Table 3 - Energy Efficiency Program Expenditures at 12, GPSC Docket No (Jan. 31, 2012). 14 Id. 15 Id. 16 See GPC Certified Demand-Side Management Programs Fourth Quarter 2011 Status Report, GPSC Docket No (Feb. 15, 2012). 17 Id. 6

38 Lighting BC Hydro Lighting 26% Georgia Lighting & 30% Power 18 Appliances New BC Hydro New Home 60% Construction Energy Trust of New Homes/Products 45% Oregon Efficiency New Construction 51% Vermont Georgia High Efficiency New 38% Power 19 Homes Water Heating Georgia Power Water Heating 0% Table 6: Non-Residential Efficiency Incentives as a Percentage of Program Cost 20 End Use/Program Type Utility Program Name Incentive Cost as % of Total Program Cost Custom BC Hydro Power Smart Partner 66% Georgia Custom 61% Power 21 Prescriptive BC Hydro Product Incentive 75% Georgia Prescriptive 15% Power 22 Retro Arizona Public 75% Commissioning Service Small Business Arizona Public Small Business 75% New Construction Service Efficiency Business New 73% Vermont Construction Energy Trust of New Buildings 45% Oregon BC Hydro New Construction 50% 18 Id. 19 Id. 20 This table contains programs that the Company identified in the Economic Measures Considered in Program Analysis handout, which the Company provided at the March 13, 2012 DSMWG meeting. We excluded the Education program from the Commercial sector because we understand that the program would not include an incentive payment for a measure. We support having an education component to most, if not all, energy efficiency programs. 21 See GPC Certified Demand-Side Management Programs Fourth Quarter 2011 Status Report, GPSC Docket No (Feb. 15, 2012). 22 Id. 7

39 D. Input 4: Total Cost of the Energy Efficiency Portfolio In light of the Company s plan to evaluate the aggressive scenario using a cumulative energy savings potential target similar to what was achieved in the TEAPOT study achievable high incentive scenario, we are concerned about cost. As discussed in Section II.B. above, incentive levels equal to 100% of incremental cost are not necessary to achieve high customer participation, and they drive up cost. We do not know what components of the TEAPOT high incentive scenario the Company plans to use in its aggressive case scenario, and therefore, lack sufficient information to evaluate the total cost of the Company s proposed aggressive case scenario. The Company will conduct its economic analysis of program concepts in May/June We would like the Company to share its total program and portfolio costs with the DSMWG, broken out by: Rebate and incentive Training and technical assistance Consumer education Program implementation Program marketing Planning & Administration Total cost E. Input 5: Participation Rates Participation information is critical to the development of any DSM scenario because energy efficiency programs must be appropriately sized to ensure cost-effective measure implementation. For example, the cost of a program could go down significantly if participation is increased from 15,000 participants annually to 45,000 participants annually. Without participation data, it is difficult to provide feedback regarding what other utilities have done to scale programs and decrease program implementation costs to ensure that consumers receive the most benefit at the least cost. Georgia Power has not provided the DSMWG with participation data by measure, or program. 23 The updated schedule that Georgia Power sent to the DSMWG on March 30th indicates that the Company would conduct economic analysis on its program concepts in May/June Upon completion of the DSM program plans, we request that the Company share forecasted participation by measure and by program. III. Conclusion The undersigned members of the DSMWG appreciate Georgia Power s interest in our perspective, and hope that the foregoing comments will facilitate and strengthen the discussions regarding the aggressive DSM change case and other issues concerning the development of additional DSM programs and modifications to existing programs. We 23 Based on the information in the Technology Catalog, we can calculate estimated participation rates for a subset of the permutations that comprise the achievable potential. 8

40 look forward to discussing the points raised in these comments and the development of the aggressive case more generally at our next DSMWG meeting on June 4th and following up, as necessary, through additional feedback provided by the June 15th deadline and any subcommittee meeting on the aggressive DSM change case. Sincerely, Alexis Chase Georgia Interfaith Power & Light Natalie Mims & Rita Kilpatrick Southern Alliance for Clean Energy Dennis Creech & John Sibley Southface Energy Institute Jill Tauber Southern Environmental Law Center cc: DSMWG Members 9

41 EXHIBIT SACE-NAM-5 Memorandum from Synapse Energy Economics, Inc. to SACE re: Georgia Power Energy Efficiency Program Participation Forecast This exhibit has been redacted in its entirety

42 Exhibit SACE-NAM-6 Summary of North Carolina Annual DSM/ Energy Efficiency Cost Recovery Filing Requirements 1 (i) (ii) Projected retail sales for the rate period For each measure for which cost recovery is requested through rider: (ii) a. Total expenses to be incurred during the rate period (ii) b. Total costs savings directly attributable to measures (ii) c. Evaluation, Measurement and Verification activities during the rate period (ii) d. Expected summer and winter peak demand reductions (ii) e. Expected energy reductions (iii) For each measure for which recovery is requested through experience modification factor rider (iii) a. Total expenses for the test period in the aggregate and broken down by type of expenditure and unit (iii) b. Total avoided costs for the test period in the aggregate and broken down by type of expenditure and unit (iii) c. Description of results from EM&V activities (iii) d. Total summer and winter peak demand reductions in the aggregate and broken down per program (iii) e. Total energy reduction in the aggregate and broken down per program (iii) f. Discussion of findings and results of programs 1 North Carolina Utility Commission Rules and Regulations, Rule R8-69(f)(1)

43 (iii) g. Evaluations of event-based programs (iii) h. Comparison of impact estimates from previous year and explanation of significant differences (iv) (v) (vi) (vii) (viii) Determination of utility incentives Actual revenues from riders Proposed Riders and basis for their determination Projected sales for customers opting out of measures Supporting work papers

44 Exhibit SACE NAM 7 Performance Incentive National Comparison State Incentive Description Authority Connecticut Rhode Island Michigan Oklahoma Utilities may earn 1-8% of program costs before taxes. Incentive levels are tied to achieving a percentage of approved savings goals. 1% incentive for 70% of goal; 5% incentive for 100%; 8% incentive for achieving 130% of goal. National Grid can earn 4.4% of the eligible efficiency budget. Threshold for performance level is 60% of the savings goal. Once the threshold has been reached, the utility can earn an additional incentive per kwh saved up to 125% of target savings. Performance incentives may not exceed the lesser of: 15% of the total cost of the EE programs; or 25% of the net cost reductions experienced by the provider s customers as a result of implementation of the energy optimization plan. Utilities can earn a 25% net savings for programs where electric energy savings can be estimated; and an incentive of 15% of the cost of programs that do not produce savings, such as education or marketing programs. Utilities can earn 8-12% of program budgets as an incentive. Separate target incentives are set New Hampshire for residential and commercial/industrial sectors. Massachusetts Utilities may earn ~5% of program costs as an incentive for meeting program goals. The incentive is based on a combination of elements including energy savings, benefit-cost, and market transformation results. North Carolina (Proposed) Duke Energy proposed that it receive 0-15% of program costs (after tax) based on the Utility Cost Test score of the Portfolio. A UCT portfolio score of greater than 2.24 allows the Company to receive the 15% after tax program cost incentive. General Statutes of CT 16a-49 Docket 4000 MCL PUD Docket DTE Order NCUC Docket No E7 Sub 1032 Sources: Energy Efficiency Policy Inventory, Regulatory Assistance Project, (search for State Energy Efficiency Policy Inventory ) and State Energy Efficiency Policy Database, American Council for an Energy Efficiency Economy,

45 EXHIBIT SACE-NAM-8 Flexibility Guidelines Reference Documentation for Duke Energy Carolinas, LLC

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