therefore reversed our opinion on this topic, and have included support for an IE structure, as specified further in the text of the decision. Numerous parties also disagreed with the proposed decision’s requirement for a mid-process Tier 2 advice letter filing at the RFA short list and RFP design stage, including the IOUs, NRDC, the Council, ORA, and CLEAResult. We have removed this requirement, and have instead substituted the requirement for an IE structure, as well as the filing of Tier 2 advice letters for contracts or batches of contracts, after award, that are valued at $5 million or more and/or with terms of longer than three years, for Commission review. Several parties commented that the 60 percent requirement for third party designed and implemented programs should not be moved back to 2022 from 2020, including the Council, CLEAResult, NAESCO, ORA, and NRDC. We will not modify this requirement, in part because some of the delay has been caused by the Commission’s process itself, and in part out of an abundance of caution and a desire to see this process be successful, if on a slightly slower timeframe. The comments of several parties, including ORA and the IOUs, included requests for clarification about whether the third party solicitation process can begin before the business plans are addressed by the Commission. The answer is no. This decision enables the IOUs to begin solicitations for IEs, and to prepare the standard contract terms and conditions, as discussed in this decision, but does not yet authorize the launch of RFAs, until such time as the programs are addressed by the Commission in a decision on the business plan filings. CEE’s comments, while supporting other aspects of the decision or concurring with others’ comments already discussed above, focus primarily on the need for further requirements for diverse contracting and workforce quality standards. Their comments were also generally supported by NRDC. As a
therefore reversed our opinion on this topic, and have included support for an IE structure, as specified further in the text of the decision. Numerous parties also disagreed with the proposed decision’s requirement for a mid-process Tier 2 advice letter filing at the RFA short list and RFP design stage, including the IOUs, NRDC, the Council, ORA, and CLEAResult. We have removed this requirement, and have instead substituted the requirement for an IE structure, as well as the filing of Tier 2 advice letters for contracts or batches of contracts, after award, that are valued at $5 million or more and/or with terms of longer than three years, for Commission review. Several parties commented that the 60 percent requirement for third party designed and implemented programs should not be moved back to 2022 from 2020, including the Council, CLEAResult, NAESCO, ORA, and NRDC. We will not modify this requirement, in part because some of the delay has been caused by the Commission’s process itself, and in part out of an abundance of caution and a desire to see this process be successful, if on a slightly slower timeframe. The comments of several parties, including ORA and the IOUs, included requests for clarification about whether the third party solicitation process can begin before the business plans are addressed by the Commission. The answer is no. This decision enables the IOUs to begin solicitations for IEs, and to prepare the standard contract terms and conditions, as discussed in this decision, but does not yet authorize the launch of RFAs, until such time as the programs are addressed by the Commission in a decision on the business plan filings. CEE’s comments, while supporting other aspects of the decision or concurring with others’ comments already discussed above, focus primarily on the need for further requirements for diverse contracting and workforce quality standards. Their comments were also generally supported by NRDC. As a
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