LCE’s Responses: LCE rejects the assertion by SoCalREN and SCE that they are required to engage in the CAEECC process and SCE’s assertion that the funding should be coordinated with the timing of SCE’s Business Plan approval. LCE claims that to engage in this resource intensive process is unnecessary for an initial filing to elect to administer EE their EE plan. They add that Senate Bill 790 modified Section 381.1 to provide CCAs a simpler route to elect to administer EE programs, in which a Tier 3 AL was sufficient and thus do not need to file an application or participate in CAEECC. LCE adds that despite their decision to pursue the elect to administer option, LCE recognizes the value of stakeholder input and solicited input from SCE, SoCalREN and ORA. In response to SCE’s assertion that LCE should update their hard to reach net-to -gross to align with SCE’s EM&V definition for small business as business that use under 20 kW or less monthly, LCE responds that SCE and other program administrators also offer direct installation services for businesses using under 200 kW monthly. LCE adds that they intend to target small businesses under 20 kW monthly, but will set the upper limit to 200 kW. LCE claims the net-to-gross values used in their cost effectiveness input file were derived from approved workpapers or from the Database for Energy Efficiency Resources and are aligned with current industry standards for direct install for small commercial measures. In response to SCE’s assertion that LCE should develop labor and material costs for their Small Commercial Direct Install program rather than use SCE’s estimates, LCE states that new and non-IOU program administrators are at a distinct disadvantage for gaining useful data to inform these calculations. However, LCE expects to be able to develop such estimates subsequent to running the program. LCE claims that SoCalREN, while not providing discussion related to LCE AL 5-E, appears to advocate for a new proceeding. LCE responds that they are following an existing process from D.14-01-033 and that any consideration of further rulemaking is immaterial to the certification of LCE’s plan. Finally, SoCalREN provided comments on successful CCA growth models without any discussion of LCE, from which one might infer that LCE may not be operating with long term
LCE’s Responses: LCE rejects the assertion by SoCalREN and SCE that they are required to engage in the CAEECC process and SCE’s assertion that the funding should be coordinated with the timing of SCE’s Business Plan approval. LCE claims that to engage in this resource intensive process is unnecessary for an initial filing to elect to administer EE their EE plan. They add that Senate Bill 790 modified Section 381.1 to provide CCAs a simpler route to elect to administer EE programs, in which a Tier 3 AL was sufficient and thus do not need to file an application or participate in CAEECC. LCE adds that despite their decision to pursue the elect to administer option, LCE recognizes the value of stakeholder input and solicited input from SCE, SoCalREN and ORA. In response to SCE’s assertion that LCE should update their hard to reach net-to -gross to align with SCE’s EM&V definition for small business as business that use under 20 kW or less monthly, LCE responds that SCE and other program administrators also offer direct installation services for businesses using under 200 kW monthly. LCE adds that they intend to target small businesses under 20 kW monthly, but will set the upper limit to 200 kW. LCE claims the net-to-gross values used in their cost effectiveness input file were derived from approved workpapers or from the Database for Energy Efficiency Resources and are aligned with current industry standards for direct install for small commercial measures. In response to SCE’s assertion that LCE should develop labor and material costs for their Small Commercial Direct Install program rather than use SCE’s estimates, LCE states that new and non-IOU program administrators are at a distinct disadvantage for gaining useful data to inform these calculations. However, LCE expects to be able to develop such estimates subsequent to running the program. LCE claims that SoCalREN, while not providing discussion related to LCE AL 5-E, appears to advocate for a new proceeding. LCE responds that they are following an existing process from D.14-01-033 and that any consideration of further rulemaking is immaterial to the certification of LCE’s plan. Finally, SoCalREN provided comments on successful CCA growth models without any discussion of LCE, from which one might infer that LCE may not be operating with long term
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