Category: Utility Programs

Dominion Energy Launches Smart Home Program

A new program launched by Dominion Energy provides a kit of smart home technology with an instant rebate to eligible customers in Virginia.

New Smart Home technology helps customers save energy and be more aware of the electric use in their home. To help customers adopt this new technology, Dominion Energy is offering eligible customers in Virginia as well as North Carolina rebates on smart home products.

The Smart Home program gives customers the opportunity to purchase a smart home kit on the program website, smarthome.domsavings.com, with an instant $25 rebate. The base kit includes a Kasa Smart Plug with Energy Monitoring, two Kasa Smart Wi-Fi Plug Minis, the Philips Hue Smart White Ambiance LED Starter Kit and a Philips Hue Motion Sensor.

Customers can enhance their smart home setup by adding an ecobee Smart Thermostat ($50 rebate) or Sense Home Energy Monitor ($70 rebate) to their kit purchase, and each is available with an additional instant rebate. The Sense Energy Monitor must be installed in your electric panel by a licensed electrician.

As such, electricians as well as solar installers with on-staff licensed electricians can become participating contractors with Dominion’s Smart Home Program. Participating contractors benefit from the program in many ways including getting listed on Dominion’s website and access to free training.  To learn more about becoming a participating contractor including the eligibility requirements, visit www.dom-vendor.com.

With integration between smart home devices and a smartphone and / or voice assistant, customers will have increased control over their home’s energy use, even remotely. Customers will have the ability to put your devices on a schedule, allow devices to perform energy-efficient actions on their own, and connect to other smart technologies.

Learn more about how the program helps customers leverage integrated energy-efficient smart home products to reduce and manage a home’s energy consumption. Visit smarthome.domsavings.com for more information. Terms and Conditions and eligibility requirements apply. Subject to change at any time.

Dominion EM&V Hearing Update

On October 27th, the SCC released the final order for the Dominion Energy EM&V proceeding. For this proceeding, the VAEEC acquired expert witness, Mark James, Senior Research Fellow in the Institute for Energy and the Environment and adjunct professor at Vermont Law School to testify on our behalf. Additionally, staff from the American Council for an Energy-Efficient Economy also provided technical assistance to our legal counsel and expert witness. In their final order, the Commission elected to adopt all of the recommendations in the Hearing Examiner’s report, which was released in July. 

Below is a summary of all of the Hearing Examiner’s findings and recommendations to the Commission with additional details on key recommendations. We have listed the page numbers in the report for the discussion on each recommendation so the reader can easily dive deeper into any recommendation of interest.

  1. The focus of this proceeding is on adopting a more rigorous and accurate EM&V, and not on whether the Company’s current EM&V meets industry standards (p 44-50); VAEEC maintained “nationally-recognized TRMs that follow industry best practices, along with new commitments on EM&V that the Company is making in its post-hearing brief, can and will provide the accuracy that the Commission rightly demand”; 
  2. The Commission should direct Staff to participate in the stakeholder process as a stakeholder to work with the Company and others to develop more rigorous and accurate EM&V data (p 50-53); James said, “With the newly established EM&V subgroup, the stakeholder process offers the opportunity for transparent presentation and discussion of options outside of a Commission proceeding. The recommendations generated by the EM&V subgroup would still be subject to Commission approval, but the products of the stakeholder group would be created through a transparent, collaborative, and consensus-driven process. Furthermore, using the stakeholder group allows for greater participation from interested parties and energy efficiency experts.” While SCC staff was concerned that participation would undermine their credibility, the Commission stated that they speak only through their Orders, not through Staff. 
  3. The Commission should adopt the dashboard proposed by Company witness Frost in his rebuttal testimony (p 53-55), and attached to this Report as Attachment 1 (p 78); “The Company’s proposed dashboard represents an executive summary of high-level metrics that is easy to read and understood

at a glance. It focuses on spending, savings, metrics noted in the VCEA (such as carbon emission reductions and bill savings), and progress towards the GTSA and VCEA targets.” 

  1. The Commission should adopt the reporting requirements committed to by Dominion Energy as further outlined in the Discussion (p 55-57); Adoption by the Commission should provide all interested parties clarity concerning the information to be provided by the Company and when that information will be provided. The provisions for using formats proposed by VAEEC witness James (or formats substantially similar) provides some flexibility as to the final format for these filings. Going forward changes in format or in the information provided can be addressed in future DSM proceedings.
  2. The Commission should direct Dominion Energy to file the May EM&V Report in the Company’s December DSM filings (p 57-58); If the entire EM&V Report from May were also filed at the beginning of the new DSM proceeding, at the time of filing, it would represent the most current EM&V Report.
  3. Deemed input values meet the measured and verified standard for determining compliance with the energy-saving requirements of the VCEA (p 58-62); VAEEC argued that, because it is impossible to measure electricity not consumed, all EM&V methods rely on extrapolations and have some margin of error and uncertainty. Indeed, VAEEC maintained  “the use of Virginia-specific inputs as recommended by Staff might prove to be less accurate than results based on deemed values.” VAEEC extended this to utility-specific data that may be less accurate and reliable than deemed values based on limitations of the utility-specific sample as compared to deemed values based on larger populations over longer periods of time. VAEEC recommended the Commission adopt the Company’s updated EM&V approach

as it is more rigorous and accurate than what was reviewed in 2019.

  1. To increase the rigor and accuracy of the EM&V process, the Commission should adopt a combination of the Company’s proposed framework and the Staff’s proposed hierarchical framework, with both frameworks as further modified herein (p 62-73);
  2. The Commission should direct the Company to document the baselines used during program design and all subsequent adjustments or changes to the baselines, and provide the documentation to Staff and the other parties upon request (p 73-75);
  3. The Commission should direct the Company to increase the coordination between DNV and the program designer(s) consistent with their commitment in this proceeding (p 75); and
  4. The Commission should direct the Company to undertake at least one baseline study based on Staff’s input. In the final order, the Commission required Dominion to select two programs to use in baseline studies to establish their own baselines for energy savings. The Company has ninety days from the final order to present this information to the SCC. 

Dominion EM&V Hearing

The Dominion Energy proceeding on Evaluation, Measurement, and Verification (EM&V) before the SCC will be held next week. The VAEEC is formally participating in this hearing in support of EM&V measures that will help ensure the energy efficiency goals of the Virginia Clean Economy Act (VCEA) are met. EM&V is a critical first step in quantifying the value of energy efficiency programs, which allows demand-side management resources, like energy efficiency, to compete with supply-side resources, such as a natural gas plant, in meeting future energy needs in a cleaner, healthier way. 

The inherent challenge of evaluating energy efficiency programs is that there is no simple “meter” to record kilowatt-hours saved. As a result, a baseline needs to be established to identify what would happen in that program’s absence. However, there must be a balance between the cost of evaluation and the benefits of obtaining more precise data, as the pursuit of precision can siphon funds from the actual implementation of that energy efficiency program without adding significant benefit. To accomplish that balance, most utilities use deemed savings, or reasonable and unbiased estimates of energy and cost savings based on standard industry methods.  

During their pre-filed testimony, the SCC staff questioned the use of deemed savings and non-Virginia data and recommended establishing customized baselines for each individual program currently underway, despite this being against industry best practices. The VAEEC has serious concerns about this recommendation. Every dollar spent on EM&V is a dollar that cannot be spent on providing actual program services to customers. A requirement to use only Virginia-specific data or a rejection of deemed savings estimates can drive up EM&V costs without always providing improvement in EM&V data.

We have several recommendations that would ensure the best use of program dollars without unnecessary spending on duplicate data gathering. 

  • Join the Mid-Atlantic Technical Resource Manual (TRM): A TRM provides the value of previous evaluation efforts while maintaining the flexibility to adapt to local- or utility-specific conditions such as lifespan estimates for specific measures, operating hours, baseline conditions, and local climatic conditions. When performing EM&V on their programs, Dominion already defers first to the Mid-Atlantic TRM, then factors in Virginia-specific data when appropriate. Formally joining the Mid-Atlantic TRM would provide uniformity in evaluation across all Virginia utilities and would further increase transparency into the process itself.
  • Allow Flexible, Portfolio-Level EM&V Spending: The Commission should set spending caps at the portfolio level to allow for greater flexibility and additional energy-saving benefits. After reviewing EM&V data, a utility should be able to shift funds between programs (e.g., 10 percent to 15 percent) without having to seek additional approval. Removing these caps would permit greater flexibility, which can ultimately boost the energy savings generated from the portfolio without imposing additional costs on customers.
  • Stakeholder Input: Allow the stakeholder group to assist in developing consensus for EM&V methods. With the newly established EM&V subgroup, an opportunity is provided to present and discuss options for EM&V methods and protocols outside of a Commission proceeding. By using the Mid-Atlantic TRM for this purpose, the stakeholder group would avoid the unnecessarily burdensome process of developing and approving the specifics of every measure-specific or program-specific baseline. The recommendations generated by the EM&V subgroup would still be subject to Commission approval, but the products of the stakeholder group would be created through a transparent, collaborative, and consensus-driven process.
  • Dashboard: We support the requirement of both a quarterly “dashboard” and “annual summary”. A dashboard should provide a program-by-program snapshot of key activities, such as participation numbers and program spending, in order to track how the company’s energy efficiency portfolio is progressing throughout the year. The annual summary would contain audited and finalized savings for the company’s DSM programs to ensure compliance with the GTSA and the VCEA.

If you want to dive into this a little more, you can read our expert witness’ pre-filed testimony here.

VAEEC’s 2020 in Review

2020 has been a unique year for sure. However, looking back, VAEEC and Virginia’s energy efficiency industry saw several monumental wins this year. In fact, Virginia had its best year on the ACEEE’s annual State Energy Efficiency Scorecard. For the first time ever, we broke into the Top 25 and Virginia was ranked #1 in the Southeast. This is a reflection of the hard work and efforts of the Commonwealth’s energy efficiency industry throughout 2020. We look forward to continuing to advance energy efficiency even further in the new year.

For our part, the VAEEC worked tirelessly with fellow stakeholders to pass several key pieces of historic energy efficiency legislation, including the Virginia Clean Economy Act (VCEA). This landmark law will pave the way for a carbon-free Virginia by 2045, ensuring investments in energy efficiency, solar, wind, and more. The VCEA mandates 5% energy savings from the investor-owned utilities by 2025, marking Virginia as just the second state in the Southeast to establish a mandatory stand-alone Energy Efficiency Resource Standard (EERS). Additional laws established mandatory benchmarking for state buildings, enabled an on-bill tariff program for electric co-ops, and added an energy audit to the residential disclosure during homebuying. We also saw the passage of a law permitting the state energy office to develop a statewide Commercial Property Assessed Clean Energy, or C-PACE, program.

The VAEEC also advanced energy efficiency in the Commonwealth beyond legislation. We identified the need to change Dominion Energy’s definition of low-income eligibility requirements and worked with our members to make it happen. The new definition will allow weatherization providers to serve even more households across Virginia. Three localities passed C-PACE ordinances and one launched a program. Blower door testing and increased ceiling insulation requirements were included in the recently adopted final draft of the Uniform Statewide Building Code.

At the end of each year, the VAEEC completes a program evaluation, which goes hand-in-hand with our Strategic Plan to answer:

  • What impacts is the organization trying to achieve?
  • What strategies will help us achieve our goals?
  • How will we know if our work is successful?

As you might remember, VAEEC staff and Board members met last summer to develop our 2020-2022 Strategic Plan. Taking feedback from our members, we created focus areas for our next three years of work:

  1. Advancement of New Energy-Efficiency Technologies
  2. Government Engagement
  3. Utility Programs and VCEA Implementation

Our evaluation focuses on each of these areas, prompts us to think about the goals, strategies, and metrics for each, and assesses whether or not we are on track to achieve our goals. To provide our membership with a snapshot of these goals and whether or not we are on track to achieve them, we are sharing our program evaluation infographics. Take a look below to get a glimpse of all of the EE advancements we were able to achieve in this unprecedented year.

To learn more about the VAEEC’s 2020 achievements, watch our short video below.

Our work would not be successful without the support of our members. Thank you for your dedication to the organization and to Virginia’s energy efficiency industry. We look forward to working with you in the new year to make 2021 our strongest year for EE yet.

Dominion DSM Stakeholder Group Updates

Dominion’s Energy Efficiency Stakeholder Group met virtually on August 27th. They discussed a number of updates, as well as brainstormed ideas for long-term planning. 

The Virginia Clean Economy Act included some changes to the stakeholder process, so two new subgroups were created, focusing on Policy and EM&V. Those groups will meet in the coming weeks. 

Additionally, Dominion provided an update on how the COVID-19 pandemic has affected their DSM programs as well as an update on the improved eligibility definition for low-income programs, which we worked to change earlier this year. While the marketplace has been open the entire time, all in-person programs were suspended last spring. Dominion resumed their Non-Residential programs on May 15th and resumed all of their single-family, residential programs in June. Recently, they allowed multi-family projects to resume in their low-income programs. All low-income program providers are following federal weatherization COVID guidelines. 

Following the SCC’s recent approval of all of Dominion’s Phase VIII DSM programs, the Dominion DSM team and their implementation vendors are working on preparation as they prepare to launch them in January 2021.

Dominion also provided an update on their next filing for Phase IX, which will be submitted to the SCC in December. The company received 53 program proposals from ten vendors in response to their most recent RFP. The program categories were: Non-Residential, Residential, Low-Income, Cross Program services (e.g. marketing, call center, rebate fulfillment, etc.) and “open” programs with this last category being used as a starting point for next year’s RFP.

Dominion’s EM&V vendor, DNV GL, gave a presentation on their annual EM&V report, which was filed back in May. The residential marketplace made up 51% of the energy savings from DSM programs in 2019. Through the marketplace program, 3.5 million light bulbs were purchased either online or at a retail store. The Non-Residential lighting program made up 30% of the energy savings in 2019 and the Non-Residential small business program made up 11%. All other programs each made up one percent or less of the total savings accrued in 2019. There was also a brief discussion about the upcoming EM&V proceeding before the SCC, which will take place next May. The VAEEC will be participating as a respondent in this case and has already begun working with our lawyers with the UVA Environmental and Regulatory Law Clinic in preparation.

The group concluded the day with a discussion on long-term planning. The company has hired the Cadmus Group to assist with this planning, which will help meet their mandated energy savings targets, which became law earlier this year. If you are already a member of the stakeholder group, and would like to participate in this planning process, be sure to add yourself to the long-term planning subgroup in Trello.

If you would like to participate in the Stakeholder meetings or would like to view materials, please email the meeting facilitator, Ted Knicker at ted.knicker@ipa-llc.org to learn more.

SCC Approves All Dominion DSM Programs for Second Consecutive Year

Yesterday, the SCC approved ALL of Dominion’s Demand Side Management (DSM) programs in their phase VIII filing and the updated programs in their VII filing. All programs- except the Low Income (LI) heating and cooling program- were approved for five years from January 2021-December 2025. The LI heating and cooling program was approved for three years, as stated by law, and will run from January 2021-December 2023. The updated phase VII programs can begin immediately and will end in December 2024 along with the remaining VII programs.

As a formal respondent in the proceedings, the Virginia Energy Efficiency Council (VAEEC) is incredibly excited with the progress shown in this final order. The Commission has also expressly agreed with the VAEEC that the creation of a standardized dashboard for evaluation, measurement, and verification (EM&V) reporting is necessary to determine the true effectiveness of these energy efficiency programs. 

The Commission also agreed that the proposed mid-stream program should not split the incentives between the homeowners and the builders. This is a great example of how our involvement in this process is crucial. The company had agreed to the 50% split incentive in their rebuttal testimony and the Hearing Examiner recommended it to the Commission. However, the Commissioners were clearly swayed by our arguments that a split incentive did not enhance energy efficiency gains in this instance.

We’re also pleased to note that Dominion has expressed its willingness to continue working on standardizing the process for qualifying low-income projects and post-construction reporting requirements. The updated eligibility criteria that Dominion agreed to earlier this week are part of this work, though there are standardization needs that still need to be addressed.  

 

A full list of the programs can be found here

Low-Income Eligibility Definition

We are excited to announce that this week, on a call with VAEEC members and staff, Dominion Energy committed to using a definition of low income eligibility requirements that weatherization providers and VAEEC have suggested for some time. That new definition is:
A household whose annual income does not exceed 80% of the local area median income as set forth by Virginia Housing Development Authority or 60% of the state median income as determined by the Virginia Department of Housing and Community Development, whichever is greater.
This change, which Appalachian Power Company is already planning to implement, will allow weatherization providers to serve more households across Virginia. Chase Counts with Community Housing Partners stated, “This is not only a big win for vulnerable Virginian households but is also an example of Virginia’s leadership in energy equity issues.”

Dominion Energy’s DSM programs filing update

On June 16, 2020, the hearing examiner in the Dominion Energy DSM Proceeding (PUR-2019-00201) released his recommendations to the Commission. Overall, the report was positive, recommending that all of the programs be approved- some with modifications- at the budget requested by the company. 

While the VAEEC is pleased overall with the recommendations, we are drafting comments as respondents in the case to address two outstanding issues:

  1. For the New Home Construction program, the hearing examiner recommends splitting the incentive between the homebuilder and the homebuyer 50/50. As we argued in our post-hearing brief, the lead actor for creating market transformation in this type of mid-stream program is the homebuilder, “who is making the design and equipment decisions necessary to achieve ENERGY STAR certification, [which] leads to more energy-efficient homes being put on the market for sale.
  2. The hearing examiner stated that the VAEEC’s request to require that all future DSM applications include energy savings data and tracking metrics towards the goal in the Virginia Clean Economy Act (VCEA) was unnecessary. Instead, it was suggested that this and all other futuristic recommendations should be further explored and developed by the stakeholder group. While we do agree with this conclusion for some of our other recommendations (e.g. geo-targeting and using AMI to enhance programming options), we feel the Commission should require inclusion of key data- as related to the mandates in the VCEA- in all future filings. Without these metrics, how can the Commission and the public understand whether or not the company is making progress towards its goals?

We hope the Commission will consider these arguments as they deliberate on their decision.

One final thing to note is the section of the hearing examiner’s report on EM&V. Throughout the proceeding, the SCC staff expressed a lack of confidence in the company’s EM&V analysis. In the company’s rebuttal testimony, Mimi Goldberg with DNV GL invited Staff to meet with them in order to walk through their process and to “improve the rigor of EM&V.” During their opening statements at the virtual hearing on April 29th, the SCC staff attorney took offense to this suggestion, which they reaffirmed in their post-hearing brief, stating, “such collaboration between [Dominion Energy] and Staff would compromise Staff’s ability to critically review future DSM filings.”

In his report, the hearing examiner not only dismissed this notion of impropriety, but made the recommendation for the Commission to direct Staff to engage with the company on these issues. The recommendation also goes on to reaffirm SCC staff’s engagement in the stakeholder processes, which to date has been greatly limited.

From the hearing examiner’s report:

“Moreover, Staff working with the Company to develop more rigorous and accurate EM&V data is consistent with the requirements of § 56-596.2 C of the Code as revised by the VCEA. This Code provision directs the Company to use a stakeholder process “to provide input and feedback on . . . (iv) best practices for [EM&V] for purposes of assessing compliance with the total annual energy savings . . . .” This Code provision further provides: “[s]uch stakeholder process shall include the participation of representatives from each utility, relevant directors, deputy directors, and staff members of the Commission who participate in approval and oversight of utility efficiency programs, . . . .” I recognize that Staff working with the Company to develop more rigorous and accurate EM&V data may go beyond the requirements of the stakeholder process set forth in § 56-596.2 C. However, Staff participating in the stakeholder process addressing EM&V, but declining to otherwise work with the Company on EM&V issues, would undermine the policy directive of the General Assembly for EM&V practices to be developed in a collaborative process. Therefore, I find the Commission should direct Staff to work with the Company and others to develop more rigorous and accurate EM&V data.”

So, what are the next steps? We wait for the SCC to issue their Final Order in the case, which should happen within the next several weeks. Regardless, Dominion’s plan is to launch the approved programs in early 2021. The next virtual stakeholder meeting is anticipated to be held sometime in August.

Dominion Rolls Out New EE Programs

This is a guest post from Honeywell, the program manager for Dominion’s newest residential energy efficiency program.

Residential homeowners looking to make their home more energy efficient in preparation for winter and beyond can benefit from the launch of Dominion Energy Virginia’s new Home Energy Assessment (HEA) Program.

HEA is one of 8 programs approved by the State Corporation Commission in support of improving energy efficiency opportunities in Virginia for residential and commercial customers.

Dominion Energy’s residential customers can receive an in-home energy assessment where a qualified participating contractor will conduct a walk-through audit and install simple measures like LED bulbs and water heater pipe insulation, while identifying other energy-saving opportunities in the home. Recommended energy efficiency improvements will be suggested for maintenance and upgrades on heating and cooling systems, ductwork and water heaters through a customized HEA report. Once customers have worked with their contractor to install the recommended improvements, they are eligible to receive valuable rebates that help to offset the cost of service.

The HEA Program was designed with three simple steps to make it easy to participate:

  • You can schedule an assessment at a time that is convenient for you with the contractor. Visit DominionEnergy.com/HomeEnergy to find a list of participating contractors.
  • The contractor conducts a 30 to 60-minute walk-through of the home and installs simple measures, while identifying other energy-saving opportunities
  • The contractor works with you to submit the rebate application for work completed

Dominion Energy’s new portfolio of energy efficiency programs were approved to run for a 5-year period through June 2024. Other new residential programs include appliance recycling and efficient products rebates. Non-residential programs provide rebates for energy efficient lighting systems and controls, heating and cooling systems, window film, small manufacturing facilities and office buildings.

All approved programs are part of the $870 million of energy efficiency programs that Dominion Energy is required to propose over a 10-year period, as ordered by the Grid Transformation & Security Act of 2018. The landmark legislation will keep Virginia’s traditional advantage of low electricity prices and reliable service while taking dramatic steps towards the future by expanding renewable energy and broadening the potential for energy efficiency programs in Virginia. If you are interested in learning more about these energy efficiency programs, please visit www.DominionEnergy.com/ECprograms.

Recap of the Dominion DSM Hearing: The Future Looks Bright

The Dominion DSM case was held Wednesday, March 20, 2019 before the three Commissioners of the State Corporation Commission (SCC). This was the first case being heard by the new Commissioner, Judge Patricia West. Our previous blog post on the DSM application went into detail about the programs themselves so this post will only focus on the proceeding. You can review all proceeding materials on the SCC webpage for this docket.

The proceeding was broken up into three main sections:

  1. Public Testimony
  2. Oral Arguments on Legal Memo
  3. DSM Proceeding

Oral Arguments

At the beginning of the proceeding, the Commissioners heard oral arguments on whether or not lost revenues should be considered as part of Dominion Energy’s commitment to propose $870M worth of energy efficiency programs over the next ten years, as part of the 2018 Grid Transformation and Security Act. Counsel for VAEEC reiterated the position, as stated in our legal brief, that lost revenues should not count towards the $870M, since the the statute that states this commitment does not mention lost revenues. Walmart, environmental respondents and the SCC staff agreed with our arguments. In addition, while the Attorney General’s office took no official position, they did mention in their oral arguments that no one- in either oral arguments or public comments (written and oral)- supported the Company’s position that lost revenues should be included in the commitment to propose $870M in energy efficiency programs over the next decade. The Commissioners asked a lot of questions during oral arguments and are anticipated to make a ruling on this issue in their Final Order for the DSM proceeding.

DSM Proceeding

During the proceeding, VAEEC, environmental respondents (Appalachian Voices and Natural Resources Defense Council), and Sierra Club supported all ten of the proposed EE programs (11 demand response programs in total). The SCC staff and the AG’s office were “unopposed” to seven programs and had “remaining concerns” about the other four.

During the hearing Dominion Energy staff stated that due to a calculation error regarding higher-than-expected participation rates for the Residential Engagement program, the Company had reduced their overall budget request to $203.9M.

VAEEC witness, Rachel Gold, with the American Council for an Energy-Efficient Economy, took the stand in support of the proposed programs and explained the value of benchmarking to evaluate whether or not the target set by the General Assembly- for Dominion Energy to propose $870 million in energy efficiency programming over the next decade- is achievable. The good news is, according to the results of that analysis done by ACEEE, this target should be easily attainable.

The seven programs with unanimous support were:

  1. Appliance Recycling Program
  2. Efficient Products Marketplace Program
  3. Smart Thermostat Management Program (DR)
  4. Smart Thermostat Management Program (EE)
  5. Non-Residential Window Film Program
  6. Non-Residential Lighting Systems & Controls Program
  7. Non-Residential Small Manufacturing Program

Initially, SCC staff stated that they were “unopposed” to the above programs. However, after further pressing by Commissioner Christie, SCC Staff stated that they did, in fact, support these programs. One interesting thing to note during this back and forth is that the Commissioners were expressing frustration with both Staff and the Company regarding the lack of analysis based on real energy savings. They argued that Staff should be able to take positions on proposed programs that are based on previously-approved programs since there would be real-energy savings data captured for those programs. While this data is provided by the Company in their annual EM&V filings, the Commission felt that the data could be provided in an more easy-to-digest format. Commissioner Christie directed the Company to produce a spreadsheet on previously approved programs to show the actual program costs and actual kWh savings. The Company asked for a one-week deadline to submit that table into evidence.

The inclusion of this type of table in future filings can bolster future applications by showing just how much savings are being realized by these programs, which could help win approval more easily. While the Commissioners are skeptical of energy efficiency programs and the projected savings they can achieve, that skepticism can potentially turn to support if strong energy-savings numbers are achieved in prior program iterations.

As mentioned above, SCC staff had concerns regarding the four remaining programs, which were:

  1. Home Energy Assessment Program: SCC staff was concerned that payout incentives were greater than material costs for individual products, which could lead to abuse. In rebuttal testimony, Dominion Energy pointed out that those assessments did not include labor costs.
  2. Customer Engagement Program: SCC staff were concerned about non-response rates and wanted the Company to provide traditional savings analysis for this program, which the Company did not do. An employee of the vendor took the stand to explain that behavioral programs cannot be analyzed in the way Staff was requesting, which was the reason the Company was unable to provide analysis. He then walked through how a behavioral program is assessed. According to our expert witness, Rachel Gold, who has worked for another leading company in this field, what he described is a standard practice used to evaluate these types of programs across the country.
  3. Non-Residential Heating and Cooling Efficiency Program: Staff’s concerns regarding this program were twofold; the TRC test score and participation rates. The Company rounded the TRC test score from 0.9965 to 1.00 in their application. Staff argued that 0.9965 was not “1” and therefore this program did not pass three of four cost tests as required by the statute. Judge Jagdman asked a clarifying question on the exact language of the statute indicating that she, at least, may be inclined to approve this program. Staff also stated they had concerns regarding the Company’s projected participation rates for the proposed program because the actual participation rates in the current program are far below the projected rates, and the new projected participation rates are even higher than the projected rates for the current program.
  4. Non-Residential Office Program: The issue with this program was related to the building size used in the modeling for the program. SCC staff stated that the Company was using office space of 100,000 sq. ft., which they were concerned was unrealistic and would therefore result in overstated cost-savings estimates. A Company witness from the vendor for this program testified that the program was modeled using 80,000 sq. ft. buildings, not 100,000 sq. ft., and that, 80,000sq. ft. was, in fact, a typical office building size in Dominion Energy’s service territory.

The Commission has until June 3rd to make their decision. We will be sure to let our members know the outcome once we have a chance to review the Final Order, so stay tuned for updates.

Future DSM Filings

During the hearing, VAEEC Board Member, Michael Hubbard, with Dominion Energy, announced that the Company had released their RFP for their next DSM filing the week before for 15 new programs. We have had a chance to review a summary of the RFP which includes some exciting new programs such as:

  • Residential EE Retrofit
  • Residential New Construction
  • Home Energy Management System
  • Residential Multi-Family EE Program
  • Residential Manufactured Housing Program
  • Residential EE Kits
  • Residential Energy Advisor Program
  • Residential Electric Vehicle Program
  • Residential Enhanced Behavioral Program
  • Non-Residential Behavioral Program
  • Non-Residential Targeted-Sector Program
  • Non-Residential Upstream and Midstream Efficient Products Incentives
  • Non-Residential New Construction
  • Non-Residential Strategic Energy Management
  • Agricultural Energy Efficiency

We will continue to keep our members apprised of how these programs shape up for the next DSM filing in October 2019.

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