As reported in last month’s newsletter, the Washington Utilities and Transportation Commission is continuing its formal investigation of numerous elements of Puget Sound Energy’s expanded conservation program filing for 2010-2011. The WUTC staff and the Public Counsel (Attorney General) have raised questions about the prudency of PSE’s desire to expand its conservation program spending in a number of key areas. No timeline for this investigation has been offered by the WUTC. Both the WUTC staff and Public Counsel are participants of PSE’s Conservation Resource Advisory Group (CRAG) and were involved and informed on the utility’s conservation program intentions throughout 2009. NEEC concerns over the market drag that results from this sort of delay prompted the following communication to David Nightingale of the WUTC, following his announcement that an anticipated public discussion on the investigation was being furthered delayed.
As a member of Puget Sound Energy’s Conservation Resource Advisory Group (CRAG), I am very concerned and troubled by recent actions by the WUTC and Public Counsel with regard to the energy efficiency program at PSE. This most recent announcement only exacerbates those concerns.
I was very surprised in December to hear that both Public Counsel and WUTC staff were calling into question the expansion by PSE of its efforts to both support an aggressive energy efficiency program and to budget adequately for the acquisition of the resource. The CRAG was, in my view, fully informed of PSE’s intentions to do this throughout 2009. The trajectory of the utility’s ambition for efficiency acquisition was established both by its year to year performance and by clearly stated projections of its intentions in future years. The CRAG had ample opportunity to review and comment on PSE program performance and the utility’s future intentions. To my ear, the utility had the clear support of CRAG members to pursue this path. More specifically, the utility provided information to the CRAG on areas of program expansion where it believed there was good reason and sufficient supporting data to justify that expansion. This certainly included the areas that are now subject to the WUTC Investigation.
The participants on the CRAG represent some of the most experienced individuals in the region in the area of energy efficiency. Personally, I have been in this industry over 30 years. Colleagues on the CRAG have equal or greater experience and expertise in planning, designing, managing, and evaluating energy efficiency programs in this region. Plainly speaking, the actions of the WUTC in this matter seem to be unwarranted based on the review and feedback of the majority of CRAG members. Moreover, this clear distraction is causing market interruptions which slow the pace of energy efficiency acquisitions and increase cost. As energy efficiency acquisition is deferred, the delay places the lowest cost and most environmentally responsible energy future in jeopardy. This would hardly seem to be in the public interest.
Your most recent e-mail now indicates that you need more time for this investigation, but you provide no estimate of when this process will proceed and reach a conclusion. Frankly, that just seems unacceptable. As a representative of the private businesses who work with residential, commercial, and industrial customers every day to help fashion good energy management solutions that meet their needs, this confusing signal and time delay is unwarranted. From the highest elected office in the United States, through regional, and state elected leadership, end use customers are being encouraged to implement energy efficiency solutions in their buildings. At the very time in which national attention and encouragement for action is greatest, the WUTC is creating delay and uncertainty.
I ask that you proceed with all due haste to clarify whatever concerns that remain in this matter. Utility’s with aggressive energy efficiency programs are in step with national and state priorities. Those who would inhibit and delay those actions are not.
Stan Price, Executive Director
Northwest Energy Efficiency Council
605 First Ave. Ste. 401
Seattle, WA 98104