BPA Educates PA PUC on Cost Effectiveness Testing Reforms
As the Pennsylvania Public Utilities Commission (PA PUC) gears up to implement Phase IV of Act 129, BPA and a coalition of Pennsylvania based non-profit groups have launched an education campaign to bring the best practices in energy efficiency programs from around the country to Harrisburg.
On October 28, 2019, the National Efficiency Screening Project conducted a briefing session on National Standard Practice Manual reforms for PA PUC staff. Attendees were able to learn from NSPM case studies about how states like Arkansas, New Hampshire, Rhode Island and Minnesota are modernizing and updating their cost effectiveness testing practices to advance energy efficiency programs, create jobs, save ratepayers money and make utility systems more reliant and resilient.
On November 1, 2019, a coalition of PennFuture, the Pennsylvania Chapter of the Sierra Club, the Clean Air Council, the Philadelphia Solar Energy Association, NRDC and the Building Performance Association filed comments before the PA PUC on 2021Total Resource Cost (TRC) Test Tentative Order of September 19, 2019 at Docket No. M-2019-3006868. The joint comments urged the PA PUC to consider reforms to take advantage of the fastest growing clean energy industry in the U.S. – energy efficiency.
The joint comments noted that the energy efficiency opportunity for Pennsylvania is enormous. However, according to Energy Efficiency Jobs in America, Pennsylvania’s 68,820 energy efficiency jobs are approximately just one half of the per capita employment rate of neighboring Maryland. The joint comments saluted the PA PUC for some of the proposed changes made in the Tentative TRC Order of September 19, 2019, but added the following suggestions:
- We believe that job creation and economic development impacts are and should be critical considerations in the policy making deliberations of all Pennsylvania state agencies, offices and commissions;
- We respectfully request that the PA PUC commence a process that applies the NSPM to the Act 129 Total Resource Cost test;
- We strongly urge the PA PUC to devote more time, attention and resources to its updates of the TRC Manual and the Pennsylvania Technical Reference Manual (PA TRM);
- We encourage the PA PUC to re-examine the basis for its 2015 decision on “non-electric benefits” or non-energy impacts and provide additional details on why that position merits continued support in 2019; and
- We respectfully request that the PA PUC consider all of the Commonwealth’s policy goals prior to approving the Tentative Order by conducting an NSPM review of the PA TRC.
Because a few November 1, 2019 comments at Docket No. M-2019-3006868 discounted the value of demand response programs in Pennsylvania, BPA also submitted Reply Comments on November 12, 2019. BPA’s Reply comments cited recent studies on demand response programs demonstrating that “customer benefits include utility bill savings, easier program participation, increased resource and service options, and greater satisfaction.” Given the success of technical advisory councils in other states, the BPA Reply comments also concluded with a request that the PA PUC “maintain its current policies toward DR and consider creating an advisory council or stakeholder group on energy efficiency policy issues.”
BPA and coalition partners will continue to monitor progress at the PA PUC on cost effectiveness testing reforms and educate PA stakeholders on how other states are moving forward and innovating on energy efficiency program reforms.