In the Commission's October 2007 decision, the utilities were ordered to create a long-term strategic plan through 2020. The Plan would serve as the foundation for the informing the 2009-2011 energy efficiency portfolios. The Commission ordered the utilities to provide:
- A draft Strategic Plan - by Feb 1, 2008
- A Revision of the Strategic Plan - by May 15, 2008
DRA supports the Commission's leadership to change the paradigm of energy efficiency and conservation to one that is an integral part of "business-as-usual" and believes the long-term plan is an essential element to achieving this shift.
To be effective, DRA believes that a Strategic Plan "must" guide the development and content of the utilities' $2 billion+ ratepayer funded energy efficiency portfolios. Instead, in a cart-before-the-horse process, the Commission has allowed the utilities to formulate portfolios before a Strategic Plan has been finalized or approved by the Commission. As DRA describes in our comments and protest (available below), the current version of the Strategic Plan describes issues and barriers, but does not provide a roadmap for how to implement programs and increase changes in the market through 2020, as the Commission directed.
Draft Strategic Plan
DRA does not believe that the utilities' draft Plan served on stakeholders in February 2008 (nor its supplemental draft published in March 2008) meets the Commission's direction to create a detailed roadmap to optimally pursue energy efficiency in California across multiple market sectors and jurisdictions for the next 12 years. The utilities will submit their final version of the plan on June 2, 2008.
- DRA's submitted Comments on the draft Long-term Strategic Plan
Revised Strategic Plan
The investor-owned utilities filed a revised Strategic Plan on June 2, 2008. While the Plan may serve as an informative white paper that summarizes the Commission's strategic planning process, which began in the summer of 2007, it does not serve as a roadmap to how to implement and achieve strategic objectives.
Accordingly, DRA supports the Commission's decision to open a new proceeding on strategic planning that would move development and management of the Strategic Plan to the Commission's Energy Division. However, DRA continues to believe that for the Strategic Plan to be meaningful, it must guide the development of the utilities multi-billion dollar energy efficiency portfolios.
DRA protested the utilities' June 2 Strategic Plan applications for these reasons:
The June 2 Strategic Plan fails to provide a long-term roadmap through 2020: The June 2 Strategic Plan summarizes the Conveners Report from the workshop process that identifies barriers and strategies, but it does not provide a roadmap for how to implement those strategies in the next round of portfolios, and there is little strategy articulated beyond 2011.
The Strategic Plan and the proposed new Order Instituting Rulemaking (OIR) should be the umbrella for integrated Demand Side Management (DSM) and include other relevant energy programs, not solely energy efficiency: The Strategic Plan should cover Integrated DSM efforts otherwise the OIR process is only reinforcing bureaucratic silos by sub-dividing Energy Efficiency.
DRA supports Energy Division’s assumption of responsibility for the Strategic Plan through the new OIR process in order to continue the Commission’s leadership role across jurisdictions to promote statewide coordination:DRA recommends the process be carried out under the guidance of a stakeholder advisory Task Force and with the assistance of a consultant that has expertise in developing long-term strategic plans.
Market transformation rules and measurement must be defined in order for a strategic planning process to be successful: Such market transformation strategies should also be applied to the energy efficiency portfolios for which they provide guidance.
The next round of energy efficiency portfolios must be guided by a finalized Strategic Plan: The strategic planning process will be rendered meaningless unless one-year bridge funding is provided so that portfolios are developed that truly reflect the Strategic Plan.
Read DRA's full protest.
Links of Interest
You may also be interested in visiting the Commission's webpage on strategic planning, where you may view all the materials, presentations, and stakeholder input from this process. This website also contains the compiled Conveners Report appendices as supporting documentation to the Strategic Plan.