Today I (Bob) spent the afternoon in a room with utility conservation folks, discussing some friendly amendments to the rules (WAC 194-37) that enforce the I937 conservation statue. Department of Commerce hosted the meeting in the big Capitol building (see photo:) ), and all of the utility folks attending were from public power. I had proposed (in writing, two weeks ago) some language modifications, and was armed and ready for friendly criticism or looks of confusion about why I was interjecting myself into this forum. Much to my satisfaction, the response in the room was in general support, and nothing negative.
I proposed three changes:
- First, change the “utility paid for it” language to “utility reported it”, to remove the implied requirement that utilities have to “pay” for conservation. There are many ways that conservation is achieved, so let’s not pigeonhole ourselves here. General support for this one, just have to be sure we don’t inadvertently exclude anything along the way such as NEEA savings. All good there.
- Second, I proposed altering “conservation from programs for measures” to “programs or measures”. The intent here was to emphasize that the measures are what makes up conservation targets and achievements, and programs are but one avenue for conservation to be achieved. No comments hrere from the crowd.
- And finally, after the words “[a utility may claim] the total savings in customer efficiency measures” I added the words “regardless of the utility’s participation in or influence upon the installation of the measure.” Tacoma offered a friendly amendment, adding the word “direct” in front of “participation”. Friendly amendment accepted. And much to my satisfaction the room seemed to agree with my added language. The NWEnergy Coalition offered that so long as savings are in a utility’s conservation potential (and thus their target), they are comfortable with the language. Agreed! No negative comments for the record folks. Phew.
Rolling right along, as my guitar teacher growing up always said.
The comments that I submitted ahead of time can be read here. Tomorrow we repeat this process with the WA UTC (Utility and Transportation Commission) – the regulatory agency that oversees the (three) investor owned utilities. My comments for this one are nearly identical, and can be read here
Stay tuned for more updates. -Bob
