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12.18.20 - Inclusive Financing Moving Forward in VA & CA



California Clean Financing Rulemaking Pre-Hearing Scheduled!


  • The California Public Utilities Commission’s Order Instituting Rulemaking to Investigate and Design Clean Energy Financing Options for Electricity and Natural Gas Customers (Rulemaking 20-08-022) has issued an email ruling (attached) which sets February 5, 2021 as the date for the pre-hearing conference (PHC).

  • PAYS Pals will recall that the audience for this rulemaking is very large because it consolidated financing topics from 16 other rulemakings! Backstory: The California Energy Efficiency Action Plan recommended that the CPUC adopt inclusive financing. Rather than working to approve inclusive financing for renewables, energy efficiency, transportation, building electrification, and community storage in various separate dockets, the inclusive financing rulemaking was introduced as a single proceeding for all distributed resources and assigned to an administrative law judge.

  • Interested parties who intend to speak at the PHC must email the name and title of the party representative to Administrative Law Judges Sisto and Fitch no later than February 1, 2021

  • “IT IS RULED, parties should come to the PHC prepared to discuss:

  • any and all facts and legal issues that are associated with but not stated in the instant application that require resolution through the submission of testimony

  • the timing and number of public participation hearings (if any) are necessary in this proceeding

  • the timing and need for evidentiary hearings (if any);

  • and any other issues directly related to the case management of this proceeding.”

  • Anthony Kinslow II, Ph.D. and Holmes Hummel, Ph.D., our fellow PAYS Pals at Clean Energy Works, have been tracking this proceeding, building coalitions, and organizing responses!


Virginia SB754 Stakeholder Meeting Dates Scheduled!


  • PAYS Pal Andrew Grigsby at Virdiant notified us that the the Virginia, Maryland & Delaware Association of Electric Cooperatives (VMDAEC), which serves the thirteen electric co-ops in Virginia, will lead the coordination of a statewide stakeholder meeting process which is required by SB 754 before coops launch their tariff based energy efficiency upgrade programs! VMDAEC has set the following dates for the stakeholder meetings:

  • Jan. 22: 1-3PM

  • Feb. 12: 10-12PM

  • Mar. 19: 10-12PM

  • Apr. 23: 10-12PM

  • The announcement is very welcome as the statute did not specify a statewide stakeholder meeting. By doing so, VMDAEC is enabling all coops to fulfill this requirement quickly and efficiently. VMDAEC’s decision will also allow for a collective due diligence process that sets the stage for what would be the first state where 100% of the cooperatives are offering inclusive, tariffed-based programs for energy efficiency home upgrades! Sam Brumberg at VMDAEC is reported to be coordinating this process!

Here’s a backgrounder for those unfamiliar with SB754

  • On April 7, 2020, the Governor of Virginia signed into law SB 754, a bill that passed unanimously in both chambers of the state legislature to expedite the path electric cooperatives can take to implement site-specific investments for energy efficiency by electric cooperatives that are more inclusive than loans.

  • Based on field experience reported by electric cooperatives in 5 states (Arkansas, North Carolina, Kansas, Kentucky, and Tennessee), Virginia cooperatives could capitalize $100 million in home energy upgrades by reaching 2% of its member-owners each year.

  • Energy cost-savings to both the utility and recipients of energy upgrades provide meaningful aid at a time when so many are struggling to cover basic household expenses, and the investments provide essential local economic stimulus, generating jobs in Virginia’s rural counties that cannot be exported.

  • The new statute conditionally exempts from initial regulatory review any tariffed on-bill investment programs offered by electric cooperatives for energy efficiency upgrades.

  • The law allows the first investment programs to launch on January 1, 2021, on the condition that a stakeholder process occurs at least 120 days in advance.

  • The law anticipates remote participation in a stakeholder process to “collaboratively” design a tariffed on-bill investment program for energy efficiency upgrades to houses and other premises.


  • The statute prescribes the required stakeholder process as having the following characteristics:

  • A cooperative shall conduct a stakeholder process to design the on-bill tariff program collaboratively with interested parties.

  • Such stakeholder process shall be open to the cooperative’s membership and invited guests and shall include an opportunity to participate for low-income and middle-income advocates, energy efficiency advocates, affordable housing advocates, and the staff of the Commission.

  • The stakeholder process shall examine and recommend, among other things, appropriate additional consumer safeguards for potential adoption by the cooperative, including oversight of third-party vendors and appropriate methods for notifying customers that vendors are subject to the Virginia Consumer Protection Act (Section 59.1-196 et seq.).

  • The stakeholder process shall allow for remote or electronic participation and may include multiple cooperatives or be coordinated, convened, and facilitated by a group or association of cooperatives.

  • The meetings of the stakeholders may be held anywhere in the Commonwealth.

  • The cooperatives shall include documentation concerning the stakeholder process in its informational filing to the Commission.

  • Thereafter, the electric cooperative may propose a tariffed on-bill investment program to its governing board for implementation. If the board approves a tariff for a tariffed on-bill program, the electric cooperative would then file a copy of the tariff along with documentation of the stakeholder process with the Virginia State Corporation Commission.

  • The State Corporation Commission can later review and accept the terms of the tariff at the cooperative’s next general rate case—or reject the tariff if the SCC finds the tariffed terms are not cost-based, non-discriminatory, just, reasonable, and fair.

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