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12.4.20 - PAYS® updates in VA, MN, and WA

Updated: Dec 15, 2020

Update on VA where SB754 Pre-approved all Coops for TOB Programs!


Tammy Agard, fellow PAYS Pal and CEO of EEtility, was invited by the Old Dominion Electric Cooperative, Virginia’s generation & transmission (G&T), which serves almost all of the VA distribution cooperatives, to address a monthly meeting of several member energy managers on the concept of Pay As You Save and on the realities of operating PAYS programs. While the Virginia coop's initial program volumes are too low for EEtility to be the program operator on the ground, EEtility is working closely with Viridiant, a local non-profit program operator and fellow PAYS® Pal, to explore how a co-delivery partnership will work! EEtility is eager to partner with other mission aligned program operators to co-implement PAYS in other areas and is very excited for this opportunity to premier their strategy for PAYS® at a meaningful scale!

Thanks to PAYS Pal Alice Madden from the Community Power Network, we have an update on Minneapolis!


The Office of Administrative Hearings (OAH) issued a judgment (attached) recommending that the PUC should approve the “TOB Stipulation”. Although the final PUC decision won’t be till February, here’s the summary of what the administrative law judge decided:

  • The OAH thinks the PUC has legal authority to approve the tariff

  • The OAH thinks that Tariffed on-bill inclusive financing has merit and approved the TOB program as stipulated between the City of Minneapolis and CenterPoint Energy which means:

  • 500 participants enrolled each year for the first 3 years starting with the City of Minneapolis until it becomes "feasible" for other communities to enroll.

  • And that “the remainder of the program costs, including items such as capital, operations and maintenance, administration, program delivery, and call center integration, would be subject to deferred accounting and placed in a tracker for possible later recovery in a future rate case.”

  • We take this to mean that the OAH has not decided how or what the ROE piece of the TOB program will be. We will keep watch for the final decision in Feb. 2021!

Hassan Shaban, fellow PAYS Pal and Founder of Empower Dataworks, is helping to introduce PAYS as a solution for energy equity in the Northwest!


  • Hassan invited LibertyHomes to give a presentation to Chelan PUD (central WA) on how PAYS could be a vehicle for complying with WA's Clean Energy Transformation Act (CETA). CETA's primary focus is on measuring and reducing energy burdens, so program implementation is only one step in the process, but PAYS fits in perfectly with the Energy Equity Flywheel framework and closes the loop on data-driven program implementation, by relying on data, analysis and program targeting:

  • Although Chelan’s rates may be too low (between 3 and 9 cents/kWh) to make many certain measures cash flow positive in the Northwest, PAYS can be implemented alongside utility incentives and will help eliminate customer co-pays, reduce incentives for some measures, and expand to deeper measures using the same program budgets.

  • We received very positive feedback after the call and have been asked to provide a 4-6 page write up on additional details about PAYS. It is our hope that PAYS as a tool for CETA compliance will make it appealing to the other 50-60 utilities in Washington state!


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