5.1.20 - Georgia Power & PAYS
Updated: Aug 31, 2020
Hi PAYS®Pals, here's your weekly newsletter!
Newsflash: Update On Georgia Power's Income Qualified Tariff-Based Energy Efficiency (IQTBEE) Pilot
There has been broad concern within the PAYS community about some of the provisions in Georgia Power's tariffed based program plan (files attached) including their proposed $7,500 per home investment cap, elimination of copays,10-yr instead of 12-yr cost recovery term, income testing, and their use of the DSM rider to cover deficiencies even after they are earning a high levelized annual return despite a low-risk program.
In an effort to illustrate the negative consequences of such a plan, EEtility and LibertyHomes conducted a simulation analysis to calculate the impact of GA Power's restrictions on the number of homes served. They pulled all Roanoke and Ouachita home data, excluded fuel switched and mobile homes since GA Power's Plan is an all-electric and stick-built pilot, and applied GA Power's specific restrictions and $1,000/home rebate in order to show the decrease in the number of homes that get a no-cost weatherization and HVAC replacement offer. As seen in the table below from this analysis, EEtility normally nets 500 no-cost Wx + HVAC upgrades for every 834 homes visited (due to having to turn away homes with poor structural integrity and the 10% that decline a no-cost offer). After applying all of GA Power's program restrictions, it was found that EEtility would only net 265 no cost Wx + HVAC offers for every 834 homes visited and the total program energy savings are reduced by 54%.
After seeing this presentation, Georgia Power has agreed to remove the $7,500 max per house budget in their filing and replace it with a $7,500 average cost instead! They will also remove the income qualification test and opt for EEtility's best practice which is to prioritize those homes with the highest energy use per sqft (energy intensity) within persistent poverty zip codes!
For EEtility and PAYS Pals, this is great news as many more low-income people will be able to be served. Fingers crossed that the commission approves the pilot with this very important change!
Other folks in the PAYS® community are submitting constructively critical comments to the GA Public Service Commission, entering all the issues previously raised into the public record while expressing strong support for the pilot and its objectives. See attached one such letter from the Southern Environmental Law Center, Southface, and GA Interfaith Power and Light filed with the GA Public Service Commission.
Hear our very own PAYS Pal, Mr. Wally Nixon, speak about Leapfrogging OBF with Tariff-Based Financing!
Mr. Wally Nixon was the featured speaker in the Smart Energy Consumer Collaborative's "Engaging Lower-Income Consumers in Energy, Part I" webinar yesterday! He was invited to share his experience as legal counsel to the Arkansas Public Service Commission when Ouachita Electric Cooperative Corporation (OECC) was transitioning its loan program to a tariff-based system. Wally gave a superb overview of debt-based financing vs tariffed-based financing and then discussed how the tariffed-based PAYS system produced far superior results in meeting the needs of OECC's underserved communities (he cites that EEtility got 3X participation, increased that average invested amount, and injected 2.8M in the local community over the first 3 years) while also producing benefits for the utility (cites 2kW saved per home = $250-300/home/yr) such that OECC could file for a 4.5% rate decrease!
His slides are attached and here's the recording!
About 200 people were in attendance, most of whom were utility representatives and about 65 people stayed on for the Q&A where Tammy Agard, CEO of EEtility, joined Wally to field questions including:
How much staff time would a utility have to add to run a tariffed program? Tammy answered that because her services are completely turnkey, none of her utility customers have had to add any staff. Utilities just have to share data on the front end and place a tariffed-charge on the back end which requires far less than one FTE.
What are the main challenges to implementing PAYS®? Tammy and Wally both confirmed that overcoming the "too good to be true" barrier is the toughest part with consumers, commissions, and utilities.
What have commissions liked about PAYS®? Wally and Tammy both confirmed that the built-in consumer protections and zero consumer risk are the key value propositions to commissions.
What is the cost of OECC's program?
Tammy answered that EEtility's implementation of PAYS® for all their programs has averaged $0.021/kWh saved. To put this into context, the low-income program average for the U.S. is $0.134 and the average for all residential programs is $0.03 according to the LBNL graphs below from this report. EEtility's cost is 30% lower than the average for efficiency programs in general and 85% lower than the average cost for low-income programs. FYI - If someone quotes a lower number for the average cost they are referencing the national average for residential programs is $0.19. This counts all programs whether they claim savings or not and reflects large quantities of extremely low-cost lighting savings.