Case Background
On August 11,
2015, the Commission issued an order approving Tampa Electric Company’s (TECO
or Utility) Demand-Side Management (DSM) Plan. The DSM plan included TECO’s Neighborhood
Weatherization Program which was originally approved and implemented in March
2008 and the Energy Education, Awareness and Agency Outreach Conservation Program
(Agency Outreach Program) which was originally approved and implemented in
March 2010. The Neighborhood Weatherization Program is designed to assist low
income families in reducing their energy usage. The goal of the program is to
provide and install conservation measures at no cost to the customer. The Agency
Outreach Program allows for the delivery of energy efficiency kits that will
help educate consumers on practices that help reduce energy consumption.
On June 29,
2017, TECO petitioned the Commission for approval to modify its Neighborhood
Weatherization and Agency Outreach programs to replace the Compact Fluorescent
Lamps (CFLs) currently included as components of the energy efficiency kits for
a specified number of Light Emitting Diode Lamps (LEDs). This modification occurred
because the vendor that packages the energy efficiency kits for these programs no
longer procures CFLs due to a decrease in the price of LEDs.
The Commission
has jurisdiction over this matter pursuant to Sections 366.80 through 366.83
and 403.519, Florida Statutes (F.S.), collectively known as the Florida Energy
Efficiency and Conservation Act (FEECA).
Discussion
of Issues
Issue 1:
Should the Commission approve TECO’s petition to
modify the Utility’s Neighborhood Weatherization and Energy Education,
Awareness and Agency Outreach DSM programs?
Recommendation:
Yes. The change from CFLs to LEDs reflects changing
technologies and allows TECO’s programs to continue to advance the policy
objectives of FEECA. The programs are still directly monitorable, yield
measurable results, and continue to be reasonably cost- effective for education
programs. The program participation standards were submitted concurrently with
the program descriptions. Staff has reviewed these standards and recommends
that they are sufficient. Therefore, staff recommends that costs associated
with the modified programs be eligible for cost recovery through TECO’s Energy
Conservation Cost Recovery factor. (Mtenga, Morgan)
Staff Analysis:
The criteria used to review the appropriateness of
DSM programs are: (1) whether the program advances the policy objectives of
FEECA and its implementing rules; (2) whether the program is directly
monitorable and yields measureable results; and (3) whether the program is cost-effective.
Staff has reviewed TECO’s petition for approval of modifications to its Neighborhood
Weatherization and Agency Outreach programs and they appear to be consistent
with these criteria.
Program
Description
TECO
requests the Commission’s approval to modify its Utility’s Neighborhood
Weatherization and Agency Outreach programs to replace CFLs with LEDs. TECO states
that the vendor who packages the energy efficiency kits for the programs will
no longer be procuring CFLs for their energy efficiency kits due to a decrease
in the price of LEDs. The proposed change would decrease the number of lamps
provided in the Neighborhood Weatherization Program from eight CFLs to six LEDs,
and it will keep the number of lamps provided in the Agency Outreach Program
the same at four lamps. If approved, TECO will transition to the LEDs once the
supply of CFLs has been fully exhausted, which is projected to be around the
beginning of 2018.
FEECA
Policy Objectives/ Program Monitoring and Evaluation
FEECA
emphasizes reducing the growth rate of peak demand and reducing and controlling
the growth rates of electricity consumption. The change from CFLs to LEDs does
not fundamentally change TECO’s programs and no changes have been made to
existing programs monitoring. In the overall summer and winter demand (kW) and
annual energy (kWh) savings evaluations for both the Neighborhood Weatherization
and the Agency Outreach programs, the proposed LEDs provide similar demand and
energy savings that were originally provided by the current CFLs. The overall
summer and winter demand (kW) and annual energy (kWh) savings for each of the
programs modified are provided below in Tables 1-1 and 1-2.
Table 1-1
Estimated Program Savings
per Participant: Neighborhood Weatherization
|
|
Summer Demand (kW)
|
Winter Demand (kW)
|
Annual Energy (kWh)
|
|
CFLs
|
0.241
|
0.337
|
1,222
|
|
LEDS
|
0.245
|
0.339
|
1,255
|
Source: TECO’s petition for approval of modifications to
programs
Table 1-2
Estimated Program Savings
per Participant: Agency Outreach
|
|
Summer Demand (kW)
|
Winter Demand (kW)
|
Annual Energy (kWh)
|
|
CFLs
|
0.025
|
0.046
|
342
|
|
LEDs
|
0.027
|
0.049
|
377
|
Source: TECO’s petition for approval of modifications to
programs
Cost-Effectiveness
Review
Pursuant
to Rule 25-17.008, Florida Administrative Code, TECO provided a
cost-effectiveness analysis of the programs using the Participant test, the
Rate Impact Measure (RIM) test, and the Total Resource Cost (TRC) test. The
Participant test analyzes the cost and benefits from a program participant’s
point of view. The RIM test ensures that all ratepayers will benefit from a
proposed DSM program, not just the program participants. The TRC test measures
the overall economic efficiency of a DSM program from a social perspective.
Each test estimates the benefits and costs and the program is determined to be
cost-effective if the ratio of benefits to costs is greater than one. Staff has
reviewed the assumptions associated with TECO’s program savings and recommends
that they are reasonable. Tables 1-3 and 1-4 below, show the results for the
cost-effectiveness for the existing CFLs and the proposed LEDs.
Table 1-3
Cost-Effectiveness Test
Results: Neighborhood Weatherization
|
|
Participant Test
|
RIM Test
|
TRC Test
|
|
CFLs
|
36,560
|
0.66
|
6.93
|
|
LEDs
|
36,448
|
0.63
|
6.14
|
Source: Staff’s Data Request No. 3 and TECO’s petition for
modifications to programs
Table 1-4
Cost-Effectiveness Test
Results: Agency Outreach
|
|
Participant Test
|
RIM Test
|
TRC Test
|
|
CFLs
|
591
|
0.70
|
4.14
|
|
LEDs
|
651
|
0.69
|
4.01
|
Source: Staff’s Data Request No. 3 and TECO’s petition for
modifications to programs
Based on these cost-effective results, the proposed program
modifications would continue to pass the Participants test and the TRC test,
but fail the RIM test which is similar to the previously approved programs.
Because these programs are educational in nature, it may not be possible for
such programs to pass cost-effectiveness tests due to the difficulty in
measuring the amount of savings. Educational programs are intended to inform
ratepayers about behaviors and the impact of electricity consuming devices. Therefore,
staff believes that the program is beneficial in meeting the goals of FEECA.
Conclusion
The change
from CFLs to LEDs reflects changing technologies and allows TECO’s programs to
continue to advance the policy objectives of FEECA. The programs are still directly
monitorable, yield measurable results, and continue to be reasonably cost-effective
for education programs. The program participation standards were submitted
concurrently with the program descriptions. Staff has reviewed these standards
and recommends that they are sufficient. Therefore, staff recommends that costs
associated with the modified programs be eligible for cost recovery through
TECO’s Energy Conservation Cost Recovery factor.
Issue 2:
Should this docket be closed?
Recommendation:
Yes. If no person whose substantial interests are
affected by the proposed agency action files a protest within 21 days of the
issuance of the PAA Order, a Consummating Order should be issued and the docket
should be closed. (Cuello)
Staff Analysis:
If no person whose substantial interests are
affected by the proposed agency action files a protest within 21 days of the
issuance of the PAA Order, a Consummating Order should be issued and the docket
should be closed.
