Staff Response: Comparative list of recommendations - November 20, 2015 — original pdf

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Item #Recommendations as Cited in LICATF FINALReportRecommendationCurrent StatusBudget ImpactFeasibilityAE ResponseRecommendation in Exec SummaryPageRecommendation in Body of FINAL doc1Austin Energy should develop better tracking data by energy efficiency program and city council district to: measure energy and demand savings, including consumption data measuring the actual customer usage both before and after the customer benefited from an energy efficiency program; analyze the demographics of program participation while protecting privacy data; and demonstrate coordination with other publically funded programsUnderwayModerateHighWith recently acquired Census data as well as a nascent data clearinghouse, we are now able to attach Census tract to premises. We will be able to report demographics without infringing on customers' privacy.Austin Energy should improve and make more transparent the tracking of its energy efficiency programs.21Austin Energy should improve and make more transparent the tracking of its energy efficiency programs.22All Austin Energy programs funded with revenues realized from the energy efficiency rate should be consistently reported to the public, the City’s advisory commissions and the Council. (Current practice)22All program costs funded with energy efficiency dollars should be consistently reported and the operations and maintenance costs should be separated out from the rebates and other direct costs of the program (Current practice; but unable to allocate/track admin costs associated with specific programs due to accounting system limits)23In any budget presentation to support its energy efficiency rate proposal, Austin Energy should not include any energy efficiency program costs funded with Customer Assistance Program revenues. (current practice)23Austin Energy should develop better tracking data by energy efficiency program and city council district to: measure energy and demand savings, including consumption data measuring the actual customer usage both before and after the customer benefited from an energy efficiency program; analyze the demographics of program participation while protecting privacy data; and demonstrate coordination with other publically funded programs (underway)24Austin Energy should provide monthly, quarterly and annual reports to the Resource Management Commission, Electric Utility Commission and City Council indicating energy efficiency, CAP Weatherization, Demand Response, Green Building and Solar activities and City Council should establish accountability procedures. (current practice)14Improving transparency, reporting and accountability for the energy efficiency, demand response and solar programs (current practice)21One key recommendation is requiring an improved annual report that would break out information not only by program but by City Council District. (underway - will report FY15 data accordingly)2Establish the long-term demand and energy saving goals for Austin Energy for its demand response and energy efficiency programs, as well as a specific demand, energy savings and units weatherized as part of the weatherization goalsCurrently a part of AE ProcessLowHighWe currently have a 900 MW goal for 2025. For each budget year, we establish program goals based on budget available.Adopt overall program goals and goals specific to low income programs.14Establishing the long-term demand and energy saving goals for Austin Energy for31recommends that the utility move forward with a program designed to meet specific goals and to evaluate the program in accordance with those goals3Allow for a mid-course “true-up” correction in the annual budgets – with City Council oversight -- for the energy efficiency, demand response and solar programsCurrently a part of AE ProcessLowHighAnnually, Austin Energy completes a financial audit to assess all budget versus actual expenditure. Tariffs are adjusted periodically to reflect over/under collection. To avoid wide fluctuations in customer tariffs, some tariffs, such as the CBC are adjusted every 3-5 years. The FY16 budget reflected such a true-up and concomitant reduction in the CBC. Staff has recommended that any unspent net AE free weatherization budget variances be rolled over to the following FY.Establish an annual energy efficiency accounting true-up schedule14-15Allowing for a mid-course “true-up” correction in the annual budgets26The City Council should establish a true up proceeding for the energy efficiency rates within six months after the close of each fiscal year to reconcile any over or under recovery of Austin Energy’s energy efficiency revenues, realized and imputed, attributable to the energy efficiency rate for that recently closed fiscal year with that fiscal year’s energy efficiency expenses, including operations and maintenance, incurred by Austin Energy. 4Adopt a more expansive “triple bottom line” evaluation such as the Societal Cost Test in considering the benefits and costs of energy efficiency and solar programs, including low-income energy efficiency and weatherizationTo be part of FY16 processLowHighWe will be adding the Societal test as a way to measure the "triple bottom line" approach recommended by the task force. This test was chosen as a way to counter some of the limitations of non tangible costs that come with the triple bottom line and the difficulty in applying this approach to measure program effectiveness (compared with the typical application in assessing purchasing alternatives).Adopt the triple bottom line used by the City of Austin Sustainability Office for program cost-effectiveness evaluation using a methodology such as the Societal Cost Test.14 Adopting a more expansive “triple bottom line” evaluation such as the Societal Cost Test19Expand the cost effectiveness test for evaluating energy efficiency andrenewable energy program incentives that benefit low and low moderate income homeownersand renters to include the energy and non-energy benefits not included in current calculationsusing a methodology such as the Societal Cost Test. 20We further recommend that funds in the CAP and free weatherization program be used as much as possible during the cooler months (September through April) when the work demand for the Austin Energy contractors is at its lowest5Investigate operating practices that could potentially increase the cost effectiveness of the low income weatherization program while maintaining all program services and standards and report back to City Council in six months with a strategy for implementationTo be part of FY16 ProcessModerateModerateThe costs reported in the LICATF report are a reflection of inflation based on contractor pricing. These increases are a function of general economics, as seen through a cost of living increase from 2005 to 2015.Conduct a weatherization program cost reduction study.33The City Council should direct the City Manager to investigate operating practices that could potentially increase the cost effectiveness of the low income weatherization program6City departments that provide services to low and low-moderate income customers based on income eligibility should use a universal application form that is not only processed by the receiving department but is also immediately referred to the other respective departments and the Health and Human Services Department should be the residual department to screen energy efficiency program applicants for income eligibilityUnder considerationModerateModerateAE currently works with several city departments and utility service providers in a coordinated effort to assist our low income customers. The process to create a universal application form will need to include specific data privacy parameters to which AE is held. Additionally, there will need to be a secure database where customer data is stored for universal access to the applications. AE is testing this approach with customers in the Holly and Rundberg Lane neighborhoodsEstablish a universal application process where city departments use a common application form that is immediately processed by the receiving department and referred to other respective departments.34The City departments that provide services to low and low-moderate income customers based on income eligibility should use a universal application form that is not only processed by the receiving department but is also immediately referred to the other respective departmentsRecommendations from original matrix based on LICATF report voted on September 25Create a residential energy efficiency program to provide low interest financing for Austin Energy customers with low and low moderate family incomes to purchase and install Energy Star window heating and/or cooling unitsTo be part of FY16 ProcessModerateHighDuring the Affordable Energy Policy Summit, this recommendation was presented to several social service agencies that partner with AE to support low income customers. The overwhelming response was negative, fearing that AE would be loaning money to customers who could not afford increased household costs, thus setting them up for further financial failure.This requires Department of Energy approval (to amend grant terms associated with funding Velocity Credit Union revolving loan provisions). Applicable to Low Moderate Provide low-interest loans for purchase and installation of Energy Star window units for energy efficient heating and/or cooling.43Create a residential energy efficiency program to provide low interest financing for Austin Energy customers with low and low moderate family incomes to purchase and install Energy Star window heating and/or cooling units7A residential moderate income energy efficiency program should be created to provide low interest financing for Austin Energy customers with low moderate family incomes to weatherize their homes and to purchase energy efficient cooling and/or heating appliances.Under considerationModerateLowSee above.Provide low interest loans for comprehensive energy efficiency to low moderate income homeowners to weatherize their homes and purchase energy efficient cooling and/or heating appliances.45A residential moderate income energy efficiency program should be created to provide low interest financing for Austin Energy customers with low moderate family incomes to weatherize their homes and to purchase energy efficient cooling and/or heating appliances8Austin Energy should allow for repayment for energy efficiency retrofits on a customer’s monthly utility bill. Financing would come from a third-party not from the utility itself. Rebates should also be provided for qualifying measuresUnder considerationHighModerateThis recommendation will mean a change to the current billing system as well as the need for additional tracking methods to ensure that payments are made and are not impacting AE debt or customer service. Staff will assess prospectively.Allow for repayment of energy efficiency retrofits on a customer’s monthly bill.38Austin Energy should allow for repayment for energy efficiency retrofits on a customer’s monthly utility bill.9A residential low income weatherization rebate pilot program should be implemented in conjunction with the affordable housing retrofit programs administered by the City’s Neighborhood Housing and Community Development Department to obtain efficiencies of scopeUnder considerationModerateModerateMuch of what is in the recommendation currently exists in the relationship AE has the with Housing Repair Coalition. The primary difference of AE releasing money to the Housing Repair Coalition would require additional fund tracking.AE cannot purchase items in bulk in a cost-effective manner.Additional appliances, while they may be Energy Star, do not equate to energy savings, but may lead to increases on the electric bill.Provide a contractor rebate pilot program to allow weatherization work to be completed in conjunction with affordable housing projects.40a residential low income weatherization rebate pilot program should be implemented in conjunction with the affordable housing retrofit programs administered by the City’s Neighborhood Housing and Community Development Department to obtain efficiencies of scope10A residential low income energy efficiency program should be created to provide Energy Star window heating and/or cooling units including installation to low income customers who are certified by the medically vulnerable customer registry of Austin EnergyCurrently a part of AE ProcessModerateHighThis change was effected in FY15.Create a residential low income energy efficiency program to provide Energy Star window heating and/or cooling units including installation to low income households who are certified by Austin Energy’s medically vulnerable registry42A residential low income energy efficiency program should be created to provide Energy Star window heating and/or cooling units including installation to low income customers who are certified by the medically vulnerable customer registry of Austin Energy11All unspent Energy Efficiency Services (EES) low-income weatherization funds, specifically reserved to low income customers since the Customer Benefit Charge (CBC) tariff went into effect should roll over to the next budget year, similar to the manner in which Customer Assistance Program (CAP) weatherization funds roll overTo be part of FY16 processModerateModerateThis should be possible, with guidance from City Financial office.All unspent Energy Efficiency Services (EES) low-income weatherization funds should roll over to the next budget year.32All unspent Energy Efficiency Services (EES) low-income weatherization funds, specifically reserved to low income customers since the Customer Benefit Charge (CBC) tariff went into effect should roll over to the next budget year12Set a goal that a minimum of 25% of the total Energy Efficiency Services budget including administrative expenses should be spent on programs that help low and low-moderate income residential customers, with at least 10% of the Energy Efficiency Services budget dedicated to a free weatherization program. Not recommendedHighLowThis recommendation would impact current budgets (see above) and would increase commercial subsidization of residential programs, creating an equity issue. Three separate staff analyses of the budget example ($42M) showed a decrease in achievable savings, resulting in greater obstacles to achieving the 900 MW goal by 2025.A minimum of 25% of the Energy Efficiency Services budget should be spent on programs that help low and low moderate income residential customers, with at least 10% of the budget dedicated to the free weatherization program.18The City Council should set a goal that a minimum of 25% of the total Energy Efficiency Services budget including administrative expenses13Furthermore, as part of the recommendation to spend at least 25% of the overall Energy Efficiency Services budget, at least 15% of the total distributed solar energy budget for new projects should be dedicated to projects that benefit low and low moderate income customersNot recommendedHighLowThis recommendation would impact current budgets (see above) and would increase commercial subsidization of residential programs, creating an equity issue. Three separate staff analyses of the budget example ($42M) showed a decrease in achievable savings, resulting in greater obstacles to achieving the 900 MW goal by 2025.At least 15% of the total distributed solar budget for new projects should be dedicated to projects that benefit low and low moderate income customers18at least 15% of the total distributed solar energy budget for new projects should be dedicated to projects that benefit low and low moderate income customers14Make Energy Star window unit air conditioners the standard energy efficiency improvement services option in the low income weatherization program and to include under limited circumstances, repair and replacement of central air conditionersNot recommendedHighLowA very small percentage of weatherized homes rely on a window unit A/C. In those cases and if the unit is beyond effective useful life, AE currently will replace the window unit. However there are no plans to encourage install of more window units in homes with central systems. Staff is currently investigating the possibility of including some minor repairs to existing central AC units in the Free Weatherization program.In the Low-income Weatherization Program, make Energy Star window unit air conditioners the standard air conditioning measure, and under limited circumstances, include repair and replacement of central air conditioners36To make Energy Star window unit air conditioners the standard energy efficiency improvement services option in the low income weatherization program and to include under limited circumstances, repair and replacement of central air conditioners1536To expand income eligibility to low income customers whose household incomes are 250% of Federal Poverty Guidelines or less as qualified by the City of Austin Health and Human Services Department. Vulnerability should be considered, and priority should be given to customers at or below 200% of the Federal Poverty Guidelines16Utilize at least 50% of Austin Energy’s multi-family budget to incentivize energy efficiency retrofits on multi-family properties that receive affordable housing subsidies from the federal, state, city, or county government or properties where at least 30 percent of the rental units are occupied by Customer Assistance Program (CAP) customers or pay a portion of their rent with housing choice vouchersUnder considerationModerateModerateEES is coordinating with CAP to create a multifamily low income program. With the recent acquisition of Census data tied to billing data, we are better able to create a program that will target low income multifamily properties.Participation by property owners, who do not directly benefit from the energy savings, will most likely be driven by the percentage of total costs covered by the rebates.This recommendation may not be compatible with the spend of 25% of the budget on low income programs or with the 1% annual savings goal.Utilize at least 50% of the multi-family budget to incentivize energy efficiency retrofits on multi-family properties that receive affordable housing subsidies from the federal, state, city, or county government or properties where, in at least 30 percent of the units, housing choice vouchers are accepted as a form of payment or customers qualify for the Customer Assistance Program bill discount.48Utilize at least 50% of Austin Energy’s multi-family budget to incentivize energy efficiency retrofits on multi-family properties that receive affordable housing subsidies from the federal, state, city, or county government or properties where at least 30 percent of the rental units are occupied by Customer Assistance Program (CAP) customers or pay a portion of their rent with housing choice vouchers17Establish a policy and ability within the Austin Energy billing system to allow for the fractional (virtual) value of solar credits from a distributed solar system on a multifamily residential property to be divided and applied to multiple residential customer accountsUnder considerationModerateModerateChanges to metering and interconnection processes, the billing system, and incentive program guidelines are required for this recommendation. Further study of potential uptake and impact should be done to ensure benefits outweigh costs.Establish ability within the Austin Energy billing system to allow for fractional division of value of solar credits from a distributed solar system on a multifamily residential property to be divided and applied to multiple residential customer accounts.47In order to reduce the cost of providing solar energy to multifamily residents, including those in affordable housing, establish a policy and ability within the Austin Energy billing system to allow for the fractional (virtual) value of solar credits from a distributed solar system on a multifamily residential property to be divided and applied to multiple residential customer accounts.18Austin Energy should develop a plan for fully enforcing the entire Energy Conservation Audit Disclosure (ECAD) ordinance, especially for those multi-family facilities whose electric cost is 150% of average electrical cost, and should present that plan to the Electric Utility Commission, the Resource Management Commission and the City Council for approvalNot recommendedHighLowThis is beyond the scope of the current ordinance as well as the scope of AE.To fully implement, AE would need additional staff with skill sets beyond the current energy efficiency staff.It may be more appropriate that enforcement fall to Code Compliance. AE could work with Code Compliance staff to provide information regarding compliance and metrics.Develop a plan for fully enforcing the entire Energy Conservation Audit Disclosure (ECAD) ordinance, especially for those multi-family facilities whose electric cost is 150% of average electrical cost51Austin Energy should develop a plan for fully enforcing the entire Energy Conservation Audit Disclosure (ECAD) ordinance, especially for those multi-family facilities whose electric cost is 150% of average electrical cost,19The Energy Conservation Audit Disclosure (ECAD) Program should be amended to establish an award or official recognition that the multi-family facility is in the top 20% of energy efficiency based on the energy efficiency rankingsTo be part of FY16 processLowHighThe new recognition process will be part of the CY15 release of data.Amend the ECAD program to provide recognition for energy efficient rental units50The Energy Conservation Audit Disclosure (ECAD) Program should be amended to establish an award or official recognition that the multi-family facility is in the top 20% of energy efficiency based on the energy efficiency rankings20Make Energy Conservation Audit Disclosure (ECAD) disclosure forms for multi-family properties available on the city’s websiteCurrently a part of AE ProcessLowHighECAD data is currently available on the City of Austin's data portal. Plans are underway to increase the amount and type of data available. With the CY15 report, we will provide Energy Use Index reports for all reporting multifamily properties.Additionally, the AE website provides a list of multifamily properties that have gone through energy efficiency improvements.Make the results of ECAD disclosure forms for multifamily properties available on the city’s website.49Make Energy Conservation Audit Disclosure (ECAD) disclosure forms for multi-family properties available on the city’s website21Austin Housing Finance Corporation should condition financing approval to applicants involved with affordable housing with a condition that applicant seek energy efficiency services from Austin Energy , including solar for new and substantial rehabilitation constructionNot recommendedModerateLowThis is not within the scope of AE.Higher rebates will impact both budget and savings goals.Require Austin Housing Finance Corporation to condition financing approval to applicants involved with affordable housing with a requirement that the applicant seek energy efficiency services from Austin Energy, including solar for new and/or substantial rehabilitation construction. Higher rebates should be considered for these applicants.52Austin Housing Finance Corporation should condition financing approval to applicants involved with affordable housing with a condition that applicant seek energy efficiency services from Austin Energy , including solar for new and substantial rehabilitation construction. Higher rebates should be considered for these applicants22Establish a minimum energy savings annual target of one percent of total energy sales through energy efficiency and demand reduction programs. In future updates to the Austin Energy Generation Plan, assess meeting this level or higher energy savings goals, subject to future budgets, affordability and other factorsNot recommendedModerateLowThis recommendation could impact budgets and adds a layer of complexity to program design, reporting and administration. The long lived AE programs have already resulted in reduced average customer consumption and incremental savings may be costly.Establish a minimum overall energy savings annual target of one percent of total energy sales through energy efficiency and demand reduction programs.15Establish a minimum energy savings annual target of one percent of total energy sales through energy efficiency and demand reduction programs.23Set a current demand savings goal for Austin Energy’s energy efficiency programs targeting low and low-moderate income customers of no less than 5% of the utility’s annual peak demand savings and increasing that goal 1% per year over the next five years reaching 10%Not recommendedHighLowThis recommendation would impact current budgets. There is a relationship between MW savings and budget. Low income programs typically result in very high $/kW numbers as AE pays for 100% of upgrades and potentially lower levels of energy and demand savings. Requiring that a percentage of the overall savings be dedicated to low income programs would result in the need for an increased budget to stay on target with the 900 MW goal.This goal is not compatible with a later goal related to dedicating a percentage of the budget to the low income programs.Set a current demand savings goal for energy efficiency programs targeting low and low moderate income customers of no less than 5% of the utility’s annual peak demand savings and increase that goal 1% per year over the next five years reaching 10%.17The Council should set a current demand savings goal for Austin Energy’s energy efficiency programs targeting low and low-moderate income customers of no less than 5% of the utility’s annual peak demand savings and increasing that goal 1% per year over the next five years reaching 10%24Improving building energy performance through continued improvements in building energy codes for new and rehabilitated residential and multi-family buildings, as well as through improved coordination, planning and compliance between Austin Energy, Planning, Review and Development and Code Compliance DepartmentsCurrently a part of AE ProcessLowHighThis is currently being done and will continue to be a focus of the Green Building effort.Building Codes. The City should continue to improve energy efficiency standards for new construction, for both homes and apartments and continue to make sure new construction is more energy efficient by improving coordination between building code development, inspection and code compliance.15Improving building energy performance through continued improvements in building energy codes28Adopt the 2015 IECC codes for residential construction (Current practice)28Further the goal of net-zero energy capable homes by considering local amendments to the energy code and suggest amendments to other building codes to encourage the adoption of new technologies (current practice)28Encourage the widespread adoption of solar PV technology (current practice)29Set the appropriate Home Energy Rating Score (HERS) if Austin Energy allows an alternative compliance path through the adoption of a 2015 IECC (underway)29Adopt either the 2015 IECC codes for commercial construction (underway)29Consider local amendments to the commercial codes to incorporate onsite renewable energy, demand response, storage and electric vehicle charging stations (underway)29Consider setting a net-zero energy capable, or net-zero load capable goals for multifamily buildings by 2020 (under consideration)29Update our Austin Green Building Programs to inspire builders to go beyond base codes (current practice)29Improve coordination between the Austin Energy Green Building Program, the Planning, Development and Review Department and Code Compliance (underway)Recommendations for further discussion25Continue the work of the Task Force through a new entity representative of the 10-1 Council and focused on affordabilityNot recommendedModerateLowThe work has been completed by the current task force and a separate affordability commission already is tasked with this effort.Support of the LICATF required a significant cost in staff time, with nearly 5,000 hours of staff time and over $350,000 in staff costs to support the current task force. Continue the work of the Task Force through a new entity representative of the 10-1 Council.53Continue the work of the Task Force through a new entity representative of the 10-1 Council.26Expand the scope of the ECAD ordinance to cover rental properties with 1 to 4 unitsNot recommendedModerateLowAn update to the current ordinance would be needed and may result in negative, unintended consequences.AE does not currently have the records to track multifamily/rental properties to the level of single family homes.Expand the scope of the ECAD ordinance to cover rental properties with 1 to 4 units.53Expand the scope of the ECAD ordinance to cover rental properties with 1 to 4 units.27Amend the multi-family program to better increase the efficiency of air conditioners in rental propertiesNot recommendedHighModerateThis will increase the rebate cost within the multifamily program, thus decreasing the reach of the program.This recommendation may not be compatible with the budget percentage goal previously noted.Amend the multi-family program to better increase the efficiency of air conditioners in rental properties54Amend the multi-family program to better increase the efficiency of air conditioners in rental properties28Promote a free energy audit to renters that experience high bills.Currently a part of AE ProcessModerateModerateAE currently offers energy audits to customers. Increasing it to a mandatory audit will require additional staff and budget as these are completed individually onsite.Better promote a free energy audit to renters that experience high bills55Better promote a free energy audit to renters that experience high bills29Consider a One Stop Weatherization ProcessNot recommendedModerateModerateAE currently works with several city departments and utility service providers in a coordinated effort to assist our low income customers. The process to create a universal application form will need to include specific data privacy parameters to which AE is held. Additionally, there will need to be a secure database where customer is stored for universal access to the applications. There are no current plans or budget for such a system. However, staff is coordinating with other city departments on targeted initiatives in the Holly and Rundberg neighborhoods)Consider a One Stop Weatherization process.56Consider a One Stop Weatherization Process30Explore avenues for increasing funds for incidental repairs made in conjunction with the weatherization programNot recommendedHighModerateThis is beyond the current AE scope. This would require additional skill sets for energy efficiency contractors. This would decrease the reach of the program.Explore avenues for increasing funds for incidental repairs made in conjunction with the low income weatherization program.55Explore avenues for increasing funds for incidental repairs made in conjunction with the weatherization program31Consider how to design Community Solar programs to benefit low and low moderate income residential ratepayersNot recommendedModerateLowProviding community solar to low income customers is not feasible at this time. Current plans for community solar show the program will be at a premium over the current fuel charge. Should low income customers participate, it will either prove too costly for limited incomes or the costs will need to be subsidized by the utility through increased charges to other utility customers. Consider how to design Community Solar programs to benefit low and low moderate income residential ratepayers.57Consider how to design Community Solar programs to benefit low and low moderate income residential ratepayers32Investigate and pursue funding from state and federal programs, the PACE program and private grant opportunities to help support and expand programs for low and low moderate income customersUnder considerationModerateModerateAE can investigate the possibility of additional grants and external funding for low income programs. However, while money is provided for these programs, there are costs incurred by AE to administer and monitor the programs.PACE is not currently designed to apply to residential customers, other than through select multifamily properties.Investigate and pursue funding to help support and expand programs for low and low moderate income customers to gain early credit under the Clean Power Plan.57Investigate how energy and efficiency and renewable energy programs that serve low-income and low-to-moderate income residential consumers can help Austin Energy comply with EPA’s Clean Power PlanConduct an audit and evaluation of the utility billing systemCurrently a part of AE ProcessHighLowThe billing system has been audited twice in the past 18 months by Deloitte and Touche and the OCA, both with successful results. Another audit by D&T is already scheduled.These "recommendations" were included as part of the TF suggested $42 M budget on page 19At least $4.2 million for Low Income Weatherization $400,000 for emergency window air conditioners for the medically vulnerableIncreased budget for the multi-family program dedicated to properties renting to low income and low moderate income customers New pilot programs to test Task Force recommendations and other new ideas for serving low and low moderate income customers.Green Buildings for low-moderate income customersHigher rebates and more generous financing terms for those in the 301 to 400% of the federal poverty guideline income bracket. Free energy audits for renters with high billsThe following 2 "Items for Future Consideration" were included in Version 9 that was voted on September 25th, but not included in final draft.