Details for: 3983-E (Part 1 of 1).pdf

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Gary A. Stern, Ph. D.
Managing Director, State Regulatory Operations

April 5, 2019
(U 338-E)
Request for Approval to Change Incentive Level for Electric
Heat Pump Water Heaters


Pursuant to Decision (D.)05-09-043, Southern California Edison Company (SCE)
hereby submits this advice letter for the Commission’s approval to increase the
incentive level for the electric Heat Pump Water Heater (HPWH) measure currently
offered within the Plug Load and Appliances (PLA) program. The program is a
statewide residential energy efficiency (EE) program.
Consistent with D.05-09-043,1 SCE is requesting in this Advice Letter authority to make
changes to an incentive level that exceed 50% of the original incentive level for a
statewide program.
SCE offers several energy efficiency rebate programs to encourage energy savings for
residential customers to reduce energy consumption by upgrading existing systems and
measures in participating homes.


See D.05-09-043, p. 152. “Under this proposal, an advice letter filing would be required only
if the proposed incentive level change impacts a statewide program offering and is more
than 50% of the original incentive level on a cumulative basis over the three-year cycle”.

P.O. Box 800

8631 Rush Street

Rosemead, California 91770

(626) 302-9645

Fax (626) 302-6396


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ADVICE 3983-E (U 338-E) -2- April 5, 2019 The PLA program advances comprehensive EE measures and promotes the sale, installation, and recycling of EE products to residential customers through educational materials, as well as through rebates and/or incentive offerings. SCE routinely reviews and analyzes incentive levels and performance of measures to determine how to best address issues faced in this sector. During such a review, SCE noted that EE savings of electric HPWHs have improved in recent workpaper updates, thus improving the cost-effectiveness of the measure. Moreover, SCE’s current incentive is significantly lower than those offered by San Diego Gas & Electric and Pacific Gas & Electric Companies for the same measure. Electric HPWHs are two to three times more efficient than conventional electric resistance water heaters.2 Compared to a conventional electric water heater, an electric HPWH improves building EE and supports California’s climate goals by reducing greenhouse gas emissions. Program incentives are necessary to drive market awareness and customer adoption, and to engage manufacturers and distributors to promote and install this highly energy-efficient and carbon-reducing technology. PROPOSED INCENTIVE CHANGES For customers to be eligible for this incentive, they must install an electric HPWH with a Uniform Energy Factor (UEF) greater than 3.09. The higher the UEF value is, the more efficient the water heater. Table 1 below lists the current and proposed incentive change. Table 1: Measure Description and Proposed Incentive Change Measure Description Efficient Electric Heat Pump Water Heaters 50 to 55 gallon (UEF>=3.09) Program ID SCE-13-SW-001B Program Plug Load and Appliance Current Proposed Incentive Incentive $200 $500 Overall, the TRC for PLA will remain favorable after the proposed measure incentive increase. 2 U.S. Department of Energy. See
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ADVICE 3983-E (U 338-E) -3- April 5, 2019 Table 2 lists the projected TRC, Net kWh/kW and total incentive for the 2019 program year if the requested incentive increase is approved. Table 2: 2019 HPWH Forecast HPWH Measure by Program PLA TRC 1.12 1.57 Net kWh 521,250 Net kW 64 Total Incentive $200,000 Although the PLA is operated by other investor-owned utilities (IOUs), the other IOUs offer this measure at varying rebate amounts.3 SCE notes that it will begin offering the same HPWH measure within the Multifamily Energy Efficiency Rebate (MFEER) program at the same incentive as proposed for the PLA program. This update will be reflected in a Program Implementation Plan (PIP) addendum. No additional budget is requested in support of the proposed rebate level for either of the programs listed in this Advice Letter. SCE will utilize existing authorized budgets to support the proposed rebate. SCE’s 2019 Energy Efficiency budgets proposed in Advice 3859-E and 3859-E-A were approved by the CPUC on April 2, 2019. No cost information is required for this advice letter. This advice letter will not increase any rate or charge, cause the withdrawal of service, or conflict with any other schedule or rule. TIER DESIGNATION Pursuant to General Order (GO) 96-B, Energy Industry Rule 5.2, this advice letter is submitted with a Tier 2 designation. EFFECTIVE DATE This advice letter will become effective on May 5, 2019, the 30th calendar day after the date submitted. 3 See Pacific Gas and Electric Company (PG&E) ( rebate_catalog.pdf), and San Diego Gas and Electric Company (SDG&E) (
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ADVICE 3983-E (U 338-E) -4- April 5, 2019 NOTICE Anyone wishing to protest this advice letter may do so by letter via U.S. Mail, facsimile, or electronically, any of which must be received no later than 20 days after the date of this advice letter. Protests should be submitted to: CPUC, Energy Division Attention: Tariff Unit 505 Van Ness Avenue San Francisco, California 94102 E-mail: Copies should also be mailed to the attention of the Director, Energy Division, Room 4004 (same address above). In addition, protests and all other correspondence regarding this advice letter should also be sent by letter and transmitted via facsimile or electronically to the attention of: Gary A. Stern, Ph.D. Managing Director, State Regulatory Operations Southern California Edison Company 8631 Rush Street Rosemead, California 91770 Telephone: (626) 302-9645 Facsimile: (626) 302-6396 E-mail: Laura Genao Managing Director, State Regulatory Affairs c/o Karyn Gansecki Southern California Edison Company 601 Van Ness Avenue, Suite 2030 San Francisco, California 94102 Facsimile: (415) 929-5544 E-mail: There are no restrictions on who may submit a protest, but the protest shall set forth specifically the grounds upon which it is based and must be received by the deadline shown above. In accordance with General Rule 4 of GO 96-B, SCE is serving copies of this advice letter to the interested parties shown on the attached A.17-01-013 et al, R.13-11-005, and GO 96-B service lists. Address change requests to the GO 96-B service list should be directed by electronic mail to or at (626) 302-3719.
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ADVICE 3983-E (U 338-E) -5- April 5, 2019 For changes to all other service lists, please contact the Commission’s Process Office at (415) 703-2021 or by electronic mail at Further, in accordance with Public Utilities Code Section 491, notice to the public is hereby given by submitting and keeping the advice letter at SCE’s corporate headquarters. To view other SCE advice letters submitted with the Commission, log on to SCE’s web site at For questions, please contact Joni Key at (626) 302-5394 or by electronic mail at Southern California Edison Company /s/ Gary A. Stern Gary A. Stern, Ph.D. GAS:jf:cm Enclosures
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ADVICE LETTER SUMMARY ENERGY UTILITY MUST BE COMPLETED BY UTILITY (Attach additional pages as needed) Company name/CPUC Utility No.: Southern California Edison Company (U 338-E) Utility type: ELC GAS PLC HEAT ELC = Electric PLC = Pipeline WATER Contact Person: Darrah Morgan Phone #: (626) 302-2086 E-mail: E-mail Disposition Notice to: EXPLANATION OF UTILITY TYPE GAS = Gas WATER = Water HEAT = Heat (Date Submitted / Received Stamp by CPUC) Tier Designation: 2 Advice Letter (AL) #: 3983-E Subject of AL: Request for Approval to Change Incentive Level for Electric Heat Pump Water Heaters Keywords (choose from CPUC listing): Compliance AL Type: Monthly Quarterly Annual One-Time Other: If AL submitted in compliance with a Commission order, indicate relevant Decision/Resolution #: Decision 05-09-043 Does AL replace a withdrawn or rejected AL? If so, identify the prior AL: Summarize differences between the AL and the prior withdrawn or rejected AL: Confidential treatment requested? Yes No If yes, specification of confidential information: Confidential information will be made available to appropriate parties who execute a nondisclosure agreement. Name and contact information to request nondisclosure agreement/ access to confidential information: Resolution required? Yes No Requested effective date: 5/5/19 No. of tariff sheets: -0- Estimated system annual revenue effect (%): Estimated system average rate effect (%): When rates are affected by AL, include attachment in AL showing average rate effects on customer classes (residential, small commercial, large C/I, agricultural, lighting). Tariff schedules affected: None Service affected and changes proposed1: Pending advice letters that revise the same tariff sheets: None 1 Discuss in AL if more space is needed. Clear Form
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Protests and all other correspondence regarding this AL are due no later than 20 days after the date of this submittal, unless otherwise authorized by the Commission, and shall be sent to: CPUC, Energy Division Attention: Tariff Unit 505 Van Ness Avenue San Francisco, CA 94102 Email: Name: Gary A. Stern, Ph.D. Title: Managing Director, State Regulatory Operations Utility Name: Southern California Edison Company Address: 8631 Rush Street City: Rosemead Zip: 91770 State: California Telephone (xxx) xxx-xxxx: (626) 302-9645 Facsimile (xxx) xxx-xxxx: (626) 302-6396 Email: Name: Laura Genao c/o Karyn Gansecki Title: Managing Director, State Regulatory Affairs Utility Name: Southern California Edison Company Address: 601 Van Ness Avenue, Suite 2030 City: San Francisco State: California Zip: 94102 Telephone (xxx) xxx-xxxx: Facsimile (xxx) xxx-xxxx: (415) 929-5544 Email: Clear Form
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ENERGY Advice Letter Keywords Affiliate Direct Access Preliminary Statement Agreements Disconnect Service Procurement Agriculture ECAC / Energy Cost Adjustment Qualifying Facility Avoided Cost EOR / Enhanced Oil Recovery Rebates Balancing Account Energy Charge Refunds Baseline Energy Efficiency Reliability Bilingual Establish Service Re-MAT/Bio-MAT Billings Expand Service Area Revenue Allocation Bioenergy Forms Rule 21 Brokerage Fees Franchise Fee / User Tax Rules CARE G.O. 131-D Section 851 CPUC Reimbursement Fee GRC / General Rate Case Self Generation Capacity Hazardous Waste Service Area Map Cogeneration Increase Rates Service Outage Compliance Interruptible Service Solar Conditions of Service Interutility Transportation Standby Service Connection LIEE / Low-Income Energy Efficiency Storage Conservation LIRA / Low-Income Ratepayer Assistance Street Lights Consolidate Tariffs Late Payment Charge Surcharges Contracts Line Extensions Tariffs Core Memorandum Account Taxes Credit Metered Energy Efficiency Text Changes Curtailable Service Metering Transformer Customer Charge Customer Owned Generation Mobile Home Parks Name Change Transition Cost Transmission Lines Decrease Rates Non-Core Transportation Electrification Demand Charge Non-firm Service Contracts Transportation Rates Demand Side Fund Nuclear Undergrounding Demand Side Management Oil Pipelines Voltage Discount Demand Side Response PBR / Performance Based Ratemaking Wind Power Deposits Portfolio Withdrawal of Service Depreciation Power Lines Clear Form
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