Details for: 4163-E (Part 1 of 1).pdf


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

February 11, 2020
ADVICE 4163-E
(U 338-E)
PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA
ENERGY DIVISION
SUBJECT:

Southern California Edison’s Request to Claim Savings for The
Los Angeles County Streetlight Project Through 2022

PURPOSE
Southern California Edison Company (SCE) requests approval to claim savings for the
Los Angeles County Streetlight Project as required by the California Public Utilities
Commission’s (Commission) Energy Division (ED) directive dated December 6, 2018
(the “Directive”) for SCE’s grandfathered streetlight program. The Directive requires
SCE to submit a Tier 3 advice letter to seek Commission’s approval to claim energy
efficiency (EE) savings for streetlight projects not completed by December 31, 2020.1
REGULATORY BACKGROUND ON GRANDFATHERED STREETLIGHTS
On October 10, 2017, ED granted SCE’s request to grandfather a specific set of 62
Acquisition2 customers to remain eligible for the light-emitting diode (LED) streetlight EE
incentives through 2020. Specifically, ED provided guidance allowing SCE to provide
such incentives to customers who entered into streetlight purchase and asset transfer
agreements prior to September 2015.3 Los Angeles County (LA County) entered into a
streetlight purchase and asset agreements prior to the September 2015 deadline and,
therefore, meets the grandfathering eligibility criteria. LA County is the last of the 62
customers whose project is still in progress.

1
2
3

Per guidance received from the Energy Division’s memo dated December 6, 2018, SCE
submits this Tier 3 advice letter. See Attachment A.
Acquisition customers are customers who are in the process of purchasing SCE-owned
(LS-1) streetlights. (See Attachment B - ED’s memo dated October 10, 2017).
Id., pg. 1.

P.O. Box 800

8631 Rush Street

Rosemead, California 91770

(626) 302-9645

Fax (626) 302-6396





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ADVICE 4163-E (U 338-E) -2- February 11, 2020 On December 6, 2018, ED gave further guidance related to the grandfathered streetlight program eligibility by issuing the Directive. In anticipation that a large number of streetlight projects, such as LA County’s streetlight project, could take more time and therefore may not be completed by December 31, 2020, ED directed that “if SCE has pending projects after December 31, 2020, SCE will be expected to honor the contracts and required SCE to submit a Tier 3 advice letter to justify the project delay and SCE’s request to provide LED streetlighting EE incentives beyond December 31, 2020.”4 BASIS FOR THE REQUEST As described in detail below, additional time is required to complete the LA County streetlight sale and LED retrofit and therefore, LA County streetlight projects will not be completed by December 31, 2020. Based on ED’s guidance as explained above, SCE is submitting this advice letter to seek approval to continue to claim the associated EE savings from the LA County’s streetlight projects towards its overall EE goal. Additionally, SCE further requests that the savings and expenses for these grandfathered streetlight projects continue to be excluded from its EE portfolio costeffectiveness calculation. ED allowed SCE to exclude the grandfathered projects from its portfolio cost-effectiveness calculations because approved deemed savings at the time of implementation were lower than the grandfathered savings.5 This same circumstance exists with the Los Angeles County sale: deemed savings at the time of expected implementation will be zero because the measure is now considered an industry standard practice. SCE requests approval of this advice letter no later than June 30, 2020 so that SCE can include the grandfathered streetlight savings in its 2021 Annual Budget Advice Letter (ABAL) which will be submitted on September 1, 2020. This request complies with the December 6, 2018 memo from ED and is reasonably necessary to accommodate the time required to complete the sale and conversion process for the last remaining customer within the grandfathered program. JUSTIFICATION FOR THE DELAY The streetlight sale and LED conversion process includes multiple steps and approvals from various stakeholders including local governmental agencies, SCE, and the Commission. At a high level, the process includes executing a purchase agreement between SCE and the local government, obtaining Commission approval authorizing the sale of the streetlights, completing the transfer of ownership of the streetlight facilities, converting each streetlight to LED technology, completing and submitting an EE incentive application, and issuing the EE incentive payment to the customer. For reasons stated below, SCE and LA County will not feasibly meet the required deadline to complete all the necessary steps by December 31, 2020. Historically, the number of streetlights in a single transaction under this program for other cities ranged from 770 to 4 5 Id., pg. 3. Id.
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ADVICE 4163-E (U 338-E) -3- February 11, 2020 18,000 streetlights. The LA County streetlight sale is the largest to date with approximately 40,000 streetlights being sold and transferred to LA County ownership. On July 12, 2019, SCE executed a streetlight purchase agreement with LA County and submitted an Application for Sale and Conveyance with the Commission on October 11, 2019.6 This Application is substantively similar to applications filed by SCE over the last two years which have been approved by the Commission without evidentiary hearings.7 Based on the historical precedent for these types of applications, SCE anticipates an approval date of approximately mid-2020. Upon Commission approval of the sale, SCE will begin the conveyance activities including visually inspecting all streetlights to assess the condition and value of each prior to LA County making final payment. SCE anticipates a completion date for the conveyance to LA County to occur in June 2021.8 Once payment is received, the transfer of ownership process will begin, and SCE will update its customer tariffs and maps accordingly. In parallel with this process and in phases, LA County will begin the conversion process to retrofit the streetlights to LED technology. Due to the significant number of lamps that will be retrofitted, the transfer of ownership and LED conversion processes may take 13-16 months at a rate of roughly 3,000 poles per month, with an anticipated completion date of mid-to-late 2022. Finally, LA County will need to complete and submit EE incentive applications for all LED retrofit streetlights. The EE incentive application process will be completed in phases that parallel the conversion process to ensure timely payment of the EE incentives which completes the conversion process. PROPOSED PROJECT TIMELINE As shown in Table I, SCE, in coordination with LA County, proposes the following timeline that reasonably reflects the additional time necessary to accommodate the Commission’s application process and the necessary activities that must occur after the Commission approves of the application. 6 7 8 SCE’s Application Pursuant to Public Utilities Code Section 851 for Commission Order Authorizing Sale and Conveyance of Streetlight Facilities to County of Los Angeles filed on October 11, 2019 (A.19-10-007). See, e.g. D.17-05-024, D.17-05-025, D.18-05-009 and D.18-06-021. The completion date is contingent upon LA County Board of Supervisors’ approvals of financing and Request for Proposal (RFP) for contractor work associated with the sale and transfer of ownership processes of the streetlight.
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ADVICE 4163-E (U 338-E) -4- February 11, 2020 Table 1 Proposed Timeline to Complete Sale, Conveyance and LED Conversion for LA County Acquired Streetlights Timeline July 12, 2019 October 11, 2019 ~Expected End of Second Quarter 2020 Jun 2020 – Jan. 2021 Jan. 2021 – Jun. 2022 Jan.2021 – Jun 2022 Jun. – Dec. 2022 December 2022 Activities SCE and LA County Execute Purchase Agreement SCE files Application for Commission Authorization of the Sale and Conveyance of Streetlight Facilities to the County of Los Angeles Commission issues final decision on SCE Application (A.)19-10-007 Complete Conveyance Activities Transfer of Ownership Process* LED Conversion Process* LED EE Rebate Application Processing and Payment Approximate Project Completion Date *These will be performed in phases and in parallel beginning January 2021 once payment is received and end in June 2022 when the last lamp is retrofitted. By the end of 2022, SCE anticipates the completion of the streetlight sale, conversion, and incentive payment processes with all local government agencies that had originally agreed to purchase streetlights from SCE. Given the significant progress SCE has made to date with LA County, it is reasonable to continue to claim the associated EE savings from these grandfathered streetlights toward SCE’s EE goals through the end of 2022. TIER DESIGNATION Pursuant to General Order (GO) 96-B, Energy Industry Rule 5.3 this advice letter is submitted with a Tier 3 designation. EFFECTIVE DATE This advice letter will become effective upon Commission approval. PROTEST 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:
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ADVICE 4163-E (U 338-E) -5- February 11, 2020 CPUC, Energy Division Attention: Tariff Unit 505 Van Ness Avenue San Francisco, California 94102 E-mail: EDTariffUnit@cpuc.ca.gov 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: AdviceTariffManager@sce.com 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: Karyn.Gansecki@sce.com 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. NOTICE In accordance with General Rule 4 of General Order (GO) 96-B, SCE is serving copies of this advice letter to the interested parties of GO 96-B, A.17-01-013 et al and R.13-11-005 service lists. Address change requests to the GO 96-B service list should be directed by electronic mail to AdviceTariffManager@sce.com or at (626) 302-3719. For changes to all other service lists, please contact the Commission’s Process Office at (415) 703-2021 or by electronic mail at Process_Office@cpuc.ca.gov.
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ADVICE 4163-E (U 338-E) -6- February 11, 2020 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 https://www.sce.com/wps/portal/home/regulatory/advice-letters. For questions, please contact Joni Key at (626) 302-5394 or by electronic mail at Joni.Key@sce.com. Southern California Edison Company /s/ Gary A. Stern Gary A. Stern, Ph.D. GAS:jk: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: AdviceTariffManager@sce.com E-mail Disposition Notice to: AdviceTariffManager@sce.com EXPLANATION OF UTILITY TYPE GAS = Gas WATER = Water HEAT = Heat (Date Submitted / Received Stamp by CPUC) Tier Designation: 3 Advice Letter (AL) #: 4163-E Subject of AL: Southern California Edison’s Request to Claim Savings for The Los Angeles County Streetlight Project Through 2022 Keywords (choose from CPUC listing): Street Lights AL Type: Monthly Quarterly Annual One-Time Other: If AL submitted in compliance with a Commission order, indicate relevant Decision/Resolution #: 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: 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: EDTariffUnit@cpuc.ca.gov 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: advicetariffmanager@sce.com 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: karyn.gansecki@sce.com 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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Attachment A
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State of California Memorandum Date: December 6, 2018 To: Mike Bushey, SCE From: Edward Randolph, Director, Energy Division Subject: Request from Sothern California Edison (SCE) to revisit estimated incentive savings treatment of energy efficiency bulb replacements for their local government agencies acquiring SCE Streetlights Summary: SCE may claim associated energy efficiency savings from the grandfathered streetlight customer projects towards its overall energy efficiency goal. SCE must report these projects’ energy efficiency savings and associated expenses in accordance with the CPUC’s reporting requirements; however, SCE may flag these projects to be excluded from the portfolio cost-effectiveness determinations. SCE shall honor its contract with 62 local government agencies that have agreed to purchase streetlights and acquire assets from SCE.1 SCE is granted until December 31, 2020 to complete the projects to claim energy efficiency savings. SCE shall file a Tier III Advice Letter and seek Commission approval to claim savings for projects not completed by December 31, 2020. SCE can claim energy efficiency savings, as shown in Table 1, for program year 2018, 2019, and 2020 using the SCE workpaper SCE17LG097 Revision 2 workpaper savings values. 1 SCE provided a spreadsheet titled “Street Light – SCE – 10-15-18.xlsx” identifying 61 local government agencies that entered the queue prior to September 2015 who remain in the process of purchasing and upgrading their street-lighting. 1
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TABLE 1 – Savings Estimate Total Acquisition LS1 2018 17,772,430 4,819,259 12,953,171 2019 64,221,355 55,605,451 8,615,904 2020 15,008,288 15,008,288 97,002,072 75,432,997 21,569,075 These 62 local government agency customers’ street lighting projects must be completed, and incentives paid before December 31, 2020. SCE shall continue to pay customer incentives at levels set prior to September 2015 on contracts with the local government agencies. 2 By January 15, 2019, SCE shall communicate to these customers either via a letter or a conference call their project plan to complete the pending projects. Additionally, SCE’s past performance and execution of delivery for the grandfathered streetlight customers within 2019 and 2020 will influence related shareholder incentives. Background: In October 2017, a CPUC Staff memo allowed SCE to ‘grandfather’ a set of local government agencies in the streetlighting acquisition pipeline to remain eligible for LED streetlighting incentives through 2020. The memo allowed SCE to honor incentives to these customers who entered streetlighting purchase and asset transfer agreement prior to September 2015.3 This memo noted that there was no approved workpaper to claim savings and directed SCE to revise its workpaper “SCE 17LG097 Revision 1.” There are two local agency customer types for SCE-owned street lights: Acquisition Customers: Customers in the process of purchasing SCE-owned (LS-1) street- lighting. This asset transfer process takes approximately three or four years to complete before any retrofits can begin. These customers submitted deposits prior to Sept 2015 to enter the acquisition queue 2 3 October 10, 2017 memo from CPUC staff Bryan Pena to Anuj Desai and Alok Singh of SCE. October 10, 2017 memo from CPUC staff Bryan Pena to Anuj Desai and Alok Singh of SCE. 2
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LS-1 Option E (AB-719) Customers: Customers of SCE-owned street lights who pay the capital cost to retrofit to LED streetlights over a period of 20 years.4 Subsequently SCE submitted a revised workpaper - SCE workpaper SCE17LG097 Revision 2. SCE is now requesting that 62 local government agency customers in the acquisition pipeline since 2015 continue to remain eligible for incentives through 2020 using the SCE workpaper SCE17LG097 Revision 2 workpaper savings values. This workpaper incorporates CPUC staff’s direction that the measure type for these projects are accelerated replacement with the 2 nd baseline equal to zero as LED is code. SCE further requests that the energy efficiency savings and expenses for these grandfathered streetlighting projects be excluded from its portfolio cost-effectiveness calculations. DISCUSSION AND RECOMMENDATIONS CPUC staff recognizes that the acquisition process takes time and therefore allowed to grandfather these customers at a higher deemed savings than currently approved. It is reasonable to grant SCE until December 31, 2020 to report these grandfathered projects’ expenses and energy efficiency savings based on the SCE workpaper SCE17LG097 Revision 2 workpaper. It is also reasonable to allow SCE to exclude these grandfather project from its portfolio cost-effectiveness calculations because approved deemed savings at the time of implementation are lower than the grandfathered savings. The fact that savings can be claimed only at implementation and the timing mismatch between implementation and what’s been grandfathered create an artificially low-cost effectiveness for these projects. SCE has claimed that had CPUC not authorized grandfathering of these projects and customers it would have removed these offerings from the portfolio. If SCE has pending projects after December 31, 2020, SCE will be expected to honor the contracts. However, SCE will be required to file a Tier III advice letter with justification on why the projects were delayed and why should the Commission grant SCE’s request. Additionally, SCE will provide to CPUC staff by January 31, 2020 and January 31, 2021 a project completion status update list for these 62 customers with the dates of completion, and the amounts of the customer incentive payments paid in the year 2019 and 2020, respectively. SCE has obligatory duties towards its customers and while it did not foresee the rapid development in codes and standard for lighting measures to facilitate a quicker replacement schedule for its customers; it 4 SCE has submitted a capital request of $30M per year in its 2018-2020 GRC filing to support retrofits for these customers. 3
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nevertheless must honor the agreements and prioritize streetlight lamp replacements, as needed. SCE submitted for CPUC staff review and approval its proposed street lighting energy efficiency savings and associated total incentive payments to their local agency customers.5 CPUC staff has reviewed SCE’s requests and SCE may pay these local government agency customers street lighting incentive per the table below: Estimated Incentive Payments: Total Acquisition 2018 $ 7,443,490 2019 $ 24,982,451 2020 $ 5,931,789 $ 38,357,731 Total $ LS1 2,328,620 $ 5,114,870 $ 21,984,518 $ 2,997,933 $ $ 5,931,789 $ 30,244,928 - $ 8,112,803 Estimated Savings: Savings Total Acquisition LS1 2018 4,819,259 12,953,171 2019 64,221,355 55,605,451 8,615,904 2020 15,008,288 15,008,288 97,002,072 5 17,772,430 75,432,997 21,569,075 September 25, 2018 email from SCE staff Cassie Cuaresma to CPUC staff Manisha Lakhanpal. 4
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Attachment B
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State of California Memorandum Date: October 10, 2017 To: Anuj Desai, SCE Alok Singh, SCE Cc:: Peter Lai, CPUC From: Bryan Pena, CPUC Subject: SCE’s Street Lighting Proposal In a meeting on August 4, 2017 and a follow-up telephone meeting on August 10, 2017, SCE discussed with CPUC staff its proposal for street lighting savings and requesting to “grandfather" a set of historical customers in the SCE acquisition pipeline who entered the purchase and asset transfer process prior to September 2015; and to establish CPUC support for an acceptable multi-year framework for savings claims in 2018 and beyond. Specifically, SCE requests that a specific set of customers in its territory who entered the acquisition pipeline in 2015 remain eligible for LED street lighting incentives through 2020 using its submitted 2017 workpaper savings values. SCE’s request is based on the understanding of the following customer types for SCE-owned street lights: Acquisition Customers: Customers in the process of purchasing SCE-owned (LS-1) street lighting. This asset transfer process takes approximately three or four years to complete before any retrofits can begin.1 LS-1 Option E (AB-719) Customers: Customers of SCE-owned street lights and pay the capital cost to retrofit to LED over a period of 20 years.2 Customers typically face a one-year turnaround time from application submission to retrofit completion. ________________________________________ 1 Customers submitted deposits prior to Sept 2015 to enter the acquisition queue. SCE has submitted a capital request of $30M per year in its 2018-2020 GRC filing to support retrofits for these customers. 2 1
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Program Participation: It has been identified that there is no currently approved workpaper under which savings resulting from this program activity can be claimed. In order to provide for any program participation in 2018 and beyond, SCE must first resolve the following issues in its workpaper SCE 17LG097 Revision 1, dated June 30, 2017, submitted for 2017 program year. The applicable workpaper defines all measures as Replace-on-Burnout (now referred to as Normal Replacement or “NR”), however, the baselines for all measures covered by that workpaper are comprised of older, HID technologies, which are representative of a pre-existing technology. Therefore, the measures defined in the workpaper are, in practice, Accelerated Replacement (AR) measures. This workpaper does not follow CPUC policy that has been in place long before 2015. AR measures are required to include a standard practice second baseline. The DEER 2016 updated directed that all AR exterior lighting measures have a second baseline of LED technologies. The projects proposed appear to be all Accelerated Replacement (AR). As a way to address these inconsistencies between the proposed projects and the proposed applicable workpaper, SCE shall revise the applicable workpaper for the 2018 program year as such: o o o o The measure application type must be corrected from Normal Replacement to Accelerated Replacement. SCE shall establish Preponderance of Evidence criteria that demonstrate that the customers, absent the incentive support, would more likely than not undertake the retrofits. This analysis must take into account the acquisition decision as well as the retrofit. All supporting data must be submitted via the normal workpaper submission process prior to any incentives being paid as with all deemed incentive offerings. Since the directed second baselines are LED technologies, the second period gross savings for the proposed projects shall be zero. Gross savings above the workpaper defined baselines shall be claimed for the RUL period only. The 2nd baseline is LED. Therefore the 2nd baseline savings is zero for the Accelerated Replacement. SCE shall apply the default net-to-gross value of 0.6 to the gross savings of these grandfather street lighting retrofits. Acquisition Customers: CPUC staff understands that there are 53 cities that entered the acquisition queue prior to September 2015 who remain in the process of purchasing and upgrading their street lighting, and that SCE is no longer entertaining new customers looking to purchase street lights. CPUC staff does not object to maintaining program eligibility requirements, rules, and incentive for these 53 cities that entered the acquisition queue in 2015. Therefore, customers in this cohort shall be exempt from POE requirements in lieu of the eligibility requirements and other program rules in effect prior to September 2015. Incentives should also be maintained at the same levels as they were prior to September 2015. LS-1 Option E (AB-719) Customers: CPUC staff understands that these customers entered into agreements with SCE at varying times after AB719 legislation was adopted and that program eligibility requirements, rules, and incentive levels tend to evolve. Therefore, customers in this cohort shall be exempt from POE requirements in lieu of the eligibility requirements and other program rules in effect at the time of customer application submittal. Incentives should also be maintained as the same levels as they were at the time of customer application submittal. 2
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For future LS-1 Option E (AB-719) Customers and other potential program participants during 2018 and beyond, Commission staff sees no reason to allow the use of past program eligibility requirements, rules, and incentive levels. These customers shall follow all requirements imposed in the revised workpaper for the 2018 program year. 2019 Program Year: Notwithstanding the above treatments for specific classes of customers, SCE shall conduct a standard practice study to examine the most current purchasing practices for LED street lighting retrofits, present its data and analysis, as well as propose findings to CPUC staff for review. CPUC considers that there is wide range of efficacy and performance in available LED products and that an ISP study would serve as a basis to establish deemed savings above the 2nd baseline. The results of any standard practice study, along with proposed workpaper revisions, should be submitted in a revised workpaper for the next Phase 1 workpaper review period for an effective date of January 1, 2019. Commission staff appreciates SCE staff bringing this to our attention, and the opportunity for an open discussion of the issues. 3
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