NOTICES

PENNSYLVANIA PUBLIC UTILITY COMMISSION

Implementation of the Alternative Energy Portfolio Standards Act of 2004: Standards for the Participation of Demand Side Management Resources; Doc. No. M-00051865

[35 Pa.B. 5895]

Public Meeting held
September 29, 2005

Commissioners Present:  Wendell F. Holland, Chairperson, statement follows; James H. Cawley, Vice Chairperson; Bill Shane; Kim Pizzingrilli; Terrance J. Fitzpatrick

Final Order

By the Commission:

   The Alternative Energy Portfolio Standards Act of 2004, 73 P. S. §§ 1648.1--1648.8 (''Act 213'' or the ''Act''), includes demand side management, energy efficiency and load management programs and technologies (''DSM/EE'') among the resources eligible for participation in Pennsylvania's alternative energy market. The Commission previously announced that it would be issuing standards governing the tracking and verification of DSM/EE measures undertaken for purposes of compliance with Act 213. Implementation of the Alternative Energy Portfolio Standards Act of 2004, Doc. No. M-00051865 (Order entered March 25, 2005) (''Implementation Order''). By Tentative Order entered June 24, 2005, we issued proposed standards for enabling the participation of DSM/EE in Pennsylvania's alternative energy market and requested comments within sixty days. Responses were received from eleven interested parties.

BACKGROUND AND HISTORY OF THIS PROCEEDING

   On November 30, 2004, Governor Edward Rendell signed Act 213 into law. Generally, Act 213 requires that electric distribution companies (''EDCs'') and electric generation suppliers (''EGSs'') include a specific percentage of electricity from alternative resources in the generation that they sell to Pennsylvania customers. The level of alternative energy required gradually increases according to a fifteen year schedule found in Act 213, as clarified in the Implementation Order. While Act 213 does not mandate exactly which resources must be utilized and in what quantities, certain minimum thresholds must be met for the use of Tier I and Tier II resources. DSM/EE was included within the definition of ''Alternative Energy Sources'' in Section 1648.2 of Act 213, 73 P. S. § 1648.2:

   (12)  Demand side management consisting of the management of customer consumption of electricity or the demand for electricity through the implementation of:

   (i)  energy efficiency technologies, management practices or other strategies in residential, commercial, institutional or government customers that reduce electricity consumption by those customers;

   (ii)  load management or demand response technologies, management practices or other strategies in residential, commercial, industrial, institutional and government customers that shift electric load from periods of higher demand to periods of lower demand, including pump storage technologies; or

   (iii)  industrial by-product technologies consisting of the use of a by-product from an industrial process, including the reuse of energy from exhaust gases or other manufacturing by-products that are used in the direct production of electricity at the facility of a customer.

DSM/EE resources have been assigned to the Tier II category pursuant to Section 2 of Act 213.

   The Pennsylvania General Assembly recognized that the inclusion of DSM/EE in the category of eligible alternative resources would present certain challenges not implicated by the utilization of other resources. Accordingly, the Commission was directed to establish standards for the verification and tracking of DSM/EE measures well in advance of the commencement of the first Act 213 reporting year on June 1, 2006:

The commission shall within 120 days of the effective date of this act develop a depreciation schedule for alternative energy credits created through demand side management, energy efficiency and load management technologies and shall develop standards for tracking and verifying savings from energy efficiency, load management and demand-side management measures. The commission shall allow for a 60-day public comment period and shall issue final standards within 30 days of the close of the public comment period.

73 P. S. § 1648.3(e) (11)

   As Act 213 went into effect on February 28, 2005, the Commission was obligated to issue these standards by June 28, 2005. Section 1648.3(e) (10) of Act 213, 73 P. S. § 1648.3(e)(10), requires the Commission to eventually include these standards in a proposed rulemaking.

   On March 3, 2005, the Commission convened the first meeting of the Alternative Energy Portfolio Standards Working Group (''AEPS WG''). The AEPS WG was established in order to provide a forum for considering the technical standards, business rules and regulatory framework necessary for Act 213's successful implementation. The Commission charged the AEPS WG with, among other tasks, studying the development of rules necessary for the participation of DSM/EE resources in the alternative energy market. The AEPS WG was to report back to the Commission on its findings within a period of time that allowed the Commission to meet the June 28, 2005 deadline.

   The AEPS WG has met periodically since March 3 to discuss and develop standards for the participation of DSM/EE resources. Interested parties first had the opportunity to file comments on this topic in response to an issues list developed by Commission staff. After reviewing these comments, Commission staff issued a draft proposal on May 2, 2005, for consideration by the AEPS WG. Stakeholders provided commentary on the details of this proposal, and offered specific recommendations for changes to the draft. By Tentative Order entered on June 24, 2005, the Commission issued its initial proposal for enabling the participation of DSM/EE. The final order being released today has been revised to reflect those comments and suggestions.

DISCUSSION

   As stated in our Tentative Order, clear rules will be critical for the future success of this initiative as well as for the ease of implementing the Act. The Commission will be guided by the following principles in establishing the rules for DSM/EE measures:

   *  Market values for individual measures or measures installed as group program items.

   *  Easily understood rules with minimal transaction and administrative costs.

   *  Reliance upon existing state and federal protocols.

   *  Equitable opportunities for residential, commercial and industrial customers to benefit directly.

   The Commission will use two means to the extent appropriate to establish qualifications for Alternative Energy Credits (''Credits'')--a catalog approach for standard energy savings measures and general guidelines for metered and custom energy savings measures.

A.  Standard Energy Savings Measures

   The first method is a ''catalog approach'' that will establish the number of Credits available for standard energy savings measures. The intent of this approach is to address standard energy savings measures that are available to a large number of customers through retail consumer-products and whose effects cannot be directly metered. Retail consumer-products to be addressed by the catalog approach include items such as energy efficient appliances, light bulbs, and HVAC equipment.

   Most commenters agreed with the catalog approach as a way to track standard energy savings and the use of general guidelines for metered and custom energy saving measures. To be clear, it is our intent that these standards and the custom measures will evolve and change over time as we gain practical experience and receive comments based on application and the passage of time.

   The energy savings from these standard measures are referred to as ''deemed savings.'' Deemed savings are ranges of energy savings above standard usage ranges from a particular application or equipment over a given period of time.

   Standard energy saving measures are detailed in the Technical Reference Manual (''TRM''), follows as Annex A. The TRM provides a consistent framework for calculating deemed savings for a menu of energy efficiency measures using supported assumptions and customer data as input values in industry-accepted algorithms. The framework in this TRM was developed for the purpose of estimating annual energy savings for a limited selection of energy efficient technologies and measures.

   The TRM builds on comparable protocols used in other states, including Vermont and New Jersey. Input values and baselines are based on the best available measured or industry data, and will be updated periodically with new information or Pennsylvania-specific information over time. The limited selection of energy efficient technologies may be expanded over time as well.

   Specific comments regarding measures within the Technical Reference Manual (TRM) were submitted by the Energy Association of Pennsylvania (''EAPA''), the Energy Coordinating Agency (''ECA''), Lawrence G. Spielvogel, PPL Electric Utilities, Inc. (''PPL''), Exelon, Department of Environmental Protection (''DEP''), Commission on Economic Opportunity (''CEO''), Office of Small Business Advocate, Office of Consumer Advocate, U.S. Steel and Industrial Energy Consumers of PA (''IECPA'').

   The EAPA and Spielvogel commented that the ''Motors'' (all sizes) hours of operation should be adjusted for Pennsylvania from 4500 annual operating hours to 4599 annual operating hours for industrial operations and 2502 annual operating hours for commercial operations. Furthermore motors purchased for back-up or stand-by purposes should not be eligible to receive renewable energy credits. These suggested changes more accurately reflect seasonal or consistent monthly use. We accept these comments and have incorporated the figures and language in the TRM.

   EAPA commented that commercial lighting should have a reduced measure life from 20 years to 15 years to reflect more frequent remodeling practices, we accept the change in the standard and have modified the standards accordingly.

B.  Metered and Custom Measures

   The second group of measures not covered by the catalog approach involves custom or metered measures and requires general guidelines for qualification and availability of Credits from these measures. Metered measures require actual metered usage or self-generation. An example of a metered measure would be distributed generation where the value of the savings measure--i.e. generator output--can be directly measured.

   Custom measures include measures that may be considered too complex or unique to be included in the catalog. It also would include measures that may involve metered data, but require additional assumptions to arrive at a ''typical'' level of savings as opposed to an exact measurement. An example includes a time-of-use pricing program that determines savings by comparing actual metered usage to typical load profiles of similar customers.

   The qualification for Credits and availability of Credits from metered and custom savings measures will need to be determined on a case-by-case basis. As a result, a set of guidelines that can facilitate such determinations and promote consistency among those determinations are necessary. The EAPA and Exelon suggested that LIURP programs should be eligible for consideration for renewable energy credit (''REC'') under Tier II. We agree that EDCs' LIURP programs should be eligible to receive REC credits as a DSM program, but the EDCs' must provide the energy savings evaluations as a custom program. The utility will receive the REC credits for LIURP because of ratepayer funding.

   Set forth as follows are general guidelines for custom and metered measures, which are a combination of proposals filed by the EAPA and US Steel in the DSM/EE WG process. The EAPA provided further comments with regard to measures that shift load. They suggest that full credit should be given for kilowatt hours shifted as well as for any conservation effect. We agree that demand side response programs that promote load shifting from high use and high cost periods to low use and low price periods is an important objective in a market environment. These programs should receive REC credits. The EAPA also recommended all measures that involved generation shall directly measure kilowatt hours generated using an approved metering device. We agree that approved metering devices should be required for accountability of energy and credits.

General Guidelines

   1.  Entities eligible to apply for credits include, but are not limited to: retail customers who have undertaken measures, EDCs' or EGSs' whose customers are participating in tariffed programs or retail contracts and who, in accordance with the language of the tariff or contract, have acquired the right to any Credits resulting from operations under the tariff or contract; and equipment or service providers who have provided equipment or services to customers pursuant to a contract that gives the provider the right to any Credits resulting from the installation of that equipment or use of the service. All measures that shift load shall be given full credit for kilowatt hours shifted and saved.

   2.  The Commission will at a later date provide for the requirements of a Program Administrator as required by the Act. The Commission will also establish by way of regulation the duties and responsibilities of the Administrator. Eligible entities may submit an application to the Administrator of the Alternative Energy Credits Program requesting a review for qualifying status. The application must be signed by the customer or his representative and be supported by an affidavit or verification.

   3.  The metered or custom measure contained in the application may incorporate or use any of the technologies or load management practices defined as Tier II resource contained in Act 213. The metered or custom measure identified in the application may use or incorporate equipment installed prior to the effective date of Act 213.

   4.  The application shall include adequate documentation to fully describe the DSM or EE measures installed or proposed by the customer and an explanation of how the installed facilities qualify for alternative energy credits under the Act. All measures that involve generation shall directly measure kilowatt hours generated using an approved metering device.

   5.  The application must include a proposed evaluation plan by which the Administrator may evaluate the effectiveness of the DSM or EE measures provided by the installed facilities. All assumptions contained in the proposed evaluation plan should be identified, explained and supported by documentation where possible. The applicant may propose incorporating tracking and evaluation measures using existing data streams currently in use provided that they permit the Administrator to evaluate the program using the reported data.

   6.  To the extent possible, the DSM or EE measures identified in the application should be verified by the meter readings submitted to the Administrator.

   7.  The Administrator may request additional information as needed.

   8.  The application will be approved if the Administrator determines that the proposal is consistent with the DSM and EE definitions contained in the Act and that the proposed evaluation measures will accurately identify the effectiveness of the proposed custom measure.

   9.  Denial of any application must be fully explained by the Administrator.

   10.  The Administrator's decision is subject to review by the Commission.

C.  Depreciation Schedule for Alternative Energy Credits

   Section 1648.3(e)(11) of Act 213 requires the Commission to develop a depreciation schedule for alternative energy credits created through demand side management, energy efficiency and load management technologies. In implementing this portion of the Act for standard energy savings measures, each savings measure in the TRM is assigned a ''measure life'' that inherently reflects depreciation. A measure life represents the average expected life of the equipment, including adjustments for possible early removal or remodeling. The measure life simply determines the number of years to count savings for the particular measure.

   The depreciation reference in Section 1648.3(e)(11) appears related to aging assets and is designed to capture the decline in energy savings and correspondingly reduce the production of alternative energy credits to reflect the decreased savings over time. The Commission believes it should adopt flexible depreciation standards for alternative energy credits produced through demand side management since not all of the technologies involve the use of depreciating assets.

   The Commission believes that an estimated depreciation factor is unneeded for measures that are separately metered. The reason is because the meter will reflect any decline in the performance of the equipment; therefore, eliminating the need to estimate a depreciation factor.

D.  Qualifying Measures

   Section 1648.2 of Act 213 defines alternative energy sources to include existing and new sources for the production of electricity by demand side management and self-generation. Thus, the Commission determines that standard, metered and custom energy savings measures that were installed prior to implementation of the Act shall be eligible to qualify for credits on a moving forward basis.

   For the standard energy savings measures that are contained in the TRM, this principle will be accounted for through each technology's measure life. For newly installed measures, the savings should be claimed over the entire measure life, even if common practice changes during the life of the measure. For previously installed measures, the savings should only extend for the remaining life of the measure. For example, if a measure with a ten year life was installed two years prior to the effective date of Act 213, the savings should only be counted for eight years.

   In implementing this portion of Act 213 for demand side management technologies, US Steel advocated in their comments to the DSM/EE WG that the Commission should avoid using a baseline calculation that only recognizes subsequent incremental on-site electricity production or conservation. US Steel argues that using a theoretical baseline calculation and recognizing only the incremental production would be inconsistent with the Act's direction to recognize existing sources and unfair to customers who have acted early and responsibly to implement energy conservation prior to the Act.

   It appears reasonable and consistent with Act 213 to recognize all of the electricity produced on-site by these facilities and not require a calculation of incremental production over a baseline figure reflecting historic energy production.¹ At the same time, implementation issues arise with such an approach. Currently, the PJM Interconnection, LLC (''PJM'') Economic Load Response Program utilizes the Customer Baseline Load (''CBL'')² calculation as a way for those customers that wish to measure load reductions to compare metered load against an estimate of what metered load would have been absent the reduction. The CBL method for determining customer baseline for reductions uses the average of highest five days of prior ten peak days. The PJM Demand Side Response Working Group is transitioning from the CBL baseline to an approach called the ''Firm Power Contract'' for resale, which uses a daily submitted schedule as the baseline for judging curtailment. Comments received from EAPA pointed out that the PJM CBL method is not practical for tracking long-term DSM measures but intended for short-term DSR activities. Firm Power Contract methodology may be considered if it becomes available in the near future, in the meantime all measures will be verified on a case by case basis. In the near term, we will accept IECPA's comments and determine as part of the application process, the benefit by measure. Such measures will be compared to industry standard applications or equipment.

   Qualifying measures must also comply with Section 1648.4 of the Act, 73 P. S. § 1648.4, which, one, prohibits the double-counting of resources towards both Pennsylvania's and another state's portfolio standard, and, two, establishes a geographic eligibility requirement. The Commission intends to address the issues of double-counting and geographic eligibility for both DSM/EE and all other alternative resources at the same time later in this implementation proceeding.

E.  Implementation and Maintenance of TRM and General Guidelines

   The Commission's Bureau of Conservation, Economics and Energy Planning (''CEEP'') will oversee the implementation, maintenance and periodic update of the TRM for the catalog measures and the general guidelines for the metered and custom measures. Updates to the TRM and general guidelines may be made on an annual basis or more or less frequently. The alternative energy credits program administrator will manage the credit certification process.³ The administrator will a) award certificates based on its review and verification of applications; b) maintain a log of issues and opportunities for improvement; and c) communicate issues to the Bureau of CEEP. The DSM/EE WG will convene periodically as requested by the Bureau of CEEP to provide input and recommendations on issues that may arise, and to develop enhancements and revisions to the TRM and general guidelines.

CONCLUSION

   This Order represents the first step in establishing a comprehensive regulatory framework for the successful implementation of Act 213. We extend our thanks to the participants in the AEPS WG and those who provided comments in helping the Commission to comply with Act 213's aggressive implementation schedule.

Therefore,

It Is Ordered That:

   1.  A copy of this Order and Annex A shall be served upon the Office of Consumer Advocate, the Office of Small Business Advocate, the Office of Trial Staff, all jurisdictional electric distribution companies, all licensed electric generation suppliers, the Pennsylvania Department of Environmental Protection, and all other members of the Alternative Energy Portfolio Standards Working Group.

   2.  The Secretary shall certify this Order and Annex A and deposit them with the Legislative Reference Bureau for publication in the Pennsylvania Bulletin.

JAMES J. MCNULTY,   
Secretary

Annex A

ENERGY--EFFICIENCY AND DSM RULES FOR PENNSYLVANIA'S ALTERNATIVE ENERGY PORTFOLIO STANDARD

TECHNICAL REFERENCE MANUAL

September 7, 2005

INTRODUCTION

   The Technical Reference Manual (TRM) provides specific efficiency thresholds and formulas to use in calculating energy-efficiency electricity savings (kWh) for Pennsylvania's Alternative Energy Portfolio Standard (AEPS). The technologies presently included in the TRM are those that are relatively easy to characterize and require few inputs for calculating savings. Other technologies may be added to the TRM over time to provide a common reference for claiming electricity savings.

   Technologies are presented in two sections, each with several end use categories:

   *  Residential Technologies

         o  HVAC
o  Lighting
o  Appliances

   *  Commercial and Industrial Technologies

         o  HVAC
o  Motors
o  Lighting

   A separate table is provided for each technology with an algorithm for calculating annual kWh savings, along with the required input assumptions to be used in the algorithm. Baseline--based on expected Pennsylvania code or federal standards in 2006--are included in the tables for the benchmark from which to count savings for the efficient measure in the algorithm. Efficiency thresholds are included for setting the minimum efficiency requirement for equipment to receive a savings credit. For illustrative purposes, example calculations are provided in the tables to show savings for measures with specific efficiencies, size or other characteristics. For proposed measures with characteristics different than the example calculation, the savings should be calculated with the algorithm using the input parameters for the particular measure.

   Each technology table also provides a measure life assumption for determining the number of years to count savings. For newly installed measures the savings should be claimed over the entire measure life, even if common practice changes during the life of the measure. For previously installed measures, the savings should only extend for the remaining life of the measure. For example, if a measure with a 10 year life was installed 2 years ago, the savings should only be counted for 8 years.

   Measure lifetimes represent the average expected life of the equipment, including adjustments for possible early removal or remodeling. In many cases the engineering technical lifetime is greater than the measure lifetime in the table used for claiming savings. The lifetime assumptions are based on lifetime assumptions used in other savings protocols, such as Vermont's Technical Reference Manual.

PURPOSE

   The framework in this TRM was developed for the purpose of estimating annual energy savings for a limited selection of energy efficient technologies and measures. The framework will provide guidance to an Administrator responsible for award of certified credits (''certificates''). The framework requires a verified number of qualifying installed units to which savings apply that would be documented by the Applicant and validated by the Administrator in awarding certificates.

GENERAL FRAMEWORK

   In general, energy and demand savings will be estimated using customer data as input values in algorithms in the protocols, tracking systems, and information from application forms, worksheets, and field tools.

   To receive energy efficiency credits, applicants must submit information in sufficient detail to support objective verification of performance, including physical verification of the measures installed, and certified performance of the measures (e.g. efficiency ratings) through Project Registration Forms and Technical Support Worksheets, which may include information as follows:

Customer Information

   Company Name
Contact Person/Title
Address
City
State
Zip
Phone
Fax
E-mail

Project Location and Information

   Address
City
State
Zip
Utility Account No

Project Participant Information

   Company Name
Contact Person/Title
Address
City
State
Zip
Phone
Fax
E-mail

Contractor/Vendor Information

   Company
Contact Name
Street Address
City
State
Zip
Telephone Number

Energy Efficient Equipment Information
   (in sufficient detail to allow verification), i.e.:

   Manufacturer
Model No
Efficiency rating
Quantity
Capacity
etc.

Proof of Purchase

   Receipts, UPC, etc.

   The Administrator will review application forms and tracking systems for all measures and conduct field inspections on a sample of installations. For some programs and jobs (e.g., custom, large process, large and complex comprehensive design), post-installation review and on-site verification of a sample of application forms and installations will be used to ensure the reliability of site-specific savings estimates.

BASELINE ESTIMATES

   Baseline values are based on the performance of new standard efficiency equipment. Baselines will be updated periodically to reflect changing codes, and common market practices.

ENERGY SAVINGS IN CURRENT AND FUTURE YEARS; DEEMED LIFE OF MEASURES / MEASURE LIVES

   Credits will apply in equal annual amounts corresponding to either: a) PJM planning years or b) calendar years beginning with the year deemed appropriate by the Administrator, and lasting for the approved life of the measure as documented in Appendix 1.

   Measure lives are assigned to each technology to reflect a number of factors, including: 1) the expected life of the technology according to industry life-expectancy statistics, 2) the likelihood units are actually installed and operational (i.e. are not purchased for stand-by service or removed through future facility upgrades), and 3) the persistence of savings (e.g. through energy substitution or supplement).

PROSPECTIVE APPLICATION OF CERTIFICATES

   The TRM will be updated periodically based on new information and available data, and then applied prospectively for future years. Such updates will not alter the number of credits, once awarded, by the Administrator.

SAVINGS CALCULATIONS WITH EXAMPLES

RESIDENTIAL TECHNOLOGIES

Central Air Conditioner

Current typical central air-conditioner (CAC) market	SEER 11
Federal standard as of January 2006 (baseline)	SEER 13
Minimum threshold for credit--ENERGY STAR	SEER 14
Estimated savings credit for a SEER 14 installation1	119 kWh
Estimated savings credit for a SEER 15 installation1	222 kWh
Estimated savings credit per CAC if SEER 14 plus documented proper sizing, charge, flow through Manual J and site measurements2	407 kWh
Estimated savings credit per CAC if SEER 15 plus documented proper sizing, charge, flow through Manual J and site measurements2	473 kWh
Change in usage calculation3	ΔkWh = ((tons × 12,000)/1,000) × (1/SEERbas - 1/SEEReffi) × FLH
Credit for proper sizing, charge and air flow4	ΔkWh = 0.20 × ((3 tons ( 12,000)/1,000) × (1/SEER) × FLH
Measure life3	18 years

[1] Based on 600 annual full load operating hours (FLH), ARI adjusted cooling hours.
[2] Based on reduction from 3 tons to 2.5 tons.
[3] From Efficiency Vermont Technical Reference Manual.
[4] Based on the LIPA Cool Homes Program (20% of improper sizing use).

Heat Pump

Current typical central air-conditioner (CAC) market	SEER 11
Federal standard as of January 2006 (baseline)	SEER 13 HSPF 7.7
Minimum threshold for credit	SEER 14 HSPF 9.0
Estimated savings credit for a SEER 14 installation1	119 kWh
Estimated savings credit for a SEER 15 installation1	222 kWh
Estimated savings credit for a HSPF 9.0 installation2	1013 kWh
Estimated savings credit if SEER 14 plus documented proper sizing, charge, flow through Manual J and site measurements3	407 kWh
Estimated savings credit if SEER 15 plus documented proper sizing, charge, flow through Manual J and site measurements3	473 kWh
Change in usage calculation4	ΔkWhcool = ((tons × 12,000)/1,000) × (1/SEERbas - 1/SEEReffi) × FLHcool ΔkWhheat = ((tons × 12,000)/1,000) × (1/HSPFbas - 1/HSPFeffi) × FLHheat
Credit for proper sizing, charge and air flow5	ΔkWh = 0.20 × ((3 tons × 12,000)/1,000) × (1/SEER) × FLHcool
Measure life4	18 years

[1] Based on 600 annual cooling full load operating hours (FLH), ARI adjusted cooling hours.
[2] Based on 1,500 annual heating FLH, ARI adjusted heating hours (excludes electric resistance hours).
[3] Based on reduction from 3 tons to 2.5 tons.
[4] From Efficiency Vermont Technical Reference Manual.
[5] Based on the LIPA Cool Homes Program (20% of improper sizing use), only cooling savings.

Compact Fluorescent Lamps

Baseline wattage purchased1	15	20	25	30
Assumed wattage replaced2	60	75	75	100
Assumed avg hrs/day use3	3.2	3.2	3.2	3.2
Estimated annual kWh savings credit	52.5	64.2	58.4	81.7
Savings calculation	ΔkWh = (Wattsbas - Wattseffi)/(1,000 × HOURS)	ΔkWh = (Wattsbas - Wattseffi)/(1,000 × HOURS)	ΔkWh = (Wattsbas - Wattseffi)/(1,000 × HOURS)	ΔkWh = (Wattsbas - Wattseffi)/(1,000 × HOURS)
Measure life4	6 years	6 years	6 years	6 years

[1] Based on typical CFL wattages
[2] Based on typical lumen equivalent substitutions
[3] From light logger study update to Impact Evaluation of the Massachusetts, Rhode Island, and Vermont 2003 Residential Lighting Programs by Nexus Market Research, Inc. and RLW Analytics, Inc., October 1, 2004
[4] Based on presumed 6,000 hour lamp life although many lamps have a rated 10,000 hour life

Compact Fluorescent Fixtures

Baseline wattage purchased1	15	20	25	30
Assumed wattage replaced2	60	75	75	100
Assumed avg hrs/day use3	2.0	2.0	2.0	2.0
Estimated annual kWh savings credit	32.8	40.1	36.5	51.1
Savings calculation	ΔkWh = (Wattsbas - Wattseffi)/(1,000 × HOURS)	ΔkWh = (Wattsbas - Wattseffi)/(1,000 × HOURS)	ΔkWh = (Wattsbas - Wattseffi)/(1,000 × HOURS)	ΔkWh = (Wattsbas - Wattseffi)/(1,000 × HOURS)
Measure life4	20 years	20 years	20 years	20 years

[1] Based on typical CFL wattages
[2] Based on typical lumen equivalent substitutions
[3] From light logger study update to Impact Evaluation of the Massachusetts, Rhode Island, and Vermont 2003 Residential Lighting Programs by Nexus Market Research, Inc. and RLW Analytics, Inc., October 1, 2004
[4] Based on presumed 40,000 hour ballast life adjusted for replacements due to remodeling, etc.

Energy Star Clothes Washers

Baseline1	MEF 1.14
Minimum threshold for credit--ENERGY STAR2	MEF 1.73
Estimated savings credit3	329 kWh
Change in usage calculation5	ΔkWh = ((volume./MEFbas) × 379) - ((volume./MEFeffi) × 379)
Measure life4	14

[1] Minimum 1.04 MEF adjusted for average sales MEF
[2] Minimum 1.42 ENERGY STAR MEF adjusted for average ENERGY STAR MEF
[3] Includes estimated weighted average electric water heating and dryer savings
[4] From Efficiency Vermont Technical Reference Manual
[5] Weighted average volume calculated to be 2.9 cu.ft. from AHAM data; weighted average 379 cycles per year from December 2000 DOE Technical Support Document for Clothes Washers

Energy Star Refrigerators

Baseline1	Minimum federal standard
Minimum threshold for credit--ENERGY STAR2	ENERGY STAR standard
Estimated savings credit	85.5 kWh
Change in usage calculation4	ΔkWh = (Wattsbas - Wattseffi)/(1,000 × HOURS)
Measure life3	17

[1] Value varies based on adjusted volume
[2] 15% higher efficiency than minimum federal standard
[3] From Efficiency Vermont Technical Reference Manual
[4] Assumed typical 5,000 operating hours per year

Energy Star Dish Washer

Baseline1	Minimum federal standard
Minimum threshold for credit--ENERGY STAR2	ENERGY STAR standard
Estimated savings credit	68.6 kWh
Change in usage calculation4	ΔkWh = (113.3 × electric water heating frequency)
Measure life3	13

[1] 0.46 energy factor
[2] 0.58 energy factor
[3] From Efficiency Vermont Technical Reference Manual
[4] assumes typical 264 cycles per year, 0.5 gal reduced water consumption per cycle and 43.6% electric water heating frequency as cited in Efficiency Vermont Technical Reference Manual

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¹  While we accept US Steel's argument on the inappropriateness of using a baseline calculation generally, the Commission acknowledges that Section 1648.3(e)(7), 73 P. S. § 1648.3(e)(7), of Act 213 places a restriction on the banking of credits during the cost-recovery period for certain alternative resource utilization that predated Act 213's effective date. Rules for the banking of alternative energy credits and any restrictions on this practice will be separately addressed by the Commission at a later date in this implementation proceeding.

²  Operating Agreement of the PJM Interconnection, LLC, pages 151-166. The Customer Baseline calculation provision is set forth in Original Sheet Nos. 156-158 and the Weather Sensitivity provisions are set forth in Original Sheet Nos. 158-159.

³  The administrator will use a credits registry to monitor compliance and provide reports to the Commission, as required by 73 P. S. § 1648.3(e)(8). The Commission continues to study PJM's Generation Attribute Tracking System. PJM continues to improve the functionality of GATS, including its ability to manage data on behind the meter applications, which will be critical to the integration of DSM/EE measures into this market.

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