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Presentation to ISO New England DRWG August 1, 2012

FERC NOPR Docket RM05-5-020 Re: NAESB Wholesale DR/EE M&V Standards Overview of Stakeholder Comments. Presentation to ISO New England DRWG August 1, 2012. OVERVIEW.

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Presentation to ISO New England DRWG August 1, 2012

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  1. FERC NOPR Docket RM05-5-020 Re: NAESB Wholesale DR/EE M&V StandardsOverview of Stakeholder Comments Presentation to ISO New England DRWG August 1, 2012

  2. OVERVIEW FERC Docket No. RM05-5-020: Standards for Business Practices and Communication Protocols for Public Utilities. Issued April 19, Comments due to FERC July 30. Overview of Stakeholder Comments Next Steps 1

  3. THREE RECOMMENDATIONS TO FERC: • Modify WEQ.021.3.11.1.9 regarding Measurement Equipment Specifications for Proxy Variables • Reinstate reference to IPMVP (industry-accepted M&V framework on which NAESB Standards are based) • Request for FERC to hold a technical conference to address Stakeholder comments 2

  4. MODIFY WEQ.021.3.11.1.9. BACKGROUND • 2007/08 - New England State Program Working Group (SPWG) raised issue with ISO-NE, and commissioned a report by RLW Analytics to look at issue. ISO-NE staff firm in position that ±2% accuracy for proxy variables required for comparability to supply side resources. • 2008 - Development of PJM M&V Manual (built largely on ISO-NE Manual). NEEP stakeholders successfully advocated to remove proxy variable measurement equipment specification to which PJM staff agreed. • Fall 2010/March 2011 - NAESB Wholesale EE M&V Working Group, led by ISO-NE staff, proposed proxy variable equip specs required in ISO-NE M&V Manual. NEEP stakeholders recommended removal of requirement (unsuccessfully, some minor change made). NAESB WEQ Exec Committee ultimately did not adopt recommendation, despite letters of support … 3

  5. Proposed Modification to NAESB Wholesale M&V STANDARDSWEQ.021.3.11.1.9 Any measurement or monitoring equipment for proxy variables that does not directly measure electrical demand, including but not limited to: voltage, current, temperature, flow rates and operating hours, shall have an accuracy to within ± 2% of full scale, unless otherwise provided in the Governing Documents. Compliance with the accuracy provisions set forth in Section WEQ.021.3.8 supersedes this proxy variable requirement. Confidence intervals per Section WEQ.021.3.8 are constructed based on the observed variability of sample measurements, where the observed sample variability inherently reflects measurement variability, as well as the underlying variability across sample points of the true variable values. 4

  6. REASONS FOR PROPOSED MODIFICATION • Requirement WEQ.21.3.11.1.9 is redundant with the overall accuracy of the Demand Reduction Value (addressed in Section WEQ.021.3.8.) • The prescribed ± 2% accuracy for measurement of “proxy variables” extends beyond the hardware-specific scope of Section WEQ.021.3.11, which requires ± 2% on power meters (which is being met by evaluation contractors) • 3. The requirement could lead to a departure from standard practice in the evaluation of EE resources, may compromise the overall accuracy of EM&V results used to quantify EE program savings while imposing higher evaluation costs on EE Providers and/or lead to barriers to participation in EE evaluation and EE programs 5

  7. Reinstate reference to IPMVP • “… NAESB has opted to remove any reference to IPMVP on the basis that it is a registered trademark, would introduce confusion to NAESB business practice standard by referencing another organization’s standard that may change, and is intended to align REQ and WEQ energy efficiency standards.” The Stakeholders generally hold the position that reference to IPMVP should be reinstated into the NAESB Standard in recognition of its strong influence on the Standard, and refer FERC to comments submitted in this docket by the Efficiency Valuation Organization (EVO) [publishers of IPMVP] regarding this issue.” • *Note: ISO-NE also removed reference to IPMVP in its M&V Manual, June 2012 Revision 4 – not clear when/where this decision to make amendment was discussed… 6

  8. Request to ferc to hold a technical conference • Issues are technical, would benefit from a technical conference • Important to bring diverging views together for more in-depth discussion, outside NAESB process • Address alignment of NAESB Wholesale EE M&V Standards with Retail EE Model Best Practices (to be voted upon by REQ Executive Committee on Aug. 22) 7

  9. Supporting Stakeholders Program Administrators Cape Light Compact Efficiency Maine Trust National Grid United Illuminating Vermont Energy Investment Corporation M&V Contractors Cadmus Group Conservation Services Group (CSG) DMI Energy & Resource Solutions, Inc. (ERS) ENE KEMA Consulting National Association of Energy Service Professionals (NAESCO) Navigant Consulting Nexant, Inc. Research Into Action SBW Consulting Shelter Analytics LLC 8

  10. NEXT STEPS • FERC Technical Conference? • Further DRWG discussion (September?) to review issues in greater depth, including addressing changes to ISO-NE M&V Manual 9

  11. Thank you! David Jacobson, DJacobson@JacobsonEnergy.com Julie Michals, jmichals@neep.org Regional EM&V Forum Northeast Energy Efficiency Partnerships 91 Hartwell Ave Lexington, MA 02421 P: 781.860.9177 www.neep.org

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