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Energy Efficiency Council (EEC)- Multifamily Sector Concerns

This article discusses the options for the Multifamily (MF) sector in the Energy Efficiency Council, including common area measures, statewide administration, IOU/regional administration, and removing MF from ESA structure. EEC recommendations are provided to extend the MF CAM program for deed restricted properties and ensure compliance with PU codes. The article also suggests redefining the MF category to support the recommendations.

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Energy Efficiency Council (EEC)- Multifamily Sector Concerns

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  1. Energy Efficiency Council(EEC)-Multifamily Sector Concerns

  2. CLARIFYING THE OPTIONS Clarifying Multifamily (MF) Program Options • MF Common Area Measures (CAM) w/ Statewide Administration. • MF CAM w/ IOU/Regional Administration. • Removing ALL MF from ESA structure.

  3. EEC RECOMMENDATIONS • Extend the MF CAM Program for deed restricted properties using IOU/Regional Administrators. REQUIREMENT: Building owner has a need for CAM and wants to participate. Use ESA Contractors to perform In Unit Installs. • Leave MF within current ESA structure and add “In Unit” Water heaters and Furnaces to MF component. REQUIREMENT: Building owner does NOT want or need CAM measures. • Ensure MF CAM Meets PU Code requirements 381.5 and 327(b) regarding the usage of community-based service providers.

  4. USE REGIONAL OR IOU ADMINISTRATION 1. Extend the MF CAM Program for deed restricted properties only using IOU/Regional Administrators. REQUIREMENT: Building Owner has a need for CAM and wants to participate. Use ESA Contractors to perform In Unit Installs. NOTE: There certainly are components of a MF CAM project that are outside the scope of most ESA contractors' abilities. Projects need engineers and specialty contractors to install items like common boilers. That said, engineering firms and specialty contractors who install common area boilers don’t install door weatherstripping any more than ESA contractors install boilers. There is no reason why multiple contractors cannot be used on large projects. The SPOC can coordinate specialty contractors and multiple programs. IOUs and Regional administrators are in the best position to understand the needs of local communities and individual tenants. They have existing relationships with local municipalities that can leverage water and other power services.

  5. WORKFORCE –SERVE IN-UNIT DWELLINGS THROUGH ESA 2. Leave MF within current ESA structure. REQUIREMENT: Building Owner does NOT want or need CAM measures.* BENEFITS: • Protects and preserves existing workforce. • Creates an opportunity to foster additional savings and increase health comfort and safety by adding common area lighting, in unit furnaces, water heaters and other measures for these low-income multifamily customers. NOTE: There is currently a HVAC and Water heater replacement program built into every ESA program. If the ESA contractor in the area is not licensed for HVAC, the IOUs contract the HVAC work to licensed ESA contractors. The infrastructure is already in place to support this recommendation. For example, according to the annual ESA reports, in 2018, SoCal Gas reports their ESA contractors installed 8,764 furnaces and 1,985 water heaters. Clearly, ESA has a robust HVAC program already in place. These recommendations are in line with SoCal Gas’s and SDG&E’s proposals at the 9/16/2019 LIOB meeting when presenting plan for PY2021 applications for serving non-deed restricted multifamily. *Based on the IOU presentations at the Multifamily working group (MFWG) on 10/3/2019, some building owners do not want or need CAM measures but are content with allowing their tenants to participate in ESA to receive in-unit measures.

  6. COMPLY WITH PU CODES 3. Ensure MF CAM Meets PU Code requirements 381.5 and 327(b) regarding the usage of community-based service providers. 381.5: It is the intent of the Legislature to protect and strengthen the current network of community service providers by doing the following… 327(b) If the commission requires low-income energy efficiency programs to be subject to competitive bidding, the electrical and gas corporations described in subdivision (a), as part of their bid evaluation criteria, shall consider both cost-of-service criteria and quality-of-service criteria. The bidding criteria, at a minimum, shall recognize all of the following factors… (1) The bidder’s experience in delivering programs and services, including, but not limited to, weatherization, appliance repair and maintenance, energy education, outreach and enrollment services, and bill payment assistance programs to targeted communities.

  7. RE-DEFINE MULTIFAMILY TO SUPPORT RECOMMENDATIONS Update the definition of MF. Statewide P&P currently defines MF as 5+ Attached Dwellings. SUGGESTION: Re-define into 2 categories: • MF CAM = 5+ attached dwellings where the deed restricted property qualifies for CAM measures though the CAM Program • MF = 5+ attached dwellings where the site does not want, does not qualify for or does not have a need for CAM. NOTE: As it currently stands, if MF is not re-defined and an IOU recommends moving ALL MF to a whole building SPOC approach, Condo and Townhome complexes where there are 5+ units attached could go unserved. These sites do not have common boiler systems and often have in unit heating and water systems. They do not need engineering or specialty licensed boiler contractors and as such should not be exposed to additional administrative expenses to serve these properties.

  8. WORKFORCE CONSEQUENCES • Potential consequences of removing ALL Multifamily from current ESA structure. • Lost jobs, disrupted careers and career paths. • Risky “test” because there will be no multifamily workforce available if a third-party administratorfails as contractors would have laid off a significant part of the ESA workforce. • The new administrator would not simply take on the current trained staff. The MF workforce is not MF only and cannot easily be transferred in an orderly manner. See EEC paper on: EXCLUSIVE RELIANCE ON MULTIFAMILY-ONLY ESA IMPLEMENTERS.

  9. WORKFORCE- LOST JOBS – IF MF IS REMOVED FROM ESA

  10. ESA CONTRACTORS SERVE MORE MF THAN ANYONE Over the past 11 years, 631,535 multifamily homes have been served by ESA contractors. No other group is in a better position to serve multifamily.

  11. ESA CAREER PATHS COULD BE RUINED • IOUs and program contractors have invested million of dollars and countless hours developing career paths and training the ESA workforce, an impressive cadre of talented individuals numbering in the thousands and many who came out of the communities served by ESA. • MF In Unit dwellings account for as much as one-third of ESA work annually - tens of thousands of units each year. Carving MF out of ESA will have grave implications for the current ESA workforce.

  12. EEC RECOMMENDATIONS -SUMMARY • Extend the MF CAM Program for deed restricted properties using IOU/Regional Administrators. • Leave MF In Unit work within the current ESA structure and add In Unit Water heaters and Furnaces to MF component. • Ensure MF CAM Meets PU Code requirements 381.5 and 327(b).

  13. Program Q&A • For More Information • Please contact the Energy Efficiency Council • http://www.energyefficiencycouncil.org/ • Allan Rago • arago@qcsca.com • 909-281-3531

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