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Utilities typically have to raise capital (mostly with debt and equity) to <strong>in</strong>vest <strong>in</strong> supplyside<br />

resources, and then they are later allowed to recover the <strong>in</strong>vestment plus the cost of<br />

capital through rates over the life of the asset. For energy efficiency <strong>in</strong>vestments,<br />

utilities are typically allowed to recover the <strong>in</strong>vestment immediately through system<br />

benefit charges, or <strong>in</strong> a very short amount of time through balanc<strong>in</strong>g accounts <strong>in</strong> rates.<br />

Because of this different approach to cost recovery, efficiency <strong>in</strong>vestments are a much<br />

lower f<strong>in</strong>ancial risk to utilities than supply-side resources.<br />

The discount rate applied to the TRC test and the PAC test should reflect this lower<br />

f<strong>in</strong>ancial risk of energy efficiency <strong>in</strong>vestments. We recommend that states use a generic<br />

market <strong>in</strong>dicator of a low-risk <strong>in</strong>vestment, such as the <strong>in</strong>terest rate on long-term US<br />

Treasury bills, when apply<strong>in</strong>g the TRC or the PAC test. This rate is widely accepted as<br />

represent<strong>in</strong>g low-risk <strong>in</strong>vestments, and is straightforward, transparent, and readily<br />

available.<br />

Calculation of Avoided Costs<br />

All of the relevant<br />

avoided costs should be<br />

accounted for, and each<br />

of them should be<br />

calculated correctly.<br />

<strong>Energy</strong> efficiency programs result <strong>in</strong> several types of avoided costs,<br />

and each of them should be <strong>in</strong>cluded <strong>in</strong> the screen<strong>in</strong>g analysis and<br />

calculated correctly. First and foremost, avoided energy and<br />

capacity costs should be based on long-term forecasts that properly<br />

capture the energy and capacity impacts of energy efficiency<br />

resources, account for the structure of the market <strong>in</strong> which the<br />

relevant utility operates, and capture differences between peak and<br />

off-peak periods.<br />

It is also important to account for the cost of transmission and distribution that is avoided<br />

by energy efficiency. In estimat<strong>in</strong>g these costs, program adm<strong>in</strong>istrators should<br />

dist<strong>in</strong>guish between those transmission and distribution costs that can be deferred or<br />

avoided through energy efficiency and those that cannot. Avoided distribution costs tend<br />

to be higher than avoided transmission costs, but avoided transmission costs are<br />

<strong>in</strong>creas<strong>in</strong>g, particularly <strong>in</strong> regions of the country that are expect<strong>in</strong>g significant growth <strong>in</strong><br />

new transmission <strong>in</strong>vestments.<br />

The avoided costs of compliance with environmental regulations should be explicitly<br />

accounted for <strong>in</strong> the Societal Cost test, the TRC test and the PAC test. The costs of<br />

environmental compliance will eventually be passed on to ratepayers, and those that can<br />

be avoided should be <strong>in</strong>cluded as part of the avoided costs of energy efficiency. Recent<br />

environmental regulations from the US Environmental Protection Agency are likely to<br />

<strong>in</strong>crease the costs of environmental compliance, and may require the retirement of many<br />

fossil-fired generation units, which will have significant implications for energy efficiency<br />

avoided costs.<br />

Similarly, there are several exist<strong>in</strong>g and anticipated <strong>in</strong>itiatives<br />

at the federal, regional and state levels to curtail the emissions<br />

of greenhouse gases (GHG). <strong>Energy</strong> efficiency is by far the<br />

lowest-cost and most plentiful option for meet<strong>in</strong>g these<br />

<strong>in</strong>itiatives. In order to meet climate change regulations at the<br />

lowest cost, the full avoided cost of comply<strong>in</strong>g with current and<br />

future GHG <strong>in</strong>itiatives should be accounted for <strong>in</strong> screen<strong>in</strong>g<br />

energy efficiency programs. In sum, energy efficiency should<br />

be evaluated on an equivalent basis with other options for<br />

| 4 <strong>Best</strong> <strong>Practices</strong> <strong>in</strong> <strong>Energy</strong> <strong>Efficiency</strong> <strong>Program</strong> Screen<strong>in</strong>g | www.nhpci.org<br />

In those states and regions<br />

with climate change<br />

requirements, energy<br />

efficiency should be<br />

evaluated on an equivalent<br />

basis with other options for<br />

mitigat<strong>in</strong>g greenhouse gases.

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