December 22, 2011 VIA ELECTRONIC MAIL ORIGINAL BY HAND ...

COMMONWEALTH OF MASSACHUSETTSDEPARTMENT OF PUBLIC UTILITIES__________________________________________Cape Light Compact to the Department of Public )Utilities, for Approval of its 2010 Electric Energy ) D.P.U. 11-68Efficiency Annual Report. )AFFIDAVIT OF KEVIN F. GALLIGANKevin F. Galligan does hereby depose and say as follows:I, Kevin F. Galligan, certify that the responses to the first set of the AttorneyGeneral’s common information requests filed on this date, on behalf of the Cape LightCompact that bear my name, were prepared by me or under my supervision and are trueand accurate to the best of my knowledge and belief.Signed under the pains and penalties of perjury.___________________________________Kevin F. GalliganDated: December 22, 2011T:\Clients\BCY\EEP\EEP Implementation\Annual Reports on EE Activities\2010 Annual Report\DPU 11-68\KFG Affidavit AG 1stSet of COMMON IRs to CLC 12-22-11 (bcy).doc

Cape Light CompactD.P.U. 11-68Response to AG Common First Set of Information RequestsDecember 22, 2011Jeffrey Leupold, Hearing OfficerPage 1 of 1AG-Comm-1-1Regarding the ENERGY STAR Appliances program, what is theNegotiated Cooperative Program as it relates to televisions?ResponseThe Compact promotes the sale of televisions with the highest efficiency levels via midstreampromotions in the form of retailer financial incentives. The intent of thisapproach is to increase sales of the most efficient models over less efficient alternatives,thus resulting in consumer energy savings.Witness responsibleKevin F. Galligan, Energy Efficiency Program Manager, Cape Light Compact.

11. Kaur, D., Peng, J., Chinta, S.J., Rajagopalan, S., Di Monte, D.A., Cherny, R.A.,and Andersen, J.K. (2006)Increased murine neonatal iron intake results in parkinson-like neurodegenerationwith age.Neurobiol. Aging. In press.12. Berg, D., Gerlach, M., Youdim, M.B., Double, K.L., Zecca, L., Riederer, P.,and Becker, G. (2001)Brain iron pathways and their relevance to Parkinson's disease.J. Neurochem. 79:225-236.13. Quik, M. (2004)Smoking, nicotine and Parkinson's disease.Trends Neurosci. 27:561-568.14. Quik, M., Parameswaran, N., McCallum, S.E., Bordia, T., Bao, S., Mc Cormack, A.,Kim, A., Tyndale, R.F., Langston, J.W., and Di Monte, D.A. (2006)Chronic oral nicotine treatment protects against striatal degenerationin MPTP-treated primates.J. Neurochem. In press.

Cape Light CompactD.P.U. 11-68Response to AG Common First Set of Information RequestsDecember 22, 2011Jeffrey Leupold, Hearing OfficerPage 1 of 1AG-Comm-1-3Regarding the Mass SAVE program, please describe the QualityControl (“QC”) process, including the number and percent ofinstallation/weatherization measures examined, the steps taken bythe Company if an installation/ weatherization measure fails theQC process, and the effect the failed QC has on the contractor whoperformed the work?ResponseIn 2010, the Compact’s Mass SAVE program used a third-party QC vendor, NorthernEnergy Services to perform quality assurance and control visits on approximately 1.6%or 37 customers. If an installation/weatherization measure failed the QC process, it wasexpected that the contractor would immediately remedy the issue. There were no majorQC failures in 2010.Witness responsibleKevin F. Galligan, Energy Efficiency Program Manager, Cape Light Compact.

Cape Light CompactD.P.U. 11-68Response to AG Common First Set of Information RequestsDecember 22, 2011Jeffrey Leupold, Hearing OfficerPage 1 of 1AG-Comm-1-4Regarding the Mass SAVE program, how to the Companiesdetermine that a “high level of customer satisfaction” (see NSTARElectric 2010 EEAR, p. 23) exists enabling a contractor to remainwithin the program?ResponseThe Compact utilized a one-stop-shopping model through its vendor RISE Engineering.RISE ensured that all customers were met with the best quality work.Witness responsibleKevin F. Galligan, Energy Efficiency Program Manager, Cape Light Compact.

Cape Light CompactD.P.U. 11-68Response to AG Common First Set of Information RequestsDecember 22, 2011Jeffrey Leupold, Hearing OfficerPage 1 of 1AG-Comm-1-5Regarding the Mass SAVE program, please provide the number,individual incentive amount and total incentive amount paid tocontractors who installed retrofit weatherization measures.ResponseThe Compact did not offer any direct monetary incentives in 2010 to contractors whoinstalled retrofit weatherization measures. However, the Compact sponsoredsubsidized trainings (e.g., Weatherization Bootcamps) as a means to incentivize andattract contractor participation. In 2010, the Compact invested approximately $20,000in contractor training/workforce development subsidies.Witness responsibleKevin F. Galligan, Energy Efficiency Program Manager, Cape Light Compact.

Cape Light CompactD.P.U. 11-68Response to AG Common First Set of Information RequestsDecember 22, 2011Jeffrey Leupold, Hearing OfficerPage 1 of 2AG-Comm-1-6Regarding the Residential New Construction and MajorRenovation program, please describe the new Tier structure put inplace in 2011 and note 1) how it differs from the Tier structure inplace in 2010 and 2) the effect of the difference(s).ResponseIn 2010, the program design was based on a National Home Energy Rating System(“HERS”) score. A new program design element was established for the 2011 programyear which requires each qualifying home to obtain a minimum percent savings over theMA User Defined Reference home.1.) Below is the comparison of the 2010 tier structure and 2011 tier structure:2010Code Plus:6 Air Changes per Hour CFM 50, 8 percent duct leakageTier I: ENERGY STAR compliance with a minimum HERS Index of 85or lessTier II: ENERGY STAR compliance with a minimum HERS Index of 85or less and 30% improvement or better over the MA User DefinedReference HomeTier III: ENERGY STAR compliance with a minimum HERS Index of 85or less and 60% improvement or better over the MA User DefinedReference Home2011Code Plus:Tier I:Tier II:No longer an option15% improvement or better over the 2011 MA User DefinedReference Home and compliance with the Thermal BypassChecklist or the Air Sealing and Insulation Section of the ThermalEnclosure Checklist30% improvement or better over the 2011 MA User DefinedReference Home and compliance with the Thermal BypassChecklist or the Air Sealing and Insulation Section of the ThermalEnclosure Checklist

Cape Light CompactD.P.U. 11-68Response to AG Common First Set of Information RequestsDecember 22, 2011Jeffrey Leupold, Hearing OfficerPage 2 of 2Tier III:45% improvement or better over the 2011 MA User DefinedReference Home and compliance with the Thermal BypassChecklist or the Air Sealing and Insulation Section of the ThermalEnclosure Checklist2.) Due to the variation of savings results generated by homes in the various tiers during2010, the program changed the tier structure in 2011 (as described above). The effect ofthis change has enabled greater and more precise savings.Witness responsibleKevin F. Galligan, Energy Efficiency Program Manager, Cape Light Compact.

Cape Light CompactD.P.U. 11-68Response to AG Common First Set of Information RequestsDecember 22, 2011Jeffrey Leupold, Hearing OfficerPage 1 of 1AG-Comm-1-7Please indicate which behavioral pilot the Company offered in2010. If the Company offers a behavioral pilot, explain how theCompany intends to determine the persistence of any behavioralchanges made by the participants.ResponseThe Compact offered a smart home energy monitoring behavioral feedback pilotin 2010. The evaluation of persistence of this pilot is ongoing.Witness responsibleKevin F. Galligan, Energy Efficiency Program Manager, Cape Light Compact.

Cape Light CompactD.P.U. 11-68Response to AG Common First Set of Information RequestsDecember 22, 2011Jeffrey Leupold, Hearing OfficerPage 1 of 1AG-Comm-1-8Describe the impact the new marketing strategies implemented inthe Residential New Construction and Major Renovation program(see NSTAR Electric 2010 EEAR, p. 12) had on participation.ResponseDuring 2010, the slow construction market created challenges in meeting participationand energy savings goals. Through the implementation of expanded recruitment andoutreach initiatives the Compact overcame these market barriers to increase participationrates in the Residential New Construction and Major Renovation Program to theprograms’ highest levels in the past three years.Witness responsibleKevin F. Galligan, Energy Efficiency Program Manager, Cape Light Compact.

Cape Light CompactD.P.U. 11-68Response to AG Common First Set of Information RequestsDecember 22, 2011Jeffrey Leupold, Hearing OfficerPage 1 of 1AG-Comm-1-9For each sector, did the Company have budget dollars that carriedover from program year 2010 to program year 2011? If yes, wasthe 2011 budget reduced to reflect the carry-over amount? Pleaseexplain. How was any carryover accounted for in the energyefficiency reconciliation factors (“EERF”) (electric) and/or theconservation charge (gas)?ResponseThe Compact had a positive carryover from program year 2010 to program year 2011 forall sectors. A positive carryover indicates that the Compact did not fully expend itsplanned budget. The updated budget in the Compact’s 2011 Mid-Term Modification andfiled in October 2010 did not reflect this positive carryover since the carryover fromprogram year 2010 to program year 2011 was not known at the time of the filing. The2010 carryover was accounted for in the 2011 EERF filing since this filing occurred after2010 carryover values were finalized. The positive carryover from 2010 reduced theactual EERF charge for 2011 that went into effect in July 2011 as compared to theestimated EERF charge for 2011 as shown in the Compact’s 2011 Mid-TermModification filed in October 2010.Witnesses responsibleKevin F. Galligan, Energy Efficiency Program Manager, Cape Light Compact.

Cape Light CompactD.P.U. 11-68Response to AG Common First Set of Information RequestsDecember 22, 2011Jeffrey Leupold, Hearing OfficerPage 1 of 2AG-Comm-1-10Regarding the electric PAs, energy efficiency programs, pleaseprovide the amount of 2010 energy efficiency savings bid into theFCM. Please describe how the bid was developed?ResponseThe calendar year 2010 spans two separate capacity commitment periods (“CCPs”).These CCPs begin on June 1 of each year, and run for 12 months, ending on May 31 ofthe following year. Hence, electric energy efficiency savings to be delivered in Januarythrough May of 2010 are put into one CCP (“CCP-1”), and those delivered in Junethrough December of 2010 into another period (“CCP-2”).CCP-1As a potential supplier of a new capacity resource, the Compact was required to submit aShow of Interest form (“SOI-1”) before February 28, 2007 and a New CapacityQualification Package (“QP-1”) before June 15, 2007. For a full schedule ofqualification and auction dates, see section III.13.1.10 of Market Rule 1 of the ISO-NEtariff.In its SOI-1, developed to meet the February 2007 deadline, the Compact estimated that itwould be able to deliver 9.886 MW of demand reduction using measures installed fromJuly 2006 through May 2010. Only those efficiency measures installed after June 16,2006 were eligible to be offered into the FCM. Like all program administrators, theCompact was required to estimate the amount of savings that would be installed in thethree-year period between the SOI-1 submittal and the delivery date in June 2010.Subsequently, for the June 2007 deadline, the Compact prepared a New CapacityQualification Package to submit to the ISO. At that time it estimated that it would beable to deliver 9.559 MW of demand reduction from measures installed from July 2006through May 2010 that refined the SOI-1 estimate. The Compact, utilizing the bestinformation available at the time, assumed that 2006 calendar year program activity andimpact factors would continue at the same level for the 46 month period between July2006 and April 2010, allowing for one full month of lag time to report installed measuresbefore June 2010.After its review, the ISO-NE accepted this second amount of qualified demand reduction.Accordingly, the Compact offered all 9.559 MW into FCA-1, held in February 2008, atthe floor price for that auction. The entire amount cleared in the auction.

Cape Light CompactD.P.U. 11-68Response to AG Common First Set of Information RequestsDecember 22, 2011Jeffrey Leupold, Hearing OfficerPage 2 of 2CCP-2The Compact measures installed from May 2010 through December 2010 were reportedand counted towards the second capacity commitment period, which ran from June 2011– May 2012. As a potential supplier of a new capacity resource, the Compact once againwas required to submit a SOI-2 form before November 14, 2007 and a QP-2 before April29, 2008.In its SOI-2, developed to meet its November 2007 deadline, the Compact estimated itwould be able to deliver 1.781 MW of demand reduction (as an incremental expansion toits existing qualified project) using measures installed from June 2010 – May 2011. Likeall program administrators, the Compact was required to estimate the amount of savingsthat would be installed three years in advance of the delivery date in June 2011.Subsequently, to meet its April 2008 deadline, the Compact prepared a New CapacityQualification Package to submit to the ISO. At that time, the Compact estimated that itwould be able to deliver 1.606 MW of demand reduction using measures installed fromJune 2010 through May 2011 that refined the SOI-2. The Compact, utilizing the bestinformation available at the time, assumed that the 2007 calendar year program activityand impact factors would continue at the same level for the 12 month period betweenJune 2010 and April 2011, allowing for one full month of lag time to report installedmeasures before June 2010.After its review, the ISO-NE accepted this amount as qualified demand reduction.Accordingly, the Compact offered all 1.606 MW into FCA-2, held in December 2008, atthe floor price for that auction. The entire amount cleared in the auction.Witness responsibleKevin F. Galligan, Energy Efficiency Program Manager, Cape Light Compact.

Cape Light CompactD.P.U. 11-68Response to AG Common First Set of Information RequestsDecember 22, 2011Jeffrey Leupold, Hearing OfficerPage 1 of 1AG-Comm-1-11Please provide the dollar amount of Lost Base Revenue that theCompany is seeking and include the manner in which the figurewas calculated. Is the Company currently collecting 2010 LBRsthrough the EERF or conservation charge?ResponseThis inquiry is not applicable to the Compact, as it does not collect Lost Base Revenue.Witness responsibleKevin F. Galligan, Energy Efficiency Program Manager, Cape Light Compact.

Cape Light CompactD.P.U. 11-68Response to AG Common First Set of Information RequestsDecember 22, 2011Jeffrey Leupold, Hearing OfficerPage 1 of 1AG-Comm-1-12Please indicate the number of HEAT Loans issued for eachCompany in 2010.ResponseThe Cape Light Compact issued 86 HEAT Loans in 2010.Witness responsibleKevin F. Galligan, Energy Efficiency Program Manager, Cape Light Compact.

Cape Light CompactD.P.U. 11-68Response to AG Common First Set of Information RequestsDecember 22, 2011Jeffrey Leupold, Hearing OfficerPage 1 of 1AG-Comm-1-13Regarding the Residential Heating and Water Heating program,please indicate whether the Company offered incentives tocontractors, the amount of the incentive and the total amount ofincentives paid in 2010.ResponseThis inquiry is not applicable to the Compact, as it did not offer the Residential Heatingand Water Heating program in 2010.Witness responsibleKevin F. Galligan, Energy Efficiency Program Manager, Cape Light Compact.

Cape Light CompactD.P.U. 11-68Response to AG Common First Set of Information RequestsDecember 22, 2011Jeffrey Leupold, Hearing OfficerPage 1 of 1AG-Comm-1-14Regarding the Residential Heating and Water Heating program,indicate which rebates were lowered and which were droppedcompletely. Explain how these decisions were informed by theHEHE Process and Impact Evaluation.ResponseThis inquiry is not applicable to the Compact, as it did not offer the Residential Heatingand Water Heating program in 2010.Witness responsibleKevin F. Galligan, Energy Efficiency Program Manager, Cape Light Compact.

Cape Light CompactD.P.U. 11-68Response to AG Common First Set of Information RequestsDecember 22, 2011Jeffrey Leupold, Hearing OfficerPage 1 of 1AG-Comm-1-15Regarding the minimization of administrative costs, pleasedescribe, for each sector, how account managers or otherindividuals involved in customer service activities “sell” energyefficiency to customers?ResponseAll Compact staff, including the customer service call center, located in the Compactoffices, worked collaboratively to “sell” energy efficiency to all customers. With thiscomprehensive approach, each customer is offered information for any area of interest.In addition, all Compact staff were involved in the design, development and launch of anew website (www.capelightcompact.org) in 2010 that continues to provide easy accessfor staff to quickly and consistently respond to customer inquiries about programincentives and offerings (as well as links to the statewide MassSave.com website).In addition, all Compact staff, and Governing Board members, volunteer to speak atpublic community meetings, trade shows and host booths at events throughout the year,that incur little or no cost, to inform and “sell” energy efficiency to customers byencouraging them to sign-up for energy assessments, offering raffles and providingdemonstrations of actual program services. The Compact also utilizes a very low costwebservice to issue periodic eNewsletters that are developed with input from all staff topromote timely energy efficiency service offerings for subscribers.Witness responsibleKevin F. Galligan, Energy Efficiency Program Manager, Cape Light Compact.

Cape Light CompactD.P.U. 11-68Response to AG Common First Set of Information RequestsDecember 22, 2011Jeffrey Leupold, Hearing OfficerPage 1 of 1AG-Comm-1-16Regarding the minimization of administrative costs, has theCompany quantified the “control” of these costs through itsparticipation in the statewide planning process?ResponseThe Compact has not specifically “quantified” or determined a precise dollar savingsvalue relative to the administrative cost benefits of its participation in the statewideplanning process. However, due to the sharing of costs that would otherwise be borne byeach Program Administrator individually, it is apparent that significant minimization ofadministrative costs has occurred. The Program Administrators have sought to minimizeadministrative costs through collaborative statewide planning and the sharing of costsassociated with statewide efforts, including preparation for regulatory filings, coordinatedprogram delivery and reporting mechanisms, joint EM&V studies, collaborativelydeveloped Request for Proposals, and statewide marketing. Without this cost sharing,administrative costs would be markedly higher for all Program Administrators.Witness responsibleKevin F. Galligan, Energy Efficiency Program Manager, Cape Light Compact.T:\Clients\BCY\EEP\EEP Implementation\Annual Reports on EE Activities\2010 Annual Report\DPU 11-68\Responses to AGCOMMON First Set of IRs 12-22-11 Final (bcy).doc