The Division of Public Utilities and Carriers told the Public Utilities Commission in testimony dated Nov. 10 that it should approve Rhode Island Energy's 2027-2029 energy efficiency plan with modifications. The Energy Efficiency and Resource Management Council, which voted on Sept. 24 to endorse the plan, asked the commission in its own testimony to consider approving the 2027 components and budget and to direct the company to submit a binding plan for 2028-2030.
Both filings are in Docket 26-37-EE, where the company filed the plan on Oct. 1.
The Division's recommendations
Jennifer Kallay of Synapse Energy Economics, the Division's consultant, wrote that she has no concerns about the plan's budget, savings and benefits. She found that five electric programs and three gas programs are not cost-effective under the updated cost-of-supply calculation in at least one year of the three-year plan, and recommended approval anyway.
Her proposed modifications include a new attachment explaining the data and method behind the plan's weatherization savings for customers who convert to heat pumps, which she said the company did not document in the plan or fully supply in response to the first round of discovery. She also recommends adding the start or end of a pilot, demonstration or assessment as a trigger for a mid-term modification, and collecting only performance incentives the company actually earns, or a portion based on historical performance.
Kallay's testimony says the company proposes to cut its electric program implementation budget by $4.5 million, or 8 percent, and its gas budget by $4.2 million, or 13 percent, from 2026 to 2029.
The council's requests
The council's consultant, Adrian Caesar of Optimal Energy, testified that the council's concerns did not stop it from endorsing the plan. One is that the plan relies on the 2024 regional avoided-cost study while the company's actual 2027-2029 performance will be measured with a later study, which could let the company earn a disproportionate performance incentive if avoided costs rise. Caesar noted that the company's own testimony says it would apply the latest avoided costs to both planned and actual performance, which he said "somewhat mitigates" the concern. The council's proposed remedy is for the commission to consider approving 2027 now and to direct a binding plan for 2028-2030.
The council also asks the commission to let it request review of mid-term modifications. Under the plan, the company starts that process when it adds or removes a program or changes a sector budget by 15 percent or more, and Caesar said the council has no formal way to compel changes.
Third, the council asks the commission to direct the company to keep Home Energy Reports until a replacement behavioral program is ready. Caesar said the electric and gas versions posted benefit-cost ratios of 8.15 and 5.79 in the 2026 plan. The company removed them, saying it would consider a program using advanced metering, but the filed plan has no replacement or timeline, according to Caesar.
What comes next
The company's reply testimony is due Nov. 17. A public comment hearing is set for 9:30 a.m. on Dec. 15 in Hearing Room A, with the evidentiary hearing starting afterward and continuing Dec. 16, under the commission's second amended schedule.