RESPONSES TO INTERROGATORIES OF CANADIAN ENERGY EFFICIENCY ALLIANCE

Transcription

1 Schedule Page of INTERROGATORY : Reference(s): none provided The Canadian Energy Efficiency Alliance (The Alliance) acknowledges Toronto Hydro s extensive experience in developing, delivering and implementing CDM programs particularly from 00 to 00. Please provide completed evaluations of its previous programs and sample copies of presentations, or other documentation that have been provided to other agencies or utilities which have emulated any of its previous programs. 0 0 Since 00, THESL has been delivering conservation and demand management (CDM) programs on target and on budget. As the architect and implementer of many awardwinning and emulated programs, THESL has a team of experienced staff dedicated to helping customers with energy efficiency, conservation, and demand response. THESL has demonstrated leadership in the development of programs such as peaksaver, which boasts over,000 installations in Toronto and was adopted as a province-wide program. THESL has consistently applied innovation in many of the programs in the residential mass market and business market. THESL has demonstrated its leadership through collaboration with numerous local partners and agencies, the Coalition of Large Distributors (CLD),and gas companies. The tables below list CDM programs executed by THESL, by year (results are not cumulative), highlighting collaboration and successes. Note that values are rounded.

2 Schedule Page of 00 Toronto Hydro CDM Programs Produced first CDM Progress Report in collaboration with CLD PROGRAM PROGRAM DEVELOPMENT PARTNER COLLABORATION Spring CFL Coupon First coupon offering compact flourescent light bulb (CFL) bulbs for the price of one The Home Depot PROGRAM HIGHLIGHTS & SUCCESSES Over,000 CFLs in market RAC Recycling Program Bring in a room air conditioner (RAC) and get a $ gift card The Home Depot Clean Air Foundation (CAF), City of Toronto, Ministry of the Environment Over,000 room air conditioners off the grid and recycled Bright Ideas Get two free CFL bulbs The Home Depot Over 0,000 CFLs distributed to almost 0,000 householders Over 00,000 in incremental CFL sales achieved Seasonal LED Light Exchange Bring in string of traditional holiday lights and get a $ voucher towards light emitting diode (LED) lights The Home Depot Almost,000 traditional strings off the grid and recycled and over,000 Seasonal LEDs purchased Cool Shops Program Small business outreach to identify and implement in store energy management measures Clean Air Foundation (CAF) Flagship program in Toronto Lighting audits conducted. Over,00 CFLs distributed

3 Schedule Page of 00 Toronto Hydro CDM Programs Produced first CDM Progress Report in collaboration with CLD PROGRAM PROGRAM DEVELOPMENT PARTNER COLLABORATION TAPS PROGRAM Festive Light Exchange Energy efficiency installations, targeting homes with electric water heaters, electric heating PROGRAM DEVELOPMENT Bring in two traditional lights strings and get one free string of Seasonal LEDs Enbridge Gas (and contractor network) PARTNER COLLABORATION City of Toronto, Toronto Association of Business Improvement Areas (TABIA) PROGRAM HIGHLIGHTS & SUCCESSES Almost,000 homes visited with over 0,000 CFLs distributed PROGRAM HIGHLIGHTS & SUCCESSES,00 traditional strings off the grid and recycled and,00 Seasonal LEDs given away Fridge Unplugged Old fridges picked up from homes for recycling and Power Pacs (containing energy efficient products) provided 00 Got Junk, Total Home Comfort Almost,000 working fridges collected during three month campaign peaksaver Switch installed on CAC to cycle down unit during peak times $ cheque for enrollment Toronto Hydro designed program Almost 00 installations for the program which was launched mid year Business Incentives power WISE Business Incentive Program Incentives for over 0 kw customers. CLD collaboration to launch powerwise Business Incentive Program (PBIP) CLD, Enbridge Gas, City of Toronto Launched incentives for business customers. Completed initial lighting retrofits and other energy efficiency measures such as chillers and motors

4 Schedule Filed: 0 Apr Page of 00 Toronto Hydro CDM Programs Produced first CDM Progress Report in collaboration with CLD PROGRAM PROGRAM DEVELOPMENT PARTNER COLLABORATION PROGRAM HIGHLIGHTS & SUCCESSES DAP Design Advisory Program Enbridge Gas, City of Designed in 00 for 00 (DAP) for the installation Toronto rollout of energy efficient equipment during construction Low Income Program Received EDA Innovations Award PR (all CDM campaigns) With CLD, received Ontario Energy Association Company of the Year PROGRAM PROGRAM DEVELOPMENT PARTNER COLLABORATION peaksaver RAC Recycling Program Initiatives (lighting retrofits and appliance replacements) by SHSC and TCHC targeting low income sector 00 Toronto Hydro CDM Programs Same program as 00 CLD Same program as prior year Toronto Community Housing Corp. (TCHC) Social Housing Services Corp. (SHSC) The Home Depot, CAF, Ministry, NRCAN, Conservation Bureau Initiated partnerships and launched program PROGRAM HIGHLIGHTS & SUCCESSES Platt s Global Energy award winner and one of the first programs Premier Dalton McGuinty and then Minister of Energy rolled out across Ontario. Over,000 installed devices Over,00 RACs off the grid and recycled

5 Schedule Page of 00 Toronto Hydro CDM Programs Received EDA Innovations Award PR (all CDM campaigns) With CLD, received Ontario Energy Association Company of the Year PROGRAM PROGRAM DEVELOPMENT PARTNER COLLABORATION Summer Challenge Bright Ideas fall multi retail Festive Light Exchange Developed by Toronto Hydro staff this was the first program of its kind in Canada Asked customers to save 0% get 0% off their bill Expanded offering from campaigns past: free CFL pack; exchange old halogen floor lamps; exchange festive lights; get coupons (leveraged high traffic of THESL events to offer OPA coupons); sign up for peaksaver. events (largest number of events to date) and first campaign with multiple retailers: The Home Depot, Costco, Home Hardware, Wal Mart OPA EKC PROGRAM HIGHLIGHTS & SUCCESSES Launched with then Minister of Energy and one of the first programs then directed to be rolled out across Ontario. Winner of CPRS ACE Awards, CMA Award, IABC Silver Leaf Award, Green Toronto Award. % of customers received credit Almost,000 CFLs distributed Almost,00 halogen torchieres and,000 incandescent festive light strings turned in. peaksaver signups. Incremental sales (OPA coupons): over 00,000 CFLs and,00 thermostats; almost,000 dimmers and 00 motion sensors Same program as 00 City of Toronto, TABIA,00 traditional strings off the grid and recycled,00 Seasonal LEDs distributed Cool Shops Program Same program as 00 The Home Depot, CAF Audited over 0 businesses

6 Schedule Filed: 0 Apr Page of 00 Toronto Hydro CDM Programs Received EDA Innovations Award PR (all CDM campaigns) With CLD, received Ontario Energy Association Company of the Year PROGRAM PROGRAM DEVELOPMENT PARTNER COLLABORATION PROGRAM HIGHLIGHTS & SUCCESSES TAPS Same program as 00 Enbridge Gas Over,000 homes visited, almost 0,0000 CFLs distributed Business Incentives power WISE Business Incentive Program DAP Same program as 00 CLD, Enbridge Gas, City of Toronto Same program as 00 Enbridge Gas, City of Toronto Over projects Seven buildings Low Income Program Same program as 00 Toronto Community Housing Corp. (TCHC) Social Housing Services Corp. (SHSC) 00 Toronto Hydro CDM Programs Over,000 stoves and refrigerators installed at TCHC buildings International Association of Business Communicators, Gold Quill Award of Excellencee and CPRS Ace National Gold Award for THESL Talk Box (used at CDM events to engage customers in a dialogue about conservation) PROGRAM PROGRAM DEVELOPMENT PARTNER PROGRAM HIGHLIGHTS & COLLABORATION SUCCESSES peaksaver Same program as 00, with incentive of a $ cheque for installation Almost,0000 installed devices (almost,0000 of these weree commercial)

7 Schedule Filed: 0 Apr Page of 00 Toronto Hydro CDM Programs International Association of Business Communicators, Gold Quill Award of Excellencee and CPRS Ace National Gold Award for THESL Talk Box (used at CDM events to engage customers in a dialogue about conservation) PROGRAM PROGRAM DEVELOPMENT PARTNER PROGRAM HIGHLIGHTS & COLLABORATION SUCCESSES RAC Recycling Program Same program as prior years The Home Depot Clean Air Foundation (CAF) Over,000 inefficient units collected and recycled over weekends in June Business Incentives power WISE Business Incentive Program Same PBIP program as 00 THESL transitioned to new BIP program below under OPA CLD, Enbridge Gas, City of Toronto 0 projects BIP Business Incentive Program (BIP) Launched revamped program in August 00 under OPA OPA directive disallowed THESL working with Enbridge or City of Toronto unlike PBIP above projects within first six months of launch DAP Same program as prior years Enbridge only (OPA directive disallowed THESL working with City of Toronto) Ten buildings

8 Schedule Page of 00 Toronto Hydro CDM Programs International Association of Business Communicators, Gold Quill Award of Excellence and CPRS Ace National Gold Award for THESL Talk Box (used at CDM events to engage customers in a dialogue about conservation) PROGRAM PROGRAM DEVELOPMENT PARTNER COLLABORATION PROGRAM HIGHLIGHTS & SUCCESSES Festive Light Exchange Same program as prior years TABIA and Cavalcade of Lights IABC Communications Award Almost,000 sets of incandescent seasonal lights turned in and almost,00 SLEDs given in exchange Summer Challenge for Business Building off of residential Summer Challenge success, launched program for business first of its kind in Canada Two IABC (International Association of Business Communicators) and two CPRS (Canadian Public Relations Society) Awards, as well as Chartwell and the Canadian Marketing Association (CMA). Almost,000 business customers got 0% credit. Summer Savings Same premise as Toronto Hydro s Summer Challenge, now overseen by OPA OPA THESL collaborated with OPA as they rolled out a program province wide based on Toronto Hydro s program % of THESL s eligible residential customers got a 0% credit The Great Refrigerator Round Up (TGRR) Have your old, second fridge picked up for free out of your home OPA OPA rolled out this CLD program province wide Over,000 appliances picked up in Toronto

9 Schedule Filed: 0 Apr Page of 00 Toronto Hydro CDM Programs International Association of Business Communicators, Gold Quill Award of Excellencee and CPRS Ace National Gold Award for THESL Talk Box (used at CDM events to engage customers in a dialogue about conservation) PROGRAM PROGRAM DEVELOPMENT PARTNER PROGRAM HIGHLIGHTS & COLLABORATION SUCCESSES TAPS Same program as prior years Partnership ended in 00, as THESL transition to OPA programs Enbridge Gas Over,000 CFLs distributed Low Income Program Same program as prior years until THESL transitioned to new SHSC and TCHCC (OPA directive disallowed Under THESL s old program: Almost,0000 old fridges and program under OPA THESL working with TCHC stoves replaced at TCHC on a go forward basis, so buildings TCHC partnership ended) Lighting retrofits at seven SHSC locations OPA Under THESL s new OPA program: Over 0,000 CFL bulbs installed at SHSC buildings 00 Toronto Hydro CDM Programs Chartwell Best Practices Award, Marketing PROGRAM PROGRAM DEVELOPMENT PARTNER PROGRAM HIGHLIGHTS & COLLABORATION SUCCESSES Peaksaver Same program, various incentives Over 0,000 installed devices (0 of these were commercial) Summer Sweepstakes OPA program OPA Almost,00 registered customers achieved 0% consumption reduction

10 Schedule Filed: 0 Apr Page 0 of 00 Toronto Hydro CDM Programs Chartwell Best Practices Award, Marketing PROGRAM PROGRAM DEVELOPMENT PARTNER PROGRAM HIGHLIGHTS & COLLABORATION SUCCESSES TGRR Have your old, second fridge picked up for free out of your home OPA Over,00 appliances collected PROGRAM PROGRAM DEVELOPMENT PARTNER COLLABORATION PROGRAM HIGHLIGHTS & SUCCESSES Festive Light Exchange Same program as prior years TABIA and Cavalcade of Lights Bronze Award winner for CPRS Ace Toronto Community relations campaign of the year. Almost,0000 strings of incandescent lights exchanged for approximately,00 strings of LED lights Low Income Program Same program as 00, but introduced Community Champion component SHSC Over,000 CFL bulbs installed in over,0000 tenant units. Community Champion program saw individuals attend hours of training sessions at Seneca College s Centre for Built Environment Take a Load Offf Toronto Spring Multi retail Get a free retractablee clothesline; get discounts on cold water laundry detergent and specialty CFLs; get EKC coupons; sign up for peaksaver in store events with: Costco Wholesale, The Home Depot, Wal Mart and Zellers Premier McGuinty launched program with THESL. Winner of three IABC awards, a CMA award and eight CPRS awards including creative PR campaign of the year.,000 clotheslines distributed, almost,0000 specialty CFLs sold, over,000 cold water laundry detergent sold. Over,00 peaksaver signups.

11 Schedule Filed: 0 Apr Page of 00 Toronto Hydro CDM Programs Chartwell Best Practices Award, Marketing PROGRAM PROGRAM DEVELOPMENT PARTNER PROGRAM HIGHLIGHTS & COLLABORATION SUCCESSES RAC Recycling Program Same program as prior years, tied in peaksaver program The Home Depot Clean Air Foundation (CAF) Two CPRS and an IABC Award Over,00 inefficient units collected and recycled Over 00 peaksaver signupss BIP Same program Over 00 projects 00 Toronto Hydro CDM Programs PROGRAM PROGRAM DEVELOPMENT PARTNER COLLABORATION PROGRAM HIGHLIGHTS & SUCCESSES Peaksaver Same program, various incentives with incentive increase to $ Over 0,000 installations (mainly residential customers) Summer Challenge Similar to Toronto Hydro s original Summer Challenge, except with registration criteria Over,00 registered customers achieved the 0% reduction

12 Schedule Filed: 0 Apr Page of 00 Toronto Hydro CDM Programs PROGRAM PROGRAM DEVELOPMENT PARTNER COLLABORATION PROGRAM HIGHLIGHTS & SUCCESSES RAC Recycling Program Same program The Home Depot Clean Air Foundation (CAF) Collected approximately,00 inefficient room air conditioners and approximately,00 old dehumidifiers BIP Same program Almost 0 projects PSB Power Savings Blitz (PSB) First full year of program (launched late 00) Completed approximately,000 lighting retrofits and achieved more than double the annual energy savings targett set by OPA DCIP Data Centre Incentive Program (DCIP) Based on an OPA approved PowerStream program PowerStream, IT community Approved project applications in 00

13 Schedule Filed: 0 Apr Page of 00 Toronto Hydro CDM Programs PROGRAM PROGRAM DEVELOPMENT PARTNER COLLABORATION PROGRAM HIGHLIGHTS & SUCCESSES Festive Light Exchange Same program events with TABIA and Cavalcade of Lights Collected approximately,000 strings of old Christmas lights, distributed approximately 0,000 LED strings Spring Turn On Receive a specialty CFL plus THESL coupons Education on phantom power and time of use rates 00 events at The Home Depot and Canadian Tire Distributed approximately 0,000 specialty CFLs Over,00 specialty CFLs and over,00 power bars with timers/sensors sold Low Income Program TGRR In suite light replacement program and the Community Champion program Same program SHSC and Green Light on a Better Environment (GLOBE) Installed approximately,000 CFLs in approximately 0,00 social housing units across Toronto By the end of 00, 0 Community Champions and 0 individuals, ncluding housing providers and staff, were trained Created a unique PR campaign to promote program, winning two CPRS and three IABC Awards. Collected approximately,00 appliances

14 Schedule Filed: 0 Apr Page of 00 Toronto Hydro CDM Programs PROGRAM PROGRAM DEVELOPMENT PARTNER COLLABORATION PROGRAM HIGHLIGHTS & SUCCESSES peaksaver Same program as prior year Toronto Hydro peaksaver creative won 00 NAMMU award Over,000 installations (mainly residential) About % of enrollments came from Toronto Hydro event sign ups The Great Exchange Toronto Hydro designed. Broadened retail partners and collection outside of retailers Collected,00 inefficient room A/C units and,00 old dehumidifiers BIP Same program Over 00 projects PSB Same program,00 lighting retrofits DCIP Same program as previous year PowerStream, IT community Approved project applications and delivered projects

15 Schedule Page of 00 Toronto Hydro CDM Programs PROGRAM PROGRAM DEVELOPMENT PARTNER COLLABORATION PROGRAM HIGHLIGHTS & SUCCESSES Festive Light Exchange Same program Collected,000 strings of old Christmas lights in exchange for,00 LED strings or gift cards Take A Load Off Toronto Hydro designed program. Purchase an ENERGY STAR washing machine and receive an instant $0 rebate, a free drying rack ($ value) and a $0 mail in rebate Caplan s Appliances and The Home Depot City of Toronto Water Department Sold,00 ENERGY STAR washers and distributed,00 dying racks Beat the Peak Designed and applied by Toronto Hydro to OPA through custom program mechanism. Leveraged high traffic THESL events to offer OPA coupons Walmart, Sears, Canadian Tire, Staples, school boards, Ontario Electronics Stewardship (OES) OPA Winner of EDA Innovation Award Distributed,000 power bars with timers Great Refrigerator Round Up Same program OPA Collected over,00 refrigerators and freezers

16 Schedule Page of 00 Toronto Hydro CDM Programs PROGRAM PROGRAM DEVELOPMENT PARTNER COLLABORATION PROGRAM HIGHLIGHTS & SUCCESSES HELP Low Income Program THESL custom program which provides low income single family homes with: insulation; furnace upgrade; low flow toilets; power bars; CFLs; drying racks; window a/c replacement; timers City of Toronto; Enbridge; City of Toronto Water Department Program launched in fall 00 Program is ongoing Vending Miser THESL custom program encouraging businesses to take advantage of a $0 incentive for an energy management system for refrigerated vending machines 00 installed GreenEats Custom program is a collaboration between partners to offer existing programs (BIP/PSB) to segment through trusted industry association. Educations on TOU rates, time shifting and CDM programs Ontario Restaurant Hotel and Motel Association; Enbridge Over leads generated during three month initiative Ice Bear Pilot Pilot rolled out at selected small commercial building sites in THESL and Veridian territory for the installation of Ice Energy (energy storage solution) OPA, Veridian, Summerhill, IceBear Twelve installations during fall 00 Pilot is ongoing

17 Schedule Page of INTERROGATORY : Reference(s): none provided While the Alliance complements Toronto Hydro in participating in the redevelopment of the Ontario Power Authority ("OPAU)-Contracted Province-Wide Conservation and Demand Management Programs (OPA Programs), what process was followed to develop these programs? Did the OPA provide Toronto Hydro with any financial resources to cover the cost of staff time associated with these processes? 0 0 The process is as follows: ) The EDA established a Joint Steering Committee (JSC) and CDM Caucus to govern the re-development of the OPA province-wide programs. ) Working groups were established with membership from large, medium and small local distributors companies ( LDCs ) who were assigned to support program development. ) The working groups met routinely to advance the development of each program. ) Program development work was brought before the CDM Caucus and ultimately the JSC for approval and recommendation to all LDCs. Yes, the Master CDM Program Agreement between the OPA and the LDCs allow for the recovery of all Eligible Expenses associated with the 00 working groups and will form part of the LDC s 0 Program Administration Budget.

18 Schedule Page of INTERROGATORY : Reference(s): none provided What limitations, if any, did Toronto Hydro encounter in participating in redeveloping the OPA programs including availability of resources, timely access to information, particularly respect to the proposed program designs, projected program budgets, cost/benefit analysis of plans, programs and specific measures as well as estimated targets. What evaluations of earlier OPA programs were provided to Toronto Hydro? Please file copies of all evaluations of OPA programs provided to Toronto Hydro. 0 THESL submits that by its application submission date it had all the required information to accurately file its proposed Board-approved programs in compliance with the OEB s CDM Code. To THESL s knowledge, no evaluation of earlier OPA programs was provided to Toronto Hydro.

19 Schedule Page of INTERROGATORY : Reference(s): none provided The OEB s CDM Code requires each LDC to file a CDM Strategy and provides a template for doing so, which Toronto Hydro appears to have conformed to in its application. Did the OPA provide similar documentation to Toronto Hydro? If so please file any shared OPA documents that would approximate what is included in the OEB template requirements. 0 No, THESL did not receive any CDM Strategy or similar documentation from the OPA.

20 Schedule Page of INTERROGATORY : Reference(s): none provided It appears to the Alliance that Toronto Hydro has conformed to the spirit of the Code. Were there practical difficulties in fully conforming to the letter of the Code? In particular, were there practical difficulties in reconciling requirements such third party evaluations from an OPA vendor list in advance of Board Approval of it s programs and the funds to retain such third parties? Was this also a difficulty in retaining vendors to develop implementation plans? 0 THESL submits that it has conformed to all aspects of the OEB Code and has provided additional evidence to clarify any ambiguity identified in other related OEB procedural orders. As it relates to expending funds to develop the proposed OEB Board-approved programs in advance of OEB approval, it is THESL s position that the costs contained in its February, 0 Addendum to the CDM Applications were prudently incurred and will be fully considered for recovery by the OEB.

21 Schedule Page of INTERROGATORY : Reference(s): none provided Does Toronto Hydro believe that the OPA programs (with the exception of the Low Income Program) have been established as required by the CDM Code? If not what criteria does Toronto Hydro consider to be an appropriate and reasonable test for the establishment of programs? 0 Please refer to the response to Board Staff Interrogatory.

22 Schedule Page of INTERROGATORY : Reference(s): none provided Has the recent OPA advertising campaign advising consumers to contact their local utility had any impact on Toronto Hydro s Call Centre activities? Has Toronto Hydro experienced any situations in which its customers would be better served by one of its non-duplicative programs than by the OPA programs? What advice did you give to such customers? 0 0 At the time of this response, THESL cannot report call centre impacts as a result of the OPA advertising campaign. The OPA CDM residential and commercial programs were recently launched on March, 0. As such, it is too early to evaluate the impact on THESL s Call Centre. No, THESL has not experienced a situation in which a customer would be better served by one of its Board-Approved programs. THESL s proposed Board-Approved programs have been designed and submitted to address a CDM market opportunity that was not identified in the OPA province-wide programs and/or is unique to THESL s customer base and/or market. THESL s proposed Board-Approved programs have been designed to be complementary and not an alternative to the OPA province-wide programs.

23 Schedule Page of 0 INTERROGATORY : Reference(s): none provided The Code requires Toronto Hydro to use the OPA measures and assumptions lists as well as its cost effectiveness tests. Is Toronto Hydro aware of any requirement in the Code to calculate rate impacts of the implementation of OPA Programs or Board approved Programs? Does Toronto Hydro have the data required to perform such rate impact calculations given that the costs associated with both types of programs will come out of the Global Adjustment Fund and applied to all customers and the benefits of such programs depend on the future supply mix in the province? Are there additional costs associated with any phase of program planning, development, implementation or evaluation that will be charged to Toronto Hydro distribution customers that are not included in the application? THESL is not aware of any section within the CDM Code which would require the filing of rate impact calculations, and THESL does not have all the required data to perform such calculations. Please see response to Board Staff Interrogatory b.

24 Schedule Page of INTERROGATORY : Reference(s): none provided Is Toronto Hydro aware of any requirement in the Code to perform sensitivity analyses for its programs? Is Toronto Hydro aware of any requirement in the Code to develop a program logic model, particularly given how the Code has differentiated OPA programs and Board approved Programs? 0 THESL is not aware of any explicit OEB Code requirements to perform or provide a sensitivity analysis or program logic modeling. For all submitted Board-approved applications, THESL followed the requirements as defined specifically under Section.0, item.. of the CDM Code.

25 Schedule 0 Page of INTERROGATORY 0: Reference(s): none provided Does Toronto Hydro anticipate the need for any changes to the Board s COM Code as a result of having gone through the first iteration of program design? 0 THESL respectfully declines to provide an answer to this interrogatory as the question does not pertain to any of the issues on the Issues List. The CDM Code has been approved by the OEB in its current form, and any revisions or amendments would be more properly addressed in a generic policy proceeding.

26 Schedule Page of 0 INTERROGATORY : Reference(s): none provided The funding for OPA programs, particularly for those programs with high incentive levels is virtually open ended for a distributor that achieves higher levels of participation than expected by the OPA for the province on average. Is Toronto Hydro prepared to overachieve on its targets if the OPA programs deliver more than expected by the OPA? If such a mechanism were in place for Board approved programs, would Toronto Hydro use it overachieve on the results it expects to achieve from its own program? The evidence suggests that Toronto Hydro is developing additional programs - will these only be submitted for approval is it appears that its share of the provincial target will be met? THESL is prepared to overachieve on its targets if the OPA programs deliver more than expected. Yes, if such a mechanism were in place for Board approved programs, THESL would use it to overachieve on the results it expects to achieve from its own program. 0 THESL is considering submitting additional programs for OEB approval later in 0. The submission of the additional programs would not be delayed to assess reports that confirm THESL s share of the provincial target will be met by current OPA and any pending Board-Approved programs.

27 Schedule Page of INTERROGATORY : Reference(s): none provided How will Toronto Hydro manage the integrations of staff working on the OPA programs with those assigned to the Board approved programs to avoid any customer confusion? 0 Each program is unique to address a target market sector. Three levels of customer support will be provided:. THESL s Web pages will provide information specific to each program and customer care telephone numbers: Customer Care staff will be trained to assist and respond to customers for all program initiatives and direct them to program specialists or information sources.. Business and technical support staff will provide customers with specialized and program specific guidance and support.

28 Schedule Page of INTERROGATORY : Reference(s): none provided Ministerial conservation-related directives since the passage of the Green Energy and Green Economy Act to both the OPA and the Board have ensured that LOC targets include both peak reductions and energy reductions. In Toronto Hydro's view, how has this impacted both the design and select ion of OPA programs and it s requested programs, particularly with respect to programs and budgets allocated to OPA demand response programs which deliver no energy saving results? 0 0 In THESL s view, the design and selection of the OPA programs were based on a two staged design approach. The first stage was to develop programs that targeted summer peak demand megawatt (MW) reductions to support the primary goal identified in Ontario s Long Term Energy Plan, formerly OPA s Integrated Power Supply Plan (IPSP); to phase out coal generation by 0. Energy end-use assets were identified in all market sectors and targeted using incentive programs to encourage investment uptake. While this effort will contribute to the success of displacing summer peak generation (e.g. coal generation) summer peak demand hours are limited and results in minimum energy consumption (megawatt-hours) reduction and do not support the Green Energy and Economy Act goal of the developing a conservation culture in Ontario. Therefore, the second design stage was to develop programs specifically for energy consumption reductions to help customer identify and invest in energy efficiency to lower their overall energy bills and to promote a sustainable conservation culture.

29 Schedule Page of THESL was very involved in the development of the OPA programs in 00 through the Electrical Distribution Association (EDA) and OPA CDM program development working groups. As one of the working group members, THESL had an inherent knowledge of all available OPA province-wide programs and selected a portfolio of programs; a combination of OPA Province-wide and potential Board-Approved programs, based on its comprehensive understanding of its markets and customer needs. 0 THESL views the demand response (DR) programs as a key program and critical to the success of achieving its CDM targets. THESL s overall CDM strategy is to target demand and consumption reductions using a combination of energy efficiency incentive programs, as well as gain control of the energy assets for purposes of demand response.

30 Schedule Page of INTERROGATORY : Reference(s): none provided In Toronto Hydro s letter to the Board dated February, 0, it requested that the Board approve an additional $, which relates to program planning and development costs for the years 00 and 0. What would this number have been if Toronto Hydro had also incurred program implementation and evaluation planning costs in advance of approval of the programs? 0 THESL submits that this is a hypothetical question at this time. However, THESL has consistently discussed estimates in the range of approximately $0,000 to staff members of the Board and Ministry since early 00 when the need for funding for planning and development purposes was first identified.

31 Schedule Page of INTERROGATORY : Reference(s): none provided Is Toronto Hydro aware of any industry standards for the ratio of program planning and development to total program costs? THESL is not aware of any industry standards for the ratio of program planning and development to total program costs.

32 Schedule Page of INTERROGATORY : Reference(s): none provided How much of this amount represents any of the costs associated with Toronto Hydro s participation in the redevelopment of OPA programs? 0 THESL submitted an Addendum to its Application for 0-0 Board-Approved CDM Programs which detailed the requested recovery of costs incurred in the planning and development of the proposed nine programs. The amount requested was for $, including estimated costs for regulatory proceedings. It does not include any redevelopment of OPA programs. The amount requested represents 0. % of the total budget of $,, for the nine programs.

33 Schedule Page of INTERROGATORY : Reference(s): none provided Will these costs increase if Toronto Hydro does not get timely approval of its programs or if the estimates of regulatory costs are greater than estimated? 0 THESL submits that a delay in the approval of its programs will affect the potential savings expected to be achieved and places greater risk on its ability to achieve the OEB assigned targets. Achieving lower than projected savings in peak demand (MW) and electric energy consumption (GWh) would reduce participant incentive costs. It would also reduce the overall program effectiveness and the cost effectiveness test ratios. Delays and increased regulatory cost would have the potential to increase the requested recovery amount submitted in the Addendum to THESL s Application for 0-0 Board-Approved CDM Programs.

34 Schedule Page of INTERROGATORY : Reference(s): Program #: Business Outreach and Education Some of the target markets for this program have been partially served by the OPA s Toronto-specific program that was implemented by BOMA Toronto. How will Toronto Hydro overcome any lost momentum in the availability of programs given that the BOMA delivered program ended in 00? 0 THESL has been working with BOMA to continue to support BOMA Toronto s CDM success in the commercial market segment. Through a channel partner relationship with THESL, BOMA will be charged with CDM targets and activities associated in achieving those targets in the commercial market segment. THESL and BOMA have been working together to maintain momentum in the market place by continuing to provide information to their customers while working on a formal agreement.

35 Schedule Page of INTERROGATORY : Reference(s): Program #: Business Outreach and Education How does this market segment for your service territory differ from the segment for the province as a whole? 0 THESL believes that the commercial market segment in Toronto is slightly more advanced along the energy efficiency timetable in comparison with other average commercial markets in Ontario, as Toronto has typically been an early mover in the area of CDM. This is based on the recognition that the commercial marketplace in Toronto is very competitive, which has played a driving role in the uptake of CDM activities as a means of differentiation between building owners. For example, lighting is often referred to as low hanging fruit or the first CDM activity that a customer will attempt. In fact, most of this opportunity has been completed by the majority of the downtown commercial core. These customers are looking to invest in deeper CDM technologies. THESL aims to have program options that will enable this objective to be met.

36 Schedule 0 Page of INTERROGATORY 0: Reference(s): Program # Commercial Energy Management and Load Control 0 Please explain the difference between customers being eligible for a program versus a program which targets specific customers. For example, low income customers are eligible for all OPA current residential programs, but nevertheless, a province wide program is under development for low income customers because the current programs are not designed to meet their needs. Is this comparable to your analysis with respect to this program? 0 Targeted programs are reflective of situations where improved participation rates can be achieved by focused sales and marketing, or by enhancing the value of any available offering to the customer. The example cited above for the low-income programs is a similar situation to that of the CEMLC program. The CEMLC program is designed to reduce the energy use and peak summer demand in the office, retail, institutional, and hospitality sectors in facilities with an average monthly demand less than 00kW. This market sector is an important target group for CDM programs for the following reasons: There has been only limited application of energy savings measures beyond lighting upgrades, and this class of facility has typically not adopted building automation technology.

37 Schedule 0 Page of Current demand response capacity is negligible for customers with an average demand ranging between 0kw and 00kW. As an example, THESL s experience to date demonstrates that in small commercial facilities that are under 0kW, participation rates have been disappointing (i.e., less than % participation in peaksaver). THESL believes there are significant CDM opportunities in this market segment that are currently not addressed by province wide programs and market specific targeting is the only way to achieve these objectives. 0 Although peaksaver and the demand response programs and could, in theory, be applied to this market group, they are designed for single-family residences and large industrials respectively. Without a load control program as an enticement in the less than 00kW class of customers there will be negligible results in this sector.

38 Schedule Page of INTERROGATORY : Reference(s): Program # Commercial Energy Management and Load Control 0 Do you anticipate that your RFP for vendors to deliver this program will result in all vendors offering similar approaches or do you anticipate that vendors will bring alternative implementation plans or deployment approaches such as proprietary software, marketing innovations and technologies that will differentiate the proposals on matters other than price? Do you also anticipate that the EM&V required will vary from one proposal to the other, particularly in response to alternative implementation plans? Is it possible that the approach, cost and effectiveness of EM&V could vary significantly given the implementation plan? For example, if the successful vendor offered real time monitoring results, would the EM&V require less sampling than a vendor who offered a program based on engineering estimates? 0 a) THESL anticipates that the vendor responses will be relatively uniform in terms of approach and implementation. THESL expects that there will be considerable variation in the technology solutions both at the field level and at the supervisory level. b) THESL does not believe that there will be significant variations to the EM&V as the requirements for vendor participation in the program EM&V will be defined in the RFP.

39 Schedule Page of c) THESL does not anticipate that the cost and effectiveness of the EM&V will vary across the proposals. The ability to handle and store data from demand response events will be one of the key criteria in the services provided by the successful respondent. There will also be the ability to automate the results using THESL s billing system as required.

40 Schedule Page of INTERROGATORY : Reference(s): Program # Commercial, Institution and Small Industrial Monitoring and Targeting 0 0 In its submission in EB-00-0, Toronto Region Conservation Authority shared its lessons learned from performance based conservation: i) performance based conservation delivers far greater energy savings than previous approaches to energy (and water) conservation, ii) the larger part of the savings is found in low/no cost improvements, iii) successful and sustainable conservation has more to do with good management than with technology, iv) conservation programs have to support building managers with information, tools and resources so that they can recognize the unique set of conservation opportunities in their facilities, v) benchmarking can identify buildings with high conservation potential, inform target setting and point to where savings are to be found in each building, and vi) monthly savings reporting flags variances in predicted savings, identifies measures which do not perform as intended, verifies savings which have been achieved and guides continuous improvement a) How will this program relate to the Green Energy and Economy Act requirements for energy management plans in the broader public sector? THESL believes the Monitoring and Targeting program is an enabler for energy management planning in all markets segments including the broader public sector. The

41 Schedule Page of program is consistent with the lessons quoted above and is designed to serve as a management tool for facilities and operations staff. Increasing the knowledge and information of where energy is consumed and the awareness level of efficiency opportunities goes hand in hand with energy management planning.

42 Schedule Page of INTERROGATORY : Reference(s): Program # Commercial, Institution and Small Industrial Monitoring and Targeting On page of this program description (section), Toronto Hydro indicated that it had used the more conservative estimate for savings based on a CIPEC report. Please confirm that this report was limited to the industrial sector and might not be representative of the full market. 0 The savings attributable to M&T systems vary with studies noting -% savings based on experience in the UK, USA and Canada. The specific reference in the CIPEC is attributable to an overall recommendation of % and is not exclusive of the industrial segment.