Comments & Testimony

The following are copies of public testimony by or on behalf of NAESCO:

2018

• NAESCO Reply Comments before the CA PUC's Administrative Law Judges' Ruling Seeking Comment on Certain M&V Issues, Including 3rd Party Programs   May 30, 2018

2017

• NAESCO Reply Comments before the CA PUC on the November 13, 2017 proposed decision addressing third party solicitation process for EE programs                  December 11, 2017
• NAESCO Comments before the CA PUC on the November 13, 2017proposed decision addressing third party solicitation process for EE programs 
  December 4, 2017
• Coalition of EE Groups, including NAESCO, Comments to FERC in response to DOE’s NOPR “Grid Resiliency Pricing Rule”
  October 23, 2017
• NAESCO Final Reply Comments before the CA PUC on the Business Plans of SCE, PG&E, SDG&E and SOCALGAS
  October 13, 2017
• NAESCO Final Comments before the CA PUC on the Business Plans of SCE, PG&E, SDG&E and SOCALGAS 
  September 20, 2017
• NAESCO Reply Comments before the CA PUC on the Third-Party Solicitation Plans of SCE, PG&E, SDG&E and SOLCALGAS
• September 1, 2017
• NAESCO Comments before the CA PUC on the Third-Party Solicitation Plans of SCE, PG&E, SDG&E and SOLCALGAS 
  August 18, 2017
• NAESCO Reply Comments before the CA PUC on Revised Sector-Level Metrics Proposals and Energy Efficiency and Demand Response Integration Options 
  July 31, 2017
• NAESCO Response to Motion before the CA PUC of PG&E (U 39-M) for Leave to Amend its Application for Approval of its 2018-2025 Rolling Portfolio Energy Efficiency Business Plan and Budget
  July 18, 2017
• NAESCO Reply Comments before the CA PUC to Responses to Attachment B of the Scoping Memo and Ruling of Assigned Commissioner and Administrative Law Judges 
  June 29, 2017
• NAESCO Comments before the CA PUC on the Supplemental Applications of SCE, PG&E, SDG&E and SOCALGAS for Approval of Energy Efficiency Rolling Portfolio Business Plans and Related Matters
  June 22, 2017
• Statement for the Record Submitted by NAESCO for the House Ways and Means Committee Hearing on Tax Reform
  June 1, 2017
• NAESCO filing before the California PUC to motion for extension of time to file comments on Program Administrators’ supplemental information
  May 30, 2017
• NAESCO Response to Applications of SCE, PG&E, SDG&E and SoCAL Gas for Approval of Energy Efficiency Rolling Portfolio Business Plan and Related Matters
  March 3, 2017
• NAESCO summary of policy position in opposition to Illinois SB1287 changing guaranteed energy savings contracts
  February 13, 2017
• NAESCO letter to CPUC to comment on Resolution e-4818
  January 17, 2017

2016

• NAESCO memo to the California Energy Efficiency Coordinating Committee, (CAEECC) regarding NAESCO’s Comments on PG&E, SDG&E, SoCal Gas October 18, 2016 Draft Business Plan Filings
• November 21, 2016
• Coalition Comments on EPA's Clean Energy Incentive Program
• November 2, 2016
• NAESCO Comments on Leads for Statewide Programs to the CAEECC Facilitators
  October 26, 2016
• NAESCO Comments on California Utility Energy Efficiency Business Plans
  September 20, 2016
• NAESCO Comments to FEMP of the Department of Energy on the Tax Treatment of an Energy Savings Performance Contract Energy Sales Agreement
  September 6, 2016
• NAESCO Letter to the California PUC in support of Comments of the Southern California Edison Company on Draft Resolution E-4795 Approval of the Database for Energy-Efficient Resources updates for 2017 and 2018, in Compliance with Decision 15-10-028
  August 15, 2016
• NAESCO Reply Comments on the Proposed Decision of Administrative Law Judge Fitch of July 19, 2016 on Order Instituting Rulemaking Concerning Energy Efficiency Rolling Portfolios, Policies, Programs, Evaluation and Related Issues
  August 15, 2016
• NAESCO Comments on the Proposed Decision of Administrative Law Judge Fitch of July 19, 2016 on Order Instituting Rulemaking Concerning Energy Efficiency Rolling Portfolios, Policies, Programs, Evaluation and Related Issues
  August 8, 2016
• NAESCO Comments on Ruling of the Administrative Law Judge on Evaluation, Measurement and Verification and Energy Savings Performance Incentive Issues
  June 24, 2016
• NAESCO Comments on Ruling of Assigned Commissioner and Administrative Law Judge Seeking Input on Approaches for Statewide and Third-Party Programs
  June 17, 2016
• NAESCO Reply Comments before the CA PUC on the Comments of Other Parties on the Administrative Law Judge's Ruling Seeking Comment on Energy Efficiency Baseline Policy and Related Issues 
  May 24, 2016
• NAESCO Comments to the California PUC on Administrative Law Judge's Ruling Seeking Comment on Energy Efficiency Baseline Policy and Related Issues 
  May 17, 2016                                                                                                                                                                                              
• NAESCO Comments to California PUC on the workshops and the policy issues involved in implementing existing conditions baselines and operationalizing directives in AB 802
  February 10, 2016
• NAESCO Comments to the EPA on the Evaluation Measurement and Verification (EM&V) Guidance for Demand-Side Energy Efficiency in the Clean Power Plan
  January 21, 2016

2015

• NAESCO Reply Comments to California PUC on Order Instituting Rulemaking Concerning Energy Efficiency Rolling Portfolios, Policies, Programs, Evaluation, and Related Issues Rulemaking 13-11-005
  September 15, 2015
• NAESCO Comments to California PUC on Order Instituting Rulemaking Concerning Energy Efficiency Rolling Portfolios, Policies, Programs, Evaluation, and Related Issues (Rulemaking 13-11-005)
  March 16, 2015
• NAESCO Comments to Massachusetts DOER on Green Communities Act RFI
  February 27, 2015

2014

• NAESCO Questions to Florida Department of Management Services on the Request for Qualifications for Shared Savings Financing for Energy Efficiency Upgrades (RFQ No: DMS-14/15-031)
  December 19, 2014
• NAESCO Comments on the NYSERDA Clean Energy Fund Proposal (Case 13-M-0094)
  December 8, 2014
• NAESCO Comments to U.S. EPA on Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units (EPA–HQ–OAR–2013–0602, 79 Fed. Reg. 34830)
  December 1, 2014
• NAESCO Comments to California Energy Commission on Proposition 39 Proposed Guideline Revisions (Docket # 13-CCEJA-1)
  November 10, 2014
• Letter to OFCC
  ​February 14, 2014
• Letter to Sentor Max Baucus on NAESCO Comments on Cost Recovery and Energy Tax Reform
  January 17, 2014
• Letter to Senator Max Baucus on Coalition Supporting 179D Tax Deduction for Energy Efficient Commercial Buildings
  January 17, 2014

2013

• NAESCO Comments to California PUC on Administrative Judge's Ruling Regarding Post-2014 Energy Efficiency Goals
  December 20, 2013
• NAESCO Prehearing Conference Statement to California PUC on Order Instituting Rulemaking Concerning Energy Efficiency Rolling Portfolios, Policies,
  Programs, Evaluation, and Related Issues
  December 6, 2013
• NAESCO Comments to New York PSC on Case 07-M-0548 and Case 13-M-0412
  November 12, 2013
• Letter to County Commissioner Association of Ohio
  November 5, 2013
• Letter to California Energy Commission on Prop 39 Draft Implementation Guidelines
  October 25, 2013
• NAESCO Comments on the Proposed Decision Implementing 2013-2014 Energy Efficiency Financing Pilot Programs
  August 22, 2013
• Joint Letter to California PUC - Recommended Priorities for the Post-2014 Energy Efficiency Rulemaking
  July 30, 2013
• Letter of Support for PennFuture’s Energy Services Contracting (ESCO) Education and Outreach Program
  March 1, 2013

2012

• NAESCO Comments on the Joint Response of Southern California Gas Company and San Diego Gas & Electric Company to Administrative Law Judge's Ruling Requesting Supplemental Information and Comments on Expert Consultant Financing Proposals
  December 14, 2012
• NAESCO Comments on Proposed Changes to PA GESA Program
  January 18, 2012
• NAESCO Comments on California NTGRs
  January 12, 2012
• NAESCO Comments on the Administrative Law Judge Ruling Regarding Program Guidance for the 2013-2014 Energy Efficiency Portfolio
  January 6, 2012

Archived Comments & Testimony