It is important that the gas utilities’ multi-year DSM plans focus on activities that will achieve a greater amount of long-term natural gas savings, better help participating customers manage their overall usage and ultimately their bills, and consider the guiding principles from Section xx and key priorities outlined above. The Board has provided a specific discussion of program types in the DSM Guidelines in Section 6.0.
The gas utilities are expected to collaborate and integrate natural gas DSM program offerings across all sectors with Province-Wide Distributor and/or Local Distributor CDM programs throughout the course of the DSM framework period. As part of the multi-year DSM plans filed by the gas utilities, the Board expects that the gas utilities will include a discussion of the areas where programs have been coordinated and/or integrated with Province-Wide Distributor and/or Local Distributor, program aspects that have the potential to be integrated in the future and any barriers that have restricted the program from being coordinated and integrated with an electricity CDM program.
Additionally, the gas utilities DSM portfolios should include programs that are specifically designed to address customer groups with significant barriers to entry (e.g., small business customers). DSM portfolios should also include programs targeted to customers who are already very invested in energy efficiency and where more complex or customer-specific options are necessary.
The Board is of the view that rate funded DSM programs for large volume customers should not be mandated as these customers are sophisticated and typically competitively motivated to ensure their systems are efficient. The small number of customers in these classes further heightens the issues of one customer subsidizing business improvements of another. If a gas utility, in consultation with its large volume customers, determines that there is substantial interest in the gas utility providing expertise and a value-added service to help improve the energy efficiency levels of these customers’ facilities, the gas utilities are able to propose a fee-for-service program which the Board will approve on its merits. The primary focus of any program proposed for large volume customers should be offering technical expertise, including conducting facility audits, advice for operational improvements, or engineering studies as opposed to capital incentives. Specifically, the gas utilities can propose a fee-for-service DSM programs to the customers in those classes identified as large volume rate classes in the table below. As can be seen in the table below, there is a very limited number of customers in these rate classes.