20140812Khawaja Direct.pdf

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DAVID J. MEYER
VICE PRESIDENT AND CHIEF COI'NSEL OF
REGULATORY & GOVERNMENTAL AFFAIRS
AVISTA CORPORATION
P.O. BOX 3727
LALL EAST MISSION AVENUE
SPOI(ANE, WASHINGTON 99220-3727
TELEPHONE: [phone]
EMAIL: david.
BEFORE THE IDAIIO PUBLIC UTIIJITTES COMMISSION
IN THE IUATTER OF THE APPLICATION ) CASE NO. AVU-E-1, O-I
oF AVTSTA CORPORiATTON FOR A ) CASE NO. AW-G-L4-O2-
FTNDING OF PRUDENCE FOR 201.3 )
EXPENDITURES ASSOCIATED WITH )
PROVIDING ELECTRIC AI\TD NATURAL GAS ) DIRECT TESTIMONY
ENERGY EFFICIENCY SERVICE IN THE ) OT
STATE OF IDAHO ) U. SAIvII KHAWA,JA
REPRESENTING
THE CADMUS GROUP, INC
FOR AVISTA CORPORATION
(ELECTRIC AND NATURAL GAS)
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I.INTRODUCTION
O. PleaEe state your fuII Ddrn€r busineEs address, and
company nErme.
A. My name is M. Sami Khawaja, and my business address
is 720 SW Washington Street, Portland, OR 97205. My
employer j-s The Cadmus Group, Inc.
a. On whose behalf are you presenting testimony in thig
proceeding?
A. I am testifying on behalf of Avista Utilities.
O. Have you previouely submitted teEtimony in this
proceeding?
A. No, I have not.
O. Please describe your qualification.
A. I hold a doctorate degree in Economics and Systems
Science. I have been conducting demand sj-de management
(DSM) program J-mpact and process evaluations since 1983. I
am the author of the Electric Power Research Institute
Impact EvaTuation Guide, coauthor of the International
Performance, Measurement, and Verification ProtocoTs,
coauthor of the EnvironmentaT Protection Agency NationaT
Action PTan for Energy Efficiency Impact EvaLuation Guide,
and author of over 30 papers on evaluation issues. f have
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taught over 40 evaluation and cost-effectiveness workshops
nationally and internationally. I am one of the
Association for Energy Service Professionals trainers. I
am currently an adjunct professor of economics at Portland
SEate University.
O. Describe your current and previoug job
responsibilities .
A. I am currently an executive consultant for The Cadmus
Group and previously managed the Energy Service Divlsion
for five years (a group of 200 energy professionals). In
1-998 I started an energy efficiency evaluation and
planning firm ca11ed Quantec. The company grew to 60
professionals and was purchased by Cadmus in 2008. Prior
to that I held various positions at other consulting
firms, PacifiCorp, and Portland State University.
O. Deecribe your involvement in the delivery of Avieta
DSM programs.
A. The Cadmus Group was retaj-ned by Avista to serve as
the third-party independent evaluator of its 201-2 and 201-3
DSM programs in Idaho and Washington. As such, we
conduct,ed impact and process evaluations of the programs
in the residential, nonresidentj-aI, and low income
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sectors. The evaluation covered both electric and natural
gas programs.
a. Were the evaluationg prepared in accordance with
industry standardE?
A. Yes. A11 evaluations were conducted in a manner
meeting Lndustry standards and established protocols.
These include: (1) International Performance Measurement
and Verif j-cation Protocols: Concept,s and Options for
Determj-ning Energy and V'Iater Savings Volume 1-, January
2OL2 (2) Model Energy Efficiency Program Impact Evaluatj-on
Guide: A Resource of the National Action Plan for Energy
Efficiency, November 2007; (3) Electric Power Research
Institute: Guidebook for Energy Efficiency Program
Evaluation, Measurement, and Verification, 2008, and (4)
the Department of Energy Uniform Methods Protocols, 201-3.
A. Have you conduct,ed similar portfolio-Level
evaluationg before?
A. Yes. Under my supervisj-on, Cadmus has recently
completed sj-mj-Iar portfolio-1eveI evaluations for the
followj-ng electric and natural gas utilities:
1. Ameren UE Missouri.
2. Ameren Illinois Utilities.
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3. Questar (Utah) .
4. California Public Utilities Commission.
5. DTE Energy (Michigan) .
5. Consumers Energy (Michigan) .
7. Salt River Project (Arizona) .
8. PacifiCorp (Oregon, Washington, Idaho, and Utah) .
9. Progress Energy (Carolinas).
L0. PECO (Pennsylvania) .
11. PPL (Pennsylvania) .
1-2. Dayton Power & Llght (Ohio) .
l-3. Empower (Maryland) .
t4. Focus on Energy (Wisconsin)
O. Have your evaluations eleewhere been reviewed by
Public Utility Commissiona or state-Ievel evaluatorg?
A. Yes. In all cases listed in the previous question,
the evaluations were either reviewed and approved or are
in the process of being revj-ewed and approved by the
representative utility commissj-ons .
A. Vlhat ie the purpose of your teetimony?
A. The purpose of my testimony is to present the
findings of our evaluatj-ons for the 2Ol3 tj-me period.
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a. Describe Cadmus' approaeh to conducting evaluations
of DSM prograrns.
A. Cadmus strongly believes that the best value
evaluators can provide is real-time feedback to program
managers. Real-time feedback aIlows for continuous
improvements and course corrections as needed. We have
worked closely with Avista's Planning, Policy, and
Analysis (PPA) and Implementatj-on teams to implement
recommended corrections from the beginning of the
evaluation. We also worked closely with the stakeholders
represented in the various technical and policy groups.
a. DeEcribe Avista's energy efficiency internal
Organization structure.
A. Avista previously had created two distinct groups for
the purpose of delivery of DSM programs. One team was
directly responsible for implementing the programs
(Implementation team) and another was responsible for
planning and analysis (PPA team). We reported directly to
the PPA team. In Ju1y, 201,4, the PPA and implementation
teams began reporting to a central manager.
O. Are you eponsoring any exhibite to be introduced in
this proceeding?
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A. Yes . I am sponsoring Exhibit No. 3 , Schedule 1 t,hat
presents our 2013 electric portfolio impact report,
Exhibit No. 3, Schedule 2 which is the 201,3 natural gas
portfolio impact memo, and Exhibit No. 3, Schedule 3 which
is the 201-2-20L3 portfolio-wide process evaluation.
O. Pleage describe any data collection and activities
aseociated with the evaluation.
A. Ful1 impact evaluations were performed for the
electric portfolio covering the 1ow income, residential,
and nonresidential sectors. Although natural gas programs
were suspended in Idaho prior to 2013, there were several
instances where natural gas savings were achieved due to
grandfathered projects or dual fuel saving measures. Thus,
we also completed a limited evaluation for gas-saving
measures in the residential and nonresidential sectors.
The low income impact evaluation included billing analysis
of electric and conversion measures using the entire
population of 20L2 participants and results applied to
2Ol3 participants. The nonresj-dential impact evaluation
performed 1-47 site and/or metering visits, individual sj-te
billing analyses, simulation modeling, and general
engineering calculations. Teams of engineers spent several
weeks in the field at different points in 20L3 and 20L4.
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The residential impact evaluation was informed by billing
analyses of the weatherization program and conversion
program. A participant and control group billing analysis
was performed for the residential behavior program as
wel1. Savings analysis utilizing the Regional Technical
Forum (RTF) , Avista's 201,2 Technical Reference Manual
(TRM), and engineering analyses was performed on all
measures, including the lumen equivalents method in
conjunction with RTF inputs for lighting savings. 357
phone surveys were conducted for the residential measure
verification and over 2,000 general population surveys.
The process evaluations completed 357 resj-dential
participant,2,L60 residential general population,201-
nonresidential participant, and 1-40 nonresidential non-
participant surveys. The evaluat.ions also included 20
contractor interviews, as well as interviews with several
implementation contractors, Avista PPA and implementation
staff. The process topics covered included participant
feedback, program management and design, trade a1ly input,
data tracking, marketing and outreach, a detailed analysis
of nonresj-dentj-aI realization rates and tariff compliance,
and a benchmarking of industry best practices. Details on
each of these evaluation activities and results can be
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found in the assocj-ated Cadmus reports: Avista 201-3 Idaho
Electric Impact Evaluation Report, Avista 201,3 Idaho
Natural Gas Savi-ngs Memo, and Avista 201,2-2013 Process
Evaluation Report.
A. P1ease sumrnarize the Company's groaa electric energy
efficiency-related eavings for this time period.
A. As shown below j-n Table L, 25,899 MWh of gross energy
savJ-ngs were acquired through Avj-sta's Idaho DSM projects
between .Tanuary 1- , 201-3, and December 3A , 201-3. The
electric portfolio had a real-ization rate of L02.7Z.
Table 1. Reported and Evaluated Electric Savings
Residential
Nonresidential
Low lncome
Residential Behavior
Total
5,130,507
17,602,253
292,767
2,t94,322
25,219,849
5,933,L97
16,595,342
499,901
2,870,90s
25,899,345
715.6%
94.3%
170.8%
130.8%
102.7%
O. What are the gross electric energy savings by
program?
A. The 20L3 program year's gross savings are summarized
in Table 2 by program.
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Table 2. Evaluated Electric Savings by Program
Non-Conversion
Low lncome Conversion
Heat Pump Replacement
Site Specific
Nonresidential Prescriptive
EnergySmart Grocer
Simple Steps, Smart Savings
Second Refrigerator and Freezer Recycling
ENERGY STAR Products
Heating and Cooling Efficiency
Space and Water Conversions
Residential Weatherization/Shell
Water Heater Efficiency
ENERGY STAR Homes
Geographic CFL Giveaway
Residential Behavior
L79,628
309,964
10,309
7,944,237
6,978,966
t,672,139
4,750,306
368,174
29,01L
L44,480
505,078
90,47L
5,487
12,550
26,U0
2,87O,9O5
25,899,345
O. What are the Company's net electric energy savings
for this time period?
As shown below in Table 3, 21,,999 MWh of net energy
savings were acquired through Avista's Idaho DSM projects
between 'January 1-, 201-3, and December 31, 201-3. The
electric portfolio had an overall NTG rat,io of 85?.
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Table 3. Evaluated NTG and Net Electric Savings
Residential
Nonresidential
Low lncome
Total
Did Avieta achieve its filed
Yes, the both the Idaho
electrie goals for 2013?
Integrated Resource Plan
goals were satisfied in
g,063,ogo
L3,436,L18
499,901
21,999,099
19,l28,lgtl
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92%
8t%
700%
8s%
L3,436,LL8
499,901
21,999,099
a.
A.
(IRP) and Avista Business Plan
201-3 (Tables 4 and 5).
The IRP goals are portfolio-Ieve1 targets, so in order to
conduct sector-Ieve1 comparison, Cadmus adopted the Avista
Business Plan goals by sector, and applied those
proportions to the IRP targets.The tables also show
savj-ngs achievements for the portfolio Residential
Behavior programs. IRP goals are sti11 exceeded.
Table 4.IRP Goals and Evaluated Savings
Residential
Nonresidential
Low lncome
Total
Excluding Residential
Behavior
7,697,009
10,849,696
452,495
19,009,200
19,009,200
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Group,
8,063,080
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o.
Table 5. Avista Business Plan Goals and Evaluated Savings
Residential 8,547,340 8,063,080 94.3%
Nonresidential 12,048,322 13,436,L18 LIL.S%
Low lncome 513,589 499,901 97.3%
Total 21,109,251 2L,999,099 Lo4,.2%
Excluding Residential
Behavior 2'"1o9'25t L9'L28'194
Pl-ease summarize the Company's naturaL gas energy
efficiency-related savings for t,his time period.
A. As shown below in Table 5 , over 5l-, 000 therms of
energy savings were acquired from the Idaho DSM projects
between .Tanuary 7- , 20L3, and December 31 , 201-3. The 2Ol3
natural gas portfolio had a realization rate of l-05?.
Table 6. Expected and Evaluated Natural Gas Savings
Nonresidential
Residential
Residential Behavior
Total
L8,L92
L,743
29,498
49,433
18,580
2,56L
30,531
5L,772
LOz%
L47%
to4%
LOs%
O. What were the natural gas energy savings by program?
A. The 20L2-2013 program savings are summarized j-n Table
7 by progiram.
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Table 7. Natural Gas Evaluated Savings by Program
Nonresidential Prescriptive
Nonresidential Site Specific
Attic lnsulation with Natural Gas Heat
Wall lnsulation with Natural Gas Heat
Natural Gas Boiler
Natural Gas Furnace
Clothes Washer With Natural Gas Water Heater
Simple Steps - Showerheads
Residential Behavior
Total
2,135
L6,445
279
370
L4t
722
420
630
30,531
sL,772
O. What were the key findings of the reEidential proceEs
evaluation?
A.
Participation levels j-n many of Avista's residential
programs trended downward during PY20L2 and PY2013.
Many factors contributed to the downward trend,
including reduced measure offerings and the 2Ol3
discontinuation of natural gas j-ncentives in fdaho.
The trend experienced by Avista's programs is similar
to particj-pation trends in other regional utility DSM
programs.
The Simple Steps, Smart Savings program saw increased
participation, partly due to new measure offerings.
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Energy-efficient showerheads were added in 201,2 and
LEDs were added in 2013.
Avista's overall program design is effective, but
there is room for improvement around internal
communication between Avista staff .
Avista staff showed a strong commitment to customer
satisfaction, achieving fast rebate processing
despite increasing complexity of applications. Avista
staff have also taken steps to improve data tracking,
such as integrating additional program data into a
central database.
In addition, program marketing through mass media
channels had to be tailored to avoid customer
confusion about different incentive offerings in
fdaho and Washington.
Key sources of program information for customers
included contractors (1,72 Ln 20]-2; 28* in 2013), bill
inserts (L5* ; 1,6*) , and word of mouth (L0*; 1,42) .
Changes j-n information sources reflected changing
program offerings such as the elimination of
appliance rebates in 2013.
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General population awareness of Avista's rebates
decreased from 53* in 20L2 to 542 in 20]-3. Bill
inserts are the most common way for the general
population to learn about Avista's rebates.
Participant satisfaction increased since the 201L
process evaluation, with 89e" of 20L3 participants
being "very satisfied" with their progfram experience.
Only a sma1I number of customers expressed any leve1
of dissatisfaction across the three years in which
Cadmus conducted surveys.
Avista's appliance rebates experJ-enced a high leveI
of freeridership, 1ike1y due to high market
penetration of ENERGY STAR applJ-ances and
comparatively 1ow incentive amounts-as a percent of
incremental cost. Avista adjusted their program
offerings to reflect this market, discontinuing
appliance rebates in 2013.
Many of Avista's customers both participants and
nonparticipants reported installing additional
energy-saving improvements without receiving any
rebate because of Avista's programs' influence. These
actions contribute to program spillover. Out of the
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3,2L5 customers Cadmus surveyed in 20L2 and 2013, 1l-3
(or roughly one in every 28 customers) reported a
spillover measure.
A. What were the key findings of the nonregidential
procesE evaluation?
A.
o Program participants were more 1ike1y than
nonparticj-pants to own their facilities: according to
surveys (7eZ of participants owned their facilities,
compared with 67* of nonparticipants).
o Overall, participants reported high satisfaction
ratings. The vast majority were "very satisfied": 87+
for Prescriptive, 752 for Site-Specific, and 88? for
EnergySmart Grocer. Only a handful of customers
(roughly 1E) reported any 1eve1 of dissatisfaction.
o A11 three nonresidential programs recei-ved the same
satlsfaction ratings or better than they did in 201-l-,
with the EnergySmart Grocer program showing a 23*
increase in "very satj-sfied" customers over 20LL.
o Contractors were the primary source of program
information for nonresidential program participants
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(378). Other common sources of informatj-on were word
of mouth (23e,) and direct contact with Avista (17*) .
Among nonparticipants, awareness of Avista's energy-
efficiency rebates has remained fairly constant since
2010, with around 4 in 10 nonparticipants being aware
of the programs (:At in 201-3) .
Avj-sta's management and implementation of DSM
programs has had some persistent organizational
challenges, which may have impacted the effectiveness
of implementation processes. While not limited to any
specific part of Avista's DSM staff, many of the
issues have primarily affected the nonresidential
program processes.
Cadmus' review of Avista's implementation and QA/QC
processes showed that the accuracy of project savings
estimates has increased since 2O1,L, but there is
sti11 room for improvement. The Figure below shows
the percentage of electric realization rates for
site-specific projects that fe11 within the range of
90* to l-10?. This range indicates a good 1eve1 of
accuracy in reported savings.
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Figure No. 1. Nonresidential Site-Specific Project Electric Realization Rates
2011-2013
7Wo
50/6
s@6
4ffi
30/o
zWo
ta6
a96
.2O!7
.20L2
.20L3
Realization Rate = 9G11O96
Cadmus' interwiews with lighting contractors
conducted as a supplement to the ongoing Panel Study
research revealed that Avista's programs increase
sales of energy-efficient lighting eguipment for both
participating and nonparticipating contractors: l-5
out of 20 reported that their sales increased because
of Avista's programs.
The prescriptive program showed 9* freeridership in
201,3, showing a large decrease in freeridership as
compared to the 201-1- result. The sj-te-specific
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program showed 30? freeridership in 2OL3, showing an
increase as compared to 201-1.
a. What recommendations resulted from the residential
impact and procese evaLuations?
A.
o Consider updating per-uni-t assumptions of recycled
equipment to reflect the findings in this evaluation.
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. If cl-othes washer rebates are
should continue to t,rack them
program unless there is
penetration of gas dryers.
ever reinstated, Avista
all within the electric
a large increase in
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o Increase measure Ieve1 detail capture on
applicatj-ons. Specific additional information should
include energy factors or model numbers for
appliances, baseline information for insulation, and
home square footage, particularly for the ENERGY STAR
Homes.
Consider tiered incentives by rating as higher SEER
systems generally require ECM fan motors.
Consider completj-ng a lighting logger study within
its territory if Avista believes the results of the
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forthcoming Residential Building Stock Assessment
(RBSA) study do not accurately represent usage in
their territory.
Consj.der researching the percentage of Simple Steps,
Smart Savings bulb purchase that are installed in
commercial settings. This will increase the average
installed hours of use and increase estimated program
savings.
Perform a billing analysis on ENERGY STAR homes using
a non-participant comparison group once enough homes
have participated under the new requirements.
Consider researching the current variable speed motor
market activity to determine if this measure should
continue as a stand-aIone rebate or be packaged with
other equipment purchases.
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Continue to promote efficiency programs
Behavior Program energy reports, a's the
increased both the rate of efficiency
participation and savings.
Avista should consider performing additional
about the peak-coincident demand savings
behavior program.
in the
reports
program
research
from the
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Continue exploring new measures, program designs, and
delivery mechanisms that leverage the national
expertise of experienced third-party implementation
firms. Possible programs may include additional
partnership with ENERGY STAR in the form of the Home
Performance with ENERGY STAR program.
Continue testing new program designs and measure
offerings through the use of pj-Iots-even if secondary
sources of funding or 1ocal partners are not
avai-1abIe.
o If determined to be cost-effective, consider
expanding the Residential Behavior program (for
example, lowering the energy consumption threshold
for participation) and implementing measures to track
the methods these customers use to save energy. Given
that Avista has already included all cost-effective
customers in their target population for this
program, future opportunities for expansion may be
limited.
As part of the transition to the new data tracking
system, consider aligning program and measure names
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with offerings articulated in annual business plans
and other planning materials.
Consider ways to encourage repeat participation (such
as marketing targeted at, previous participants and
onlj-ne profiles that reduce application paperwork).
Continue use of customer freeridership and market
assessments as a way to assess the appropriateness of
measure offerings.
Develop a transparent process for assessing measure
or program cost-effectiveness and communicating
results internally. Consider ways to ensure high-
guality cost-effectiveness analysis that aligns with
industry best practJ-ces, such as obtaining an
objective third-party review of curent cost-
effectiveness screening processes.
Continue Avista's commitment
satisfaction, but monitor;
to customer
Increased staffing costs; and
Impacts of the 90-day participation window on
f reerj-dership.
Utilize survey results from this evaluation and other
data collection activities to understand which
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audiences are more 1ike1y to participate in Avista
programs.
O. What recommendationE resulted from the nonresidential
impact and procees evaluationE?
A.
o Create a quality control system to double-check all
projects with savings over 300,000 kwh.
o Avista may want to consj-der tracking and reporting
demand reduction to better understand measure load
profiles and peak demand reduction opportunitj"es.
. Update prescriptive measure assumptions and sources
on a regular basis.
o Streamline file structure to enable revi-ewers more
easily identify the latest documentation.
o Continue to perform fo11ow-up measure confirmation
and/or site visit,s on a random sample of projects (at
least 10?) .
o Consider flagging sites for additional scrutiny when
the paid invoj-ce does not include installation labor
as it may indicate that the work was not yet
performed.
Khawaja, Di 22
The Cadmus Group, Inc
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Avista may consider adding a flag to their tracking
database to automatically detect potential outlj-ers
(e.9., savings per doI1ar tkwh/$ or therm/$l ) .
In the case of redundant equipment, Avista may want
to consider incenting pump projects through the Site-
Specific Program to more accurately characterize the
equipment operating hours.
Avista may want to set minimum standards for modeling
design guidelines. The Energy Trust of Oregon
provides an example on their website.
Avista should continue efforts to define and document
program processes. Cadmus understands that a
reorganizatj-on of the DSM group has occurred
concurrent to the delivery of this report. This
change may be an opportunity for fresh perspectives,
clarified responsibilities, and improved coordination
within and between teams. We believe unifying the
organJ-zational structure under central leadership is
a step in the right direction and may help alleviate
some previously documented issues with internal
communicati-ons .
Khawaja, Di 23
The Cadmus Group, Inc
I
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In addition to the reorganization, Cadmus recommends
that Avista develop standardized processes within the DSM
group, including clear delineation of roles and precise
descrj-ption and assignment of all processes and
responsibilities for both residential and nonresidential
programs. A11 affected parties should be included in
formali-zing and standardizing the DSM group's processes,
ro1es, and responsibilities. Further, all parties must
formally agree to clearly delineated responsibilities
under the new organizational structure. V'Ihi1e these
activities need to be prescriptive and precise, we cautj-on
that the resulting structure should sti1l a11ow some
flexibility: increased clarity, transparency, and
accountability should serve to enhance program delivery
and customer satisfaction.
o Consider taking action to strengthen the use of
program materials. Consider providing trade aI1ies
with printed program information flyers or brochures
to give to customers. Maintaining up-to-date
information for trade al1ies is critj-ca1 when they
are the key party delivering the program's message
and participation details.
Khawaja, Di 24
The Cadmus Group, Inc
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o Identify underserved
opportunities to target
underserved industri.es :
o Investigate overall customer industry distribution
o Compare to participant industry distribution
o Develop targeted outreach strategies for any
underserved sectors
Continue to monitor the effectiveness of the site-
specific project review process and refj-ne as needed.
Cadmus recommends implementing the following to
ensure continued improvement:
o A11 large prescriptive or site-specific projects
reporting savings over a threshold of 300,000 kwh
or 10,000 therms should undergo a complete QA/QC
review prior to j-ncentive payment in addition to
the standard Top Sheet review process. Typically, a
QA/QC process reviews engineering calculations,
verifies inputs, checks payback period and
incentive payments for reasonableness, and ensures
compliance with program requirements and tariff
rules. In order to align with the above
recommendation regardj-ng program management and
Khawaja, Di 25
The Cadmus Group, Inc
industries,
outreach
and seek
to specific
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implementation, Cadmus recommends that Avista
determine and document the specific requirements
and steps in the QA/QC process through a
collaborative process that will ensure
accountability and balance needs for efficj-ency and
customer satisfaction.
o Conduct an external third-party review of Top
SheeEs, including reviewing a random sample of
completed Top Sheets for completeness and accuracy.
These were not reviewed as part of the current
process evaluation, but should be included in the
next process evaluation. Review should not only
verify the presence of the Top Sheets, but also the
quality and accuracy of the information provided.
a. Wtrat recommendations resulted from the low income
impact evaLuationE?
A.
o Consider including a control/comparison group in
future billing analyses.
o Consider options for increasing the analysis sample
size due to sma11 program populations (such as
combining Washington and Idaho program participants).
Khawaja, Di 26
The Cadmus Group, fnc
1 o Obtain a fu11 list of weatherization measures from
2 agencies.
3 o Consider targeting high-use customers.
4 o Track and compile additional data from agency audits.
5 o Consider performing quantitative, non-energy benefit
6 analyses.
7 O. Based on the proceas evaluation findiDga, were the
8 programa delivered efficiently?
9 A. Yes, compared to simj-Iar undertakings by other
l0 utilities, they were.
ll O. Can you please srrnmarize your testimony.
12 A. Yes. I believe the Avista evaluation addresses all
l3 measurement and verification needs in accordance with
14 industry and regulatory standards. Impact evaluation on
15 the 201-3 program years verified electric savings exceeding
16 IRP and Avj-sta Business Plan goaIs. The process evaluation
17 revealed that the programs are run efficiently and some
l8 areas for j-mprovement exj-st.
19 O. DoeE that eomplete your pre-filed direct testimony?
20 A. Yes, i-t does.
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Khawaja, Di 27
The Cadmus Group, Inc