What You Don’t Know May Hurt You: Lessons from Today’s Large Customer Self-Direct Programs

摘要

Self-direct and opt-out programs, which allow large energy-using customers to forgo paying into public benefit fund (PBF) programs and instead direct those funds toward internal energy efficiency projects, are growing in popularity around the country. Whether or not these programs serve the public good in the same manner as other PBF-funded energy efficiency programs is not clear at all. The reason we cannot say whether self-direct programs do what we expect energy efficiency programs to do – namely, acquire energy efficiency in a manner that benefits the public – is because we do not know enough about self-direct programs and their impacts. Additionally, most self-direct programs rely on a dollar-for-dollar parity to determine that selfdirect programs are in fact making efficiency investments that are equal to what would have been made had the companies remained in the existing PBF program. The metrics and unproven assumptions on which self-direct programs are evaluated and justified are neither robust nor well-vetted. This paper argues, based on interviews with actual self-direct program administrators, that a lack of data, a lack of substantial evaluation activity within self-direct programs and a focus on financial parity make it difficult to determine whether self-direct programs are a good policy choice. This paper concludes by recommending the types of data collection and evaluation activities that would be helpful for policymakers to better understand how and whether self-direct programs are working.