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 forgopaying into public benefit fund (PBF) programs and instead direct those funds toward internalenergy efficiency projects, are growing in popularity around the country. Whether or not theseprograms serve the public good in the same manner as other PBF-funded energy efficiencyprograms is not clear at all.The reason we cannot say whether self-direct programs do what we expect energyefficiency programs to do – namely, acquire energy efficiency in a manner that benefits thepublic – 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 selfdirectprograms are in fact making efficiency investments that are equal to what would have beenmade had the companies remained in the existing PBF program. The metrics and unprovenassumptions on which self-direct programs are evaluated and justified are neither robust norwell-vetted. This paper argues, based on interviews with actual self-direct programadministrators, that a lack of data, a lack of substantial evaluation activity within self-directprograms and a focus on financial parity make it difficult to determine whether self-directprograms are a good policy choice. This paper concludes by recommending the types of datacollection and evaluation activities that would be helpful for policymakers to better understandhow and whether self-direct programs are working.