Commerce affirms that causality is not required for conservation resources under I-937.

As you may know, Seinergy submitted an application to the Washington State Department of Commerce, which issues determinations about the Energy Independence Act commonly known as Initiative 937. These advisory opinions help utilities and the energy efficiency industry understand how to implement and abide by the state mandate.

We are pleased to report that Commerce agrees with our understanding of the law. In their own words, “evidence of causality or direct influence by a utility on the decision to implement a conservation measure is not necessary for the conservation measure to be used to satisfy a utility’s conservation target.”

Commerce’s advisory opinion acknowledges “the statute does not require that the utility involve itself in every installation of a conservation measure.” And regarding how utilities set targets, “The Power Council methodology … identifies the resources that are cost-effective without regard to who will bear the costs, reap the benefits, or undertake the effort that may be required to acquire the resources.”

Read Commerce’s complete response.


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