triennial plan ii: straw proposal

Triennial Plan II:Straw Proposal

Program Descriptions and Issues

Outline

Business Programs Residential Programs Renewable/Alt Energy Programs Cross-Cutting Programs

Template:– Recent Program Results– Opportunity– Budget / Revenues– Delivery / Strategy– Issues• Stakeholder Topics, Questions to be added

Business Programs

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Incentive Program – Recent Results

Metric Results of FY11 Programs

Total Participants 1205

Total Projects 1949

Efficiency Maine Costs $11,045,371

Participant Costs $10,145,729

Lifetime kWh Savings 586,638,242

Lifetime $ Savings $47,315,549

B/C Ratio 1.93 (Evaluated)

Incentive Program – More Results (1)

Measure Prescriptive CustomLighting 1562 92HVAC 62 3Compressed Air 0 33Variable Frequency Drive 22 24Miscellaneous 0 28Agriculture 10 0Motors 59 0Refrigeration 54 0Total 1769 180

Business Incentive Program -- # Measures Installed (FY-11)

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Incentive Program – More Results (2)

Education and Training– 175 new Qualified Partners (QPs) among trade allies in the supply chain– Participated in 15 targeted business trade shows– Presented Program overview and Energy Management Practices at 30

business and trade association meetings throughout the State Tech Support

– Answered +/- 660 incoming calls for customer support– Established web-based incentive application process and tracking tool

QC – Inspected 421 projects

• 100% of all projects over $5,000 incentive • 10% of projects under $5,000

Eligible Measures – new prescriptive LED incentives (wall pack, outside light, parking

garage, refrigerated case light, screw-in & pin based lamps)– Discontinued: motors

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Incentive Program – Description (1)

Opportunity– Continue EM’s long-running, well-developed program– Broad reach, easy access for customers– Potential to enhance delivery strategy

• Potential to further simplify, streamline delivery strategy• Pay for Performance (delivery contractor, QP, customer)

– Measures• Refrigeration• Compressed Air• LED Conversion• Lighting design & controls

Budget / Revenue– FY-12 $8.7M (electric) + $252,000 (gas) (SBC, RGGI, MPRP)– FY-13 $6.1M (electric) + $252,000 (gas) (SBC, RGGI, MPRP)

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Incentive Program – Description (2)

Delivery / Strategy – Blend of tech support, education, training, financial incentives,

and QC– Financial Incentives for a fraction of the “incremental cost” for

eligible measures on the Prescriptive List approach or Custom approach, vary by “retrofit” and “new” / “replace on burnout”

– Partnership with trade ally network (400 QPs)– Contracted program support competitively bid– Currently Eligible Measures:

• 22 Fluorescent and LED lighting measures• 21 Refrigeration measures• 12 Commercial A/C and Heat Pump measures• 7 Variable Frequency Drive (VFD) measures• 10 Specific Ag measures (fans, vacuum pumps)• Compressed Air measures

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Incentive Program -- Issues

Delivery / Strategy – Continue to develop and rely on a significant role of the market / trade

allies (QPs), or use more 3rd-party contractors under contract to the Trust

Budget / Revenue– Market demand is growing, budgets shrinking; “foot on the gas, foot on

the brake”– Continue to direct approx. 30% of RGGI revenues through this Program?– Continue to run Natural Gas conservation funds for “Commercial”

customers through this Program?• Should other gas utilities also pay in to Conservation Fund?

– TriPlan 2 Proposed Budgets• Baseline -- $6.1M/yr (electric) + $242,000(gas)/yr• Additional Funding Scenario -- $10M /yr (electric) + $450,000 (gas)/yr

Other– _____– _____

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Small Business Direct Install – Description (1)

Recent Results– N/A (Pilot project rolling out in FY12-13)

Opportunity– Success in other jurisdictions

• confirmation TBD from emerging pilot in Maine– Tens of thousands of potential participants

• typically slower to adopt new technology, turnover equipment• limited time/resources to investigate options

– Ubiquitous use of inefficient lights; uniform “plug and play” solution

Recent Budget / Revenue– FY-13: $1.0M, SBC

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Small Business Direct Install – Description (2)

Delivery / Strategy (Current Pilot)

– We bring the program “direct” to the Small Businesses’ door

– No money up-front– Customer balance may be repaid through utility on-bill

financing– Prescriptive lighting (ubiquitous need, uniform solution,

predictable savings / costs)– Easy to target geographically

• Pilot is targeting 2 areas (Northern Maine) to start

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Small Business Direct Install - Issues

Delivery / Strategy– Should we plan for a Statewide program (currently piloting in BHE/MPS)?

• How to address On Bill Financing if utilities not interested?– Should we plan for an expansion beyond lighting to include HVAC and/or

Refrigeration?

Budget / Revenue– How do answers to above questions differ if we assume (a) Baseline

Funding or (b) Increased Electric Budget Scenario?– TriPlan 2 Proposed Budgets

• Baseline: $1M/yr• Additional Funding Scenario: $2M/yr

Other– _____– _____

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Multi-Family Weatherization Project -- Description (1)

Recent Results– N/A – Program commenced June, 2012

Opportunity– Maintain momentum from federal grant-funded pilot project– Efficiencies of addressing multiple units at once

• lower transaction costs• All fuels synergies (electric, heating/cooling)

– Address “Landlord-Tenant Market Barrier”– Address traditionally underserved market: Significant # of business

owners, serving middle-class renters, where other subsidies (WAP) don’t apply or are insufficient

Budget / Revenue– Current Funding ($6.5M) relies on $4.5M federal grant which ends

9/30/2013– Big thermal opportunity, questionable fit for electric funds

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M-F Weatherization Project - Description (2)

Delivery / Strategy– Targets

• 1,800 units (from 5-20 unit buildings )• 20% Energy Savings

– Delivery Contractor provides:• Outreach

– Partner with, work through local banks– Apartment associations, housing authorities, etc.

• Baseline energy assessment/analysis• +/- $1,500/unit financial incentive• Loan loss reserve to ease financing

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M-F Weatherization Project - Issues

Delivery / Strategy– Potential to limit eligibility to electrically heated/cooled units

• Market potential unknown

Budget / Revenue– Project funding ends 9/30/2013

• How do we address the statutory targets re: weatherizing, reducing heating fuel consumption with little or no heating oil funds?

• Should we attempt to continue M-F efforts using electric SBC funds?

– TriPlan 2 Proposed Budgets• Baseline: $0/yr• Additional Funding Scenario: $___/yr

– Source: SBC? Other? Other:

– ______

Large Customer Program –Recent Results (Electric only)



Efficiency Maine Costs $ 4,717,139

Participant Costs $ 8,461,453


Lifetime $ Savings $ 28,533,872*

B/C Ratio 6.8 (per Evaluation)* Subsequent 3rd party analysis determined actual savings to be higher than reported in the Annual Report, which explains the higher B/C ratio found in the Evaluation.

Large Customer Program –Recent Results (GHG savings only)





Lifetime GHG Savings 620,008 (tons CO2e)

Lifetime $ Savings $ 197,588,241*

B/C Ratio 11.1 (per Evaluation)* Subsequent 3rd party analysis determined actual savings to be higher than reported in the Annual Report, which explains the higher B/C ratio found in the Evaluation.

Large Customer Program - Description

Opportunity– Very favorable B/C ratio– Market survey suggest large market potential, unmet demand– Successful results in other states– Reach some of the biggest energy consumers and largest employers in the

state to help them lower energy costs and improve competitiveness– Address market barrier – secure approval for capital projects in Maine

facilities by buying down upfront project cost to meet large companies’ capital budgeting process (e.g., payback, IRR)

Budget / Revenue– FY-12 $6.7M (RGGI, ARRA-federal, MPRP)– FY-13 $2.5M (RGGI, MPRP)– Electric projects straightforward for EM to bid into FCM, generate additional

revenues to EM– Enhanced Financing could unlock new opportunities by removing the

upfront cost barrier and enabling projects to be funded through operating budgets rather than limited capital budgets.

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Large Customer Program - Description

Delivery / Strategy

– Competitive Bidding approach • Low administrative and marketing costs for EM• Technical project screening / analysis• Objective selection process

– Complements Business Incentive Program• Large Program >$100,000

– Introducing limited Account Management approach• Strategic, deeper savings• Less risk for customer• Marginally more labor and cost for EM

Large Customer Program - Issues

Delivery / Strategy– What strategies exist to reward/capture collateral energy

saving opportunities (i.e., to address cream skimming and loss of future cost-effective opportunities)?

– Should marketing/selection rely exclusively on competitive bidding? • Pros – low delivery costs, objective selection process, high

leverage• Cons – timing in capital planning process, uncertainty for

bidders, recent experience of low uptake– If budgets increases, should strategy increase use of Account

Management approach and reflect this in budget/results?– Whether to focus 100% of RGGI funds on electric customers

(whence they come), or continue 85-15 split electric-GHG/thermal, or other.

Other:– ________20

Large Customer Program – Issues (2)

Budget / Revenue– Should Staff pursue Enhanced Financing through the PUC

during TriPlan 2?– TriPlan 2 Proposed Budgets

• Baseline: $2.1M/year (RGGI, MPRP)• Additional Funding Scenario: $10M (RGGI, MPRP,

Enhanced Financing)

Other:– _____– _____

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Business Sector Training (1)

Recent Results– Building Operator Certification (BOC) trained 36 facility

operators– Converted lessons into savings of more than 5 million kWh per

year– Other targeted training for facility managers

Opportunity– Closer coordination of program design and implementation

between the training courses and the Business Program needs– More targeted, simplified training for QPs to help their

customers

Budget / Revenues– FY-11: $83,000/ Yr

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Business Sector Training (2)

Delivery / Strategy– Turn-key delivered by contractor– Series of classes training facility managers to lower energy

costs and maintenance costs, while enhancing building occupant comfort and safety, through energy efficiency• instruct students in the use of advanced building

equipment and controls Issues

– Whether the proprietary BOC course is still in high demand after several years in Maine

– Whether BOC should be complemented or replaced by something less intensive, less costly

– TriPlan 2 Budget Proposal:• Baseline: $100,000• Additional Funding Scenario: $200,000

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Business Programs – To Be Discontinued

High Performance Schools– Rolled into the New Construction Program

Commercial Grant Program– Funding from federal ARRA grant exhausted– Electric opportunities available through Business Incentive

Program Municipal Grant Program

– Funding from federal ARRA grant exhausted New Construction – Maine Advanced Building Retro-Commissioning Small Business Audits and Loan Program (?)

– Lost revenue stream– Very limited uptake– Focus on DI pathway– Limit to available capital

• from existing loan repayments

Residential Program

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Retail Products Program – Recent Results


Total Participants 1.9 million CFLs



Lifetime kWh Savings 614,388,191*

Lifetime $ Savings $ 46,745,171

B/C Ratio 6.0 †

* Subsequent 3rd party analysis determined actual savings to be higher than reported in the Annual Report, which explains the higher B/C ratio found in the Evaluation.† Factoring in both Lighting and Appliance Program results. Lighting results alone achieved 7.4 B/C.

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Retail Products Program – Description (1)

Opportunity

– Lighting• >30M sockets state-wide (550k homes * 60 ea)• 14M prospective sockets for CFLs per evaluation (2M/yr)• EISA regulation reduces savings credit for CFL’s• LEDs emerging as cost-effective

– Electronics• Smart Strips, TVs, PCs, monitors

– Appliances• 33,000 fridges, clothes washer & dehumidifiers promoted in

FY-12• Additional opportunities for cost-effective products

– but lower B/C than other residential retail products

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Retail Products Program – Description (2)

Budget / Revenue– FY-12: $3.8M (SBC, RGGI, MPRP)– FY-13: $4.5M (SBC, RGGI, MPRP)

• Includes low income-dedicated funding

Delivery / Strategy– Retail store MOUs

• 347 stores participating– Incentive Delivery

• Upstream discounting• In-Store Coupons

– In-store marketing• Staff saved $500,000/yr in marketing and re-deployed to

customer incentives– Alternative Channels (e.g. Good Shepherd Food Bank, other

program cross selling)– Evaluation Lessons:

• 19% of Lighting participants meet definition of “Low Income”

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Retail Products Program – Issues

Delivery / Strategy– Measures• Smart strips offer potential savings, but are

confusing for consumers• Absent Additional Funding Scenario, discontinue

Appliance Rebates–B/C is only 1.5 compared to Lighting (7.4)

Budget / Revenue– Continue to allocate a portion of the low-income

customers’ 20% SBC set-aside to be run through this program?

– TriPlan 2 Budget Proposal:• Baseline: $3.8M/Yr.• Additional Funding Scenario: $ 7.1M/Yr.

Refrigerator Recycling Program


Total Participants Estimate 5000 units/yr

Efficiency Maine Costs $ 2.0 Million FY12&FY13

Participant Costs $ 0


Lifetime $ Savings $ 10,250,000

B/C Ratio 3.0 (Projected, TriPlan 1)

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Refrigerator Recycling Program - Description

Opportunity– Retire in-use, inefficient fridges and freezers– Target secondary units that get little use but remain plugged

in– Estimated potential = 5,000-10,000 units/year

• Assuming 500,000 residential units• 1-2% “harvest rate”

– Successfully used in other jurisdictions Budget / Revenue

– FY-12&13 -- $2M over 2 years, from SBC funding Delivery / Strategy

– Turn-key contractor• Handles marketing, customer service, screening, pickup,

recycling/disposal, payment– Need cost-effective communication channels (Utility bill

stuffers, PR)– Cross-sell with other programs

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Refrigerator Recycling Program - Issues

Delivery / Strategy

– Unknown free ridership or incremental savings– Program design harder to implement in practice than

in theory

Budget / Revenue

– TriPlan 2 Proposed Budgets• Baseline Funding: $1.2M/year• Additional Funding Scenario: $1.2M/year

Whole House Retrofit – Recent Results


Total Participants 3,200 (Rebate only)

Efficiency Maine Costs $8,588,496

Participant Costs $20,368,825

Lifetime MMBtu Savings 4,820,173 (35 million gallons)

Lifetime $ Savings $101,335,965*

B/C Ratio 2.56 (per Evaluation)* Subsequent 3rd party analysis determined actual savings to be lower than reported in the Annual Report, which explains the lower B/C ratio found in the Evaluation.

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Whole House Retrofit – Description (1)

Opportunity– Continue momentum from federally funded rebate and revolving loan

programs for whole home energy improvements – Maine

• oldest building stock in US and significant heating degree days• growing population of residents on fixed income, for whom volatile

heating costs pose serious financial risk– Universe of opportunity

• 500,000-550,000 residential units• 70% of homes heat with #2 oil, price of #2 oil up 300% or more in

past decade making energy saving investments more attractive / cost-effective

– Economics of energy upgrades improving• HESP Rebate pilot demonstrated opportunity to achieve deep

energy savings for modest cost (avg. $8,300/project)• Other pilots (Air Sealing, Unity) demonstrating opportunity to

achieve significant savings for low cost ($300-$500/project)– Possible reduced energy consumption of 160 million gallons of oil

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Budget / Revenue

– FY-12 and 13: $20.4 M Capital Base for loans (federal ARRA)• May be split with Large Customer Program

– FY-12 and 13: $2M for Residential Direct Install (federal ARRA)

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Delivery / Strategy Carry forward momentum from successful, federally funded rebate program

that ended late 2011 Combine education, marketing, and partnership with trade allies (contractors) Expand into related networks (real estate, mortgage, insurance, etc.) PACE and PowerSaver Loans

– Sales and marketing strategy through contractor base and municipalities– Single call for loan application for multiple products– Third-party loan origination and loan servicing

Residential Direct Install– Market based and driven through contractor base– Capture easy, low-cost savings through Air Sealing or similar measures– Entice customers to take first steps toward whole house upgrade– Generate leads for financing program (for more expensive projects with

longer term paybacks)• $300 for evidence of 6 hours of air sealing and insulation & home

data.• $100 for post weatherization project data and full test out.

Data collection and analysis

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Whole House Retrofit – Issues

Budget / Revenues Original proposal to US DOE:

Recapitalize the fund for 8 years, as needed, through revenue bonding using loan repayments/interest to cover bond obligations

Consider options to recapitalize by selling notes to Secondary Market

TriPlan 2 Budget Proposals: Continue use of Natural Gas Conservation Fund in Unitil

territory for Residential Direct Install $137,500/year

Consider use of $13M in QECBs (Qualified Energy Conservation Bonds) through a “Green Communities Program”

Uncertainty support for bonding

Efficient Heating Equipment Program



Efficiency Maine Costs $1.2 million

Participant Costs $456,000

Lifetime MMBtu Savings 179,825

Lifetime $ Savings $2.23 million

B/C Ratio 1.34

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Efficient Heating Equipment Program

Opportunity– Mechanism for supporting upgrades by homeowners to

highest efficiency equipment including condensing boilers and heat pumps

Budget / Revenue– Gas and Electric program components could be funded out

of SBCs– FY-11: $1.2M– There is no “All Fuel” or “Unregulated Heating Fuel” funding

currently authorized

Delivery / Strategy– Sales and marketing strategy through contractor base– Supported by financing programs– Set equipment standards beyond Energy Star

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Replacement Heating Equipment Program - Issues

Delivery / Strategy– Whether to shift to Retail Products (in-store rebate) strategy

or continue with direct homeowner/contractor mail-in rebate– Should we limit use of funds from electric or gas conservation

fund to paying for electric or gas efficient equipment, respectively?

Budget / Revenue– TriPlan 2 Proposed Budget

• Baseline Budget – $___ for cost-effective electric heat pumps (elec SBC)– $___for cost-effective natural gas systems (gas SBC)

• Additional Funding Scenario:– $___ for cost-effective electric heat pumps (elec SBC)– $___ for cost-effective natural gas systems (gas SBC)

Other– __________

Low Income Program – Recent Results (Fridges & CFLs)



Efficiency Maine Costs $ 325,515



Lifetime $ Savings $ 465,922

B/C Ratio 1.43

Low Income Program – Recent Results (Whole House Retrofits)


Total Participants 1,000 (est.)

Efficiency Maine Costs $ 5 million


Lifetime kWh Savings TBD

Lifetime $ Savings $ TBD

B/C Ratio TBD

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Low Income Program – Description (1)

Opportunity– 3,400 LIHEAP, electrically heated homes (per MaineHousing

records)– Many more non-LIHEAP (HUD Section 8, USDA Section 515)– Landlords maintain audited demographics

Budget / Revenue– FY-11: $2.6M from SBC for Refrigerators and CFLs, only

$325,000 spent– FY-12: $5M from SBC for Whole House Retrofit for electrically

heated homes– FY-13:

• $800,000 from SBC for Retail Products (Lighting) • $1.9M from SBC and MPRP for Whole House Retrofit for

electrically heated homes• $1M from federal ARRA grant for alternative heat systems

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Low Income Program – Description (2)

Delivery / Strategy

– Refrigerator Replacement Program was slowing down dramatically

– Single-family electric heat homes• Relying on MaineHousing / CAP Agencies for Marketing,

Screening, Delivery

– Multi-family electric heat apartments• Competitive bid to contractors for audit and install• Managed by 3rd-party administrator

– Introducing use of efficient heat pumps

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Low Income Program - Issues

Delivery / Strategy– Single-family electric heat homes

• Challenges identifying suitable candidate homes– Many SFH have already switched fuels– Need access to customer contact info

– Target fewer, larger loads through individual house treatments (i.e., weatherization) or smaller, more ubiquitous loads through retail channels or low-income service channels (i.e., lighting/electronics)?

Budget / Revenue– What fraction of Low Income budget (if any) should go to

weatherization versus retail products (lighting, electronics)? – TriPlan 2 Proposed Budget:

• Baseline: $2.8M• Additional Funding Scenario: $2.8M

Other– _________

Renewable Energy Programs

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Renewable Resource Program – Recent Results

Metric FY11 Solar/Wind Rebate

FY11 RD&D Program

Total Participants

371 10

Efficiency Maine Costs

$ 571,528 $ 429,064

Participant Costs $ 4,765,571 $ 137,390

Lifetime MMBtu Savings

80,595 N/A

Lifetime $ Savings

$ 1,583,307 N/A

B/C Ratio 0.30 (TRC) N/A

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Renewable Resource Program - Description

Opportunity– Movement of renewable industry to mainstream through new

professional standards and requirement for cost-effective renewable energy installations

Delivery / Strategy– Website information and forms– Delivery through installers with NABCEP certificates of knowledge &

insurance– Recent rule change requires cost-effectiveness to end user and

projected kWh output to calculate rebate amount– 2.5 cents per modeled lifetime kWh output, caps at $2000/resid;

$4000/business Budget / Revenue

– $100,000 from Alternative Compliance Payments and Voluntary Contributions

– $728,000 remaining from Original Solar/Wind SBC for use in new rebate structure, will be exhausted in FY13

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Renewable Resource Fund - Issues

Delivery / Strategy– N/A

Budget / Revenue– New revenue stream needed in order to continue rebate

program– TriPlan 2 Proposed Budget

• Baseline: $100,000• Additional Funding Scenario: $ _____

Other– _____– _____

Cross-Cutting Programs

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Innovation Program - Description

Recent Activity– Funded 2 proposals – one piloting supplemental mini-split heat pumps,

the other piloting heat pump water heaters; Results due June 2013– Previously funded apartment CHP system and 2 pilots for Smart Meter

customer dashboard applications Opportunity

– Pilot programs for initiatives that show cost-effective energy savings that are good candidates for addition to sustained EMT programs

– Ability to test new ways of delivering savings– Targeted pilots intended to be nimble and timely

Delivery / Strategy– Competitive RFP – Ability to fine-tune RFP solicitation to address opportunities– Focus on proposals where EMT foresees future revenue stream and

scalable opportunity Budget / Revenue

– FY-12: $400,000 from SBC and RGGI

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Innovation Program - Issues

Delivery / Strategy– Should Staff continue to prioritize close nexus to

emerging program needs in the RFP design/criteria?

Budget/Revenues– TriPlan 2 Proposed Budgets• Baseline: $300,000/Yr• Additional Funding Scenario: $___

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Energy Education and Information - Description

Recent Results– Save Like a Mainer Campaign FY-12 & 13

• Fostering appreciation of energy efficiency based on successful case studies from real customers in Maine

• Combining websites, radio ads, print ads, trade show display, Chamber events, social media messaging, speaking engagements with networks, earned media, etc.

– Schools for Energy Efficiency• Delivered by non-profit organization• 2 participating school districts; 15 schools• Enlisting and organizing volunteer facility managers, teachers

and students to set energy saving targets, develop and implement a plan, and monitor and report on the progress

– Community Energy Nights• Delivered by a non-profit organization• Targeting 8 towns where schools have been active in energy

efficiency curriculum• Audience includes students and parents

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Energy Education and Information - Description

Opportunity– Enhance awareness through education and outreach to increase

likelihood of program participation– Take advantage of new information and communication channels

related to Smart Meters• Consider differences between Commercial and Residential sector

opportunities– Take advantage of newfound access to utility data about customer

usage, geographic location– Foster information exchange in Maine among opinion leaders about

issues related to energy efficiency, alternative energy, and customer-sited renewable energy

Budget / Revenue– FY-12: $400,000 – Funds come from SBC & FCM

Delivery / Strategy– Competitive RFPs, targeted to enhance program participation– Focus on proposals with demonstrable energy savings and/or a link

to increased program participation– Enhanced EM Website

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Energy Education and Information - Issues

Delivery / Strategy– Should we move away from programs targeted at educating primary

and secondary school students about the origins and types of energy?– Should we focus programs on providing information, education, training

on the supply chain (retailers, contractors, suppliers, A&Es, etc.)?– Should we focus on programs that have a nexus to helping achieving

the results/metrics of the Triennial Plan’s other program areas?– Should this program focus on providing information / learning that will

apply to mid- and longer-term EE opportunities and leave short-term opportunities ?

– What new or different strategies should be pursued under an Additional Revenue Scenario strategy?

Budget/Revenue– TriPlan 2 Budget Proposal

• Baseline: $300,000/Yr• Additional Revenue Scenario: $______/Yr

Other:– _______

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Evaluation – Description and Issues

Recent Results– Completed 6 independent, 3rd party impact evaluations, including

• Home Energy Savings Program• Business Incentive Program• Commercial Grant Program• Large Impact Program

– Interim results reported from Residential Lighting Program evaluation– PACE Program evaluation underway

Opportunity– Incorporate program design improvements and savings calculations

per evaluation recommendations– Analyze project data and utility data to enhance strategies

Budgets / Revenues– TriPlan 1 Budgets: $900,000/yr– TriPlan 2 Proposed Budgets

• Baseline: $800,000/yr• Additional Funding Scenario: Proportionate to program increase

Please Share Your Ideas:Send Written Comments to:

Email – [email protected] – Triennial Plan Comments

151 Capitol Street, Suite 1Augusta, ME 04330

Workshops start July 10 Latest that comments will be considered is August 15

triennial plan ii: straw proposal

Documents

evaluatedincentive program

qpscontracted program

gas sbc

bidcurrently eligible

gas utilities

market trade allies

delivery strategypay

delivery strategypotential