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PROPOSED NEW 16 TAC § 7.480
RELATING TO ENERGY
CONSERVATION PLANS AND
PROPOSED AMENDMENTS TO 16 TAC
§ 7.460
§
§
§
§
§
BEFORE THE
RAILROAD COMMISSION
OF TEXAS
COMMENTS OF ATMOS ENERGY CORPORATION ON PROPOSED NEW 16 TAC
§ 7.480, RELATING TO ENERGY CONSERVATION PLANS AND AMENDMENTS TO
16 TAC § 7.460
Atmos Energy Corporation’s (“Atmos Energy”) Mid-Tex and West Texas Divisions
submits these timely filed comments in response to proposed 16 Tex. Admin. Code (“TAC”)
§ 7.480 (“Rule 7.480”) relating to Energy Conservation Programs (“ECPs”) and proposed
amendments to 16 TAC § 7.460 (“Rule 7.460”), approved for publication by the Railroad
Commission of Texas (“Commission”) on September 19, 2023, and published in the October 6,
2023 issue of the Texas Register.
I. OVERVIEW
Atmos Energy is the country’s largest natural gas-only distributor and safely delivers
reliable, affordable, efficient, and abundant natural gas to more than 3 million distribution
customers in over 1,400 communities across eight states, with over 2 million of those customers
located in Texas. Recognizing our continued role as a vital component of the country’s long-term
sustainable energy future, Atmos Energy is continuing to execute its comprehensive environmental
strategy focused on reducing Scope 1, 2, and 3 emissions (as defined by the Greenhouse Gas
(“GHG”) Protocol) and other environmental impacts from its operations, fleet, facilities, gas
supply, and customer end-use. The largest source of GHG emissions associated with Atmos
Energy’s business is the end-use combustion of our natural gas product (Scope 3 emissions).
Energy efficiency programs are the most impactful opportunity to reduce emissions, while
maintaining customer choice, lowering energy bills, and reducing overall energy consumption.
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Based on an American Gas Foundation study, GHG emissions from U.S. residential natural gas
use could be reduced by as much as 40% from 2020 to 2050 through the use of energy efficient
emerging natural gas technologies, at about 10% of the cost of electrification.
At Atmos Energy, we continue to work on reducing our Scope 3 GHG emissions through
energy efficiency programs that help our customers conserve energy, save money, and reduce their
environmental impact. Atmos Energy currently offers conservation and energy efficiency
programs in its Louisiana, Mississippi, Colorado, and Texas Mid-Tex divisions, with Louisiana
being the latest authority to approve the program in early 2022. These programs are marketed as
SmartChoice Rebates and provide financial incentives to purchase high-efficiency natural gas
equipment and smart thermostats, install home weatherization upgrades, in addition to providing
free energy-saving devices. Atmos Energy appreciates the efforts of the 88
th
Texas Legislature to
pass House Bill 2263 (“HB 2263”), which for the first time sets public policy in the State of Texas
regarding the implementation of ECPs for local distribution companies (“LDCs”) in the state and
will standardize the requirements and oversight of such programs for the benefit of Texas natural
gas customers.
Based on our experience with implementation of ECPs in other states, Atmos Energy offers
the following comments on the Commission’s proposed Rule 7.480 to comply with the directives
of HB 2263 and to serve as guidance for LDCs as they develop ECPs for approval.
In addition, Atmos Energy offers comments on the proposed amendments to Rule 7.460 to
incorporate penalty guidelines for potential violations of the second sentence in Texas Utilities
Code § 104.258(c).
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II. COMMENTS ON RULE 7.480
Atmos Energy has reviewed the Comments submitted by CenterPoint Energy Resources
Corp. and supports the recommended changes to Rule 7.480 contained therein. Atmos Energy
also provides the following additional information for consideration by the Commission.
In designing, developing, and implementing ECPs in other states, Atmos Energy has
focused on beginning with a basic set of proven, high-impact programs that can be deployed
quickly and help to build the infrastructure necessary for future, more comprehensive portfolios of
programs. As the Southeast Energy Efficiency Alliance explains in its treatise “Energy Efficiency
Quick Start Programs: A Guide to Best Practices”:
The development of a portfolio of Quick Start programs provides a unique
opportunity to develop a strategic approach that will both meet short-term
objectives and set the stage for long-term growth and success. Thoughtful planning
of the Quick Start programs and proactive thinking regarding the transition to
Comprehensive Portfolio programs can lead to better performance towards goals,
more satisfied customers and more efficient program delivery.
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In recognition of this fact, Texas Utilities Code § 104.403(g) requires that a proposed ECP
portfolio “must be designed to overcome barriers to the adoption of energy-efficient equipment,
technologies, and processes and be designed to change customer behavior as necessary.” To meet
this requirement, LDCs will need to incur costs for marketing and outreach activities, training of
local trade allies to perform the offerings in the portfolio (such as home energy audits), quality
control and quality assurance processes, partnership with retailers to provide customers with
available rebates, as well as Evaluation, Measurement, and Verification requirements to verify
savings. These costs as a proportion of the overall budget tend to be higher in the first few years
of the program. Atmos Energy has found it to be most effective to use a third-party administrator
(“TPA”) who has extensive expertise in this area to develop, administer, and evaluate its ECPs. In
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https://www.seealliance.org/wp-content/uploads/Quick-Start-Best-Practices-041414-FINAL.pdf at p. 3.
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the states where Atmos Energy has statewide programs available, we have found that our TPAs
have been extremely successful in overcoming the barriers to adoption and encouraging
participation so that all available incentives are claimed by our customers to their net benefit based
on well-established principles of cost-effectiveness.
In Atmos Energy’s Mid-Tex Division, we currently have a modest ECP that reaches a
subset of our Mid-Tex customers, which has been constrained from growth due to the limitations
in cost recovery associated with that program. In compliance with the provisions of Texas Utilities
Code §§ 104.401 et seq. and Rule 7.480, the Mid-Tex Division plans to make a filing for a broader
program with a budget that will allow broader participation across the state. The West Texas
Division, which does not yet have any energy conservation offerings, will make a similar filing.
Each proposal will include a budget that reflects all “costs prudently incurred to implement the
energy conservation programs, including costs incurred to design, market, implement, administer,
and deliver an energy conservation program” per § 104.403(b) and will include supporting
information to show that these costs are reasonable and necessary. Based on past experience, the
“administrative costs” as defined in Rule 7.480 may exceed 15% of the total budget. As a frame
of reference, attached as Exhibit A is Atmos Energy’s Louisiana Division first Annual Report for
its Energy Efficiency Program Portfolio. The costs by category and the resulting savings are
reflected on page 5 of this report. As discussed on pages 14-15, this portfolio of programs was
demonstrated to be cost-effective, providing net benefits to customers in Louisiana, and the costs
were found to be prudently incurred.
Similarly, in its initial proposal and subsequent reporting, Atmos Energy will demonstrate
in our Texas filings that the ECP proposed is cost-effective, providing net benefits to customers
through energy savings and that costs associated with ECP implementation are prudently incurred
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as required by the statute. In order to allow for the Commission to determine on a case-by-case
basis the prudence of such proposed costs and in compliance with the provisions of § 104.403,
Atmos Energy respectfully requests that Rule 7.480 be modified to remove the requirement in
subsection (g) limiting administrative costs to 15% of the total costs of the portfolio.
III. COMMENTS ON RULE 7.460
Texas Utilities Code § 105.023(b-1) states that a civil penalty under that section may not
be less than $1,000 and not more than $1,000,000 for each violation of Section
104.258(c). Section 105.023(e) goes on to direct the Commission by rule to establish a
classification system to be used by a court for violations of 104.258(c).
Section 104.258(c) arguably has two possible violations, one of which is addressed by the
proposed amendments to Rule 7.460. Specifically, § 104.258(c) says that:
A provider may not disconnect natural gas service to a residential customer during
an extreme weather emergency. The provider shall defer collection of the full
payment of bills that are due during an extreme weather emergency until after the
emergency is over and shall work with customers to establish a pay schedule for
deferred bills.
The proposed amendment at Rule 7.460(b)(1) addresses the first potential violation captured in the
first sentence of § 104.258(c), and the subsequent table proposes a classification system to be used
for violations of that first sentence. The second sentence in § 104.258(c) is incorporated in the
language of current Rule 7.460(c) related to deferring collection of bills and offering payment
plans. While it appears from the context and content of HB 2263 that the penalty range up to
$1 million was intended to refer to violation of the requirement not to disconnect during an extreme
weather emergency, failure to comply with the requirements of the second sentence of this
subsection regarding collection of bills and offering payment plans could also be viewed as a
violation and thus requires the establishment of a classification system as well.
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Accordingly, Atmos Energy recommends that the proposed changes to Rule 7.460 also
include the following additions to subsection (c):
(c) Payment plans. Providers shall defer collection of the full payment of bills that
are due during an extreme weather emergency until after the emergency is over and
shall work with customers to establish a payment schedule for deferred bills as set
forth in § 7.45 of this title (relating to Quality of Service). In accordance with Texas
Utilities Code § 105.023, the Office of the Attorney General of Texas on its own
initiative or at the request of the Commission may file suit to recover a civil penalty
for a violation of this paragraph. The table in this paragraph contains a
classification system to be used by a court when such a suit is filed. Figure 16
§ 7.460(c).
Figure: 16 TAC § 7.460(c)
Classification System
Violation Factors
Factor Value (1-2)
Points Tally
Demand for collection of full
payment of bills due is made during
an extreme weather emergency
1
Repeat violations based on
provider’s history of compliance
2
Good faith effort to remedy
violation
-1
Total
Penalty maximum per violation
1-3 points = Class D Violation
$3,000
IV.
CONCLUSION
Atmos Energy appreciates the opportunity to submit these comments and looks forward to
working with the Commission, Staff, and other interested parties to developing the final version of
this significant rulemaking.
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Respectfully submitted,
/s/Daniel R. Renner
Daniel R. Renner
State Bar No. 16778900
Coffin Renner LLP
1011 W. 31
st
Street
Austin, Texas 78705
(512) 879-0900
(512) 879-0912 (fax)
dan.renner@crtxlaw.com
ATTORNEY FOR:
ATMOS ENERGY CORPORATION
Louisiana Rate Division
Program Year 1
Louisiana Energy Efficiency Program Portfolio
Annual Report
Docket No. R-31106
ene1’8Y®
Exhibit A
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Table of Contents
1.0 Executive Summary ................................................................................................................................. 3
2.0 Portfolio Impact ...................................................................................................................................... 5
2.1 Program Costs ......................................................................................................................................... 5
2.2 Program Savings ...................................................................................................................................... 5
3.0 Portfolio Programs .................................................................................................................................. 5
3.1 Residential Solutions Program ................................................................................................................ 5
3.1.1 Program Description ............................................................................................................................ 5
3.1.2 Program Highlights ............................................................................................................................... 6
3.1.3 Program Budgets, Savings & Participation .......................................................................................... 6
3.1.4 Program Events & Training .................................................................................................................. 6
3.1.5 Planned or Proposed Changes to Program & Budget .......................................................................... 8
3.2 Income Qualified Program ...................................................................................................................... 9
3.2.1 Program Description ............................................................................................................................ 9
3.2.2 Program Highlights ............................................................................................................................... 9
3.2.3 Program Budgets, Savings & Participation .......................................................................................... 9
3.2.4 Program Events & Training .................................................................................................................. 9
3.2.5 Planned or Proposed Changes to Program & Budget ........................................................................ 10
3.3 Commercial Solution Program .............................................................................................................. 10
3.3.1 Program Description .......................................................................................................................... 11
3.3.2 Program Highlights ............................................................................................................................. 11
3.2.3 Program Budgets, Savings & Participation ........................................................................................ 11
3.2.4 Program Events & Training ................................................................................................................ 11
3.2.5 Planned or Proposed Changes to Program & Budget ........................................................................ 14
4.0 Evaluation, Measurement & Verification ............................................................................................. 14
4.1 Overview ............................................................................................................................................... 14
Residential Solutions Program – EM&V Procedures ................................................................................... 14
Income Qualified Solutions Program – EM&V Procedures ......................................................................... 15
Commercial Solutions Program – EM&V Procedures ................................................................................. 15
Custom Track? ................................................................................................ Error! Bookmark not defined.
Prescriptive Track? ......................................................................................... Error! Bookmark not defined.
4.2 Cost Benefit – Third Party Evaluator Results ........................................................................................ 15
5.0 Supplemental Requirements ................................................................................................................ 15
Exhibit A
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5.1 Lost Revenue ......................................................................................................................................... 15
5.2 Staffing .................................................................................................................................................. 16
5.3 Information Provided to Consumers to Promote EE ............................................................................ 16
1.0 Executive Summary
In accordance with the rules established by the Louisiana Public Service Commission (“LPSC”), Atmos
Energy (“Atmos”) is submitting this report as the review of the eighth year of the Quick Start Energy
Efficiency Program and the first year of participation for Atmos Energy’s service territory. Pursuant to
LPSC Docket No. R-31106, this annual report is filed four months after the end of the eighth program
year, for continuation of the Quick Start Energy Efficiency Program. To comply with providing
information as required by the rule, the Arkansas Public Service Commission (“APSC”) Standardized
Annual Report Packet (“SARP”) was utilized. This report includes the following sections:
• A narrative report containing program descriptions; activity; savings; participation and trainings;
Evaluation, Measurement and Verification (EM&V) overview; staffing levels; and information
provided to consumers to promote programs.
• A workbook detailing program budget, costs, savings and cost-benefit analysis.
This report addresses the performance of each energy efficiency program implemented under the
Atmos Quick Start portfolio. During the Quick Start period (February 1, 2022 — Dec. 31, 2022), Atmos
operated the energy programs as follows:
• Residential Programs
o Residential Solutions offering financial incentives and technical support to residential
customers with the Atmos Energy Louisiana service area. Prescriptive rebates will be
available to residential customers who replace their existing natural gas appliances with
high-efficiency gas equipment.
o The Residential Solutions Program is also available to Louisiana Homebuilders who build
new homes and choose to install energy efficient natural gas equipment.
o A network of qualified trade allies, vendors, and installation contractors was made
available to help Residential customers navigate equipment installation.
o Direct install measures and energy savings kits were made available at no-cost to
residential customers. These measures included low-flow showerheads, faucet
aerators, and water heater pipe insulation.
o Downstream incentives were available to customers for the purchase of energy efficient
natural gas clothes dryers, natural gas storage, condensing and tankless water heaters,
and Wifi-enabled smart Thermostats through participating retailers.
o The availability of program incentives and services was advertised on the Atmos Energy
website, periodic bill inserts, select media outlets, as well as through basic cooperative
marketing materials developed and available to participating trade allies. All
communication channels aimed to make Atmos Energy customers aware of the benefits
of efficient equipment and the services available from Atmos Energy through the
SmartChoice program.
Exhibit A
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o Residential Income Qualified offering services to customers facing higher risks from
rising energy costs due to income level. This program offered Energy Efficiency kits from
local Community Action Agencies. These kits included low flow devices and well as
thermal pipe insulation to decrease natural gas and water usage.
• Commercial Programs
o The Commercial Solutions program is designed to support commercial customers by
identifying energy-savings opportunities and overcoming the market barriers to
implementing cost-effective, EE investments. The program promotes both prescriptive
and custom measures. Incentives for eligible measures are paid on a $/therm saved per-
project basis. These projects may include direct installation, process improvements,
other system-level custom projects and/or projects involving unique equipment not part
of the prescriptive offerings.
o Program staff pre-inspects and pre-approves projects eligibility and provides M&V
services or review as needed. The program is promoted to key trade allies (e.g.,
engineering firms, energy service providers, trade allies) so they can promote
participation to their customers.
o Multiple commercial contractors, consultants, and engineers were used to help deliver
the SmartChoice Program through multiple channels and projects.
o The Commercial Solutions Program completed over 130 facility assessments across the
state which provided customer education on the value of energy efficiency and function
of energy efficient products. During these assessments, the SmartChoice Program also
offered the installation of no-cost energy savings measures such as: showerheads,
faucet aerators, pre-rinse spray valves, exterior door weatherstripping, overhead door
weatherstripping, steam traps, and Dryer Smart devices.
For Program Year 1(“PY1”), Atmos achieved an energy savings of 554,386 therms through the
implementation of the 3 programs offered to Louisiana customers. Total Resource Cost (TRC) test for
all programs passes at 1.69.
Overall, the Commercial Solutions program saved the largest amount of therms inside the program and
the depth and variety of measures proved this program to be very successful. The Residential Solutions
program saw participation ramp up as the year went on and over 2,300 unique residential customers
participated. The Income Qualified Program had 1,500 customers participate and receive no-cost energy
savings kits.
While 50.56% of budget was utilized during the first year of the program, we anticipate greater
utilization in future years as program awareness increases.
Exhibit A
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2.0 Portfolio Impact
2.1 Program Costs
Program
Marketing &
Delivery
Incentives/Direct
Install Costs
EM&V
Total
Residential Solutions
$300,213
$369,029
$38,890
$708,222
Income Qualified
$44,600
$36,195
$7,540
$88,335
Commercial Solutions
$207,000
$256,509
$33,480
$496,989
Total
$551,813
$661,733
$80,000
$1,293,546
2.2 Program Savings
Program
Rate Class
Annual Therms
Lifetime Therms
Residential Solutions
Residential
37,488
541,614
Income Qualified Solutions
Residential
12,074
130,375
Commercial Solutions
Non-Residential
504,824
4,511,108
Total
554,386
5,183,097
3.0 Portfolio Programs
3.1 Residential Solutions Program
3.1.1 Program Description
The Atmos Energy Residential Solutions Program provides residential customers with access to
qualified vendors and installation contractors, and trade allies within the Atmos Energy Louisiana
service area. Prescriptive rebates are available to residential customers who replace their existing
equipment with high-efficiency gas equipment. Eligible measures, efficiency requirements and
incentive amounts are detailed in the “eligible measures and incentives” section that follows. The
program is also available to homebuilders who build a new home and install eligible equipment.
Equipment installation is delivered directly through a trained network of local trade allies. In
addition to the incentives available for eligible equipment, trade allies also install no-cost instant
savings measures (direct install measures) at the time of the equipment installation. Available
direct install measures include low-flow showerheads, faucet aerators, water heater pipe
insulation and water heater wraps. On top of the trade ally incentive mechanism described above,
downstream incentives are available to customers for the purchase of energy efficient dryers and
gas storage, condensing and tankless water heaters through participating retailers.
The availability of program incentives and services are advertised on the Atmos Energy website,
periodic bill inserts, select media outlets, as well as through basic cooperative marketing materials
developed in partnership with the Atmos Energy SmartChoice Program and available to
participating trade allies. Atmos Energy SmartChoice rebate information is also available at retail
stores and distribution centers throughout the State. The program also utilizes a toll-free number
Exhibit A
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as an alternative intake channel for interested customers. All communication channels aim to
make Atmos Energy customers aware of the benefits of efficient equipment and the services
available from Atmos Energy through this and the SmartChoice program. Program staff and
participating trade allies support customers in home.
3.1.2 Program Highlights
In PY1, the program proved to be a success in terms of customer participation, contractor
participation and retail footpring:
• Energy savings were achieved with the successful installation of 9 unique eligible measures
in 2,358 households.
• The program achieved 37,488 Therms in energy savings
• 28 different residential contractors participated in PY1. This includes 17 Louisiana plumbers
and 11 Louisiana HVAC contractors. Program team met and presented the program to over
100 unique contractors throughout the state.
• 7 Louisiana Homebuilders enrolled and began installing energy efficient equipment in new
homes
• Point of Purchase rebate and educational material installed in 54 retail stores and 32 supply
houses throughout the state
• Customer satisfaction was very high among survey respondents
• 2,358 Participants installed 3,446 measures in PY1
• TRC – 0.31
3.1.3 Program Budgets, Savings & Participation
Program
Year
Cost
Energy Savings
Measures
Budget
Actual
%
Plan
Evaluated
%
Plan
Actual
%
PY1
$1,011,042
$708,222
70%
134,962
37,488
28%
5,794
3,446
59%
3.1.4 Program Events & Training
Hosted in-person Contractor training and outreach meetings throughout the state to educate
Plumbing contractors, HVAC contractors, and homebuilders on the value of energy efficient
equipment as well as the incentives available through the SmartChoice Program. Local Atmos
Energy offices or other meeting spaces were utilized to conduct these training sessions and
contractors were continued to be engaged throughout 2022. During these initial program kick-
off meetings, contractors were given marketing material to present to customers. These events
and trainings occurred in:
• Monroe
• West Monroe
• Lafayette
• Kenner
• Prairieville
Exhibit A
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• Baton Rouge
• Kenner
• Metairie
• Mandeville
• Covington
• Houma
• Slidell
• Hammond
• LaPlace
• Harvey
• Broussard
• Livingston
• Ponchatoula
• Reserve
• Attended and presented to contractors at Diggers’ Night Out (Contractor Meeting in
Slidell)
• Multiple Plumbing-Heating-Cooling Contractors of Louisiana (PHCCLA) events
throughout the state
• TPA staff held sales and customer service training for personnel at 54 retail stores
throughout Louisiana. These stores include Lowe’s, Home Depot, Stine, and other
building supply and hardware stores. During these training sessions, TPA staff would
educate store personnel on the benefits of the energy efficient equipment (Energy Star
clothes dryers, water heaters, smart thermostats) and the rebates for customers. Point
of purchase material for the program was placed in the stores and updated monthly at
all 54 stores.
• TPA staff held sales training at 32 supply houses throughout the state (Southern Pipe
and Supply, Ferguson’s, LCR Plumbing Warehouse, Butcher Distributing, etc). During
these sales trainings, TPA staff would help promote energy efficient water heaters,
furnaces, and smart thermostats to contractors.
• Acadian Home Builder’s Association Events
• Northshore Home Builders Association Events
• Southeast Louisiana Home Builders Association Events
• Home Builders Association of Northeast Louisiana
Exhibit A
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• Earth Day Awareness events at multiple retail locations to promote energy efficiency
and sustainability.
• Events throughout October (Energy Awareness Month) to help educate residential
customers on tips and strategies to reduce energy consumption.
• Over 30 Contractor appreciation events at Supply Houses and Distributors to promote
SmartChoice Program to contractors.
3.1.5 Planned or Proposed Changes to Program & Budget
Atmos Energy SmartChoice Program plans to add weatherization measures such as duct sealing
in accordance with Arkansas TRM 7.0 to achieve residential savings. This measure will be
implemented by local Louisiana Contractors to address leaking return and supply ducts in
residential homes to improve airflow and reduce HVAC runtime. Duct Sealing can be implemented
in all weather zones of Louisiana and will provide increased therm savings and participation for
residential customers.
Third Party Administrator has added additional local staff devoted solely to the Residential
Solutions program. This Residential Solutions Specialist will work with Contractors and
Homebuilders in Louisiana to market and drive more program participation. This will ensure TPA
staff will have even more robust communication with trade allies, homeowners, and
homebuilders.
SmartChoice Program is installing more direct install measures in homes and apartment
complexes and not relying on direct install kit distribution as heavily in 2023. This will ensure the
realization rate of the direct install measures is much higher. TPA Staff is working with Housing
Authorities, apartment communities and residential customers to install these items directly into
dwellings. The goal was set to install these measures in 5,000 homes and as of April 1, 2023 the
TPA has installed these low flow devices in over 2,200 homes.
In PY1 the marketing and education program sent over 56,000 direct install kits emails and over
22,000 smart thermostat emails to Atmos Energy Customers. In order to drive more participation,
the Marketing and education team will slightly increase the direct install kit email outreach to
over 66,000 residential customers in Program Year 2. The Smart Thermostat eblast outreach will
be increased to over 45,000 and cooperative advertising with Distributors will help drive more
participation.
Added more specific and restrictive language regarding the necessity of gas water heaters for
customers who receive direct install kits. This will mitigate the instances of customers receiving
the kits that do not have natural gas water heating.
Added square footage information on rebate paperwork for smart thermostats to ensure more
accurate calculation of savings for these measures.
Program Staff is looking into the viability of using Smart Thermostats as a no-cost direct install
measure for the residential and income qualified program.
Exhibit A
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Atmos Energy SmartChoice Program is exploring potential co-op campaigns with Electric utilities
(CLECO and Entergy) who also offer smart thermostat rebate programs. The utility programs
could advertise these energy efficient measures together for customers who have dual-fuel HVAC
systems.
Third Party Administrator will improve program tracking data and methods of sharing this
information with Evaluator.
3.2 Income Qualified Program
3.2.1 Program Description
The Atmos Energy Income Qualified Program targets income qualified customers in Louisiana
who need access to energy efficient technologies. The objective of the Income Qualified
Program is to generate savings for this community, while improving homeowner awareness of
energy use.
The program offers the installation of low flow shower heads, aerators, pipe wrap, and water
heater wraps (if needed) at no cost to the homeowner. The program also offers the installation
of energy efficient gas water heating equipment at no cost to the homeowner. The program will
work with Community Action Agencies in Louisiana to confirm.
3.2.2 Program Highlights
In PY1, the program proved to be a success in terms of customer participation and Community
Action Agency participation.
• Energy savings were achieved with the successful installation of 3 eligible measures in 1,500
households.
• The program achieved 12,074 (Therms) in energy savings
• 6 different Community Action Agencies participated in PY1 (Quad Area, St. Tammany,
SMILE, Lafourche, Quachita, East Carrol)
• Customer satisfaction among participants was high
• Reached 46% of goal, achieved 12,074 (kWh/Therms) in PY1
• 1,500 Participants in PY1
• TRC - .60
3.2.3 Program Budgets, Savings & Participation
Program
Year
Cost
Energy Savings
Measures
Budget
Actual
%
Plan
Evaluated
%
Plan
Actual
%
PY1
$192,140
$88,335
46%
26,075
12,074
46%
1,455
1,500
103%
3.2.4 Program Events & Training
Multiple Contractor meetings throughout the state
Held Training sessions with the following Community Action Agencies (CAA). These training
sessions included provided income qualified customers with access and education to energy
Exhibit A
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efficiency technology and information on how to reduce energy usage. While these training
sessions were taking place, customers received a no-cost energy savings kit with instructions on
how to install them in their homes.
• Quad Area CAA
• St Tammany CAA
• SMILE CAA
• Lafourche CAA
• Quachita Parish CAA
• East Carroll CAA
3.2.5 Planned or Proposed Changes to Program & Budget
Atmos Energy SmartChoice Program plans to add weatherization measures such as duct sealing
in accordance with Arkansas TRM 7.0 to achieve residential savings. This measure will be
implemented by local Louisiana Contractors to address leaking return and supply ducts in
residential homes to improve airflow and reduce HVAC runtime. Duct Sealing can be implemented
in all weather zones of Louisiana and will provide increased therm savings and participation for
residential customers.
Third Party Administrator has added additional staff devoted solely to the Residential Solutions
program. This Residential Solutions Specialist will work with Contractors and Homebuilders in
Louisiana to market and drive more program participation. This will ensure TPA staff will have
even more robust communication with trade allies and homebuilders.
Program Staff is looking into the viability of using Smart Thermostats as a no-cost direct install
measure for the residential and income qualified program.
Atmos Energy and TPA staff are conducting Energy Awareness days at Community Action Agencies
throughout the state that will help customers to reduce bill payments, as well as educate them
on the SmartChoice Program. During this time, they will be enrolled for potential weatherization
measures at their homes. This will drive therm savings to the program.
In addition to the six CAAs listed above, in PY2 the SmartChoice Program will work with the
following Income Qualified assistance groups:
• Jefferson Community CAA
• CENLA CAA
• Delta Community CAA
• St. John the Baptist CAA
Working closely with Habitat for Humanity, Creating New Horizons, and other non-profit
organizations who build and renovate residential homes for the income qualified customer base.
The SmartChoice Program will provide enhanced equipment rebates and weatherization
measures installed during the construction of the home to drive savings and participation.
Third Party Administrator will improve program tracking data and methods of sharing this
information with Evaluator.
Exhibit A
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3.3 Commercial Solution Program
3.3.1 Program Description
The Atmos Energy SmartChoice implemented a Commercial Program that offers incentives for
direct install and prescriptive measures, and in some cases custom projects, which result in a
verifiable energy usage reduction, focusing on simple, direct install measures for which deemed
savings are available.
This program offers technical assistance provided with other commercial programs that have
been effective in removing market barriers for small commercial customers. This includes
providing facility assessments and customer education on the value of energy efficiency and
function of energy efficient products. Incentives for the program are paid on a $/therm saved
basis using program caps as warranted to ensure that program dollars are allocated across a large
number of participants. The program offers technical support and also develops and maintains a
contractor network to provide additional outreach and customer participation.
3.3.2 Program Highlights
In PY1, the program proved to be a success in terms of customer participation, contractor
participation and savings goals:
• Energy savings were achieved with the successful installation of eligible measures for 80
projects.
• The program achieved 504,824 (Therms) in energy savings
• Over 12 different commercial contractors participated in PY1 (Associated Foods, Gaudin
Equipment, MSS, Louisiana Steam, Bernhard, etc)
• Customer satisfaction for this program was also very high
• Reached 97% of goal, achieved 495,919 (kWh/Therms) in PY1 (additional 20,000 therms will
be added to PY2 as customer did not get information in time for PY1)
• 48 Unique Participants in PY1
• TRC – 2.69
3.2.3 Program Budgets, Savings & Participation
Program
Year
Cost
Energy Savings
Measures
Budget
Actual
%
Plan
Evaluated
%
Plan
Actual
%
PY1
$920,480
$496,989
54%
521,713
504,825
97%
10,052
3,433
34%
3.2.4 Program Events & Training
Hosted Contractor training and outreach meetings throughout the state to educate Plumbing
contractors, HVAC contractors, and homebuilders on the value of energy efficient equipment as
well as the incentives available through the SmartChoice Program. Local Atmos Energy offices
or other meeting spaces were utilized to conduct these training sessions and contractors were
continued to be engaged throughout 2022. These events and trainings occurred in:
• Monroe
Exhibit A
Page 11 of 22
12 | P a g e
• West Monroe
• Lafayette
• Kenner
• Prairieville
• Baton Rouge
• Kenner
• Metairie
• Mandeville
• Covington
• Houma
• Slidell
• Hammond
• LaPlace
• Harvey
• Broussard
• Livingston
• Ponchatoula
• Reserve
• Presented the SmartChoice Program to hundreds of restaurant owners and suppliers at
Louisiana Restaurant Showcase Event
• Presented the SmartChoice Program to Child Nutrition Directors and Facility Directors at
Louisiana School Nutrition Association Events. Multiple Schools have decided to purchase
Energy Star rated cooking equipment in school cafeterias due to the SmartChoice
Program.
• Presented the SmartChoice Program for facility directors at Louisiana Hospital Association
Events. Multiple hospitals have utilized the custom incentive program in order to
complete energy saving projects such as boiler upgrades and replacements, steam system
improvements, and condensate return projects.
• Earth Day Awareness events at multiple retail locations
• Completed 130 facility assessments throughout the state for a diverse cross section of
customers (Hospitals, Schools, Restaurants, Hotels, Auto repair, Non-Profits, etc). These
facility assessments provided education and project recommendations for customers to
utilize the custom or prescriptive rebate program. During these site assessments, TPA
staff also completed no-cost direct install measures to offer immediate natural gas
reduction.
• TPA Staff focused on locally owned dry cleaners to deliver no-cost facility assessment and
steam trap replacements. These sites included:
Exhibit A
Page 12 of 22
13 | P a g e
o D & D Cleaners - Monroe, LA – The SmartChoice Program identified 12 failed
steam traps resulting in an estimated 9,547 Therms saved annually. This project
represents an estimated 22% of their annual gas usage.
o Oil Center Cleaners - Lafayette, LA - The SmartChoice Program identified 11 failed
steam traps resulting in an estimated 10,409 Therms saved annually. This project
represents an estimated 25% of their annual gas usage.
o Scott Oak Cleaners - Scott, LA - The SmartChoice Program identified 10 failed
steam traps resulting in an estimated 6,211 Therms saved annually. This project
represents an estimated 14% of their annual gas usage.
o Thurmanize Cleaners - Monroe, LA - The SmartChoice Program identified 19
failed steam traps resulting in an estimated 12,672 Therms saved annually. This
project represents an estimated 23% of their annual gas usage.
o Congress Cleaners - Lafayette, LA - The SmartChoice Program identified 10 failed
steam traps resulting in an estimated 6,953 Therms saved annually. This project
represents an estimated 11% of their annual gas usage.
o Golden Cleaners – Lafayette ,LA - The SmartChoice Program identified 8 failed
steam traps resulting in an estimated 5,159 Therms saved annually. This project
represents an estimated 8 % of their annual gas usage.
o Kenner Cleaners - Kenner, LA - The SmartChoice Program identified 7 failed
steam traps resulting in an estimated 6,492 Therms saved annually. This project
represents an estimated 26 % of their annual gas usage.
o Hardy Cleaners - Lafayette, LA - The SmartChoice Program identified 6 failed
steam traps resulting in an estimated 12,150 Therms saved annually. This project
represents an estimated 10% of their annual gas usage.
o Northside Cleaners - Lafayette, LA - The SmartChoice Program identified 11 failed
steam traps resulting in an estimated 8,183 Therms saved annually. This project
represents an estimated 9% of their annual gas usage.
o Rosers Cleaners- Kenner, LA - The SmartChoice Program identified 5 failed steam
traps resulting in an estimated 4,742 Therms saved annually. This project
represents an estimated 10% of their annual gas usage.
Exhibit A
Page 13 of 22
14 | P a g e
• Ochsner Main Campus - Jefferson, LA - The SmartChoice Program identified boiler,
insulation, condensate return, and steam trap measures totaling 72,005 Therms saved
annually.
• St. Francis Hospital - Monroe, LA - The SmartChoice Program identified steam trap and
pipe insulation measures totaling 144,957 therms saved annually.
• LSU Hospital - Monroe, LA -The SmartChoice Program identified boiler and steam trap
measures totaling 14,651 therms saved annually.
• Morehouse Parish School Board - Bastrop, LA - The SmartChoice Program identified
Energy Star Commercial Cooking measures totaling 19,532 therms saved annually.
• The Boulevard Bistro Restaurant - Covington, LA - The SmartChoice Program identified
Energy Star Commercial Cooking measures totaling 4,020 therms saved annually.
• Interstate Hyundai - West Monroe, LA - The SmartChoice Program identified direct
install measures totaling 18,635 therms saved annually.
3.2.5 Planned or Proposed Changes to Program & Budget
Third Party Administrator will improve program tracking data and methods of sharing this
information with Evaluator.
Build a more robust trade ally network across different delivery channels to further diversify the
measure mix of the commercial solutions program.
4.0 Evaluation, Measurement & Verification
4.1 Overview
ADM Associates ADM Associates (ADM), the TPE for PY1, evaluated the portfolio in PY1. Two
standards were used to evaluate these savings. For prescriptive measures, verify that savings are
being calculated according to the AR TRM V3.0 and AR TRM V7.0, both adapted for Louisiana
weather. For custom measures, this effort comprises the calculation of savings according to
accepted protocols (e.g., IPMVP). This is to ensure that custom measures are cost-effective and
provide reliable savings.
Residential Solutions Program – EM&V Procedures
EM&V of the Residential Solutions Program consist of a measurement of the existing baseline
conditions of a sample of homes, the nature of the energy efficiency improvements installed,
usage characteristics of the homes pre and post retrofit and assessing whether the homeowners
would have undertaken the efficient actions in the absence of the program. Data gathering to
expedite EM&V was coordinated with the Implementation Contactor and the EM&V implementer
in the final implementation design.
Exhibit A
Page 14 of 22
15 | P a g e
In most cases, TPE applied the AR TRM V7.0 to verify claimed savings. In the case where a measure
is not included in either version of the AR TRM, an alternative TRM was used. For example, natural
gas dryers were not included in the AR TRM V7.0, therefore the Evaluators used deem savings
calculations from the AR TRM V9.0. Additionally, other measures, such as the tankless water
heaters and smart thermostats did not include weather adjusted water temperatures for water
heating in the applicable weather zones, therefore ADM developed weather adjusted savings.
Income Qualified Solutions Program – EM&V Procedures
EM&V of the Residential Solutions Program consist of a measurement of the existing baseline
conditions of a sample of homes, the nature of the energy efficiency improvements installed,
usage characteristics of the homes pre and post retrofit and assessing whether or not the
homeowners would have undertaken the efficient actions in the absence of the program. Data
gathering to expedite EM&V was coordinated with the Implementation Contactor and the EM&V
implementer in the final implementation design.
Commercial Solutions Program – EM&V Procedures
EM&V approach for this program reflects the types of projects completed. To ensure that projects
provide the expected savings, the evaluation approach employs on and off-site verification
assessments to confirm the measures are installed and used under conditions specified by the
TRM, or any other agreed upon methodology. Evaluation activities also assess assumed baseline
conditions through contractor site assessments, when it is appropriate.
4.2 Cost Benefit – Third Party Evaluator Results
Program
Realized Annual
Energy Savings
(Therms)
Number of
Measures/
Projects
Total
Program
Expenditures
Total
Resource Cost
Test (TRC)
Utility
Cost Test
(UCT)
Residential Solutions
37,488
3,446
$708,222
0.3
0.31
Income Qualified Solutions
12,074
1,500
$88,335
0.61
0.61
Commercial Solutions
504,824
3,433
$496,989
2.69
3.86
Total
554,386
8,379
$1,293,547
1.43
1.69
5.0 Supplemental Requirements
5.1 Lost Revenue
Since PY1 was the first year that Atmos participated in the Energy Efficiency program, LCFC was
neither projected nor collected. Atmos Energy reserves the right to do so in the future.
The level of proposed LCFC for each class will be determined by multiplying the class LCFC factor
by the projected annual level of energy savings achieved through each program for each class.
The class LCFC factor will be calculated by dividing the most recent twelve months of EECR
revenue, including formula rate plan increases or decreases, by the class therm sales from the
same period.
Exhibit A
Page 15 of 22
16 | P a g e
5.2 Staffing
Atmos does not directly allocate time spent managing its Energy Efficiency program but absorbs
the direct labor costs.
5.3 Information Provided to Consumers to Promote EE
The programs utilized a direct marketing approach via in-house and third-party program staff as
well as participating contractors. Marketing materials were developed for use within the
programs.
Third Party Staff conducted a robust energy education campaign that was focused on targeted
internet search to help customers discover the energy efficiency program. This was done through
paid search result advertising, Meta (Facebook and Instagram), television and streaming
platforms, and email marketing education efforts.
The Energy Education Campaign ran from May-December in order to raise awareness of the
Atmos Energy Smart Choice Program.
Digital Campaign
Google Responsive Display
• Impressions – 14,030,401
• Clicks – 174,452
• CTR – 1.24%
• Avg CPC - $0.06
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Page 16 of 22
17 | P a g e
Google Responsive Paid Search
• Impressions – 160,531
• Clicks – 30,114
• CTR – 18.75%
• Avg CPC - $0.58
Google Discovery
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Page 17 of 22
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• Avg CPC - $1.00
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Page 18 of 22
19 | P a g e
Sample Digital Creative
Key Takeaways for Digital Campaign
• Google Paid Search was the highest performer
o Incredible Avg. Click-Through-Rate of 18.75%!
• Healthy CTR on Google Display, with a very low Cost-Per-Click
• Utilize video more often on Meta to increase CTR/user engagement
• Setting up conversion tracking would be beneficial in 2023
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Page 19 of 22
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Page 20 of 22
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Page 21 of 22
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Page 22 of 22
