Laserfiche WebLink
2010 -2012 Administrative Cost Cap and Targets- Questions, Issues and Recommendations <br />1) TRAVEL COSTS: IOUs want travel costs for direct implementation non - incentive (DI -NI) and for <br />marketing to be billed to those respective categories, rather than to administrative costs. The allowable <br />costs attachment (ACA) (2006, cited in December 12, 2009 Ruling in D. 08 -07 -021) is silent on this. The <br />ACA does, however, include EM &V travel in the EM &V category. IOUs would like to charge travel /time <br />for staff participation in Strategic Plan workshops in that category. <br />Recommendation: a) Travel costs for IOU staff to travel to workshops regarding the Strategic Plan can <br />be billed to EM &V travel; b) Travel costs for DI -NI activities and marketing can be charged to those <br />respective cost categories; c) travel costs to EE conferences may be charged to administrative costs. . <br />Justification: It is standard practice within the CPUC accounting division to allow travel costs —such as <br />meeting with customers, etc -- to be charged to the applicable program area (ie, to DI -NI or to <br />Marketing and Outreach (M &). Travel costs by IOU staff should be limited, but this will be achieved via <br />the cost targets for M &O and DI -NI. <br />2) CONFERENCE TRAVEL AND FEES /UTILTY SPONSORSHOP OF CONFERENCES: The IOUs suggest <br />that all travel and fees related to EE conferences are appropriate administrative costs. However, ED has <br />conferred with CPUC accounting and we jointly recommend that IOU sponsorship of conferences, i.e. <br />"platinum" "gold" level sponsorships of conferences, are explicitly prohibited as allowable IOU EE <br />conference costs. Sempra reports that its sponsorship of such conferences are currently billed as <br />corporate costs; SCE argues that IOU membership fees in smaller trade oriented associations sometimes <br />includes free entry into related conferences. <br />Recommendation: IOU sponsorships of EE conferences (i.e., "platinum" "gold" level donations) be <br />explicitly prohibited from inclusion in EE budgets as administrative costs. IOUs mayjoin membership - <br />based issue - specific (i.e. HVAC) trade organizations that include as a component of membership benefits <br />entry into conferences. Other staff travel costs to participate in EE conferences are also allowable <br />administrative costs. <br />Justification: IOU sponsorship of major national EE conferences is corporate marketing, not EE program <br />work. IOU staff may participate in such large conferences through regular entry fees in the case that IOU <br />staff are presenting or have targeted educational or networking goals for specific conferences; these are <br />justifiable EE administrative costs. <br />3) BENEFITS /PENSIONS /PAYROLL TAXES: IOUs want to place vacation and sick leave costs relating <br />to labor costs for DI, M &O in those categories, stating that "these follow labor charges." The ACA places <br />these costs in the administrative cost category, but for EM &V states that benefits, payroll tax, and <br />pensions are in the EM &V cost category. All IOUs currently place all EE staff pensions and benefits in the <br />GRC; SCE also includes EE payroll taxes in the GRC, whereas Sempra and PG &E currently place those <br />under administrative costs. <br />Recommendation: IOUs should be allowed to continue to place EE pension and benefit costs in the GRC. <br />However, the IOUs should be required to consistently place EE payroll taxes as general <br />EE administrative costs (i.e. SCE should change its current practice of placing these costs in the GRC). <br />Labor vacation and sick leave costs should follow labor as the IOUs have proposed. <br />01 -01 -2013 Proliggry &fzdential Page E -3 <br />