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cost target level. <br />Citation 3: Marketing Activities (p.73, OP #13b) <br />(p. 73] <br />Using this data as a guideline for our programs, we reduce the ME&O budget to 6% of <br />the adopted portfolios, which is a reduction from the proposed levels of around 8 %, but <br />still above national trends (excluding Vermont as an outlier). This is not a hard cap, as <br />with administrative costs, but a budget target. This target is reasonable. As discussed in <br />the ME&O section, the centerpiece of our ME&O program — the statewide ME&O <br />branding and outreach program — has a budget of $60 million, with additional funding <br />coming from already approved budgets for the LIFE and Demand Response programs. <br />This reduction is also consistent with the direction of D.07 -10 -032, in which we noted <br />our concerns about the increasing ratepayer costs of ME&O for California's demand side <br />programs and directed a statewide, integrated approach. <br />[Ordering Paragraph #13b] <br />Marketing, Education and Outreach costs for energy efficiency are set at 6% of total <br />adopted energy efficiency budgets, subject to the fund- shifting rules in Section II, Rule 11 <br />of the Energy Efficiency Policy Manual <br />Citation 4: Direct Implementation Activities [p.6, 50, 57, OP #13c] <br />!p. 6] <br />Similarly, we place a target of 20% on non - resource support costs.7 <br />7 This activity includes direct implementation non - incentive costs associated with <br />incentive -based programs, such as education and training, engineering support and <br />project management, and long term strategic plan support. <br />(p. 50] <br />Direct Implementation costs for delivering programs, which are defined as "costs <br />associated with activities that are a direct interface with the customer or program <br />participant or recipient (i.e., contractor receiving training)," are also excluded.31 Direct <br />Implementation includes non - resource programs such as Emerging Technologies, <br />VVE&T, Lighting Market Transformation, Zero Net Energy Pilots, local & statewide <br />DSM integration and On -Bill Financing. Also included are direct implementation non- <br />01 -01 -2013 Pro] i ( t4nfzdential Page E -9 <br />