Topic:"Rate Design" in M03669

1 2. 2010 DSM PLAN RESULTS 2 In its August 4, 2009 Decision, 9 3 the UARB approved NSPI's 2010 DSM Plan to achieve 4 an energy savings target of 81.13 GWh at an expenditure of up to $22.56 million. 5 Figure 2.1 shows the savings results co...

AI summary The UARB approved NSPI's 2010 DSM Plan in 2009, targeting 81.13 GWh in energy savings with a budget of $22.56 million. Figure 2.1 compares actual savings to targets, and the NMR Group evaluated the results, which will be reviewed by the UARB's verification consultant.

5.1.3 Potential Savings from NSPI Initiatives ENSC has not included Nova Scotia Power initiatives in the 2012 DSM Plan savings projections. However, ENSC recognizes the significant savings contributions that could be realized from NSPI ini...

AI summary ENSC did not include NSPI initiatives in the 2012 DSM Plan but acknowledges their potential savings from LED street lights, voltage control, smart metering, and rate design. ENSC plans to discuss these opportunities with NSPI for inclusion in future DSM Plans.

OVERSIGHT IN A PERFORMANCE-BASED MODEL Regulatory oversight of a dedicated DSM "utility" like ENSC is broadly analogous to regulatory oversight of other monopoly functions. In this respect, regulatory models exist on a continuum, ranging f...

AI summary The text discusses regulatory oversight of ENSC, a dedicated DSM utility in Nova Scotia, under a performance-based model. It contrasts this with the traditional cost-of-service model used by NSPI and highlights the shift in UARB's oversight role from pre-approving plans to focusing on budget and performance reviews.

sometimes the primary motivating factors in consumers' decisions to pay for energy savings measures. A recent paper on this subject 8 presents several interesting examples of this problem: - Program managers know that many consumers attrib...

AI summary The text discusses the limitations of the Total Resource Cost (TRC) methodology in capturing non-energy benefits (NEBs) such as comfort, productivity, and image, which consumers value highly. These benefits are not accounted for in the TRC, despite contributing significantly to the cost customers are willing to pay for energy-saving measures. Studies highlight the importance of NEBs, often exceeding energy savings in value.

ISSUE A: OVERALL DSM TARGETS ARE NOT LIMITED TO ENSC PROGRAMS ALONE The approved 2009 IRP update 12 clearly suggests that DSM forecasts account for all DSM efforts and savings, including not only resource acquisition DSM programs to be man...

AI summary The 2009 IRP update indicates that DSM targets include not only ENSC programs but also contributions from other entities like NSPI and government policies. The document argues that DSM goals should account for non-program strategies such as energy efficiency codes and standards, which can significantly impact savings. Additionally, the exclusion of the ELI rate class from DSM programs makes the targets more ambitious than initially perceived.

NH-R2. Starting in January 2010, Nova Scotia building code required all new Before designing any future residential new construction homes to have a minimum EnerGuide rating of 80. Builders or energy efficiency programs, the DSM Administra...

AI summary The Nova Scotia building code since 2010 requires new homes to have a minimum EnerGuide rating of 80. Building inspectors are crucial in enforcing these energy efficiency standards. Marketing efforts for the NH program were effective in 2010 but require further enhancement. Homeowners are motivated by potential energy cost savings.

2 COLUMN Α В С D E F G Н 4 Program Cos st Recovery by Benefits 5 6 System Benefits 25.0% $10,936,664 Combined Class and 7 8 Participant Benefits Total 75.0% 100.0% $32,809,993 $43,746,657 9 Total 100.070 ψ 4 3,740,037 ] - Functionalization...

AI summary The table outlines the recovery of program costs and benefits, including system benefits and participant benefits, with percentages and dollar amounts allocated across different rate classes and energy-related factors. The data covers generation, transmission, and distribution costs, as well as energy-related costs, showing a breakdown by residential, industrial, and other categories.

for roughly a fifth of the sample (see Figure 1). These treated households who increase their consumption are on average increasing their daily usage by 0.34 kwH from a baseline usage of 30.79 kWh per 17 We experimented with a quadratic in...

AI summary The analysis reveals that households increasing energy consumption under an increasing block tariff pay $2/month more at Tier 2 summer rates. Conservatives show higher treatment effects (41%) than liberals (19%), with minimal response from liberals using renewable energy. Larger homes and electric homes show stronger effects, while median-usage households exhibit amplified responses for renewable energy adopters.

Conclusion "Nudge" based policy prescriptions seek to make us healthier, richer in our retirement (through opt out defaults), and better environmental citizens. In one consumer finance experiment, "nudges" that are inexpensive to implement...

AI summary The text discusses how 'nudge' policies in energy conservation may have differential effects on liberals and conservatives, with the latter potentially resisting or defying such measures. It highlights the role of Home Energy Reports (HER) in influencing behavior, the need for targeted messaging, and the potential effectiveness of combining nudges with stricter policies like building codes and higher electricity prices.

5 AUTHOR BIOGRAPHIES Daniel Violette, Ph. D. Dr. Violette is a Principal with Summit Blue Consulting who has over 20 years of experience in the energy industry. He is a founder and former CEO of Summit Blue and also served as a Vice Presid...

AI summary This section provides biographies of five individuals involved in energy and regulatory proceedings. It outlines their professional backgrounds, areas of expertise, and contributions to energy efficiency, demand response, and resource planning. The individuals include experts in energy consulting, academic research, and industry practice.

Two primary feedback options - On-bill report: feedback information integrated into NSPI bills - Standalone report: feedback provided to customers separately from utility bills - - May involve combination of mailed information and online t...

AI summary The document outlines two primary feedback options for customer engagement: on-bill reports integrated into NSPI bills and standalone reports provided separately, which may include mailed information and online tools. Implementation will involve collaboration between ENSC and NSPI, with the final format determined in 2011. The Smart Meter-Integrated Home Energy Report is also under consideration.

Date Filed: March 29, 2011 ENSC EAC IR-32 Page 1 of 1 1 Request IR-31B: 4 facilitated by Dr. David Wheeler.17 The final report resulting from this process envisioned a 5 performance-driven oversight mechanism, whereby ENSC would be respons...

AI summary The document discusses the implementation of a performance-based oversight mechanism and a multi-year framework for energy and demand savings, similar to approaches used in Vermont. It requests further details on how ENSC would initiate this approach and how it functions in other jurisdictions.

Ratepayer Impact Measure Test The RIM Test measures whether billing rates will go up or down as a result of an efficiency program. Put another way, it measures whether non-participants in a program will be better or worse off as a result o...

AI summary The Ratepayer Impact Measure (RIM) Test evaluates whether efficiency programs lead to increased or decreased billing rates for non-participants. It compares the value of avoided supply investments, such as energy and transmission costs, to the program's costs and lost utility revenues from reduced sales.

Concerns about the TRC and Societal Tests as Currently Applied We have two fundamental concerns about the TRC and Societal Tests as they are currently applied: - 1. Most non-energy benefits are not factored into the tests. - 2. Supply inve...

AI summary The text raises two concerns regarding the application of the Total Resource Cost (TRC) and Societal Tests. First, non-energy benefits are not considered in the tests. Second, supply investments are not subject to the TRC, creating an uneven hurdle for demand-side investments compared to supply-side alternatives.

begin using our personal values rather than market values to determine what is cost-effective. The result will be efficiency programs with at least somewhat lower levels of participation and savings. Now consider Home Performance with ENER...

AI summary The text discusses the limitations of using the Total Resource Cost (TRC) test for evaluating energy efficiency programs, particularly Home Performance with ENERGY STAR. It argues that the TRC test fails to justify such programs due to the high costs involved, even though they provide significant energy savings. This is problematic in the current era, where pursuing all cost-effective efficiency is a key policy imperative.

Quantifying All Non-Energy Benefits The second option for fixing the TRC is to tackle the benefits side of the equation. Specifically, regulators could theoretically require that all non-energy benefits are estimated and factored into TRC...

AI summary This text discusses the theoretical ideal of including all non-energy benefits in the Total Resource Cost (TRC) screening process, arguing that while it would provide a more balanced assessment of costs and benefits, it is likely too complex, controversial, and expensive to implement in practice. Examples include health and safety benefits from energy efficiency programs, which may be underestimated if not properly quantified.

DIRECT EVIDENCE OF MEL WHALEN, P.ENG. 1 MR. WHALEN, WOULD YOU PLEASE INTRODUCE YOURSELF? 2 3 My name is Melvin E. Whalen. I am President of Multeese Consulting Incorporated. I am 4 a Professional Engineer, registered in the Province of Nov...

AI summary Mel Whalen, a Professional Engineer and President of Multeese Consulting, has extensive experience in planning, load forecasting, integrated resource planning, and rate design. He was engaged by Board counsel to review Efficiency Nova Scotia Corporation's 2012 DSM proposal. Tim Woolf from Synapse Energy Economics Inc. is also participating in the review.

sed on abstract arguments and perceived, undocumented concerns. Second, there are many different ways to quantify and present rate impacts. With many energy efficiency programs there may be a trade-off between short-term increases in rates...

AI summary The text critiques the Dunsky report's alternative ramp-up schedule for relying on abstract arguments and undocumented concerns. It highlights challenges in quantifying rate impacts and notes trade-offs between short-term rate increases and long-term customer bill reductions through energy efficiency programs.

- Q. Once rate and bill impacts of energy efficiency programs are properly quantified, what are the additional factors to consider in deciding whether specific rate impacts are acceptable? - A. I recommend that three important factors be c...

AI summary The discussion focuses on factors to consider when assessing the acceptability of rate impacts from energy efficiency programs. Key considerations include program participation levels, program design, and overall benefits. The level of participation affects the equity of rate impacts, with higher participation reducing concerns for non-participating customers.

Q. You mentioned above that the overall benefits of efficiency programs should be a factor in assessing rate impacts. What do you mean by this? A. It is important to recognize that while energy efficiency can increase rates it also results...

AI summary The response emphasizes that energy efficiency programs, while potentially increasing rates, also provide significant benefits such as reduced electricity costs. It suggests that the Board should consider these benefits when evaluating rate impacts and recommends using the Program Administrator Cost test to assess cost reductions. A comparison between scenarios with different efficiency budgets is recommended to determine the optimal balance between rate impacts and benefits.

Q. Are you recommending that ENSC conduct analyses of the rate and bill impacts of its energy efficiency programs at this time? A. No, not necessarily. My point is that if concerns about rate impacts are used to slow the ramp-up rate of en...

AI summary The respondent indicates that while ENSC is not currently recommending analyses of the rate and bill impacts of its energy efficiency programs, such analyses are important if concerns about rate impacts are used to slow program implementation. Proper quantification is necessary to assess trade-offs between higher rates and energy efficiency benefits.

PROFESSIONAL EXPERIENCE Synapse Energy Economics Inc ., Cambridge, MA. Vice President, 2011 to present. Provides expert consulting on the economic, regulatory, consumer, environmental, and public policy implications of the electricity and...

AI summary The text outlines the professional experience of an individual with extensive expertise in energy economics, regulatory affairs, and public policy, including roles at Synapse Energy Economics Inc., the Massachusetts Department of Public Utilities, and other organizations, with a focus on energy efficiency, clean energy, and utility regulation.

3463). Oral testimony regarding the settlement of Narragansett Electric Company's 2004 Demand-Side Management Programs. On behalf of the Division of Public Utilities and Carriers. November 21, 2003. California Public Utilities Commission (...

AI summary The text lists various testimonies provided in different regulatory proceedings across multiple jurisdictions, including topics such as demand-side management programs, performance-based ratemaking, and appliance efficiency standards. These testimonies were given on behalf of various organizations and legal entities.

ARTICLES AND PRESENTATIONS Managing Electricity Industry Risk with Clean and Efficient Resources , The Electricity Journal , with John Nielson, David Berry and Ronald Lehr, Volume 18, Issue 2, March 2005. Local Policy Measures to Improve A...

AI summary The text lists various articles and presentations related to energy efficiency, renewable resources, electricity market restructuring, and environmental policies. Topics include integrated resource planning, renewable portfolio standards, performance-based ratemaking, and electricity pricing. These materials span from 1992 to 2005 and cover international and regional perspectives on energy and utility regulation.

1 Education & Outreach and Development & Research costs were allocated based on Customer counts used in the Cost of Service Studies submitted in 2009 Compliance Filing 2 3 4 5 COLUMN ۸ 4 5 Α В С D E F G Н 1 J ĸ · FORMULA Σ col A to I J x 7...

AI summary The text discusses the allocation of Education & Outreach and Development & Research costs based on customer counts from the 2009 Compliance Filing. It includes a detailed table showing program costs incurred on various rate classes and the distribution of these costs.

Expert Witness and/or Litigation Support Engagements 2009-2012 ofNevada Annual Low-Income Evaluations for State for legislative committees 2002-2003 Philadelphia Gas Works, Seniors & Low Income Rate Design 2002 of US Department Health & Hu...

AI summary The text lists various expert witness and litigation support engagements conducted between 1999 and 2012, primarily involving evaluations and studies related to low-income energy programs, rate design, and policy studies for utility companies and government agencies across multiple jurisdictions.

IT IS FURTHER ORDERED that: - 1) With regard to the SVS, the Board is satisfied that ENSC is reviewing the recommendations and orders ENSC to file its response to the recommendations no later than July 31, 2011, for consideration by the Bo...

AI summary The Board orders ENSC to respond to recommendations, improve rate impact data, complete a free ridership study, develop policies for non-electricity programs, continue PDWG engagement, and meet quarterly to review program progress. These actions aim to enhance transparency, stakeholder involvement, and accountability in energy efficiency initiatives.

ergy savings from actual DSM programs in future years. [ENSC Closing Submission, pp. 3-5] [66] ENSC acknowledged some of the concerns raised, and submitted that the proper question for the Board is: ... what evidence is on the record to su...

AI summary ENSC argues that the Board should evaluate evidence before approving increased DSM spending, citing concerns over rate impacts and over-achievement of IRP targets. The CA supports the 2012 budget, noting a 100% increase from 2010 and ENS's new operational status. Rate impacts from DSM spending are acknowledged but require careful analysis.

4.2.1 Findings - [71] The Board understands that the targets for energy and demand savings are considered to be aggressive when compared to other jurisdictions; however, these targets and associated investments were established early in th...

AI summary The Board acknowledges the aggressive DSM targets set in the IRP and notes that NSPI met them successfully. ENSC, as the new administrator, faces challenges in meeting these targets. The Board approves the 2012 DSM investment of $43.7 million, allowing ENSC flexibility and including savings from non-program initiatives.

4.4 Bill Impacts [79] In his direct evidence on behalf of Board Counsel, Mr. Woolf discussed the need to establish key principles regarding how to quantify bill and rate impacts due to increasing DSM budgets in order that these rate and bi...

AI summary The text discusses the principles for quantifying bill and rate impacts from increasing DSM budgets, emphasizing the need to evaluate these impacts on participants, non-participants, and all customers. The Province recommends ENSC consult with NSPI and the PWDG to develop principles for incorporating these impacts into DSM plan filings.

9.0 SUMMARY OF BOARD FINDINGS [153] The Board accepts the 2010 DSM Plan evaluation and verification, with the qualification made in the SVS for a 10% reduction for the Efficient Products-Direct Install program. [154] The Board understands...

AI summary The Board accepts the 2010 DSM Plan evaluation with modifications, approves the 2012 investment in DSM programs, and directs ENSC to address data systems, cost allocations, and stakeholder engagement. The Board also requires ENSC to complete a free ridership study and develop policy for tracking costs across mandates.

NON-CONFIDENTIAL _________________________________________________________________________________________________________ algorithm or other mathematical representation of factors, such as bill impacts, rate impacts, energy and demand sav...

AI summary The text references an algorithm or mathematical model designed to represent factors such as bill impacts, rate impacts, energy and demand savings, and effects on avoided or marginal costs, likely in the context of regulatory proceedings related to utility rate structures and cost recovery mechanisms.

fuel supplies and lack of competition. - 10. In this submission EAC will address the following issue areas using the testimony and evidence presented before the Board in this proceeding: - a. 2012 DSM Budget and Proposed Energy Savings fro...

AI summary EAC addresses the 2012 DSM budget's reduced energy savings due to ELI's unforeseen savings, the budget's reasonableness, and the absence of a process for determining energy savings targets. The discussion highlights regulatory discretion and the need for established processes in IRP energy savings targets.

Rate Impacts 1. There is no formal process to properly assess the rate and bill impacts of DSM in Nova Scotia. However as the analysis provided by Mel Whalen and Tim Woolf suggests, and as the IRP identified, DSM is the most cost-effective...

AI summary The text highlights the absence of a formal process to assess DSM rate impacts in Nova Scotia, despite DSM being identified as the most cost-effective resource. Experts like Mel Whalen and Tim Woolf emphasize the need for detailed, long-term analysis of rate impacts on both participants and non-participants, challenging the use of rate impacts to limit energy efficiency budgets.

and makes no adjustment for any classes revenue/cost ratio. In the ELI situation, as its R/C ratio is below 1, the ELI class will be allocated a smaller share of the savings than shown by Mr. Whalen. For all of the foregoing reasons, NPB r...

AI summary NPB challenges Mr. Whalen's analysis of rate impacts, arguing his proposal would impose incremental costs on most customer classes except ELI. Whalen's initial analysis focused only on large customers and ELI, but later calculations (MCI-U3) showed net costs for all classes in 2012. NPB questions the validity of his claims about positive rate impacts for ELI customers.

19 See, for example, Exhibit [E-12], Supra Note 8, Page 3, Lines 5-6. 20 Exhibit [E-1], Supra Note 7, Page 29. 21 Exhibit [E-12], Supra Note 8, Page 2, Lines 26-28. 1 ENSC sees continued value and support in having the PDWG continue throug...

AI summary ENSC supports the continuation of the PDWG throughout 2011. It argues that performance-based rates, which provide financial incentives and penalties beyond cost recovery and rate of return, are designed to maximize efficiencies shared between rate-payers and shareholders, and that the independence of the shareholders from government and Nova Scotia Power Inc. is not applicable to this rationale.

ADDITIONAL POINTS It became apparent during the hearing that ENSC has assumed responsibility for efficiency programs beyond electricity. One can reasonably expect there will be overlap in service delivery and administrative overheads in re...

AI summary The text highlights ENSC's expanded role in multi-fuel efficiency programs, raising concerns about overlapping costs and administrative burdens. The Avon Group recommends a public report on shared service allocations and criticizes NSPI's lack of detailed rate impact analysis in the ACE Plan filing. Rate impacts and cost recovery mechanisms are emphasized as critical issues requiring transparency and stakeholder input.

Reply Submission In the past, Nova Scotian stakeholders have agreed that DSM is the better ratepayer option to pursue, not only because it offered the least cost procurement option, when compared to supply options, but also because stakeho...

AI summary The document argues that Demand Side Management (DSM) is a cost-effective strategy for Nova Scotia's electricity system, emphasizing its role in reducing fuel and capacity costs. It highlights overachievement of Integrated Resource Plan (IRP) targets, urging increased DSM budgets to capitalize on efficiency opportunities. The Efficiency Nova Scotia Corporation (ENSC) acknowledges potential for more savings with higher funding, while risks of inaction include lost momentum and public trust.

Undertakings of Mel Whalen According to EAC's analysis and interpretation of Undertaking 2, the ELI class is actually in a position to benefit by $500,000 in fuel cost savings from a DSM budget of 53.4 million. ELI is expected to pay 2 mil...

AI summary The analysis argues that ELI (a rate class) benefits from DSM budget increases through fuel cost savings and should support expanded DSM programs. It criticizes ELI's opposition to increased DSM ambition, noting they stand to gain from avoided capacity costs and rate stabilization. The text highlights underestimation of benefits in Undertaking 2/3 and calls for equitable program provisions.

May 20, 2011 1 1. INTRODUCTION 2 3 In this proceeding, UARB approval is requested for the proposed Electricity Demand 4 Side Management Plan for 2012 (the 2012 DSM Plan). 5 6 ENSC, as DSM Administrator, filed its Closing Submission in this...

AI summary The document outlines the submission of a reply to the Closing Submissions in a proceeding requesting UARB approval for the 2012 DSM Plan. The Consumer Advocate requests a revision to the cost allocation methodology for Enabling Strategies, suggesting a more equitable method based on shared benefits across rate classes. ENSC acknowledges the argument but does not explicitly commit to revising the methodology.

4.4 Bill Impacts [79] In his direct evidence on behalf of Board Counsel, Mr. Woolf discussed the need to establish key principles regarding how to quantify bill and rate impacts due to increasing DSM budgets in order that these rate and bi...

AI summary The text outlines principles for quantifying the bill and rate impacts of increasing Demand Side Management (DSM) budgets. It emphasizes the need to evaluate these impacts on program participants, non-participants, and all customers on average, as well as the importance of considering both long-term and comprehensive cost and benefit analyses. The Province recommends that ENSC collaborate with NSPI and the Program Development Working Group to develop these principles for DSM plan filings.

4.4.1 Findings [81] The Board is persuaded that there is a need to have better information on rate and bill impacts in future proceedings and directs ENSC to undertake the necessary consultation with a view to providing enhanced informatio...

AI summary The Board emphasizes the need for improved information on rate and bill impacts in future proceedings, directing ENSC to consult and provide enhanced information as suggested by Mr. Woolf in connection with the 2013 DSM Plan.

5.1.2 Adoption of Energy-Efficiency Codes and Standards In this filing, ENSC has reported energy savings attributed to the adoption of codes and standards from two sources: a new residential energy code and a new federal standard for gener...

AI summary ENSC reports energy savings from new residential and federal lighting standards, and plans to include NSPI initiatives in future DSM Plans. ENSC also proposes supporting new energy codes and standards for residential and commercial sectors, including T-8 lighting and a national commercial building energy code.

5.5 Integrated Multi-Fuels Mandate [117] ENSC noted that the Province is in the process of changing its mandate and future responsibilities: With the expectation that ENSC will obtain a multi-fuels mandate in time for integration with 2012...

AI summary ENSC is transitioning to an integrated multi-fuels mandate, aiming to streamline processes and reduce costs. Concerns were raised about cross-subsidization and the need for clear cost allocation. The CA urged ENSC to develop a plan to prevent electricity ratepayers from subsidizing non-electricity users. Avon recommended a public report on shared service cost allocations.

sup> The load shape class determinants from the 2012 FAM load forecasts have been applied by NSPI in its update to revenue requirement (section 11.1) filed in its reply evidence on September 13, 2011. - 2011 2 • The major difference betwee...

AI summary The document discusses NSPI's update to its revenue requirement, incorporating load shape class determinants from 2012 FAM forecasts and the shutdown of New Page Port Hawkesbury. It details DSM program costs approved by the UARB, allocation methods, and the use of DCRR and DCRR BA components to address discrepancies in DSM program cost recovery.

n details are presented in Appendix B. - 7. The individual DSM Cost Recovery Rider charges, both DCRR and DCRR BA, by class are presented for approval in Schedule A of the 2012 DSM Cost Recovery Rider 4 The GRLF load sales as used for the...

AI summary The document discusses the DSM Cost Recovery Rider (DCRR) and its balance adjustment (DCRR BA), including how charges are calculated and presented for approval. It refers to the 2012 DSM Cost Recovery Rider, the 2009 DSM Settlement Agreement, and the allocation of expenditures among rate classes. The approach will be reviewed after three years, with Nova Scotia Power anticipating a review of the cost allocation methodology beyond 2012.

(5) All residential rate classes will use the same unit fixed cost estimate. Line # TABLE 2 Allocation of 75% of DSM Program Costs associated with benefits realized by participating classes. 1 2 COLUMN A B C D E F G H I J 3 4 5 FORMULA Σ c...

AI summary The text discusses the allocation of 75% of DSM program costs across various rate classes, providing a detailed breakdown of program costs and their distribution. All residential rate classes will use the same unit fixed cost estimate.

(5) All residential rate classes will use the same unit fixed cost estimate. COLUMN A B C D E F G H I K L FORMULA Σ col A to J K x 75% Program costs incurred on participating rate classes. Efficient Existing Prescriptive New Business DI Sm...

AI summary The document outlines the allocation of program costs across different residential and non-residential rate classes, using a uniform unit fixed cost estimate for all residential classes and allocating 75% of program costs directly to participating rate classes.

Efficiency Nova Scotia Corporation ("ENSC"), which was created by legislation that was proclaimed January 22, 2010, is subject to regulation by the Nova Scotia Utility and Review Board ("NSUARB" or "Board"). It filed its first Electricity...

AI summary Efficiency Nova Scotia Corporation (ENSC) is regulated by the Nova Scotia Utility and Review Board (NSUARB). ENSC filed its first Electricity Efficiency and Conservation Plan, the 2012 DSM Plan, and the NSUARB issued a decision and order in 2011. With ENSC's expanded mandate, the Board directed ENSC to develop a cost allocation model and policy to track time and costs for electric and other fuel mandates.