Just weeks before the California Public Utilities Commission is expected to act on massive investor-owned utility energy efficiency plans, measuring the investments\u2019 effectiveness is in dispute. The plans outline $4.2 billion in spending on energy efficiency from 2009 through 2011--on top of $2.2 billion utilities spent on energy saving measures between 2006 and 2008. They aim to make conservation from negawatts just as certain as MWs from a new power plant when it comes to grid reliability. In addition, the plans attempt to meet greenhouse gas reduction requirements under an expected carbon cap-and-trade program. They also aim to transform a wide range of products--from lighting to buildings--toward energy efficiency. Another question is not only who, but how many, review efficiency efficacy--if the spending is reviewed at all. The plans outline 500 separate programs. There is supposed to be a \u201cfirewall\u201d between those who carry out utilities efficiency plans and those who evaluate them. It appears, however, that the firewall may be selectively opened. Currently, utilities have a large measure of involvement in the evaluation process, which can be performed by contractors they pay but who also answer to the CPUC Energy Division. An evaluation of utility efficiency programs in 2006-07 that the commission sent to the Legislature last month showed that net energy savings and the monetary benefit of those savings to ratepayers were lower than reported by the utilities. It found, for instance, that while the utilities reported that ratepayers received a net benefit of $1.765 billion due to energy savings achieved by spending $1.563 billion dollars, the evaluation and verification process showed the benefits totaled only $836 million, or 47 percent of what the companies claimed. One reason for the lower figure was that the commission adjusted for utility energy savings claims related to increased CFL usage. In many cases, the commission said that the utilities could not take credit for CFL usage because consumers would have bought the bulbs irrespective of utility programs. \u201cThe commission faces a very fundamental question,\u201d The Utility Reform Network legal Director Bob Finkelstein stated in an August 3 filing. To improve the performance of the utility energy efficiency programs the commission must change the evaluation process, he said. Otherwise, California may not see the programs perform much better in the years to come. The consumer organization is urging the commission to affirm a strong role for its Energy Division when it comes to evaluation after what it sees as over-reliance in the past by utilities on subsidizing compact fluorescent light bulbs. TURN consulting economist Cynthia Mitchell called the bulbs \u201ca real waste of consumer money.\u201d Underlying the arguments over the technical details of evaluation is concern over the degree to which either the utilities or the CPUC\u2019s Energy Division should control the process. The filings show that issue is particularly contentious because the evaluations become the basis for determining whether ratepayers pay potentially hundreds of millions of dollars in bonuses to utilities when they meet their energy savings goals. As consumer advocates advise, the CPUC\u2019s Energy Division wants an elevated role for evaluation because of the increase in funding for utility energy efficiency programs. It also said that given the commission\u2019s ambitious goals of transforming technology through its efficiency program it needs to add new criteria to the evaluations. However finding qualified people to perform the evaluations is difficult. To get around this problem, the Energy Division proposed allowing exceptions to the existing \u201cfirewall,\u201d which is supposed to prevent entities, such as contractors, that carry out the efficiency programs from also evaluating them. The division said that appropriate oversight and contract terms could guard against conflict of interest and maintain the integrity of the evaluations. Allowing the exceptions would expand the pool of people who could carry out the deeper evaluations. The division also wants a larger role for itself in managing the evaluation process too and wants to broaden the opportunity for public involvement. Pacific Gas & Electric, though, does not believe deeper involvement by the commission\u2019s Energy Division is sufficiently justified. \u201cPG&E generally supports the current division of Energy Division and investor-owned utility roles,\u201d wrote company attorney Michael Klotz in a filing. He added that the commission should hold off on major changes to the evaluation, measurement and verification process until it updates its procedure for granting bonuses to utilities for achieving energy efficiency. In a July 7 ruling in the energy efficiency proceeding, CPUC administrative law judge David Gamson observed that the commission may not rule on changes to the evaluation process until after it has approved the utility spending plans, a process running almost a year behind schedule. Consideration of the plans is due early this fall and the decision on how to evaluate their effectiveness may not come until November. In the meantime, utilities are \u201cstaffing up\u201d their energy efficiency programs, said Jody London, a consultant who represents cities in the energy efficiency proceeding. They are assuming that they will continue to play the primary administrative role, she said.