….Repair Indefinitely 1 A New Class of Retrofits:… ACEEE 2010 Summer Study A Brief History of EULs in California Douglas Mahone Cal Technical Forum March 19, 2015

….Repair Indefinitely 2 A New Class of Retrofits:… ACEEE 2010 Summer Study Ramifications of EULs for Retrofits CPUC believes –Incenting to reach code is paying customers to do what law already requires –All equipment fails at end of EUL –Max EUL is 20 yrs Exception: special cases allow 30 yrs EUL (schools, local governments) Problems –Owners are not required to retrofit –Equipment often lasts beyond EUL –Many measures last longer than 20 yrs

….Repair Indefinitely 3 A New Class of Retrofits:… ACEEE 2010 Summer Study Why is the Max EUL 20 years? Discounted value of savings disappears after 20 years –While this makes sense as a rule of thumb for savings claims, it does not dictate when actual equipment fails This is a tax principle being extrapolated to technical questions Are there other options available? What is the best rationale for using alternatives?

….Repair Indefinitely 4 A New Class of Retrofits:… ACEEE 2010 Summer Study CPUC Exceptions Current program Decision: –May assume 30 yr EUL for schools retrofits under AB 39 –Ditto for local governments Tacit acknowledgment that 20 yrs may be too short