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Triennial Plan II: Straw Proposal Program Descriptions and Issues.

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Presentation on theme: "Triennial Plan II: Straw Proposal Program Descriptions and Issues."— Presentation transcript:

1 Triennial Plan II: Straw Proposal Program Descriptions and Issues

2 Outline Business Programs Residential Programs Renewable/Alt Energy Programs Cross-Cutting Programs Template: – Recent Program Results – Opportunity – Budget / Revenues – Delivery / Strategy – Issues Stakeholder Topics, Questions to be added

3 Business Programs 3

4 Incentive Program – Recent Results 4 MetricResults of FY11 Programs Total Participants1205 Total Projects1949 Efficiency Maine Costs$11,045,371 Participant Costs$10,145,729 Lifetime kWh Savings586,638,242 Lifetime $ Savings$47,315,549 B/C Ratio1.93 (Evaluated)

5 Incentive Program – More Results (1) MeasurePrescriptiveCustom Lighting156292 HVAC623 Compressed Air033 Variable Frequency Drive2224 Miscellaneous028 Agriculture100 Motors590 Refrigeration540 Total1769180 Business Incentive Program -- # Measures Installed (FY-11) 5

6 Incentive Program – More Results (2) Education and Training – 175 new Qualified Partners (QPs) among trade allies in the supply chain – Participated in 15 targeted business trade shows – Presented Program overview and Energy Management Practices at 30 business and trade association meetings throughout the State Tech Support – Answered +/- 660 incoming calls for customer support – Established web-based incentive application process and tracking tool QC – Inspected 421 projects 100% of all projects over $5,000 incentive 10% of projects under $5,000 Eligible Measures – new prescriptive LED incentives (wall pack, outside light, parking garage, refrigerated case light, screw-in & pin based lamps) – Discontinued: motors 6

7 Incentive Program – Description (1) Opportunity – Continue EMs long-running, well-developed program – Broad reach, easy access for customers – Potential to enhance delivery strategy Potential to further simplify, streamline delivery strategy Pay for Performance (delivery contractor, QP, customer) – Measures Refrigeration Compressed Air LED Conversion Lighting design & controls Budget / Revenue – FY-12 $8.7M (electric) + $252,000 (gas) (SBC, RGGI, MPRP) – FY-13 $6.1M (electric) + $252,000 (gas) (SBC, RGGI, MPRP) 7

8 Incentive Program – Description (2) Delivery / Strategy – Blend of tech support, education, training, financial incentives, and QC – Financial Incentives for a fraction of the incremental cost for eligible measures on the Prescriptive List approach or Custom approach, vary by retrofit and new / replace on burnout – Partnership with trade ally network (400 QPs) – Contracted program support competitively bid – Currently Eligible Measures: 22 Fluorescent and LED lighting measures 21 Refrigeration measures 12 Commercial A/C and Heat Pump measures 7 Variable Frequency Drive (VFD) measures 10 Specific Ag measures (fans, vacuum pumps) Compressed Air measures 8

9 Incentive Program -- Issues Delivery / Strategy – Continue to develop and rely on a significant role of the market / trade allies (QPs), or use more 3 rd -party contractors under contract to the Trust Budget / Revenue – Market demand is growing, budgets shrinking; foot on the gas, foot on the brake – Continue to direct approx. 30% of RGGI revenues through this Program? – Continue to run Natural Gas conservation funds for Commercial customers through this Program? Should other gas utilities also pay in to Conservation Fund? – TriPlan 2 Proposed Budgets Baseline -- $6.1M/yr (electric) + $242,000(gas)/yr Additional Funding Scenario -- $10M /yr (electric) + $450,000 (gas)/yr Other – _____ 9

10 Small Business Direct Install – Description (1) Recent Results – N/A (Pilot project rolling out in FY12-13) Opportunity – Success in other jurisdictions confirmation TBD from emerging pilot in Maine – Tens of thousands of potential participants typically slower to adopt new technology, turnover equipment limited time/resources to investigate options – Ubiquitous use of inefficient lights; uniform plug and play solution Recent Budget / Revenue – FY-13: $1.0M, SBC 10

11 Small Business Direct Install – Description (2) Delivery / Strategy (Current Pilot) – We bring the program direct to the Small Businesses door – No money up-front – Customer balance may be repaid through utility on-bill financing – Prescriptive lighting (ubiquitous need, uniform solution, predictable savings / costs) – Easy to target geographically Pilot is targeting 2 areas (Northern Maine) to start 11

12 Small Business Direct Install - Issues Delivery / Strategy – Should we plan for a Statewide program (currently piloting in BHE/MPS)? How to address On Bill Financing if utilities not interested? – Should we plan for an expansion beyond lighting to include HVAC and/or Refrigeration? Budget / Revenue – How do answers to above questions differ if we assume (a) Baseline Funding or (b) Increased Electric Budget Scenario? – TriPlan 2 Proposed Budgets Baseline: $1M/yr Additional Funding Scenario: $2M/yr Other – _____ 12

13 Multi-Family Weatherization Project -- Description (1) Recent Results – N/A – Program commenced June, 2012 Opportunity – Maintain momentum from federal grant-funded pilot project – Efficiencies of addressing multiple units at once lower transaction costs All fuels synergies (electric, heating/cooling) – Address Landlord-Tenant Market Barrier – Address traditionally underserved market: Significant # of business owners, serving middle-class renters, where other subsidies (WAP) dont apply or are insufficient Budget / Revenue – Current Funding ($6.5M) relies on $4.5M federal grant which ends 9/30/2013 – Big thermal opportunity, questionable fit for electric funds 13

14 M-F Weatherization Project - Description (2) Delivery / Strategy – Targets 1,800 units (from 5-20 unit buildings ) 20% Energy Savings – Delivery Contractor provides: Outreach – Partner with, work through local banks – Apartment associations, housing authorities, etc. Baseline energy assessment/analysis +/- $1,500/unit financial incentive Loan loss reserve to ease financing 14

15 M-F Weatherization Project - Issues Delivery / Strategy – Potential to limit eligibility to electrically heated/cooled units Market potential unknown Budget / Revenue – Project funding ends 9/30/2013 How do we address the statutory targets re: weatherizing, reducing heating fuel consumption with little or no heating oil funds? Should we attempt to continue M-F efforts using electric SBC funds? – TriPlan 2 Proposed Budgets Baseline: $0/yr Additional Funding Scenario: $___/yr – Source: SBC? Other? Other: – ______ 15

16 Large Customer Program – Recent Results (Electric only) MetricResults of FY11 Programs Total Participants9 Efficiency Maine Costs$ 4,717,139 Participant Costs$ 8,461,453 Lifetime kWh Savings423,281,776 Lifetime $ Savings$ 28,533,872* B/C Ratio6.8 (per Evaluation) * Subsequent 3 rd party analysis determined actual savings to be higher than reported in the Annual Report, which explains the higher B/C ratio found in the Evaluation.

17 Large Customer Program – Recent Results (GHG savings only) MetricResults of FY11 Programs Total Participants9 Efficiency Maine Costs$ 3,434,218 Participant Costs$ 15,894,752 Lifetime GHG Savings620,008 (tons CO2e) Lifetime $ Savings$ 197,588,241* B/C Ratio11.1 (per Evaluation) * Subsequent 3 rd party analysis determined actual savings to be higher than reported in the Annual Report, which explains the higher B/C ratio found in the Evaluation.

18 Large Customer Program - Description Opportunity – Very favorable B/C ratio – Market survey suggest large market potential, unmet demand – Successful results in other states – Reach some of the biggest energy consumers and largest employers in the state to help them lower energy costs and improve competitiveness – Address market barrier – secure approval for capital projects in Maine facilities by buying down upfront project cost to meet large companies capital budgeting process (e.g., payback, IRR) Budget / Revenue – FY-12 $6.7M (RGGI, ARRA-federal, MPRP) – FY-13 $2.5M (RGGI, MPRP) – Electric projects straightforward for EM to bid into FCM, generate additional revenues to EM – Enhanced Financing could unlock new opportunities by removing the upfront cost barrier and enabling projects to be funded through operating budgets rather than limited capital budgets.

19 Large Customer Program - Description Delivery / Strategy – Competitive Bidding approach Low administrative and marketing costs for EM Technical project screening / analysis Objective selection process – Complements Business Incentive Program Large Program >$100,000 – Introducing limited Account Management approach Strategic, deeper savings Less risk for customer Marginally more labor and cost for EM 19

20 Large Customer Program - Issues Delivery / Strategy – What strategies exist to reward/capture collateral energy saving opportunities (i.e., to address cream skimming and loss of future cost-effective opportunities)? – Should marketing/selection rely exclusively on competitive bidding? Pros – low delivery costs, objective selection process, high leverage Cons – timing in capital planning process, uncertainty for bidders, recent experience of low uptake – If budgets increases, should strategy increase use of Account Management approach and reflect this in budget/results? – Whether to focus 100% of RGGI funds on electric customers (whence they come), or continue 85-15 split electric-GHG/thermal, or other. Other: – ________ 20

21 Large Customer Program – Issues (2) Budget / Revenue – Should Staff pursue Enhanced Financing through the PUC during TriPlan 2? – TriPlan 2 Proposed Budgets Baseline: $2.1M/year (RGGI, MPRP) Additional Funding Scenario: $10M (RGGI, MPRP, Enhanced Financing) Other: – _____ 21

22 Business Sector Training (1) Recent Results – Building Operator Certification (BOC) trained 36 facility operators – Converted lessons into savings of more than 5 million kWh per year – Other targeted training for facility managers Opportunity – Closer coordination of program design and implementation between the training courses and the Business Program needs – More targeted, simplified training for QPs to help their customers Budget / Revenues – FY-11: $83,000/ Yr 22

23 Business Sector Training (2) Delivery / Strategy – Turn-key delivered by contractor – Series of classes training facility managers to lower energy costs and maintenance costs, while enhancing building occupant comfort and safety, through energy efficiency instruct students in the use of advanced building equipment and controls Issues – Whether the proprietary BOC course is still in high demand after several years in Maine – Whether BOC should be complemented or replaced by something less intensive, less costly – TriPlan 2 Budget Proposal: Baseline: $100,000 Additional Funding Scenario: $200,000 23

24 Business Programs – To Be Discontinued High Performance Schools – Rolled into the New Construction Program Commercial Grant Program – Funding from federal ARRA grant exhausted – Electric opportunities available through Business Incentive Program Municipal Grant Program – Funding from federal ARRA grant exhausted New Construction – Maine Advanced Building Retro-Commissioning Small Business Audits and Loan Program (?) – Lost revenue stream – Very limited uptake – Focus on DI pathway – Limit to available capital from existing loan repayments 24

25 Residential Program 25

26 Retail Products Program – Recent Results MetricResults of FY11 Programs Total Participants1.9 million CFLs Efficiency Maine Costs$ 4,039,443 Participant Costs$ 6,534,669 Lifetime kWh Savings614,388,191* Lifetime $ Savings$ 46,745,171 B/C Ratio6.0 * Subsequent 3 rd party analysis determined actual savings to be higher than reported in the Annual Report, which explains the higher B/C ratio found in the Evaluation. Factoring in both Lighting and Appliance Program results. Lighting results alone achieved 7.4 B/C.

27 Retail Products Program – Description (1) Opportunity – Lighting >30M sockets state-wide (550k homes * 60 ea) 14M prospective sockets for CFLs per evaluation (2M/yr) EISA regulation reduces savings credit for CFLs LEDs emerging as cost-effective – Electronics Smart Strips, TVs, PCs, monitors – Appliances 33,000 fridges, clothes washer & dehumidifiers promoted in FY-12 Additional opportunities for cost-effective products – but lower B/C than other residential retail products 27

28 Retail Products Program – Description (2) Budget / Revenue – FY-12: $3.8M (SBC, RGGI, MPRP) – FY-13: $4.5M (SBC, RGGI, MPRP) Includes low income-dedicated funding Delivery / Strategy – Retail store MOUs 347 stores participating – Incentive Delivery Upstream discounting In-Store Coupons – In-store marketing Staff saved $500,000/yr in marketing and re-deployed to customer incentives – Alternative Channels (e.g. Good Shepherd Food Bank, other program cross selling) – Evaluation Lessons: 19% of Lighting participants meet definition of Low Income 28

29 Retail Products Program – Issues Delivery / Strategy – Measures Smart strips offer potential savings, but are confusing for consumers Absent Additional Funding Scenario, discontinue Appliance Rebates – B/C is only 1.5 compared to Lighting (7.4) Budget / Revenue – Continue to allocate a portion of the low-income customers 20% SBC set-aside to be run through this program? – TriPlan 2 Budget Proposal: Baseline: $3.8M/Yr. Additional Funding Scenario: $ 7.1M/Yr. 29

30 Refrigerator Recycling Program MetricResults of FY12 Programs Total ParticipantsEstimate 5000 units/yr Efficiency Maine Costs$ 2.0 Million FY12&FY13 Participant Costs$ 0 Lifetime kWh Savings105,640,000 Lifetime $ Savings$ 10,250,000 B/C Ratio3.0 (Projected, TriPlan 1)

31 Refrigerator Recycling Program - Description Opportunity – Retire in-use, inefficient fridges and freezers – Target secondary units that get little use but remain plugged in – Estimated potential = 5,000-10,000 units/year Assuming 500,000 residential units 1-2% harvest rate – Successfully used in other jurisdictions Budget / Revenue – FY-12&13 -- $2M over 2 years, from SBC funding Delivery / Strategy – Turn-key contractor Handles marketing, customer service, screening, pickup, recycling/disposal, payment – Need cost-effective communication channels (Utility bill stuffers, PR) – Cross-sell with other programs 31

32 Refrigerator Recycling Program - Issues Delivery / Strategy – Unknown free ridership or incremental savings – Program design harder to implement in practice than in theory Budget / Revenue – TriPlan 2 Proposed Budgets Baseline Funding: $1.2M/year Additional Funding Scenario: $1.2M/year 32

33 Whole House Retrofit – Recent Results MetricResults of FY11 Programs Total Participants3,200 (Rebate only) Efficiency Maine Costs$8,588,496 Participant Costs$20,368,825 Lifetime MMBtu Savings4,820,173 (35 million gallons) Lifetime $ Savings$101,335,965* B/C Ratio2.56 (per Evaluation) * Subsequent 3 rd party analysis determined actual savings to be lower than reported in the Annual Report, which explains the lower B/C ratio found in the Evaluation.

34 Whole House Retrofit – Description (1) Opportunity – Continue momentum from federally funded rebate and revolving loan programs for whole home energy improvements – Maine oldest building stock in US and significant heating degree days growing population of residents on fixed income, for whom volatile heating costs pose serious financial risk – Universe of opportunity 500,000-550,000 residential units 70% of homes heat with #2 oil, price of #2 oil up 300% or more in past decade making energy saving investments more attractive / cost-effective – Economics of energy upgrades improving HESP Rebate pilot demonstrated opportunity to achieve deep energy savings for modest cost (avg. $8,300/project) Other pilots (Air Sealing, Unity) demonstrating opportunity to achieve significant savings for low cost ($300-$500/project) – Possible reduced energy consumption of 160 million gallons of oil 34

35 Whole House Retrofit – Description (2) Budget / Revenue – FY-12 and 13: $20.4 M Capital Base for loans (federal ARRA) May be split with Large Customer Program – FY-12 and 13: $2M for Residential Direct Install (federal ARRA) 35

36 Whole House Retrofit – Description (3) Delivery / Strategy Carry forward momentum from successful, federally funded rebate program that ended late 2011 Combine education, marketing, and partnership with trade allies (contractors) Expand into related networks (real estate, mortgage, insurance, etc.) PACE and PowerSaver Loans – Sales and marketing strategy through contractor base and municipalities – Single call for loan application for multiple products – Third-party loan origination and loan servicing Residential Direct Install – Market based and driven through contractor base – Capture easy, low-cost savings through Air Sealing or similar measures – Entice customers to take first steps toward whole house upgrade – Generate leads for financing program (for more expensive projects with longer term paybacks) $300 for evidence of 6 hours of air sealing and insulation & home data. $100 for post weatherization project data and full test out. Data collection and analysis 36

37 Whole House Retrofit – Issues Budget / Revenues Original proposal to US DOE: Recapitalize the fund for 8 years, as needed, through revenue bonding using loan repayments/interest to cover bond obligations Consider options to recapitalize by selling notes to Secondary Market TriPlan 2 Budget Proposals: Continue use of Natural Gas Conservation Fund in Unitil territory for Residential Direct Install $137,500/year Consider use of $13M in QECBs (Qualified Energy Conservation Bonds) through a Green Communities Program Uncertainty support for bonding 37

38 Efficient Heating Equipment Program MetricResults of FY11 Programs Total Participants1546 Efficiency Maine Costs$1.2 million Participant Costs$456,000 Lifetime MMBtu Savings179,825 Lifetime $ Savings$2.23 million B/C Ratio1.34

39 Efficient Heating Equipment Program Opportunity – Mechanism for supporting upgrades by homeowners to highest efficiency equipment including condensing boilers and heat pumps Budget / Revenue – Gas and Electric program components could be funded out of SBCs – FY-11: $1.2M – There is no All Fuel or Unregulated Heating Fuel funding currently authorized Delivery / Strategy – Sales and marketing strategy through contractor base – Supported by financing programs – Set equipment standards beyond Energy Star 39

40 Replacement Heating Equipment Program - Issues Delivery / Strategy – Whether to shift to Retail Products (in-store rebate) strategy or continue with direct homeowner/contractor mail-in rebate – Should we limit use of funds from electric or gas conservation fund to paying for electric or gas efficient equipment, respectively? Budget / Revenue – TriPlan 2 Proposed Budget Baseline Budget – $___ for cost-effective electric heat pumps (elec SBC) – $___for cost-effective natural gas systems (gas SBC) Additional Funding Scenario: – $___ for cost-effective electric heat pumps (elec SBC) – $___ for cost-effective natural gas systems (gas SBC) Other – __________ 40

41 Low Income Program – Recent Results (Fridges & CFLs) MetricResults of FY11 Programs Total Participants585 Efficiency Maine Costs$ 325,515 Participant Costs$ 0 Lifetime kWh Savings5,972,672 Lifetime $ Savings$ 465,922 B/C Ratio1.43

42 Low Income Program – Recent Results (Whole House Retrofits) MetricResults of FY12 Programs Total Participants1,000 (est.) Efficiency Maine Costs$ 5 million Participant Costs$ 0 Lifetime kWh SavingsTBD Lifetime $ Savings$ TBD B/C RatioTBD

43 Low Income Program – Description (1) Opportunity – 3,400 LIHEAP, electrically heated homes (per MaineHousing records) – Many more non-LIHEAP (HUD Section 8, USDA Section 515) – Landlords maintain audited demographics Budget / Revenue – FY-11: $2.6M from SBC for Refrigerators and CFLs, only $325,000 spent – FY-12: $5M from SBC for Whole House Retrofit for electrically heated homes – FY-13: $800,000 from SBC for Retail Products (Lighting) $1.9M from SBC and MPRP for Whole House Retrofit for electrically heated homes $1M from federal ARRA grant for alternative heat systems 43

44 Low Income Program – Description (2) Delivery / Strategy – Refrigerator Replacement Program was slowing down dramatically – Single-family electric heat homes Relying on MaineHousing / CAP Agencies for Marketing, Screening, Delivery – Multi-family electric heat apartments Competitive bid to contractors for audit and install Managed by 3 rd -party administrator – Introducing use of efficient heat pumps 44

45 Low Income Program - Issues Delivery / Strategy – Single-family electric heat homes Challenges identifying suitable candidate homes – Many SFH have already switched fuels – Need access to customer contact info – Target fewer, larger loads through individual house treatments (i.e., weatherization) or smaller, more ubiquitous loads through retail channels or low-income service channels (i.e., lighting/electronics)? Budget / Revenue – What fraction of Low Income budget (if any) should go to weatherization versus retail products (lighting, electronics)? – TriPlan 2 Proposed Budget: Baseline: $2.8M Additional Funding Scenario: $2.8M Other – _________ 45

46 Renewable Energy Programs 46

47 Renewable Resource Program – Recent Results MetricFY11 Solar/Wind Rebate FY11 RD&D Program Total Participants37110 Efficiency Maine Costs $ 571,528$ 429,064 Participant Costs$ 4,765,571$ 137,390 Lifetime MMBtu Savings 80,595N/A Lifetime $ Savings$ 1,583,307N/A B/C Ratio0.30 (TRC)N/A

48 Renewable Resource Program - Description Opportunity – Movement of renewable industry to mainstream through new professional standards and requirement for cost-effective renewable energy installations Delivery / Strategy – Website information and forms – Delivery through installers with NABCEP certificates of knowledge & insurance – Recent rule change requires cost-effectiveness to end user and projected kWh output to calculate rebate amount – 2.5 cents per modeled lifetime kWh output, caps at $2000/resid; $4000/business Budget / Revenue – $100,000 from Alternative Compliance Payments and Voluntary Contributions – $728,000 remaining from Original Solar/Wind SBC for use in new rebate structure, will be exhausted in FY13 48

49 Renewable Resource Fund - Issues Delivery / Strategy – N/A Budget / Revenue – New revenue stream needed in order to continue rebate program – TriPlan 2 Proposed Budget Baseline: $100,000 Additional Funding Scenario: $ _____ Other – _____ 49

50 Cross-Cutting Programs 50

51 Innovation Program - Description Recent Activity – Funded 2 proposals – one piloting supplemental mini-split heat pumps, the other piloting heat pump water heaters; Results due June 2013 – Previously funded apartment CHP system and 2 pilots for Smart Meter customer dashboard applications Opportunity – Pilot programs for initiatives that show cost-effective energy savings that are good candidates for addition to sustained EMT programs – Ability to test new ways of delivering savings – Targeted pilots intended to be nimble and timely Delivery / Strategy – Competitive RFP – Ability to fine-tune RFP solicitation to address opportunities – Focus on proposals where EMT foresees future revenue stream and scalable opportunity Budget / Revenue – FY-12: $400,000 from SBC and RGGI 51

52 Innovation Program - Issues Delivery / Strategy – Should Staff continue to prioritize close nexus to emerging program needs in the RFP design/criteria? Budget/Revenues – TriPlan 2 Proposed Budgets Baseline: $300,000/Yr Additional Funding Scenario: $___ 52

53 Energy Education and Information - Description Recent Results – Save Like a Mainer Campaign FY-12 & 13 Fostering appreciation of energy efficiency based on successful case studies from real customers in Maine Combining websites, radio ads, print ads, trade show display, Chamber events, social media messaging, speaking engagements with networks, earned media, etc. – Schools for Energy Efficiency Delivered by non-profit organization 2 participating school districts; 15 schools Enlisting and organizing volunteer facility managers, teachers and students to set energy saving targets, develop and implement a plan, and monitor and report on the progress – Community Energy Nights Delivered by a non-profit organization Targeting 8 towns where schools have been active in energy efficiency curriculum Audience includes students and parents 53

54 Energy Education and Information - Description Opportunity – Enhance awareness through education and outreach to increase likelihood of program participation – Take advantage of new information and communication channels related to Smart Meters Consider differences between Commercial and Residential sector opportunities – Take advantage of newfound access to utility data about customer usage, geographic location – Foster information exchange in Maine among opinion leaders about issues related to energy efficiency, alternative energy, and customer-sited renewable energy Budget / Revenue – FY-12: $400,000 – Funds come from SBC & FCM Delivery / Strategy – Competitive RFPs, targeted to enhance program participation – Focus on proposals with demonstrable energy savings and/or a link to increased program participation – Enhanced EM Website 54

55 Energy Education and Information - Issues Delivery / Strategy – Should we move away from programs targeted at educating primary and secondary school students about the origins and types of energy? – Should we focus programs on providing information, education, training on the supply chain (retailers, contractors, suppliers, A&Es, etc.)? – Should we focus on programs that have a nexus to helping achieving the results/metrics of the Triennial Plans other program areas? – Should this program focus on providing information / learning that will apply to mid- and longer-term EE opportunities and leave short-term opportunities ? – What new or different strategies should be pursued under an Additional Revenue Scenario strategy? Budget/Revenue – TriPlan 2 Budget Proposal Baseline: $300,000/Yr Additional Revenue Scenario: $______/Yr Other: – _______ 55

56 Evaluation – Description and Issues Recent Results – Completed 6 independent, 3 rd party impact evaluations, including Home Energy Savings Program Business Incentive Program Commercial Grant Program Large Impact Program – Interim results reported from Residential Lighting Program evaluation – PACE Program evaluation underway Opportunity – Incorporate program design improvements and savings calculations per evaluation recommendations – Analyze project data and utility data to enhance strategies Budgets / Revenues – TriPlan 1 Budgets: $900,000/yr – TriPlan 2 Proposed Budgets Baseline: $800,000/yr Additional Funding Scenario: Proportionate to program increase 56

57 Please Share Your Ideas: Send Written Comments to: Email – Post –Triennial Plan Comments 151 Capitol Street, Suite 1 Augusta, ME 04330 Workshops start July 10 Latest that comments will be considered is August 15

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