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Request for Conditional Exemption to 2013 RA Window Requirement for Peak Day Pricing. CPUC Resource Adequacy Workshop. Thursday, January 26, 2012. Background.
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Request for Conditional Exemption to 2013 RA Window Requirement for Peak Day Pricing CPUC Resource Adequacy Workshop Thursday, January 26, 2012
Background • D.11-06-022 granted an exception to the RA window (1-6pm) for 2012 and ordered PG&E’s PDP program to comply with the RA window (1-6pm) in 2013. • D.11-06-022 also acknowledged that changing the current PDP hours (2-6 pm) in the tariff requires CPUC approval and ordered PG&E to propose the change in PG&E’s 2012 Rate Design Window (RDW). • D.10-02-032 ordered PG&E to make its 2012 RDW filing in February 2012. PG&E will timely file and include the request to change the PDP hours. • Based upon past experience with the RDW, PG&E is concerned that a final decision may not be issued in timely fashion for the 2013 PDP season. Portfolio Modification
Request for Conditional Exemption • PG&E requests a conditional exemption to the RA window for PDP for 2013. • If PG&E receives a decision in the 2012 RDW in time to implement for the 2013 season, PG&E will waive the exemption (assuming the decision affirms the change in hours). • If the RDW decision does not adopt the hours change or is not timely, the exemption would apply and PG&E would receive full RA credit for the PDP program for 2013 only (as is the case for 2012). • If the hours change is not adopted, PG&E would place the issue in scope for consideration in Phase II of this proceeding. Portfolio Modification
Justification for Request • When initiated, the CPP/PDP program complied with RA window requirement. However, the CPUC updated the RA Window, thereby requiring a change to the PDP hours to maintain conformance. • PG&E is following CPUC directive and seeking to change the hours as ordered. • PG&E is following the CPUC’s prescribed procedural path for conforming to the hours change. • It would be fundamentally unfair to PG&E’s customers to impose additional procurement costs upon them because the regulatory process prescribed by the CPUC does not allow for the program hours to be changed in a timely fashion. • The conditional request is reasonable in that it allows the new hours to be adopted if a decision approving the change is issued in a timely fashion. Portfolio Modification
Request for Conditional Exemption to 2013 Local Dispatchability Requirement CPUC Resource Adequacy Workshop Thursday, January 26, 2012
Background • PG&E’s demand response programs are locally dispatchable with the exception of Capacity Bidding Program (CBP), Demand Bidding Program (DBP) and the Aggregator Managed Portfolio (AMP). • In its 2012-2014 DR Funding Application, PG&E requested the changes necessary to have all DR (except dynamic rates) locally dispatchable in 2013. • The CPUC decision on PG&E’s 2012-2014 DR Funding Application was due in 2011 but has been delayed by the CPUC, through no fault of PG&E. Portfolio Modification
Request & Justification for Conditional Exemption • In D.11-10-003 (p. 8), the CPUC provided an exemption “[i]f Commission proceedings addressing demand response program designs and funding issues have not concluded with sufficient time to modify the program in question prior to the 2013 RA compliance year.” • PG&E requests that compliance with the local dispatchability requirement in D.11-10-003 for CBP, AMP and DBP in 2013 be conditionally waived if a decision on the 2012-2014 DR application is delayed to the extent the changes needed to implement local dispatchability cannot be reasonably accomplished in time for the 2013 RA year. Portfolio Modification