Rule 24 Requirements 1 for UDC and LSE Under Limited Scope

1. Rule 24 Requirements1for UDC and LSEUnder Limited Scope October 9, 2014 Steve De Backer 1 Other than RQMD

2. Rule 24 Requirements1 for UDC and LSE Under Limited Scope • Isolating utility staff that provide services to third-party DRPs • Establish and maintain third parties as DRPs • CISR-DRP and Related Tasks • Modifying PG&E systems to produce and track non-interval data necessary for Rule 24 • Transferring non-interval data on a periodic basis to DRPs • Reviewing PDR registrations • Preventing customers from dually enrolling in utility demand response programs and with a third-party DRP. • Verify wholesale settlements 1 Other than RQMD

3. Rule 24 Requirements1 for UDC and LSE Under Limited Scope Isolating Utility Staff • Requires an isolated work group. • This work group will have access to all of PG&E’s DR processes and access to the CAISO’s DRS under the roles of UDC and LSE. • PG&E’s DR department cannot have access to any information direct or indirectly that is related to an unaffiliated DRP.

4. Rule 24 Requirements for UDC and LSE Under Limited Scope Establish and maintain third parties as DRPs • Probably the easiest of the processes • Better to focus on higher impact issues

5. Rule 24 Requirements for UDC and LSE Under Limited Scope CISR-DRP and Related Tasks • The new CISR-DRP form has 82 valid combinations. • Each valid combination requires different setup and handling throughout the duration of the customer’s authorization. • Processes need to be setup to provide this data to a DRP and to provide updates to the data when it changes information. • Required data elements: • Customer Service Agreement information: name, mailing address, service address, electric rate schedule, etc. • Basic meter information including the meter number, the type of meter, and the intervals currently being collected by the meter. • Customer’s Monthly Meter Read Cycle. • The identity and contact information of the customer’s LSE, MDMA, and Meter Service Provider. • A Unique Customer Identifier (UCI) • A maximum of the most recent 12 months of customer billing data or the amount of data recorded for that specific service agreement. • Confidential end-user information such as the customer’s service voltage, the Sub Load Aggregation Point (S-LAP), Pricing Node (P-Node). • If the customer is currently enrolled or in the process of becoming enrolled in any event-based utility DR program(s). If yes, then PG&E must provide (1) the earliest date that the customer can opt out of the program without a financial impact to the customer; and (2) the earliest date that the customer can opt out of the program regardless of financial impact to the customer.

6. Rule 24 Requirements for UDC and LSE Under Limited Scope Reviewing PDR registrations PG&E must review each of the following items: • PG&E is the UDC for each of the customers. • The UCI is correct for each customer in the registration. • Each of the customers’ service agreement are still active. • A CISR-DRP exists and is still active between the DRP and each customer in the registration. • The LSE for each of the customer’s is the LSE shown for the registration. • The customer name and service address closely match the values in PG&E’s systems. • The S-LAP is correct for each of the customers. • The P-Node, if entered, is correct for each of the customers. • The Default Load Aggregation Point is correct for the UDC. • Review each customer for participation in a PG&E retail DR program. • When the registration contains bundled customers, that there is an LSE DRP agreement with the DRP.

7. Rule 24 Requirements for UDC and LSE Under Limited Scope Preventing dual enrollments Rule 24 activities causing a check for enrolled or pending DR participants: • When receiving a CISR-DRP, PG&E will indicate to DRP if customer is enrolled or is in the process of becoming enrolled in a PG&E DR program. • When reviewing registration for a third-party DRP, PG&E will indicate in its comments to CAISO whether customer is enrolled or is in the process of becoming enrolled in a PG&E DR program. PG&E assumes that CAISO will reject customer registration if they are participating in program. DR program activities causing a check for active or pending registrations: • As part of the DR program enrollment process PG&E will check if the customer is in an active registration or pending third-party registration. The three processes above should prevent a customer from being active in a DR program and a third-party DRP registration at the same time. However, PG&E will periodically run a report to determine if there is an overlap between an active or pending third-party PDR registration and an active or pending DR participant.

8. Rule 24 Requirements for UDC and LSE Under Limited Scope Verify wholesale settlements • PG&E as the LSE validates the CAISO’s wholesale settlement calculations for each resource that receives a market award. • PG&E performs this activity whether or not it is the DRP for the resource.

9. Rule 24 Requirements for UDC and LSE Under Limited Scope Possible Simplifications • Do not provide the P-Node • Treat PDP participants the same as other DR program participants • Do not provide the earliest opt-out without financial impact. • Do not change out meters to obtain a shorter metering interval.