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Request for Conditional Exemption to 2013 RA Window Requirement for Peak Day Pricing

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

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  1. Request for Conditional Exemption to 2013 RA Window Requirement for Peak Day Pricing CPUC Resource Adequacy Workshop Thursday, January 26, 2012

  2. 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

  3. 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

  4. 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

  5. Request for Conditional Exemption to 2013 Local Dispatchability Requirement CPUC Resource Adequacy Workshop Thursday, January 26, 2012

  6. 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

  7. 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

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