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Before the Public Utilities Commission of the State of California

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Before the Public Utilities Commission of the State of California BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of Southern California Edison Company (U338-E) for Approval of Demand Application 08-06-001 Response Programs, Goals, and Budgets for (filed June 2, 2008) 2009-2011 Application of San Diego Gas & Electric Company (U 902M) for Approval of Demand Application 08-06-002 Response Programs, Goals, and Budgets for (Filed June 2, 2008) 2009-2011 Application of Pacific Gas and Electric Company for Approval of the Demand Application 08-06-003 Response Programs, Goals, and Budgets for (Filed June 2, 2008) 2009-2011 (U 39-E) RESPONSE OF THE CALIFORNIA INDEPENDENT SYSTEM OPERATOR TO MOTON OF PACIFIC GAS AND ELECTRIC COMPANY, SOUTHERN CALIFORNIA EDISON COMPANY, AND SAN DIEGO GAS & ELECTRIC COMPANY FOR FUNDING AND AUTHORIZATON TO OPERATE DEMAND RESPONSE PROGRAMS AND PILOTS IN 2009 Dated: September 29, 2008 CALIFORNIA INDEPENDENT SYSTEM OPERATOR CORPORATION Baldassaro “Bill” Di Capo, Esq., Counsel CALIFORNIA INDEPENDENT SYSTEM OPERATOR CORPORATION 151 Blue Ravine Road Folsom, CA 95630 Tel. (916) 608-7157 Fax (916) 608-7222 E-mail [email protected] A.08-06-001; A.08-06-002; A.08-06-003 CAISO RESPONSE TO JOINT MOTION OF THE UTILITIES FOR FUNDNG AND AUTHORIZATON TO OPERATE DR PGRGRAMS AND PILOTS IN 2009 Pursuant to Rule 2.6 (c) of the Commission’s Rules of Practice and Procedure and ALJ Hecht’s August 27, 2008 Ruling Extending Deadline for Response to Motion1, the California Independent System Operator Corporation (“CAISO”) submits this Response to the Motion of Pacific Gas and Electric Company (“PG&E”), Southern California Edison Company (“SCE”); San Diego Gas & Electric Company (“SDG&E”). (The CAISO hereinafter alternatively refers to the moving parties collectively as the “Utilities” and the motion as the “Joint Motion.”) In the Joint Motion, the Utilities anticipate the possibility that Commission approval of their DR Applications for the 2009-2011 Program cycle may not occur before the end of the 2008 calendar year. They seek authorization and funding for certain activities during the pendency of those Applications. The Utilities use the term “Bridge Period” to reference any period of time after January 1, 2009 during which final approval of Utilities’ respective applications the 2009-2011-Program-cycle is still pending (see Joint Motion at pp. 1-2 and p.6); the propose that the Bridge Period be extend on a month-to-month basis, as necessary (Joint Motion at p. 6.) I. THE CAISO SUPPORTS FUNDING TO RUN THE PILOT PROGRAMS IN 2009 AND TO MAKE THOSE PREPATIONS NECESSARY TO READY THE UTLITIES TO RUN THEIR SUITE OF PROGRAMS IN BALANCE OF THE PROGRAM CYCLE (2010 AND 2011) In our Response to the Utilities’ Amended Applications, which we file today, concurrently with this Response, the CAISO voices its appreciation for the support of the Commission and the Utilities to design and implement Participating Load Pilot Projects (PL Pilots) under the initial release of MRTU. The CAISO believes that the PL Pilots will be a good investment in the future development and promotion of DR in California. The CAISO expects that much will be learned through the pilot experience and 1. The August 27th Ruling amended the schedule to respond to the Joint Motion, setting September 26, 2008 as the date for parties to file Responses. 1 A.08-06-001; A.08-06-002; A.08-06-003 CAISO RESPONSE TO JOINT MOTION OF THE UTILITIES FOR FUNDNG AND AUTHORIZATON TO OPERATE DR PGRGRAMS AND PILOTS IN 2009 anticipates that the PL Pilots will provide important input and guidance with regard to the way DR programs are designed and implemented in the future. As such, the CAISO encourages the Commission to timely resolve any funding impediments to the PL Pilots and hopes that a suitable resolution, or a bridge funding mechanism, will be approved, so that work may begin on the PL Pilots as soon as November 2008, in anticipation of a June 2009 implementation date. The CAISO agrees with the Utilities that planning for a possible Bridge Period, and therefore, Bridge Funding, is both prudent and essential should the Commission’s final decision on the 2009-2011 DR program applications be delayed into next year. In addition, if a delay is certain, the CAISO agrees that limiting program operations to clean-up of 2006-2008 demand response activities would be short-sighted and would hinder the Utilities’ ability to begin the necessary planning and implementation efforts needed to prepare DR programs and pilots for summer 2009 and beyond. II. ACCORDINGLY, THE CAISO IS SUPPORTIVE OF THE UTLITY REQUEST FOR INTERIM FUNDNG TO RUN THE PILOT PROGRAMS IN 2009 The CAISO supports the Utility requests for Commission authorization for the Utilities to do the following, during the Bridge Period: Undertake 2009-2011 program planning activities during the Bridge Period to minimize the impact of a delay (Joint Motion Request #2); Fund the 2009 MRTU-related pilots and PG&E’s small load aggregation pilot and, importantly, allowing the Utilities to begin work on these projects as early as November 2008 (Joint Motion Request #3). 2 A.08-06-001; A.08-06-002; A.08-06-003 CAISO RESPONSE TO JOINT MOTION OF THE UTILITIES FOR FUNDNG AND AUTHORIZATON TO OPERATE DR PGRGRAMS AND PILOTS IN 2009 Conduct Evaluation, Measurement and Verification (EM&V) related to 2009-2011 planning and activities (Joint Motion Request #4) Count the demand savings achieved during the Bridge Period toward 2009 DR goals adopted by the Commission (Request #7). The Utilities’ other requested items, Nos. 1, 5 and 6 pertain to questions of cost approvals and allocations; which are matters pertaining to state policy and rates; the CAISO does not have an opinion as to these requests. III. THE COMMISSION SHOULD ALLOW THE UTILITIES FLEXIBILITY, AS LESSIONS ARE LEARNED FROM THE PILOT PROGRAMS RUN IN 2009, TO MODIFY OR FASHION NEW DR PROGRAMS FOR LAUNCH IN THE BALANCE OF THE PROGRAM CYCLE As we have argued in our Response to the Amended Applications of the Utilities, The Commission should support and allow the utilities to make adjustments to new DR programs, or to apply for new programs, via Advice letters. As the CAISO adds functionality and enhancements for DR resources under MRTU MAP, program changes may well be necessary and, therefore, accordingly, the Commission consider accommodating the utilities’ need for flexibility, so that the may make appropriate and cost-effective program adjustments. 3 A.08-06-001; A.08-06-002; A.08-06-003 CAISO RESPONSE TO JOINT MOTION OF THE UTILITIES FOR FUNDNG AND AUTHORIZATON TO OPERATE DR PGRGRAMS AND PILOTS IN 2009 Dated: September 29, 2008 Respectfully submitted, CALIFORNIA INDEPENDENT SYSTEM OPERATOR CORPORATION By: /s/ Baldassaro “Bill” Di Capo Baldassaro “Bill” Di Capo, Esq., Counsel CALIFORNIA INDEPENDENT SYSTEM OPERATOR CORPORATION 151 Blue Ravine Road Folsom, CA 95630 Tel. (916) 608-7157 Fax (916) 608-7222 E-mail [email protected] 4 CERTIFICATE OF SERVICE I hereby certify that on October 2, 2008. I served, on the Service List for Consolidated Proceedings A08-06-001, A08-06-002, A08-06-003 and R.07-01-041 by electronic mail, a copy of the foregoing RESPONSE OF THE CALIFORNIA INDEPENDENT SYSTEM OPERATOR TO MOTON OF PACIFIC GAS AND ELECTRIC COMPANY, SOUTHERN CALIFORNIA EDISON COMPANY, AND SAN DIEGO GAS & ELECTRIC COMPANY FOR FUNDING AND AUTHORIZATON TO OPERATE DEMAND RESPONSE PROGRAMS AND PILOTS IN 2009 Executed on October 2nd at Folsom, /s/Anna Pascuzzo// California Anna Pascuzzo, An employee of the California Independent System Operator A.08-06-001, A.08-06-002, A.08-06-003 – Service List CAISO RESPONSE TO JOINT MOTION OF THE UTILITIES FOR FUNDNG AND AUTHORIZATON TO OPERATE DR PROGRAMS AND PILOTS IN 2009 DOUGLAS A. AMES BALDASSARO DI CAPO BENJAMIN SCHUMAN TRANSPHASE COMPANY CALIFORNIA INDEPENDENT SYSTEM PACIFIC CREST SECURITIES 4971 LOS PATOS AVE. OPERATOR 111 SW 5TH AVE, 42ND FLR HUNTINGTON BEACH, CA 92649 151 BLUE RAVINE ROAD PORTLAND, OR 97204 [email protected] FOLSOM, CA 95630 [email protected] [email protected] DARA BILTEKOFF CASE ADMINISTRATION CALIFORNIA ENERGY MARKETS ENERGY CURTAILMENT SPECIALISTS 2244 WALNUT GROVE AVENUE 425 DIVISADERO ST. SUITE 303 4455 GENESEE STREET ROSEMEAD, CA 91770 SAN FRANCISCO, CA 94117 BUFFALO, NY 14225 [email protected] [email protected] [email protected] David Peck Dorris Lam DANIEL W. DOUGLASS CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION DOUGLASS & LIDDELL 505 VAN NESS AVENUE 505 VAN NESS AVENUE 21700 OXNARD STREET, SUITE 1030 ROOM 4103 AREA 4-A WOODLAND HILLS, CA 91367-8102 SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 [email protected] [email protected] [email protected] EDWARD W. O'NEILL ELIZABETH EISENHAUER EDWARD G. POOLE DAVIS, WRIGHT, TREMAINE, LLP ENERGY CURTAILMENT SPECIALISTS ANDERSON & POOLE 505 MONTGOMERY STREET, SUITE 800 4455 GENESEE STREET 601 CALIFORNIA STREET, SUITE 1300 SAN FRANCISCO, CA 94111-6533 BUFFALO, NY 14225 SAN FRANCISCO, CA 94108 [email protected] [email protected] [email protected] ERIC WOYCHIK GLEN SMITH Hazlyn Fortune COMVERGE, INC. ENERGY CURTAILMENT SPECIALISTS CALIF PUBLIC UTILITIES COMMISSION 9901 CALODEN LANE, STE 1 4455 GENESEE STREET 505 VAN NESS AVENUE OAKLAND, CA 94605 BUFFALO, NY 14225 ROOM 5303 [email protected] [email protected] SAN FRANCISCO, CA 94102-3214 [email protected] HELEN ARRICK JANET COMBS Jennifer Caron BUSINESS ENERGY COALITION SOUTHERN CALIFORNIA EDISON CALIF PUBLIC UTILITIES COMMISSION 77 BEALE STREET, RM 1848E 2244 WALNUT GROVE AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94105 ROSEMEAD, CA 91770 AREA 4-A [email protected] [email protected] SAN FRANCISCO, CA 94102-3214 [email protected] JACK ELLIS JENNIFER SHIGEKAWA Jessica T.
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