For example, it is not necessary to have default pilot to determine if TOU rates would impose a hardship on certain customer groups. SB 1090 requires evidence to be gathered that assumes no change in usage. Therefore, the SB 1090 findings can be developed by applying proposed TOU rates to existing usage data. None of the parties advocating a default TOU pilot prior to default TOU have explained how information gathered from the pilot could provide information that is more informative on the SB 1090 findings than analysis of existing usage data. The utilities already have the data necessary to evaluate how customer bills would have differed if they had been on TOU instead of tiered rates. In contrast, an attempt to use a default TOU pilot to obtain this data would be skewed by customers who change their usage pattern as a result of knowing they are on a TOU rate. Thus the best data to use is the data that already exists. After careful review, we find that only a few of the recommended study topics would require a default TOU pilot. These topics can and should be studied on an ongoing basis once default TOU is implemented. We expect that the design of TOU rates will need to be monitored and updated on an ongoing basis, and these studies will assist with that process. Notably, systems operability, customer retention rates and load shift will be best studied once default TOU rates are in place. The 2018 default TOU pilot will provide an opportunity to begin studying these areas in advance of full rollout. However, because we agree there are benefits to default TOU pilots, we require each IOU to include a default TOU rate in its design of pilots approved by this decision. The purpose of this default TOU pilot will be primarily to study aspects of TOU that are directly impacted by the self-selection bias, and to
For example, it is not necessary to have default pilot to determine if TOU rates would impose a hardship on certain customer groups. SB 1090 requires evidence to be gathered that assumes no change in usage. Therefore, the SB 1090 findings can be developed by applying proposed TOU rates to existing usage data. None of the parties advocating a default TOU pilot prior to default TOU have explained how information gathered from the pilot could provide information that is more informative on the SB 1090 findings than analysis of existing usage data. The utilities already have the data necessary to evaluate how customer bills would have differed if they had been on TOU instead of tiered rates. In contrast, an attempt to use a default TOU pilot to obtain this data would be skewed by customers who change their usage pattern as a result of knowing they are on a TOU rate. Thus the best data to use is the data that already exists. After careful review, we find that only a few of the recommended study topics would require a default TOU pilot. These topics can and should be studied on an ongoing basis once default TOU is implemented. We expect that the design of TOU rates will need to be monitored and updated on an ongoing basis, and these studies will assist with that process. Notably, systems operability, customer retention rates and load shift will be best studied once default TOU rates are in place. The 2018 default TOU pilot will provide an opportunity to begin studying these areas in advance of full rollout. However, because we agree there are benefits to default TOU pilots, we require each IOU to include a default TOU rate in its design of pilots approved by this decision. The purpose of this default TOU pilot will be primarily to study aspects of TOU that are directly impacted by the self-selection bias, and to