The Revised Proposal (February 20, 2014) makes a number of changes in response to parties’ comments, most of which are improvements. The GPI believes that the Revised Staff Proposal provides a workable basis for a PEL methodology, as statutorily required for the RPS program. [GPI Comments on the Revised Proposals for a PEL, 3/19/14, pg. 1.] The revised CalWEA proposal has one great advantage over the other proposals. It is the only proposal that attempts to deal directly with the statutory directive to make a determination as to whether a utility’s PEL Budget causes a disproportionate rate impact for its ratepayers. [GPI Comments on the Revised Proposals for a PEL, 3/19/14, pg. 6.] 2. RPS Data Confidentiality Decision Verified The Commission issued a The May 22, 2015, Scoping Memo and preliminary staff proposal on Ruling of AC for R.1502020 make it clarifying RPS confidentiality clear that revising confidentiality rules is rules on July 1, 2013. Parties, a key issue in the continuing including the GPI, filed development of the RPS program (see comments and replies in Scoping Memo, pg. 6) August 2013. Pleadings R.1105005 was closed without While some data legitimately deserve resolving the various issues confidential treatment, in our opinion that had been addressed in the confidential treatment is sought, and staff proposal, and the matter under the current rules granted, for far was continued in the scoping more categories of data than what is memo for R.1502020. The necessary to provide reasonable GPI advocated strongly for protection for the efficient conduct of keeping as much information commercial enterprise. One prerequisite in the public domain as for an efficient market economy is possible, and we opposed informed market participants. The efforts by the IOUs to expand excessive withholding of information as confidentiality protections confidential is counterproductive to the beyond where they legitimately development of efficient markets when need to be. It quickly became it impinges on information flow. We clear that the parties were far fully support the Commission’s efforts apart, and that the value of
The Revised Proposal (February 20, 2014) makes a number of changes in response to parties’ comments, most of which are improvements. The GPI believes that the Revised Staff Proposal provides a workable basis for a PEL methodology, as statutorily required for the RPS program. [GPI Comments on the Revised Proposals for a PEL, 3/19/14, pg. 1.] The revised CalWEA proposal has one great advantage over the other proposals. It is the only proposal that attempts to deal directly with the statutory directive to make a determination as to whether a utility’s PEL Budget causes a disproportionate rate impact for its ratepayers. [GPI Comments on the Revised Proposals for a PEL, 3/19/14, pg. 6.] 2. RPS Data Confidentiality The Commission issued a preliminary staff proposal on clarifying RPS confidentiality rules on July 1, 2013. Parties, including the GPI, filed comments and replies in August 2013. R.1105005 was closed without resolving the various issues that had been addressed in the staff proposal, and the matter was continued in the scoping memo for R.1502020. The GPI advocated strongly for keeping as much information in the public domain as possible, and we opposed efforts by the IOUs to expand confidentiality protections beyond where they legitimately need to be. It quickly became clear that the parties were far apart, and that the value of Decision The May 22, 2015, Scoping Memo and Ruling of AC for R.1502020 make it clear that revising confidentiality rules is a key issue in the continuing development of the RPS program (see Scoping Memo, pg. 6) Pleadings While some data legitimately deserve confidential treatment, in our opinion confidential treatment is sought, and under the current rules granted, for far more categories of data than what is necessary to provide reasonable protection for the efficient conduct of commercial enterprise. One prerequisite for an efficient market economy is informed market participants. The excessive withholding of information as confidential is counterproductive to the development of efficient markets when it impinges on information flow. We fully support the Commission’s efforts Verified