the 24 daily profiles proposed by GPI in this proceeding, provide all of the information that is needed for the differentiation of energy prices. [GPI Comments, 6/27/16, pg. 3.] The GPI is pleased that virtually all of the Opening Comments filed on June 27 endorse basing the time-differentiation of energy prices on the marginal generation-cost curves (MGC) of the IOUs. Any of the net demand curves labeled L3 L5 in Table 1 in the – Scoping Memo could act as a surrogate basis to use for producing TOU curves, but there is no question that MGC curves would be more accurate. [GPI Reply Comments, 7/19/16, pg. 1.] 2. Structuring of TOU Decision Verified Periods GPI believes that there is no purely The value of energy is a analytical method that can be used to function of time-of-day and determine appropriate TOU time season. The GPI advocated for periods, but that the determination of increasing the granularity of appropriate TOU periods is as much an TOU profiling, especially for art as it is a science. The art is to larger customers and for balance considerations of simplicity and generators, and we proposed an practicality with considerations of hourly profiling method for accuracy. [D.17-01-006, pg. 25.] TOU and TOD differentiation. GPI believes that the biggest challenge Our proposal both contributed to consumers in dealing with TOU rates to the deliberations leading to will be the need to adjust their the Decision, and it contributed equipment settings when there is a to the structure of the data change of season, and that therefore, request that Commission Staff minimizing the number of seasonal sent to the IOUs for changes during the year should be a data. major goal of TOU design. Although the proposal pg. 25.] GPI’s was not adopted in whole, it TOU proposal is based upon GPI’s contributed to and enriched the setting two hourly energy profiles record on which the Decision offered each month, one that is based, and thus the GPI corresponds to weekdays and the other made a substantial contribution that corresponds to weekends. Each of to the Decision. these 24 profiles would contain hourly
the 24 daily profiles proposed by GPI in this proceeding, provide all of the information that is needed for the of energy prices. [GPI Comments, 6/27/16, pg. 3.] The GPI is pleased that virtually all of the Opening Comments filed on June 27 endorse basing the time-differentiation of energy prices on the marginal generation-cost curves (MGC) of the IOUs. Any of the net demand curves labeled L3 – L5 in Table 1 in the Scoping Memo could act as a surrogate basis to use for producing TOU curves, but there is no question that MGC curves would be more accurate. [GPI Reply Comments, 7/19/16, pg. 1.] 2. Structuring of TOU Periods The value of energy is a function of time-of-day and season. The GPI advocated for increasing the granularity of TOU profiling, especially for larger customers and for generators, and we proposed an hourly profiling method for TOU and TOD differentiation. Our proposal both contributed to the deliberations leading to the Decision, and it contributed to the structure of the data request that Commission Staff sent to the IOUs for data. Although the GPI’s proposal was not adopted in whole, it contributed to and enriched the record on which the Decision is based, and thus the GPI made a substantial contribution to the Decision. Decision GPI believes that there is no purely analytical method that can be used to determine appropriate TOU time periods, but that the determination of appropriate TOU periods is as much an art as it is a science. The art is to balance considerations of simplicity and practicality with considerations of accuracy. [D.17-01-006, pg. 25.] GPI believes that the biggest challenge to consumers in dealing with TOU rates will be the need to adjust their equipment settings when there is a change of season, and that therefore, minimizing the number of seasonal changes during the year should be a major goal of TOU design. pg. 25.] GPI’s TOU proposal is based upon setting two hourly energy profiles offered each month, one that corresponds to weekdays and the other that corresponds to weekends. Each of these 24 profiles would contain hourly Verified differentiation