standardization in budget categories across the utilities) Ex. 37 (TURN Rebuttal/Goodson), pp. 4 (addressing the need for standardization in budget reporting, and the importance of historical costs, in assessing the reasonableness of proposed budgets) TURN Opening Brief, pp. 68-70 Verified CARE The Role of AMI Data D.16-11-022, Section 4.4, – pp. 315-316 (LBNL study) TURN demonstrated that the PD and APD erred in authorizing the utilities to issue TURN Comments on PD, two RFPs to generate end-use profiles of p. 6; TURN Comments on CARE customers and segregate the APD, pp. 14-15 (LBNL population into groups based on load study) profiles. TURN recommended that the D.16-11-022, Compare utilities first take advantage of the report Section 4.4 PD, with recently issued by LBNL, which was Section 4.4, and APD, funded by ratepayers and commissioned in Section 4.4. (DRAM R.13-09-011, in which LBNL used bidder directives dropped); customer-level data to segment all customers into clusters based on load TURN Comments on PD, profiles, end-uses, and their ability to shift pp. 6-7; TURN Comments load, with CARE and non-CARE on APD, p. 15 (data customers separately clustered. TURN sharing with DRAM suggested that this public dataset first be bidders) used to meet the goals, to Commission’s APD Rev. 4 See also the extent possible. In D.16-11-022, the (Redline), Section 4.4, Commission rejected the approach showing the changes originally proposed in the PD and APD and regarding the LBNL study found that LBNL developed “the and data sharing with segmented profiles are ripe for the IOUs to DRAM bidders use and The Commission directed act on.” the utilities to use the LBNL dataset in conducting marketing, outreach, and enrollment in ESA, Demand Response, and other energy efficiency programs. TURN also cautioned against the directive in the PD and APD that the utilities share the vendor-developed load profiles with potential DRAM bidders in accordance
standardization in budget categories across the utilities) Ex. 37 (TURN Rebuttal/Goodson), pp. (addressing the need for standardization in budget reporting, and the importance of historical costs, in assessing the reasonableness of proposed budgets) TURN Opening Brief, pp. 68-70 CARE – The Role of AMI Data TURN demonstrated that the PD and APD erred in authorizing the utilities to issue two RFPs to generate end-use profiles of CARE customers and segregate the population into groups based on load profiles. TURN recommended that the utilities first take advantage of the report recently issued by LBNL, which was funded by ratepayers and commissioned in R.13-09-011, in which LBNL used customer-level data to segment all customers into clusters based on load profiles, end-uses, and their ability to shift load, with CARE and non-CARE customers separately clustered. TURN suggested that this public dataset first be used to meet the Commission’s goals, to the extent possible. In D.16-11-022, the Commission rejected the approach originally proposed in the PD and APD and found that “the LBNL developed segmented profiles are ripe for the IOUs to use and act on.” The Commission directed the utilities to use the LBNL dataset in conducting marketing, outreach, and enrollment in ESA, Demand Response, and other energy efficiency programs. TURN also cautioned against the directive in the PD and APD that the utilities share the vendor-developed load profiles with potential DRAM bidders in accordance D.16-11-022, Section 4.4, pp. 315-316 (LBNL study) TURN Comments on PD, p. 6; TURN Comments on APD, pp. 14-15 (LBNL study) Compare D.16-11-022, Section 4.4 with PD, Section 4.4, and APD, Section 4.4. (DRAM bidder directives dropped); TURN Comments on PD, pp. 6-7; TURN Comments on APD, p. 15 (data sharing with DRAM bidders) See also APD Rev. 4 (Redline), Section 4.4, showing the changes regarding the LBNL study and data sharing with DRAM bidders Verified 4