PG&E’s reply is that some CDA information is required for PG&E to implement the ECR program, such as a customer’s subscription level and their CDA effective dates. PG&E grants that CDA pricing information should remain confidential, however they assert that the language as currently set out in the CSIAL is sufficient and does not require clarification. While the Decision makes no specific determination on this protested issue, we agree with SEIA and PG&E that pricing information in the CDA should remain confidential between the ECR customer and developer. The IOUs are therefore ordered to supplement their CSIALs and JPIAL to clarify that the pricing component of a CDA will not be included in the CDA information required by the IOU. ECR rate design and incentives to develop ECR projects In its protest of the PG&E and SCE CSIALs, SEIA claims that the rate designs suggested for ECR in the CSIALs will fail to encourage ECR development. unstated, we infer from SEIA’s protest that this failure to encourage ECR development is contrary to SB 43’s requirement that the IOUs support” “provide for ECR development. SEIA’s argument is that the rate design for ECR is flawed because it makes term economic decision-making for the potential ECR customer difficult. Without some certainty as to costs and credits, and subscription terms, SEIA argues that customers will not be able to predict the financial impact of an ECR subscription and will therefore be disinclined to sign up for ECR. SEIA offers several empirical examples of how the ECR rate design as proposed by PG&E and SCE will purportedly be unable to support ECR development in their territories. The upshot of these examples is that ECR developers would be to offer a customer premium as low as 2.5 cents/kWh and keep a “hard-pressed” project financially viable for a developer which, when combined with presumed
PG&E’s reply is that some CDA information is required for PG&E to implement the ECR program, such as a customer’s subscription level and their CDA effective dates. PG&E grants that CDA pricing information should remain confidential, however they assert that the language as currently set out in the CSIAL is sufficient and does not require clarification. While the Decision makes no specific determination on this protested issue, we agree with SEIA and PG&E that pricing information in the CDA should remain confidential between the ECR customer and developer. The IOUs are therefore ordered to supplement their CSIALs and JPIAL to clarify that the pricing component of a CDA will not be included in the CDA information required by the IOU. ECR rate design and incentives to develop ECR projects In its protest of the PG&E and SCE CSIALs, SEIA claims that the rate designs suggested for ECR in the CSIALs will fail to encourage ECR development. unstated, we infer from SEIA’s protest that this failure to encourage ECR development is contrary to SB 43’s requirement that the IOUs “provide support” for ECR development. SEIA’s argument is that the rate design for ECR is flawed because it makes economic decision-making for the potential ECR customer difficult. Without some certainty as to costs and credits, and subscription terms, SEIA argues that customers will not be able to predict the financial impact of an ECR subscription and will therefore be disinclined to sign up for ECR. SEIA offers several empirical examples of how the ECR rate design as proposed by PG&E and SCE will purportedly be unable to support ECR development in their territories. The upshot of these examples is that ECR developers would be “hard-pressed” to offer a customer premium as low as 2.5 cents/kWh and keep a project financially viable for a developer which, when combined with presumed term