ISOs. For clarity, CLECA supports continued reliance on weather normalization to set total RA requirements, but distinguishes this use from coincidence adjustments. In summary, CLECA argues that the process for allocating RA requirements should be aligned with cost-causation, use clear and available data, and only be adjusted in limited, known ways. recommends that: 1) Energy Division and the CEC should post load data within seven days of receiving the data from the CAISO and clearly identify the data source, 2) Energy Division should clarify how it shares results of coincidence adjustments with LSEs, 3) Energy Division should use the most recent year of load data, 4) CEC should use non-weather-normalized peak load data for coincidence adjustments, and 5) Energy Division should provide RA obligations to LSEs no later than June 1. DACC summarizes the steps that Energy Division and CEC have taken since D.15-06-063 to provide more information about the load forecast process, concludes that these steps are insufficient and that towards increased “progress transparency and consistency continues to lag.” DACC notes that little workshop discussion addressed changing from to approach “historic” “forecast” or methods in other jurisdictions, as we suggested in D.15-06-063. The continuing concerns that DACC expresses are 1) using more years of data may dampen peaks and may not reflect changing grid conditions, 2) variation in the number of peaks used among LSEs may not lead to standardized or fair treatment of different LSEs, and 3) weather normalization should be applied for forecasts, but not for historical peaks for coincidence adjustments. DACC contends that other ISOs handle these issues differently. DACC concludes that
ISOs. For clarity, CLECA supports continued reliance on weather normalization to set total RA requirements, but distinguishes this use from coincidence adjustments. In summary, CLECA argues that the process for allocating RA requirements should be aligned with cost-causation, use clear and available data, and only be adjusted in limited, known ways. recommends that: 1) Energy Division and the CEC should post load data within seven days of receiving the data from the CAISO and clearly identify the data source, 2) Energy Division should clarify how it shares results of coincidence adjustments with LSEs, 3) Energy Division should use the most recent year of load data, 4) CEC should use non-weather-normalized peak load data for coincidence adjustments, and 5) Energy Division should provide RA obligations to LSEs no later than June 1. DACC summarizes the steps that Energy Division and CEC have taken since D.15-06-063 to provide more information about the load forecast process, concludes that these steps are insufficient and that “progress towards increased transparency and consistency continues to lag.” DACC notes that little workshop discussion addressed changing from “historic” to “forecast” approach or methods in other jurisdictions, as we suggested in D.15-06-063. The continuing concerns that DACC expresses are 1) using more years of data may dampen peaks and may not reflect changing grid conditions, 2) variation in the number of peaks used among LSEs may not lead to standardized or fair treatment of different LSEs, and 3) weather normalization should be applied for forecasts, but not for historical peaks for coincidence adjustments. DACC contends that other ISOs handle these issues differently. DACC concludes that
164214092.docx