: Protests to Utility Proposals for Length of Authorization Olivine, OhmConnect and the Joint Protesting Parties protested this issue. Olivine commends PG&E and SCE for supporting indefinite authorization timelines. Olivine is opposed SDG&E’s position and notes that Rule 24/32 does not limit “indefinite” to a period of three years. OhmConnect also supports PG&E and SCE’s approach and opposes SDG&E’s approach. OhmConnect clarifies that all components of the OAuth Solution 3 should be pre-populated, not only the length of authorization. The Joint Protesting Parties believe the length of authorization must include the indefinite option because requesting that a customer renew annually or every three years would be onerous, especially compared to Utility programs where customers remain enrolled automatically. Discussion The current CISR-DRP Request form allows the customer to enter the start and end date for the authorization timeframe that the Utility will release data to the third-party demand response provider. SDG&E provided no explanation for why choosing an indefinite timeframe might not “best serve the customer.” SDG&E’s approach of allowing “indefinite” authorization timeframe, but only up to three years was not explained and is inconsistent with the plain meaning of ‘indefinite.’ We find that the customer, not SDG&E is in the best position to determine whether the length of authorization offered by the Demand Response Provider best suits their needs.
: Protests to Utility Proposals for Length of Authorization Olivine, OhmConnect and the Joint Protesting Parties protested this issue. Olivine commends PG&E and SCE for supporting indefinite authorization timelines. Olivine is opposed SDG&E’s position and notes that Rule 24/32 does not limit “indefinite” to a period of three years. OhmConnect also supports PG&E and SCE’s approach and opposes SDG&E’s approach. OhmConnect clarifies that all components of the OAuth Solution 3 should be pre-populated, not only the length of authorization. The Joint Protesting Parties believe the length of authorization must include the indefinite option because requesting that a customer renew annually or every three years would be onerous, especially compared to Utility programs where customers remain enrolled automatically. Discussion The current CISR-DRP Request form allows the customer to enter the start and end date for the authorization timeframe that the Utility will release data to the third-party demand response provider. SDG&E provided no explanation for why choosing an indefinite timeframe might not “best serve the customer.” SDG&E’s approach of allowing “indefinite” authorization timeframe, but only up to three years was not explained and is inconsistent with the plain meaning of ‘indefinite.’ We find that the customer, not SDG&E is in the best position to determine whether the length of authorization offered by the Demand Response Provider best suits their needs.
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