year for the first violation. Two or more Type II violations will result in removal for three years. The Utilities were ordered by Resolution E-4838 to file supplemental compliance advice letters by May 26, 2017. The Commission’s Executive Director granted the Utilities’ request for an extension for those supplemental filings until June 15, 2017. The above-referenced advice letter was filed on June 15, 2017. In the advice letter, the Utilities included the following: proposed modifications to affected tariffs, aggregator agreements and associated forms, effective January 1, 2018 including the explanation of the policy, the attestation form, how the DAV affects incentive calculations, consequences of non-compliance, along with initial verification requirements and dispute resolution processes that would be amended according to language included in the Final Plan. The Utilities also proposed that, if the Commission approved the tariff language, that it authorize a Tier 1 Advice Letter process to insert the language into applicable tariffs. This proposal and the tariff language were collectively filed as Tier 2 Advice Letters (AL) 3542-E-A (SCE), AL 4991-E-B (PG&E), and AL 3031-E-A (SDG&E) on June 15, 2017 with modified tariff language. (Collectively, these advice letters are “AL 3542-E-A et al.”) D.16-09-056 directed the joint Utilities to develop an audit verification mechanism by retaining a consultant to “assess whether it is possible, and if so by what methods and data sources, to evaluate whether non-residential customers are complying with the demand response prohibition requirement.” The Utilities were directed to serve the consultant report to the service list of R.13-09-011 no later than April 1, 2017; to host a workshop for the consultant to explain its report; and to file a Tier 3 Advice Letter requesting approval of a final audit verification plan (Plan) which incorporates feedback from the workshop.
year for the first violation. Two or more Type II violations will result in removal for three years. The Utilities were ordered by Resolution E-4838 to file supplemental compliance advice letters by May 26, 2017. The Commission’s Executive Director granted the Utilities’ request for an extension for those supplemental filings until June 15, 2017. The above-referenced advice letter was filed on June 15, 2017. In the advice letter, the Utilities included the following: proposed modifications to affected tariffs, aggregator agreements and associated forms, effective January 1, 2018 including the explanation of the policy, the attestation form, how the DAV affects incentive calculations, consequences of non-compliance, along with initial verification requirements and dispute resolution processes that would be amended according to language included in the Final Plan. The Utilities also proposed that, if the Commission approved the tariff language, that it authorize a Tier 1 Advice Letter process to insert the language into applicable tariffs. This proposal and the tariff language were collectively filed as Tier 2 Advice Letters (AL) 3542-E-A (SCE), AL 4991-E-B (PG&E), and AL 3031-E-A (SDG&E) on June 15, 2017 with modified tariff language. (Collectively, these advice letters are “AL 3542-E-A et al.”) D.16-09-056 directed the joint Utilities to develop an audit verification mechanism by retaining a consultant to “assess whether it is possible, and if so by what methods and data sources, to evaluate whether non-residential customers are complying with the demand response prohibition requirement.” The Utilities were directed to serve the consultant report to the service list of R.13-09-011 no later than April 1, 2017; to host a workshop for the consultant to explain its report; and to file a Tier 3 Advice Letter requesting approval of a final audit verification plan (Plan) which incorporates feedback from the workshop.
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