PG&E’s proposal, CLECA notes that CAISO will not move its resource adequacy availability assessment hours from 1:00 p.m.- 6:00 p.m. to 4:00 p.m. – 9:00 p.m. until 2019. PG&E does not deny CAISO’s plans, but adds that its loss of load expectations heat map analysis is already showing greatest value from 6:00 p.m. to 9:00 p.m. The Joint Demand Response Parties requests that the Commission require PG&E to return its Capacity Bidding Program hours to their current hours, arguing that PG&E has not substantiated why the program hours need to be modified. The Joint Demand Response Parties adds that PG&E is anticipating changes in resource adequacy Availability Assessment Hours that have not been adopted by the Commission in the resource adequacy proceeding and are not consistent with CAISO tariffs. The Joint Demand Response Parties do not consider the heat map analysis cited by PG&E equivalent to an analysis conducted by the Commission or CAISO. The Joint Demand Response Parties point out to the importance of consistent rules across the Utilities and consistency of Capacity Bidding Program operating hours and resource adequacy availability assessment hours. The Joint Demand Response Parties adds that third-party providers rely on Commission and CAISO rules as written. According to the Joint Demand Response Parties, allowing Utilities to modify those rules before adoption lead to market uncertainty and customer confusion. PG&E explains that PG&E’s loss of load expectations analysis is already showing a need for the proposed hours. PG&E’s analysis is clearly not equivalent to a Commission decision; however, we cannot simply ignore PG&E’s conclusions. Therefore, we see value in PG&E’s effort to be proactive and proposal to adjust the operating hours based on the grid needs. However, we also want to allow time for current program participants to adjust to these new
PG&E’s proposal, CLECA notes that CAISO will not move its resource adequacy availability assessment hours from 1:00 p.m.- 6:00 p.m. to 4:00 p.m. – 9:00 p.m. until 2019. PG&E does not deny CAISO’s plans, but adds that its loss of load expectations heat map analysis is already showing greatest value from 6:00 p.m. to 9:00 p.m. The Joint Demand Response Parties requests that the Commission require PG&E to return its Capacity Bidding Program hours to their current hours, arguing that PG&E has not substantiated why the program hours need to be modified. The Joint Demand Response Parties adds that PG&E is anticipating changes in resource adequacy Availability Assessment Hours that have not been adopted by the Commission in the resource adequacy proceeding and are not consistent with CAISO tariffs. The Joint Demand Response Parties do not consider the heat map analysis cited by PG&E equivalent to an analysis conducted by the Commission or CAISO. The Joint Demand Response Parties point out to the importance of consistent rules across the Utilities and consistency of Capacity Bidding Program operating hours and resource adequacy availability assessment hours. The Joint Demand Response Parties adds that third-party providers rely on Commission and CAISO rules as written. According to the Joint Demand Response Parties, allowing Utilities to modify those rules before adoption lead to market uncertainty and customer confusion. PG&E explains that PG&E’s loss of load expectations analysis is already showing a need for the proposed hours. PG&E’s analysis is clearly not equivalent to a Commission decision; however, we cannot simply ignore PG&E’s conclusions. Therefore, we see value in PG&E’s effort to be proactive and proposal to adjust the operating hours based on the grid needs. However, we also want to allow time for current program participants to adjust to these new
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