Rank 4: Programs included in this rank will have a TRC B/C ratio extremely low, i.e., less than 0.5. Some of these programs also have a very poor record of providing actual load reduction close to their contractual commitments. These programs are generally not self sustaining and do not justify continued ratepayer support.⁴³

DRA ranks PG&E's Business Energy Coalition programs as Rank 4, the statewide Base Interruptible Program as Rank 3, and all other programs as Rank 2. DRA recommends:

Ranks 1 and 2: Approve programs for 2009-2011 but require utilities to seek additional approval, as appropriate, through advice letter filing updates to reflect resolution of any major uncertainties.

Rank 3: Approve for 2009, but require new applications for 2010 showing a need for the programs.

Rank 4: Do not approve.⁴⁴

8.8. CAISO

CAISO focused its attention within this proceeding primarily on the demand response pilots proposed in the utilities' applications. CAISO supports the efforts of the utilities to conduct pilots to test the ability of demand response activities to function under the new CAISO markets. In addition, CAISO cautions against counting benefits for avoided transmission and distribution investments in the cost effectiveness analyses of current programs; CAISO argues that these benefits should not be counted until or unless the utilities are able to show how the utilities use demand response savings in their planning to avoid building new transmission and distribution.⁴⁵

8.9. Energy Curtailment Specialists

Energy Curtailment Specialists participated on the limited issues of appropriate baseline methodologies for demand response programs and timely approval of aggregator contracts. Energy Curtailment Specialists advocates for the adoption of a 5-in-10 day baseline methodology with an optional day-of adjustment.⁴⁶ Energy Curtailment specialists also initially advocated for the approval of its contract with SCE.

8.10. CPower

CPower (formerly ConsumerPowerline) is concerned about the possibility that later contracts between a utility and a third-party aggregator would undermine aggregators' earlier contracts by offering more attractive or beneficial terms. In order to address this, CPower suggests that the Commission allow the amendment of existing contracts to match the terms of new contracts.⁴⁷

8.11. Ice Energy

Ice Energy advocates for the expansion of Permanent Load Shifting, as a portion of the utilities' demand response activities.

⁴³ Exhibit 314, pp. 13-14.

⁴⁴ Exhibit 314, p. 15.

⁴⁵ CAISO Opening Brief, p. 10.

⁴⁶ Energy Curtailment Specialists Reply Brief, p. 3.

⁴⁷ CPower Opening Brief, p. 2.