4. Opposition to PG&E's PDP Proposal

A number of parties support the concept of PDP but have recommended various modifications to PG&E's rate, default implementation, and cost recovery proposals, which are addressed in this decision.

EUF/CMTA states that although it supports the development of a portfolio of Demand Response (DR) programs that accesses all cost-effective DR and enables all customers to respond meaningfully, they do not support implementation of PG&E's PDP tariff as presented. According to EUF/CMTA, PG&E's PDP tariff will inhibit or reduce response from some customers, will cause structural cost shifting, fails to address equity considerations and, as proposed, provides no net societal benefit.

After fully considering input and comments from a variety of parties in the dynamic pricing phase of PG&E's last GRC rate design proceeding, A.06-03-005, the Commission, in D.08-07-045, ordered PG&E to propose various default CPP rates. PG&E has complied with that order by filing its PDP proposal that is the subject of this proceeding. While we recognize that there are uncertainties and potential problems associated with the PDP program being adopted today, we are convinced that the program should go forward, in furtherance of our long-term policy to provide dynamic pricing to all customers. We note the EUF/CMTA concerns, along with those of the other parties, and emphasize that the intent of our decision today is to implement a PDP program that fairly balances the risks and costs to various affected customers and customer classes while remaining generally consistent with the guidelines provided in D.08-07-045. As further discussed, we have found it necessary to modify certain elements of PG&E's proposed PDP program and the related cost recovery request.