29. Incremental Load Impact Study Costs

PG&E forecasts $1.321 million (excluding contingencies) in incremental measurement and evaluation (M&E) spending to estimate annual load impacts for default PDP rates, to update enrollment forecasting models (also called discrete choice models) so they are consistent with the final decision in this case, and to complete the studies described in Ordering Paragraphs 11 and 12 of D.08-07-045.

The funding for M&E for PG&E's existing demand response programs is covered primarily in D.09-08-027 on PG&E's 2009-2011 demand response application, with the exception of PG&E's existing small and medium C&I and residential DR programs, SmartAC and SmartRate, for which load impact evaluation costs are covered by amounts approved in D.08-02-009 and D.06-07-027, respectively. PG&E indicates that it did not include additional costs for default PDP or new dynamic pricing rates in its 2009-2011 demand response application because ALJ Hecht had directed that the utilities "should not make proposals in their [2009-2011 DR] Applications that duplicate proposals that are under consideration in [A.06-03-005] or other proceedings."³⁶ Therefore, PG&E has included the incremental costs for updating its discrete choice models and its evaluation of load impact for default PDP in this proceeding.

No party opposes PG&E's incremental M&E activities or the associated cost estimate. They are reasonable and the cost estimate will be adopted and included in determining the revenue requirement for this proceeding.

³⁶ PG&E cites Administrative Law Judge Ruling Providing Guidance on Content and Format of 2009-2011 Demand Response Activity Applications, R.07-01-041, February 27, 2008 at 15.