37. Cost-effectiveness Evaluation

EPUC recommends that once credible data is available to assess the impact of the PDP program on generation capacity procurement, the program be evaluated. EPUC asserts that the program should be continued only if PG&E can demonstrate that the program results in measureable cost-effective reductions in generation procurement cost that conclusively justify the continuation of the program as the default rates for PG&E's customers. EUF/CMTA also expressed a concern with respect to the difficulty in determining the cost-effectiveness of PDP.

In response, PG&E points out that it is already under orders to assess the load impacts and financial benefits of its active and anticipated DR programs including D.08-04-050, D.09-03-026, D.08-07-045, D.08-02-009, and D.06-07-027. PG&E notes that in D.09-03-026, Ordering Paragraph 10, the Commission directed PG&E to report annually the financial benefits of DR programs enabled by its AMI system, and, in D.08-04-050, PG&E was directed to assess the load impacts of each DR resource on an ex post and ex ante basis, annually. PG&E asserts, given the existing analyses and reporting requirements, there is no need for additional reporting requirements.

We agree there is no demonstrated need for additional cost-effectiveness reporting requirements at this time. There should be sufficient information available for parties to analyze and make recommendations, with respect to the PDP program, in future appropriate proceedings.