3. Petition for Modification
The Petition requests the removal of the requirement that the utilities file their annual demand response load impact reports in R.07-01-041, instead requesting permission for the utilities to submit their reports to the Commission's Energy Division and serve them on parties, as the current requirement provides for the utilities to do after the closure of R.07-01-041 and any successor proceedings.
PG&E, SCE, and SDG&E all experienced technical difficulties in filing their 2009 load impact reports with the Commission's Docket Office. The load impact protocols require PG&E to produce over 165,000 ex post and ex ante load impact tables as part of their annual report. The electronic files containing the 2009 load impact reports, including all tables, took approximately 1,400 megabytes of memory. This file size exceeds the limits set for electronic filing with the Commission's Docket Office. In addition, the Microsoft Excel "pivot tables" used to produce the load impact report tables cannot convert to PDF-A compliant format, as required by the Docket Office for all electronic filings.
Due to these incompatibilities with the electronic filing requirements, PG&E instead attempted to file its 2009 Load Impact Report in hard copy with the Docket Office. In order to ensure that all documents filed in hard copy may be archived appropriately and remain available for reference in future years, the Commission's Docket Office requires that when a filing is made in hard copy, the complete document, including all tables, attachments, and appendices, be provided on paper, and not on an electronic storage medium such as a CD or DVD. PG&E estimates that, in order to fulfill this requirement, the process of printing all tables for its report would require 4,000 printer hours (equivalent to approximately 166 days) with labor costs of up to $75 per hour. In order to avoid these difficulties and costs for filing the 2009 load impact reports, the utilities requested and received permission to file a limited number of tables in hard copy, with the remainder of the tables provided for filing on CD-ROM.
Based on its experience with the 2009 load impact reports, PG&E claims that the reports along with the tables "cannot meet the Docket Office's requirement for e-filing, are too voluminous to file in hard-copy, and would be extremely time-consuming and expensive to print."1 PG&E believes that submitting future load impact reports to the Energy Division in electronic format, and serving them on interested parties pursuant to the Commission's Rules of Practice and Procedure, regardless of whether the Rulemaking or a successor proceeding is open, would serve the same purpose as filing them with the Docket Office. For these reasons, PG&E requests modification of OP 4 in
D.08-04-050 as follows:
"4. SCE, SDG&E, and PG&E shall perform annual studies of their DR activities using the adopted protocols, and shall submit these reports consistent with Protocol 26 on April 1 of each year to the Commission's Energy Division and serve them on the most recent service list for this, or a successor proceeding. The information contained in those reports may be used in other Commission proceedings, as appropriate."2
1 Petition of PG&E to Modify D.08-04-050, OP 4 to Direct Submission of Annual Load Impact Reports to Energy Division and to Eliminate the Requirement to File in
R.07-01-041, April 6, 2009 at 5.
2 Petition of Pacific Gas and Electric Company to Modify D.08-04-050, OP 4 to Direct Submission of Annual Load Impact Reports to Energy Division and to Eliminate the Requirement to File in R.07-01-041, April 6, 2009 at 6.
