4. Discussion

The Load Impact Protocols set forth in Attachment A of D.08-04-050 established the format of the tables in which the utilities must report estimates of the hour by hour ex post and ex ante load impacts of each demand response programs.

Depending on the number of demand response programs on which the utility must report, the preparation of all tables required by the load impact protocols may require more than one hundred thousand tables. Since these reports are too large to be filed electronically, they must be filed in hard copy, which, under the Commission's usual practices, means printing all of these (thousands of) tables. In order for the content of each table to remain legible, each table fills a full printed page. The Commission understands that it is both impractical and potentially wasteful of paper and other resources to print thousands of pages of tables, especially when there are other options for storage of this data, such as web posting and CD-ROMs. However, it is important to retain at least some summary data within the formal record of this demand response proceeding, both to facilitate other activities within this docket, such as development of cost effectiveness protocols, and to ensure that this important information remains available for public reference in this or successor proceedings.

In order to ensure that there is basic load impact data available within the record of this or a successor proceeding without imposing unnecessary or burdensome requirements, we modify OP 4 of D.08-04-050 to require filing of an executive summary of the load impact report along with several summary tables. We retain the requirement that the utilities prepare the entire load impact report as previously ordered, which contains all information and tables required in Protocol 26, and transmit the complete reports to the Commission's Energy Division via CD-ROM or other electronic storage medium. The utilities will also serve the complete report, or a notice of its availability, in an electronic format, to the most recent service list of this or a successor proceeding.

This approach will allow interested parties access to the detailed information required in the load impact protocols without overburdening either the utilities or the Commission's Docket Office with the preparation or storage of large volumes of printed material. Instead of filing thousands of hourly load impact tables with the Docket Office, utilities will file summary information, including a Summary Table that contains aggregate average ex ante load impacts for each Monthly System Peak Load Day. These tables will provide a reasonable estimate of demand response impacts on electric load. The executive summary and summary table requirements are described in the new Appendix 1 to
D.08-04-050.