4.2.5. Benefits that are Currently Difficult to Quantify

The following types of demand response benefits are difficult to quantify. Because of the difficulty quantifying these benefits, the Commission is not requiring that an LSE include values for these benefits in their cost-effectiveness calculations according to the 2010 Protocols at this time, with the exception of avoided GHG emissions costs, which will be calculated by the Avoided Cost Calculator. However, we require the LSEs to submit qualitative descriptions of the following benefits, when relevant for a particular demand response program:

· Environmental benefits

· Market and reliability benefits

· Non-energy and non-monetary benefits

Parties are strongly encouraged to provide relevant information about any of the optional inputs, and to comment on the estimates and qualitative discussions provided by the LSEs.