6. Departures from and Modifications to the Protocols

The 2010 Protocols require that any changes or modifications to the protocols or use of confidential data be approved in writing by staff in the Commission's Energy Division.

In addition, the 2010 Protocols suggest several areas of research that would be required to more accurately estimate values for a number of demand response costs and benefits, particularly the so-called "difficult-to-quantify" benefits. The Commission may, in a future proceeding, establish a procedure for carrying out this research, and invites parties in their comments on the utilities' future cost-effectiveness analyses to make proposals for carrying out this needed research. One such area that has been identified as needing additional study is in the use of backup generators during demand response events. While future proceedings will address this issue, at this time the Commission strongly encourages the utilities to develop methods to collect data from demand response participants about ownership and usage of backup generators during demand response events.