8. Improving Load Shape Data

All parties agree that improvements are needed to energy efficiency load/impact shape data in time for the next program cycle. As part of the workshop process, participants developed an action plan for this purpose that was modeled to a large extent after this 2006 Update process. We have reviewed the workshop proposal and post-workshop suggestions for refinements. Drawing from this input, we adopt an action plan today that, in our view, will enable us to address this high priority issue in a practical and timely manner.

Specifically, we direct the utilities to contract with appropriate expertise to develop a Load Shape Update Initiative in our energy efficiency rulemaking, R.06-04-010. The utilities should notify Energy Division of their intended contractor(s). The selected contractor(s) are expected to exchange information with the assigned ALJ and Energy Division in developing the work products for this initiative. The Load Shape Update Initiative should include public workshops with technical experts to help scope the effort as well as review the draft report described below. Energy Division may schedule and lead these workshops, or delegate this function to the contractor(s).

The primary purpose of the Load Shape Update Initiative is to assist with the following:

(1) Identifying near- and long-term improvement objectives for the updating process, including how best to incorporate recently completed studies and studies underway into the E3 calculator;

(2) Developing criteria for prioritizing end-uses/measures for load shape improvements, and

(3) Establishing priorities for load shape improvements by end uses/measures and a schedule for completing those improvements.

To this end, the Load Shape Update Initiative should provide Energy Division and interested parties with a better understanding of the following:

(4) What load shapes/blocks exist in the E3 calculators, CEC and utility load forecasts and the data source quality;

(5) The magnitude of the problem(s) with existing load shape data, utility vs. statewide; and

(6) The costs and benefits associated with potential improvements to existing load shape data.

The contractor(s) will be tasked with developing a draft report addressing the issues identified above, as well as others that emerge from the scoping workshop(s), as appropriate. The contractor(s) shall submit a draft report no later than October 1, 2006 that includes preliminary recommendations on issues (1)-(3) above. Energy Division (or the contractor(s)) will hold public workshops on the draft report as soon as practicable thereafter, so that the contractor(s) can respond to feedback and questions. Based on the workshop feedback, the contractor(s) will develop a final report by November 15, 2006 that, among other things, summarizes the areas of consensus and non-consensus among workshop participants by issue area and presents final recommendations. Energy Division, the assigned ALJ or Assigned Commissioner in R.06-04-010 may also solicit post-workshop written comments on the final report from interested parties, as they deem appropriate.

All reports, notices of availability, notices of workshops or other filings related to the Load Shape Update Initiative should be distributed to the service list in the energy efficiency rulemaking, R.06-04-010, consistent with the electronic service rules established for that proceeding.⁵³

We will not take formal action on this matter by issuing a decision or ruling on specific improvements needed to load shape data, the scope of work for studies to improve the data, the associated budget level or schedule for these efforts. These determinations should be made by Energy Division, per our discussion in D.05-01-055 of EM&V responsibilities in 2006 and beyond:

"Energy Division will be responsible for: (1) allocating Commission authorized funding for program and portfolio impacts-related EM&V among the individual studies, (2) developing the work scope for each study consistent with our adopted EM&V protocols, (3) writing RFPs and selecting the contractors, and (4) managing and contracting for the work."⁵⁴

Accordingly, the information and recommendations obtained through the Load Shape Updating Initiative is designed to assist Energy Division as it proceeds to develop the study scopes, specific work tasks, schedules and budgets for load shape improvements as part of its ongoing EM&V responsibilities. We reiterate our expectation that, consistent with the working relationships we have already established with the CEC in our energy efficiency proceedings, "we anticipate that the CEC staff can be called upon to provide Energy Division with technical input and, if needed, staffing support for these functions."⁵⁵

The results of these efforts to improve load shapes should be considered in the DEER updating process as well, as TURN suggests in its comments. However, we do not specify how the load shape studies should be managed (e.g., as part of the DEER updating process or through separate EM&V contracts, etc. ) or at what level they should be funded out of authorized EM&V budgets, as some parties suggest. These determinations should be made by Energy Division as part of the division's ongoing EM&V responsibilities, as described above.

Nor do we specify today how final determinations will be made on what types of data generated by the load shape studies (or other EM&V studies) represent an improvement to existing values in DEER, and therefore should replace those values. Joint Staff is currently developing EM&V process protocols that will address this as well as other process issues related to updating DEER values (e.g., the process for obtaining input from interested parties and technical experts, and schedule for making revisions). Those protocols are subject to review and adoption under the procedures we established for EM&V protocols in D.05-04-051.⁵⁶

We do specify today, however, that funding for the Load Shape Update Initiative and resulting load shape update studies to be conducted during 2006-2008 will come out of authorized EM&V funding for the 2006-2008 program cycle. Energy Division should determine the specific budget category (or categories) for funding these efforts, in consultation with the program administrators.

It is clear from the record in this proceeding that improvements in energy efficiency load shape data are needed in time to plan for the 2009-2011 energy efficiency program cycle. This planning process will be well underway six months before the utilities file their June 1, 2008 applications for their 2009-2011 portfolio plans. Therefore, it appears that the highest priority load shape improvements identified through the Load Shape Updating Initiative will need to be completed and incorporated into the E3 calculator by the end of December, 2007. As soon as practicable after the final report is submitted, Energy Division should update the EM&V roadmap in consultation with the assigned ALJ in R.06-04-010 to reflect this schedule.

⁵³ The electronic service rules are contained in Appendix A of Ordering Instituting Rulemaking to Excamine the Commission's post-2005 Energy Efficiency Policies, Programs, Evaluation, Measurement and Verification, and Related Issues, R.06-04-010, issued on April 13, 2006.

⁵⁴ D.05-01-055, mimeo., p. 108.

⁵⁵ Id.

⁵⁶ See D.05-04-051, pp. 67-73.