FINDINGS

By Advice Letter 2019-E, PG&E requests authorization to file new electric tariff schedule OBMC-Optional Binding Mandatory Curtailment Plan in compliance with D. 91548 and D. 82-06-021.

PG&E's proposal is in compliance with D. 91548, as modified by D. 82-06-021 and D. 82-09-028 and should be approved.

ORA filed a protest, in part, objecting to the OBMC policy adopted in D. 91548, that part of the protest should be denied.

ORA's recommendation that OBMC participants should be assessed a charge for this service should be denied.

ORA's recommendation that customers who require additional metering be allowed to choose both the interval meter and the installation company should be denied.

ORA's recommendation that PG&E's proposed penalties for non-compliance be doubled should be adopted

SVMG's request that the required level of curtailment be lowered from 20 percent to 10 percent should be denied.

BART filed a protest on July 25, 2000. Its request for additional information was responded to by PG&E on August 2, 2000, and BART augmented its protest on August 9, 2000. BART's concern that the OBMC program will affect its status in rotating outages is not supported and should be denied.

D.91548 did not exempt BART from rotating outages.

PG&E's proposed tariff sheets include ambiguous language that should be revised before the sheets become effective.

Public necessity requires that the 30-day comment period be reduced in order to secure the benefits of the OBMC program during the summer peak season. We have balanced the public interest in avoiding the possible harm to public welfare from delay in considering the Resolution against the public interest in having the full 30-day period for review and comment, as required by Rule 77.7(f)(9), and concluded that the former outweighs the latter. We conclude that the 30-day review and comment period should be reduced to 15 days.