FINDINGS

1. In Advice Letter 2018-E, filed on July 20, 2000, PG&E requested modifications to its VPRC.

2. Program participants in PG&E's VPRC program are currently paid the day-ahead market clearing price of the PX less the participant's otherwise applicable tariff rate. In this advice letter PG&E is proposing that program participants be paid the full PX market clearing price without any adjustments. PG&E's proposed modification to the payment calculations have already been found by the Commission to be anti-competitive and should be denied.

3. PG&E proposes to revise the market clearing price threshold for bids so that it would be equal to one half the price cap on the CAISO Real Time Market with a minimum of $100/MWh and a maximum of $250/MWh. PG&E's proposal will allow E-BID customers greater flexibility to participate in the program and assist in lowering California's energy demands, and should be approved.

4. PG&E's proposal to reduce the E-BID enrolment fee from $600 to $100 could increase participation in the program and should be approved.

5. PG&E's proposal to install interval meters free to new program participants could increase participation in the program and should be approved. ORA recommendation that PG&E's shareholders pay for these meters is denied.

6. ORA's recommendation that meters be chosen and installed competitively and paid for by PG&E should be denied.

7. PG&E's proposal to give program participants the option of electing whether or not to be subject to interval metered hourly pricing after the rate freeze conflicts with D.00-06-034 and should be denied.

8. PG&E's proposal to reduce the minimum curtailment requirement from 20 percent of baseline to 10 percent is not adequately supported and should be denied.

9. PG&E's proposal to increase the total number of customers that may participate in the program from 500 to 1000 and the number of smaller customers from 50 to 300 is not adequately supported and should be denied.

10. PG&E's proposal to rescind the limit on the maximum total load reduction for any one curtailment (500 MW) that was established in Resolution E-3650 is not adequately supported and should be denied.

11. The changes proposed by ORA should be denied.