7. Measurement and Evaluation

BOMA recommends that PG&E be required to address price elasticities in its rate design proposals to understand the likely short-term and long-term price responses for different rate types.¹²⁹

In D.08-04-050, the Commission adopted protocols and regulatory guidance to estimate the load impact of demand response. The decision requires the three major IOUs to conduct annual studies of their demand response activities.¹³⁰ PG&E should conduct annual studies of TOU/CPP, RTP, and PTR during years each of those rates is in effect.

PG&E should use its load impact studies to estimate the likely responses of customers to dynamic pricing rates, as desired by BOMA.

Additionally, PG&E should conduct an ex post review of when CPP events were called and the degree to which the calls aligned with days when a combustion turbine did or would have operated based on price and reliability considerations. This analysis could help PG&E and the Commission improve CPP rate design and the triggering of CPP events so that CPP is consistent with actual system conditions. PG&E should present the results of this analysis in its GRC Phase 2's and any other proceeding in which CPP rate design proposals are being considered.

¹²⁹ BOMA Comments, February 28, 2008, pp. 5-6.

¹³⁰ D.08-04-050, OP 4.