5. Shifting of Funds to Support Proxy Demand Resource

In A.08-06-001, SCE requested various funds to develop a Demand Response Portal and enhance the SCE billing system to support demand response activities. In this petition, SCE requests authority to redirect $2,535,000 authorized to support Demand Response Portal activities, along with $1,000,000 approved for billing system enhancements, towards system improvements needed to support participation in Proxy Demand Resource activities in general, and particularly SCE's Capacity Bidding Program and demand response contracts. SCE states that redirecting this funding will allow modifications of its computer systems, including its customer service system, to track information needed for Proxy Demand Resource participation and improve integration with CAISO Proxy Demand Resource systems. SCE also asserts that, even if these funds are redirected as requested, system modifications required to fully support Proxy Demand Resource may require additional funding through SCE's 2012-2014 program and budget applications proceeding.

As discussed in Section 3 above, the final rules for the CAISO Proxy Demand Resource tariff were not available at the time SCE submitted its revised version of A.08-06-001 in September 2008, and understanding of the operational requirements for Proxy Demand Resource have changed greatly since the adoption of D.09-08-027. D.09-08-027 emphasizes the importance of participation in Proxy Demand Resource, and it is reasonable to provide funding for system changes that will facilitate such participation. SCE states that changes in understanding of Proxy Demand Resource rules have led to a change in the focus of the Demand Response Portal project from creation of a new information access system to an emphasis on integrating SCE systems with CAISO systems to facilitate information-sharing. Specifically, SCE states that some of the functionality originally envisioned for the Demand Response Portal has been incorporated into other SCE computer systems, and the initial efforts of the mapping of customer locations by local areas within the customer service system have narrowed to focus on participants in Proxy Demand Resource-compatible activities such as Capacity Bidding Program and demand response contracts.

Given the information now available on Proxy Demand Resource rules and requirements, it is reasonable to redirect funding formerly allocated for the Demand Response Portal and customer mapping activities to Proxy Demand Resource systems integration. Because of this, we approve the SCE request to modify D.09-08-027 to redirect a total of $3,535,000 to Proxy Demand Resource-related system development activities.