As discussed in Section 4.7 above, the Joint Parties agreed that PG&E will add a price response trigger as part of its demand response program with the CAISO market. We agree that the price response trigger is in compliance with Commission policy on demand response, in particular with D.10-06-034. We are concerned, though, that setting such a high price response trigger may limit the program's usefulness to PG&E as well as the value of the program. Setting the SmartACTM Program's price response trigger at a lower price range may provide a more flexible resource.
Even though we authorize the Revised Settlement Agreement in its entirety, including the portion regarding the price response trigger, we encourage PG&E to consider improving this price response trigger as they are applied to demand response and the CAISO market in PG&E's upcoming 2012-2014 Demand Response Portfolio Application.