As the Commission stated in Resolution E-3689:
[I]nclusion of smaller customers into interruptible programs could provide a large additional source of untapped new load capable of being curtailed.
The activities of both the utilities and the ISO appear to be focusing almost exclusively upon the larger customers17 who possess the metering (and to a lesser extent the telemetry) equipment needed to participate in curtailable programs. This may have led to duplication of effort and a chasing of a limited amount of load by a number of programs. One purpose of this rulemaking is to identify if and how smaller customers can participate in curtailable programs. Issues that we need to examine are the ability of smaller customers to participate; development of rate design and incentive policies of such participation; a cost/benefit analysis of such programs; and the marketing of any such programs. We are also interested in examining if PG&E and SDG&E should develop an Air Conditioning Cycling program similar to those already operated by both Edison and the Sacramento Municipal Utility District (SMUD)18.
17 Generally those with demand above 500 kW. 18 Edison's program is designed to provide approximately 350 MW of demand relief. SMUD's program, which is triggered to avoid rotating outages, is designed to provide approximately 200 MW of demand relief.