IEP Motion

IEP's motion seeks to strike portions of SCE, SDG&E, and ORA's prepared testimony related to use of a Generation Meter Multiplier (GMM). IEP argues that GMMs are a "lawfully ineligible" basis for line loss calculations for purposes of determining short-run avoided cost payments to Qualifying Facilities (QFs) because the underlying models to calculate the GMMs have not been made available. IEP cites Rule 74.3 of the Commission's Rules of Practice and Procedure, Decision (D.) 84-12-068, and D.87-12-066 as the basis of its position.

The subject testimony proposes to establish line loss factors by using the output of a model that the California Independent System Operator (ISO) uses in the normal course of its business. The ISO calculates and publishes GMMs for each interconnected generator in each hour. The output of the ISO model is used by the ISO to perform settlements for transactions that occur in its control area. SCE, SDG&E, and ORA do not propose to have special runs of the GMM model performed for purposes of establishing the line loss factors but will simply apply the ISO model results in the calculation of avoided costs.

In response to the motion, ORA argues:

"Use of quantitative information in many matters relating to Commission regulation is extremely common. Virtually all of that quantitative information utilizes computer modeling to some extent. Burdening parties with the requirement to provide the basis for calculation of information gathered from neutral and objective third parties (sic) sources is burdensome upon the regulatory process. Under IEP's reasoning, interest rate forecasts from Data Resources Inc. (DRI) and forecasts of input cost indices from third party sources could be suppressed."¹

I agree with ORA's reasoning. The parties to this proceeding are not using computer models in the manner envisioned by Rule 74.3, therefore, IEP's motion is denied.