: Protests to Utility Proposals for Length of Authorization Olivine, OhmConnect and the Joint Protesting Parties protested this issue. Olivine commends PG&E and SCE for supporting indefinite authorization timelines. Olivine is opposed SDG&E’s position and notes that Rule 24/32 does not limit “indefinite” to a period of three years. OhmConnect also supports PG&E and SCE’s approach and opposes SDG&E’s approach. OhmConnect clarifies that all components of the OAuth Solution 3 should be pre-populated, not only the length of authorization. The Joint Protesting Parties believe the length of authorization must include the indefinite option because requesting that a customer renew annually or every three years would be onerous, especially compared to Utility programs where customers remain enrolled automatically. Discussion The current CISR-DRP Request form allows the customer to enter the start and end date for the authorization timeframe that the Utility will release data to the third-party demand response provider. SDG&E provided no explanation for why choosing an indefinite timeframe might not “best serve the customer.” SDG&E’s approach of allowing “indefinite” authorization timeframe, but only up to three years was not explained and is inconsistent with the plain meaning of ‘indefinite.’ We find that the customer, not SDG&E is in the best position to determine whether the length of authorization offered by the Demand Response Provider best suits their needs.
TABLE 1 Adopted Implementation Phasing (Months) Asterisk * Indicates Modification to Utility Proposal Phase PG&E SCE SDG&E 1 6 mo. Authentication Authorization with streamlined design Design with 2 & 4 for Display of Terms & Conditions Dual Authorization Expanded Data Set Mobile friendly design Shorter Data Set Synchronously Email Notification* “Future-Proof” architecture* Authentication Authorization with streamlined design Demand Response Provider revocation Design with 2 & 4 for Display of Terms & Conditions Dual Authorization Expanded Data Set Length of authorization options. Mobile friendly design Shorter Data Set Synchronously Email Notification* “Future-Proof” click-through architecture* Authentication Authorization with streamlined design Demand Response Provider revocation Design with 2 & 4 for Display of Terms & Conditions Dual Authorization Length of authorization options. Mobile friendly design “Future-Proof” click-through architecture* 2 mo. Alternative Authentication Demand Response Provider revocation x Customer revocation through SCE MyAccount* Alternative Authentication Expanded Data Set 3 mo. All Three Utilities, Application for: Additional improvements as determined the Customer Data Access Committee that cannot be achieved within the Advice Letter Funding Cap* API Solution 1* Revocation using click-through authorization* Expanding the click-through authorization solution(s) to other distributedresource*
Volume (1234.2) Unit (kWh) Rate ($0.032/kWh) Cost ($100.23) ATTACHMENT 1 Comparison of Current and Expanded Data Set Pacific Gas & Electric (PG&E) (CONTINUED) PG&E CURRENT RULE 24 DATA ELEMENTS (CONTINUED) PG&E EXPANDED (FUTURE) RULE 24 DATA ELEMENTS (CONTINUED) Utility Demand Response Programs Utility Demand Response Programs Program Name Capacity Reservation Level (CRL) for CPP/PDP customers Earliest End Date w/o penalty Earliest End Date w/o penalty DR Program Nomination if fixed Service Providers Service Providers LSE MSP MDMA Known future changes to LSE Contact Information for LSE, MDMA, MSP Tracked line items Charge name (e.g. Net In/Net Out) Volume (1234.2 in kWh) Unit (kWh) Rate ($0.032/kWh, if any) ELEMENTS NOT ADDING IN THE FUTURE (PG&E)
ATTACHMENT 1 Ordered Current and Expanded Data Set San Diego Gas & Electric (SDG&E) ADOPTED SDG&E CURRENT AND EXPANDED 32 DATA ELEMENTS Account Elements Bill tier breakdown (if any) Account name (ACME INC. or JOE SMITH) Name (Over Baseline 1%-30%) Account address (123 OFFICE ST...) Volume (1234.2) Account ID (2-xxx...) Cost ($100.23) Outage block (A000) Bill TOU kwh breakdown (if any) Service Elements Name (Summer Off Peak) SDG&E Unique Identifier Volume (1234.2) Service ID (3-xxx...) Cost ($100.23) Service address (123 MAIN ST #100...) Bill demand breakdown (if any) Service tariff (D-TOU) Name (Summer Max Demand) Service voltage (if relevant) Volume (1234.2) Service meter number (if any) Cost ($100.23) # of Service meters Bill line items (sum should equal bill total charges above) Meter Read Cycle Sublap Charge name (DWR Bond Charge) Pricing Node Volume (1234.2) Known future changes Status of Service Unit (kWh) Service tariff options (CARE, FERA, etc.) Rate ($0.032/kWh) Known future changes to Sublap Cost ($100.23) Known future changes to Pricing Node Tracked line items Local Capacity Area Charge name (e.g. Net In/Net Out) Known future changes Local Capacity Area Volume (1234.2 in kWh) Standby Rate Option if On-Site Generation Unit (kWh) Customer Class Indicator Rate ($0.032/kWh, if any) Billing Elements Cost ($100.23, if any) Bill start date Historical Intervals Bill end date Start