ALJ Issued Ruling Requesting Comments on PCIA Forecasting Data Access

In response to the ALJ ruling on September 17, 2021, parties provided their comments on CalCCA’s proposal to authorize a nondisclosure agreement to allow CCAs and other entities with customers who pay the PCIA to access confidential, market-sensitive ERRA and PABA monthly report data year-round for the limited, non-proceeding purpose of developing PCIA rate forecasts. The ALJ Ruling requests responses to the following additional questions:

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1. In comments on the September 2021 ruling, CalCCA asserted that CCAs need access to confidential PCIA forecasting data to enable CCAs to “absorb” spikes in the PCIA by reducing the generation rates they charge for their own procured power. How will access to confidential PCIA and PABA rate forecasting data year-round enable CCAs or Direct Access providers to prevent rate spikes for customers? Please provide a detailed explanation, including (a) an explanation of how a CCA or Direct Access provider would use PCIA and PABA rate forecasts during each quarter of the year to protect customers from rate spikes, and (b) an analysis of the impact of having more accurate estimates (rather than less accurate estimates based on public data) on a CCA's or Direct Access provider’s ability to protect customers from rate spikes during each quarter of the year.
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2. What specific information should reviewing representatives, under a nondisclosure agreement, be allowed to disclose to CCAs or Direct Access providers for the purpose of developing or understanding PCIA or PABA rate forecasts? Please explain (a) why this specific information is necessary for the intended purpose, (b) how this information will be used to develop or understand PCIA or PABA rate forecasts, and (c) what are the risks associated with disclosure of this specific information by reviewing representatives to CCAs or Direct Access providers.
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3. Should the Commission mitigate the risks of PCIA data access by only allowing reviewing representatives to disclose to CCAs or Direct Access providers the reviewing representative’s estimated PCIA and PABA forecasts, without disclosing any information about the underlying data or drivers of these forecasts? (a) Would this information be sufficient to enable CCAs or Direct Access providers to prevent rate spikes for customers? (b) Are there any risks associated with reviewing representatives disclosing solely their PCIA and PABA forecast estimates to CCAs or Direct Access providers?

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