OhmConnect Filed a Reply to PG&E and SDG&E Opposition

In D.20-06-031, the Commission amended the Maximum Cumulative Capacity (“MCC”) Buckets to limit the proportion of a Load Serving Entity’s (“LSE”) resource adequacy (“RA”) obligation that could be met with use-limited resources. In particular, the decision adopted an 8.3% cap in the MCC demand response (“DR”) bucket (“MCC DR Bucket Cap”).

OhmConnect submitted the Petition for Modification requesting that the Commission the revise Ordering Paragraph 19 of D. 20-06-031 to increase the MCC DR Bucket to 11.3%. SDG&E and PG&E generally opposed the PFM by raising concerns about the proposal’s negative impact on system reliability.

In its Reply, OhmConnect argues that:

1. PG&E and SDG&E improperly attempt to scare the Commission into rejecting the Petition by making unfounded and misleading claims about its effects on system reliability; and
   ‍
2. The Petition complies with Rule 16.4(d); PG&E and SDG&E attack OhmConnect’s description of “new and changed facts” using claims that are misleading and false.

‍

OhmConnect’s Reply includes various reasons why granting the Petition would not harm system reliability.

The Petition does not request that the Commission lift the Maximum Cumulative Capacity (“MCC”) DR bucket cap entirely. Rather, the Petition asks the Commission to recognize that credits representing capacity from IOU-administered DR programs fill the existing 8.3 percent MCC DR bucket first, while third-party DR competes for whatever room is left under the cap.
‍

The proposal to raise the DR bucket cap by the amount of IOU DR on the system such that third-party DR  resources are subject to the full 8.3 percent cap—is consistent with how MCC DR bucket caps are actually calculated

‍‍

In addition, the Reply disputes the IOUs’ claim that the PFM includes new and changed facts in violation of Rule 16.4(D).

PG&E argued that OhmConnect has “failed to explain why the petition could not have been presented within one year of the effective date of the Decision (i.e., June 25, 2020).” Similarly, SDG&E states that “OhmConnect fails to adequately justify its late submission, accordingly, the PFM should be summarily denied.”

‍

In response, OhmConnect points out that the decision stated “Should parties identify any new or changed facts regarding this issue, a petition for modification may be filed for consideration,” and that this PFM is in response to that guidance."

‍