Demand Flexibility Rulemaking (R.22-07-005)

Background

California’s electricity system is undergoing rapid transformation on the pathway to 100% renewable power, with the expected high penetration of renewables, electrification of buildings and transportation, and deployment of behind-the-meter (BTM) distributed energy resources (DERs). Many stakeholders are concerned about potential adverse impacts of these trends on the State’s power grid and agree that going forward it is essential for California to leverage demand response (also referred to as load or demand flexibility management) as a critical resource in integrated resource planning (IRP) to meet the State’s aggressive GHG emissions reduction targets.

If the State is to fully capture the significant demand-side potential enabled by electrification and customer DERs, a key “chicken-and-egg” problem related to demand response and retail rates must be resolved. For large numbers of customers (both residential and commercial) to adopt flexible demand management solutions at the scale necessary to support the future electricity grid, automation technologies for controlling various end-uses and DERs must be inexpensive and ubiquitous. For this to be true, there must exist a robust and stable policy pathway that is standardized, easy to implement, and allows the industry to develop low-cost, flexible demand management capabilities and integrate them into smart end-use devices and DERs by default for use by all customer classes.

Energy Division (ED) Staff have held an exploratory workshop in June 2021 which solicited feedback from the industry and stakeholders. Considering the responses from industry, ED crafted and released a whitepaper charting the six steps to enable demand flexibility called "Advanced Strategies for Demand Flexibility Management and Customer DER Compensation." ED Staff held another workshop on the whitepaper in July 2022 to inform the industry its recommendations to harness demand flexibility. In response to the release of the whitepaper, the Commission opened up Rulemaking 22-07-005 on July 14, 2022, "Order Instituting Rulemaking to Advance Demand Flexibility Through Electric Rates." 

Read our fact sheet on the CPUC's Jan. 25, 2024 decision approving pilot programs for PG&E and SCE.

Procedural Timeline

There are currently 2 tracks in the R.22-07-005 rulemaking with differing timelines.

Backgroung Workshops and Working Group Materials

• May 25, 2021: Exploratory Workshop on Demand Flexibility (scroll to bottom of page)
• June 22, 2022: ED Whitepaper Release "Advanced Strategies for Demand Flexibility Management and Customer DER Compensation"
• July 21, 2022: Workshop on Advanced Demand Flexibility Management and DER Compensation
• November 11, 2022: Scoping Memo and Ruling for Phase I Released
• November 2022: Working Groups 1 and 2 established  
  • Working Group documents including presentations, meeting notes, and recordings of past meetings will be hosted by SCE on SharePoint: request access
• November 29, 2022: Income-Graduated Fixed Charge Workshop - Workshop recording (password - IGFCwkshp1122)
• December 21, 2022: PG&E-hosted Workshop on Income Verification - Workshop recording
• February 1, 2023: Workshop on E3 Fixed Charge Tool and Income Verification Follow-Up
  • Workshop recording (password - GwFpJQx5)
  • Workshop slides 
• February 10, 2023: Revised E3 Fixed Charge Tool and ED Staff Responses to Party Feedback on Fixed Charge Tool - Revised Draft Fixed Charge Tool, ED Staff Responses to Feedback on Draft Fixed Charge Tool
  • Please provide feedback on any remaining errors you see in the tool, as well as feedback on the new feature that were added to the tool since the initial draft (ability to specify method for adjusting volumetric rates, electrification dashboard, printable results, and any other revisions since the initial draft).  Please provide this feedback through the following link by COB February 15th. https://forms.office.com/r/83rUkq0k9W
  • We will plan on addressing any additional feedback that parties submit and releasing a final build of the tool by February 17th.
•  April 18, 2023: Several bugs were identified and corrected in the E3 Fixed Charge Tool. Parties can use the version of the Updated E3 Fixed Charge Tool to correct testimony. Instructions on how to submit corrected testimony is forthcoming.
• Oct 17, 2023: Workshop on DFOIR Track B Working Group Proposals, including consideration of the barriers and needs of low-income and disadvantaged communities.
  • Meeting Recording (Part 1) | Meeting Transcript (Part 1)
  • Meeting Recording (Part 2) | Meeting Transcript (Part 2)
  • Meeting Recording (Part 3) | Meeting Transcript (Part 3)
• July 10, 2024: IOU-Hosted Workshop on Fixed Charge ME&O (recording)

Track A

Track A Opening Testimony

• TURN and NRDC
  • TURN and NRDC Opening Testimony
  • TURN and NRDC Opening Testimony Errata (clean)
  • TURN and NRDC Opening Testimony Errata (redline)
• Sierra Club
  • Sierra Club Opening Testimony
  • Sierra Club Opening Testimony Errata (clean)
  • Sierra Club Opening Testimony Errata (redline)
• SEIA
  • SEIA Opening Testimony
  • SEIA Opening Testimony Errata
• Public Advocates Office (PAO)
  • Public Advocates Opening Testimony - Implementation
  • Public Advocates Opening Testimony - Rate Design
  • Public Advocates Opening Testimony - Rate Design Errata (clean)
  • Public Advocates Opening Testimony - Rate Design Errata (redline)
• Pacificorp
  • Pacificorp Opening Testimony
• Liberty
  • Liberty Opening Testimony
• Joint IOUs
  • PG&E zip files
  • SCE zip file
  • SDG&E zip file
  • Joint IOUs Opening Testimony Exhibit 1
  • Joint IOUs Opening Testimony Exhibit 1 Errata (clean)
  • Joint IOUs Opening Testimony Exhibit 1 Errata (redline)
  • Joint IOUs Opening Testimony Exhibit 2
• CEJA
  • CEJA Opening Testimony
  • CEJA Opening Testimony Att 1
  • CEJA Opening Testimony Att 2
• Bear Valley Electric
  • Bear Valley Electric Service Opening Testimony

Track A Reply Testimony

• TURN and NRDC
  • Rebuttal Testimony of Mohit Chhabra and Sylvie Ashford
• Sierra Club
  • Rebuttal Testimony of John D. Wilson
• SEIA
  • Rebuttal Testimony of R.Thomas Beach
  • Errata to Rebuttal Testimony of R.Thomas Beach
• UCAN
  • Rebuttal Testimony of Mark Fulmer
• Public Advocates Office (PAO)
  • Rebuttal Testimony on Income Graduated Fixed Charge Rate Design
  • Rebuttal Testimony on Income Verification Implementation
• Joint IOUs
  • Bear Valley, Liberty Utilities, and PacifiCorp
  • PG&E, SCE, and SDG&E
• Advanced Energy United
  • Rebuttal Testimony of Brian Turner
• California Community Choice Association
  • Brian Dickman and Justin Kudo
• Center for Accessible Technology
  • Rebuttal Testiimony of Melissa W. Kasnitz
• CEJA
  • Rebuttal Testimony of Tyson Siegele
• CESA
  •  Rebuttal Testimony of Richard McCann
• Clean Coalition
  • Rebuttal Testimony 
  • Printable Results 

Link to Docket

Rulemaking 22-07-005 found here.