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Erik Jacobson
Regulatory Relations

Pacific Gas and Electric Company
77 Beale St., Mail Code B13U
P.O. Box 770000
San Francisco, CA 94177
Fax: 415-973-3582

February 8, 2019

Advice 5477-E
(Pacific Gas and Electric Company ID U 39 E)

Public Utilities Commission of the State of California

PG&E’s Disadvantaged Communities Pilot Plan

Pacific Gas and Electric Company (PG&E) submits this Tier 2 advice letter to the
California Public Utilities Commission (Commission or CPUC) pursuant to Ordering
Paragraph (OP) 11 of Decision (D.) 18-11-029. This advice letter includes PG&E’s
proposal for undertaking a demand response (DR) pilot focused on Disadvantaged
Communities (DACs).
OP 11 of D. 18-11-029 requires that no later than four months before the start of the
pilot or 60 days after the issuance of this decision,1 whichever is earlier, each of the
three Investor Owned Utilities submit Tier 2 advice letters that include plans for their
DAC Pilot. This plan must comply with the requirements listed in the Proposal2 and
adopted by D. 18-11-029, including section 3.5.3 titled “Regulatory Process.”3


D. 18-11-029 was adopted on November 20, 2018 and issued on December 10, 2018.
PG&E understands the reference to “Proposal” to be the Assigned Commissioner’s original
straw proposal released on February 7, 2018, as updated. Subsequent to the original
proposal, the CPUC held a workshop on February 15, 2018. Thereafter, on June 15, 2018, an
ALJ Ruling was issued containing a series of questions on numerous topics, including DACs.
PG&E along with other interested stakeholders filed responses and replies on July 20, 2018
and August 3, 2018, respectively.
The DAC Pilot Proposal addresses the ten criteria listed on pages 74-75 of the Decision.


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Advice 5477-E -2- February 8, 2019 Proposed DAC Pilot Overview PG&E plans to partner with Olivine, Inc.,4 a well-regarded industry leader providing infrastructure and services that enable distributed and aggregated resources to effectively and efficiently offer grid services in the DAC areas. Olivine has extensive expertise in working with both Investor Owned Utilities (IOUs) and Community Choice Aggregators (CCAs) to administer Demand Response (DR) programs. Olivine has recently completed an innovative Community Energy Initiative5 (CEI) in Richmond, California which is studying the ability of residents living in DACs to participate in DR. The proposed pilot, as described more fully in the attached DAC Pilot Plan, intends to leverage and expand on elements of the recently completed Richmond CEI in the City of Fresno. Specifically, PG&E and Olivine propose to study the willingness and ability of residential customers to provide DR in DACs near the Malaga Power Generation6 facility in south-central Fresno. Households within the pilot area have some of the highest environmental justice percentile rankings in the State, according to the State’s analysis conducted using the CalEnviroScreen Tool.7,8 These communities overlap with communities prioritized by the San Joaquin Valley’s AB 617 9 Environmental Justice Steering Committee. CARB staff has recommended south-central Fresno for deployment of community air monitoring and development of a community emissions reduction program 10. PG&E and Olivine look forward to engaging with CARB staff, local environmental justice and community organizations to support the development of an action plan to reduce exposure to air pollution in these areas. Discussion Key attributes of the proposed DAC Pilot are identified in the following table and compared to the recently completed Richmond CEI. There are significant differences between the size and scope of the current CEI in Richmond compared to the proposed DAC Pilot in Fresno. Notable differences include the number of participants (50 vs. up to 2,500), the location (climate differential) and CAISO market integration among others. 4 Link: Link: 6 The Malaga facility is a 96 MW gas fired peaking plant. 7 Based on the Cal EnviroScreen tool. Link: 8 Link: 9 In response to Assembly Bill (AB) 617 (C. Garcia, Chapter 136, Statutes of 2017), the California Air Resources Board (CARB) established the Community Air Protection Program (CAPP). The Program’s focus is to reduce exposure in communities most impacted by air pollution. 10 5
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Advice 5477-E -3- Attributes Study Population Climate Zone AC Saturation Customer Outreach Richmond (CEI) 50 residential households Coastal/Winter Peaking Low Social Media and Community Organizations Study Events DR Type Reward Type Load Reduction Behavioral Rewards Via Gift Card Only Market Integration Resources not Market Integrated February 8, 2019 Fresno (DAC Pilot) 2,500 residential households Inland/Summer Peaking High Social Media and Community Organizations plus Energy Savings Assistance Program contractors and Community Energy Navigators Load Reduction and Load Shifting Behavioral and Automated Rewards Redeemed Via On-Line Store for Energy Automation Devices or Gift Card Resources Market Integrated via either the existing Supply Side or Excess Supply Pilot or both Disadvantaged Communities Advisory Group D. 18-11-029 includes a provision for the DAC Pilot Proposal to address “If and how the Utilities are coordinating with the Disadvantaged Communities Advisory Group (DACAG).11 To this end, PG&E presented its DAC Pilot Proposal to the DACAG on January 25, 2019, at its meeting in Fresno.12 At that meeting the DACAG provided the following input: • • • • • Attempt to overlap the DAC DR Pilot target area with the AB 617 target area if possible. Avoid calling load shift13 demand response events that may lead to customers incurring higher energy costs. Focus on community engagement driven through local community organizations. Understand the local community including language preferences. Update the DACAG at least annually during the pilot lifecycle and perhaps more frequently at the request of a DACAG subgroup formed for that purpose. PG&E has incorporated the feedback from the initial DACAG meeting in this proposal to the extent possible. Adopting this Pilot proposal will not increase any current rate or charge, cause the withdrawal of service, or conflict with any rate schedule or rule. 14 11 D. 18-11-029 at p. 75. ALJ Hymes notice to parties on January 15, 2019. This notice to the service list for 17-01012 et al. included details of the meeting. 13 In the context of the Pilot a load shift event many consist of the customer being informed that clean energy is abundant during certain periods. The customer will have discretion over how to respond to this information. For example, providing information that shifting use of electric clothes drying from a rainy Friday evening to a sunny Saturday morning on certain days during the winter and spring will result in significantly lower GHGs and other air emissions related to that use of energy. If a market integrated load shift product that customers can participate in is approved during the timeframe of the Pilot, PG&E and Olivine will assess whether such product can be reasonable integrated into the Pilot design. 12
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Advice 5477-E -4- February 8, 2019 Protests Anyone wishing to protest this submittal may do so by letter sent via U.S. mail, facsimile or E-mail, no later than February 28, 2019, which is 20 days after the date of this submittal. Protests must be submitted to: CPUC Energy Division ED Tariff Unit 505 Van Ness Avenue, 4th Floor San Francisco, California 94102 Facsimile: (415) 703-2200 E-mail: Copies of protests also should be mailed to the attention of the Director, Energy Division, Room 4004, at the address shown above. The protest shall also be sent to PG&E either via E-mail or U.S. mail (and by facsimile, if possible) at the address shown below on the same date it is mailed or delivered to the Commission: Erik Jacobson Director, Regulatory Relations c/o Megan Lawson Pacific Gas and Electric Company 77 Beale Street, Mail Code B13U P.O. Box 770000 San Francisco, California 94177 Facsimile: (415) 973-3582 E-mail: Any person (including individuals, groups, or organizations) may protest or respond to an advice letter (General Order 96-B, Section 7.4). The protest shall contain the following information: specification of the advice letter protested; grounds for the protest; supporting factual information or legal argument; name, telephone number, postal address, and (where appropriate) e-mail address of the protestant; and statement that the protest was sent to the utility no later than the day on which the 14 PG&E filed for Chapter 11 bankruptcy protection on January 29, 2019. PG&E will provide a supplement to this Advice Letter or appropriate notice to the Commission should events related to the bankruptcy-proceeding affect implementation of the pilot project proposed in this Advice Letter.
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Advice 5477-E -5- February 8, 2019 protest was submitted to the reviewing Industry Division (General Order 96-B, Section 3.11). Effective Date PG&E requests that this Tier 2 advice letter become effective on regular notice, March 10, 2019, which is 30 calendar days after the date of submittal. Notice In accordance with General Order 96-B, Section IV, a copy of this advice letter is being sent electronically and via U.S. mail to parties shown on the attached list [and the parties on the service list for A.17-01-012 et al. Address changes to the General Order 96-B service list should be directed to PG&E at email address For changes to any other service list, please contact the Commission’s Process Office at (415) 703-2021 or at Send all electronic approvals to Advice letter submittals can also be accessed electronically at: /S/ Erik Jacobson Director, Regulatory Relations Attachment 1 – Disadvantaged Communities Demand Response Pilot Proposal cc: Service List A.17-01-012 et al.
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ADVICE LETTER SUMMARY ENERGY UTILITY MUST BE COMPLETED BY UTILITY (Attach additional pages as needed) Company name/CPUC Utility No.: Pacific Gas and Electric Company (ID U39E) Utility type: ELC GAS PLC ✔ HEAT ELC = Electric PLC = Pipeline WATER Contact Person: Yvonne Yang Phone #: (415)973-2094 E-mail: E-mail Disposition Notice to: EXPLANATION OF UTILITY TYPE GAS = Gas WATER = Water HEAT = Heat (Date Submitted / Received Stamp by CPUC) Tier Designation: 2 Advice Letter (AL) #: 5477-E Subject of AL: PG&E’s Disadvantaged Communities Pilot Plan Keywords (choose from CPUC listing): Compliance AL Type: Monthly Quarterly Annual ✔ One-Time Other: If AL submitted in compliance with a Commission order, indicate relevant Decision/Resolution #: D.18-11-029 Does AL replace a withdrawn or rejected AL? If so, identify the prior AL: No Summarize differences between the AL and the prior withdrawn or rejected AL: Yes Yes ✔ No ✔ No No. of tariff sheets: N/A Estimated system annual revenue effect (%): N/A Estimated system average rate effect (%): N/A When rates are affected by AL, include attachment in AL showing average rate effects on customer classes (residential, small commercial, large C/I, agricultural, lighting). Tariff schedules affected: N/A Service affected and changes proposed1: N/A Pending advice letters that revise the same tariff sheets: N/A 1 Discuss in AL if more space is needed. Clear Form
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Protests and all other correspondence regarding this AL are due no later than 20 days after the date of this submittal, unless otherwise authorized by the Commission, and shall be sent to: CPUC, Energy Division Attention: Tariff Unit 505 Van Ness Avenue San Francisco, CA 94102 Email: Name: Erik Jacobson, c/o Megan Lawson Title: Director, Regulatory Relations Utility Name: Pacific Gas and Electric Company Address: 77 Beale Street, Mail Code B13U City: San Francisco, CA 94177 Zip: 94177 State: California Telephone (xxx) xxx-xxxx: (415)973-2093 Facsimile (xxx) xxx-xxxx: (415)973-3582 Email: Name: Title: Utility Name: Address: City: State: District of Columbia Telephone (xxx) xxx-xxxx: Facsimile (xxx) xxx-xxxx: Email: Zip: Clear Form
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Advice 5477-E February 8, 2019 Attachment 1 Disadvantaged Communities Demand Response Pilot Proposal
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Disadvantaged Communities Demand Response Pilot Proposal Pacific Gas and Electric Company & Olivine February 8, 2019 Background D. 18-11-029 or the Decision (issued December 10, 2018) ordered the IOUs to each submit a Tier II Advice letter within 60-days after the issuance of this Decision (by February 8, 2019) proposing a demand response (DR) pilot focused on providing direct economic benefits to disadvantaged communities (DACs). Total funding for the DAC DR Pilots over the period 2019-2022 is $2.5 million across the three IOUs with PG&E allocated $1.0 million with 10% of the budget dedicated to EM&V. 1 The Decision defines DACs as census tracts that score above 75th percentile using the CalEnviroScreen tool plus an additional 22 census tracts that score in the highest five percent of CalEnviroScreen’s pollution burden, but do not have an overall CalEnviroScreen score because of unreliable socioeconomic or health data. 2 The Decision provides for the use of zip codes or census tracts in targeting for the purposes of this pilot and provides support for marketing and outreach efforts to increase enrollment and participation in DACs, while learning more about the target population and the residents’ ability to respond to DR events. This Pilot Proposal outlines how PG&E and its partner, Olivine, plan to implement the DAC Pilot in the 2018-2022 DR Program cycle. 1 Decision 17-12-003, Ordering Paragraph 58. D.18-11-029, p. 62. Link: 2 1
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Pilot Target Location Using the methodology Olivine developed that was adopted under D. 18-11-029, this pilot would target census tracts in zip codes that qualify as DACs within a 10mile radius of the Malaga natural gas fired peaking plant in south Fresno 3. The pilot will include customers residing in zip codes: 93701, 93702, 93703, 93721, 93725 and 93728, which fully encompasses south-central Fresno community selected for the Community Air Protection Program under Assembly Bill (AB) 617. 4 Geographically this community is bounded by Golden State Boulevard to the west, McKinley Avenue to the north, Chestnut Avenue to the east, and includes the small community of Malaga at the southern tip of the boundary. The census tracts in these zip codes are DACs that fall within a 10-mile radius of the Malaga natural gas fired peaking plant in south Fresno. These DACs have some of the highest environmental justice (EJ) percentile rankings in the State. The average overall CalEnviroScreen Score and Population Characteristics for the area values are both above the 97th percentile. Of the approximately 25,000 residential households within this target area, approximately 75% are California Alternative Rates for Energy (CARE) 5 eligible. Pilot Strategy During hot summer afternoons the Malaga powerplant can be dispatched to meet high energy demand in the greater Fresno area 6. Distribution lines serving South Central Fresno can also experience high loading conditions during these same periods. This Pilot intends to target 2,500 residential customers within a 10-mile radius of the Malaga power generation plant. Using a statistically relevant sample size near a gas fired peaking plant will provide insights for future program designs that are 3 The Malaga Power Plant is a 96 MW gas fired peaking plant located in south Fresno. AB 617 called for the California Air Resources Board (CARB) to establish the Community Air Protection Program (CAPP). This Program’s focus is to reduce exposure in communities most impacted by air pollution. 4 5 CARE provides for discounted rates based on income eligibility. Link: 6 All communities in the Pilot area fall into the Fresno sub-Load-Aggregation-Point (subLAP) as currently defined by the CAISO. 2
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applicable and scalable for use in similarly situated households throughout the Central Valley area (approximately 500,000 households). The Pilot will collect demographic, psychographic and energy usage data in order to evaluate the willingness and ability of residents within this community to participate in DR either by reducing or shifting load in response to both grid and environmental signals. At scale these types of DR actions could materially reduce the need for dispatch and cycling of peaking plants and reduce high loading on distribution lines potentially extending the life of that equipment. Marketing and outreach efforts to increase understanding and engagement in DR programs will be tested to better understand how to access diverse and hard to reach populations within the targeted community, how to overcome challenges and barriers to participation, and ways to provide additional value to both participating and non-participating residents by leveraging other demand side management program options available. The following areas will be explored during the study period. • Awareness and Willingness to Participate: What is the current level of awareness of DR program availability and understanding of how DR programs create value for customers and the community? What is the current level of interest in participating in demand response programs? If possible compare responses of DAC households to non-DAC households. • Energy Use and Ability to Participate: How do the different DAC households use energy in their homes? How well can DAC households respond to and participate in DR programs? If the population is large enough, we intend to compare usage and responses by households in and outside of DACs. • Outreach: What are the best methods to reach different types of households in DACs, including those that are hard to reach? • Messaging: What kind of messaging resonate best with households? • Benefits: What kinds of DR incentives and program offerings will be of greatest value to DAC households and benefit them the most? 3
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Theory of Pilot Intervention The Pilot leverages and expands on Olivine’s recently completed Community Energy Initiative (CEI) based in Richmond, CA. The CEI was a limited study (50 participants) that provided incentives for survey participation: • • • • • • • • How and when do individuals use energy in their homes? Can a household reduce energy when requested? Will households participate in DR programs? Are there observed differences between households in DACs and those not in DACs but proximate to DACs? What are important concerns of households for their communities? Do carbon emissions fit into those concerns and to what extent? What methods and approaches for outreach are most successful? How much facility do households have with technology? Mobile application tools were developed to provide awareness for energy usage and messaging capabilities for load reduction through behavioral demand response. Outreach and Enrollment: The Pilot intends to leverage and expand the study in Richmond within the targeted zip codes in Fresno. As was the case in Richmond social media and community organizations will be used for outreach. In Fresno, partnerships will be formed with local community-based organizations to reach the diverse populations. Marketing and educational materials will be developed in the population’s native language (e.g. Spanish) beginning in the last quarter of 2019. In addition to social media and community organizations, PG&E and Olivine will attempt to engage one or more Energy Savings Assistance program contractors as well as one or more San Joaquin Valley Pilot Community Energy Navigator located in the south-central Fresno area. 7 Training on the Pilot program design and use of the Olivine on-line application will be rolled out in the first quarter of 2020 to support community awareness, outreach and initial enrollment efforts. 7 These entities provide services and are both well-known and trusted in the community. Therefore, their participation would be useful in the recruitment effort. 4
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Participants will be provided access to an existing easy-to-use mobile app and website, as was used in Olivine’s CEI in Richmond, to support customer engagement and education throughout the pilot and to facilitate communications, collection of surveys and other direct participant information. In order to provide for as many customers as possible there will be both behavioral as well as automated technology enabled options offered and enrollment processes will include online capabilities to provide for near real-time validation of customer eligibility. The formal enrollment period is expected to end by the summer of 2020 DR event season and to include initial surveys and assessments. Demand Response Testing: During the Pilot there will be study period for both home energy summer peak shaving and winter/spring load shifting 8 to analyze the capabilities of the population to provide both load reduction as well as shift consumption into periods of excess renewable supply. The summer of 2020 is planned to be peak shaving event study season. Late afternoon and early evening hours will be used for DR events targeting high value times when the Malaga power station may be dispatched and/or PG&E substations may have high loading. The effectiveness of varying triggers such as grid need, pricing, and air quality will be tested. Market price signals as well as forecasts of potential dispatch of the Malaga power-plant will be used. Similarly, during the winter months of 2020-2021, home energy excess supply will be studied focusing on the capabilities of the participants to shift load usage to match available renewable energy supply. 9 8 In the context of the Pilot, a load shift event may consist of the customer being informed that clean energy is abundant during certain periods. The customer will have discretion over how to respond to this information. For example, providing information that shifting use of electric clothes drying from a rainy Friday evening to sunny Saturday morning on certain days during the winter and spring will result in significantly lower GHGs and other air emissions related to that use of energy. If a market integrated load shift product that customers can participate in is approved during the timeframe of the Pilot, PG&E and Olivine will assess whether such product can be reasonable integrated into the Pilot design. 9 Due to higher levels of renewables especially solar generation, California can experience times of oversupply of generation especially during non-summer months. This is sometimes referred to as the “belly of duck curve.” Link: 5
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Up to ten (10) DR events will be targeted for each study season and incentives will be paid for both specific events as well as consistent performance and participation in surveys. The Pilot will include the measurement and evaluation activities to determine the value of the capabilities to the targeted pilot location as well as broader generalizations at scale, responses to differing triggers and impacts from the measured performance. Market Integration The Pilot operations will leverage the existing capabilities and infrastructure already deployed by Olivine in other PG&E pilot programs, including the Supply Side II (SSP II) and Excess Supply (XSP) DR Pilot. 10 One or both of these existing pilots will serve as the mechanism for integration of the DAC DR Pilot into the CAISO wholesale market. Amount and Form of Economic Benefits The Pilot intends to provide 50% of the budget monies directly to participants within the Community. Participants will receive direct incentives for providing responses to surveys and for participating in DR events. Participants are expected to have the opportunity to earn up to $250 (subject to change in final pilot design) in direct incentives through some combination of initial Pilot survey completion, participation in Pilot peak shaving and load shifting events, and completion of the final Pilot survey. Through energy monitoring, awareness and education, participants may have the opportunity to save energy and reduce their energy bills. Eligible participants will also receive free technology installation and support to reduce their energy usage and to leverage other available Demand Side program options and incentives. 10 Olivine’s webpage provides an overview of the Supply Side II Pilot and Excess Supply Pilot Link (SSP II): Link (XSP): 6
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Pilot Analysis and Assessment Including Cost-Effectiveness As these DAC DR Pilots are first of their kind, PG&E and Olivine will work with stakeholders and Energy Division Staff to develop a plan for quantitative and qualitative evaluation of the Pilot, including assessment of program design and delivery, customer experience, load impacts, environmental impacts and costeffectiveness. PG&E and Olivine will develop key performance indicators and will report out annually and at the end of the pilot in a fashion similar to the current SSP-II and XSP Pilots. These key performance indicators will be reflective of customer benefits including safety, reliability affordability, awareness and access. Additionally, consistent with guidance provided in D. 18-11-029, key performance indicators will be developed and reported reflecting air quality improvements related to the pilot. Consumer Protection No customer will be charged any fee for participating in the Pilot nor will there be any penalty for exiting the Pilot once enrolled. For low income customers participating in the Pilot no out-of-pocket payment will be required to receive demand response automation equipment, such as smart plugs or smart thermostats beyond redemption of “points” earned through Pilot participation. Furthermore, Pilot test events will be structured in a way that will attempt to either reduce energy consumption (peak shaving) or reduce energy costs (load shifting) or both. Coordination with Other IOU’s PG&E’s lead on the DAC DR Pilot did reach out to both SCE and SDG&E leads to discuss opportunities for collaboration and to ensure that PG&E was not duplicating the learnings that either SCE or SDG&E were planning from their DAC DR Pilot design. Disadvantaged Community Advisory Group (DACAG) On January 25, 2019 the DAC Pilot proposal was presented to the DACAG at its meeting in Fresno. Feedback from the DACAG was incorporated into this proposal. During that meeting plans for coordination were discussed to update the DACAG at least annually through the pilot lifecycle and the DACAG will 7
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consider forming a subgroup to coordinate more frequently with the DAC DR pilot. Justification for Choice of Third-Party PG&E has chosen to partner with Olivine for this Pilot based on Olivine’s wealth of knowledge related to demand response program and platform design including all aspect of CAISO market integration. In addition, Olivine has recently completed the Richmond Community Energy Initiative which allows this Pilot to extend and leverage Olivine’s learnings from that work as well as leverage the on-line application that Olivine built for that earlier study. Finally, the partnership between PG&E and Olivine allows this Pilot to leverage platforms that Olivine has already developed for PG&E’s existing SSP II and XSP Pilots. Customer Data Sharing Customer data for this pilot would fall under Rule 27 addressing primary purpose use. PG&E’s existing Master Service Agreement with Olivine includes provisions on confidentiality and data security regarding the handling of confidential information and PG&E Data from PG&E or its customers. This is consistent with the process established for the two existing pilots (SSP II and XSP) for which Olivine serves as the primary contractor and PG&E as the pilot administrator. Additional Supporting Information The remaining pages provide addition information, including the proposed schedule for the pilot, a proposed illustrative budget and the proposed roles and responsibilities between PG&E and Olivine. 8
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Proposed Schedule for Pilot Q1 2019 – Submit Tier II Advice Letter Q1 2020 – Begin outreach through community organizations and social media. Train contractors on DAC DR Pilot design and Olivine on-line application Q1 2021 – Continue load shifting event season with up to 5 additional load shifting events. Q2 2019 – Tier II Advice Letter Approved Q3 2019 – Finalize scope of work and contract provisions with Olivine Q2 2020 – Open season Q3 2020 – Peak shaving for enrolling customers event season with up into the Pilot. to 10 peak shaving Completion of initial events of 1-2 hours pilot participation during early evening surveys. Participating hours. Participating customers earn first customers earn peak pilot rewards. shaving event awards. Q2 2021 – Post event season survey. Participants who engaged in 5 or more peak shaving and/or 5 or more load shifting events can earn additional rewards for completing post event season survey Q3 2021 – Olivine compiles survey and event season data and publishes DAC DR Pilot Final Report. Q4 2019 – Identify Fresno area community organizations and plan social media outreach Q4 2020 – Begin load shifting event season with up to 5 load shifting events of 1-2 hours duration on weekends during periods of excess renewable generation. Participating customers earn load shift event awards. Q4 2021 – Learnings from DAC DR Pilot are incorporated into PG&E’s post-2022 program design and funding application (to be filed in November 2021). Proposed Illustrative Budget for Pilot Budget Category Incentives Marketing Administration EM&V Total 2019 2020 $250,000 $75,000 $100,000 $25,000 $450,000 $75,000 $50,000 $125,000 Total for three years of pilot 2021 $250,000 $425,000 $100,000 $75,000 $1,000,000 9
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Proposed Roles and Responsibilities for Pilot PG&E Olivine Pilot Administrator Development of Pilot Material Pilot Design Review & Approval Participant Recruitment and Enrollment Pilot Material Review & Approval Participant Eligibility Review & Approval Pre and Post Survey Administration Event Notification Pilot Assessment Review & Approval Customer Care Nomination Management Award and Dispatch Settlements & Reporting 10
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PG&E Gas and Electric Advice Filing List General Order 96-B, Section IV AT&T Albion Power Company Alcantar & Kahl LLP Alta Power Group, LLC Anderson & Poole Atlas ReFuel BART Barkovich & Yap, Inc. P.C. CalCom Solar California Cotton Ginners & Growers Assn California Energy Commission California Public Utilities Commission California State Association of Counties Calpine Cameron-Daniel, P.C. Casner, Steve Cenergy Power Center for Biological Diversity City of Palo Alto City of San Jose Clean Power Research Coast Economic Consulting Commercial Energy County of Tehama - Department of Public Works Crossborder Energy Crown Road Energy, LLC Davis Wright Tremaine LLP Day Carter Murphy Dept of General Services Don Pickett & Associates, Inc. Douglass & Liddell Downey & Brand East Bay Community Energy Ellison Schneider & Harris LLP Energy Management Service Evaluation + Strategy for Social Innovation GenOn Energy, Inc. Goodin, MacBride, Squeri, Schlotz & Ritchie Green Charge Networks Green Power Institute Hanna & Morton ICF International Power Technology Intestate Gas Services, Inc. Kelly Group Ken Bohn Consulting Keyes & Fox LLP Leviton Manufacturing Co., Inc. Linde Los Angeles County Integrated Waste Management Task Force Los Angeles Dept of Water & Power MRW & Associates Manatt Phelps Phillips Marin Energy Authority McKenzie & Associates Modesto Irrigation District Morgan Stanley NLine Energy, Inc. NRG Solar Office of Ratepayer Advocates OnGrid Solar Pacific Gas and Electric Company Pioneer Community Energy Praxair Regulatory & Cogeneration Service, Inc. SCD Energy Solutions SCE SDG&E and SoCalGas SPURR San Francisco Water Power and Sewer Seattle City Light Sempra Utilities Southern California Edison Company Southern California Gas Company Spark Energy Sun Light & Power Sunshine Design Tecogen, Inc. TerraVerde Renewable Partners Tiger Natural Gas, Inc. TransCanada Troutman Sanders LLP Utility Cost Management Utility Power Solutions Utility Specialists Verizon Water and Energy Consulting Wellhead Electric Company Western Manufactured Housing Communities Association (WMA) Yep Energy
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