Details for: 3951-E (Part 1 of 1).pdf


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Gary A. Stern, Ph.D.
Managing Director, State Regulatory Operations

February 8, 2019
ADVICE 3951-E
(U 338-E)
PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA
ENERGY DIVISION
Southern California Edison Company’s Proposal for a Demand
Response Pilot in Disadvantaged Communities, in Compliance
With Commission Decision 18-11-029

SUBJECT:

PURPOSE
In compliance with Decision (D.)18-11-029, Southern California Edison Company (SCE)
hereby submits its Demand Response Disadvantaged Communities Pilot Proposal for
approval by the California Public Utilities Commission (“Commission” or “CPUC”).1
BACKGROUND
In January 2017, Pacific Gas and Electric (PG&E), Southern California Edison (SCE)
and San Diego Gas & Electric (SDG&E) (jointly, the IOUs) filed separate applications
requesting approval and funding for their 2018-2022 demand response portfolios.2 On
March 15, 2017, the Commission determined it is within the scope of the proceeding to
determine whether the IOUs’ proposed programs and portfolio “adequately focus on
locating demand response participants in particular geographic areas, such as
disadvantaged communities (DACs) or areas of highest value to the grid that could also
defer or displace investment in generation, transmission and distribution.”3
On December 21, 2017, the Commission issued D.17-12-003 that approved the IOUs
DR portfolio funding applications. It also determined there was insufficient record to
direct the IOUs to make immediate program changes to target constrained local
capacity areas and disadvantaged communities.4 However, the Commission found
there is sufficient interest to initiate a stakeholder process to develop program
1
2
3
4

D.18-11-029, Ordering Paragraph (OP) 11.
A.17-01-012, A.17-01-018, and A.17-01-019 (consolidated).
Scoping Ruling (March 15, 2017), p. 4.
D.17-12-003, FOF 141.

P.O. Box 800

8631 Rush Street

Rosemead, California 91770

(626) 302-9645

Fax (626) 302-6396





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ADVICE 3951-E (U 338-E) -2- February 8, 2019 changes,5 and authorized a three year budget of $2.5 million dollars, $1 million each for SCE and PG&E and $500,000 for SDG&E, for demand response pilot programs to target constrained local capacity areas and disadvantaged communities.6 The Commission also indicated that it would issue a subsequent decision to provide guidelines to the IOUs to develop and seek approval for pilot proposals based on the guidelines.7 On December 10, 2018, the Commission issued D.18-11-029 which provided guidelines for pilots targeting demand response and a regulatory process for submittal and approval of the pilot proposals. In that decision, the Commission stated that DR pilot plans should include the following elements: 1. Target location (which disadvantaged communities in a local capacity area). 2. Strategy to target residential and small commercial customers in disadvantaged communities. 3. The amount and form of economic benefit for the participating customer, and third party, including the amount of capacity payments and how they would be allocated. (Calculation of economic benefit for the participating customer should make explicit equity considerations that would reflect the relative value of capacity in a constrained area, and the relative difficulty of providing it in hot climate zones.) 4. If and how the proposed pilot will be bid into the CAISO market, e.g. as part of an existing program if it is not large enough to meet the CAISO requirements for aggregation size by sub-LAP. 5. Theory of the pilot intervention, e.g., a logic model, and how it would meet the purpose and goal adopted in this Decision. 6. How the Utilities are coordinating with the Disadvantaged Communities Advisory Group. 7. If and how the Utilities are coordinating with each other in their proposed ideas and building off past and current pilots. 8. How to track cost-effectiveness for the purpose of informing future programs. 5 6 7 Id., pp. 145-146. D.17-12-003, OP 58. D.17-12-003, p. 146.
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ADVICE 3951-E (U 338-E) -3- February 8, 2019 9. Justification for choice of a third-party or the Utility; and explanation for how the third parties would gain the necessary data for the pilots. 10. Customer protection measures that will be taken.8 On December 19, 2018, in a parallel rulemaking (R.15-03-015),9 the Commission issued D.18-12-015 which approved SCE’s Affordable, Clean Energy through Efficient Electric Conversion Pilot (SJV Pilot).10. SCE’s SJV Pilot will, among other things, offer new, efficient electric appliances at zero upfront cost to the customer, including space heating and cooling, cooking equipment, and water heaters to eligible customers who reside in the communities of California City, Ducor, and West Goshen and do not have access to natural gas. PILOT SUMMARY SCE’s Demand Response Disadvantaged Communities (DR DAC) pilot proposes to offer customers located in the communities of California City, Ducor, and West Goshen (located within the San Joaquin Valley) the necessary equipment and incentives to manage their heat pump water heaters (HPWH) in response to grid needs and demand response events. In partnership with SCE’s SJV Pilot, SCE will offer to install grid responsive control devices on HPWH offered to eligible customers by SCE’s SJV Pilot. Eligible customers can elect to allow SCE to manage their HPWH operations during demand response events throughout a specified participation period. Customers will earn $175 dollars in bill credit per period for participating in this Pilot. Although participating customers cannot override individual events while participating, they may dis-enroll from the pilot program at any time and subsequently forfeit their bill credit. Participating customers must participate in the pilot for the full period to receive the entire bill credit. Please see Attachment A for SCE’s DR DAC Pilot Plan. SCE is proposing to partner with the SJV Pilot to increase the effectiveness of the limited budget approved in D.17-12-003.11 As advised in D.18-11-029, utilities should coordinate as much as possible and leverage opportunities to expand or build on forthcoming pilots.12 As such, SCE will be coordinating across the two pilots to maximize the limited budget and share information to the extent possible. 8 9 10 11 12 D.18-11-029 at pp. 74-75. Order Instituting Rulemaking to Identify Disadvantaged Communities in the San Joaquin Valley and Analyze Economically Feasible Options to Increase Access to Affordable Energy in those Disadvantaged Communities. D.18-12-015, OP 1. D.17-12-002, OP 58. D.18-11-029, p. 73.
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ADVICE 3951-E (U 338-E) -4- February 8, 2019 SCHEDULE AND BUDGET SCE’s SJV Pilot and DR DAC Pilot will begin installing communication devices that allow SCE to remotely communicate with the customer’s HPWH in 2019. Customers can elect to participate in the DR DAC Pilot beginning in 2020. Please see Attachment A, Section 4.b for more details on SCE’s schedule for the DR DAC Pilot. SCE proposes the following allocation of the authorized $1 million budget, with ten percent set aside for the evaluation of the success of the pilot.13 The Table below shows the estimated costs for the pilot. Please see Attachment A, Section 4.b for more details on SCE’s budget Table 1: DR DAC Pilot Proposed Budget Item Qty Unit Cost Measurement & Evaluation1 Grid-Responsive Control Devices2 Marketing DR Pilot to Customers / Consumer Protection3 Study Plan Develop of the Grid Response Water Heater Study DR Customer Incentives (for two participation periods) Administrative Costs4 Grand Total 299 449 2,000 100 Funded by DR DAC Pilot 100,000 598,000 44,900 100,000 299 - 175 / period - 104,650 52,450 1,000,000 1 D.17-12-003 allocates ten percent of the total authorized budget for evaluation of the pilot Includes budget for the grid responsive communication device, installation of the device and cellular communication 3 Includes Consumer Protection as described in Section 5.10 of Attachment A. 4 Includes general administration and direct implementation expenses 2 PROPOSED TARIFF CHANGES This advice letter will not cause the withdrawal of service nor conflict with any other schedule or rule. TIER DESIGNATION Pursuant to General Order (GO) 96-B, Energy Industry Rule 5.2 and OP 11 of D.18-11-029, this advice letter is submitted with a Tier 2 designation. 13 D. 17-12-003, p. 146.
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ADVICE 3951-E (U 338-E) -5- February 8, 2019 EFFECTIVE DATE This advice letter will become effective on March 10, 2019, the 30th calendar day after the date submitted. NOTICE Anyone wishing to protest this advice letter may do so by letter via U.S. Mail, facsimile, or electronically, any of which must be received no later than 20 days after the date of this advice letter. Protests should be submitted to: CPUC, Energy Division Attention: Tariff Unit 505 Van Ness Avenue San Francisco, California 94102 E-mail: EDTariffUnit@cpuc.ca.gov Copies should also be mailed to the attention of the Director, Energy Division, Room 4004 (same address above). In addition, protests and all other correspondence regarding this advice letter should also be sent by letter and transmitted via facsimile or electronically to the attention of: Gary A. Stern, Ph.D. Managing Director, State Regulatory Operations Southern California Edison Company 8631 Rush Street Rosemead, California 91770 Telephone (626) 302-9645 Facsimile: (626) 302-6396 E-mail: AdviceTariffManager@sce.com Laura Genao Managing Director, State Regulatory Affairs c/o Karyn Gansecki Southern California Edison Company 601 Van Ness Avenue, Suite 2030 San Francisco, California 94102 Facsimile: (415) 929-5544 E-mail: Karyn.Gansecki@sce.com There are no restrictions on who may submit a protest, but the protest shall set forth specifically the grounds upon which it is based and must be received by the deadline shown above. In accordance with General Rule 4 of GO 96-B, SCE is serving copies of this advice letter to the interested parties shown on the attached GO 96-B, A.17-01-013 et al and
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ADVICE 3951-E (U 338-E) -6- February 8, 2019 R.13-11-005 service lists. Address change requests to the GO 96-B service list should be directed by electronic mail to AdviceTariffManager@sce.com or at (626) 302-3719. For changes to all other service lists, please contact the Commission’s Process Office at (415) 703-2021 or by electronic mail at Process_Office@cpuc.ca.gov. Further, in accordance with Public Utilities Code Section 491, notice to the public is hereby given by submitting and keeping the advice letters at SCE’s corporate headquarters. To view other SCE advice letters submitted with the Commission, log on to SCE’s web site at https://www.sce.com/wps/portal/home/regulatory/advice-letters. For questions, please contact Lisa Mau at (626) 302-3684 or by electronic mail at lisa.mau@sce.com. Southern California Edison Company /s/ Gary A. Stern Gary A. Stern, Ph.D. GAS:lm:cm Enclosures
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ADVICE LETTER SUMMARY ENERGY UTILITY MUST BE COMPLETED BY UTILITY (Attach additional pages as needed) Company name/CPUC Utility No.: Southern California Edison Company (U 338-E) Utility type: ELC GAS PLC HEAT ELC = Electric PLC = Pipeline WATER Contact Person: Darrah Morgan Phone #: (626) 302-2086 E-mail: Darrah.Morgan@sce.com E-mail Disposition Notice to: AdviceTariffManager@sce.com EXPLANATION OF UTILITY TYPE GAS = Gas WATER = Water HEAT = Heat (Date Submitted / Received Stamp by CPUC) Tier Designation: 2 Advice Letter (AL) #: 3951-E Subject of AL: Southern California Edison Company’s Proposal for a Demand Response Pilot in Disadvantaged Communities, in Compliance With Commission Decision 18-11-029 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 #: Decision 18-11-029 Does AL replace a withdrawn or rejected AL? If so, identify the prior AL: Summarize differences between the AL and the prior withdrawn or rejected AL: Confidential treatment requested? Yes No If yes, specification of confidential information: Confidential information will be made available to appropriate parties who execute a nondisclosure agreement. Name and contact information to request nondisclosure agreement/ access to confidential information: Resolution required? Yes No Requested effective date: 3/10/19 No. of tariff sheets: 0 Estimated system annual revenue effect (%): Estimated system average rate effect (%): 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: None Service affected and changes proposed1: Pending advice letters that revise the same tariff sheets: None 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: EDTariffUnit@cpuc.ca.gov Name: Gary A. Stern, Ph.D. Title: Managing Director, State Regulatory Operations Utility Name: Southern California Edison Company Address: 8631 Rush Street City: Rosemead Zip: 91770 State: California Telephone (xxx) xxx-xxxx: (626) 302-9645 Facsimile (xxx) xxx-xxxx: (626) 302-6396 Email: advicetariffmanager@sce.com Name: Laura Genao c/o Karyn Gansecki Title: Managing Director, State Regulatory Affairs Utility Name: Southern California Edison Company Address: 601 Van Ness Avenue, Suite 2030 City: San Francisco State: California Zip: 94102 Telephone (xxx) xxx-xxxx: Facsimile (xxx) xxx-xxxx: (415) 929-5544 Email: karyn.gansecki@sce.com Clear Form
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ENERGY Advice Letter Keywords Affiliate Direct Access Preliminary Statement Agreements Disconnect Service Procurement Agriculture ECAC / Energy Cost Adjustment Qualifying Facility Avoided Cost EOR / Enhanced Oil Recovery Rebates Balancing Account Energy Charge Refunds Baseline Energy Efficiency Reliability Bilingual Establish Service Re-MAT/Bio-MAT Billings Expand Service Area Revenue Allocation Bioenergy Forms Rule 21 Brokerage Fees Franchise Fee / User Tax Rules CARE G.O. 131-D Section 851 CPUC Reimbursement Fee GRC / General Rate Case Self Generation Capacity Hazardous Waste Service Area Map Cogeneration Increase Rates Service Outage Compliance Interruptible Service Solar Conditions of Service Interutility Transportation Standby Service Connection LIEE / Low-Income Energy Efficiency Storage Conservation LIRA / Low-Income Ratepayer Assistance Street Lights Consolidate Tariffs Late Payment Charge Surcharges Contracts Line Extensions Tariffs Core Memorandum Account Taxes Credit Metered Energy Efficiency Text Changes Curtailable Service Metering Transformer Customer Charge Customer Owned Generation Mobile Home Parks Name Change Transition Cost Transmission Lines Decrease Rates Non-Core Transportation Electrification Demand Charge Non-firm Service Contracts Transportation Rates Demand Side Fund Nuclear Undergrounding Demand Side Management Oil Pipelines Voltage Discount Demand Side Response PBR / Performance Based Ratemaking Wind Power Deposits Portfolio Withdrawal of Service Depreciation Power Lines Clear Form
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. Emerging Markets and Technologies Demand Response Disadvantaged Communities Pilot Plan Installation of Grid Responsive Control Devices on Heat Pump Water Heaters in San Joaquin Valley Prepared by: Southern California Edison (U-338-E) February 8, 2019
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Contents 1. Purpose .................................................................................................................................... 3 2. Regulatory Background ..................................................................................................... 3 3. Demand Response Disadvantaged Communities Pilot Summary...................................... 5 4. Demand Response Pilot Plan Requirements ........................................................................ 6 a) Problem Statement ............................................................................................................................6 b) How the Pilot Will Address a Demand Response Goal or Strategy ..................................................................7 c) Pilot Objectives and Goals ....................................................................................................................8 d) Budget and Timeframe ........................................................................................................................8 e) Relevant Standards or Metrics .............................................................................................................10 f) Methods to Test Cost-Effectiveness of the Pilot .........................................................................................10 g) Evaluation, Measurement, and Verification Plan .......................................................................................10 h) Strategy to Identify and Disseminate Best Practices and Lessons Learned ......................................................11 5. Demand Response Disadvantaged Communities Pilot Requirements ............................ 11 1. Target Location ...............................................................................................................................12 2. Strategy to Target Residential and Small Commercial Customers in Disadvantaged Communities .........................13 3. Amount and Form of Economic Benefit for the Participating Customer, and Third Party, Including the Amount of Capacity Payments and How They Would Be Allocated ............................................................................................14 4. If and How the Proposed Pilot Will Be Bid into the CAISO Market ..................................................................14 5. Theory of the Pilot Intervention .............................................................................................................14 6. How the Utilities are Coordinating With the Disadvantaged Communities Advisory Group ....................................14 7. If and How the Utilities are Coordinating With Each Other in Their Proposed Ideas and Building Off Past and Current Pilots ...............................................................................................................................................15 8. How to Track Cost-Effectiveness for the Purpose of Informing Future Programs ................................................15 9. Justification for Choice of a Third-Party or the Utility; and Explanation for How the Third Parties Would Gain the Necessary Data for the Pilots..................................................................................................................16 10. Customer Protection Measures That Will Be Taken .................................................................................16 Southern California Edison ii
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1. Purpose The purpose of this document is to set forth SCE’s Pilot Plan targeting demand response in disadvantaged communities as directed in D.18-11-029.1 2. Regulatory Background In January 2017, Pacific Gas and Electric (PG&E), Southern California Edison (SCE) and San Diego Gas & Electric (SDG&E) (jointly, the IOUs) filed separate applications requesting approval and funding for their 2018-2022 demand response portfolios.2 On March 15, 2017, the Commission determined it is within the scope of the proceeding to determine whether the IOU’s proposed programs and portfolio “adequately focus on locating demand response participants in particular geographic areas, such as disadvantaged communities or areas of highest value to the grid that could also defer or displace investment in generation, transmission and distribution.”3 On December 21, 2017, the Commission issued D.17-12-003 that approved the IOU DR portfolio funding applications. It also determined there was insufficient record to direct the IOUs to make immediate program changes to target constrained local capacity areas and disadvantaged communities.4 However, the Commission noted that there was sufficient interest to initiate a stakeholder process to develop program changes, 5 and authorized a three-year budget of $2.5 million dollars, $1 million each for SCE and PG&E and $500,000 for SDG&E, for demand response pilot programs to target constrained local capacity areas and disadvantaged communities.6 The Commission also indicated that it would issue a subsequent decision to provide guidelines to the IOUs to develop and seek approval for pilot proposals based on the guidelines.7 1 Decision Resolving Remaining Application Issues For 2018-2022 DR Portfolios, D.18-11-029, Ordering Paragraph (OP) 11 at http://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M248/K670/248670669.pdf. 2 PG&E’s DR Application, A.17-01-012 at http://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M172/K519/172519506.PDF, SCE’s DR Application, A.17-01018 at http://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M172/K519/172519247.PDF, and SDG&E’s DR Application, A.17-01-019 at http://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M172/K519/172519249.PDF (consolidated). 3 DR Scoping Memo and Joint Ruling issued on March 15, 2017, A.17-01-012 p. 4, at http://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M180/K998/180998907.PDF. 4 DR Decision 2018-2022, D.17-12-003, FOF 141 at http://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M202/K275/202275258.PDF 5 Id. at 145-146. 6 Id., OP 58 7 Id. at 146 Southern California Edison 3
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On December 10, 2018, D.18-11-029 provided Commission guidelines for pilots targeting demand response and a regulatory process for submittal and approval of the pilot proposals. In that decision, the Commission stated that DR pilot plans should include the following elements: 1. Target location (which disadvantaged communities in a local capacity area). 2. Strategy to target residential and small commercial customers in disadvantaged communities. 3. The amount and form of economic benefit for the participating customer, and third party, including the amount of capacity payments and how they would be allocated. (Calculation of economic benefit for the participating customer should make explicit equity considerations that would reflect the relative value of capacity in a constrained area, and the relative difficulty of providing it in hot climate zones.) 4. If and how the proposed pilot will be bid into the CAISO market, e.g. as part of an existing program if it is not large enough to meet the CAISO requirements for aggregation size by sub-LAP. 5. Theory of the pilot intervention, e.g., a logic model, and how it would meet the purpose and goal adopted in this Decision. 6. How the Utilities are coordinating with the Disadvantaged Communities Advisory Group. 7. If and how the Utilities are coordinating with each other in their proposed ideas and building off past and current pilots. 8. How to track cost-effectiveness for the purpose of informing future programs. 9. Justification for choice of a third-party or the Utility; and explanation for how the third parties would gain the necessary data for the pilots. 10. Customer protection measures that will be taken.8 On December 19, 2018, in a parallel rulemaking (R.15-03-015),9 the Commission issued D.18-12-015 which approved SCE’s Affordable, Clean Energy through Efficient Electric Conversion Pilot10 (SJV Pilot). SCE’s SJV Pilot will offer new, efficient electric appliances at zero upfront cost to the customer, including space heating and cooling, cooking equipment, and water heaters to eligible customers who reside in the communities of California City, Ducor, and West Goshen and do not have access to natural gas.11 8 Decision Resolving Remaining Application Issues For 2018-2022 DR Portfolios, D.18-11-029 at pp. 74-75, at http://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M248/K670/248670669.pdf. 9 Order Instituting Rulemaking to Identify Disadvantaged Communities in the San Joaquin Valley and Analyze Economically Feasible Options to Increase Access to Affordable Energy in those Disadvantaged Communities. 10 San Joaquin Valley (SJV) DAC Pilot Projects Decision, D.18-12-015, O.P. 1 at http://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M252/K052/252052725.PDF 11 See SCE’s Proposed Pilot Projects in Response to Assigned Commissioner’s Scoping Memorandum and Ruling, filed on January 31, 2018, at http://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M214/K172/214172730.PDF. Southern California Edison 4
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SCE Proposes to combine and leverage these two pilots (the SCE DR DAC pilot and the SCE SJV Pilot) to both coordinate across these proceedings and increase the efficacy of the funding to enhance the pilot outcomes for the maximum overall benefits of SCE’s disadvantaged communities. 3. Demand Response Disadvantaged Communities Pilot Summary SCE’s Demand Response Disadvantaged Communities (DR DAC) pilot proposes to offer customers located in the communities of California City, Ducor, and West Goshen (located within the San Joaquin Valley) the necessary equipment and incentives to manage their heat pump water heaters (HPWH) in response to grid needs and demand response events. In partnership with SCE’s SJV Pilot, SCE will offer to install grid responsive control devices on HPWH offered to eligible customers by SCE’s SJV Pilot. Eligible customers can elect to allow SCE to manage their HPWH operations during demand response events throughout a specified participation period. Customers will earn $175 dollars in bill credit per period for participating in this Pilot. Although participating customers cannot override individual events while participating, they may dis-enroll from the pilot program at any time and subsequently forfeit their bill credit. Participating customers must participate in the pilot for the full period to receive the entire bill credit. SCE’s DR DAC Pilot demand response events will mirror event triggers in SCE’s Summer Discount Plan. Demand response events can be dispatched in response to emergencies, constrained electrical grids, high wholesale energy prices, or as part of testing.12 A DR DAC pilot demand response event can occur at any time during the year, may last up to 6 hours per day, and will not exceed 35 hours annually.13 The intent of this DR DAC Pilot is to gather information regarding DR participation among customers located in DACs as well as performance of the HPWHs. Information gathered from this pilot will be used to inform future demand response program design to better target customers located in DACs and to test the feasibility of a similar program in the future. 12 Please see SCE’s Schedule D-SDP Domestic Summer Discount Plan, Special Conditions 7 for SDP Event Triggers at https://www1.sce.com/NR/sc3/tm2/pdf/ce342.pdf. 13 SCE is considering using its Experimental Schedule UCLT Utility-Controlled Load Tests tariff, which limits the maximum test event hours to 35 hours per service account per calendar year, (see Special Conditions 2) at https://www1.sce.com/NR/sc3/tm2/pdf/ce60-12.pdf. Southern California Edison 5
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SCE’s DR DAC pilot is leveraging SCE’s SJV pilot project14 to increase the effectiveness of the limited budget approved in D.17-12-003.15 As advised in D.18-11029, utilities should coordinate as much as possible and leverage opportunities to expand or build on forthcoming pilots. Additionally, the DR DAC Pilot will coordinate with other IOUs’ California Alternate Rates for Energy (CARE) and Energy Savings Assistance (ESA) Programs to study load profile data on low income customers as ordered in D.17-12-009.16 As such, SCE will be coordinating across its DR DAC and SJV pilots, as well as the IOUs’ CARE / ESA programs to maximize the DR DAC Pilot’s limited budget and leverage information, where feasible. 4. Demand Response Pilot Plan Requirements D.12-04-045 established the guidelines for demand response pilot programs and requires that all future demand response applications shall include a Pilot plan for every Demand Response Pilot proposed.17Each Pilot Plan should contain the following: • • • • • • • • A problem statement; How the pilot will address a DR goal or strategy; Specific objectives and goals for the pilot; A clear budget and timeframe; Relevant standards or metrics; Methodologies to test the cost-effectiveness of the pilot; An Evaluation, Measurement, and Verification plan; and A strategy to identify and disseminate best practices and lessons learned. SCE addresses each of the following elements below. a) Problem Statement As discussed in the Assigned Commissioner’s Office (ACO) Proposal for Demand Response Pilot Plans to Benefit Disadvantaged Communities, issued on June 15, 2018, existing gas power plant capacity in California is located disproportionately in 14 SJV DAC Pilot Projects Decision, D.18-12-015 at http://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M252/K052/252052725.PDF. 15 DR Decision 2018-2022, D.17-12-003 approved $1M dollars for SCE to conduct its pilot. O.P.58 at http://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M202/K275/202275258.PDF. 16 Low Income Decision, D.17-12-009, p. 322-323 at http://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M202/K113/202113200.pdf. 17 DR Decision 2012-2014, D.12-04-045, OP 80 at pp. 229-230 at http://docs.cpuc.ca.gov/PublishedDocs/PUBLISHED/GRAPHICS/165317.PDF. Southern California Edison 6
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disadvantaged communities, and targeted demand response programs can reduce localized air pollution and other negative impacts from living near gas plants. Targeted demand response programs can also reduce the need for investments in gas generation, shift electricity usage to better match renewable energy production, and reduce pollution from the dispatch and cycling of gas plants to meet system energy needs.18 Lastly, demand response in disadvantaged communities can provide economic benefits to program participants by reducing their electricity bills. b) How the Pilot Will Address a Demand Response Goal or Strategy As part of SCE’s SJV Pilot, SCE is offering, among other things, to replace existing fossil-fuel-burning water heaters with cleaner and more efficient HPWHs of appropriately equal size for eligible customers. In partnership with SCE’s SJV Pilot, SCE’s DR DAC Pilot will offer to convert the HPWH into a grid-responsive water heaters by adding a grid responsive control device. Eligible customers can elect to allow SCE to manage their HPWH operations during demand response events throughout a specified participation period. The pilot as designed will support the demand response goal established in D.16-09056. D.16-09-056 established the following goal for demand response programs. Commission regulated demand response programs shall assist the State in meeting its environmental objectives, cost-effectively meet the needs of the grid, and enable customers to meet their energy needs at a reduced cost.19 The DR DAC Pilot as designed will support the needs of the grid by incentivizing customers to allow SCE to manage their HPWH in response to grid needs and demand response events. Participating customers cannot override individual events while participating but may dis-enroll from the pilot program at any time and subsequently forfeit their bill credit. Although inconvenient, the program will allow customers to meet their energy needs at a reduced cost by providing a bill credit to participating customers. 18 DR DAC Straw Proposal, A.17-01-012, Assigned Commissioner’s Office (ACO) Proposal for Demand Response Pilot Plans to Benefit Disadvantaged Communities, p. 1 at http://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M216/K330/216330837.PDF. 19 Decision Adopting Guidance for Future DR Portfolios and Modifying Decision 14-12-024, D.16-09-056, O.P. 7 at http://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M167/K725/167725665.PDF. Southern California Edison 7
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c) Pilot Objectives and Goals As discussed in the Assigned Commissioner’s Office (ACO) Proposal for Demand Response Pilot Plans to Benefit Disadvantaged Communities, issued on June 15, 2018, “the purpose of conducting the pilots envisioned by D.17-12-003 is to further a policy objective of enhancing the economic and/or environmental benefits that California’s investments in demand response programs provide to disadvantaged communities.”20 The goal for this pilot “is to lead to the identification of policy recommendations to improve existing programs, or to contribute to the development of new programs, to advance this policy objective.”21 In addition, the goal of SCE’s DR DAC Pilot is to gain insight into how aggregated distributed resources can be used to benefit the grid and simultaneously offer residents of disadvantaged communities the ability to realize economic benefits through participation in a Demand Response program. Pilot results could potentially inform how best to offer DR programs in disadvantaged communities and are intended to be used to identify policy recommendations to improve existing demand response programs and contribute to the development of new programs. d) Budget and Timeframe Budget D.17-12-003 authorized $1 million for SCE’s DR DAC Pilot Program during the 2018 to 2022 program cycle. In addition, D.17-12-003 directed that ten percent of the total authorized budget be set aside for evaluation of the success of the pilot.22 Given the size of the budget, D.18-11-029 recommends that IOUs leverage opportunities to expand or build on forthcoming pilots or other funded research.23 As such, SCE’s DR DAC pilot will leverage SCE’s SJV pilot project24 in order to maximize the information to be gathered and lessons to be learned. SCE’s DR DAC Pilot and SJV Pilot will offer to replace 449 fossil-fuel-burning water heaters with electric HPWHs, each equipped with a grid-responsive control device. The SJV Pilot will fund all 449 HPWHs and 138 of the control devices.25 SCE’s Emerging Products and Technologies (EP&T) program will jointly fund 12 of the control devices as part of a 20 DR DAC Straw Proposal, A.17-01-012, Attachment A, ACO Proposal for DR Pilot Plans to Benefit Disadvantaged Communities, p. 6 at http://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M216/K330/216330837.PDF. 21 Id. 22 DR Decision 2018-2022, D.17-12-003 at pp. 146 at http://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M202/K275/202275258.PDF. 23 Decision Resolving Remaining Application Issues For 2018-2022 DR Portfolios, D.18-11-029 at pp.73, at http://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M248/K670/248670669.pdf. 24 SJV DAC Pilot Projects Decision, D.18-12-015 at http://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M252/K052/252052725.PDF. 25 SCE’s Comments on PD Approving SJV DAC Pilot Projects filed November 29, 2018, R.15-03-010, p.1 at http://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M249/K622/249622896.PDF. Southern California Edison 8
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detailed technical assessment study.26 The DR DAC Pilot will fund the remaining 299 control devices. The estimated costs apportioned to the DR DAC pilot are shown in the table below. Table 1: DR DAC Pilot Proposed Budget Item Qty Unit Cost Measurement & Evaluation1 Grid-Responsive Control Devices2 Marketing DR Pilot to Customers / Consumer Protection3 Study Plan Development of the Grid Response Water Heater Study DR Customer Incentives (for two participation periods) Administrative Costs4 Grand Total 299 449 2,000 100 1 Funded by DR DAC Pilot 100,000 598,000 44,900 100,000 299 - 175 / period - 104,650 52,450 1,000,000 D.17-12-003 allocates ten percent of the total authorized budget for evaluation of the pilot 2 Includes budget for the grid responsive communication device, installation of the device and cellular communication 3 Includes Consumer Protection as described in Section 5.10. 4 Includes general administration and direct implementation expenses Timeline SCE’s SJV pilot will begin pilot implementation in 2019. During the first year of pilot implementation, 12 customers will be selected to participate in a study led by SCE’s EP&T program programs. The EP&T study will assess the technical performances of the grid response control devices which includes how well the HPWH responds to demand response signals and which strategies are best for managing HPWH operating during demand response events. SCE will then offer the remaining 299 customers an opportunity to participate in its DR DAC pilot in 2020-2021. Participants will be provided a grid response control device and an incentive to allow SCE to manage HPWH operation during energy events. Following installation of the HPWHs and control devices, the DR DAC Pilot will call energy events concurrent with Summer Discount Plan (SDP)27. In 2022, SCE will analyze and evaluate all available data collected to determine if the DR DAC pilot should be developed into a future program. 26 SCE’s Pilot Proposal Update and Comments on Questions, filed on September 10, 2018, p. 15 at http://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M236/K010/236010069.PDF. 27 SCE’S Domestic Summer Discount Plan Schedule D-SDP at https://www1.sce.com/NR/sc3/tm2/pdf/ce342.pdf. Southern California Edison 9
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e) Relevant Standards or Metrics D.12-04-045 requires all demand response pilots to include information on relevant standards or metrics or a plan to develop a standard against which the pilot outcomes can be measured.28 Benchmarking standards and metrics for grid responsive control devices are still being investigated at this time. This pilot will help inform if a grid responsive control device will be able to provide flexible load control. As such, all approved grid responsive control devices must be able to communicate DR signals through a communication plan. Each device will include its own cellular data plan that will be used to transmit data and signals to and from SCE’s server. The focus of the DR DAC Pilot will be on understanding customer experience with the HPWHs and demand response performance because the technology is still being evaluated at this time. Technologies will be identified and studied in the Grid Responsive Water Heater Study conducted by SCE.29 Additionally, devices will be set to mirror the events of SCE’s SDP.30 f) Methods to Test Cost-Effectiveness of the Pilot SCE intends to track the cost-effectiveness of the Pilot based on the most recent ex ante protocols published by the CPUC to the extent that SCE is able to quantify costs and benefits of the pilot.31 As stated in the demand response cost effectiveness protocols, a qualitative analysis of the cost or benefit should be provided for costs and benefits that cannot be quantified.32 The information gathered from tracking the empirical values to provide an assessment the cost-effectiveness during the pilot will be used to inform future programs. g) Evaluation, Measurement, and Verification Plan The DR DAC Pilot intends to leverage information gained from the EP&T study and the data gathered from the SJV Pilot. As discussed above, as part of the SJV Pilot, SCE’s EP&T Program will conduct a 12 customer Grid-Responsive HPWH study to determine whether a grid responsive HPWH can be utilized to benefit the grid and how residents respond to this technology to manage energy consumption usage patterns. 28 DR Decision 2012-2014, D.12-04-045, p.183 at http://docs.cpuc.ca.gov/PublishedDocs/PUBLISHED/GRAPHICS/165317.PDF. 29 SJV DAC Pilot Projects Decision, D.18-12-015, p. 29 at http://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M252/K052/252052725.PDF. 30 SCE’s Domestic Summer Discount Plan Schedule D-SDP at https://www1.sce.com/NR/sc3/tm2/pdf/ce342.pdf. 31 CPUC Demand Response Cost-Effectiveness Protocols at http://www.cpuc.ca.gov/general.aspx?id=7023. 32 2016 Demand Response Cost-Effectiveness Protocols , Section 1G at http://www.cpuc.ca.gov/WorkArea/DownloadAsset.aspx?id=11573. Southern California Edison 10
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The DR DAC Pilot will expand its study across a larger population. The DR DAC Pilot EM&V study will be conducted on an opt-in basis on all 449 SJV participants, where SJV homeowners who have been provided electric appliances will be invited to participate in surveys regarding their heat pump water heater usage. Using this EM&V plan, SCE aims to understand the likelihood of customer participation to determine the optimal DR event dispatch windows, optimal incentive structures, customer profiles, as well as potential for scaling the program to other SCE territories. The main objective of the DR DAC EM&V plan will be to evaluate the feasibility of utilizing demand response to control heat pump water heaters. Surveys will assess participants’ attitudes toward DR responsive HPWH, identify effective incentive structures for participation, and examine if and how the peak time of usage of water heaters coincide with SCE’s peak times for demand response. Surveys will be distributed at the beginning of the study, and depending on the information obtained from the participants, another survey will be sent out after 6-12 months to understand any change in attitude or perception of DR events. To the extent possible, the DR DAC pilot will coordinate its surveys with the SJV pilot to minimize impact to customers. Customer participation will be assessed and the number of customers who opt out over the course of the pilot will be tracked. To earn the entire bill credit, customers must complete the full term of their participation period. Survey questions will also assess the reasons on customer opt-out and identify barriers to effective participation such as inadequate incentives, and health, work, or other reasons for non-participation. Additionally, if the number of customers opting-in to the DR DAC Pilot result in an adequate sample size, SCE may be able to identify load shapes using their interval meter data. However, since SCE will not know the number of participants in this pilot until enrollment is completed, SCE cannot predict whether any statistically significant data will be obtainable. h) Strategy to Identify and Disseminate Best Practices and Lessons Learned SCE’s DR DAC EM&V report will be provided to the Disadvantaged Communities Advisory Group and to the Demand Response Measurement & Evaluation Committee (DRMEC) so that best practices and lessons learned from this pilot can be disseminated to the appropriate stakeholder groups and be leveraged for implementation in future DR programs. 5. Demand Response Disadvantaged Communities Pilot Requirements Southern California Edison 11
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As discussed in Section 2, On December 10, 2018, the Commission issued D.18-11029 which provided guidance for the pilots targeting demand response in disadvantaged communities. The Commission provided guidance that pilot plans should include the following elements. 1. Target location (which disadvantaged communities in a local capacity area). 2. Strategy to target residential and small commercial customers in disadvantaged communities. 3. The amount and form of economic benefit for the participating customer, and third party, including the amount of capacity payments and how they would be allocated. (Calculation of economic benefit for the participating customer should make explicit equity considerations that would reflect the relative value of capacity in a constrained area, and the relative difficulty of providing it in hot climate zones.) 4. If and how the proposed pilot will be bid into the CAISO market, e.g. as part of an existing program if it is not large enough to meet the CAISO requirements for aggregation size by sub-LAP. 5. Theory of the pilot intervention, e.g., a logic model, and how it would meet the purpose and goal adopted in this Decision. 6. How the Utilities are coordinating with the Disadvantaged Communities Advisory Group. 7. If and how the Utilities are coordinating with each other in their proposed ideas and building off past and current pilots. 8. How to track cost-effectiveness for the purpose of informing future programs. 9. Justification for choice of a third-party or the Utility; and explanation for how the third parties would gain the necessary data for the pilots. 10. Customer protection measures that will be taken.33 SCE addresses each of the following elements below. 1. Target Location D.18-11-029 directs the utilities to target disadvantaged communities in local capacity areas.34 SCE’s DR DAC Pilot will target customers who reside in the communities of California City, Ducor, and West Goshen. Even though these communities are not located in local capacity areas, SCE believes given the limited funding, more could be learned from this DR DAC Pilot by collaborating with the SJV Pilot and focusing on the same disadvantaged communities. Collaborating with the SJV pilot is expected to increase environmental benefits and reduce energy costs for pilot participants in 33 Decision Resolving Remaining Application Issues For 2018-2022 DR Portfolios, D.18-11-029, p. 74-75, at http://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M248/K670/248670669.pdf. 34 Id. at 74. Southern California Edison 12
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California City, Ducor, and West Goshen as described in further detail below. And as advised by D.18-11-029, SCE is encouraged to coordinate as much as possible and leverage opportunities to expand or build on forthcoming pilots.35 2. Strategy to Target Residential and Small Commercial Customers in Disadvantaged Communities SCE is targeting residential customers in single family dwellings who reside in the communities of California City, Ducor, and West Goshen. SCE’s DR DAC pilot will not be offered to small commercial customers. SCE explored piloting the grid-responsive water heaters with commercial customers such as schools, fitness centers, and community centers; however, commercial entities vary widely in their use of hot water during peak hours as compared to residential customers. As a result, SCE has limited its DR DAC pilot to residential customers to develop a clear understanding of how grid responsive HPWHs impact the residential segment. This approach aligns with SCE’s SJV Pilot approach. SCE will target eligible residential customers for the DR DAC Pilot upon their enrollment in SCE’s SJV Pilot. As such, SCE’s DR DAC Pilot will use the same eligibility criteria as the SJV Pilot. 36 Below are some of the eligibility criteria for the SJV Pilot and the DR DAC Pilot. 1. Pilot participants must be SCE customers, or become SCE customers. 2. Participants must lack access to natural gas service. 3. The property owner must timely authorize work on the building. 4. Pilot participants must be residential customers with an enclosed garage at the site. This is so that the enclosure will maintain a regulated indoor temperature.37 5. Customers must be residents of California City, Ducor or West Goshen. 6. Customers must be on a CARE rate.38 35 Id. at 73 SCE’s Proposed Pilot Projects in Response to Assigned Commissioner’s Scoping Memo and Ruling filed January 31, 2018, p. A-12, available at http://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M214/K172/214172730.PDF. 37 SCE’s SJV DAC Pilot Proposal Update and Comments on Questions, Filed September 10, 2018, p.15 at http://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M236/K010/236010069.PDF. 38 SJV DAC Pilot Projects Decision, D.18-12-015, p.26-27 at http://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M252/K052/252052725.PDF. 36 Southern California Edison 13
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3. Amount and Form of Economic Benefit for the Participating Customer, and Third Party, Including the Amount of Capacity Payments and How They Would Be Allocated Both customers and third parties will benefit economically from SCE’s SJV and DR DAC pilots. All customers who are eligible to participate in the SJV Pilot will be assessed to receive new electric appliances including a new HPWH. Additionally all participants may receive a grid-responsive control device at no cost from either the SJV Pilot or DR DAC pilot. Furthermore, customers who agree to participate in SCE’s DR DAC Pilot will receive a financial incentive in the form of a $175 annual bill credit, if they complete the full participation term of the pilot. Due to a lack of historical data regarding HPWHs in the San Joaquin Valley, capacity payments will not be used at this time. Data gathered from the DR DAC Pilot may be used to determine capacity payments in the future. Through SCE’s SJV and DR DAC Pilots, third-party contractors will also benefit economically as SCE intends to hire contractors to perform the installation of the appliances, the grid responsive control devices, and any necessary structural upgrades to the dwellings required to support the appliances. SCE intends to coordinate between the pilots and work with contractors to minimize inconvenience to customers. 4. If and How the Proposed Pilot Will Be Bid into the CAISO Market SCE does not intend to bid the DR DAC Pilot into the CAISO market. Depending on the EM&V study results of the pilot, SCE may seek authority to implement a future DR program that could be bid into the CAISO market. 5. Theory of the Pilot Intervention Please see Section 4b. and Section 4c. 6. How the Utilities are Coordinating With the Disadvantaged Communities Advisory Group The IOUs engaged with the Disadvantaged Communities Advisor Group (DACAG) and discussed the demand response pilots targeting disadvantaged communities with the DACAG during their regularly scheduled meetings. On January 25, 2019, on behalf of the other IOUs, PG&E presented the requirements of demand response pilots targeting disadvantaged communities as provided in D.18-11-029. SCE is scheduled to present Southern California Edison 14
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an overview of its DR DAC Pilot at the DACAG’s next scheduled meeting on February 22, 2019. 7. If and How the Utilities are Coordinating With Each Other in Their Proposed Ideas and Building Off Past and Current Pilots On December 7, 2018, Southern California Edison, Pacific Gas and Electric, and San Diego Gas and Electric discussed the potential for collaboration on their DR DAC Pilots. It was determined that there is no service area overlap between any of the IOUs pilots and therefore coordination was not feasible. However, as discussed above, SCE does intend to share lessons learned for its DR DAC Pilot. SCE will provide its DR DAC EM&V report to the Disadvantaged Communities Advisory Group and to the Demand Response Measurement & Evaluation Committee (DRMEC) so that lessons from this pilot can be leveraged for implementation in future DR programs. As described above, SCE intends to build its DR DAC Pilot on its SJV Pilot in order to maximize the limited budget to benefit customers in DAC communities. Because this is the first time HPWHs are being studied in the San Joaquin Valley, there are no prior pilots upon which to build. In addition, the DR DAC Pilot will work with SCE’s CARE and ESA Programs for low income customers. D.17-12-009 directed the IOUs’ CARE / ESA Programs to work with a disaggregation vendor to create individual CARE Program customer reports that illustrated disaggregate household usage by end use, over time.39 These reports are to be accessible to Energy Savings Assistance (ESA) Program contractors and customers and should be coordinated with the MyEnergy/My Account platforms.40 Phase 1 of the report is expected to be completed in April 2019. 8. How to Track Cost-Effectiveness for the Purpose of Informing Future Programs SCE discusses how it will track the cost effectiveness of this program to inform future program in Section 4.f. 39 Low Income Decision D.17-12-009, p. 322-323 at http://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M202/K113/202113200.pdf 40 Id. at OP 97 Southern California Edison 15
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9. Justification for Choice of a Third-Party or the Utility; and Explanation for How the Third Parties Would Gain the Necessary Data for the Pilots SCE intends to administer the DR DAC Pilot activities, instead of using a third-party administrator, because SCE is also administering SCE’s SJV Pilot. Having both pilots under the same administrator is anticipated to result in lower costs and more effective coordination and implementation of the two pilots. SCE will be responsible for overall project management activities: scoping work, hiring contractors where necessary, ensuring all parties coordinate and meet their timeline and deliverables. This includes selecting, procuring, and coordinating third-party contractors and installers; coordinating procurement activities, and other related activities. Stakeholders in this work stream include SCE, community-based organizations (CBOs), any partners on the project, and the contractors and subcontractors working on the project.41 To the extent permitted by applicable collective bargaining agreements, including, but not limited to, various project labor agreements, the majority of field work will be bid out to one or more third parties. Contractors that employ and/or train a local workforce will receive priority consideration during the selection process. SCE will follow established contractor procurement guidelines when selecting third party contractors and implementers. SCE will have regular check-ins and discussions with the third parties involved to ensure they have the necessary data for the pilot. Many activities rely on gathering data about, or from, pilot communities and their residents. SCE will work closely with the stakeholders and Community Based Organizations to ensure that appropriate forms of community engagement are incorporated into this plan. 10. Customer Protection Measures That Will Be Taken In its Comments submitted in response to the DR proposed decision42, Olivine expressed concern regarding lack of consumer protections and recommends that the pilots “include guidelines on consumer protection, a customer “bill of rights” and energy professionals associated with the pilots should be required to be trained on those guidelines and customer rights.”43 Olivine suggests that the utilities can model their 41 SCE’s Proposed Pilot Projects In Response to Assigned Commissioner’s Scoping Memo and Ruling filed January 31, 2018, p. A-14 at http://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M214/K172/214172730.PDF 42 Proposed Decision Resolving Remaining Application Issues for 2018-2022 DR Portfolios, issued October 25, 2018 at http://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M234/K963/234963092.PDF 43 Comments of Olivine, Inc , filed on November 14, 2018, p.4 at http://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M241/K165/241165638.PDF Southern California Edison 16
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consumer protection measures on the consumer protection guidelines that were developed in response to consumer complaints by net energy metering solar consumers.44 D.18-09-044 described the solar consumer issues as aggressive and misleading sales tactics and marketing practices. Such practices include persistent robocalls; pressure to sign a contract or agreement on the same day by solar salespersons; misrepresentation of the utilities’ role; and confusing, incomplete or incorrect information about the costs and benefits of rooftop solar, including estimated bill savings and value.45 Olivine also suggests that community members who participate in the pilot should not be required to make any purchase to participate in the pilot.46 The Commission notes in D.18-11-029 that there is a lack of record on consumer protection measures for the pilots targeting disadvantaged communities, so the Commission will not adopt additional guidelines on consumer protection. However, the Commission will require that the Utilities include adequate consumer protection measures so that customers living in disadvantaged communities are not taken advantage of.47 To protect customers in DACs, SCE will provide the necessary equipment needed to participate in SCE’s DR DAC Pilot at no cost to the customer. In addition, SCE will provide pilot participants an incentive to participate in SCE’s pilot. The DR DAC Pilot will also coordinate with SCE’s SJV Pilot to work with the Community Based Organizations (CBOs) to develop measures to protect customers. Throughout the pilot, SCE will work with CBOs to provide in-depth energy education including an overview of the new appliances, discussions about time-of-use rates, and applicable tariffs.48 The CBOs include: • Self Help Enterprises • Leadership Council for Justice and Accountability (Represented on DACAG) • Center for Race, Poverty and the Environment (Represented on DACAG) GRID Alternatives’ CBO network (Represented on DACAG) SCE will use the information gathered from the DR DAC Pilot to learn about DAC communities and how best to engage with community members, to then develop tailored, targeted programs that will have a greater chance at successful enrollment and participation. 44 Id. Decision Adopting Net Energy Metering Consumer Protection Measures Including Solar Information Packet, D.18-09-044, p.8 at http://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M230/K892/230892616.PDF 46 Comments of Olivine, Inc , filed on November 14, 2018, p.4 at http://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M241/K165/241165638.PDF 47 Decision Resolving Remaining Application Issues For 2018-2022 Demand Response Portfolios, D.18-11-029, p.85 at http://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M248/K670/248670669.pdf. 48 SCE’s San Joaquin Valley DAC Pilot Plan, p. A-10 at http://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M214/K172/214172730.PDF. 45 Southern California Edison 17
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