Process - PG&E, Pacific Gas and Electric · Process Purpose Pacific Gas ... Commission staff’s...

Erik Jacobson Director Regulatory Relations

Pacific Gas and Electric Company 77 Beale St., Mail Code B10C P.O. Box 770000 San Francisco, CA 94177 Fax: 415-973-1448

January 3, 2017 Advice 4992-E (Pacific Gas and Electric Company ID U 39 E) Public Utilities Commission of the State of California Subject: Electric Rule 24 Direct Participation Enrollment Click-Through

Process Purpose Pacific Gas and Electric Company (PG&E) hereby submits this Advice Letter (AL) in compliance with Ordering Paragraph (OP) 10 of Decision (D.) 16-06-008. PG&E seeks approval for improvements to the Electric Rule 24 process for demand response providers to obtain customer authorization to access the customer’s data for direct participation in the California Independent System Operator’s (CAISO) wholesale market. The improvements were developed by PG&E, Southern California Edison (SCE), San Diego Gas & Electric (SDG&E), the California Public Utilities Commission (CPUC or Commission), other stakeholders, and interested parties, under Energy Division guidance, for Solution 3 described in this AL.

Background D.12-11-025 ordered the implementation of Electric Rule 24 (Rule 24) for PG&E and SCE and Electric Rule 32 (Rule 32) for SDG&E1, which allows third-party Demand Response Providers (DRPs) access to retail customers’ data for purposes of registering and using retail customers’ loads in the CAISO market for purposes of demand response, after obtaining the customer’s authorization. This decision ordered PG&E, SCE, and SDG&E, jointly the utilities, to work with stakeholders to finalize the Commission staff’s proposed Rule 24 and to create related documents to support this rule. The related documents included a specific Customer Information Service Request (CISR) form for DRPs (CISR-DRP), the Service Agreement between the DRP and the utility, the Registration Form for DRPs to register with the Commission, and a standard

1 Henceforth, any reference to Rule 24 applies to Rule 24 for SCE and PG&E, and Rule 32 for

SDG&E.

Advice 4992-E - 2 - January 3, 2017

residential and small commercial customer notification letter that are used for the purposes of Rule 24. On October 10, 2013, PG&E filed Tier 3 Advice Letter (AL) 4298-E, on behalf of itself, SCE, and SDG&E, with the revised Rule 24 tariff and related documents. The Commission approved AL 4298-E on March 19, 2014, in Resolution E-4630, with modifications consistent with D.13-12-029, which addressed four Petitions for Modification (PFM) on D.12-11-025. This resolution ordered the IOUs to file modifications in a Tier 1 AL, which PG&E filed on behalf of itself, SCE, and SDG&E on February 18, 2014, under AL 4361-E, and subsequently on April 2, 2014, under AL 4361-E-A. The Commission approved both AL 4361-E and 4361-E-A on April 8, 2014. As described in D.16-06-008, part of PG&E’s process for electronic submission of a CISR-DRP used certain third party electronic signature verification vendors, which third party DRPs criticized as cumbersome for customers. As a result, the Commission found that “direct participation is an evolving process that can be improved.”2 The Commission ruled that the utilities should develop a “click-through” electronic signature process that starts and ends on a third-party DRP’s website and provides customer authentication and authorization for the utility to release the customer’s data to a third party DRP.3 It also ordered the utilities to meet with stakeholders to discuss how to simplify the direct participation enrollment process, and to file a consensus proposal in a Tier 3 AL, by November 1, 2016.4 The utilities and Energy Division hosted the first publicly noticed working group meeting with stakeholders and interested parties on Streamlining and Simplification of Direct Participation Enrollment Process on July 25, 2016. Subsequent publicly noticed meetings were held on August 24, September 13, September 29, October 5, October 18, and November 3, as well as two other meetings on November 16 and December 1. These in-person meetings were supplemented by calls on August 4, September 6, September 28, September 30, October 26, November 10, and November 22. The working group included the utilities, the Energy Division, the Office of Ratepayer Advocates (ORA), Advanced MicroGrid, the California Energy Efficiency Industry Council, Chai Energy, CPower, eMotorWerks, EnergyHub, EnerNOC, Mission:Data, NRG, OhmConnect, Olivine, SolarCity, Stem, Sunrun, UtilityAPI, and WeatherBug, as well as individuals interested in the working group discussions but who may not be parties. The Assigned Commissioner’s office also attended several of the noticed meetings.

2 D.16-06-008, Finding of Fact (FoF) 27. 3 D.16-06-008, pages 11-14; Findings of Fact (FoF) 5, 6, and 7; Conclusions of Law (CoL) 2 and

3; OP 1. 4 D.16-06-008, CoL 13; OP 9 and 10.


Given the state of ongoing discussions about business requirements, different solutions, and the diversity of opinions in the group, SCE filed a request for an extension of the November 1, 2016 date to file a Tier 3 AL pursuant to Ordering Paragraph (OP) 10 of D.16-06-008, on behalf of the utilities. The utilities requested a four-month extension to March 1, 2017. Several parties responded5 objecting to the utilities’ request for extension, and argued for only a 30-day extension. On October 28, 2016, SDG&E filed a response to the objections on behalf of the utilities, providing additional information on why a four-month extension was necessary to properly develop a budget at the level of accuracy the Energy Division requested. The utilities pointed out that providing a better response on March 1, 2017, instead of a more rushed response sooner, could limit delays to the schedule and potential increases in costs potentially identified at a later date when the remaining uncertainty over the DRPs’ business needs could be reduced during the working group process. On November 1, 2016, the Executive Director issued a letter denying the four-month extension, but granting a two-month extension until January 1, 2017, citing urgency to have a solution in place for the 2018 DRAM and stating that the utilities had provided insufficient information on why a delay was requested. This AL is filed in accordance with this January 1, 2017, extension.

Summary of Working Group Process The working group convened more than 16 times, often on a weekly or biweekly schedule, to discuss the Streamlining and Simplification of the Direct Participation Enrollment Process. PG&E took notes that were distributed to the members of the working group for six of these meetings.6 The working group categorized its work into the following key areas:

• A long-term solution for customer authentication and authorization using the “click-through” process;

• Shorter-term improvements that could be implemented prior to the implementation of the long-term solution;

• The data delivery and exchange process, including a revised data set for Rule 24; and

• Simplification of the Commission-approved CISR-DRP form.

Throughout the process the Energy Division provided additional guidance on the scope and contents of the advice letter. In particular, during the October 5 noticed meeting, the Assigned Commissioner’s office ordered the utilities and third-party DRPs (and

5 CPower, EnerNOC, Inc., and EnergyHub on October 25, 2016; SolarCity Corporation on

October 27, 2016; Mission:data Coalition, Chai Energy, WeatherBug Home, and UtilityAPI, Inc., on October 28, 2016; California Energy Efficiency Industry Council on October 31, 2016.

6 Notes were provided for the July 25, August 24, September 13, October 18, October 26, and November 22 meetings.


interested parties) to provide an informal status report on behalf of the workshop participants describing the two long-term solutions proposed, and listing the pros and cons and application to other Distributed Energy Resources (DERs) for each. On October 12, 2016, PG&E served the Informal Status Report on the service list for A.14-06-001, et. seq., and describes the two solutions here for reference:7 Solution 1

The customer would begin on the third party DRP site and provide specific customer information on the third party site, which is sent directly from the browser to the utility (as opposed to first going through the third party’s backend database or supporting systems before being passed to the Utility). The information would then be authenticated by the utility’s back-end systems. Once authenticated, the customer would authorize the release of data on the DRP site and the parameters would be sent to the utility to complete the process. The authentication and authorization steps could, at the option of the DRP, be completed on a single screen. The customer would not leave the DRP website during this process; however, this solution requires the utilities to build one, or possibly two, custom API endpoints to authenticate the customer’s identity and authorize the release of data to the DRPs. In addition, new code and associated security measures must be developed to ensure customer specific information is sent directly from the browser to the utility as opposed to being first saved by the third party’s backend systems supporting the DRP site.

Solution 3

The customer would begin on the third party DRP site, but then be directed to log into the utility site, where existing utility privacy controls exist to authenticate the customer. Once authentication is completed, the customer authorizes the release of his or her data and is redirected back to the DRP site automatically to complete the process. While the process starts and ends on the DRP’s website, the customer provides his or her authentication and authorization information

7 The working group initially proposed three solutions, referred to as Solution 1, Solution 2, and

Solution 3, but Solution 2 was eliminated early on due to concerns about the manner in which a customer’s Personally Identifiable Information (PII) is transmitted across third party services, which is a privacy concern for the utilities.

The status report follows the template which Energy Division staff provided electronically at the October 5 workshop, and includes additional guidance provided on October 10 by email. It may be accessed electronically by following the instructions below:

1) Go to: https://pgera.azurewebsites.net/Regulation/search 2) Select “Demand Response OIR 2013 [R.13-09-011]” or “Demand Response Rule 24 Cost Recovery [A.14-06-001] from the dropdown menu. 3) Select 10/12/2016 as the date and PGE as the party to narrow the search criteria. 4) Click Search.


directly on the utility website, utilizing enhancements to simplify and streamline an existing Green Button Connect (GBC) system, which is an international, industry standards-based solution.

In response to the Informal Status Report, the Energy Division provided guidance during the October 18 working group meeting,8 which the Energy Division further refined in subsequent working group meetings through the December 1 meeting. Energy Division Guidance, Issued in Conjunction with the Assigned Commissioner’s Office This advice letter should contain:

• Plans for implementing click-through Solution 3 (long-term solution) and cost recovery, with the following considerations:

o A description of the business requirements as proposed by the DRPs in the Informal Status Report in Appendix E;

o Budget estimates and cost recovery within a 50 percent margin of error; o A phased implementation timeline, including differentiation between what

can be provided in time for the 2018 DRAM9; o Additional considerations for how Solution 3 could be extended to support

“other DERs” (Distributed Energy Resources); and o Inclusion of a reporting process for tracking API performance metrics.

• A schedule for developing an advice letter for implementing Solution 1, including cost recovery.

• Plans to incorporate a “full data set”, as described by the DRPs in Appendix B of the Informal Status Report, with 90-second synchronous data requests (to the extent possible within this AL) at the completion of the authorization process, which requires modifications to Rule 24.

8 The Energy Division and the Assigned Commissioner’s Office provided verbal guidance

accompanied by a PowerPoint presentation during the October 18 working group meeting, and distributed the presentation by email the same day to the working group distribution list. Further guidance was provided during the November 3 click-through working group meeting, in conjunction with the Assigned Commissioner’s Office, both verbally and through a presentation that was presented and distributed to the working group that day. The Energy Division clarified its guidance over the following working group meetings and calls: November 10, November 16, November 22, and December 1.

9 PG&E expects that the majority of DRPs could begin to register customers around June 2017 to support deliveries in January 2018; however, this is not expected to be enough time for the utilities to implement click-through Solution 3 given a January 3, 2017, AL filing and the subsequent time for a Tier 3 AL final resolution. However, the Energy Division clarified that “in time for” the 2018 DRAM could be considered the end of the first quarter of 2018 to support a summer 2018 season.


• Discussion of the CISR-DRP simplification work, which may require the utilities to file a subsequent AL describing modifications to the CISR-DRP and Rule 24 (Tier 2 if no cost recovery is needed, Tier 3 if it is necessary).

• Historical spending on Green Button Connect per D.13-09-025. • Discussion of any Petitions for Modification (PFMs) that would need to be filed to

support this AL.

Green Button Connect Development and Spending

Background on the Green Button Standard Used for Solution 3

Solution 3, as envisioned by the working group, builds upon the Green Button Standard, which is an easy way to access and share customer data. PG&E was one of the first utilities to respond to the White House’s call-to-action on a vision to provide consumers with easy-to-understand data about their household energy use. By December 2011, PG&E launched Green Button Download. Using this tool, customers can download, in human or machine-readable format, their usage and associated cost per Service Agreement (SA). Customers can use this data themselves or share this file with a third party of their choice. In 2011, the CPUC ordered the IOUs to file an application to provide third party access to customer usage data via the utility backhaul when authorized by the customer (D.11-07-056, OP 8). The CPUC further specified that all IOUs should propose a common format and be consistent with ongoing national standards in their applications. In September 2013, PG&E received approval from the CPUC to move forward with the proposed Customer Data Access (CDA) implementation plan using the Green Button Connect standard in D.13-09-025. Green Button Connect (GBC) builds on the Green Button Download concepts and allows customers to set on-going, on-demand access to their data to an authorized third party. PG&E began work on its solution in late 2013 and launched Green Button Connect My Data (CMD), which PG&E later renamed Share My Data (SMD), in 2015. This product allows customers to share their gas and electric usage, billing, and account information, on an on-going basis and across many Service Agreements, with a registered third party of their choice. A customer does not have to log in every day to download and send files – the customer only needs to authorize a third party once.10 This data sharing process can help customers understand their energy usage, help save money, and understand the cost implications of a major purchase. This product also can be used by a large customer, with technical expertise and multiple SAs, to obtain and analyze large data sets over time. Share My Data allows for a customer to access up to four years of historical data as well as grant on-going access to their data.

10 Customers may revoke an authorization previously granted at any time.


It takes several years to create, test, and adopt industry standards, such as Green Button. The Green Button standard (published by the North American Energy Standards Board, or NAESB, as the Energy Services Provider Interface, or ESPI) has undergone a significant development and vetting process over the past six years by various standards organizations (Smart Grid Interoperability Panel and NAESB), user groups (UCA International Users Group and the Green Button Alliance), and government entities (Department of Energy; National Institute of Standards and Technology, or NIST; CPUC; and Ontario Ministry of Energy), to support use cases as diverse as solar cost savings estimation, energy management for property managers, electric vehicle fuel cost savings analysis, energy efficiency analysis, agricultural water pump leak detection, residential TOU rate analysis, and Proposition 39-related services for schools. Today, many utilities across the U.S. and Canada have adopted the Green Button standard, including over 60 million U.S. customer accounts representing 100 million individuals and over 2.5 million Canadian customer accounts representing 8 million individuals. PG&E has taken its involvement a step further by attempting to be the first utility in the nation to complete the formal GBC certification process. The depth and breadth of PG&E’s commitment to the support of Green Button standards has been widely recognized by many third party developers and leaders in the energy sector.

Prior Development on PG&E’s Share My Data Platform

PG&E’s SMD was launched in two phases in 2015. Phase 1 of SMD launched in March 2015, and created the core infrastructure and functionality, customer and third party authorization and SMD registration processes, and customer experience. This is a foundation PG&E can build upon as uses for customer authorized data sharing expand. Two core pieces of this infrastructure that are discussed in this advice letter include:

• OAuth: An online third-party authorization standard that allows an end user's account information to be shared with third-party services without exposing the user's sensitive authentication information (e.g., username, password, etc.). It also gives the customer full transparency into who is authenticating the customer and what data sharing the customer is authorizing. OAuth allows customers to use a familiar online experience (i.e., similar to services offered by Facebook and Google) to authorize the release of their data using a proven and secure system. This system also allows third parties to build to a supported industry standard, which promotes interoperability and quick development and innovation.

• API: An application programming interface (API) is a set of definitions, protocols, and tools for building application software. An API enables data sharing quickly and at scale, based on requests that a registered third party makes for specific data items that they have been authorized to receive. PG&E offers “synchronous” API requests, which can be used to obtain customer information quickly (often within 90 seconds) in a fast, on-demand manner. This API approach tends to be less expensive and fastest to support at scale as opposed to push systems, which make all of the data available, not just that which is requested. PG&E also supports asynchronous request for larger data sets (e.g., years of historical interval data), in which PG&E will notify the third party when the requested data is ready to be retrieved. However, this doesn’t lend to dynamic real-time third party services and generally is slower to accommodate new uses.


As a part of the Phase 1 development process, PG&E solicited feedback from third parties and large customers who heavily used Customer Information Service Request (CISR) forms and screen scraping tools (i.e., the use of a computer program to extract customer data from a customer’s online utility account webpage). After PG&E better understood what data elements were useful to these parties, it released Phase 2 with additional data items, including customer account information, billing information, expanded usage information, and others. Today, PG&E’s SMD platform supports the following features:

• ESPI: Fully aligned with ESPI standard implementation agreement specification (which includes OAuth 2.0). PG&E is in the process of ESPI standard certification testing

• Scalability: Ability to support up to 1.1 million service agreements11 with the current infrastructure

• Authorization flow: 2 pages, with full terms and conditions displayed, and 4 clicks in the shortest customer experience

• Customer-centric authorization: Customer can select any date length of authorization (including indefinite) and can view and revoke their authorization at any time in their online utility account

• Mobile device capable • Development tools: software development kits, documentation, third party

development resources Please see Appendix A for a Report on Status of Spending on Current GBC per D.13-09-025.

Key Areas Where Parties in the Working Group Achieved Consensus and Where Differences Remain

Summary table

PG&E provides the following table summarizing PG&E’s preferred Rule 24 click-through solution as described in this AL, segmented by what is already available in PG&E’s Rule 24 processes and within Share My Data (SMD), what PG&E supports building, and what areas are more appropriately addressed in the Distributed Resource Plan proceeding or future discussions.

11 PG&E supports all interval/non-interval meter types and residential and non-residential

customer classes.


Capability Already Available in PG&E’s Current Rule 24 Processes

Capability PG&E Supports Building12

Capability that is Out of Scope for this AL

Authentication & Authorization

Supported in Form 79-1152 CISR-DRP process

Adding click-through (1 page each for authentication and authorization and 2 clicks in the best case, optimized for an easy mobile experience)

N/A

• Authentication Requirements

Validation of the Form 79-1152 fields and an approved type of customer signature

Adding click-through, where the customer can use existing utility credentials, create new utility credentials, or use alternative authentication credentials

N/A

• Dual Authorization

Supported in the Form 79-1152 process

Adding click-through support N/A

• Authorization Terms and Conditions

Form 79-1152 shows the full terms and conditions

Click-through page will show a summarized list of, and link to full, terms and conditions

N/A

• Length of Authorization

Customer can select any date

DRP defines the preferred date that customer sees pre-selected, or customer selects a date >= the DRP’s minimum date

N/A

• Revocation Supported in Form 79-1152, and a customer can call PG&E at any time

Adding SMD-based revocation for DRPs, online MyAccount revocation for customers

N/A

Data Delivery Combined SMD API and a secure flat file transfer (ESFT) for the current Rule 24 data set

Enabling all current Rule 24 data items to be available through synchronous APIs; a combination of synchronous APIs and ESFT flat files also could provide most of the expanded Rule 24 data set

Full SMD API delivery within 90 seconds for all of the expanded Rule 24 data set; support for certain add’l data items requested

Reporting Performance Metrics

Quarterly Rule 24 reports

Quarterly or monthly reports posted on PG&E’s website

Dynamic, near real-time reporting via PG&E’s website

12 PG&E plans to file another advice letter shortly after this one with short-term solutions it can

implement to bridge the gap between current capabilities and what will be provided in the long-term solution.

Advice 4992-E - 10 - January 3, 2017

Areas of consensus:

a) Dual third party DRP authorizations

As described in PG&E AL 4742-E, filed November 20, 2015, PG&E must support multiple authorizations for a given customer in the click-through solution, similar to how it supports them in the CISR-DRP form today (i.e., a customer can use one authorization for the release of data to up to two third party DRPs for a given SA). While PG&E’s current SMD system does not support this functionality today, the DRPs requested this requirement13 and parties agreed that this is an enhancement that would streamline and simplify the direct enrollment process by allowing a customer to use the click-through process once to authorize two partnering DRPs.14 PG&E has incorporated it into the Solution 3 implementation requirements. PG&E notes that its IT estimation process determined that this requirement can be provided given the importance that the third party DRPs placed on this. However, it comes at a very high cost and with significant effort to develop. Given this, PG&E suggests that this functionality is best suited for the first phase of the project, which requires PG&E to push other scoped efforts to a later phase.

b) No more than 2 screens for authentication and authorization

DRPs have requested a business requirement15 to limit the number of screens to two for a customer performing the authentication and authorization steps of the click-through process. This request was made in comparison to certain existing website processes, which require a number of additional screens for the customer to complete this process. The utilities are committed to improving the customer experience and believe that authentication could be completed on one screen and authorization on another, and have incorporated this into the business requirements for Solution 3.

c) Summary of terms and conditions

The current CISR-DRP form provides a comprehensive list of data items that the customer releases to a third party DRP that support the provision of DR services in the CAISO wholesale market. It also provides the terms and conditions of that release and identifies actions PG&E is authorized to take upon receipt of the completed form. The working group concurs that the data items can be summarized16 into three categories (customer account information, interval data, and DR program participation), while taking advantage of the online nature of the click-through process by providing a link to Rule 24, where the data items are identified. The click-through authorization will also summarize the actions authorized and the other terms and conditions currently described in the existing CISR-DRP form. PG&E, SCE, and SDG&E also plan to file

13 Informal Status Report, Appendix E, OAuth Improvements #1, page 1. 14 Customers can authorize release to many different DRPs using separate authorizations. 15 Informal Status Report, Appendix E, User Experience #2, page 1. 16 Informal Status Report, Appendix E, User Experience #9, page 2.

Advice 4992-E - 11 - January 3, 2017

these revisions to shorten and simplify the CISR-DRP form in a separate AL to be filed as soon as possible after this AL.

d) Other business requirements

See Appendix B for a list of other DRP business requirements PG&E will support.

Areas Where Differences Remain:

a) Number of clicks reasonable for all use cases

In Appendix E of the Informal Status Report, the DRPs specified that the best-case number of clicks to complete the authentication and authorization steps is at most four. While the working group has discussed setting default behaviors that are believed to accommodate the majority of residential customers, there is some optionality available in the way the customers authenticate themselves and flexibility in the length of authorization that adds clicks to the process. As PG&E manages the authentication process, it may require controls to prevent identity theft and fraud, such as a checkbox to ensure a customer, not a robot, is using the click-through process. In addition, customers with multiple service agreements tied to their account will, by default, have all of their electric service agreement pre-selected, but may only want to authorize access to a subset of these for DR services, so additional clicks will be necessary in that use case as well. While the utilities understand that reducing the number of clicks as much as possible improves the customer experience and will strive to minimize this, PG&E cautions that there are use cases that do not support a four click requirement, based on the functionality necessary and described elsewhere as the business requirements for Solution 3, and such hard restrictions are impractical and unreasonable.

b) Alternative authentication to utility account login

The utilities require that customer authentication for purposes of release of customer data occur on the utility website in order to ensure utility compliance with customer privacy requirements and anti-identity theft protections. The utilities acknowledge that certain customers may prefer other authentication processes, but believe that this process is best at protecting all customers’ data and ensuring their data privacy. The CPUC’s privacy rules and the California Information Practices Act require authentication of customers using the customers’ authorized credentials (alternative or username/password) in order to protect customer privacy and prevent identity theft. The DRPs’ business requirements17 have described the use of alternative forms of authentication to complete the CISR-DRP process, and have suggested the use of two specific, static inputs, such as service account and zip code. PG&E considers the DRP’s proposal insufficient to properly authenticate a customer. It also does not comply with CPUC and California Information Practices Act regulations, as mentioned above.

17 Informal Status Report, Appendix E, OAuth Improvements #7 and User Experience #2 and

#6, page 1.

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While the use of specific, static inputs would allow DRPs to pre-populate or auto-fill the alternative authentication fields to speed up the authorization process, this does not take into account the rapidly evolving best practices for protecting online privacy and for preventing online fraud and identity theft. These require specific online authentication techniques such as authenticating that the online authorization occurred on the customer’s computer or through the customer’s e-mail, or that customer authorizations are subject to post-authorization confirmation by the customer. Further, there is a clear trend toward using multi-factor authentication for consumer-facing accounts containing sensitive information. This would mean that in addition to entering something the customer knows, such as a PIN or password, the customer would also be required to enter another piece of information, such as a unique transaction-specific encrypted password sent to their device.18 Google, for instance, allows customers to opt-in for “2-Step Verification” to enhance the security of their account by asking for a password and a code that is sent via text, voice call, mobile app, or USB device.19 The working group discussed that the utilities will determine the elements used for the alternative authentication process and can change them, as long as the evolving authentication techniques are no more onerous than required to engage in similar online utility transactions, such as a PG&E My Energy account. Most parties agreed to this standard, but not every party supported this requirement. PG&E notes that its IT estimation process determined that this requirement can be provided given the importance that the third party DRPs placed on this; however, it comes at high cost and with significant effort to develop. As a result, PG&E will need to provide this functionality in Phase 2 of the project.

c) Requirements for length of authorization and revocation

On the current version of the CISR-DRP, customers have a number of options for specifying the length of authorization and the processes for revocation. For instance, the customer can pre-define a specific end date for their authorization to expire, or specify that their authorization is indefinite, and either solely have the ability to revoke their authorization at any time, or may pre-authorize a DRP to also have the ability to revoke their authorization at any time.

18 The California Data Breach Report provides guidance on what “reasonable” security

measures are. The report details 20 security controls that must be implemented proportionate to the organization’s risk environment. Failure to do so constitutes a lack of reasonable security. Multi-factor authentication is discussed in recommendation #2: https://oag.ca.gov/breachreport2016#recommendations. NIST is also in the process of releasing their updated Digital Authentication Guidelines, which issue guidelines to federal agencies to use multi-factor authentication to protect any accounts containing personal data. https://pages.nist.gov/800-63-3/sp800-63b.html

19 https://www.google.com/landing/2step/index.html

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The DRP’s proposal20 is designed to streamline the process and reduce the number of issues that could occur if the customer were to select a date that is inconsistent with the period the DRP needs to enroll the customer in the DRP’s program. The requirements are: 1) the DRP will be able to specify a preferred end date (or an indefinite period) which will be pre-populated and presented to the customer as part of the customer’s affirmative online choices and preferences; 2) the DRP will be able to specify a minimum end date (or indefinite); 3) the customer will be allowed to choose between the minimum date and any date after the minimum end date; 4) in the event that the DRP selects a preferred end date equal to the minimum end date, the customer will not be permitted to choose a different length of authorization than what the DRP has selected; and 5) the DRP must be able to revoke the authorization at any time. The requirements will be presented such that if the customer does not want to authorize what the DRP has pre-selected, then the customer would not authorize the DRP and would cancel the click-through process. While the utilities have expressed concern over the reduced optionality for the customer on the length of authorization and the ability for the DRP to be able to revoke the authorization at any time, the utilities believe that customer choice and the streamlining of the click-through process can be best supported by making revocation of the authorization clear and easy, instead of maintaining broader customer choice over the length of the authorization. PG&E plans to support the DRPs’ proposal, and to provide the customer with a reminder on the authorization webpage that the customer has the right to revoke its authorization at any time.21 In addition, it will be clearly stated that the DRP has requested access to a particular length of authorization, and optionality will be provided to modify that date to the extent possible, unless the DRP has made the preferred end date equal to the minimum end date. This solution requires modification to Rule 24, Section D.1.d., as described in Appendix D of this AL. PG&E notes that its IT estimation process determined that this requirement can be provided given the importance that the third party DRPs placed on this; however, to minimize costs and manage the scope of the Phase 1 release, it logically lives with other improvements (e.g., change in OAuth redirection steps, passing of scope string) related to OAuth 2.0 conformance targeted for Phase 2. As a result, PG&E will provide this functionality in Phase 2 of the project, as described later in this AL.

d) Reporting of performance metrics

DRPs also outlined a number of performance metrics within their business requirements.22 The Energy Division also described its intent for each of the utilities to provide a publicly accessible website to track the performance of Solution 3. The working group discussed a number of the performance metrics and PG&E agreed that it

20 Informal Status Report, Appendix B, page 2. 21 This is consistent with D.11-07-056, Customer Privacy Rule 4(b) and stated in Rule 27. 22 Informal Status Report, Appendix E, Utility Webpages’ Performance, page 2.

Advice 4992-E - 14 - January 3, 2017

could provide such metrics, but may revise these to add additional items or improve upon these metrics. PG&E also considered a proposal to include a daily reporting frequency online (lagged by one day) of aggregated utility-level data on the click-through process, and to serve a monthly report to the service list to track performance over time. By the end of the working group meetings, the DRPs came to a consensus that prioritization of this business requirement is lower than enabling the basic functionality of the click-through process for authentication and authorization. In addition, PG&E found during its estimation process that there are high costs and complexities involved in supporting the daily reporting online. Therefore, PG&E will offer a quarterly or monthly report that can be posted on PG&E’s website and served to the service list.

e) Expansion of Rule 24 data set to new items

DRPs also requested an expanded Rule 24 data set, as listed in Appendix C of this AL. Where indicated, PG&E has committed to expand the set for all items requested, with the exception of the following for this AL:

• PG&E disagrees with providing customer payment information. • PG&E disagrees with providing PDF copies of the customer’s energy statements.

PG&E supports providing data items necessary to enable DRPs participation in CAISO market and to support the enrollment process, with limitations only where PG&E’s review has resulted in concerns over customer privacy, scope, and release of confidential data that PG&E is not permitted to disclose for all customers. 23 As a result, PG&E has not priced out the provision of customer payment information and PDF copies of the customer’s energy statements. For instance, PG&E’s energy statements (bills) have both gas and electric information, as well as sensitive customer payment information, including whether or not the customer is behind on payments. With regards to the gas information, in particular, Rule 24 does not authorize this data release, which is irrelevant for direct participation in the CAISO market. In addition, payment information involves gas commodity service, which may be provided by a third party who could consider it commercially sensitive.24 Therefore, PG&E will not provide copies of the customers’ bills or payment information.

23 PG&E’s position to not include this data in this click-through AL process today does not

preclude the provision of this information at some future date if release of these types of information are properly assessed and approvals are obtained. However, given the limited time available for this AL and expedited implementation of Rule 24 click-through process for the 2018 DRAM, these matters are not in scope.

24 Rule 27, Section 5(c) requires that PG&E “shall not disclose to any third party more covered information than is reasonably necessary or as authorized by the Commission to carry out on behalf of the covered entity a specific primary purpose identified in the notice required under section 2 or for a specific secondary purpose authorized by the customer.” PG&E also clarifies that it does offer gas data for its gas services in Share My Data, under the

Advice 4992-E - 15 - January 3, 2017

Some elements of the electric bill and customer data may involve third party providers, such as community choice aggregation (CCA) entities. PG&E believes that Rule 23, C. 3. a. requires the CCAs to allow a CCA customer to authorize a third party to receive the customer’s CCA information under a Rule 24 authorization.25 PG&E will provide this data unless the Commission disagrees with this position.

f) Synchronous data provision within 90 seconds

The DRPs have described in their guiding principles that synchronous data should be delivered on-demand and streaming within 90 seconds of the click-through authorization process being completed for the full data set. PG&E currently supports a hybrid system of providing the current Rule 24 data set using the SMD API and a flat-file ESFT process. In the implementation described in this AL, PG&E supports providing all existing Rule 24 and SMD provided data sets with synchronous APIs. However, PG&E found that there will be significant costs and implementation effort associated with adding a number of the data items in the third party DRP’s expanded data set. To elaborate, the expanded data set requires re-architecting PG&E’s backend source systems, as the current data lives in multiple disparate systems that were not originally designed to support myriad and synchronous API requests by external parties. The majority of these expanded data set items are also not directly modeled in the current Green Button Connect standard’s XML schema definition, representing additional cost and effort to map and define these data elements as part of the XML schema definition. The expanded data set items are not needed in the form of synchronous APIs to participate in a Rule 24 demand response product, and it is reasonable to provide these data items in the existing flat file process. PG&E feels it will be most efficient to scope out and deliver these additional data items via synchronous APIs in a more comprehensive manner if and when the click-through process is formally moved to the Distributed Resource Plans proceeding, based on indications from Energy Division that this transfer will occur soon. After the transfer occurs, a broader group of stakeholders can consider a wider range of use cases associated with supporting other DERs.

ShareMyData customer authorization process. Third party gas commodity providers’ billing information in PG&E’s possession is also not provided via ShareMyData.

25 Electric Rule 23, section C. 3. a.: “a. PG&E shall provide customer-specific usage data pursuant to Schedule E-CCAINFO. PG&E and CCA shall abide by the instructions of a customer as to the entities to whom access to the confidential customer information is provided.” Comparable language is in the Direct Access tariff, Rule 22 C. 3. a. addressing release of DA customer’s information to third parties with customer authorization. For the customer gas information, there is nothing comparable in the gas tariffs.

Advice 4992-E - 16 - January 3, 2017

Meanwhile, for Rule 24 improvements achievable in the short-term, PG&E plans to file a separate AL later this month for the additional data items it can provide from the third party DRP’s expanded data set utilizing the existing flat file process (with the exception of those data items described in the prior section that PG&E will not provide in the scope of this proceeding).

g) Expansion of the Click-Through Process to Other DERs

PG&E notes that in the limited time available, it has tried to consider how implementation of Solution 3 could support other DERs, but cannot at this time provide specific budget estimates or discuss applications to other proceedings. A clear definition of those other use cases should be determined in a broader stakeholder process with the appropriate groups of parties that can advise on these other use cases. This work also needs to consider a broader scope of customer privacy and data access issues, as the Commission may need to revise Electric Rule 27 (Rule 27) to better align with the issues discussed in this AL, or identified in a broader Distributed Resource Plan context. For instance, data minimization principles in Rule 27, Sections 3 and 5, specify that data released to third parties should be tied to a specific purpose, which could complicate the simplified authorization described in this AL.26 Nevertheless, PG&E has incorporated design principles into the click-through solution that it believes could support broader use cases and other DERs. However, PG&E cautions that it undoubtedly will need to adjust this implementation as use cases expand.

h) ED Guidance to Provide a Schedule to Develop an Advice Letter for Implementing Solution 1

As stated in the Informal Status Report as a joint utility consensus position, PG&E strongly opposes Solution 1. PG&E believes it is redundant to develop two solutions that achieve the same purpose with a similar customer experience and, therefore, inefficient and wasteful use of its customers’ funding. In addition, as discussed in the section on the Schedule for Developing and Funding Solution 1, the two solutions cannot be undertaken concurrently because this would extend the amount of time to implement any solution far beyond the 2018 DRAM. Equally importantly, Solution 1 involves the customer providing confidential authentication information on the third party DRP’s website, requiring the customer and PG&E to trust that the third party DRP’s implementation of this solution does not transmit or store this information on third party servers. The customer also does not clearly and unequivocally know who they are authenticating with, or that PG&E supports

26 The authorization may otherwise need to be segmented such that each data set would need

to be tied to a specific purpose that the DRP has registered for in advance, and each data set would have its own terms and conditions that the customer would need to authorize, associated to that specific purpose.

Advice 4992-E - 17 - January 3, 2017

the process. PG&E would not be able to guarantee that each DRP’s implementation of Solution 1 meets cybersecurity requirements used to mitigate phishing attacks, identity theft, etc., and cannot ensure a customer’s authentication and authorization meets the requirements in the Commission’s privacy rules in each of the third party DRPs’ systems.27 The Commission’s privacy rules28 require that the utility and the Commission verify that the customer authorization is by the actual customer, which requires that the utility and the Commission can verify this with the appropriate documentation. In addition, the privacy rules state that the utility is responsible for verifying that the customer’s authorization is “prior, express, [and] written,” which means that it is obtained before the service is provided, clearly and unmistakably stated, and what is being agreed to is in clear and conspicuous writing. That requires PG&E to maintain control over the customer authentication and authorization process and documentation of it, and retain the ability to update and revise the customer authentication process to meet new best practices and industry standards to customer authentication, avoiding identity theft, and avoiding customer fraud – all of which are essential elements of Solution 3. PG&E also strongly supports using Solution 3 because it relies on a national standard for sharing energy data, utilizing best practices from across the industry. The Green Button standard was designed to ensure consistency across utilities, customer privacy, and cybersecurity compliance with the NIST. In a letter to President Picker and former Commissioner Florio, the Green Button Alliance emphasized the importance of using Solution 3 to leverage a widely accepted industry standard, which supports evolution of the solution and extension to other use cases given its widespread acceptance across the energy industry. However, Solution 1 deviates from this, locks in a proprietary solution, and limits interoperability, which impedes the creation of an ecosystem that can scale and drive widespread adoption.29

i) Application of the CISR-DRP form to CCA/DA customers via Rule 23 and Rule 22

PG&E clarifies that when it is the Meter Data Management Agent (MDMA) for CCA/DA customers, these customers may authorize and require PG&E and the relevant CCA or ESP to release their billing and usage information to third parties, including DRPs under Rule 24, and that PG&E will continue to do so under the click-through process, as permitted under Electric Rule 23 (Section C.3.a), Electric Rule 22 (Section C.3.a.) and Rule 24 (Section D), as discussed above.

27 Informal Status Report, Section 3 (pages 2-5) and Section 5 (pages 11-12). 28 Specifically those in D.11-07-056, Attachment D, Rule 6(d) and 6(e) and Electric Rule 27.

29 Green Button Alliance, Notice of Ex-parte Communication, filed in R.13-09-011 and R.07-01-041 on October 13, 2016.

Advice 4992-E - 18 - January 3, 2017

Solution 3 Implementation Plan and Cost Recovery

Description of business requirements

The DRP’s Appendix E of the Informal Status Report described a series of 30 requirements for Solution 3, and 7 categories of performance metrics to track, which upon Energy Division guidance, formed the basis of the requirements used for Solution 3. PG&E organized the list and led a series of discussions between the October 26 and December 1 meetings to clarify these DRP requirements and develop a list of 42 high level core requirements agreed to by DRPs and the CPUC that PG&E used to develop IT estimates. PG&E used this list of requirements to provide estimates for budget and time for this project, in the context of current resource availability, other projects and priorities, etc. across the company. The estimates provided in this section are within the Energy Division’s 50 percent margin of error bounds, based on information available now for the scope of work endorsed by PG&E, and may require future revisions. PG&E provides additional detail on the requirements described below in Appendix B.

Summary of budget and phasing

Given the large number and complexity of the business requirements identified, PG&E plans to release high priority requirements over two primary project phases spanning 15 months. A third project phase will include lower priority performance reporting requirements to be released 3 months later. PG&E forecasts overall total project costs for its preferred solution across the three project phases to be $4.4 million for the implementation of Solution 3. PG&E will enhance its existing Green Button Connect implementation, called the Share My Data platform to address the 42 business requirements related to Solution 3. The project is expected to span three phases that will require 18 months to fully deploy all functionality described below.

Phase 1

Phase 1 will encompass the following core functionality as described in further technical detail in Appendix B:

• Dual third party authorizations • Streamlining the customer authorization experience, including:

o Reducing the number of pages and clicks o Summarizing the terms and conditions for the authorization o Simplifying the page design

• Responsive design for mobile and desktop devices • Online authorization of Rule 24 actions • DRP revocation via API

PG&E anticipates releasing Phase 1 functionality within 9 months of the approval of this advice letter.

Advice 4992-E - 19 - January 3, 2017

Phase 2

Phase 2 will encompass the following features as described in further technical detail in Appendix B:

• Alternative authentication to utility account login • Optimizing the “forgot password” process so that a customer picks up where they

left off after resetting their password • Full conformity with the OAuth 2.0 specification to dynamically update the

authorized data elements and end date, and an updated redirection page DRPs can send customers to

• Requesting new access token for any re-authorizations that may occur

PG&E anticipates releasing Phase 2 functionality within 6 months of the completion of Phase 1.

Phase 3

Phase 3 will encompass the remaining scope, including basic performance reporting, and outstanding requirements and defects. PG&E anticipates releasing Phase 3 functionality within 3 months of the completion of Phase 2.

Requirements not supported

PG&E will not implement a type of offline testing environment known as a sandbox environment for third parties. PG&E’s SMD platform already provides adequate testing opportunities via basic API connectivity tests during third party registration, which allows third parties to test and confirm their ability to support APIs and the OAuth standard. As described earlier in this AL, the type of daily reporting requested by the Energy Division in this working group process comes at a high cost and with significant implementation time to complete. Given the low priority assigned by the third party DRPs during the working group process, PG&E will instead provide quarterly or monthly reporting for transparently tracking the performance of Solution 3 at minimal cost that can be served to the relevant service lists and posted publicly on its website.

Continuing support

PG&E plans to fund the ongoing operations and maintenance of this project using a combination of existing, authorized funding for Rule 24 support personnel30 and SMD program and platform support.31 PG&E is not seeking additional O&M funding via this Advice Letter process.

30 D.16-03-008, D.16-06-008, and D.16-06-029 include O&M to support Rule 24 processes

through 2017, and O&M support in 2018-2022 is included in PG&E’s Demand Response Application to be filed January 16, 2017.

31 D.13-09-025 includes O&M to support the SMD program and platform through 2016. O&M support in 2017-2019 is included in PG&E’s General Rate Case request.

Advice 4992-E - 20 - January 3, 2017

As discussed in the working groups, PG&E may seek third party DRP input and feedback as part of the design phase of this project. PG&E can contact the interested parties in this proceeding as well as the list of existing third parties with milestones of the completed phases and communicate as specifications are formalized to ensure that IT changes will continue to meet third party DRP requirements as the project continues through its development lifecycle. In addition, PG&E plans to notify all existing and potential third parties to the changes on the SMD platform as part of the change management procedures in this project.

Reporting performance metrics

PG&E supports providing the performance metrics the DRPs requested in Appendix E of the Informal Status Report, but may revise these to add additional items or improve upon the metrics discussed here. PG&E will compile these metrics and report them on an aggregated basis on a quarterly or monthly basis, in compliance with the Commission’s minimum aggregation reporting requirements.

• The following aggregated values shall be reported o Mean and max load time o Standard deviation o 90th percentile load time

• Time spent between the first step and the last step o Mean and max load time o Standard deviation o 90th percentile load time

• Number of views per page • Number of unique user views per page

Support for Other DERs

As discussed above, PG&E incorporated certain design principles into the click-through solution that it believes will enable future enhancements to support broader use cases. Phase 2 development on the OAuth 2.0 specification to dynamically update the authorized data elements, in particular, envisions an application that may support other DERs. For instance, depending on what third party programs a customer is interested in, a third party could use this solution to request a specific subset of data items that are necessary for that program in the OAuth sequence, and the customer can provide their authorization for that data set. There is a lot of work to be done to facilitate this process for other DERs, but this framework supports that long-term goal.

Data Delivery Implementation Plan and Cost Recovery

Description of business requirements

As described above, PG&E currently provides Rule 24 data in two formats: SMD API and an Electronic Secure File Transfer (ESFT) process. PG&E proposes a multi-staged approach for meeting the DRPs’ requirements to expand this data set and to provide it in a synchronous API in approximately 90 seconds:

Advice 4992-E - 21 - January 3, 2017

• Current Rule 24 data set: o For data currently being shared via SMD API: PG&E will provide with a

synchronous API o For data currently being shared via ESFT flat file: PG&E will provide with a

synchronous API • Expanded Rule 24 data set:

o Data items that are currently available in SMD API: PG&E will provide with a synchronous API

o Data items that are not currently available in SMD API: PG&E plans to add to the ESFT flat file process, with the exception of the data items that PG&E does not support adding

In summary, third party DRPs requested 53 initial data elements across 12 categories32. The working group discussed a further expansion of this list to 61 data items that form the basis of the current and expanded Rule 24 data set. PG&E will support 31 of the requested data elements over synchronous APIs, of which 15 are currently provided using the Rule 24 ESFT flat file process that will be moved to an SMD API, 15 are already provided via SMD APIs, and 1 is a new data element to be added as a part of this implementation as a SMD API. This AL describes the provision of data items that PG&E plans to provide in the SMD API, and a separate AL will be filed later in January outlining short-term solutions that can be added to existing processes.

Summary of budget and phasing

PG&E plans to transition DRPs to use SMD synchronous APIs for both the current Rule 24 data set, and the data set currently available in SMD. Please refer to Appendix C for the full list of data items that will be included in PG&E’s implementation. PG&E has estimated that the data delivery project described here can be performed concurrently with the Solution 3 implementation and anticipates releasing this in Phase 1 within 9 months of the approval of this advice letter. PG&E estimates that the cost to implement this piece of the project, independent of the Solution 3 implementation, is $1.2 million. Both the budget and phasing are within the Energy Division’s requested 50 percent margin of error bounds, based on information available now for the scope of work endorsed by PG&E, and may require future revisions. PG&E notes that the third party DRPs requested synchronous data requests within 90 seconds, and PG&E’s implementation supports an average response time of 90

32 Informal Status Report, Appendix B, page 11.

Advice 4992-E - 22 - January 3, 2017

seconds, but notes that this response depends on the number and size of concurrent requests.33

Requirements not supported

As described above, PG&E will not support the customer payment information or PDF copies of the customer’s energy statements.

Support for Other DERs

The data set available in SMD today and through this implementation are expected to be helpful for a number of other use cases. The Green Button standard for PG&E’s data delivery implementation is an industry standard that promotes interoperability and the SMD API is quick and scalable. As discussed earlier in the section on Synchronous data provision within 90 seconds, PG&E believes it is most efficient to scope out and deliver additional data items via synchronous APIs in a more comprehensive manner if and when the click-through process is formally moved to the Distributed Resource Plans proceeding, where a broader group of stakeholders can consider a wider range of use cases associated with supporting other DERs.

Schedule for Developing and Funding Solution 1 The utilities came to a consensus during this working group process that simultaneous development of both Solutions 1 and 3 would utilize the same resources and prolong the completion of Solution 3. Therefore, in an effort to provide one solution as quickly as possible that provides a streamlined and simplified click-through process, it was determined that the solutions would be developed sequentially, with separate advice letter processes, rather than to wait for both to be properly scoped with corresponding budget and timeline estimations at a later date. PG&E recommends that sufficient time (at least a year to support a full cycle of new customer authorizations) be provided to allow parties to determine if Solution 3 is adequate. Only if Solution 3 proves inadequate should the working group reconvene to develop Solution 1. PG&E envisions that the utilities will notify the Energy Division when Solution 3 has been completed and will work with stakeholders to develop a process to evaluate Solution 3 via a publicly noticed working group meeting, and determine if further enhancements are sufficient before developing Solution 1. If Solution 1 is required, a new series of working group meetings would need to be planned and publicly noticed to develop the DRP business requirements associated with the implementation of Solution 1. At the conclusion of the working group process, the utilities would each file a Tier 3 AL to provide the Commission with a similar set of business and IT requirements, timeline and phasing, and budget estimates and cost

33 For instance, a request that involves four years of historical hourly meter intervals for a large

number of SAs may not complete within exactly 90 seconds, depending on the number of other concurrent requests.

Advice 4992-E - 23 - January 3, 2017

recovery. If click-through is moved to the Distributed Resource Plan proceeding, PG&E anticipates that this discussion would take place in the broader context of that proceeding. At this time, it is difficult to estimate how long the working group process might take. It is expected that the development of Solution 1 will take longer than Solution 3, which represents enhancements to existing Green Button Connect systems compared to Solution 1’s completely new process. In addition, it is unclear what cost recovery might be available at that time to support implementation for Solution 1. For instance, the timelines in this AL are likely to exceed the expected date of the final decision on the 2018 applications, which means subsequent spending would need to be tied to the next DR cycle application, for the period after 2022. Additional funding such as a new cost recovery request likely will be necessary to support implementation of Solution 1 but the amount cannot be determined until a later date.

Application of the D.16-06-008 OP13 Budget Cap to Click-Through Discussions with Energy Division staff have informed PG&E that D.16-06-008, OP 13, should be interpreted to allow for a cap of $10.39 million for the click-through solution and a second $10.39 million cap to increase registrations up to mass market implementation. In order to clarify this element of the decision, PG&E is filing a Petition for Modification requesting that the Commission modify OP 13 to state that the $10.39 million cap applies twice, once for click-through implementation and then again for expansion of Rule 24 capacity beyond the Intermediate Implementation step. PG&E also requires modification to D.16-06-008, OP1, to allow for the definition of click-through as proposed in this AL. As written, OP1 describes a requirement where both the customer and utility are to be provided immediate access to a copy of the completed CISR-DRP “form and a time-stamped electronically signed agreement form.” However, the streamlined electronic click-through process discussed in the working group and filed in this AL does not envision a CISR-DRP form, per se. Rather, the customer authenticates him- or herself and provides his or her authorization based on the terms and conditions in the CISR-DRP form. PG&E will keep an electronic record of the date and time of the authorization, the third party(s) authorized, the SAs authorized, the historical data that was authorized, what data elements were authorized, the end date of the authorization, and changes authorized. PG&E’s proposed revisions to OP 13 and OP 1 are contained in the Petition for Modification that PG&E will file on January 3, 2017, or soon after.

Advice 4992-E - 24 - January 3, 2017

Revisions to Rule 24 and CISR-DRP Form Necessary to Implement Click-Through Proposed tariff modifications to Rule 24 to support the click-through process and changes to shorten and simplify the CISR-DRP form are presented in the attached red-line of Electric Rule 24. PG&E, SCE and SDG&E will be filing the revised CISR-DRP as soon as possible in a separate advice letter. PG&E proposes that SCE, SDG&E, and PG&E file final tariff revisions together in compliance with this resolution, or with the CISR-DRP revisions AL.

Conclusion and Relief Requested PG&E requests approval for two projects totaling $5.6 million that it plans to develop concurrently over 18 months to support the direct participation enrollment process upon the approval of this AL, composed of:

• $4.4 million for PG&E’s proposed Solution 3 Implementation within 18 months • $1.2 million for PG&E’s proposed Data Delivery Implementation within 9 months

PG&E notes that revisions may be necessary to these estimates given the short period of time provided to develop these estimates and the uncertainty that remains, which PG&E approximates falls within a 50 percent margin of error. In addition, PG&E requests that the Commission suspend plans to develop and file a Tier 3 AL for funding a yet-to-be-defined Solution 1 until it can properly evaluate whether Solution 3 is adequate for supporting the streamlining and simplification of the direct participation enrollment process. PG&E seeks clarification on the application of the budget cap described in D.16-06-008, OP 13, and as requested in its Petition for Modification of D.16-06-008, filed on or soon after January 3, 2017. PG&E urges the Commission to provide speedy approval on this AL to allow the utilities to begin implementation right away. If the Commission supports the proposals described in this AL, PG&E requests that the Commission direct SCE, SDG&E, and PG&E to file modifications to Rule 24 as the Commission may direct in its resolution on this AL, as well as approve the future CISR-DRP form modifications AL, a future short-term solutions AL, and PG&E’s PFM of D.16-06-008 filed separately in support of the principles outlined in this AL.

Tariff Revisions PG&E proposes revisions to Electric Rule No. 24, Direct Participation Demand Response in Appendix D of this AL. If the Commission supports the modifications, PG&E asks the Commission to direct SCE, SDG&E, and PG&E to file modifications in compliance with the Commission’s resolution.

Advice 4992-E - 25 - January 3, 2017

Protests Anyone wishing to protest this filing may do so by letter sent via U.S. mail, facsimile or E-mail, no later than January 23, 2017, which is 20 days after the date of this filing. 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: [email protected]

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 B10C P.O. Box 770000 San Francisco, California 94177 Facsimile: (415) 973-1448 E-mail: [email protected]

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 protest was submitted to the reviewing Industry Division (General Order 96-B, Section 3.11).

Effective Date Pursuant to General Order (GO) 96-B and D.16-06-008, this advice letter is submitted with a Tier 3 designation and will be effective upon Commission approval.

Advice 4992-E - 26 - January 3, 2017

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.14-06-001 et al and R.13-09-011. Address changes to the General Order 96-B service list should be directed to PG&E at email address [email protected]. For changes to any other service list, please contact the Commission’s Process Office at (415) 703-2021 or at [email protected]. Send all electronic approvals to [email protected]. Advice letter filings can also be accessed electronically at: http://www.pge.com/tariffs/. /S/ Erik Jacobson Director, Regulatory Relations

Attachments

cc: Service List A.14-06-001 and R.13-09-011

Attachments This Advice Letter contains the following attachments:

• Appendix A: Report on Status of Spending on Current GBC per D.13-09-025 • Appendix B: Technical Description of Solution 3 Implementation Business

Requirements • Appendix C: Full List of Rule 24 Data Items with the Expanded Data Set • Appendix D: Proposed Modifications to Rule 24

CALIFORNIA PUBLIC UTILITIES COMMISSION ADVICE LETTER FILING SUMMARY

ENERGY UTILITY

MUST BE COMPLETED BY UTILITY (Attach additional pages as needed)

Company name/CPUC Utility No. Pacific Gas and Electric Company (ID U39 E)

Utility type: Contact Person: Annie Ho

ELC GAS Phone #: (415) 973-8794

PLC HEAT WATER E-mail: [email protected] and [email protected]

EXPLANATION OF UTILITY TYPE

ELC = Electric GAS = Gas PLC = Pipeline HEAT = Heat WATER = Water

(Date Filed/ Received Stamp by CPUC)

Advice Letter (AL) #: 4992-E Tier: 3 Subject of AL: Electric Rule 24 Direct Participation Enrollment Click-Through Process

Keywords (choose from CPUC listing): Compliance, Rules, Agreements

AL filing type: Monthly Quarterly Annual One-Time Other _____________________________

If AL filed in compliance with a Commission order, indicate relevant Decision/Resolution #: D.16-06-008

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: ____________________

Is AL requesting confidential treatment? If so, what information is the utility seeking confidential treatment for: No

Confidential information will be made available to those who have executed a nondisclosure agreement: N/A

Name(s) and contact information of the person(s) who will provide the nondisclosure agreement and access to the confidential information: __________________________________________________________________________________________________

Resolution Required? Yes No Requested effective date: Upon Commission Approval 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 proposed: N/A

Pending advice letters that revise the same tariff sheets: N/A

Protests, dispositions, and all other correspondence regarding this AL are due no later than 20 days after the date of this filing, unless otherwise authorized by the Commission, and shall be sent to:

California Public Utilities Commission Pacific Gas and Electric Company

Energy Division EDTariffUnit 505 Van Ness Ave., 4th Flr. San Francisco, CA 94102 E-mail: [email protected]

Attn: Erik Jacobson Director, Regulatory Relations c/o Megan Lawson 77 Beale Street, Mail Code B10C P.O. Box 770000 San Francisco, CA 94177 E-mail: [email protected]

Advice 4992-E January 3, 2017

Appendix A: Report on Status of Spending on Current GBC per D.13-09-025

Authorized CPUC Budget $19,400,000

Expenditures 2013 2014 2015

2016 YTD (as of Nov

2016) ITD Costs Capital $1,849,754 $6,204,073 $3,159,147 $212,524 $11,425,499 Expense $18,865 $476,724 $1,886,097 $1,883,672 $4,265,358 Total $1,868,619 $6,680,797 $5,045,244 $2,096,197 $15,690,857

EXPENSE Description 2013 2014 2015 2016 Grand Total Phase 1: Business $18,865 $329,058 $75,963 $0 $423,886 Phase 1: IT

$120,169 $0 $120,169

Education & Awareness

$95,114 $32,254 $432,870 $560,238 Phase 2: Business

$283,681 -$5,300 $278,381

Phase 2: IT

$279,626 $3,785 $283,411 IT O&M

$694,119 $747,611 $1,441,731

Business O&M $52,552 $400,285 $704,706 $1,157,543 Total $18,865 $476,724 $1,886,097 $1,883,672 $4,265,358

CAPITAL Description 2013 2014 2015 2016 Grand Total Phase 1: Business $116,126 $666,308 $221,851 $0 $1,004,285 Phase 1: IT $323,849 $5,014,997 $1,280,635 $0 $6,619,481 Phase 2: Business

$561,168 -$24,740 $536,428

Phase 2: IT

$1,070,398 $237,264 $1,307,662 Hardware $1,409,780 $522,768 $25,096 $0 $1,957,644 Total $1,849,754 $6,204,073 $3,159,147 $212,524 $11,425,499


Appendix B: Technical Description of Solution 3 Implementation Business Requirements DRP Requirements per Appendix E of the Informal Status Report OAuth Improvements Supported? The url that DRP redirects the user to should be the OAuth authorize url (as defined in OAuth 2.0 specification)

Phase 2

The IOU only redirects to authentication interface if needed, then redirects back to the original OAuth authorization url.

Phase 2

Authentication interface must be skipped if user already has valid authentication session cookie

Phase 1

Authentication interface must be able to allow password resets/reminders and still remain in authorization flow.

Phase 2

Authentication interface must be able to allow login credentials as authentication fields.

Phase 1

Best case authorization interface must be 1-click "Authorize" button Phase 1 Default is all services [Accounts] are pre-selected and customer has to un-select the ones they want to exclude.

Phase 1

Redirected back to DRP with [authorization] code after clicking "Authorize", no confirmation page on IOU.

Phase 1

Valid implementation of OAuth 2.0 Code Grant Flow per https://tools.ietf.org/html/rfc6749#section-4.1

Phase 2

Authorize url meets OAuth 2.0 spec per https://tools.ietf.org/html/rfc6749#section-4.1.1

Phase 2

Be able to handle state parameters, even through authentication interface Available Be able register multiple redirect_uris with IOUs so that DRPs can have testing/staging/production redirect_uris

Phase 1

Creation of sandbox like environment, open to outside world, for 3rd parties to test their implementations against. This may include the need to publish test version APIs and a test OAuth flow for testing purposes.

No1

Be able to handle re-authorization for new code grant if DRP has lost previous auth code or access_token.

Phase 2

Be able to handle a user declining to authorize a DRP in both authentication and authorization interfaces.

Phase 2

Be able to redirect errors back to the DRP per https://tools.ietf.org/html/rfc6749#section-4.1.2.1

Phase 2

Authentication interface must have alternative instant authentication for users without logins (account#+zip, etc.)

Phase 2

DRP ability to revoke auth (irrespective of authentication that was initially used). Phase 1 Support authorizations to 2 or more DRPs for the same customer at the same time

Phase 1

Stitching aka 'bridging' of SA IDs (whereby customer is still at same physical location, but changes rates etc. resulting in new SA ID).

Available

1 The implementation cost and effort involved is significant to support. PG&E’s SMD platform already provides for basic API connectivity tests during third party registration, which allows third parties to test and confirm their ability to support APIs and the OAuth standard.


User Experience Supported? In the best case scenario (happy path), Authentication and Authorization would be accomplished with no more than 2 clicks.

Phase 1

The best-case number of fields the user must complete for combined authorization and authentication steps shall be at most two.

Phase 1

The best-case number of unique pages or sections of a page that must load is at most two

Phase 1

The maximum number of form fields filled out by the customer shall be two fields used for Authentication.

No2

No form fields shall be required to be filled out during the Authorization Step. Phase 1 The Authentication step shall require one of the following sets of information to be typed into form fields: Username & Password OR Service Account ID & Zip code.

No3

Autofill compliant fields for authentication Phase 1 Reduce all legalese language while maintaining the availability of all legalese Phase 1 Improve clarity of language that helps the majority of customers understand what they are agreeing to by using clear and concise plain English.

Phase 1

Eliminate all "screen clutter" including any links, images, or space that does not directly related to helping the customer with Rule 24 registration

Phase 1

When the page is displayed on mobile devices, all elements and fields required to complete the process shall be visible and interactable above 600 pixels below the top of the screen (or similar as dimensions may change and screen height/width ratios change)

Phase 1

When the page is displayed on desktop devices, all elements and fields required to complete the process shall be visible and interactable above 1000 pixels below the top of the screen (or similar as dimensions may change and screen height/width ratios change)

Phase 1

Do not allow the user to complete the Authorization process if they change configurations such that the DRP's service will no longer be viable given the modified configurations

Phase 1 & Phase 2

Phase 1 OAuth Improvements: • Dual Third Party Authorizations

PG&E will implement changes in multiple areas to support dual third party authorizations including the third party registration and testing process, customer authorization and revocation functionality, and API and token management. DRPs will 2 PG&E considers the use of two static, specific fields insufficient to properly authenticating a customer over time, because this does not take into account the rapidly evolving best practices for protecting online privacy and for preventing online fraud and identity theft. The utilities will determine the elements used for the alternative authentication process and can change them, as long as the evolving authentication techniques are no more onerous than required to engage in similar online utility transactions, such as a PG&E My Energy account. 3 Ibid.


be allowed to register as either a primary or secondary third party and select a partner third party of a different type. DRPs who register as a primary third party must support OAuth authorization by customers. Secondary third party partners will not need to perform OAuth, but will be presented to the customer at the time of primary third party initiated OAuth authorization as a secondary third party also being authorized to receive data. Secondary third parties will be able to subsequently request the same data over API as the primary third party using their third party client token. If a customer or DRP later modifies or cancels an authorization that is part of a dual authorization, the changes will affect both DRPs.

• Streamlining Authorization Pages As per the DRP requested user experience requirements, PG&E will implement changes to Share My Data authorization pages to eliminate un-necessary screen clutter, reduce legal language, and condense the number of authorization pages and steps to 1.

• Responsive Design As per the DRP requested user experience requirements, PG&E will optimize the Share My Data authorization page to display in a user-friendly manner on mobile and desktop devices.

• Online Authorization of Rule 24 Actions PG&E will implement changes to the Share My Data authorization pages to indicate customers are also authorizing ‘actions’ to be taken on their behalf to support third party DRP services including meter reprogramming to provide more granular data and de-enrollment from certain PG&E supported DR programs. This would be in addition to additional capabilities for customers to use Share My Data to authorize sharing of Rule 24 related data elements (See Data Delivery Project section).

• DRP Authorization Cancellation DRPs will be provided a new API to trigger cancellations of customer authorizations. The ability for DRPs to cancel an authorization will be indicated as part of the terms and conditions when customers initially authorize on Share My Data. Phase 2 OAuth Improvements:

• Alternative Authentication PG&E will implement changes to support an alternate customer authentication for Share My Data that does not require customers to have previously registered for MyAccount so as to provide a username and password. To implement alternative authentication, PG&E intends to leverage an existing "One Time Access" alternative authentication mechanism that allows customers to authenticate without username/password for a limited set of functionality. PG&E intends to leverage this mechanism for alternative authentication related to Share My Data authorizations. Alternative authentication through this mechanism currently requires users populate two fields at best, however due to changing security and privacy considerations this requirement is subject to change in the future. Specifically,


PG&E's "One Time Access" feature allows residential customers to provide their Account Number and the last 4 digits of social security number, while business customers provide their Account Number and the last 4 of their tax ID. PG&E notes this existing alternative authentication mechanism has been extensively reviewed and approved by security, and to implement a separate independent mechanism specific to Share My Data authorizations would represent significant cost and ultimately may not be approved by PG&E security and privacy. For authorizations initiated using alternative authentication, customers' online authorization management capabilities may not be as automated. Customers may need to contact Share My Data Operations team to cancel or update an authorization initiated via alternative authentication mechanisms or otherwise request the authorized DRP cancel the authorization.

• Forgot Password In instances where customers are redirected by a third party to Share My Data and forget their password, DRPs have requested the customer remains in the Share My Data authorization flow after resetting their password. PG&E's existing forgot password flow used for MyAccount authentication takes a customer out of the authentication flow via a reset link that is emailed to the customer. At best, PG&E will maintain the context of a Share My Data third party Authorization flow only when the customer clicks the custom link PG&E sends to the customer's email. In respect to DRPs' request to expand the scope of the original Forgot password requirement in Appendix E of the Informal Status Report to also cover forgot username and new user registration scenarios, the expansion in scope will not be supported by PG&E. In respect to maintaining authorization flow for the forgot username flow, the current process takes the customer out of the authentication flow by sending their username to their MyAccount associated email with no link back to MyAccount. In respect to MyAccount new user registration, the new user registration flow is used across the MyAccount customer platform and is not easily changed. Given PG&E will also be implementing alternative authentication in addition to support for maintaining the authorization flow during forgot password scenarios, PG&E will not be implementing the expanded version of this requirement as it relates to forgot username and new user registration.

• OAuth 2.0 conformity PG&E will implement changes to conform to the OAuth 2.0 specification. These changes include the ability for DRPs to redirect customers directly to the authorizationServerAuthorizationEndpoint and pass a dynamic scope string and state parameters as part of the redirect. These changes will allow for customer authorization selections related to authorized data elements and authorization end date selection to be dynamically pre-populated on a customer per customer basis, enabling a true 1-click authorization experience whereby the customer either agrees to authorize or not and return to the third party. As these changes cannot be accommodated as part of PG&E’s initial Phase 1 project due to the varied scope already included, PG&E proposes as part


of its Project Phase 1 release to pre-populate customer authorization pages based on DRP’s registration selections during the Share My Data registration process, in order to still allow a customer to at best, experience a 1-page, 1-click authorization process.

• Requesting New Access Token In instances where a third party has lost the authorization code or access_token from a previous authorization, PG&E will update Share My Data to allow third parties to simply redirect the customer back to the OAuth interface (authorizationServerAuthorizationEndpoint) again to initiate a new authorization flow in the same way as was done for the first authorization.


Appendix C: Full List of Rule 24 Data Items with the Expanded Data Set Rule 24 Data Element Currently Available To Be Added Account Elements

Account name (ACME INC. or JOE SMITH) Yes Yes, SMD API

Account address (123 OFFICE ST...) No Yes, SMD API Account ID (2-xxx...) No Yes, SMD API

Outage block (A000) No Yes, proposed for flat file Service Elements

PG&E Unique Identifier Yes Yes, SMD API Service ID (3-xxx...) Yes Yes, SMD API Known future changes to Status of Service No Yes, proposed for flat file

Service address (123 MAIN ST #100...) Yes Yes, SMD API Service tariff (D-TOU) Yes Yes, SMD API Service tariff options (CARE, FERA, etc.) No Yes, proposed for flat file Service voltage (if relevant) Yes Yes, SMD API Service meter number (if any) Yes Yes, SMD API # of Service meters Yes Yes, SMD API Meter Read Cycle Yes Yes, SMD API Sublap Yes Yes, SMD API Known future changes to Sublap No Yes, proposed for flat file Pricing Node Yes Yes, SMD API Known future changes to Pricing Node No Yes, proposed for flat file Local Capacity Area No Yes, proposed for flat file Known future changes to Local Capacity Area No Yes, proposed for flat file

Standby Rate Option if On-Site Generation No Yes, SMD API 4

Customer Class Indicator No No5 Historical bills No6 Billing Elements

Bill start date Yes Yes, SMD API Bill end date Yes Yes, SMD API Bill total charges ($) Yes Yes, SMD API Bill total kWh Yes Yes, SMD API

Bill tier breakdown (if any) Name (Over Baseline 1%-30%) No Yes, SMD API Volume (1234.2) No Yes, SMD API Cost ($100.23) No Yes, proposed for flat file

4 The rate schedule includes a leading "S" when customer is on Standby. 5 The working group discussed that customer class is to be defined as described in the Rule 24 tariff and the DRAM contract, but in reviewing this calculation, the DRP has all of the data elements necessary to perform this calculation, so it is unnecessary for PG&E to provide it. 6 PG&E’s review has resulted in concerns over customer privacy, scope of this data item in the context of participation in the CAISO market, and release of confidential data that PG&E is not permitted to disclose for all customers.


Rule 24 Data Element Currently Available To Be Added Bill TOU kwh breakdown (if any)

Name (Summer Off Peak) Yes Yes, SMD API Volume (1234.2) Yes Yes, SMD API Cost ($100.23) No Yes, proposed for flat file

Bill demand breakdown (if any) Name (Summer Max Demand) Yes Yes, SMD API Volume (1234.2) Yes Yes, SMD API Cost ($100.23) No Yes, proposed for flat file

Bill line items (sum should equal bill total charges above)

Charge name (DWR Bond Charge) No Yes, proposed for flat file Volume (1234.2) No Yes, proposed for flat file Unit (kWh) No Yes, proposed for flat file Rate ($0.032/kWh) No Yes, proposed for flat file Cost ($100.23) No Yes, proposed for flat file

Tracked line items Charge name (e.g. Net In/Net Out) No Yes, proposed for flat file Volume (1234.2 in kWh) No Yes, proposed for flat file Unit (kWh) No Yes, proposed for flat file Rate ($0.032/kWh, if any) No Yes, proposed for flat file Cost ($100.23, if any) No Yes, proposed for flat file

Payment Information No No7 Historical Intervals

Start Yes Yes, SMD API Duration Yes Yes, SMD API Volume (1234.2) Yes Yes, SMD API Unit (kWh) Yes Yes, SMD API

Utility Demand Response Programs Program Name Yes Yes, SMD API Capacity Reservation Level (CRL) for CPP/PDP customers No Yes, proposed for flat file

DR Program Nomination if fixed No Yes, proposed for flat file Earliest Termination Date from UDC DR Program without Financial Obligation Yes Yes, SMD API

Earliest Termination Date from UDC DR Program regardless of Financial Obligation

Yes Yes, SMD API

Service Providers LSE Yes Yes, SMD API Known future changes to LSE No Yes, proposed for flat file MDMA Yes Yes, SMD API MSP Yes Yes, SMD API

Contact Information for LSE, MDMA, MSP Yes Yes, already provided separately in a manual process

7 PG&E’s review has resulted in concerns over customer privacy, scope of this data item in the context of participation in the CAISO market, and release of confidential data that PG&E is not permitted to disclose for all customers.


Appendix D: Proposed Modifications to Rule 24

Pacific Gas and Electric Company San Francisco, California U 39

Revised Cal. P.U.C. Sheet No. 33694-E Cancelling Revised Cal. P.U.C. Sheet No. 33506-E

ELECTRIC RULE NO. 24 Sheet 1

DIRECT PARTICIPATION DEMAND RESPONSE

(Continued)

Advice Letter No: 4361-E-A Issued by Date Filed April 2, 2014 Decision No. Brian K. Cherry Effective March 3, 2014 Vice President Resolution No. E-4630 1C0 Regulatory Relations

TABLE OF CONTENTS

A. APPLICABILITY B. DEFINITIONS C. GENERAL TERMS D. ACCESS TO CUSTOMER DATA E. DEMAND RESPONSE PROVIDER (DRP) SERVICE ESTABLISHMENT F. METERING SERVICES G. DISCONTINUATION OF SERVICE BY DRP H. CREDIT REQUIREMENTS I. COMPLAINT AND DISPUTE RESOLUTION PROCESSES J. ACRONYMS





(Continued)

Advice Letter No: 4831-E-A Issued by Date Filed May 20, 2016 Decision No. Steven Malnight Effective November 30, 2016 Senior Vice President Resolution No. 2C0 Regulatory Affairs

A. APPLICABILITY

This Rule establishes the terms and conditions that apply to those entities, which are subject to this Rule, who wish to take part in Direct Participation Demand Response Service (“DR Service”). DR Service is offered by the California Independent System Operator (CAISO) and allows a Demand Response Provider (DRP) or a retail customer to participate or “bid-in” directly into the CAISO wholesale market for compensation by the CAISO, in accordance with the market awards and dispatch instructions established by the CAISO. DRP DR Services under this Rule are subject to the dual participation rules. As a general rule, DRPs are prohibited from registering customer service agreements that are already registered with another DRP or that are participating in a PG&E event-based demand response program(s). (See Section C.2.d for detailed rules)

1. Entities and Services Subject to Rule 24

a. PG&E acting on behalf of its customers as the Load Serving Entity (LSE),

DRP, Utility Distribution Company (UDC), Meter Data Management Agent (MDMA), or Meter Service Provider (MSP).

b. Affiliates of PG&E acting as a DRP c. Non-Utility affiliated DRPs enrolling PG&E Bundled Service customers. d. Bundled Service customers acting as a DRP for their own load.

2. Entities Not Subject to Rule 24

a. Non-Utility DRPs enrolling only Direct Access (DA), or Community Choice

Aggregation (CCA) Service customers,

b. DA, or CCA Service customers acting as a DRP for their own load, c. Electric Service Providers (ESPs) and CCAs acting as a LSE for DA, or CCA

Service customers, d. Non-Utility affiliated MDMAs and MSPs providing metering services to DA

Service customers.

The descriptive headings of the various sections of this Rule have been inserted for convenience of reference only and shall in no way define, modify, or restrict any of the terms and provisions thereof.





(Continued)

Advice Letter No: 4742-E Issued by Date Filed November 20, 2015 Decision No. Steven Malnight Effective January 1, 2016 Senior Vice President Resolution No. 3C0 Regulatory Affairs

B. DEFINITIONS Certain specific terms used in this Rule are defined below. Additional definitions for more widely used terms in PG&E’s tariffs are also found in Electric Rule 1. 1. AFFILIATE: Any legal entity in which five percent or more of the outstanding

shares are owned, controlled, or held with power to vote, directly or indirectly either by the DRP or any of its subsidiaries; or by the DRP’s controlling entity or any of its subsidiaries; or by any company in which the DRP, its controlling entity, or any of the DRP’s affiliates, exert substantial control over the operation of the company or indirectly have substantial financial interests in the company which is exercised through means other than ownership. For purpose of this definition, “substantial control” includes, but is not limited to, the possession, directly or indirectly and whether acting alone or in conjunction with others, of the authority to direct or cause the direction of the management or policies of the company. A direct or indirect voting interest of five percent or more by the DRP in an entity’s company creates a rebuttable presumption of control.

For the purposes of this Rule, Utility affiliates participating in DR Services are considered “non-Utility DRPs”.

2. AGGREGATOR: An entity that contracts with end-use customers in multiple

locations to help provide them with DR Services. For instance, an Aggregator will consolidate customers’ loads so that they may be put into a single CAISO demand response resource. An Aggregator will also generally perform customer-facing functions such as customer marketing, communications and payments for participation. An Aggregator might utilize a CAISO DRP to bid DR resources into the CAISO market or elect to become a CAISO DRP itself.

3. CAISO’s DR Service: The CAISO’s wholesale DR market mechanism(s),

market model(s), and/or market product(s) that allow retail customers’ loads to be bid in to the CAISO’s wholesale markets.

4. CAISO DEMAND RESPONSE PROVIDER (CAISO-DRP): An entity that is

responsible for delivering certain DR Services into the CAISO’s wholesale market and which has undertaken, in writing, by execution of the applicable agreement to comply with all applicable provisions of the CAISO Tariff. CAISO-DRP functions generally include registering customer service accounts or agreements in the Demand Response Registration System (DRRS) and working with a Scheduling Coordinator to bid into and settle with the CAISO market.

5. CISR-DRP: The customer information service request form (Form 79-1152 or its

successor) approved by the Commission for customers to authorize the release of their customer information under Section D. 1. a. of Electric Rule 24 to a non-utility DRP for purpose of direct participation in the CAISO wholesale market, or the authorized electronic authorization processes on PG&E’s website or from a DRP website for customer authorization to release its customer information to the DRP, for the purpose of direct participation.





(Continued)

Advice Letter No: 4742-E-A Issued by Date Filed December 21, 2015 Decision No. Steven Malnight Effective January 1, 2016 Senior Vice President Resolution No. 4C0 Regulatory Affairs

B. DEFINITIONS (CONT’D.)

65. CPUC DEMAND RESPONSE PROVIDER (DRP): An entity that is responsible for performing any or all of the functions associated with either a CAISO-DRP and/or an Aggregator. DRPs serving bundled customers must register with the CPUC and CAISO DRP’s must also register with the CAISO. Unless otherwise specifically stated, all references to “DRP” herein shall refer to this definition.

Any of the following entities may elect to become a DRP: PG&E, non-Utility entities such as Electric Service Providers (ESPs) and Community Choice Aggregation (CCA) entities who elect to participate in CAISO DR Services with bundled service customers, a third-party who wishes to bid in bundled service accounts in the CAISO wholesale market, or a bundled service retail customer (bidding in its own load). Unless otherwise specifically stated, all references to “DRP” herein shall refer to all of these entities.

76. DEMAND RESPONSE (DR): The load reduction and/or increase by retail customers in response to a signal or pricing mechanism. Currently under this tariff, Demand Response is bid into the wholesale market as a Proxy Demand Resource or a Reliability Demand Response Resource as defined and offered under CAISO tariffs.

87. DEMAND RESPONSE (DR) SERVICE: DR Service in this Rule generally refers to demand response activities associated with a DRP’s or a customer’s direct participation in the CAISO’s wholesale market where a retail customer, either on its own or enrolled in a DRP’s DR Service, changes its electric demand in accordance with the market awards and dispatch instructions established by the CAISO.

98. DRP’s DR Service: A DR program or service provided by the DRP to one or more retail customers to bid loads on their behalf into the CAISO wholesale energy market using the CAISO’s DR Service(s).

109. EVENT-BASED DEMAND RESPONSE: The dispatchable load reduction or increase by retail customers in response to a day-ahead or day-of event signal.

110. INTERVAL METER: For the purposes of this rule, an “interval meter” is defined as a meter and communication system capable of measuring, storing, and transferring the minimum data required for the CAISO’s settlement processes. Minimum data requirements are specified by the CAISO and vary by the CAISO’s DR Services.


Revised Cal. P.U.C. Sheet No. 36694-E Cancelling Original Cal. P.U.C. Sheet No. 35857-E



(Continued)


B. DEFINITIONS (CONT’D.) 121. PRICING NODE (PNode): A single network Node or subset of network Nodes

where a physical injection or withdrawal of electricity is modeled and for which a Locational Marginal Price is calculated by the CAISO and used for financial settlements. A network Node is a point in the CAISO’s Full Network Model representing a physical location within the CAISO’s Balancing Authority Area or the CAISO Controlled Grid.

132. RELEVANT CAISO DEMAND RESPONSE SYSTEMS (Relevant Systems):

One or more of the information technology (IT) systems that the CAISO uses to complete the necessary steps to allow DRPs to provide DR Services under its tariff. These systems include but are not limited to the CAISO’s Demand Response System and the Demand Response Registration System and their successors. User Guides can be found on the CAISO’s website (www.caiso.com)

143. RESOURCE REGISTRATION: Entry by a DRP of the physical location(s) of

one or more retail customer’s loads into the CAISO’ Relevant Systems. 154. REVENUE QUALITY METER DATA (RQMD): Interval Meter Data that has

been validated, edited, and estimated in accordance with the Direct Access Standards for Metering and Meter Data (DASMMD) as described in Electric Rule 22.

165. SERVICE AGREEMENT (SA): For the purposes of this Rule, a customer’s

service agreement refers to a PG&E-specific identifier for tracking and measuring energy service deliveries for retail billing purposes of a specific load associated to a specific physical location.

176. SETTLEMENT QUALITY METER DATA (SQMD): SQMD is RQMD that has

been processed, aggregated, formatted, and stored pursuant to CAISO’s procedures for CAISO’s settlement and auditing purposes. See CAISO Tariff Appendix A, Master Definitions Supplement.

187. SUB-LAP (S-LAP): A CAISO defined subset of PNodes within a Default Load

Aggregation Point (DLAP). 198. TELEMETRY: An electric meter capable of recording, storing, and

transferring the minimum data required in accordance with the CAISO’s telemetry technical requirements (current technical requirements are available on the CAISO’s website (at www.caiso.com).

2019. UNIQUE CUSTOMER IDENTIFIER: An identifier assigned by the UDC and

entered into the CAISO’s Relevant Systems by a DRP. The identifier is specific to a customer’s Service Account. PG&E will assign a unique customer identifier for a customer’s service account or service agreement.

http://www.caiso.com/





(Continued)


B. DEFINITIONS (CONT’D.)

210. UTILITY DISTRIBUTION COMPANY (UDC): An entity that owns or operates a distribution system for the delivery of energy to and from the CAISO controlled grid. PG&E is the applicable UDC under this Rule.

Herein, the “Utility” is PG&E and it may serve one or more of the following functions: UDC, LSE, MDMA, MSP and DRP.

C. GENERAL TERMS

1. General Obligations of PG&E

a. Non-Discrimination and Competitive Neutrality

(1) Neutral Discharge of Responsibilities

PG&E, acting in any capacity described herein, shall discharge its responsibilities in a neutral manner to all DRPs. When acting as an MDMA, this would include ensuring that the meter data for each service agreement sent to the DRP meets the current validated, edited, and estimated (VEE) standards established in the Direct Access Standards for Metering and Meter Data (DASMMD). Unless otherwise authorized by the California Public Utilities Commission (CPUC or Commission), the Federal Energy Regulatory Commission (FERC), or the affiliate transactions rules1, PG&E shall not provide or represent that it will provide to itself, its affiliates or customers of itself or its affiliates any preferential treatment with regard to PG&E services than other, unaffiliated, service providers would receive, including, but not limited to, terms and conditions, information, pricing or timing.

_______________________ 1 D.97-12-088, 77 CPUC 2d 422, 449, as amended by D.98-08-035, 81 CPUC 2d 607 and D.98-12-

075, 84 CPUC 2d 155, D.06-06-062 and D.06-12-029.





(Continued)


C. GENERAL TERMS (CONT’D.)

1. General Obligations of PG&E (Cont’d.)

a. Non-Discrimination and Competitive Neutrality (Cont’d.)

(2) Non-Discriminatory Response to Requests for PG&E Services PG&E, acting in any capacity, shall process requests for similar PG&E services in the same manner and within the same period of time for its affiliates, customers of itself and its affiliates, and for all unaffiliated market participants and their respective customers. PG&E shall provide non-discriminatory access to its meter data, where available, to third-party DRPs when authorized by the customer. In particular, PG&E shall not have any greater access to meter data for the purposes of fulfilling its DRP duties and obligations than does a third-party DRP.

(3) Competitive Neutrality Confidential, competitive information received by PG&E from unaffiliated DRPs, or from the CAISO about the DRPs or their customers, in connection with PG&E’s performance of its duties to implement and administer the DRP’s use of PG&E’s bundled load for DR Services shall be limited to PG&E staff who are responsible for performing PG&E’s non-DRP responsibilities under this Rule. Such confidential, competitive information shall not be used to promote PG&E’s services to its customers or customers of its affiliates. PG&E staff receiving such confidential, competitive information from the DRPs or the CAISO in the discharge of PG&E’s roles and responsibilities as a non-DRP shall not share such confidential, competitive information with other individuals in PG&E who are also responsible for discharging PG&E’s roles and responsibilities as a DRP under this Rule.

b. Timeliness and Due Diligence

Consistent with state law and CPUC decisions, PG&E acting in any capacity shall exercise due diligence in meeting its obligations and deadlines under this Rule so as to facilitate a customer’s election to participate in a DRP’s DR Service in CAISO’s wholesale markets as quickly as possible.





(Continued)


C. GENERAL TERMS (CONT’D.) 1. General Obligations of PG&E (Cont’d.)

c. Review of DRP Customer Service Agreement(s) in the CAISO’s Relevant Systems

PG&E, acting as an LSE, shall review all customer service agreement(s) (within its electric service territory) submitted by a DRP to the CAISO’s Relevant Systems as defined in the CAISO tariff. PG&E’s review shall be limited to ensure accuracy of the customer information presented and that the customer is not otherwise participating in a PG&E event based demand response program at the same time period. PG&E shall also review customer service agreement(s) submitted to the CAISO’s Relevant Systems for Entities not subject to this Rule in the same manner contained in this subsection and on the same non-discriminatory basis.

PG&E will conduct such review in accordance with the timelines set forth in the CAISO’s Business Practice Manuals (BPMs). PG&E shall notify the CAISO and the DRP within ten (10) business days if the customer information presented in the registration submitted to the CAISO’s Relevant Systems is inaccurate, if the DRP is not appropriately registered for DRP DR Services at the CPUC, and confirm that the customer service agreement does not conflict with the dual participation rules in Section C.2.d To the extent reasonable and feasible, PG&E and the DRP shall coordinate and cooperate to ensure an accurate registration of the customer service agreement.

d. Provision of Customer Data by PG&E

In response to a completed, customer authorized submittal of PG&E’s Form 79-1152 (CISR-DRP) by a customer or non-Utility DRP, PG&E shall in a timely fashion provide the required information to the DRP to facilitate a customer’s enrollment in a DRP DR Service(s). This information will be provided in accordance with Section D of this Rule. The customer may also request the timeframe of continuous meter data transmittal or how. The customer or its authorized DRP may instruct PG&E to terminate the continuous data release at any time by using the CISR-DRP shall be terminated.

e. PG&E Tariffed Demand Response Programs

For those customers enrolled in a PG&E event-based demand response program, PG&E will act as the customer’s DRP if PG&E elects to submit the customer into the CAISO’s DRS. This customer could be a PG&E Bundled Service, Direct Access, or Community Choice Aggregation Service customer.





(Continued)



1. General Obligations of PG&E (Cont’d.)

f. KYZ Pulse Installations

Upon the request of and payment by the customer or its agent, PG&E, acting as the MSP, shall install where feasible a KYZ pulse initiating device or another acceptable telemetry solution. A DRP may, with the permission of the CAISO, use the information from such a device to submit preliminary settlement data to the CAISO. The customer or its DRP will be responsible for the cost of the installation. If the customer wishes to terminate the delivery of its KYZ pulse data to the DRP at any time, the DRP will take action, upon receipt of notification from the customer, to discontinue data transmission from its facilities, as soon as practicable, but no later than 45 days after customer notification of termination, to allow for financial settlements to occur.

2. General Obligations of DRPs Enrolling Bundled Service Customers

This Section is applicable to all DRPs enrolling Bundled Service customers, unless otherwise specified. Requirements for PG&E, acting as the DRP for DA, CA and CCA Service customers, are specified in Section D. a. Timeliness and Due Diligence

DRPs shall exercise due diligence in meeting their obligations and deadlines under this Rule so as to facilitate customer enrollment in DRP DR Service in a timely manner. To the extent ordered by the CPUC, DRPs shall make all payments resulting from CPUC-authorized charges owed to PG&E for services specified under this Rule in a timely manner subject to applicable payment dispute provisions.

b. Arrangements Between DRPs and Their Customers

DRPs shall be solely responsible for having appropriate contractual or other arrangements with their customers necessary to implement DRP DR Service consistent with all applicable laws, CAISO requirements, CPUC requirements, if any, and this Rule.

c. Scheduling Coordinator (SC)

In accordance with the CAISO’s tariff, a DRP must become or contract with a SC prior to registering customers into a CAISO’s Relevant Systems. PG&E shall not act as an SC on behalf of a non-Utility DRP. The DRP must obtain its own SC to participate in DR Services or otherwise qualify to act in that capacity.





(Continued)



2. General Obligations of DRPs Enrolling Bundled Service Customers (Cont’d.)

d. Dual Participation

DRPs are prohibited from placing a customer’s service agreement into the CAISO’s Demand Response (DR) System for any time period within the Start Date and End Date of another DRP’s registration of the customer’s service agreement and that has been given a “Confirmed” status by the CAISO under its rules and procedures. Non-Utility DRPs are also prohibited from enrolling and registering a customer service agreement in DR Services if the customer is already enrolled in a PG&E event-based demand response program. The customer can disenroll from the PG&E program at any time if it withdraws to enroll in a DRP service. When a DRP is notified by PG&E via its CISR-DRP process that a customer is already enrolled in a PG&E event-based DR program, it is the notified DRP’s obligation to ensure that the customer has disenrolled from PG&E’s event-based demand response program before placing the customer service agreement in the CAISO’s Relevant System for the same period. The effective date to disenroll that customer from its current program to enroll it in DRP’s DR Service will be established in accordance with PG&E’s demand response program rules and its Electric Rule 12. In the event of a conflict between PG&E’s DR program specific requirements and its Electric Rule 12, the program’s tariff requirements will apply. For instance, a customer who is currently participating in a PG&E event-based demand response program and wishes to enroll with a non-Utility DRP DR Service must first disenroll from PG&E’s program. Disenrollment will be subject to any contractual or program obligations currently in effect with PG&E’s demand response program. Similarly, if a customer is currently registered at the CAISO for DR Services, that customer must be disenrolled prior to that customer’s participation in either another DRP’s registration or a PG&E event-based demand response program. However, a DRP is not prohibited from also enrolling and registering its own customers for other DR Service(s) that it offers. It is the DRP’s obligation to ensure the DRP’s customer service agreements do not conflict with the CAISO rules on DR Services.





(Continued)




d. Dual Participation (Cont’d)

Customers enrolled in PG&E’s Peak Day Pricing program will be automatically disenrolled from the program upon registration by a non-Utility DRP of the customer’s service agreement that has been given a “Confirmed” status by the CAISO. Under PG&E’s Electric Rule 12, the earliest disenrollment date for Peak Day Pricing is the customer’s next meter read date. Therefore, the Start Date of a non-Utility DRP customer service agreement registration for which the customer service account is enrolled in Peak Day Pricing would be on the next or future meter read date. PG&E shall provide a one-digit meter read cycle letter to the non-Utility DRP via Form 79-1152 (its CISR-DRP process) as also described in Section D.1.a. It is the DRPs’ obligation to use the cycle letter and match it for the customer service agreement or account’s next or future meter read date(s) from PG&E’s meter reading schedules. PG&E’s meter reading schedules can be found in http://www.pge.com/myhome/customerservice/smartmeter/analogmeters/schedule/. If a customer is a residential or small commercial customer, non-Utility DRPs shall notify the customer prior to the registration of the customer service agreement or account in the CAISO Relevant System through the Customer Notification Form Letter, required in Section C.7, that the customer will be disenrolled from Peak Day Pricing and may lose bill protection, if applicable. When PG&E is acting as a DRP, it is obligated to ensure that the customer has disenrolled from non-Utility DRP’s DR Service before enrolling the customer in its own event-based program.

e. Resource Registration of DR Resources at the CAISO

DRPs shall be solely responsible for registering DR resources at the CAISO with the customers to whom they are providing DRP DR Services.

f. Notification of Customer Enrollment in DRP DR Service

The CAISO, through its registration process, will make available to PG&E, as an LSE, the ability to verify its customers’ enrollment status and other information pertinent to the DRP’s customers’ participation in DR Services. DRPs shall not be responsible for providing separate notification to PG&E of an enrollment of a customer in DRP DR Services.

http://www.pge.com/myhome/customerservice/smartmeter/analogmeters/schedule/

http://www.pge.com/myhome/customerservice/smartmeter/analogmeters/schedule/





(Continued)




g. Utilizing the MDMA for Revenue Quality Meter Data

DRPs shall utilize the MDMA chosen by the customer (or the customer’s LSE) for gaining access to Revenue Quality Meter Data (RQMD).

h. Utilizing the MDMA for Settlement Quality Meter Data The MDMA shall be responsible and liable to send timely and accurate individual customer RQMD to the DRP, or its designated agent, who shall convert this data to Settlement Quality Meter Data (SQMD) and send it to its Scheduling Coordinator (SC). (See Section F.2 for detailed rules)

For Direct Access customers, DRPs may contract with the MDMA chosen by the customer (or the customer’s LSE) for submitting SQMD to the DRP’s SC.

i. Access to Electronic Data by non-Utility DRP

For non-Utility DRPs electing to use PG&E’s Electronic Data Interchange (EDI) functionality when PG&E serves as an MDMA, PG&E shall provide these DRPs with access to the appropriate electronic platform (e.g. the MDMA server) to facilitate energy data exchanges required for DRP’s DR service(s). The requirements for such access are found in Section E.4 below.

j. Net Benefits Test

All DRPs bidding Bundled Service customer’s load into the CAISO’s wholesale market using the CAISO’s DR Service(s) must submit bids that are at or above the Net Benefits Test described in Section 30.6.3 of CAISO’s Fifth Replacement FERC Electric Tariff.





(Continued)



3. Transfer of Cost Obligations Between DRPs and Customers Nothing in this Rule is intended to prevent DRPs and customers from agreeing to reallocate between them any costs for DRP’s DR Services that are subject to this Rule to be paid by either of them.

4. LSE Is Not Liable for DRP DR Services

To the extent the customer takes service from a DRP, the customer’s LSE has no obligations to the customer with respect to the services provided by the DRP.

5. DRP is Not Liable for LSE’s Services

The DRP has no obligations to the customer with respect to the services provided by that LSE. The customer must look to its LSE, not the DRP, to carry out the responsibilities associated with those services.

6. Split Loads Not Allowed

Customers requesting DRP DR Service may not partition the electric loads of a service agreement or service account among different DRPs at any one time. The entire load and load reduction for a service account can be registered in the CAISO’s DRS to only one DRP at any one time.

7. Formal Notification for Residential and Small Commercial Customers

Residential customers are defined as PG&E customers who are eligible for service under one of its residential rate schedules. Small Commercial customers are defined as any non-residential customers with a maximum billing peak demand of less than 20 kilowatt (kW). Non-Utility DRPs intending to enroll Residential and Small Commercial customers in DR Services are required to meet additional CPUC requirements before submitting such customer service accounts for Resource Registration at the CAISO Relevant System. These DRPs must obtain approval from the CPUC’s Energy Division for a Customer Notification Form Letter (Form Letter), in hard copy or electronic form, to be provided to each customer explaining the DRP’s terms and conditions of participating in the DRP’s DR Service. If the customer is enrolled in PG&E’s Peak Day Pricing program, the Form Letter shall also provide the estimated disenrollment date from Peak Day Pricing and that the customer may lose bill protection, if applicable. The disenrollment date shall be on the customer’s next or future meter read date (see Section C.2.d)





(Continued)



7. Formal Notification for Residential and Small Commercial Customers (Cont’d.) The non-Utility DRP must provide the Form Letter to the customer before placing its service account in a DRP’s Resource Registration in the CAISO Relevant System. The Form Letter shall provide any grace period in which the customer can cancel the DR Service enrollment without any charges or penalties.

8. Master Metered Customers

Master metered customers who provide sub-metered tenant billings may participate in DRP DR Service as only a single master service account. A master-metered customer may not partition the electric loads of a single master meter among several DRPs.

9. Service Fees and Other Charges

PG&E may incur costs in order to facilitate a non-Utility DRPs’ participation in CAISO’s DR Services. Any fees to reimburse PG&E for these costs are described in PG&E rate Schedule E-DRP and must be paid on a timely basis to ensure service under this Rule.





(Continued)


D. ACCESS TO CUSTOMER DATA 1. Access to Customer Usage Data – Release of Information to non-Utility DRPs

PG&E will provide confidential customer-specific information and usage data for a bundled, DA or CCA service customer to parties specified by that customer, subject to PG&E’s Rule 27, and the following provisions: a. The inquiring party must have customer authorization using Form pursuant

to a CISR-DRP before a customer’s personally identifiable information can be released. The information, upon such authorization, will be released only to the inquiring party, unless otherwise authorized by the customer, as part of the Form CISR-DRP process. The inquiring party as the recipient of this data agrees to abide by the applicable Commission customer privacy requirements. For the purposes of this program, the Form CISR-DRP shall permit the customer to authorize the following: (1) Customer Service Agreement and Account information, including

without limitation, service address and rate schedule. (2) Up to 48 months 1 year of historical interval data, monthly billed usage,

tier breakdown, bill line items, billed charges, as applicable, if it is available for that specific service agreement.

(3) Unique Customer Identifier to track customer service agreement in

CAISO Relevant Systems. This information will be provided to the customer’s Load Serving Entity (LSE) too if different from PG&E.

(4) Customer one-digit meter read cycle letter for purposes of verifying

Meter Read Date and date to begin DR Service.

(5) Ongoing monthly interval usage data (6) Ongoing monthly billed usage, tier breakdown, bill line items, billed

charges, rates, as applicable, for that specific service agreement. A maximum of the most recent twelve (12) months of customer billing data or the amount of data recorded for that specific service agreement.

b. When a CISR-DRP is received, PG&E shall also transmit the following data,

defined as Confidential Information in the DRP Service Agreement (Form 79-1160), to the non-Utility DRP:

(1) Confidential end-user information such as customer’s service voltage,

the sub-Load Aggregation Point (sub-LAP) and Pricing node (Pnode), Local Capacity Area, the identity and contact information of customer’s LSE, MDMA and MSP. PG&E will also provide known future changes to i) the customer’s load serving entity, and ii) the status of a service agreement ID, including the expected change date, if applicable.





(Continued)


(2) PG&E’s demand response program(s) and tariff schedule(s) in which the service agreement(s) or account(s) are currently enrolled and the estimated date of when the customer may be eligible to participate in DR Service without





(Continued)


D. ACCESS TO CUSTOMER DATA (CONT’D.) 1. Access to Customer Usage Data – Release of Information to non-Utility DRPs

(Cont’d)

b. When a CISR-DRP is received, PG&E shall also transmit the following data, defined as Confidential Information in the DRP Service Agreement (Form 79-1160), to the non-Utility DRP (Cont’d):

(2) PG&E’s demand response program(s) and tariff schedule(s) in which

the service agreement(s) or account(s) are currently enrolled and the estimated date of when the customer may be eligible to participate in DR Service without direct financial consequence from PG&E. Applicable PG&E demand response tariffs include: PG&E’s Schedule(s) E-RSAC, E-CSAC, E-DBP, E-SLRP, E-OBMC, E-CBP, E-RSMART, and E-BIP and PG&E’s Aggregator Managed Portfolio (AMP). PG&E will also indicate if account(s) listed above is participating in the Peak Day Pricing option of its applicable rate schedule.

PG&E shall also provide information, as it is available, on the earliest eligible date(s) on which the customer can leave its current program without any contractual or program obligations under the terms and conditions of the tariff that may result in financial or tariff implications such as but not limited to, losing bill protection or incentive payments, return of received incentives, and/or penalties.

(3) Basic meter information including the meter number, the type of meter

and the intervals currently being collected by the meter.

c. Customer information specified in Sections D.1.a.(1-3) will be released to the customer or its authorized agent up to two (2) times per year per service agreement or account at no cost to the requesting party. Thereafter, PG&E may have the right to assess a processing charge as approved by the CPUC. Customer data specified in Section D.1.a.(5) will be released to the customer or its authorized agent on an ongoing basis at charges authorized by the CPUC, unless provided through electronic means, as outlined in Metering Services, Section F.

d. When a CISR-DRP is received by PG&E, the customer also:

(1) Grants the DRP permission to request that PG&E shorten the interval length of its electric meter(s), as made available by PG&E, for the Service Agreement(s) listed above (when PG&E is the Meter Service Provider for the Service Agreement(s)).

(2) Acknowledges and Authorizes that if it is on Peak Day Pricing (PDP), it

will automatically be unenrolled from PDP when a DRP enters its Service Agreement into the CAISO’s Relevant System and will bear any resulting financial consequences, including without limitation, loss





(Continued)


of bill protection, incentive payments, and return of incentives.





(Continued)


D. ACCESS TO CUSTOMER DATA (CONT’D.) 1. Access to Customer Usage Data – Release of Information to non-Utility DRPs

(Cont’d) d. Durations by which the non-Utility DRP may continue to receive access to a

customer’s information shall be specified by the customer in the CISR-DRP. The customer may choose from the following options: (1) a specified time period indefinite data release, until otherwise canceled by the customer or DRP, (2) indefinitely until otherwise canceled by the customer or DRP release of data until a date certain, (3) authorization for non-Utility DRP to terminate data release upon DRP DR Service cancellation. If the customer makes no election, Utility will assume that customer authorization is for an indefinite period of time per CPUC Resolution E-4599.

If the authorization comes to PG&E via authorized electronic processes from a DRP website, that bypasses Form 79-1152, the customer will be offered time period options selected by the DRP. The customer may accept a DRP-offered option, or the customer may reject the DRP’s selection by not completing the electronic authorization process.

In the event that the customer, not the non-Utility DRP on the customer’s behalf, revokes access to customer meter data, PG&E shall provide the non-Utility DRP with immediate notice of the revocation.

Under all Options (3), it is the non-Utility DRP’s responsibility to notify PG&E to terminate the non-Utility DRP’s access to the customer’s data. Upon receipt of the notice of termination from the non-Utility DRP or the revocation of data access authorization from the customer, PG&E will cease to provide the customer on-going interval usage data to the non-Utility DRP. However, the non-Utility DRP may continue to receive previously generated data that pertains to the period of time during which customer authorization was valid. This information will assist the non-Utility DRP in settling invoices with the CAISO related to customer service accounts during the time that they were active in DR Services.

e. When PG&E is acting as the MDMA, if daily meter data is available through PG&E’s portals, the daily meter data will not be RQMD. RQMD data will be available on a monthly basis. When Open ADE is available to PG&E, the tariff for Open ADE will govern the provision of daily meter data.

2. Access to Direct Access or CCA Service Customer Data when PG&E is the DRP

but not the MDMA a. PG&E, in its role as a DRP, will contract with the customer’s MDMA in order

to receive the necessary meter data (as described in Section F) for the purposes of managing its own DRP DR Services program, and to assist in its forecasting, bidding, dispatch, and settlement activities.

3. Customer Inquiries Concerning Billing-Related Issues





(Continued)


a. Customer inquiries concerning PG&E’s charges or services should be

directed to PG&E.





(Continued)


D. ACCESS TO CUSTOMER DATA (CONT’D.) 3. Customer Inquiries Concerning Billing-Related Issues (Cont’d)

b. Customer inquiries concerning the non-Utility DRP’s charges

or services should be directed to the non-Utility DRP. c. Customer inquiries concerning the LSE’s charges or services should be

directed to the LSE.

4. Customer Inquiries Related to Emergency Situations and Outages

a. PG&E will be responsible for responding to all inquiries related to distribution service, emergency system conditions, outages, and safety situations. Customers contacting the DRP with such inquiries should be referred directly to PG&E.

b. It may be necessary for PG&E to shed or curtail customer load at the

request of the CAISO, or as otherwise provided by CPUC authorized tariffs. PG&E shall provide notice to the non-Utility DRP of such curtailments as soon as practical, however PG&E is not responsible to notify the non-Utility DRP’s Scheduling Coordinator. Nothing in this rule shall change the criteria for load-shedding established by the CAISO, the CPUC, or PG&E’s operation procedures.

c. PG&E shall continue to be responsible for implementing its own CPUC-

approved DR programs.

E. DRP DR SERVICE ESTABLISHMENT

DRPs enrolling bundled service customers must satisfy the following regulatory requirements, as they might apply, before the DRP can provide DRP DR Services in PG&E’s service territory.

1. CPUC Registration Requirements

a. Execute a Demand Response Provider Service Agreement (DRP Service

Agreement – Form No 79-1160) with PG&E. b. Satisfy PG&E’s credit requirements as specified in Section H. c. Register with the CPUC and maintain a valid DRP registration at the CPUC.





(Continued)


E. DRP DR SERVICE ESTABLISHMENT (CONT’D) 1. CPUC Registration Requirements (Cont’d)

d. Complete the CPUC DRP Registration Application Form. DRPs enrolling

PG&E’s residential and small commercial customers shall also provide the CPUC a performance bond under the name of the CPUC as a security deposit or financial guarantee bond in an amount pursuant to the matrix below and as specified in the CPUC Registration form.

2. CAISO Requirements

All DRPs enrolling PG&E Bundled Service customers must: a. Execute the necessary service agreements for registering

resources with the CAISO. b. Meet all the CAISO’s requirements for the DRP and maintain their

registration at the CAISO as a qualified DRP. 3. Maintenance of DRP Registration at the CPUC

a. The CPUC will post the list of registered DRPs on its website. The CPUC

will enforce all rules for the DRP registration and may suspend or revoke a DRP registration if the CPUC determines that the DRP violated Rule 24 or terms and conditions outlined in the CPUC DRP Registration Form. The CPUC may require that the DRP periodically renew its registration to maintain its status.

b. The CPUC will investigate complaints relative to DRP activities and may

suspend or revoke a DRP registration if a civil or business court, or the CPUC, finds that the DRP has engaged in activities that warrant such action, after appropriate due process considerations. The CPUC may also allow the DRP to cure any identified deficiencies or inappropriate activities within a reasonable period of time.

Number of Customers Security Deposit Amount

1 – 2,500 $25,000

2,501 - 5,000 $50,000

5,001 – 10,000 $75,000

10,001 + $100,000





(Continued)


E. DRP DR SERVICE ESTABLISHMENT (CONT’D) 3. Maintenance of DRP Registration at the CPUC (Cont’d)

c. DRPs shall keep the CPUC registration information up to date.

4. EDI Requirements

Until superseded by another data exchange process, such as Open ADE, and to the extent the DRP elects to use Electronic Data Interchange (EDI) or an analogous platform to communicate with PG&E for DRP DR Service implementation, the DRP must satisfy applicable technical requirements, including, without limitation:

a. A DRP must complete all necessary electronic interfaces for the DRP and PG&E to communicate meter reading and usage data.

b. The DRP must have the capability to exchange data with PG&E via the

Internet. Alternative arrangements to EDI may be allowed if mutual agreement is made between PG&E and the DRP.

c. The DRP must have the capability to perform EDI transactions, and enter

into appropriate agreements related thereto. F. METERING SERVICES

Metering Services are comprised of three primary functions: Meter Ownership, Meter Services (installation, maintenance, and testing), and MDMA services. Each participating DRP DR Service customer must have an interval meter capable of meeting CAISO DR Service requirements being read remotely by PG&E when acting in its capacity as MDMA. 1. Meter Changes

If a meter change is required to participate in DRP DR Services (i.e. the existing meter is not an appropriate interval meter), and PG&E is the MSP, the customer and DRP have choices for how to proceed: a. The customer may be scheduled to receive an interval meter as part of

PG&E smart meter deployment. In this instance, the customer and DRP can elect to begin DRP DR Services after PG&E completes its deployment of PG&E smart meters and is able to provide the required interval data.

b. If an interval meter with a shorter measurement duration is desired, and

such a meter and metering service related back-office capability are readily available from PG&E, PG&E will provide this meter at an additional CPUC-approved fee.





(Continued)


F. METERING SERVICES (CONT’D.) 1. Meter Changes (Cont’d.)

b. (Cont’d.)

(1) For Bundled Service and CCA Service accounts with a maximum

demand of 200 kW or greater for at least one month in the past 12 billing months, PG&E will provide and install the metering and communication equipment at no cost to the customer.

(2) For Bundled Service and CCA Service accounts whose maximum billed

demand has not exceeded the level specified in item 1 above, the customer can elect one of the following; i. Pay the cost to have PG&E install an appropriate interval meter that

is not a SmartMeter interval meter at the customer’s expense pursuant to Electric Rule 2, Special Facilities, or

ii. If the PG&E SmartMeter requirements meet CAISO DR Services

metering standards, wait until a PG&E SmartMeter is installed and remote-read enabled.

c. For Direct Access service accounts where PG&E is the Meter Data

Management Agent (MDMA), no incremental fees under this rule are required. Metering services shall be provided pursuant to Electric Rule 22.

d. For Direct Access service accounts where PG&E is the MSP but not the

MDMA, then the customer will be responsible for any and all costs associated with providing acceptable interval data to the DRP, including costs for any additional metering, communication equipment, and fees assessed by the customer’s Electric Service Provider (ESP).

e. PG&E is not required to install an interval meter and communication

equipment or SmartMeter to provide remote read capability if the installation is impractical or not economically feasible.

f. PG&E shall endeavor to complete the meter change request within fifteen

(15) days in the absence of a meter installation backlog or other circumstances beyond PG&E’s control such as, but not limited to, delays in the installation of a communication line to the meter. PG&E shall provide notice of any current meter service backlog and estimate its next available installation date. However, if the DRP or the customer is willing to pay a fee to expedite the installation of the meter, PG&E will endeavor to accommodate the request. The fee shall be consistent with fees adopted by the CPUC.





(Continued)


F. METERING SERVICES (CONT’D)

1. Meter Changes (Cont’d)

g. If requested by the customer or the DRP, PG&E as the MSP will make available a KYZ pulse connection to the customer’s meter so as to provide near real-time access to meter data to the DRP and the customer. The charge for the installation will be reasonable and consistent with CPUC-approved fees for similar services, and shall be paid for by either the customer or DRP. The installation shall not interfere with the normal operation of the meter. PG&E will endeavor to complete the installation of its pulse termination block (also known as the pulse interface box) within 15 days of payment by the non-Utility DRP or customer. Resource and access constraints, or certain emergency conditions, may preclude PG&E from meeting this timeframe. In these instances, PG&E shall provide the DRP notice of the next expected available installation date.

2. MDMA Services Performed by PG&E

PG&E shall perform all MDMA services required for DRP DR Service for Bundled Service customers and Community Choice Aggregation Service customers. Also, PG&E shall perform MDMA services for those Direct Access Service customers that have elected PG&E to be its MDMA. MDMA obligations include but are not limited to the following: a. Meters for each of the DRP’s customers shall be read and converted into

RQMD and transferred to the DRP or its designated agent pursuant to applicable standards.

b. PG&E shall provide the DRPs (or their designated agents) with reasonable

and timely access to meter data as required to allow the proper performance of billing, settlement, scheduling, forecasting and other functions;

c. The LSE and DRP shall have access to individual customer RQMD via an

electronic interface (e.g., MDMA server)





(Continued)


F. METERING SERVICES (CONT’D.) 2. MDMA Services Performed by PG&E (Cont’d.)

d. PG&E shall provide RQMD customer data to the DRP in accordance with

standards adopted in the DASMMD or other standards in compliance with the CAISO’s applicable requirement, for the DRP’s or its agent’s consolidation into SQMD for the CAISO. PG&E shall be liable for providing timely and accurate RQMD to the non-Utility DRP or its designated agent to facilitate final meter data submission in accordance with the CAISO’s tariff. If the MDMA is found, through the CPUC’s remedy and dispute resolution process, to have failed to comply fully with the applicable requirements for submission of timely and accurate RQMD so as to be the sole fault for the ability for the DRP or its agent to comply fully with the applicable CAISO requirements, the MDMA shall be held liable, limited to the penalties imposed by the CAISO upon the non-Utility DRP or its Scheduling Coordinator (SC) due to the non-compliance.

3. MSP Services performed by PG&E

When acting as an MSP, PG&E shall, on a non-discriminatory basis, ensure that the revenue meter equipment is accurate within acceptable limits as specified in PG&E’s applicable rules, and provide testing as necessary to maintain this standard. PG&E shall endeavor to fulfill requests for meters with interval durations specified by the DRP and/or its customers consistent with Section F.1.b above.

4. Telemetry

If a telemeter is required or communication facilities for sending telemeter information are required to participate in a DRP’s program, the telemetering services and communication must conform to the CAISO’s telemetry technical requirements. The DRP is solely responsible for providing a communication solution or telemetry solution subject to CAISO requirements at the expense of the DRP. To the extent that PG&E has the expertise and technical resources to install or assist with installation of the required telemetry solution or communication solution, PG&E may install or assist the DRP to facilitate the installation of the telemetry solution, at the DRP’s expense.

5. Charges for Metering Services

The metering services for supporting DRP DR Services may be more extensive than normal metering services. PG&E, as an MSP, may charge the DRP for metering services only to the extent such charges are authorized by the CPUC.





(Continued)


G. DISCONTINUATION OF SERVICE BY DRP 1. Service Changes at the Individual Customer Level

The DRP may elect to discontinue providing DRP DR Service to its customers, or the customer may elect to disenroll from the program pursuant to any agreement between the DRP and its customers. Should the customer terminate electric service with PG&E, the customer is responsible for terminating its arrangement with the DRP directly. For customers who change their LSE, the DRP is responsible for effectuating necessary changes in the CAISO’s Relevant Systems.

2. Service Changes at the CAISO Resource Registration Level

A customer enrolled as part of a Resource Registration at the CAISO may have its DRP DR Service discontinued by its DRP due to the following conditions: a. The CPUC terminates or revokes the DRP's registration or its ability to

participate in CAISO’s DR Services b. The CPUC issues an order that otherwise prohibits the DRP from entering

into a DRP Service Agreement (Form 79-1160); c. The DRP has materially breached its obligations under the terms and

conditions of the DRP Service Agreement; d. The DRP exercises its contractual right to terminate the DRP Service

Agreement; e. The DRP is no longer authorized by the CAISO to provide DR Services. f. The CPUC revokes the Utilities’ authority to participate in DR Service(s)

activities. 3. Discontinuation of DRP DR Service by the DRP

a. The DRP is responsible for notifying the LSE, PG&E, SC and MDMA, if

impacted, when it will discontinue DRP DR Service to the customer. b. If the DRP elects to discontinue offering DRP DR Services, the DRP shall

also notify the CAISO, CPUC, and the LSE of its decision to do so and specify the date(s) on which service will be discontinued. The DRP will effect a termination of its Resource Registration with the CAISO;

c. If the DRP is no longer able to provide DRP DR Service because its

authorization to do so has been terminated or revoked, the DRP shall notify the impacted parties (LSEs, PG&E, SC, MDMA), the CAISO and the CPUC unless they are already involved in the decision on such revocation or termination.





(Continued)


G. DISCONTINUATION OF SERVICE BY DRP (CONT’D.) 3. Discontinuation of DRP DR Service by the DRP (Cont’d.)

d. If the Non-Utility DRP has not revoked the CISR-DRP authorization for it to

receive the customer’s usage data as of the date the DRP DR Service is canceled, the Non-Utility DRP must notify DRP DR Service participants that they should contact PG&E to revoke the authorization for the non-Utility DRP to receive their usage data as of the date the DRP DR Service is canceled.

e. In the event a non-Utility DRP has been authorized to terminate deliveries of

a customer’s metering data streams upon the customer’s disenrollment in its DRP DR Service program, the non-Utility DRP is required to notify PG&E to stop transmission of data, consistent with the customer’s instructions to the DRP.

H. NON-UTILITY DRP CREDIT REQUIREMENTS REQUIRED BY PG&E

1. PG&E may require the non-Utility DRP enrolling Bundled Service customers to

establish and maintain its creditworthiness through evaluations, deposits, or other security in the manner described in Section H.2, to the extent the CPUC approves the ability for PG&E to levy charges for services rendered as a result of DR activities. That is, the creditworthiness only applies to charges that are billed by PG&E directly to the non-Utility DRP. The method of determining the amount of credit that a DRP would need to submit in order to initiate services within PG&E’s service territory shall be equal to two times the estimated or actual monthly CPUC-approved fees for DRP DR Service, as described herein and as verified by PG&E. The non-Utility DRP will be obliged to provide the CPUC with a separate performance bond as part of its registration process for Residential and Small Commercial customers.

2. The non-Utility DRP may establish its creditworthiness with PG&E through any

one of the following: a. Credit Evaluation

A non-Utility DRP with a demonstrable current credit rating of Baa2 or higher from Moody’s or BBB or higher from Standard and Poor’s, or Fitch is deemed to be creditworthy unless PG&E determines that a material change in the non-Utility DRP’s creditworthiness has occurred. PG&E requires the non-Utility DRP to complete a credit application including financial information reasonably necessary to establish credit. The creditworthiness evaluation may be conducted by an outside credit analysis agency, determined by PG&E, with final credit approval granted by PG&E. This evaluation will be completed within ten (10) business days. Credit reports will remain strictly confidential between the credit analysis agency and PG&E, except to the extent PG&E is required to disclose to the CPUC or its agents. A credit application processing fee, as approved by the CPUC, may be charged to offset the cost of determining the non-Utility DRP’s





(Continued)


creditworthiness.





(Continued)


H. NON-UTILITY DRP CREDIT REQUIREMENTS REQUIRED BY PG&E (CONT’D.) 2. The non-Utility DRP may establish its creditworthiness with PG&E through any

one of the following (Cont’d.): b. Security Deposits

The non-Utility DRP may submit and maintain a security deposit in lieu of submitting to or being qualified under a creditworthiness evaluation. The amount of the security deposit required to establish credit will be twice the estimated maximum monthly bill that PG&E may expect to remit to the non-Utility DRP for participating in one month of Demand Response Activities, where such estimate is based on the last twelve (12) months of historical activity. The initial value of the security deposit will be two times the monthly fees assessed by PG&E upon the DRP. Security deposits may be in the form of (1) cash deposits, with interest earned at the 3-month Non-Financial commercial paper rate, (2) letters of credit, defined as irrevocable and renewable issued by a major financial institution rated A/A2 by S&P/Moody’s, respectively , (3) surety bonds, defined as renewable and issued by a major insurance company rated A/A2/A by S&P/Moody’s/A.M. Best, respectively, or (4) guarantees, with guarantors having a credit rating of Baa2 or higher from Moody’s or BBB or higher from Standard and Poor’s or Fitch unless PG&E determines that a material change in the guarantor’s creditworthiness has occurred, or, in other cases, through the credit evaluation process described above. Security deposits must be posted with PG&E prior to the DRP’s participation in DRP DR Service.

c. Security Deposit Payment Timetable

Non-Utility DRPs are obligated to post security deposits with PG&E prior to receiving certain services from PG&E which help facilitate their DR activities. PG&E shall provide notice to the non-Utility DRP of the appropriate deposit amount upon receiving a service request from the non-Utility DRP. Such a deposit shall be required at least three (3) days prior to PG&E providing its services to the non-Utility DRP for DR activities.

d. Interest on Cash Deposit

PG&E will pay interest on cash deposits as described in its Electric Rule 7.





(Continued)


H. NON-UTILITY DRP CREDIT REQUIREMENTS REQUIRED BY PG&E (CONT’D.) 2. The non-Utility DRP may establish its creditworthiness with PG&E through any

one of the following (Cont’d.): e. Ongoing Maintenance of Credit

To ensure continued validity of established unsecured credit, the non-Utility DRP shall promptly notify PG&E of any material change in its credit rating or financial condition. The non-Utility DRP shall also furnish evidence of an acceptable credit rating or financial condition, as set forth above, to PG&E upon request. In the event PG&E determines that the non-Utility DRP’s, or the non-Utility DRP’s guarantor’s, creditworthiness has materially changed, as set forth above, and the non-Utility DRP, within 30 days written notice, does not rectify or provide a security deposit commensurate with the change in creditworthiness, then PG&E shall notify the CAISO that the non-Utility DRP has defaulted on its credit requirements and is no longer eligible to participate as a DRP under PG&E’s tariffs.

f. Re-establishment of Credit

A non-Utility DRP whose eligibility as a DRP has been terminated, revoked or suspended under this section may reestablish its creditworthiness by the provision of a security deposit, or by any other manner described in this Section H.

I. COMPLIANT AND DISPUTE RESOLUTION PROCESSES

1. Disputes Involving Entities Subject to this Rule

Disputes arising under this Rule or Schedule E-DRP shall be resolved in accordance with the CPUC’s complaint procedures, Article 4 of the Commission’s Rules of Practice and Procedure. Parties may choose to seek resolution through the Alternate Dispute Resolution Processes available through the Commission. The Commission shall resolve complaints regarding customer agreement eligibility, whether brought by the DRP, PG&E or the customer, expeditiously. However, entities seeking damages related to this Rule must do so in court.

(T)





(Continued)


I. COMPLIANT AND DISPUTE RESOLUTION PROCESSES (CONT’D.) 2. Suspension or Revocation of Non-Utility DRP’s Registration at the CPUC

Pursuant to the Commission’s authority provided by California Public Utilities Code Sections 451, and 701 through 702, the CPUC’s enforcement authority includes; but is not limited to, suspension or revocation of non-Utility DRP registration and imposition of penalties and/or fines after appropriate due process. The CPUC’s Consumer Affairs Branch (CAB) shall process and report to the Commission all informal consumer complaints against non-Utility DRPs on a quarterly basis. If CAB staff determines, after consultation with Energy Division staff and facilitating mediation between a retail customer complainant and a non-Utility DRP, that a resolution cannot be reached, the complaint may be escalated to the CPUC’s Safety and Enforcement Division (SED). SED may consider taking appropriate enforcement action, including proposing for Commission consideration the suspension and/or revocation of the non-Utility DRP’s registration, and fines and/or penalties against the non-Utility DRP. SED will notify the non-Utility DRP, the CAISO, the relevant LSEs, and the UDC of such pending adverse action. The non-Utility DRP that is the subject of the SED action may respond to such action consistent with the procedures provided in the Commission’s Rules of Practice and Procedure. This process does not exclude alternative means of investigation of complaints regarding non-Utility DRPs as provided by the CPUC’s Rules of Practice and Procedure. Information regarding formal and informal complaint processes is available through the CPUC’s Public Advisor’s Office or at www.cpuc.ca.gov. Grounds for potential suspension or revocation of non-Utility DRP’s registration and/or penalties or fines are based on the statutes cited in this section and the Commission Decisions (D.)12-11-025 and 13-12-029. Examples of conduct that may violate these authorities include, but are not limited to: a. Forgery of Rule 24 forms and other required documents; b. Use of deceptive or unclear advertisements or terms and conditions in

contracts; c. Improper registration for servicing residential and small commercial

customers (see DRP Registration Application Form); d. Failure in notifying customers when servicing residential and small

commercial customers (see Section C.7); e. Failure in notifying PG&E and other impacted entities of a customer

discontinuation of DR Services (see Section G.3); f. Violation of dual participation rules (see Section C.2.d) g. Non-payment of PG&E fees or credit/performance bond lapse. (see

Sections E.1 and H).


Revised Cal. P.U.C. Sheet No. 35840-E Cancelling Original Cal. P.U.C. Sheet No. 33721-E



(Continued)


I. COMPLIANT AND DISPUTE RESOLUTION PROCESSES (CONT’D.) 2. Suspension or Revocation of Non-Utility DRP’s Registration at the CPUC (Cont’d.)

h. Unauthorized data transfer of customer specific data to others (see Section

D.1.d); i. Invalid DRP Service Agreement (Form 79-1160) with PG&E and the CAISO

(see Section E); j. Failure to fulfill the mutually agreed-upon terms and conditions, e.g., non-

payment to the enrolled customers for services rendered (See Customer Notification Form Letter).

k. Provision of faulty or misleading equipment/data to the customer by the DRP

to the detriment of the customer. 3. Appeal of a non-Utility DRP Suspension or Revocation at the CPUC

A non-Utility DRP may appeal in writing to the CAB regarding notification of suspension, revocation, or immediate revocation. To appeal the notification, the disqualified entity must first contact the CAB within thirty (30) days to discuss the issue. If the revoked entity has new information to provide the CAB, then it must be provided to CAB within thirty (30) days. If the revoked entity and the CAB cannot resolve the dispute, then the revoked entity can file a complaint using the CPUC’s Formal Complaint process. Information on the formal Complaint process is available through the Public Advisor's Office at the CPUC or on CPUC’s website: www.cpuc.ca.gov.

J. ACRONYMS

The following acronyms are used within this Rule 24:

(BPM) - Business Practice Manual (CAB) - CPUC’s Consumer Affairs Branch (CAISO) - California Independent System Operator (CCA) - Community Choice Aggregation (CISR-DRP) - Customer Information Service Request for Demand Response Providers (CPUC) - California Public Utilities Commission (DA) - Direct Access





(Continued)


J. ACRONYMS (CONT’D.) (DASMMD) - Direct Access Standards for Metering and Meter Data (DLAP) - Default Load Aggregation Point (DR) - Demand Response (DRP) - Demand Response Provider (DRS) - Demand Response System (EDI) - Electronic Data Interchange (ESP) - Electric Service Provider (FERC) - Federal Energy Regulatory Commission (LSE) - Load Serving Entity (MDMA) - Meter Data Management Agent (MSP) - Meter Service Provider (Open ADE) - Open Automated Data Exchange (RQMD) - Revenue Quality Meter Data (SA) - Service Agreement (SC) - Scheduling Coordinator (S-LAP) - Sub Load Aggregation Point (SQMD) - Settlement Quality Meter Data (UDC) - Utility Distribution Company (VEE) - Validated, Edited, and Estimated

PG&E Gas and Electric Advice Filing List General Order 96-B, Section IV

AT&T Division of Ratepayer Advocates Office of Ratepayer Advocates Albion Power Company Don Pickett & Associates, Inc. OnGrid Solar Alcantar & Kahl LLP Douglass & Liddell Pacific Gas and Electric Company Anderson & Poole Downey & Brand Praxair Atlas ReFuel Ellison Schneider & Harris LLP Regulatory & Cogeneration Service, Inc. BART Evaluation + Strategy for Social

Innovation SCD Energy Solutions

Barkovich & Yap, Inc. G. A. Krause & Assoc. SCE Bartle Wells Associates GenOn Energy Inc. SDG&E and SoCalGas Braun Blaising McLaughlin & Smith, P.C. GenOn Energy, Inc. SPURR Braun Blaising McLaughlin, P.C. Goodin, MacBride, Squeri, Schlotz &

Ritchie San Francisco Water Power and Sewer

CENERGY POWER Green Charge Networks Seattle City Light CPUC Green Power Institute Sempra Energy (Socal Gas) California Cotton Ginners & Growers Assn Hanna & Morton Sempra Utilities California Energy Commission ICF SoCalGas California Public Utilities Commission International Power Technology Southern California Edison Company California State Association of Counties Intestate Gas Services, Inc. Southern California Gas Company

(SoCalGas) Calpine Kelly Group Spark Energy Casner, Steve Ken Bohn Consulting Sun Light & Power Center for Biological Diversity Leviton Manufacturing Co., Inc. Sunshine Design City of Palo Alto Linde Tecogen, Inc. City of San Jose Los Angeles County Integrated Waste

Management Task Force TerraVerde Renewable Partners

Clean Power Los Angeles Dept of Water & Power TerraVerde Renewable Partners, LLC Clean Power Research MRW & Associates Tiger Natural Gas, Inc. Coast Economic Consulting Manatt Phelps Phillips TransCanada Commercial Energy Marin Energy Authority Troutman Sanders LLP Cool Earth Solar, Inc. McKenna Long & Aldridge LLP Utility Cost Management County of Tehama - Department of Public Works

McKenzie & Associates Utility Power Solutions

Crossborder Energy Modesto Irrigation District Utility Specialists Crown Road Energy, LLC Morgan Stanley Verizon Davis Wright Tremaine LLP NLine Energy, Inc. Water and Energy Consulting Day Carter Murphy NRG Solar Wellhead Electric Company Defense Energy Support Center Nexant, Inc. Western Manufactured Housing

Communities Association (WMA) Dept of General Services ORA YEP Energy

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