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On March 11^th OPA filed updated comments on updated straw proposal.

Changes to the proposed recommendations include:

(1) for both the critical peak pricing (CPP) and peak time rebates (PTR) designs: (i) allowing for delays if costly billing system upgrades are necessary; (ii) allowing customers to opt-out at any time but not to re-enroll for 12 months; (iii) that utilities “pay the standard offer provider their bid price and any revenue generated above (or below)… [that price] would be part of an annual reconciliation filing”; and (iv) amending the recommendation to set prices “through an administrative process rather than through solicitation of time-differentiated bids from suppliers” to clarify that “Synapse does not object to obtaining separate bids for time-varying-rates (or time-differentiated bids) for the purpose of gathering additional information”;

(2) for the CPP design, targeting “customers who are likely to be best able to shift load (e.g. EV customers)”;

(3) for the PTR design, noting that net energy billing (NEB) customers “may be ineligible if the presence of customer-sited distributed generation prevents the establishment of a reasonable baseline… or if the customer would be double-compensated for solar generation and load reduction during peak events”; and

(4) for EV-only incentives: (i) “Vendor responses to requests for pricing should be used to determine… [which] chargers could represent viable options”; (ii) that if utilities provide a second meter free of charge, “if converted to another type of account, the meter charges consistent with the other rate would apply to the second meter to prevent gaming”; and (iii) that utilities “pay the standard offer provider their bid price and any revenue generated above (or below)… [that price] would be part of an annual reconciliation filing.”