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The letter expresses general support for load management and dynamic rates, based on VCE’s experience as a Load Serving Entity implementing a UNIDE (CalFUSE) hourly dynamic rate pilot and prior demand response work. It requests adequate customer and automation support, sector-first focus, phased piloting, tailored implementation for different LSE types, and clarification on how savings outweigh implementation costs.",{"@graph":69,"@context":123},[70,84,106],{"@type":71,"itemListElement":72},"BreadcrumbList",[73,77,79,82],{"item":74,"name":75,"@type":76,"position":8},"https://docshare.wps.com","Home","ListItem",{"item":78,"name":9,"@type":76,"position":14},"https://docshare.wps.com/document/",{"item":80,"name":40,"@type":76,"position":81},"https://docshare.wps.com/document/research-report/",3,{"item":83,"name":65,"@type":76,"position":19},"https://docshare.wps.com/document/valley-clean-energy-comments-on-2022-load-management-rulemaking-docket-21-oir-03/315807/",{"url":83,"name":65,"@type":85,"image":86,"author":91,"headline":65,"publisher":94,"fileFormat":97,"inLanguage":63,"description":67,"dateModified":98,"datePublished":99,"encodingFormat":97,"isAccessibleForFree":100,"interactionStatistic":101},"DigitalDocument",{"url":87,"@type":88,"width":89,"height":90},"https://docshare.wps.com/thumbnails/valley-clean-energy-comments-on-2022-load-management-rulemaking-docket-21-oir-03/315807.png","ImageObject",300,407,{"name":92,"@type":93},"Đào","Person",{"url":74,"name":95,"@type":96},"DocShare","Organization","application/pdf","2026-11-06","2026-09-20",true,{"@type":102,"interactionType":103,"userInteractionCount":105},"InteractionCounter",{"@type":104},"ViewAction",11,{"@type":107,"mainEntity":108},"FAQPage",[109,115,119],{"name":110,"@type":111,"acceptedAnswer":112},"What is the document’s main purpose and who submits it?","Question",{"text":113,"@type":114},"The document submits Valley Clean Energy’s formal comments to the California Energy Commission on the 2022 Load Management Rulemaking under Docket 21-OIR-03.","Answer",{"name":116,"@type":111,"acceptedAnswer":117},"What aspects does VCE ask the CEC to consider when finalizing the draft Rule?",{"text":118,"@type":114},"VCE asks for adequate customer and automation support, a focus on key sectors first, pilot and phased implementation, an expanded scaling strategy, and tailoring the approach to the type of LSE.",{"name":120,"@type":111,"acceptedAnswer":121},"Why does VCE raise concerns about the draft Rule’s approach to dynamic rates?",{"text":122,"@type":114},"VCE supports dynamic rates in principle but is concerned that the draft Rule’s top-down regulatory approach may limit innovation, misdirect resources into paperwork, and be counter-productive for an effective demand-shift tool.","https://schema.org",{"og:url":83,"og:type":125,"og:title":65,"og:site_name":95,"og:description":67},"article",{"robots":127,"canonical":83},"index,follow",{"doc_id":129,"site_id":62},315807,1790562883,{"code":4,"msg":5,"data":132},{"doc_id":129,"user_id":133,"nickname":92,"user_avatar":134,"doc_module":4,"category_id":39,"category_name":40,"doc_title":65,"doc_description":67,"doc_content":135,"file_id":136,"file_url":137,"file_type":138,"file_size":139,"view_count":105,"is_deleted":4,"is_public":8,"is_downloadable":8,"audit_status":8,"page_count":19,"language":140,"language_code":63,"site_id":62,"html_lang":63,"table_of_contents":141,"faqs":142,"seo_title":143,"seo_description":67,"update_tm":144,"read_time":52,"preview_page_count":4},1374402968488,"https://ap-avatar.wpscdn.com/davatar_29158cc5080c5b710cf443261637dec0","| DOCKETED |  |\n| --- | --- |\n| Docket Number: | 21-OIR-03 |\n| Project Title: | 2022 Load Management Rulemaking |\n| TN \\#: | 246226 |\n| Document Title: | Valley Clean Energy Comments on 2022 Load Management Rulemaking |\n| Description: | N/A |\n| Filer: | System |\n| Organization: | Valley Clean Energy |\n| Submitter Role: | Public Agency |\n| Submission Date: | 9/27/2022 6:20:43 PM |\n| Docketed Date: | 9/27/2022 |\n\nComment Received From: Valley Clean Energy  \nSubmitted On: 9/27/2022  \nDocket Number: 21-OIR-03  \nVCE Comments on 2022 Load Management Rulemaking; 21-OIR-03  \nAdditional submitted attachment is included below.  \nBoard of Directors  \nDan Carson  \nDavis City Council  \nWade Cowan  \nWinters City Council  \nLucas Frerichs  \nDavis City Council  \nJesse Loren Chair  \nWinters City Council  \nGary Sandy  \nYolo County Board of Supervisors  \nDon Saylor  \nYolo County Board of Supervisors  \nTom Stallard Vice Chair  \nWoodland City Council  \nMayra Vega  \nWoodland City Council  \nSeptember 27, 2022  \nCommissioner Andrew McCallister California Energy Commission  \nSubmitted Electronically  \nRe: VCE Comments on 2022 Load Management Rulemaking; 21-OIR-03  \nDear Commissioner McCallister,  \nI am writing on behalf of Valley Clean Energy (VCE), a community choice aggregation (CCA) program serving Yolo County. In late July VCE submitted comments on the then current draft Load Management Rule, sharing our thoughts from the perspective of the State’s only Load Serving Entity (LSE) implementing a UNIDE (CalFUSE) based hourly dynamic rate pilot (the SCE pilot is underdevelopment) . In that communication we expressed our general support for the load management concept. However, based on VCE’s implementation experience as an LSE, we also suggested the CEC consider a number of key issues related to the design and rollout of the proposed Rule.  \nIn our July 21, 2022 comments, VCE suggested the CEC staff consider the following general topics as they finalized the draft Rule for consideration by the Commission:  \n• Provide adequate customer and automation support  \n• Focus on key sectors first  \n• Pilot and Phase Implementation  \n• Expand the scaling strategy to include how to build out the expertise/resources necessary for a successful widespread rollout  \n• Tailor implementation approach to the type of LSE  \nVCE observes that staff’s summary of proposed modifications beginning on page 5 of the September 12, 2022 Notice of Third 15-Day Public Comment Period Proposed Revisions to the Load Management Standards do separate POU’s and CCA’s into a separate section and provide some additional flexibility, but the draft Rules do not appear to address identified key barriers to successful implementation. VCE continues to be concerned that the draft Rule’s top-down regulatory approach will curb innovation, needlessly redirect energy and resources to a “paper chase”, and will ultimately be counter-productive for a demand shift tool that we all need to be high performing.  \nTo be clear, VCE is championing dynamic rates – what we have concern with is the approach to its implementation contained in the draft Rule. As we submit this comment letter, as we suspect many others are also doing, VCE is simultaneously submitting comments into the CPUC’s Order Instituting Rulemaking to Advance Demand Flexibility Through Electric Rates (Rulemaking 22-07-005) . In our comments to that proceeding, consistent with our comments shared here, we argue for an expedited, expanded but targeted approach to deployment of dynamic rates:  \n“Based on VCE’s experience to date developing and implementing a 5 MW dynamic rate pilot to incentivize agricultural customers to shift irrigation pumping load as approved in D.21-12-015 (the “AgFIT Pilot”) and the Lawrence Berkeley National Laboratory’s California Demand Response Potential Study Phase 3 Final  \n604 Second Street, Davis, CA 95616  \n(530) 446-2750  \n[ValleyCleanEnergy.org](ValleyCleanEnergy.org)  \nReport1 which sparked the pilot, there is im","cbCaieE0tFAmuJLA","https://ap.wps.com/l/cbCaieE0tFAmuJLA","pdf",743523,"English","# Re: VCE Comments on 2022 Load Management Rulemaking; 21-OIR-03\n## Background and general support\n## Key topics for the CEC staff\n## Concerns about the draft Rule’s implementation approach\n## Recommendations on dynamic rate deployment\n## Questions about costs and savings language","[{\"question\":\"What is the document’s main purpose and who submits it?\",\"answer\":\"The document submits Valley Clean Energy’s formal comments to the California Energy Commission on the 2022 Load Management Rulemaking under Docket 21-OIR-03.\"},{\"question\":\"What aspects does VCE ask the CEC to consider when finalizing the draft Rule?\",\"answer\":\"VCE asks for adequate customer and automation support, a focus on key sectors first, pilot and phased implementation, an expanded scaling strategy, and tailoring the approach to the type of LSE.\"},{\"question\":\"Why does VCE raise concerns about the draft Rule’s approach to dynamic rates?\",\"answer\":\"VCE supports dynamic rates in principle but is concerned that the draft Rule’s top-down regulatory approach may limit innovation, misdirect resources into paperwork, and be counter-productive for an effective demand-shift tool.\"}]","Valley Clean Energy Comments on 2022 Load Management Rulemaking - Docket 21-OIR-03 | PDF",1789906650]