[{"data":1,"prerenderedAt":-1},["ShallowReactive",2],{"detail-sidebar-cat-0-en-105":3,"doc-seo-315782-105":59,"doc-detail-315782-en":130},{"code":4,"msg":5,"data":6},0,"success",[7,13,18,23,28,33,38,43,48,51,55],{"id":8,"doc_module":4,"doc_module_name":9,"category_name":10,"show_sort_weight":11,"slug":12},1,"Document","Story & Novel",90,"story-novel",{"id":14,"doc_module":4,"doc_module_name":9,"category_name":15,"show_sort_weight":16,"slug":17},2,"Literature",80,"literature",{"id":19,"doc_module":4,"doc_module_name":9,"category_name":20,"show_sort_weight":21,"slug":22},4,"Exam",70,"exam",{"id":24,"doc_module":4,"doc_module_name":9,"category_name":25,"show_sort_weight":26,"slug":27},5,"Comic",60,"comic",{"id":29,"doc_module":4,"doc_module_name":9,"category_name":30,"show_sort_weight":31,"slug":32},6,"Technology",50,"technology",{"id":34,"doc_module":4,"doc_module_name":9,"category_name":35,"show_sort_weight":36,"slug":37},7,"Healthcare",40,"healthcare",{"id":39,"doc_module":4,"doc_module_name":9,"category_name":40,"show_sort_weight":41,"slug":42},8,"Research & Report",30,"research-report",{"id":44,"doc_module":4,"doc_module_name":9,"category_name":45,"show_sort_weight":46,"slug":47},9,"Religion & Spirituality",20,"religion-spirituality",{"id":46,"doc_module":4,"doc_module_name":9,"category_name":49,"show_sort_weight":46,"slug":50},"World Cup","world-cup",{"id":52,"doc_module":4,"doc_module_name":9,"category_name":53,"show_sort_weight":52,"slug":54},10,"Lifestyle","lifestyle",{"id":56,"doc_module":4,"doc_module_name":9,"category_name":57,"show_sort_weight":24,"slug":58},19,"General","general",{"code":4,"msg":60,"data":61},"ok",{"site_id":62,"language":63,"slug":64,"title":65,"keywords":66,"description":67,"schema_data":68,"social_meta":123,"head_meta":125,"extra_data":127,"updated_unix":129},105,"en","vce-comments-vce-comments-on-2022-load-management-rulemaking-21-oir-03","VCE Comments - VCE Comments on 2022 Load Management Rulemaking - 21-OIR-03","","VCE submits public comments to the California Energy Commission regarding its 2022 Load Management Rulemaking docket 21-OIR-03, sharing experience from designing and launching the UNIDE (CalFUSE) based hourly dynamic rate pilot. The comments assess the AgFit pilot’s goal of sending clear price signals to agricultural customers to reduce summer peak irrigation pumping. Key observations emphasize dynamic rates must be matched with customer support and automation, focus should be on early high-opportunity sectors, adequate time and expertise are required for scaling, and participation pathways should be tailored to specific LSE profiles.",{"@graph":69,"@context":122},[70,84,105],{"@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/vce-comments-vce-comments-on-2022-load-management-rulemaking-21-oir-03/315782/",{"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/vce-comments-vce-comments-on-2022-load-management-rulemaking-21-oir-03/315782.png","ImageObject",300,407,{"name":92,"@type":93},"\tJames","Person",{"url":74,"name":95,"@type":96},"DocShare","Organization","application/pdf","2026-10-28","2026-09-20",true,{"@type":102,"interactionType":103,"userInteractionCount":39},"InteractionCounter",{"@type":104},"ViewAction",{"@type":106,"mainEntity":107},"FAQPage",[108,114,118],{"name":109,"@type":110,"acceptedAnswer":111},"What pilot experience does VCE reference in these comments?","Question",{"text":112,"@type":113},"VCE describes its experience implementing the UNIDE (CalFUSE) based hourly dynamic rate pilot, including the AgFit pilot designed for agricultural customers.","Answer",{"name":115,"@type":110,"acceptedAnswer":116},"Why does VCE say rates alone are not sufficient?",{"text":117,"@type":113},"VCE argues meaningful participation requires adequate customer support and automation; without meeting customers “where they are at,” participation would be limited or nonexistent.",{"name":119,"@type":110,"acceptedAnswer":120},"What approach does VCE recommend for prioritizing load-shift opportunities?",{"text":121,"@type":113},"VCE recommends focusing on sectors with early opportunity rather than broad-based implementation, and notes transportation and building electrification should be included as priority areas.","https://schema.org",{"og:url":83,"og:type":124,"og:title":65,"og:site_name":95,"og:description":67},"article",{"robots":126,"canonical":83},"index,follow",{"doc_id":128,"site_id":62},315782,1790563047,{"code":4,"msg":5,"data":131},{"doc_id":128,"user_id":132,"nickname":92,"user_avatar":133,"doc_module":4,"category_id":39,"category_name":40,"doc_title":65,"doc_description":67,"doc_content":134,"file_id":135,"file_url":136,"file_type":137,"file_size":138,"view_count":39,"is_deleted":4,"is_public":8,"is_downloadable":8,"audit_status":8,"page_count":19,"language":139,"language_code":63,"site_id":62,"html_lang":63,"table_of_contents":140,"faqs":141,"seo_title":142,"seo_description":67,"update_tm":143,"read_time":52,"preview_page_count":4},2336474466412,"https://ap-avatar.wpscdn.com/davatar_155a257f0dc6eb9ab79c44ca47cae57d","| DOCKETED |  |\n| --- | --- |\n| Docket Number: | 21-OIR-03 |\n| Project Title: | 2022 Load Management Rulemaking |\n| TN \\#: | 244173 |\n| Document Title: | VCE Comments |\n| Description: | N/A |\n| Filer: | System |\n| Organization: | Valley Clean Energy (VCE) |\n| Submitter Role: | Public |\n| Submission Date: | 7/21/2022 4:54:52 PM |\n| Docketed Date: | 7/21/2022 |\n\nComment Received From: Mitch Sears  \nSubmitted On: 7/21/2022  \nDocket Number: 21-OIR-03  \nVCE Comments  \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  \nJuly 21, 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, to share our experience in implementing a UNIDE (CalFUSE) based hourly dynamic rate pilot approved in late 2021 as part of the CPUC’s summer reliability proceeding (R.20- 11-003) . The AgFit pilot is designed to send understandable and actionable price signals to agricultural customers to incentivize the shift of flexible irrigation pumping away from daily load peaks – particularly in summer. VCE has become a strong advocate for the exploration of dynamic price signals as an important tool to “shave the peaks and fill the valleys” of the demand curve and supports the Commissions overall objectives of the Load Management Rulemaking.  \nWe hope the following high-level observations, based on our efforts to design and launch the AgFit pilot, are helpful as the Commission considers the Load Management proposal. As the AgFit pilot matures over the next three years our learnings will increase and be documented and shared in a  \nmore formal manner with regulatory agencies and other interested parties.  \n• Rates are just one of several critical components. It is early in our process but based on the pilot design concept and earlier CEC EPIC funded research by our pilot partner Polaris, VCE observes that rates must be matched with adequate customer support and automation to gain meaningful participation. Our customer recruitment field work to date has provided early validation of this observation. Well designed and targeted rates alone are not likely to achieve the reliability and climate goals that the Rulemaking is designed to address. Without a strategy to meet the customer (or their devices)“where they are at” the participation in our pilot would have been limited or non-existent. We encourage the Commission to give careful thought to this design issue and incorporate the support, resources, and flexibility LSE’s will need for successful design and implementation.  \n• More important to focus on where there is early opportunity. The LBNL study referenced below identifies where the most load shift potential exists in California1 – which was a key driver for VCE’s decision to focus on agricultural pumping in its pilot proposal. The draft Rulemaking framework does not appear to make a distinction based on opportunity-based loading order. Based on VCE’s experience with the effort/resources needed to develop a single rate, this broad-based implementation strategy introduces unnecessary risk to the ultimate success of the Load Management framework. VCE recognizes that transportation and building electrification also represent large opportunities for load shift and should be included in the consideration of early priorities. Based on our early experience, VCE believes that a more targeted approach that builds practical knowledge would help mitigate risks associated","cbCaismcj9DcaGTZ","https://ap.wps.com/l/cbCaismcj9DcaGTZ","pdf",712846,"English","# Overview of VCE comments\n## Purpose and pilot context (AgFit / UNIDE-CalFUSE)\n## Key observations for the rulemaking\n## Pilot maturation and future documentation","[{\"question\":\"What pilot experience does VCE reference in these comments?\",\"answer\":\"VCE describes its experience implementing the UNIDE (CalFUSE) based hourly dynamic rate pilot, including the AgFit pilot designed for agricultural customers.\"},{\"question\":\"Why does VCE say rates alone are not sufficient?\",\"answer\":\"VCE argues meaningful participation requires adequate customer support and automation; without meeting customers “where they are at,” participation would be limited or nonexistent.\"},{\"question\":\"What approach does VCE recommend for prioritizing load-shift opportunities?\",\"answer\":\"VCE recommends focusing on sectors with early opportunity rather than broad-based implementation, and notes transportation and building electrification should be included as priority areas.\"}]","VCE Comments - VCE Comments on 2022 Load Management Rulemaking - 21-OIR-03 | PDF",1789906430]