CLECA Proposal on Matinee Pricing Barbara R. Barkovich, Barkovich & Yap., Inc. For California Large Energy Consumers Association Matinee Pricing Workshop February 24, 2016

Structure of Rate Design for Proposed Pilot Propose optional overlay to existing tariffs rather than separate tariff Assures recovery of any applicable T&D costs or non-bypassable charges Dynamic prices should only be for generation component of rates, not T&D Periods of low prices should be periods of low cost, i.e. low market prices Propose form of rate design as “inverse” dynamic pricing Matinee prices can be triggered when there are low or negative price “events” Recommend dynamic event-based prices rather than static TOU periods because there is evidence that these low or negative prices do not occur on every day of high renewable output months (see charts that follow) Consideration needs to be given to adjusting energy rates or demand charges for revenue shortfalls from matinee periods

Variation in spring prices even within a month The following two slides show the variation in forecast spring prices in April and May 2020 based on PG&E data from its 2015 rate design window proceeding. While April has quite a number of hours of lower day ahead prices in the 10-4 time period, the prices in May vary widely during those same hours. Although we know that weekend prices are softer than weekday prices, it is impossible to predict which days would have the lower prices. This variation supports our proposal that matinee pricing be dynamic.

Response to proposals of others CLECA can support use of RTP tariff as proposed by SCE with caveats Some CLECA members are on RTP rates Agree RTP rates should be refined in SCE 2016 RDW Do not support SCE position to exclude customers participating in demand response programs from the pilots Customers already on RTP do participate in DR programs. Why discriminate? Do not agree support PG&E position to exclude DR customers At least for BIP program, DR incentives only affect generation demand charges, not energy Agree that matinee pricing pilots cannot be implemented in 2016 and that need would not be until spring of 2017 Disagree with TURN on opt-out pilots These pilots are to be beneficial to customers selecting them and voluntary to take advantage of low-priced power when grid conditions permit Customers should not be defaulted onto them