PG&E spends $275 million a year on energy efficiency investments that reduce demand by 100 MW. It also spends $65 million a year on demand response to reduce peak loads by 400 MW.  If we assume that energy efficiency investments are effective an average of 12 years the incremental cost of those investments is $66 per MWH (6.6 cents per kWh). For demand response the incremental cost, which should match the market value, is $163 per kilowatt-year (or $13.60 per kW-month). Both of these values are reasonable investments for long-term resources.

Yet, PG&E argues in the PCIA exit fee proceeding and its annual ERRA generation cost proceeding that the appropriate market valuation for its resources are the short-term fire sale values that it realizes in the daily markets. According to PG&E, customers do not realize any additional value from holding these resources beyond what those resources can be bought and sold for the CAISO markets and in bilateral short-term deals.

So we are left with the obvious question: Why is PG&E continuing to invest in energy efficiency and demand response if the utility states that it can meet all of its needs in the short-term markets? This hypocrisy is probably best explained by PG&E manipulating the regulatory process. PG&E’s proposed “market valuation” sets the exit fee for community choice aggregation (CCA) at a high level. Instead, that market valuation should reflect how much CCAs have saved bundled customers in avoided procurement, and what PG&E pays for adding new resources.