Load Impact Protocols

Load Impact Protocols

The Load Impact Protocols (LIPs) are used to estimate ex-ante Qualifying Capacity (QC) and establish RA-eligible QC for DR resources. The LIPs were adopted by D.08-04-050, which prescribes a set of guidelines for estimating the load impact (or load change) resulting from DR activities. These guidelines established a consistent method for measuring program performance across DR resources on ex-post basis and for forecasting anticipated performance (or available capacity) on ex-ante basis. Additionally, the resulting capacity estimates are used to analyze the cost-effectiveness of DR programs managed by the IOUs and for other CPUC activities such as the RA framework and long-term integrated resource planning. 

Important Resources

The Load Impact Protocol Filing Guide is the master document Energy Division releases about annually to provide guidance on the LIP process and filing requirements. The most recent iteration is version 4.0 released 2/1/2024. Version 5.0 will be released in December 2024.

Relevant templates for LIPs:

Historical LIP reports are archived at California Measurement Advisory Council: CALMAC.

The Demand Response Measurement and Evaluation Committee (DRMEC)—with members from CPUC, California Energy Commission, and the three IOUs—is responsible for running the annual LIP workshops. Slides can be found here.

Legislative History of LIPs

  • D.10-04-006 Ordering Paragraphs (OP) 1-2: established Investor-Owned Utility (IOU) Executive Summary Requirement in Appendix 1 

  • D.10-06-036 OP 10: established 5-hr window “measurement hours” from LIP ex ante to determine monthly Qualifying Capacity (QC) of Demand Response (DR) resource according to protocols 17, 21, 22, 23.

  • Also made numerous line-item changes to protocols, including removing uncertainty adjustments from table generators, which type of ex post days are required, eliminating 1-in-10 weather year, when an evaluation plan is needed, and other clarifications.

  • D.16-06-045 OP 5a: exempted third-party DR resources from LIPs and allowed the use of contracted capacity to be resource adequacy (RA) QC.

  • D.19-06-026 OP 17: acknowledged expiration of exemption authorized in D.16-06-045.

  • D.20-06-031

  • OP 13-14: established 3rd-party Demand Response Provider (DRP) quarterly testing requirements.

  • OP 15a: clarified 3rd-party DRP ex post and ex ante must be estimated at Sub-LAP.

  • OP 15b: permitted mid-year QC updates if QC values vary by >20% of 10 MW, whichever is greater.

  • OP 16: directed ED to coordinate with supply-side working group on mid-year QC process/requirements and how to enhance LIPs.

  • OP 17: requires LIP results from 3rd party DRPs to be public to the maximum extent allowable, while protecting customer privacy and market sensitive information.

  • OP 12: modified quarterly testing requirements for third-party DRPs for RA-year 2023. Established RA-year 2024 as test year.

  • Appendix A established “worst day” criterion instead of “peak day” for RA QC and 24-hour slice-of-day framework.

  • D.22-08-039: LIPs were reasonable to use for slice-of-day test year.

  • D.23-04-010 OP 11-12: established slice-of-day requirements, including snapback effect requirements in ex ante.

  • D.23-06-029

  • OP 27: removed transmission loss factor and planning reserve margin adders starting in 2024.

  • OP 30: required quarterly testing reports to be factored into RA QC award considerations.

 

Load Impact Protocol Simplification Working Group

In Decision (D.) 23-06-029 in R.21-10-002, the CPUC authorized Energy Division to conduct a stakeholder process to pursue simplification of the current LIPs. The working group met from July 2023 through January 2024, ultimately submitting a report to the commission in R.23-10-011 for consideration in Phase II. Some of the resources can be found below:

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