Public Utilities - Proposed Cost Effectiveness Programs For 2012

Transcription

1 STATE OF CALIFORNIA PUBLIC UTILITIES COMMISSION SAN FRANCISCO, CA Edmund G. Brown Jr., Governor June 19, 2013 Advice Letter 2751-E Akbar Jazayeri Vice President, Regulatory Operations Southern California Edison Company P O Box 800 Rosemead, CA Subject: Cost-Effective Plan with Revised Result for the Demand Bidding Program Dear Mr. Jazayeri: Advice Letter 2751-E is effective March 21, 2013 per Resolution E Sincerely, Edward F. Randolph, Director Energy Division

2 ADVICE LETTER (AL) SUSPENSION NOTICE ENERGY DIVISION Utility Name: Southern Calif. Edison Utility No./Type: 338/Electric Advice Letter No.: AL 2751-E Date AL filed: June 28, 2012 Utility Contact Person: Darrah Morgan Utility Phone No.: (626) Date Utility Notified: 7/27/2012 via: [ x ] to: Darrah.Morgan@sce.com Fax No.: ED Staff Contact: Joanne Leung Tel & (415) , leu@cpuc.ca.gov For Internal Purposes Only: Date Calendar Clerk Notified: / / Date Commissioners/Advisors Notified: / / [ x ] INITIAL SUSPENSION (up to 120 DAYS) This is to notify that the above-indicated AL is suspended for up to 120 days beginning July 28, 2012 for the following reason(s) below. If the AL requires a Commission resolution and the Commission s deliberation on the resolution prepared by Energy Division extends beyond the expiration of the initial suspension period, the advice letter will be automatically suspended for up to 180 days beyond the initial suspension period. [ ] Section 455 Hearing is Required. [ ] Advice Letter Requests a Commission Order. [ X ] Advice Letter Requires Staff Review Expected duration of initial suspension period: 120 days. [ ] FURTHER SUSPENSION (up to 180 DAYS beyond initial suspension period) The AL requires a Commission resolution and the Commission s deliberation on the resolution prepared by Energy Division have extended beyond the expiration of the initial suspension period. The advice letter is suspended for up to 180 days beyond the initial suspension period. Protestant to the advice letter: Division of Ratepayer Advocates If you have any questions regarding this matter, please contact Joanne Leung at (415) or via at leu@cpuc.ca.gov cc: Edward Randolph Bruce Kaneshiro Joy Morgenstern Maria Salinas

3 Akbar Jazayeri Vice President of Regulatory Operations June 28, 2012 ADVICE 2751-E (U 338-E) PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA ENERGY DIVISION SUBJECT: Cost-Effective Plan With Revised Result for the Demand Bidding Program In compliance with Decision (D.) , Southern California Edison Company (SCE) hereby submits a cost-effective plan with program changes to improve SCE s Demand Bidding Program (DBP) cost-effectiveness result. The DBP cost-effectiveness analysis and plan are described in Attachment A, the Demand Response (DR) DR Reporting Template for 2011 and 2012 DBP Program Performance are set forth in Attachment B, and the Guidance on Cost-Effectiveness from the California Public Utilities Commission s (Commission s) Energy Division is detailed in Attachment C. All three are attached hereto. PURPOSE Pursuant to Ordering Paragraph (OP) 48 of D , SCE is proposing a costeffective plan with program changes to improve SCE s DBP cost-effectiveness result. In this advice filing, SCE proposes to reduce the program administration budget by $355,999 and encourage customer performance through controlled enrollment to improve the cost-effectiveness of DBP. BACKGROUND On December 16, 2010, D ordered all utilities to adopt the 2010 DR Cost- Effectiveness Protocols (2010 Protocols) in all future cost-effectiveness analyses of their DR activities unless otherwise directed. In Application (A.) et al., the DR Application for , the utilities applied the 2010 Protocols and performed the DR cost-effectiveness accordingly. Pursuant to OP 26 of D , all utilities were ordered to either decrease the overall budget requested or increase the relative benefits for each program to make P.O. Box Walnut Grove Ave. Rosemead, California (626) Fax (626)

4 (U 338-E) June 28, 2012 their programs cost-effective. Energy Division published guidance on the format to be used for the cost-effectiveness analyses in May 2012 pursuant to OP 83 of D SCE has performed the required analysis following the guidance published by the Energy Division and developed a cost-effective plan to revise the DBP results accordingly. PROPOSED DEMAND BIDDING PROGRAM AND BUDGET CHANGES SCE proposes to take three steps to improve the cost-effectiveness of DBP. These are: 1. Remove non-performers from the program; 2. Reduce program labor and direct Marketing, Education & Outreach costs; and 3. Re-allocate 10 percent of DBP administration costs to the Base Interruptible Program (BIP). SCE will be modifying DBP to add an annual performance evaluation. At the customer s annual performance evaluation time, a customer who is enrolled for one year, but has not actively participated in the program will be evaluated for removal from the program with an option to re-enroll in DBP or other eligible DR programs. In addition, SCE plans to reduce the DBP Marketing budget to $10,000 in 2012, $40,000 in 2013 and $87,500 in Labor costs will be reduced by $218,499 for Finally, SCE is allocating 10 percent of the administration budget from DBP to BIP to reduce the DBP budget to reflect the anticipated decrease in DBP performance associated with dual participation for The combination of all the changes above will increase the Total Resource Cost benefitcost ratio to 0.97 in 2013 and 0.91 in These steps are described in detail in Attachment A to this advice letter. Please see Attachment A for DBP s Cost-Effective Plan, Attachment B for the DR Reporting Template for 2011 and 2012 DBP Program Performance, and Attachment C for Guidance on Cost-Effectiveness provided by the Energy Division. PROPOSED FUTURE TARIFF CHANGES SCE requests Commission approval of the Cost-Effective Plan to revise the costeffectiveness of DBP as outlined in Attachment A, Section D. Once this filing is approved, SCE will file a new Tier 1 advice letter to propose tariff changes to implement the approved Cost-Effective Plan along with program changes. This advice filing will not increase any rate or charge, cause the withdrawal of service, or conflict with any other schedule or rule.

5 (U 338-E) June 28, 2012 TIER DESIGNATION Pursuant to OP 48 of D , this advice letter is submitted with a Tier 2 designation. EFFECTIVE DATE This advice filing will become effective on July 28, 2012, the 30 th calendar day after the date filed. NOTICE Anyone wishing to protest this advice filing may do so by letter via U.S. Mail, facsimile, or electronically, any of which must be received no later than 20 days after the date of this advice filing. Protests should be mailed to: CPUC, Energy Division Attention: Tariff Unit 505 Van Ness Avenue San Francisco, California EDTariffUnit@cpuc.ca.gov Copies should also be mailed to the attention of the Director, Energy Division, Room 4004 (same address above). In addition, protests and all other correspondence regarding this advice letter should also be sent by letter and transmitted via facsimile or electronically to the attention of: Akbar Jazayeri Vice President of Regulatory Operations Southern California Edison Company 2244 Walnut Grove Avenue Rosemead, California Facsimile: (626) AdviceTariffManager@sce.com Leslie E. Starck Senior Vice President c/o Karyn Gansecki Southern California Edison Company 601 Van Ness Avenue, Suite 2030 San Francisco, California Facsimile: (415) Karyn.Gansecki@sce.com

6 (U 338-E) June 28, 2012 There are no restrictions on who may file a protest, but the protest shall set forth specifically the grounds upon which it is based and shall be submitted expeditiously. In accordance with Section 4 of General Order (GO) 96-B, SCE is serving copies of this advice filing to the interested parties shown on the attached GO 96-B and A et al. service lists. Address change requests to the GO 96-B service list should be directed by electronic mail to AdviceTariffManager@sce.com or at (626) For changes to all other service lists, please contact the Commission s Process Office at (415) or by electronic mail at Process_Office@cpuc.ca.gov. Further, in accordance with Public Utilities Code Section 491, notice to the public is hereby given by filing and keeping the advice filing at SCE s corporate headquarters. To view other SCE advice letters filed with the Commission, log on to SCE s web site at For questions, please contact Amy Liu at (626) or by electronic mail at Amy.Liu@sce.com. Southern California Edison Company AJ:al:sq Enclosures Akbar Jazayeri

7 CALIFORNIA PUBLIC UTILITIES COMMISSION ADVICE LETTER FILING SUMMARY ENERGY UTILITY MUST BE COMPLETED BY UTILITY (Attach additional pages as needed) Company name/cpuc Utility No.: Southern California Edison Company (U 338-E) Utility type: Contact Person: Darrah Morgan ELC GAS Phone #: (626) PLC HEAT WATER Disposition Notice to: EXPLANATION OF UTILITY TYPE ELC = Electric GAS = Gas PLC = Pipeline HEAT = Heat WATER = Water (Date Filed/ Received Stamp by CPUC) Advice Letter (AL) #: 2751-E Tier Designation: 2 Subject of AL: Cost-Effective Plan With Revised Result for the Demand Bidding Program Keywords (choose from CPUC listing): Compliance AL filing type: Monthly Quarterly Annual One-Time Other If AL filed in compliance with a Commission order, indicate relevant Decision/Resolution #: D Does AL replace a withdrawn or rejected AL? If so, identify the prior AL: Summarize differences between the AL and the prior withdrawn or rejected AL 1 : Confidential treatment requested? Yes No If yes, specification of confidential information: Confidential information will be made available to appropriate parties who execute a nondisclosure agreement. Name and contact information to request nondisclosure agreement/access to confidential information: Resolution Required? Yes No Requested effective date: 7/28/12 No. of tariff sheets: -0- Estimated system annual revenue effect: (%): Estimated system average rate effect (%): When rates are affected by AL, include attachment in AL showing average rate effects on customer classes (residential, small commercial, large C/I, agricultural, lighting). Tariff schedules affected: None Service affected and changes proposed 1 : Pending advice letters that revise the same tariff sheets: 1 Discuss in AL if more space is needed.

8 Protests and all other correspondence regarding this AL are due no later than 20 days after the date of this filing, unless otherwise authorized by the Commission, and shall be sent to: CPUC, Energy Division Attention: Tariff Unit 505 Van Ness Avenue San Francisco, CA Akbar Jazayeri Vice President of Regulatory Operations Southern California Edison Company 2244 Walnut Grove Avenue Rosemead, California Facsimile: (626) Leslie E. Starck Senior Vice President c/o Karyn Gansecki Southern California Edison Company 601 Van Ness Avenue, Suite 2030 San Francisco, California Facsimile: (415)

9 ATTACHMENT A Southern California Edison s Plan to Improve the Cost-Effectiveness for the Demand Bidding Program

10 Southern California Edison s Plan to Improve the Cost-Effectiveness for the Demand Bidding Program Table of Contents A. BACKGROUND... 1 B. SUMMARY OF STEPS TO IMPROVE THE COST-EFFECTIVENESS OF DBP... 1 C. COMPLIANCE WITH ENERGY DIVISION COST-EFFECTIVENESS GUIDANCE... 1 D. STEPS TO IMPROVE THE COST-EFFECTIVENESS OF THE DEMAND BIDDING PROGRAM Remove Non-Performers on the Program Reduce Program Labor and ME&O costs Allocation of 10% of DBP Admin costs to BIP... 3 E. QUALITATIVE BENEFITS Market Benefits Non-Energy and Non-Monetary Benefits Other Qualitative Benefits Specific to DBP... 5

11 A. Background On December 16, 2010, the California Public Utilities Commission ( Commission ) issued Decision (D.) which established cost-effectiveness protocols ( Protocols ) for demand response (DR). In addition, it adopted the use of the DR Reporting Template developed by Energy and Environmental Economics, Inc. (E3). On March 1, 2011, Southern California Edison Company (SCE) filed Application (A.) which performed cost-effectiveness analyses of its program portfolio using the newly adopted 2010 Protocols and Reporting Template. On April 30, 2012, the Commission issued D that authorized the continuation of SCE s programs. However, that decision also required that each individual program be cost-effective, rather than evaluating the programs from a portfolio basis. SCE s Demand Bidding Plan (DBP) was found to be possibly cost-effective because its Total Resource Cost (TRC) benefit-cost ratio fell in the range of 0.5 and 0.9. As such, SCE was ordered to modify DBP and other possibly cost-effective programs in Ordering Paragraph (OP) 26 by decreasing the overall budget requested or increasing the relative benefits for each program. OP 48 specifically directs SCE to submit a Tier 2 Advice Letter indicating which steps it will take to make DBP cost-effective. This filing will discuss how SCE intends to modify DBP to improve costeffectiveness. B. Summary of Steps to Improve the Cost-Effectiveness of DBP In order to increase the cost-effectiveness of DBP, SCE plans to: 1. Remove non-performers on the program; 2. Reduce program labor and direct Marketing, Education & Outreach costs; and 3. Re-allocate 10% of DBP administration costs to BIP. The combination of all the changes above will increase the TRC benefit-cost ratio to 0.97 in 2013 and 0.91 in These steps are described in detail in Section D below. C. Compliance with Energy Division Cost-Effectiveness Guidance On May 11, 2012, Commission Staff issued Guidance ( Guidance ) on Cost- Effectiveness 1 to comply with OP 83 of D This Guidance provided direction on the format to be used for all cost-effectiveness analyses required in the utilities compliance filings. SCE has complied with items 1 through 6 of this guidance document by: 1. Following all requirements in D ; 2. Following all requirements in Attachment 1 of D ; 3. Following all requirements from Exhibit PG&E-11 in A et. al.; 1 See Attachment C to Advice 2751-E for a copy of the Guidance. 1

12 4. Following all cost-effective requirements listed in Attachment 1 of the May 13, 2011 Scoping Ruling for A ; 5. Filing two versions of the Demand Response Reporting Template, one using load impacts filed on June 1, 2012 and the other using load impacts filed on April 1, 2011; See Attachment B and 6. Including a tab in the DR Reporting Template that includes program costs that are allocated from other budgets. See Attachment B, File DR Reporting Template June 2012, Tab Guidance #6 In addition, Item 7 of the Guidance requires the utilities to provide qualitative descriptions of benefits to complement the quantitative inputs/outputs of the DR Reporting Template. Section E of this Attachment provides those qualitative benefits associated with DBP. Finally, Item 8 of the Guidance requires the utilities to provide written explanations of any changes for inputs or other aspects of the cost-effectiveness analysis. Section D of this Attachment will describe the changes to DBP and an additional tab will be included in the DR Reporting Template to describe the accounting modifications. See Attachment B, File DR Reporting Template June 2012, Tab Guidance #8 D. Steps to Improve the Cost-Effectiveness of the Demand Bidding Program 1. Remove Non-Performers on the Program SCE is modifying DBP to add an annual performance evaluation. At its annual performance evaluation time, a customer who is enrolled for one year, but has not actively participated in the program will be evaluated for removal from the schedule with an option to re-enroll in DBP or other eligible DR programs a) Challenges Due to the Non-Penalty Design of DBP Although DBP rewards customers for reducing load during events, the program does not penalize customers if they fail to perform to their bid or if they enroll in the program but do not bid at all. Of the 1,395 customers enrolled in DBP at the end of 2010, 647 did not bid in any event hours in An additional 129 customers bid but did not manage to earn any credit at all during Combined, these 776 customers represent 56% of the enrolled accounts in DBP. Over half of these 776 accounts have been on DBP for four years or more, suggesting that the non-penalty nature of DBP has led to customers staying on the program indefinitely, even if they are neither engaged with the program nor receiving any benefits. 2

13 b) Benefits of Removing Non-Performers Removing non-performers will preserve the penalty-free design of DBP while encouraging customers to place bids and to follow through on their bids. SCE believes that this will strengthen the link between customer bids and customer performance, which will be increasingly important as DBP is integrated into the wholesale market. Removing non-performing customers from DBP will also help SCE and these customers determine if another DR program might be a better fit, given their lack of success with DBP. Finally, removing non-performing customers could improve the ability of the Statewide Load Impact Studies to assign a load impact value to new customers to the program. The studies use enrollment to determine a per-customer load impact, but the large number of nonparticipating DBP customers inflates the enrollment figure with customers that never participate. 2. Reduce Program Labor and ME&O costs SCE plans to reduce funding in labor and marketing, education and outreach (ME&O) to assist in improving the program s cost-effectiveness result. SCE will reduce $218,499 in labor for along with taking a $137,500 reduction in marketing because of the timing of the final decision for These reductions can be found in the updated DR Reporting Template and will be reflected as a fund shift in our monthly report. 3. Allocation of 10% of DBP Admin costs to BIP In the 2012 DR Application proceeding, parties, including SCE, argued the current cost effectiveness protocols do not adequately capture the benefits of programs with substantial dual participation such as DBP. Until such time this issue can be adequately modeled in the protocols, SCE is proposing to re-allocate 10% of DBP administration and ME&O costs to BIP. SCE bases this proposal on a matching principle analogous to that used in financial accounting which requires a matching of revenues with the costs incurred to generate those revenues. In this case BIP customers who dual participate with DBP receive the benefits of the DBP incentive payments; yet the BIP program does not carry the related costs incurred by SCE to be able to offer the DBP incentives to them. SCE has elected to reallocate a very conservative 10% of DBP administrative and ME&O costs to BIP (this reallocation has an insignificant impact on the cost-effectiveness of BIP). Based on MW, the DBP customers who are also enrolled in BIP constitute 88% of the total DBP MW. This mismatching of benefits and costs between programs where dual-participation is allowed is not explicitly addressed in the Protocols. SCE recommends that such adjustments be allowed and that this subject be considered in future workshops. 3

14 E. Qualitative Benefits 1. Market Benefits a) Improved System Reliability: DR improves the reliability of the grid as system operators are provided with more flexible resources to meet contingencies, thus lowering the likelihood and consequences of forced outages. The DR Reporting Template takes into account improved system reliability in terms of assigning capacity benefits to a DR program across summer months (May through October). However, because there is excess capacity in the winter months, DR programs receive no capacity value during the winter months. Because capacity benefits are the largest share among total quantifiable benefits in the DR Reporting Template, a year-round DR program, such as DBP, does not receive the full value it should, compared to a summer-only program. Further, a year-round DR program can alleviate transmission and distribution constraints. As more and more DR programs have the capability of being dispatched locally, DR programs should be assigned some value for its capability to mitigate localized outages. This value is difficult to quantify until more information regarding localized dispatch is available. b) Reduced price volatility: Prices of energy are most volatile at times of peak demand. DR programs, such as DBP, help to balance the demand at those times by mitigating the suppliers ability to exercise market power by raising power prices significantly above production costs. c) Enhanced market competitiveness: Even at times of normal demand, the availability of DR increases market competition as demand is limited and suppliers of traditional generation are all trying to cater to that demand. 2. Non-Energy and Non-Monetary Benefits a) Spillover awareness effect: In addition to reducing load at peak times, DR programs lead customers to be more aware of DR, energy efficiency, and energy conservation in general. This can motivate them to enroll in other customer programs offered by the utility. Also, effective awareness encourages customers to promote programs by word of mouth to their friends and neighbors (for residential programs) or business associates (for commercial), thus helping to widen the potential customer base. Particularly in the case of DBP, its flexibility and its absence of penalties encourages enrollment in the program, which in turn facilitates the marketing of other, more valuable DR programs to these customers. b) Improved Choice: DR such as DBP gives customers more options for managing their electricity costs and improves the way they use energy. 4

15 c) Environmental and Societal benefits: Participation in DBP allows customers to lessen their impact on the environment. It also gives companies and corporations a better image of being environmentally friendly. 3. Other Qualitative Benefits Specific to DBP Several DBP customers are dually enrolled as BIP customers. Dually enrolled customers provide the benefit of flexible load reduction during different times of needs. However, due to the rules in the DR Protocols, MW load impacts may only be counted once. Therefore, the DR Reporting Template shows that there are approximately 10 MW of DBP in the summer, even though there are approximately 75 MW available. This approach reduces the cost-effectiveness evaluation of DBP. Currently, the TRC benefit-cost ratio of DBP equals However, if DBP was evaluated as a standalone program without dual participation consideration, then the TRC benefit-cost ratio would equal The purpose of the dual participation adjustment in the DR Protocols is to prevent double counting of load impacts during times when both programs are called simultaneously. However, DBP may be called many more times than BIP, and concurrent calls between DBP and BIP are rare. This elimination of the DBP MW inaccurately reduces the benefits of DBP. In addition, DBP is a gateway program for new DR customers, providing them an opportunity to participate in a DR program without any penalties. It allows customers to manage consumption of electricity in response to supply and demand balances without a serious commitment. Once customers understand how they can manage their load, then they can commit to a more cost-effective program that can also be more beneficial to them. 5

16 ATTACHMENT B Demand Response Reporting Template for 2011 and 2012 Demand Bidding Program Performance [Copies of the Excel files are available upon request by (advicetariffmanager@sce.com) or by telephone ( ).]

17 ATTACHMENT C Energy Division s Guidance on Cost-Effectiveness

18 Energy Division Guidance on Cost-effectiveness Energy Division is providing this guidance pursuant to Ordering Paragraph 83 of D , which orders Commission staff to provide guidance on the format to be used for any cost-effectiveness analysis required in the utilities compliance filings. All compliance filings must follow previous Commission cost-effectiveness directives, including: 1. All requirements in D All requirements in Attachment 1 2 of D (the Demand Response Cost-Effectiveness Protocols), including use of Demand Response (DR) Reporting Template to report program costeffectiveness. 3. Energy Division's Guidance to SDG&E, SCE and PG&E on the DR Cost Effectiveness Protocol Templates (1/21/11), submitted as Exhibit PG&E-11 in A All cost-effectiveness requirements listed in Attachment 1 of the May 13, 2011 Scoping Ruling 3 for A , pages A1-A2, with the following clarifications: Each program s monthly allocations of avoided costs and A factor analysis shall be based only on Energy and Environmental Economics, Inc. s (E3) suggested method, using 250 peak hours. A B factor of 100% for day-of programs and 88% for day-ahead programs shall be used. Programs which cannot be clearly defined as either day-of or day-ahead can use a different B factor, but an explanation for the deviation must be provided. A C factor of 95% shall be used for any program which cannot be triggered at the discretion of the utility. Otherwise, a C factor of 100% can be used. The D factor for any program shall be based on each utility s estimated ability to use a program on a locational basis, or any other relevant factor, during the program cycle. An E factor of 140% (reflecting peak energy prices) shall be used for all DR programs. If there is a clear reason to use a different energy price for a particular program, a utility may do so, but an explanation must be provided. 5. Each utility should use the updated load impacts that will be filed on June 1, 2012 as inputs to their updated cost-effectiveness analyses. In addition, each utility shall file a cost-effectiveness analysis using the load impacts filed on April 1, 2011, which were used in proceeding A If D requires that a particular Demand Response program achieve a certain level of costeffectiveness, that analysis shall be based on the June 2012 load impacts. The additional analysis using the 2011 load impacts will allow the Commission to compare the cost-effectiveness analysis

19 in the compliance filings pursuant to D with the cost-effectiveness analysis filed in A , and will not be used to determine whether a program is cost-effective. Note that this requires each utility to file two versions of the Demand Response Reporting Template, one using load impacts from the 2011 report and the other using load impacts from the 2012 report. The filenames used should include the phrase 2011LI or 2012LI so as to make it clear which version uses which load impacts. 6. Program costs which are not included in the budget of the specific program, but are allocated from other budgets (including budgets approved in other proceedings), shall be clearly identified and explained. Each utility shall include this information on a clearly-marked tab in their DR Reporting Templates which lists all budgets that were included in the cost-effectiveness analysis, and use the format below: Budget Amount BIP DBP CBP XYZ Category 6: EM&V $10,535,927 53% 12% 26% 9% Category 7: DR residential ME&O $1,300,000 0% 0% 0% 100% Category 8: Notification systems $20,000,000 25% 25% 25% 25% A. xx-xx-xxx Incentives $75,600,285 62% 10% 26% 2% A. xx-xx-xxx IT costs $3,597,123 53% 12% 26% 9% 7. D states We note that D provided guidance to the Utilities to include qualitative descriptions of certain benefits to complement the cost-effectiveness numbers. All three of the applications failed to include this information, which we find to be critical in making our evaluation. Many of our choices in terms of our approach are severely limited by this lack of compliance with our guidance. Going forward, we expect to have this information to inform our deliberation on how to determine cost-effectiveness of DR applications. As a result, we expect that these compliance filings will comply with the requirement in the DR Cost-effectiveness Protocols that qualitative analysis of additional (optional) benefits be included along with the DR Reporting Template. We expect that these compliance filings will provide qualitative descriptions of any relevant environmental, market, or non-energy benefits, or any other non-quantified data, for each Demand Response program. 8. The utilities shall provide a written explanation for any inputs, or other aspect of the costeffectiveness analysis of any program, that are different than the analysis previously provided for the program. This includes any changes to any of the five adjustment factors. It is not necessary to include an explanation of changes which were made to comply with the directives in this guidance, such as use of recent load impacts. The written explanations can be brief, should be included on a clearly-marked tab in the DR Reporting Templates, and should use the format below: Program Change Explanation CBP admin costs Changed because Decision decreased the EM&V and ME&O budgets allocated to this program BIP admin costs Changed because Decision decreased the EM&V and ME&O budgets allocated to this program BIP A factor Program availability increased from 120 to 180 hours, increasing the A factor to 73%