The CPUC's consolidated review of PG&E, SCE, and SDG&E demand response applications set the program rules and budgets for 2024–2027. California's industrial DR capability — led by Base Interruptible Program (BIP) participants — was directly at stake.
What we filed
Sam Harper's April 2023 direct testimony (with rebuttal in May 2023) took positions across the program portfolio:
- Support increases to BIP incentive levels, plus an incremental "all other hours" incentive, and BIP customers' eligibility for automated demand response incentives.
- Support PG&E's 15-minute BIP option — matching program mechanics to how flexible industrial loads actually operate.
- Strongly oppose design changes to RA-eligible emergency DR programs that would unnecessarily increase dispatches and exacerbate customer fatigue; support reasonable limits on consecutive-day and rolling-30-day BIP events.
- Support the cost-effectiveness of the SCE and PG&E BIP programs, extension of the temporary increase in DR reliability capacity, and continued exemption of energy storage (not paired with fossil generation) from the prohibited-resources policy.
- Support a process for evaluating whether CAISO market integration of demand response is actually achieving its goals.
The engagement continued through briefs, comments on the proposed decision, and post-decision implementation work.
Why it matters
Baseline methods, event limits, and incentive design decide whether megawatts of proven industrial flexibility stay in California's programs — at exactly the moment the state's resource adequacy picture needs them. The perspective in this testimony is operational: Harper Advisory's principals have run industrial demand response from inside major manufacturers, not just modeled it.
Facing a related regulatory or commercial question? Harper Advisory works with a focused number of large industrial energy users across ERCOT, CAISO, PJM, and other US markets.
Contact UsThis summary is drawn from documents on the public record and is provided for general information. It is not legal advice, and it does not disclose any confidential client matter.