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Dan Johnson's avatar

See the first two files at this link: https://www.energy.ca.gov/files/2025-energy-code-date-and-hourly-factors. This is for the forthcoming Code taking effect 1/1/26.

Here is the Accounting Methodology Report, which explains LSC (formerly called TDV): https://efiling.energy.ca.gov/GetDocument.aspx?tn=255318-1

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Dan Johnson's avatar

I've enjoyed your writing, thank you.

You note that TOU has "the intention of modifying the ratepayer’s behavior and shifting their energy usage." But I think we should also consider that TOU is just price gouging during hours of the day when people cannot easily shift load. Cooking dinner and doing household chores. Why do I say this?

The California Energy Code code for buildings uses a weighted time series for each hour of the year for each of 16 state regions, which gives the Long-term System Cost of electricity on that hour, which is based on a 30 year look ahead. (Formerly called Time Dependent Valuation.) The values are highest on hours when CAISO is feeling pain. CAISO does not feel abnormal pain from 4-9pm and I can find no empirical reason why rates are higher during these hours. The peak CAISO hours tend to be 7-midnight (after sunset, while air conditioning is still running), if we had to pick a five hour block, but even five hours is an arbitrary number, and this is getting pushed even later into the night by grid battery deployment.

4-9pm does not align with carbon pollution intensity either. It's either an anachronism or a cooking tax.

There was a time around 2017 when CAISO was pleading with IOUs to set aggressive TOU rates including "super off peak" to handle the duck curve, but IOUs never did it, and instead grid scale batteries solved the duck curve. TOU price differentials have been decreasing as rates overall rise.

I'd love if you could explain why 4-9pm is still a thing. Thanks again for your work.

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