What the Base Interruptible Program is
The Base Interruptible Program (BIP) is an emergency demand response program in California: large industrial customers commit to curtail load on short notice when the grid needs it, in exchange for capacity payments. The resource is fast, fuel-independent, all-weather, and zero-carbon, and it is the principal way CLECA members provide grid services.
It is also large. BIP accounts for 804 MW of the roughly 1,500 MW of supply-side demand response in California. During the August 14, 2020 heat storm, CLECA members shed over 290 megawatts of an estimated 850 megawatts of total system load shed — with one member voluntarily reducing more than 50 megawatts beyond its program obligations at the Governor's request.
A record of performance
CLECA's defense of BIP rests on performance data rather than assertion. SCE's BIP delivered an average load reduction of 409 to 520 MW across eight full dispatch events in the summers of 2020 and 2021. The Reliability Demand Response Resource (RDRR) category through which BIP participates in CAISO markets performed at 89 percent across the four highest-load days of the September 2022 heat wave.
CLECA argues from that record that BIP is among the most cost-effective Resource Adequacy resources available and should be valued accordingly — in the Avoided Cost Calculator, in capacity proceedings, and in the cost-effectiveness analyses that govern program budgets.
The erosion problem
Recent Commission decisions have eroded BIP's economic foundation. D.21-06-029 and D.23-06-029 changed dispatch triggers, eliminated availability provisions, and created dual-participation conflicts with the Emergency Load Reduction Program (ELRP). The results show up in enrollment: PG&E's BIP declined from 300 MW in 2017 to 170 MW in 2022, a loss of over 40 percent, and SCE estimated roughly 250 MW of BIP capacity was at risk of disenrollment after the RA decision — capacity that would cost ratepayers an estimated $80 million per year to replace.
CLECA's response has been specific: petitions for modification, proposed event-day limits, incentive increases, and dual-participation reform — filed before the November opt-out periods when members make their participation decisions. In A.22-05-002, the consolidated 2024-2027 demand response programs proceeding, CLECA's testimony documented the attrition and proposed the fixes.
Defending the tariff
The same discipline applies to utility advice letters. CLECA files comments and protests when PG&E and SCE advice letters threaten the BIP design, using cost-effectiveness as the principal evaluative lens — and it times its interventions to the November opt-out periods when members make participation decisions.
Why the Avoided Cost Calculator fight is also a BIP fight
The Avoided Cost Calculator (ACC) is the model the Commission uses to value distributed energy resources, including demand response. If the ACC's Generation Capacity values are suppressed, BIP's cost-effectiveness calculation drops, its incentive payments compress, and its tariff defense becomes harder in every subsequent proceeding. That is why CLECA's methodological work in R.22-11-013 — and its objections to the 2026 ACC working model — is inseparable from its demand response California advocacy. The current demand response rulemaking, R.25-09-004, carries these questions forward, and CLECA has argued there that customers on dynamic rates should remain able to participate in supply-side demand response programs.