It is highly recommended that in evaluating DR

One of the challenges associated with CV calculations is the fact that the methodology was developed with conventional generators in mind and then adapted and applied to variable renewables [63]. While this SB 203580 methodology has also been adapted to provide a high level estimate the CV of DR [64], the traditional CV methodology does not inherently capture all of the impacts on generation adequacy associated with the operation of DR.
It can be appreciated that the availability of conventional generation depends upon the mechanics of electricity generation and upon the control systems in place, while wind generation availability is contingent upon natural phenomenon and the physical resource. The wind resource, although variable and uncertain, can be represented to a certain degree of accuracy and there is significant wind data and wind time series available. DR availability, on the other hand, depends upon the mechanics of the devices and upon the control systems, but crucially, also depends upon consumer behavior and user preferences. It is phytochrome influence that introduces challenges to the representation of the DR resource availability. It is crucially important, as is recommended in [66], that the wind, load and DR data is time-synchronized in CV calculations and the limited DR data can be a considerable challenge in this regard.