The Workshop Report states that the UDCs' proposal provides for load profiles that are based on existing rate categories, systems, procedures, load research meters, and samples. For Edison, the use of dynamic load profiles will result in modifications to its processes in order to acquire, update, and process data on a real time basis. Costs will be incurred to maintain these profiles, apply them in customer bills and ISO settlements, and disseminate them to the marketplace.
The Workshop Report states that the current UDC proposal requires minimal incremental costs to make customer class-based profiles available on January1, 1998. The UDCs plan to recover the costs for the changes to its systems and processes pursuant to Section 376. If additional segmentation or dynamic updating of load profiles is required, the UDCs will incur additional costs, and the UDCs will seek additional funding for recovery of these costs. Several ESP and customer representatives expressed opposition to allowing the UDCs to recover these costs through Section 376. The Workshop Report suggests that the Commission consider the tradeoffs between certain UDC implementation costs and the possible resulting increase in the accuracy of the load profiles if additional segmentation or dynamic profiling is used.
Calpine et al. do not object to having PG&E and SDG&E recover the cost of dynamic load profiles and additional segmentation through Section 376, so long as there is reasonable regulatory oversight by the Commission as to the amounts of such costs. Calpine et al. state that the cost associated with the development of dynamic load profiles and greater segmentation options is the price which must be paid for developing and implementing a more efficient market.
Enron comments that it plans to closely examine all Section 376 cost recovery requests by the UDCs. At this time, Enron does not have sufficient information to agree that the UDCs' costs to create load profiles, maintain profiles, apply them to customer bills and ISO settlements, and disseminate them to the public are properly recoverable under Section 376.
We previously discussed direct access implementation costs in D.97-05-040. Consistent with that decision, the UDCs may record in the subaccounts of the Industry Restructuring Memorandum Account (IRMA) the costs that are attributable to the implementation of direct access. As noted in D.97-05-040, the booking of costs to these subaccounts is no guarantee that the UDCs will be entitled to recover these costs.
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