Earlier in this decision, we adopted Edison's proposal for it to utilize dynamic load profiles for certain customer classes beginning January 1, 1998. We are concerned that Edison may not be able to develop workable and robust dynamic load profiles by that date. While we are concerned that Edison, or any party, would advocate in pleadings filed before this Commission that it could have something in place, and then not be able to follow through with this commitment, we also understand the uncertainty that accompanies breaking new ground. We would much prefer that any applicant that makes a pleading before the Commission, and then learns that a statement made in good faith is no longer correct, inform the parties and the Commission immediately of such facts, so that we do not make a decision based on outdated information.
If Edison cannot meet the January1, 1998 deadline for having dynamic load profiles in place for residential and small commercial and industrial customers, it should speak up now or be prepared to comply with its own proposal. If necessary, Edison should request an extension under Rule 48 of our Rules of Practice and Procedure of the January1, 1998 deadline for having dynamic load profiles for those customer classes. Such a request shall be submitted no later than November10, 1997, and Edison should be prepared to explain in such a request why its request for an extension is reasonable.
Regardless of which type of load profile Edison will have on January1, 1998 for its residential and small commercial and industrial customers, Edison shall make those load profiles available to others no later than November10, 1997.
1. In D.97-05-040, the Commission ordered that the investor-owned electrical corporations hold a workshop with other interested parties to develop statistical load profile methodologies.
2. The load profile workshop was held on June5, 1997, and the Workshop Report was filed on June16, 1997.
3. A meeting was held on July 16, 1997 to discuss whether an exemption from the metering requirement should apply to customers with a maximum demand of 20 to 50 kW, and the Eligibility Supplement was filed on August 8, 1997.
4. On August1, 1997, the Profiles Supplement was filed, and the load profile data for current rate categories were made available to interested parties, except for Edison's dynamic load profiles for its Domestic and GS-1 customers.
5. D.97-05-040 permits customers with maximum demands of less than 20 kW to participate in direct access through load profiling.
6. The UDCs propose the adoption of an interim load profile approach that creates load profiles in existing rate categories that are based on daily load shapes.
7. In general, load profiling is the process of taking the cumulative kWh usage of a customer over a billing cycle and assigning it to individual hours in the cycle, based on the aggregate characteristics of the customer segment in which the customer resides.
8. Dynamic load profiles are created by reading load research meters on a daily basis, and producing daily load shapes which reflect the actual usage for that customer segment for the day.
9. Edison proposes to use dynamic load profiles for its Domestic and GS-1 classes.
10. Static load profiles are created by averaging historical data from load research samples by class, and creating load shapes that approximate customer segment usage for the given day.
11. PG&E and SDG&E propose to use static load profiles for the majority of their rate categories.
12. Deemed load profiles are created by using engineering estimates to create daily load shapes, and are used for rate schedules with predictable loads such as street lights and traffic control devices.
13. The Workshop Report states that for PG&E and SDG&E, the use of dynamic load profiles is not feasible by January1, 1998.
14. The advantage of dynamic load profiling is that it reflects fairly current conditions which affect customer load.
15. Static load profiles which use past history as a reflection of future consumption may not accurately reflect current consumption because of recent weather conditions or other relevant variables affecting electric usage.
16. Regression techniques and other methods to improve the static load profiles will take some time to implement.
17. Edison plans to use a static load profile for its master metered customers who serve residential customers.
18. The Commission stated in D.97-05-040 that the issue of master meters in a direct access environment would be addressed in an upcoming decision.
19. Except for street lights and traffic lights, and possibly agricultural customers, the use of dynamic load profiling appears appropriate for all other customer classes, because current conditions may not be adequately reflected in the static load profiles which rely on historical data.
20. The load of street lights and traffic lights is fairly consistent from day to day and year to year.
21. Kirkwood, PacifiCorp, Sierra Pacific, and SCWC have not submitted any load profiles or commented on the Workshop Report or the supplements.
22. The choice of technology to carry out the metering functions is best left to the marketplace.
23. SDG&E and PG&E propose to apply deemed load profiles to all of their street light accounts.
24. Edison proposes to restrict the use of deemed load profiles to street lights that are owned or maintained by Edison.
25. Customer-owned street lights should not be barred from load profiling simply because of who owns or maintains the photocell.
26. Segmentation allows the variety of customers within a rate schedule to be further divided into more discrete categories of similar customer types.
27. The use of segmentation for dynamic load profiles could further enhance the accuracy of the load profiles by subdividing customers within a rate schedule into more discrete customer load profiles, but the development of criteria for dividing customer groups into additional segments is likely to take some time.
28. Consideration of segmented load profiles should be deferred to 1998.
29. D.97-05-040 left open the question of whether load profiles for certain customers whose maximum demand is equal to greater than 20 kW, but less than 50 kW, should be permitted.
30. In the Eligibility Supplement, PG&E and SDG&E propose that load profiles for all direct access customers up to 50 kW be permitted on an interim basis using the UDCs' simplified load profile methodology.
31. Edison opposes the interim blanket exemption, and proposes that a temporary backlog exemption be adopted instead.
32. The Commission does not know for certain how much hourly interval meters will cost, what kinds of monthly fees will be associated with such meters, and what the availability of such meters will be.
33. If the cost of having an hourly interval meter is high, or if there is a waiting list to have such meters installed, this will discourage customers from signing up for direct access.
34. If the cost of having an hourly interval meter is low, and hourly interval meters can be readily installed, it is likely that more customers will choose direct access.
35. If load profiles for customers with a maximum demand of 20 to 50 kW are not permitted, the number of customers who select direct access in this range of usage will depend on the affordability and availability of hourly interval meters.
36. If load profiles for customers with a maximum demand of 20 to 50 kW is permitted, more customers will be eligible for direct access, but that is likely to increase the amount of error due to inaccurate load profiles.
37. The workshop assessing the impact of the metering requirement on customers with a maximum demand of 20 to 50 kW should also address the inconsistencies in the load profiles regarding the 20 kW threshold.
38. If the load profiles do not match actual customer usage, a discrepancy in the UFE will result.
39. Separately identifying the UFE that is attributable to load profiling will help to control the size of the UFE, and to allocate the UFE losses to those who are responsible for it.
40. The use of dynamic load profiles should help to reduce the amount of UFE.
41. Additional metering points should help to reduce the amount of UFE, and to allow the UFE to be allocated to those who cause the UFE losses.
1. Edison's motion to accept its comments to the Eligibility Supplement one day out of time should be granted.
2. The use of dynamic load profiles for the three major electric utilities in this state will result in uniform load profiling methodologies throughout most of the state, and will result in improved accuracy of the load profiles.
3. The UDCs' proposal to use static load profiles on an interim basis for the majority of the customer classes, and Edison's use of dynamic load profiles for its residential and small commercial and industrial customers, should be adopted.
4. Until the Commission resolves the issue of how direct access affects master metered customers and sub-metered customers, a static load profile for master metered customers should not be offered.
5. The UDCs should take action immediately to ensure that dynamic load profiling is in place for all the customer classes, except for agricultural customers, street lights and traffic lights, no later than July1, 1998.
6. Unless exempted from having to provide direct access to its customers, Kirkwood, PacifiCorp, Sierra Pacific, and SCWC remain obligated under Ordering Paragraph 5 of D.97-05-040 to provide load profiles to its customers with loads of less than 20 kW.
7. The issue of whether other entities should be allowed to create and design load profiles should not be addressed at this time, but should be revisited in 1998.
8. The UDCs should make all street lights, regardless of ownership, eligible for direct access using deemed load profiles.
9. The UDCs should be permitted to require in their tariffs and profiles that the customer must meet or exceed the photocell maintenance requirements of the UDC in order to be eligible for direct access using that load profile.
10. The photocell maintenance requirement is reasonable because it helps to ensure that the street light usage is consistent with the estimate of usage in the deemed load profiles.
11. Since electricity usage for traffic lights is fairly consistent, SDG&E's use of a static load profile for its traffic lights accounts should be permitted since the usage is unlikely to vary much from a deemed load profile.
12. In deciding whether load profiles for customers with a maximum demand of 20 to 50 kW should be permitted, the Commission should weigh the cost and availability of hourly interval meters, and what may happen if the Commission allows or does not permit the use of load profiles for this customer group.
13. The interim blanket exemption proposal of PG&E and SDG&E should be adopted because it will permit those customers who fall within the 20 to 50 kW range to examine the costs and benefits of moving toward an hourly interval meter, while being able to use load profiles on an interim basis.
14. A customer whose maximum demand is under 50 kW in nine out of the last twelve months may use the 20 to 50 kW load profile, provided that the maximum load for any one of those twelve months is less than 80 kW.
15. The interim blanket exemption will provide an opportunity for market forces to determine how much hourly interval meters should cost, and allow the supply of such meters to match the demand.
16. Interim load profiling for 20 to 50 kW customers is equitable given the uncertainty over the cost and availability of hourly interval meters, and is consistent with the provisions of Section 365(b).
17. To access the impact of the metering requirement on 20 to 50 kW customers, the Commission should convene a workshop no later than May30, 1998.
18. To the extent load profiles are used in a transaction over which we have jurisdiction, the same load profile that a given customer uses should be used for all applications.
19. The UDCs should develop a plan to place more meters at strategic points in the transmission and distribution system to detect where the UFE losses are occurring, and who is responsible for the losses.
20. The Commission needs to revisit a number of load profiling issues in 1998.
21. To assess the effects of load profiling, and to determine how load profiling methodologies and administration can be improved, the Commission needs to monitor the data associated with the use of load profiles for direct access.
22. Consistent with D.97-05-040, the UDCs may record in the IRMA subaccounts the costs that are attributable to the implementation of direct access.
23. The booking of costs to the IRMA subaccounts is no guarantee that the UDCs will be entitled to recover these costs.
24. Should it be necessary, Edison may request an extension of the deadline by which it must have dynamic load profiles available to certain classes by January1, 1998.
IT IS ORDERED that:
1. The motion of Southern California Edison Company (Edison) to accept its comments to the Eligibility Supplement one day out of time is granted. The Docket Office is directed to file Edison's comments to the Eligibility Supplement as if it was filed on August11, 1997.
2. The interim load profile approach that was proposed by Pacific Gas and Electric Company (PG&E) and San Diego Gas & Electric Company (SDG&E), and as discussed in this decision, is approved.
a. The interim load profile period shall last until dynamic load profiles for all customer classes, except for street lights and traffic lights, can be instituted.
b. PG&E and SDG&E shall file with the Docket Office and serve a status report within 30 days from today's date as to the reasons why dynamic load profiling cannot be instituted for their residential and small commercial and industrial customers by January1, 1998.
(1) Such a status report shall also inform the Commission as to what steps they will take to ensure that dynamic load profiling can be in place beginning on July1, 1998, as well as the estimate of the costs that they anticipate spending to institute load profiles.
(2) Interested parties may file comments on the status report within 21 days of the status report's filing date.
c. Edison shall be required to file and serve a status report within 30 days from today's date on what steps it needs to take to ensure that dynamic load profiling can be instituted for the other customer classes described in this decision by July1, 1998.
(1) The status report shall also estimate the costs that Edison anticipates spending to institute the remaining dynamic load profiles.
(2) Interested parties may file comments on the status report within 21 days of the status report's filing date.
d. Edison shall make the load profiles that it plans to utilize for its residential and small commercial and industrial customers available to others starting on, or before, November 10, 1997.
3. Kirkwood Gas and Electric Company, PacifiCorp, Sierra Pacific Power Company, and Southern California Water Company shall file a status report with the Commission's Docket Office within 30 days from today explaining what their intentions are with respect to the offering of load profiles to their customers who have a maximum demand of less than 20 kW, their reasoning for their actions, and what their timetable is for implementing load profiles.
a. The status report shall be served on the service list for this proceeding, and interested parties may file comments on the status reports within 21 days of the report's filing date.
4. The interim blanket exemption proposal of PG&E and SDG&E is adopted.
a. PG&E, SDG&E, and Edison shall make available interim load profiles for customers with a maximum demand of 20 kW or greater, but less than 50 kW.
b. The 20 to 50 kW load profiles shall be made available for use no later than January1, 1998, and shall remain in effect until September30, 1998 unless extended by the Commission.
5. PG&E, SDG&E, and Edison shall institute dynamic load profiles for all eligible load profile customers, as discussed in this decision, no later than July1, 1998.
1. The Energy Division shall convene a workshop, in conjunction with the utility distribution companies (UDCs) and other interested parties, within 100 days from today, to discuss the process for segmenting the current customer rate schedules into more segmented rate categories.
a. The Energy Division shall prepare a workshop report about the segmentation issues and its recommendations, and shall file the report with the Commission's Docket Office within 130 days from today, and shall serve the report on those attending the workshop, and anyone else requesting a copy of the report.
(1) Interested parties may file comments to the report within 21 days of the filing of the report.
7. The Energy Division shall convene a workshop with the UDCs and other interested persons no later than May30, 1998, to assess the impact of the metering requirement on 20 to 50 kW customers, to determine whether the load profiles should continue past September30, 1998, and to examine the inconsistencies in the load profile cut-off points.
a. The Energy Division shall prepare and file a workshop report with the Commission's Docket Office within 30 days of the workshop's conclusion, and serve it on those in attendance at the workshop, and to anyone else requesting a copy.
(1) Interested persons may file comments to the workshop report within 21 days of such filing.
8. The Energy Division shall convene a workshop with the UDCs and other interested persons no later than February 15, 1998, to determine whether there should be dynamic load profiles for agricultural customers.
a. The Energy Division shall prepare and file the workshop report by March13, 1998, and serve it in accordance with Ordering Paragraph 7.a.
(1) Interested persons may file comments to the workshop report no later than March 31, 1998.
9. The UDCs shall apprise the Commission of the independent system operator's efforts to control unaccounted for energy (UFE) losses, and shall develop plans to place more meters at strategic points in the transmission and distribution system so as to detect losses attributable to UFE.
a. The UDCs shall file a report regarding the above on or before March31, 1998 with the Docket Office, and shall serve the report on the electric restructuring service list.
(1) Interested parties may file comments to the report on or before April24, 1998.
10. The Energy Division should hold a workshop within 75 days from today to discuss with the UDCs and other market participants the type of data that the Energy Division should gather, and the type of information that the UDCs and other market participants should be required to maintain, to assess the effects of load profiling, and to determine how load profiling methodologies and administration can be improved.
a. The Energy Divison shall prepare and file a workshop report with the Docket Office within 100 days from today, and serve that report on the parties who attended the workshop, as well as on anyone else requesting a copy of the report.
(1) Interested parties may file comments on this workshop report within 120 days from today.
b. The Commission shall delegate to the assigned Commissioners the authority to issue whatever rulings may be necessary to establish a monitoring program to evaluate the effects of load profiling, and to identify how the load profiling methodologies and procedures can be improved.
This order is effective today.
Dated October 30, 1997, at San Francisco, California.
P. GREGORY CONLON
President
JESSIE J. KNIGHT, JR.
HENRY M. DUQUE
JOSIAH L. NEEPER
RICHARD A. BILAS
Commissioners
I will file a concurring opinion.
/s/ P. GREGORY CONLON
President
TABLE OF CONTENTS
OPINION REGARDING THE LOAD PROFILING 2
WORKSHOP REPORT AND ITS SUPPLEMENTS 2
I. Summary 2
II. Background 3
A. Introduction 5
B. Load Profile Methodologies 6
1. Introduction 6
2. Comments On Load Profile Methodologies 12
a. Introduction 12
b. Static and Dynamic Load Profiles 12
(1) Discussion 15
c. Deemed Load Profiles 19
(1) Discussion 21
C. Segmentation 22
D. Load Profiles For 20 kW to 50 kW Customers 27
1. Introduction 27
2. Proposals For 20 to 50 kW Customers 27
3. Comments On Load Profiles For 20 To 50 kW 29
4. Discussion 36
E. Load Profile Applications 38
F. Future Review 43
G. Implementation Costs 46
H. Extension Of Deadline For Edison's Dynamic Load Profiles 48
Findings of Fact 48
Conclusions of Law 52
ORDER 54
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