F. Future Review
The UDCs contend that the issues related to load profiling are complex and contentious. In addition, any adopted changes are likely to result in significant system changes which require substantial lead times to implement. Due to these considerations, the UDCs propose that the interim load profiling methodology, as discussed earlier, be adopted for January 1, 1998. However, the UDCs believe that a proceeding should be opened in 1998 to further examine load profile development methodologies. The UDCs propose that among the issues to be deferred are: segmentation proposals beyond the UDCs' current proposals, more advanced reconciliation techniques, and more advanced procedures for settlement of energy imbalances.
The Workshop Report states that most workshop participants are in accord with the UDCs' proposal for addressing unresolved load profiling issues in a future Commission proceeding. They believe that the proceeding should begin as soon as possible after January1, 1998, and implementation of the approved methodology should be scheduled for no later than January1, 1999.
The UDCs propose the following schedule:
1st quarter 1998 Status report on use of load profiles
Workshops and workshop reports
2nd quarter 1998 Hearings, if necessary
3rd quarter 1998 Commission decision
January 1, 1999 Implementation
The CEC staff proposed to implement a more permanent load profiling design in 1999 so that there will be one year's worth of data when the Commission reevaluates load profiles in 2000. The CEC staff also suggests that data collection include the PX price variation, direct access penetration into residential and commercial sectors, and energy imbalance costs due to load profile errors.
AEI believes that the Commission should immediately form a load profile evaluation group within the Commission or the CEC. The purpose of the group would be to assess the accuracy of both UDC load profiles and retailer load profiles, for settlement and CTC calculation applications. This group should also regularly talk with the ISO to discuss any irregularities that the ISO may observe with respect to system load errors. If persistent errors recur, an independent review of each retailer's load profiles should be undertaken at the expense of the retailers.
AEI also contends that an ESP should be permitted to estimate its own load profiles as soon as it has sufficient information about its own customers. Allowing the ESPs to estimate their own load profiles will reduce cost-shifting by increasing the settlement accuracy of retailer power generation costs and will also promote innovative rate and marketing programs.
DGS/UC/CSU contend that the majority of the parties in attendance at the workshop indicated a desire to have further proceedings about load profiling take place as soon as possible in 1998.
Calpine et al. contend that the UDCs' proposed schedule is too long. Calpine et al. recommend that a status report on the use of load profiles be prepared by March1, 1998, that hearings be held in April, that a Commission decision issue in June 1998, and that the remaining load profiling issues be implemented by July1, 1998.
ORA agrees with the CEC that workshops should begin as soon as possible to develop an improved load profiling method for 1998. If the workshops cannot develop consensus on an improved approach, ORA recommends that the Commission adopt the equations that ORA presents in Attachment B of its July1, 1997 comments, and that hearings be scheduled in early 1998 to resolve the other load profiling issues.
Edison comments the UDCs' proposal offers a simple and pragmatic approach for implementing load profiling on January1, 1998. Edison contends that the recommendations for expanded load profiles for use on January1, 1998 threaten implementation of direct access for smaller customers. To conduct a hearing to develop new load profiling methodologies is a poor use of scarce resources in the time allotted. Edison recommends that the Commission adopt the UDCs' proposal at this time, and defer any further consideration of load profiling until the first quarter of 1998, at the earliest.
We agree that the Commission needs to revisit a number of different load profiling issues in 1998. However, we do not believe that the UDCs' schedule is the one that should be followed. As discussed above, we plan to move toward the use of dynamic load profiles almost immediately. We will also explore whether the dynamic load profiles should be further segmented. Other issues involving the use of load profiles should also be addressed as expeditiously as possible in 1998.
To assess the effects of load profiling, and to determine how load profiling methodologies and administration can be improved, the Commission needs to become involved in monitoring the use of load profiles for direct access. A substantial part of the data may come from the UDCs, the ISO, the PX and other market participants. To evaluate the type of data that the Commission staff should gather and that market participants should maintain, the Energy Division should hold a workshop with interested parties within 75 days from today's date. At the conclusion of the workshop, the Energy Division shall prepare and file a workshop report with its recommendations. The report shall be filed within 100 days from today's date. Interested parties may file comments on this workshop report within 120 days from today's date. 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 determine how the load profiling methodologies and procedures can be improved.
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