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REVISED (DRAFT) OPINION REGARDING THE LOAD PROFILING WORKSHOPS

Findings of Fact

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. D.97-05-039 contemplates that starting on January 1, 1999, any retail energy service company may provide metering systems for any customer.
38. D.97-05-039 did not address who should supply the meter to a load profile customer.
39. The unbundling of metering services does not really affect customers on load profiles because a load profile customer is likely to remain on a kWh, time-of-use, or demand meter, until the customer chooses to install a meter which meets the standards for direct access metering.
40. 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.
41. If the load profiles do not match actual customer usage, a discrepancy in the UFE will result.
42. 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.
43. The use of dynamic load profiles should help to reduce the amount of UFE.
44. 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.

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