IV. Workshop Report
The Workshop Reports notes that the agenda for the workshop was derived from a review of the comments on the DAIP, the pro forma tariffs, and service agreements. The Workshop Report also notes that the workshop process made considerable progress toward reaching a consensus on a number of issues.
The DAIP explains that two steps are required to change a consumer's energy supplier from the UDC to an ESP. The first step is for the ESP to enter into an agreement with the UDC which enables the ESP and the UDC to coordinate the provision of basic and additional direct access services to the customer. The second step is for the ESP to submit the direct access service requests (DASRs) to the UDC.
The Workshop Report identified the following issues with respect to the direct access service election process.
· UDCs' requirement for direct access customers to execute individual competition transition charge (CTC) agreements.
· Option to have customers contact UDC to make direct access request.
· Batch processing of DASRs.
· DASR processing criteria and treatment of "deficiencies."
· Partitioning of a meter or single account with multiple meters.
· Notification of former ESP of customer change in ESP.
· Role of UDC in disputes between customer and the ESPs.
· Charges for processing DASRs.
· Standardization of formats for UDCs' tariffs and service agreements.
According to the Workshop Report, a consensus was reached on five issues. The first item is with respect to the UDCs dealing directly with customers who elect direct access. Section 3.4.1 of the joint DAIP states that for initial implementation, all necessary arrangements for direct access must be coordinated between the customer and the ESP. SDG&E and Edison had reserved the option to deal directly with customers who elect direct access. SDG&E and Edison clarified at the workshop that it was their intention to facilitate election of direct access for those customers who choose to contact the UDCs directly for information about switching to a non-UDC provider. The UDCs propose the following consensus language for the joint DAIP:
"UDCs will assist customers requesting Direct Access information or service by providing general information on Direct Access, providing general information on the process for signing up for Direct Access, and providing a list of CPUC approved ESPs if available by the Commission. UDC Direct Access service sign-up must be done through the submittal of a DASR by the customer's chosen ESP as stated in the tariff and the ESP/UDC Agreement. SDG&E and SCE reserve the right to change this practice at a later date."
The second item of consensus pertains to batch processing of DASRs. The UDCs stated that it would be possible to perform batch processing of electronic DASRs. PG&E and Edison appear to require that all DASRs be submitted in electronic form, while SDG&E is willing to accept paper DASRS.
The third item of consensus pertains to DASR processing criteria and how deficient DASRs will be treated. The UDCs provided clarifying information about their processing criteria for DASRs, and how they would define and respond to deficiencies. The UDCs propose the following consensus language as part of the joint DAIP:
"UDCs will generally work towards providing materiality standards for discretionary items in the tariffs, including specific guidelines on DASR submission and rejections, and Customer and ESP defaults."
The fourth item of consensus is with respect to the partitioning of a meter or a single account with multiple meters. The UDCs propose the following consensus language as part of the joint DAIP:
"Utilities will clarify tariff language to explicitly state that a Customer with multiple accounts on a single premises can be served by different ESPs as long as the accounts are not totalized or their energy measurements partitioned."
The last item of consensus about the election process pertains to notifying a former ESP of a change in ESP. The UDCs propose that the UDC will notify the former ESP of a customer's switch to a new ESP. This would not include the initial set up of direct access where one ESP's DASR may replace the DASR of another ESP.
The Workshop Report notes that the parties were unable to reach a consensus on several issues. They were unable to agree on whether a direct access customer must execute individual CTC agreements with the UDC. (See joint DAIP, section 3.4.2.) The Workshop Report recommends that this issue be clarified.
The Workshop Report states that D.97-05-039 allows the ESPs to select one of three billing options for each direct access customer served by an ESP. The first option is utility consolidated billing. Under this option, the utility bills for both the UDC and ESP charges, and presents a single bill to the customer. The second option is ESP consolidated billing, where the ESP bills the customer on a single bill for both the UDC and ESP charges. The third option is separate bills to the customer from the UDC and the ESP.
The workshop addressed four billing related issues. The issues are: (1) how notices and bill inserts will be treated with ESP consolidated billing; (2) the requirement for the billing agent to conform to the meter agents' schedule for reading meters; (3) whether ESPs must be able to provide both consolidated and dual billing; and (4) rate-ready versus bill-ready billing.
On the issue of bill inserts and consolidated billing, a consensus was reached with respect to the use of the billing envelope space. In Attachment 6 of the Workshop Report, revised Rule 23 and 22 of PG&E and Edison, respectively, permit the ESP in a consolidated billing situation to enclose any additional material in its billing envelope at its sole discretion. Agreement regarding the mailing of mandated notices in a consolidated billing scenario was also reached. This is reflected in revised Rule 23 and 22 of Attachment 6 at page 29.
Where meters need to be read manually, the metering and data management agent (MDMA) must be able to determine the schedule for reading meters in order to optimize routes and maximize meter reading efficiencies. This schedule must recognize any billing frequency requirements. Edison believes that there can be some flexibility in changing the billing cycle data, but that is limited by billing system constraints and meter reading limitations. The UDCs propose the following consensus language to the joint DAIP:
"UDCs have limited ability to accommodate customers who wish to change their billing cycle dates. If ESPs develop a criteria on how the utilities may proportion the limited billing capacity to handle a customer's switch to a particular billing day, the UDCs will consider changing some customer billing dates as requested by the ESPs."
Another issue that was raised was whether the ESPs should be required to provide both consolidated and dual billing. Based on the discussion at the workshop, the UDCs offered the following consensus language:
"An ESP doesn't need to have `dual billing' capability. However, if the ESP or UDC consolidated billing service defaults, then the only options available are to take all the ESP's DA customers off DA service altogether, or for the ESP to find another, non-UDC billing agent."
An unresolved issue is whether PG&E should be required to offer bill- ready service on January 1, 1998. Under bill-ready billing, the ESP computes and provides the utility with the ESP's bill that is ready to be incorporated into the consolidated bill the utility presents to its customers. Under rate-ready billing, the ESP provides the utility with its rates for energy, which the utility then applies independently to the usage of the customer, and computes the bill for inclusion in the utility consolidated bill.
PG&E contends that it cannot offer bill-ready service on January 1, 1998 because of limitations imposed by existing billing systems and because of the time frame for implementation of direct access. This would require the ESP to supply rate schedules to PG&E which PG&E will then apply to the customer's usage to compute the ESP's charges for the consolidated bill. SDG&E and Edison will offer bill-ready service under utility consolidated billing. That is, they will accept the ESP's charges in a bill-ready format that requires no computation by the utility.
According to the Workshop Report, the ESPs believe that PG&E should be required to provide the same billing options as Edison and SDG&E. The ESPs argue that if PG&E is not required to do so, this will be a barrier due to the increased cost of communicating customer information using multiple formats. In addition, the ESPs contend that rate-ready billing allows the UDC access to confidential rate information which could be used to the advantage of PG&E's unregulated affiliate.
The workshop participants also agreed that an ESP should not be required to be able to provide all billing options.
The issues addressed at the workshop regarding credit and collections are as follows:
· Partial and prorated payments under UDC consolidated billing, and what happens when there is a disputed bill.
· Delinquent payments prior to switching to direct access.
· Circumstances under which UDCs may disconnect and reconnect distribution service.
· Purchasing of receivables.
With respect to the first issue, the Workshop Reports states that the primary concern of the UDCs is that Public Utilities(PU) Code Section 779.2 prohibits the UDCs from disconnecting service for non-payment of non-utility charges. When there is only a partial payment, this could lead to disconnection of service because the utility charge may not be paid.
If the customer owes an outstanding balance to the UDC, the issue arises as to whether the UDC must be paid before the customer is allowed to switch to direct access. The Workshop Report states that the UDCs appear willing to work collaboratively with ESP representatives to develop a mutually acceptable policy as to which delinquent balances must be settled before a customer is allowed to switch to direct access.
On the issue of disconnection, the UDCs have stated that they will not disconnect service for nonpayment of ESP bills. The ESPs have requested that in such a situation, the UDCs expedite a DASR to transfer the customer back to the UDC from the ESP. The UDCs and the other participants have not reached an agreement on this issue.
PG&E proposes to require the ESPs who select utility consolidated billing to sell their accounts receivable to PG&E. The sale would not be at a negotiated discount, but will instead involve an initial assumed bad debt rate with periodic true-ups to reflect actual uncollectible accounts. PG&E asserts that over a period of time, the money received by the ESP under the purchase of accounts receivable will be the same as under the straight pass-through method proposed by the other utilities.
PG&E contends that purchasing the accounts receivable is necessary because PG&E's current billing system can track only one receivable per customer account. Major system changes would be required to track payments, delinquencies and similar elements of ESP receivables as well as PG&E receivables for the same customer account.
The following metering issues were discussed at the workshop:
· Meter ownership issues related to direct access customers returning to bundled service.
· Whether ESPs may install meters prior to January 1, 1998.
· Conditions regarding the unbundling of metering functions.
· Whether ESPs may provide billing/metering without providing energy service.
· Meter timing issues related to inspection and installation prior to January 1, 1998.
With respect to meter ownership, Section 7.4.2 of the DAIP states that if a direct access customer returns to bundled UDC service, the UDC may either purchase the existing meter or replace it. At the workshop, the UDCs indicated that they will allow direct access customers returning to bundled service to maintain ownership of a meter purchased while receiving direct access service, provided the meter meets Commission-approved standards and the UDCs can safely access and read the meter with its existing system.
Regarding installation of meters prior to January 1, 1998, the workshop participants agreed that once all the criteria, standards, registration and certification procedures, tariffs, and systems infrastructures are approved, obtained, and otherwise in place, an ESP may install a meter for its customers prior to January 1, 1998, as long as the UDC can read the meter with its existing system.
With regards to the tariff references to the metering-related schedules, standards, and equipment or procedures, the workshop participants agree that those should be tied to Commission-approved standards.
The Workshop Report notes that there are a number of unresolved metering issues. One area of disagreement concerns the provisioning by the UDCs of default metering services to the ESPs' direct access customers. The terms and conditions of default metering remain in contention between the ESPs and the UDCs.
Another unresolved issue is whether the transformers behind the meter are part of the meter and subject to the provisions that apply to meters. Edison and SDG&E consider the transformers to be part of the distribution system, and not subject to the meter provisions.
Another concern is over the provisioning of default metering services for direct access customers. Edison proposes that it provide default metering services for direct access customers only if it provides the services as a package. The ESPs oppose the packaging of these services, while ORA contends that the package concept is inconsistent with the Commission's unbundling decision.
The DAIP requires that the ESPs can provide metering and billing only to their direct access customers and that these services can only be selected by a customer through an ESP. Section 7.3.3 of the DAIP provides that the ESPs must agree to assume responsibility for all the functions in the metering service package. The Workshop Report states that the inference is that unless an ESP provides the entire package of metering services, it cannot provide any portion of the package.
Another unresolved issue is whether the ESPs can provide billing or metering functions without having to provide energy service. The UDCs contend that the ESPs must provide energy service to offer billing or metering services. Enron contends that the ESPs should be allowed to provide billing or metering services without having to offer energy service.
Under Section 7.3.2 of the joint DAIP, the ESPs may either purchase the UDC's existing metering equipment, or they may remove or pay the UDC to remove the equipment and install their own. The sell or replace choice is the option of the UDC. The ESPs contend that the sell or replace choice should be at the option of the ESP.
The main issue regarding aggregation is whether a customer can change rate schedules, and how the subsequent calculation of the transmission and distribution charges and the CTC will be calculated. The UDCs believe that customers should not be able to escape the CTC responsibility associated with a particular rate schedule through the aggregation process.
The joint DAIP proposes that certain service fees be implemented. The following service fee issues were discussed at the workshop:
· Timing of implementation of service fees and avoided cost credits.
· Application of direct access service fees that currently apply to UDC service.
· Application of service fees to ESPs vs. direct access customers.
At the workshop, PG&E offered to develop an outline of a compromise concept that would allow the Commission to adopt a workable fee structure effective on January 1, 1998, without limiting the opportunities of parties to take issue with the detail underlying these fees. PG&E provided a draft of this document to the Energy Division following the workshop. This material was included in the Workshop Report as Attachment 4. PG&E's compromise concept proposes to set interim charges that would become effective on either November 1, 1997 or January 1, 1998. A review of these interim charges could take place with the avoided-cost-credit review that is scheduled for later in 1998. If the charges are adjusted by the Commission after that review, a recovery or crediting of the difference would take place.
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