A. Sub-Committee Priority
I agree that the first priority for Group A deliberations should
be phase-in and metering.
B. Phase-In and Supply Inequity
If participation is on some constrained basis, i.e. a phase-in,
consideration must be given to the problem of lowest cost supply
contracts being captured by those in the first wave of participation.
If participation is on a first come-first served basis, the market
will favor those ready to participate early (cf. Ed Yates's remarks);
and no management/preservation of supply should be needed.
C. Pilot Projects
The role of the DAWG and its sub-groups should not be to approve
pilot projects. It may be useful for these groups to prepare topics
for pilot projects. The DAWG in its 8-30-96 report should adopt
as a policy position that some elements of the ultimate implementation
plan should be tested beforehand. To assume that a plan, even
one that is limited or phased in, will emerge as a successful
operation because of a CPUC fiat is a bad assumption. The
DAWG may have a role in suggesting criteria for approval of project
proposals submitted to the utilities. I am unable to attend the
6/7/96 meeting of the DAWG but the presentations regarding pilot
projects in Illinois and New Hampshire may be helpful. In answer
to Sean Casey's question, our position is that approval of a pilot
project by the CPUC implies an order to the parties.
D. MW Load as a Cap for Aggregations
If the proposed cap is 8MW for an aggregation, it would be of
interest to know how that number was contrived. Are there other
ways of defining customers that would make up an aggregation like
that? If 8MW is the threshold for an individual customer, does
that include one customer, e.g. Robinsons-May, with multiple meters
or is Robinsons-May an aggregation? What kind of customer has
one meter that uses more that 8MW?
E. Metering
The 6/7/96 meeting might be instructive on the need for metering.
Our position has been that a consumption profile would be a basis
for assessing time-of-use rates. As Mike Jaske pointed out, the
profile would be adjusted on a continual basis from the on-going
generation of data by the meters still in place which were used
to establish the profile in the first place.
F. Responses to Keith McCrea's Memo
1. A phase-in is not required. The economics of customers
of our class as well as residential consumers suggests that only
when aggregated do they have any appeal to marketers. There are
simply not that many aggregated customers who would be ready by
1/1/98.
4. TOU meters are not necessary. See E. Metering
above.
5. I am unsure what this question means.
G. Considerations Influencing Phasing of Direct Access
Kudos to Mike Jaske and Ed Yates for a comprehensive review.
II.B.1. Carefully established conditions under which aggregations, i.e. our customer class (cf.F.1 above) could participate should insure successful implementation.
2. Does not this imply pilot projects?
III.C. The 100,000 customer limitation on billing creates a real limitation if a customer equals a meter. Los Angeles Unified School District, for example, probably has 10,000 meters alone. This limitation effectively precludes application of the 8MW limit.