Issues are numerous, but time and resources of most parties are finite.
It is not realistic to assume that all semi-relevant issues can be debated in this forum; we have to be selective; many implementation and protocol-related issues will have to be developed later once the basic parameters of the program are established. Development of protocols regarding information flows, etc. should be driven by the requirements of the direct access program, not vice versa.
The report of this Working Group will not be the last word on direct access implementation. The biggest contribution that this Group can make is to address in as much detail as possible the major issues regarding direct access eligibility, aggregation and phase-in.
The broad issues to which, in our opinion, we should be devoting the bulk of our time and attention are as follows:
1. Is a phase-in of direct access necessary? Why or why not?
2. If "no," then proceed to metering and aggregation issues.
3. If "yes," then
a. How many MW in the first year, second year, etc.?
b. How should a limited number of MWs be allocated to customers?
4. Are TOU meters necessary for all classes of direct access customers?
a. Why or why not?
b. Advantages/disadvantages of TOU meter requirement?
c. Load shaping/cost shifting issues.
5. How should aggregation be handled within classes, across classes?
Is any limit needed on the size of the aggregated
group, initially or otherwise?
If the above issues can be fully developed in the Working Group report, we will have produced a useful product. In our view, these are the issues of greatest importance to potential direct access customers which, therefore, deserve in-depth attention of the Group. Once the basic parameters of "customer choice" are determined, the mechanics of how the program will operate will follow.