CMA INPUT ON

PHASE-IN ISSUES


Phase-in schedule:

Several scenarios should be developed, one of which would be "least case" of 800 MW in first year.

Need to have the utilities address in detail:

(a) What are the precise technical barriers to direct access phase-in? How are these barriers being addressed?

(b) Are these barriers created by number of transactions versus MWs involved? Why is a MW limit needed?

(c) Do schedule coordinators simplify the phase-in process?

Assuming that the utilities can demonstrate the need for some phase-in beyond the first year, how much can the 800 MW be expanded in second year, et seq.?

Allocation of Phase-in Volume:

Assuming that some MW limit is adopted, the MWs should be allocated based on actual 1996 kwh consumption by rate schedule (e.g., each rate schedule would be allocated the same percent of phase-in volume as the classes' percent of total kwh consumption in 1996).

An open season should be held. Customers' nominations or expressions of interest would be limited to their 1996 kwh consumption unless the customer joined the system after January 1, 1996. A new customer's allocation would be limited to projected annual use based on the consumption data that does exist. The expression of interest would include a reasonable earnest money deposit or bond which would be forfeited if a customer does not use its allotment (assuming the allotment equals or exceeds a minimum acceptable amount).

If total interest for a rate schedule is less than the phase-in allotment for that rate schedule, all customers would receive their entire request. If interest exceeds phase-in volume for a rate schedule, amounts would br prorated. On the nomination form, customers could elect not to participate if their allotment did not exceed a given minimum. Customers would indicate their chosen minimum on their nomination form. If not all rate schedules had sufficient interest to use their entire allotment, the balance could be allocated to the remaining rate schedules. One way to allocate unused amounts to other rate schedules would be on the basis of unsatisfied demand.

Example:

Rate Schedule % Subscribed % Unsatisfied

A 60 100

B 140 71

C 220 45

D 75 100

E 1 15 87

F 335 30

G 90 100

There would be no proration for rate schedules A, D & G. Schedule F is the most oversubscribed so it would be allotted the residual volume until 45% of its needs are met. Then schedules F&C would be allotted the residual volume until 71% of the requests were met. Then schedules F, C, & B would use the residual volume until 87% of the requests were met.

This method would allow all customers an equal opportunity to participate in direct access. If customers chose not to participate and there is residual volume, that volume is allocated to the customers who desired access, but received the least. Thus, the plan promotes fair and equal access.

Customers who select direct access but whose needs cannot be fully satisfied should have two options for the portion of their load not served by bilateral contracts.

1. Purchase residual load from the UDC.

2. Purchase residual load from a supplier who procures the residual energy from the power exchange.

Thus, if a customer is only awarded 40% of its usage through the phase-in, the customer's supplier could serve the entire load, but would be required to buy 60% from the PX. This way a supplier can serve the full requirements of its customers and customers can deal with only one supplier if they so chose.

Participation in one phase of direct access will have no bearing on participation in future phases. (Customers are not penalized or given preferential treatment for participation in earlier phases.) A customer's allocation of direct access volumes would not be transferrable. The customer must either "use or lose" the allocation.