DRA FURTHER VIEWS REGARDING PHASE-IN - JULY 26/96

4.2.1.4 Alternative 4:

Multiple Phase-In DescriptorsAlternatives

4.2.1.1-4.2.1.3 are not necessarily mutually exclusive. Given the geographic variation in billing and network capabilities for the UDC's and other electric supply institutions in conjunction with the uncertainty concerning the geographic distribution of the peak load, annual energy consumption and billing characteristics of the electric customers who will participate in the direct access phase-in, option 4.2.1.4 permits a delay in the determination of the appropriate combination of peak load, annual energy consumption and transactions descriptors until the distribution of characteristics for the direct access phase-in customers has been more clearly specified.

Pros: The advantages of multiple descriptors include: (1) Consistent with maximizing the number and variety of electric customers participating in the direct access phase-in. (2) Explicitly recognizes the variation across the UDC's and other electric supply institutions with respect to their respective billing and network capabilities.

Cons: The disadvantages of multiple descriptors include: (1) Greater planning uncertainty for the UDC's and/or other electric supply institutions due to the delay in determining the appropriate set of descriptors until the characteristics of those electric customers participating in the direct access phase-in are revealed. (2) Possible delay in the commencement date for the initial direct access phase-in.

4.2.2.3

Pros: (3) Consistent with maximizing the variety of electric customers participating in the initial direct access phase-in.

4.2.3.5 Alternative 5: No Customer Participation Rule

IF the electric customer education/information process is properly structured, the electric customer interest revelation process is well planned, implemented and monitored and the potential problem of customer oversubscription is adequately addressed, then there is no need for an additional set of customer participation rules in order to achieve the desired distribution of customer participation in the direct access phase-in across the various classes of electric customers.

Pros: The advantages of no customer participation rule include: (1) The reduction in the cost of the direct access phase-in due to the elimination of redundancy. (2) Consistent with maximizing the number and variety of electric customers participating in the initial direct access phase-in.

Cons: The disadvantages of no customer participation rule option include: (1) Increased performance pressure on the electric customer education/information process. electric customer interest revelation process and oversubscription adjustment process.

4.3.3.4 Alternative 4: Modified First-Come, First-Served with Lottery Tie-Breaker

IF the electric customer education/information process is properly structured and the electric customer interest revelation process is well planned, implemented and monitored, then the first-come, first-served rationing process can achieve any targeted level of fairness provided that a lottery is used when necessary to break ties among electric customers in the first- come, first-served queue.

Pros: The advantages of this rationing plan include: (1) Captures the benefits of both the rationing by queuing and lottery alternatives. (2) Minimizes if not eliminates the downside risks associated with the rationing by queuing or lottery alternatives.

Cons: The disadvantages of this rationing plan include; (1) Increased performance pressure on the electric customer education/information process and the electric customer interest revelation process. (2) Does not maximize the number and variety of electric customers.