DAWG - Technical Team A

DOD'S PROPOSAL TO PHASE-IN PHYSICAL

DIRECT ACCESS ON A NON-DISCRIMINATORY BASIS

(Alternative 1)


The goal of this procedure is to allocate what might be scarce direct access load opportunities on a non-discriminatory basis so that all classes of customers can participate on an equitable basis and to provide assurance that all available direct access capacity will be fully subscribed and available for direct access by January 1 of each of the phase-in years. With these goals in mind, DOD proposes the following procedure:

1. Each July 1, starting in 1997, and continuing through the phase-in period, customers or their agents will provide a notice to their host utility of their intention to obtain power through direct access. At a minimum, the notice will provide the amount of load (demand and energy) for which the customer or agent seeks direct access, and a breakdown of the load by the FERC Retail Sales Accounts 440 through 446.

Those sales accounts include:

440 Residential Sales

442 Commercial and Industrial Sales

444 Public Street and Highway Lighting

445 Other Sales to Public Authorities (Major Only)

446 Sales to Railroads and Railways (Major Only)

In accordance with the December 20, 1995 Commission Order, initially only blocks of load of 8 MW or larger will be accepted. To prevent agents or customers from requesting capacity in excess of the load than they actually require or represent, the customer or agent must provide sufficient evidence that it, in fact, is representing the customer requesting direct access.

2. The host utility will accumulate the total amount of load requesting direct access by major sales accounts in order to determine if all of the requested direct access load can be accommodated in that year. The total amount of load available for direct access in any year will be broken down into major sales groups according to FERC Retail Sales Accounts 440 through 446, in proportion to the most recent year's breakdown of sales by those sales groups. For example, in 1998, the minimum total amount of load available for direct access in PG&E's service territory is 800 MW (December decision, Page 221). If 30% of PG&E's 1996 sales are commercial and industrial sales, then 240 MW (30% x 800 MW) will be available for commercial and industrial customers to participate in direct access in 1998. Similarly, if 40% of PG&E's 1996 sales are residential sales, then 320 MW (40% x 800 MW) will be available for residential customers to participate in direct access in 1998. The same procedure will be applied to SCE and SDG&E.

If less than the available direct access load in any sales class is initially subscribed, then all customers or their agents will receive notice by August 1 that all of their requested load will be available for direct access starting January of the following year. The remaining available load for a sales class that is not fully subscribed is then released for use by the other classes in proportion to the sales for those classes.

If more than the available direct access load in any sales class is initially subscribed, the load for all customers requesting subscription in that class will be reduced proratably. For example, in the previous example, if, in July 1997, 480 MW of commercial and industrial load requests direct access, when there is only 240 MW available, then the requested load for all customers requesting load availability for direct access will be reduced by 50% (240 MW ) 480 MW = 50%).

All customers or their agents will then be notified on or before August 1 of the amount of their load which will be available for direct access on January 1.

3. On or before October 1, all customers or their agents who have had load accepted for direct access must provide detailed information regarding their alternative power supply arrangements. This information must be in detail sufficient to show that the customer has an alternative arrangement, with whom that customer has the arrangement, evidence that the transmission system arrangements have been considered and evidence that the customer or agent is aware of all required services and the costs associated with the new arrangement (including power supply costs, transmission service costs, ancillary service costs, LDC costs, CTC costs, metering and billing costs, etc.). DOD recommends that a comprehensive form be developed and approved by the CPUC for this purpose. Where contracts are required for the procurement of these services, the customer or agent must provide copies of signed contracts. Confidential information regarding prices need not be disclosed. In addition, the customer must provide estimating scheduling of the power secured for direct access.

Finally, the customer or agent must also provide evidence that it has arranged to secure the proper metering to accommodate the new power supply arrangement.

The purpose of all this disclosure of detailed information is to ensure that all load which has been made available for direct access is actually fully subscribed to and implemented in each of the years of the phase-in.

4. Any load that cannot meet the October 1 requirements is released and the capacity made available to the remaining customers. The capacity will first be released to customers within the sales class on a pro rata basis. If the class cannot use the released direct access capacity then it will be made available to the remaining constrained classes. It will be released among the constrained classes on a sales basis, and within the classes on a pro rata basis.

5. Notice of additional released capacity will be provided to customers on November 1. An acceptance of that additional released capacity for direct access will be made by customers or their agents on or before December 1. This timing will ensure that all available direct access load will be fully subscribed and implemented on January 1 of each year.

6. The block size requirement may have to be adjusted in subsequent years of the phase-in depending upon the responses received in previous years.