DAWG - Technical Team A

DOD'S PROPOSAL TO PHASE-IN PHYSICAL

DIRECT ACCESS ON A NON-DISCRIMINATORY BASIS

(Alternative 2)


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 sufficient evidence that it, in fact, representing the load requesting direct access. This is to prevent agents or customers from requesting capacity in excess of the load then they actually require or represent. Initially, only blocks of load of 8 MW or larger will be accepted from end-use customers or agents (including aggregators) in accordance with the Commission's December 20, 1995 Order. This has the dual benefit of allowing all classes of customers to participate (either through an aggregator or independently) and providing administrative advantages because the utility initially has to deal with fewer entities.

2. The host utility will accumulate the total amount of load requesting direct access in order to determine if all of the requested direct access load can be accommodated in that year.

If less than the total available direct access load is initially subscribed to, 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. Additional requests for direct access will then be allowed in blocks of 5 MW or greater.

If more than the available direct access load is initially subscribed, the load for all customers requesting subscription will be reduced proratably. For example, if, in July 1997, 1600 MW of load requests direct access, when there is only 800 MW available, then the requested load for all customers or agents requesting load availability for direct access will be reduced by 50% (800 MW ) 1600 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 service 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 or agents with 8 MW or larger blocks of power. If those customers or agents cannot use the released capacity, then it will be made available to customers or agents representing loads of 5 MW or larger.

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 load size requirements for the first and second cuts may have to be adjusted in subsequent years of the phase-in depending upon the responses received in previous years.