Date: 26 Jul 96 15:39:11 
From: Kaye West/CONPLN/SSC/THD 
To: seancasey 
Subject: Implementation.

THE HOME DEPOT

The Home Depot has 83 number of stores in California.    Our stores are located 
throughout California and are served by all three of California's investor 
owned utilities.

We commend your efforts at developing an implementation process for retail 
competition.  While much of the focus regarding retail competition has seemed 
to be upon generation issues, The Home Depot is especially concerned with the 
how and when we will be able to have choice in electricity suppliers.  The Home 
Depot has been made aware of the comments to be filed by SPURR/REMAC.  These 
comments appear to be very positive step forward in developing the 
implementation procedures for retail choice.
We would like to emphasize three key points for the Implementation Direct 
Access Working Group.  First ,the meter is both the cash register and data 
point for the entire procurement process.  To fully facilitate the ability to 
choose alternative supply options, customers, must have access to their meter 
pulse data.  This access should include the ability to remotely read meters and 
to allow the customer's designated third party supplier to access the meter.  
Without this ability, The Home Depot will be severely constricted in its 
ability to manage its loads and analyze its purchase options.

Second, to implement choice, The Home Depot needs defined procedures and 
standards regarding implementation.  These procedures should be defined so that 
existing utility suppliers cannot claims any type of exclusivity over the 
access to the meter, or the meter's data.  The procedures and standards should 
empower The Home Depot to develop its own procurement systems, while allowing 
the utility to access the data it needs for its operations and to audit the 
accuracy of the data.

Finally, the ability to have retail choice should be based on the customer's 
capacity to participate in a competitive environment, not some arbitrary MW 
allocation or lottery system.  The Home Depot is prepared to make a significant 
commitment to a procurement system so we can participate in retail choice.   
However, the current uncertainty in when and how The Home Depot can participate 
restricts our ability to implement this procurement system.  We strongly 
support the SPURR/REMAC concept that customers who are prepared with a 
procurement system that addresses the increased complexity of choice be allowed 
immediate access to competition.

The Home Depot appreciates this opportunity to share our comments on 
implementation of retail choice in California.  The Home Depot views these 
issues as a key in our ability to enhance the operations of our stores.  While 
compromise is a necessary element of this process, we expect that on the issues 
of access to data the Implementation Direct Access Working Group will 
aggressively move the process beyond the traditional procedures where the 
utility has monopoly control over the meters and the data.  We also expect the 
Direct Access Working Group to develop implementation rules that will allow 
those customers who are prepared for choice, to participate in a supply choice 
market

.