From:  Chris S. King[SMTP:chrisk@cellnet.com]
Sent:  Monday, September 23, 1996 2:16 PM
Subject:  Position Paper, Team D

CellNet would like to present the following position paper at the DAWG   
Team D meeting at LAX on September 26:


               Position Paper
          Nondiscriminatory Access
                   by
          CellNet Data Systems, Inc.

Principle:

It is a generally accepted principle that consumers should have
non-discriminatory access to choice of electric suppliers in a Direct
Access environment. Specifically, the California Legislature, in AB-1890,
stated: "...it is essential to... Provide customers with open,
nondiscriminatory, and comparable access to transmission and distribution
services."

Position:

CellNet asserts that it is not possible to have nondiscriminatory access to
distribution services without customer access to low-cost hourly metering.
This is because customers without hourly metering will not have choice of
pricing options, such as time-of-use or real-time pricing, that marketers
plan to make available to large customers. Customers lacking such metering
will have no access to the savings available by shifting load to better
match the hourly pricing set in the state power pool, which will determine
market prices for energy.

CellNet proposes that the Commission define "nondiscriminatory access" so
as to include nondiscriminatory access to low cost hourly metering. The
Commission should take steps to ensure that low-cost hourly metering is
available to any customer desiring it. One option is the provision of
universal hourly metering capability by the UDC, with the costs offset,   
to the extent possible, by the operating savings in meter reading and
distribution operations realized by the UDC. In other states, utilities
have deployed on a widespread basis technology  that is capable of
supporting hourly metering at minimal incremental cost. They have   
deployed the technology at zero net cost to ratepayers.

Pros:

1.  Consumers receive nondiscriminatory access to retail energy pricing   
options.

2.  Commission leadership can result in cost-effective hourly metering   
that could otherwise be cost prohibitive for most electricity consumers.

3.  Power marketers and ESCOs will have equal capability to develop and
sell electricity pricing options to all consumers

4.  Hourly metering results in the "triple benefits" of restructuring
foreseen by the CPUC: cost reduction for any customer who can shift load,
deferral of new peaking generation, and more productive use of existing
generating plant.

Cons:

There are no apparent cons to nondiscriminatory access to hourly   
metering, provided the metering is cost-effective.

Chris S. King
CellNet Data Systems, Inc.




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