Draft Position Statement by

CPUC's Division of Ratepayer Advocates

Issue - Obligation to Serve

July 2, 1996


The following are DRA's proposals on the issue of Obligation to Serve for the DAWG groups "B" and "D", to be presented at the "D" meeting on July 11, 1996:

1. The UDC will have the obligation to connect customers to the distribution system at fair and reasonable rates, subject to line extension and other rules that may apply.

2. The UDC will have the obligation to deliver energy from the competing central and distributed generators to customers.

3. The UDC will not be the provider of last resort of energy or ancillary services to direct access customers.

4. The UDC will not have an obligation to provide metering, billing or other competitive functions to direct access customers or customers with contracts for differences.

5. The UDC will not have an obligation to provide any competitive customer service such as energy efficiency, load dispatch, power quality to any customer.

6. The UDC will have the obligation to connect central and distributed generators to the transmission or distribution system at fair and reasonable rates, subject to line extension and other rules that may apply.

7. The UDC will have the obligation to provide open, non discriminatory transmission delivery service to all generators and retail providers based on the comparability principle.

8. The UDCs will have the obligation to provide open, non discriminatory access to distribution to all retail competitors and distributed generators based on the comparability principle, so that those competitors can reach customers.

The UDCs will have the obligation to expand distribution facilities to accommodate competing providers in their efforts to reach customers. The UDCs and their affiliates will not substitute their own distributed generation for T&D upgrades or expansion.

PROS: Promotes competition in generation. Promotes customer choice.

CONS: None identified.