DRAFT OF SECTION 18.2 OF DAWG REPORT

BY: DAN L. CARROLL (Implementation Team, representing CIU)

DATE: JULY 22, 1985

18.2 Oversight of Implementation

18.2.1 CPUC Monitoring Direct Access.

Upon implementation of direct access, whether through a phase-in process or universal availability as of January 1, 1998, the Commission must monitor implementation for a number of reasons. These include efforts to ensure that the Implementation Plan is properly followed; assessment of whether all the systems put into place as part of implementation are working properly and adequately; determination whether market participants are conducting themselves appropriately in accordance with the Policy Decision and the Implementation Plan; and, assuming a phase-in, assessment of the next steps in and total necessary length of the phase-in.

The Direct Access Working Group therefore suggests that the Commission act well before January 1, 1998, to establish a monitoring apparatus to advance these and any other monitoring goals which other stakeholders and the Commission may perceive. Whatever the form of that monitoring apparatus, we suggest that the Commission issue a status report regarding implementation no less frequently than every six months. Such a report should be followed by a public comment period, for stakeholders to state their agreement or disagreement with the Commission's assessment of implementation activities.

18.2.2 Verification That Phase-in Is On Track.

As addressed in Section 18.2.1, one of the primary reasons for a monitoring apparatus is to verify that a phase-in, if it occurs, is on track. The Commission must carefully monitor all implementation activities, especially during the first year of any phase-in, to determine whether its overall goal of making direct access universally available to electricity consumers in California on an expeditious schedule is being advanced.

18.2.2.1 Speed-Ups To Accelerate Phase-in.

Depending upon what the Commission determines through its monitoring program, it may wish to implement mechanisms to accelerate the phase-in. For example, if the various systems established to operate the ISO and PX, and to conduct billing activities, are not taxed by initial subscription, the Commission may wish to broaden the availability of direct access before the next increase scheduled under the Implementation Plan. The Commission may also wish to suggest changes in practice or procedure which would streamline customer participation.

18.2.2.2 Slow Downs to Adjust to Problems.

The Commission's monitoring program may lead to the conclusion that direct access implementation is not proceeding according to the Implementation Plan. In that circumstance, the Commission may wish to assess whether steps should be taken to decelerate the implementation of direct access. The Direct Access Working Group does not conclude, however, that any such reduction in the pace of implementation should include interrupting direct access to customers already receiving it, other than as may already be provided in the Implementation Plan. Instead, any necessary reduction in the pace of implementation should be addressed to the number and speed of future customers joining the direct access customer pool.

Besides impact on number of customers involved, the Commission may also be able to determine technological adjustments which can be made to decrease the pace of direct access implementation, assuming that is necessary.