DIRECT ACCESS WORKING GROUPTEXT FOR DRAFT REPORT ON PHASE-IN AND LOAD PROFILES

Date: July 24, 1996

4.2.3 Representation from All Customer Classes All customer groups are to participate in direct access at the beginning of the program. Nevertheless, there could be a problem with customer classes that are very small, in terms of kWh sales (i.e.,) usage, maximum demand, or number of customers. Two such small classes are street lighting and traffic signals. Street lighting's energy sales are less than one percent of an IOU's total system sales. Energy sales for traffic signals are also less than one percent. In fact, the combined sales of street lights and traffic signals is approximately one percent of the total system sales for each IOU. In terms of maximum demand and number of customers, street light's and traffic control signals' shares are even smaller. So, any phase-in that is based on the proportional share of energy usage, number of customers, or maximum demand may, in effect, restrict the participation of traffic signals and street lighting customers, which are local governments. For instance, street lighting's energy sales are forecasted to be 0.7% of PG&E's total system sales in 1996. Using the 800 MW available for direct access in 1998 for PG&E, street light's share would be 5.6 MW, proportional to energy usage. Street lights' load would, however, have to be aggregated, and its share would not equal the 8.0 MW aggregation limit. Under these assumptions, street lighting could not participate in the first year of the direct access program for PG&E. The other difficulty is the definition of a customer with regards to street lighting and traffic signals. From the perspective of a municipality, the city or county sees itself as one customer. However, there may be many separate billing accounts for street lighting and traffic signals as well as other electric uses. Besides, an account could be for one street light or hundreds. So, from the utility's viewpoint, a city is not one customer, but many customers. To insure that street lighting and traffic signals have the opportunity of participating in direct access there should be no MW limit to aggregation. Street lights and traffic signals should be allowed to aggregate in any form. As an alternative to this recommendation, there could be a specific reservation set-aside for street lighting and traffic signals.

4.2.6.2 Load Profiles for Small Customers In its policy decision the Commission ordered that all customer groups should have the opportunity of participating in direct access at the beginning. At the same time the Commission adopted a five-year plan to install RTP or TOU meters for customers other than those within the domestic, GS-1, and TC-1 customer groups. The decision was silent with regards to metering street lights. There is a special problem for street lighting. Almost all street lights are unmetered today. They are charged a flat rate for energy. Energy usage is based on manufacturers' data on lamp and ballast demand and hours of operation. This data is reviewed in each utility's general rate case. There is common agreement among utilities and street light customers on kWh usage and demand for the myriad of lamp-types in California. Most importantly, there is already a known load profile for street lighting. Street light's have a flat load shape. A street light comes on at dusk, stays on at a basically constant load during the night, and goes off at dawn. So, load profiles can be used for street lighting, and they will be accurate, reflecting actual usage. There is no need to require interval meter and communication systems for street lighting. Traffic signals would be another good load profile candidate. They operate 24 hours a day. All signals basically operate in the same manner. They have a high load factor, more than 90%. Load profiles would be viable substitutes for hourly interval metering for street lights and traffic signals. Load forecasting for street lights and traffic signals is non-controversial and is performed in the utilities' general rate cases. Load data is readily available. It would be relatively simple and straightforward to assign usage to each hour of the day. Most importantly, the use of load profiles for street lights and traffic signals would not lead to cost-shifting, and, moreover, the two classes are quite small less than one percent of a utility's total revenues. In conclusion, there should be no interval metering required for street lights and traffic control signals.

4.5 Specific Phase-in Proposals Direct access should be open to all street lighting and traffic signals customers. No phase-in is necessary. Accurate load profiles exist for the two classes, so there is no need for interval meters. Local governments, which are responsible for street lighting and traffic signals, are aware of electric restructuring and are presumed knowledgeable about direct access and would be able to make a rational customer choice. By opening up these two classes to direct access, the Commission could see what interest there is in direct access from small customers. Moreover, due to their small loads one percent of total system load there would be relative little risk to an IOU.

Prepared by Reed V. SchmidtBartle Wells Associates, July 24, 1996Telephone: 415/775-3113Fax: 415/775-4123e-mail: bwa@slip.netOn behalf of the California City-County Street Light Association