Docket Clerk
California Public Utilities Commission
505 Van Ness Avenue
San Francisco, California 94102
RE: R.94-04-031/I.94-04-032
Dear Docket Clerk:
Enclosed for filing with the Commission are the original and five copies of the REPLY COMMENTS OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) ON THE SEPTEMBER 30, 1996 COMMENTS ON THE DIRECT ACCESS WORKING GROUP AUGUST 30, 1996 REPORT in the above-referenced proceeding.
We request that a copy of this document be file-stamped and returned for our records. A self-addressed, stamped envelope is enclosed for your convenience.
Your courtesy in this matter is appreciated.
Very truly yours,
Megan Scott-Kakures
MSK:SBW:DOCUMENT.01
Enclosures
cc: All Parties of Record
(U 338-E)
| Order Instituting Rulemaking on the Commission's Proposed Policies Governing Restructuring California's Electric Services Industry and Reforming Regulation. | ))) ) ) |
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Order Instituting Investigation on the Commission's Proposed Policies Governing Restructuring California's Electric Services Industry and Reforming Regulation. | )))))) |
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ANN P. COHN
JAMES M. LEHRER
MEGAN SCOTT-KAKURES
Attorneys for
SOUTHERN CALIFORNIA EDISON COMPANY
2244 Walnut Grove Avenue
Post Office Box 800
Rosemead, California 91770
Telephone: (818) 302-6855
Facsimile: (818) 302-1922
Dated: October 15, 1996
I. "UNBUNDLING" OF UDC DISTRIBUTION FUNCTIONS IS NOT
REQUIRED FOR DIRECT ACCESS AND WOULD JEOPARDIZE ITS TIMELY IMPLEMENTATION
2A. The UDC Must Be Able To Measure And Bill For The Electric
Service It Provides To Its Customers 2B. The Current Proposals
For Distribution Unbundling Do Not Involve True Competition, But
Rather Cherry-Picking Made Possible By Artificial Regulatory "Credits"
6C. The Commission Should Not Jeopardize The Gains From Competition
In Generation By Attempting Also To Unbundle Distribution Services
10II. A PHASE-IN OF DIRECT ACCESS IS NECESSARY 11A. Operational
And Technical Considerations Require That The First Year of Direct
Access Be Limited With A Gradual Phase-In Thereafter 12B. Load
Profiling Must Be Limited To Residential Customers On An Interim
Basis 16C. All Aggregation Should Be Included Within The Final
Phase-In Schedule 17III. PRESENT AFFILIATE RESTRICTIONS ARE SUFFICIENT
18IV. IMPACT OF AB 1890 22A. New Direct Access Issues Raised By
AB 1890 22B. Direct Access Issues Resolved By AB 1890 23V. CONCLUSION
25BEFORE THE PUBLIC UTILITIES COMMISSION OF THE
STATE OF CALIFORNIA
| Order Instituting Rulemaking on the Commission's Proposed Policies Governing Restructuring California's Electric Services Industry and Reforming Regulation. | ))) ) ) |
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Order Instituting Investigation on the Commission's Proposed Policies Governing Restructuring California's Electric Services Industry and Reforming Regulation. | )))))) |
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Southern California Edison Company ("Edison") files these comments in reply to the comments of various parties on direct access filed on September 30, 1996, following the filing of the Direct Access Working Group ("DAWG") Report. Edison itself filed comments jointly with Pacific Gas and Electric Company ("PG&E") on September 30, presenting the two utilities' proposal to give all customers direct access as soon as reasonably possible, considering the need for an orderly and successful transition. Edison will not repeat the details of that proposal except as necessary to address concerns raised by other parties in their September 30 comments./ The Joint Assigned Commissioners' Ruling (the "ACR") of September 27, 1996, also directs the parties to address 11 specific issues in their reply comments. Edison does so in these comments.
The parties raised a number of issues in their opening comments,
most of which Edison and PG&E already addressed in their
opening comments. However, a few issues raised in some of the
comments and at the DAWG Forum require further discussion. The
most important are: (1) unbundling -- the economic advantages
to California consumers of a bundled distribution service and
the need to concentrate present resources on direct access implementation
issues, not unbundling (ACR Issues 9, 10 and 11); (2) phase-in
-- primarily the ISO's and retail market's technological barriers
to complete direct access on January 1, 1998 (ACR Issues 2
and 4); and (3) utility marketing affiliates -- the lack
of need for further restrictions (ACR Issue 8)./
Fundamental to the operation of any business is the ability of the business to measure the commodity or service sold to its customers and to bill for and collect the charges for those services. Just as the grocery store would not permit its competitor to operate the cash register in the checkout line, or the gasoline service station would not permit a competitor to operate the gas pump for its customers, the UDC cannot be required to rely on third-party electric service providers ("ESPs") to measure the electric service the UDC provides to its customers, or to bill and collect for those services. To require otherwise would threaten the commercial viability of the UDC.
The Commission recently has recognized the importance of the UDC role with respect to its distribution functions. In D.96-09-045, issued last month, the Commission stated:
Billing services, call center operations and the utility's
responsiveness to service orders are among the types of customer
services related to the electric distribution system that we intend
to continue to oversee even as generation becomes competitive.
We want to ensure that utilities 'continue to provide quality
distribution services' that do not discriminate against direct
access customers in their service territories./
.. . . [C]ompetition is primarily in generation, not in the
provision of monopoly distribution services. The concerns
raised in this investigation [of service and safety standards]
are related to those elements of the utilities' electric systems
which are monopolistic. (Emphasis added)/
In the same decision, the Commission made the following Finding of Fact:
The portions of the electric system which are subjects of this investigation [including billing services, call center operations and response to service orders] are for the provision of service that is monopolistic in character, likely to remain monopolistic for the foreseeable future, and requires protection from the pressures of competition in the generation sector./
The restructuring legislation explicitly recognizes the fundamental need of the UDC to bill and collect its charges, e.g., for CTC./ The statutory requirement that "the consumer . . . pay . . . directly to the [UDC]" serves an important purpose. It provides assurances for the collection of CTC, which in turn supports the credit status of the rate reduction bonds that are used to provide the 10% rate reduction to residential and small commercial customers under the restructuring legislation.
Moreover, preserving for the UDC its right to meter the services it provides will -- assuming appropriate cost recovery -- encourage utility-wide deployment of real-time metering and communications systems using standardized technologies and protocols. As President Conlon and Commissioner Duque emphasized in their letter of October 4, 1996 to five legislators on this subject, "the most effective policy will encourage the prompt installation of [real-time] meters." Because the economies of scale for real-time metering are very large,/ the UDC is best positioned to achieve the prompt installation of these systems that President Conlon and Commissioner Duque identified as important to implementation of direct access.
Of course, ESPs are free to perform billing and metering functions for the services they provide. They can measure the electricity they sell to their customers (or use metering data provided by the UDC if they so choose). They can bill their customers for the services they provide and collect the appropriate charges (or rely on UDC billing services at a reasonable cost if they so choose). Where retailers have aggregated residential or other customers, those retailers can perform metering and billing for those end-use customers as Edison and PG&E explained in their Opening Comments./ The UDC will bill the retailer, which (among other requirements) will be required to meet creditworthiness standards. The retailer can then bill the end user for appropriate charges.
Thus, electric restructuring will permit the competitive supply of electricity with ESPs and UDCs each free to meter and bill for the services they provide. The UDC will also provide certain other closely related services. For example, the UDC will respond to customer complaints and questions regarding UDC-provided services and will handle collection problems for its bills. Of course, ESPs can handle complaints and collection for the services they provide.
Consistent with preserving these fundamental attributes of the UDC's business, Edison is fully prepared to facilitate competition through restructuring, including opportunities for ESPs. As we show below, however, the current proposals for unbundling of UDC distribution functions were designed to provide cherry-picking opportunities to the ESPs -- not true competition -- and would instead result in protracted regulatory litigation.
The distribution unbundling proposals supported by various parties in the DAWG -- and reflected in a draft Interim Opinion in this Restructuring docket/ -- do not involve competition in the UDC distribution functions. Instead, these parties demand that the Commission determine "credits" to be given to various classes of customers, for various types of distribution services, supposedly representing the UDC's "avoided costs" of having an ESP provide that distribution service. Even aside from the fallacious assumption that the UDC should be required to turn over its cash register to a non-regulated third party not of its choosing, the proposed "credits" are simply artificial regulatory devices benefiting ESPs and lower cost customers at the expense of higher cost customers.
Consider a hypothetical example. Meter reading costs vary widely according to geographic area and other factors. Suppose some meters can be read for 25 cents a month and others for $1.25 a month, with an average cost for that service of 75 cents. Unbundling proponents seek to have the Commission require that the low cost customers, whose meters they would like to read at a cost of 25 cents, be given the average credit of 75 cents on their bills, enabling the ESPs to make a profit of up to 50 cents. Through this adverse selection, the UDC would be left with an obligation to serve only higher cost customers, whose rates would have to be increased as lower cost customers are cherry-picked away by ESPs. This cost-shifting would be an unacceptable result. Not only would it be contrary to sound public policy, but it would undermine the rate freeze implemented by the Commission and AB 1890./ Indeed, the restructuring legislation appears to prevent the cost-shifting and differential rates for distribution services that would result from the proposed unbundling of distribution functions./
The current unbundling proposals also would require complex and burdensome regulatory proceedings to determine these various distribution service credits. The greater the efforts to limit cherry-picking by defining additional customer groups for each distribution service, the more complexity would be added to the regulatory process. Nor would this be a one-time burden; rather, the regulatory credits would need to be revised over time as costs, technology and markets change. The lessons of the BRPU experience and QF Standard Offer pricing -- where the Commission set prices by "proxy" methods which reached 20 cents/kWh and $200/kWyear -- amply demonstrate the hazard of setting artificial prices through the regulatory process.
The distribution unbundling proposed to this Commission is not competition at all. In a competitive market, when ESPs attempt to cherry-pick low cost customers, the UDC could meet the competition by reducing its rates for those customers. For example, if Southwest Airlines offers a low price for a particular route, the competing airlines on that route can match that price. That is not, of course, what the ESPs have in mind here. They are hoping that the UDC would be prevented from responding to their cherry-picking efforts and that they would be free to pocket the difference between the regulatory credit and the cost of serving the customer.
The proposals for distribution unbundling are efforts to ensure profits for suppliers, not efforts to ensure that consumers obtain the maximum benefit from electric restructuring. The criticism of suppliers directed at this Commission's core aggregation program in the gas industry demonstrates this point. The basis of the complaint is that gas prices have been reduced so successfully by competition in the commodity market that aggregators cannot make profits marketing to residential customers. That complaint simply shows the success of the competitive market in gas procurement, as this Commission has recognized./ Creating subsidies, as sought by the unbundling proponents, does not benefit consumers; it only raises customers' costs.
Edison recognizes that UDC costs will be affected by restructuring in a variety of ways. Some costs may decrease as a result of competition and new contracts, and others will increase (for example, as a result of increases in customer confusion, call volume to the UDC, billing inquiries, settlement complexity, and market coordination requirements). At best, the magnitude of "avoided costs", if any, for particular areas of distribution unbundling -- such as metering and billing would be quite small, because the UDC must continue to perform those functions for the electric services it provides.
Moreover, these costs are not a large portion of the consumer's bill. For example, metering experts ITRON and Cellnet both suggest in their opening comments that the average cost of meter reading is $1 per month or less, per residential customer./ Thus, any possible savings from unbundling metering reading services would be a small fraction of this $1 per month -- minimal when compared to Edison's average residential customer bill of approximately $65./ Allowing each ESP to install its own metering equipment could well impede competition in the economically far more significant generation market, if consumers face additional cost to switch to lower-cost generation supply.
Changes in UDC costs not otherwise addressed in appropriate Restructuring proceedings may be addressed in the PBR process. Cost increases and decreases can be addressed as part of the "true-up" of the PBR revenue requirement -- a less burdensome and more appropriate process than the complex regulatory proceedings required to establish "avoided cost" credits as requested by unbundling proponents.
Proposals to unbundle metering and billing services by January 1, 1998 seriously threaten the orderly implementation of direct access. The metering and billing functions are at the heart of the complex settlement process and other procedures that will have to be established, verified, and phased-in on an ambitious schedule. It would be reckless to threaten the implementation of direct access -- itself a monumental task -- at the same time that critical settlement functions such as metering and billing are being dismantled and opened to experimentation.
The experience of the U.K. electric industry is particularly instructive. In April 1994, the competitive electric supply market in the U.K. was extended from 5,000 very large customers (maximum demand above 1MW) to 50,000 large customers (maximum demand above 100 kW). At the same time there was an attempt to unbundle metering and data collection services. The effort to introduce so many changes at once led to chaos in the metering, settlement and billing functions. An Energy Information Centre poll in July 1995 found that 73% of consumers had experienced billing problems in the previous year, with 53% claiming that those problems were still unresolved./ Some customers' bills were 10 to 100 times above actual consumption./ The Pool Auditor determined that one of the fundamental causes of the chaos that ensued in 1994 was "attempting to introduce too many changes at the same time, in what amounted to a massive step change" in the system./
It is imperative that the Commission implement direct access in a manner that builds public confidence that the competitive electric supply market will work smoothly and effectively. Public confidence in electric restructuring would be eroded by serious failures such as system interruption, data bottlenecks and inaccurate billing.
Proposals for unbundling also present great risk of customer exploitation
and marketing fraud, which are of significant concern to the Legislature
and the CPUC. Experience in the telecommunications industry shows
the extent to which unscrupulous marketers can take advantage
of customer confusion and lack of information. Effective enforcement,
penalty and audit systems will be needed to ensure consumer protection
and system integrity in connection with distribution service unbundling,
especially for a vital commodity such as electric service. Unbundling
distribution functions will greatly increase the opportunity for
fraud on consumers and will undermine the important goal of consumer
protection.
A number of parties object to a phase-in period, claiming -- without any substantial basis -- that no technological barriers exist to complete access on January 1, 1998, and the ACR poses questions as to what operational and technological considerations must be considered in implementing direct access. (Issues 2 and 4). However, it is impossible, before implementation begins, to identify the specific systems problems which may arise from such a new and massive project as the ISO, PX and new market structure represent. Therefore, Edison continues to support a phase-in of direct access, with a limited initial year program to test and validate essential hardware and software systems, and a rolling monthly phase-in thereafter, subject to ISO and CPUC adjustment based on systems performance and consumer protection objectives.
The reliable and efficient operation of the new market structure depends upon the seamless integration of a complex array of hardware and software systems These systems must support the operational requirements of the integrated electric power system while in parallel facilitating the underlying commercial transactions occurring in the marketplace. Figure 1 illustrates the information and communications requirements under the new market structure, while Figure 2 shows the functional roles and responsibilities of the various market participants.
As these figures illustrate, the market structure operates like a food chain, with each element of the market dependent on the next to ensure successful operation. The ability of the ISO to perform scheduling and settlement functions is impaired if any market participant (such as a scheduling coordinator or a retailer) fails to perform its key functions.
Throughout the DAWG process, the debate over phase-in schedule properly has centered around the capabilities of the wholesale market structure, the ISO and Power Exchange. While these remain key issues, it is the metering and communications systems, along with the necessary requirements to settle mismatches of generation and load in a timely and efficient manner, within the retail market that present the largest unknown in terms of the performance of the new market structure. The technical requirements and protocols for interacting with the ISO and Power Exchange have not been finalized. As a result, the metering and communications requirements for the retail market are not well defined and the responsibility for developing the necessary systems has not been established. These retail market systems must be developed, implemented, and tested before the market can operate successfully. It was failures of these retail market structure systems that brought the UK competitive electricity market to a state of near chaos following its start up in April 1994.
The development and implementation of the ISO and the Power Exchange is an unprecedented undertaking. No other state or country in the world has attempted to implement a market structure as sophisticated and complex as that mandated by this Commission and the Legislature. The requirement that we simultaneously implement direct access compounds the complexity involved and makes the challenge all the more difficult. In Edison's view, it simply does not make sense to suggest there would be no phase-in period for direct access. Opening up the entire market to direct access at the same time would leave no margin for error and would, frankly, create the potential for a calamitous failure.
Edison believes that common sense supports the concept of a limited initial year program. We need the experience of that initial year to validate the performance of the essential systems, and to make corrections and adjustments as necessary, before proceeding with large scale implementation of direct access. Systems development for the Power Exchange and the ISO are proceeding on the assumption that a phase-in period will occur./ Furthermore, the Commission should not ignore that all customers will have the ability to enter into "contract for differences" types of arrangements beginning January 1, 1998. Although CFD's may not be a complete substitute for some customers during a constrained phase-in period, they do provide opportunities for all to participate in the new market structure at the beginning.
Edison offers this recommendation based on its considerable experience in the areas of electric system operations and with metering and communications systems. However, ultimate responsibility for these decisions regarding reliability rests with the Commission. The Commission can, of course, choose to ignore our recommendation and determine that safety and reliability can be maintained and consumers can be provided adequate protection and education even while directing the utilities to make direct access available to the entire market at one time. In that event, Edison will do its best to achieve successful immediate direct access, but we have serious doubts concerning the systems consequences.
For residential customers, the availability of direct access would be limited if immediate installation of interval meters were required. The Commission should allow the interim use of load profiles for residential customers, under the following conditions:
Several parties suggest that small commercial customers should be included with residential in the interim use of load profiling and other parties assert that all customers can be on load profiles, based on their specific SIC codes. However, beyond the residential class, the problems with the use of load profiles become so significant that their use cannot be justified, even on an interim basis. Because of much broader diversity in usage patterns among non-residential customers, extending load profiles to them will seriously compromise settlement accuracy and lead to cost shifting. For example, a 24-hour retailer would have a different profile than a retailer only open from 10 to 10, and a manufacturer with one shift would have a different profile from a manufacturer with two shifts. Further, the use of load profiles would create an opportunity for firms to misrepresent their business sector in order to gain the advantage of a more favorable load profile, and would force the UDC into a policeman role in order to detect and prevent this form of fraud.
In the ACR, Issue 7 asks whether specific customer groups or customers within specific geographic areas should be given the opportunity to choose direct access outside of any adopted phase-in schedule. Specific customer groups should not be allowed to participate in direct access outside the phase-in schedule -- whether through pilot programs before direct access begins, aggregation beyond the 1800 MW limit on January 1, 1998, or aggregation beyond the ISO/CPUC-imposed phase-in limits in 1999 and thereafter. This would be contrary to the very purpose of a phase-in, which is to limit participation in direct access until it can be demonstrated that the new market can operate efficiently and reliably.
Furthermore, any approach which involuntarily aggregates
customers according to geography, if that is contemplated by Issue
7, appears contrary to the aggregation requirements set forth
in AB 1890, which requires that each customer provide positive
written declaration of its desire to participate in an aggregation
arrangement (Section 366 (a)).
The goal of maximizing customer choice so as to enable cost savings requires that the nonutility affiliates or subsidiaries of regulated California energy utilities continue to be allowed to compete throughout the state, regardless of the service territory boundaries of the utility with which they are related (ACR Issue 8). The various nonutility affiliates of the investor-owned energy utilities operate in robust unregulated markets, populated by a myriad of competitors. There is no need to restrict competition and thereby artificially induce reduced consumer choice and/or higher prices. In fact, such actions would be the antithesis of the very market-driven philosophy which the Commission has increasingly advocated./ Rather, the appropriate role for the Commission in this regard would seem to be that which it has filled long and well: the prevention of improper cross-subsidies between utilities and their affiliates, and the resulting assurance of ratepayer indifference to the existence of such affiliates.
Edison has had a comprehensive set of Commission-mandated rules for affiliate transactions in place since 1988./ These rules govern virtually every conceivable aspect of utility-affiliate relationships, including: (1) the provision of goods, services, and tangible or intellectual property; (2) extensive periodic and special reporting requirements for all transactions; (3) the protection of the financial and operational integrity of the utility; (4) the movement of utility personnel; and (5) the use of the utility's name and reputation.
Furthermore, the Commission took the additional step in 1992 of issuing Interim Reporting Requirements for affiliate transactions which supplement those which were already in place for Edison./ Finally, the Commission regularly exercises its duties and rights under Public Utilities Code Sections 314(a), 314(b) and 314.5 to audit the books and records of the utilities under its jurisdiction, including an examination of transactions with affiliates.
Contrary to the assertion made by the "Joint Parties" (the Office of Ratepayer Advocates, Eastern Pacific and Utility Partnership Solutions) that ". . . Edison's annual affiliate transaction reports have never been audited,"/ the Commission has, in fact, audited not only Edison's reported transactions with affiliates, but also audited the full spectrum of Edison's affiliate transaction polices and its compliance with them. The Commission's 1992 audit of Edison's transactions with nonutility affiliates, conducted by a nationally-recognized management consulting firm selected and supervised by the Commission's staff, cost over $600,000 to perform, and involved 9 months of investigation, more than 20,000 pages of data request responses, and over 100 interviews of affiliate and utility personnel. It is noteworthy that the Commission's auditors found that,
Overall, the PGACT [the Policies and Guidelines for Affiliated Company Transactions - see footnote 14] is a valuable tool for ensuring ratepayer indifference to affiliate operations. It is the most detailed and comprehensive set of guidelines that M&A has reviewed and is being studied in other states as a possible model./
The auditors concluded that:
Edison's ratepayers have not been measurably affected by the formation or operation of the nonutility subsidiaries, nor are any future negative impacts foreseen. Rigorous financial separation has effectively diminished possible cost of capital impacts, and utility obligations and customer service levels have been unaffected. Sound procedures effectively limit any unfair transfer of human capital and provide for the equitable distribution of personnel-related costs./
It has been alleged by some that nonutility affiliates of the utility might have an unfair competitive advantage if they are allowed to conduct free-market business within the utility's territory because of an "intangible" benefit which stems from the good name and reputation of the affiliate./ However, in approving the holding company structure, the Commission found that "intangible benefits, to the extent that they exist at all, have never been reflected in rates and have never imposed any cost to utility customers,"/ and stated:
The name and reputation of a utility is not an asset to which ratepayers have a claim. Indeed, the Commission has never included good will in the rate base of a utility for ratemaking purposes. It follows that ratepayers have never had to pay through rates a return on the value of good will. Ratepayers have paid nothing for the enhancement of the utility's name and reputation. Those have been built by the management of the utility if they are of any value./
Likewise, the employment of prior Edison employees by Edison Source does not convey an advantage by the sharing of "privileged customer information," as alleged by New Energy Ventures ("NEV"). Edison employees who resign from the utility and seek employment with a nonutility affiliate are subject to numerous restrictions not imposed upon those who go to work for unaffiliated firms such as NEV, as some have. For example, they must sign non-disclosure agreements, and their files (both paper and computerized) are thoroughly reviewed to ensure that no non-public utility information (including customer data and other proprietary or confidential information) is taken to a nonutility affiliate. Edison's position on the transfer of non-public customer information of any sort is clear, unequivocal, and has been stated numerous times in Commission proceedings and other forums: no such customer data will be provided to third parties, including nonutility affiliates, without customer consent. Data is made available to all parties under identical terms and conditions.
There is simply no evidence to indicate that the Commission's existing rules for affiliate transactions are in any way inadequate to prevent improper subsidies between Southern California Edison and its affiliates. To the contrary, there is a nine-year documented track record which shows that the rules work, and work well. In the absence of any evidence of real or potential subsidies, the only restrictions that reasonably apply to nonutility affiliates in their dealings with customers (in or out of the utility's service territory) are those laws of trade and commerce that apply to all competitors in open markets. The remedies available to all parties for violation of such laws by competitors are obvious, well-known, and require no action by the Commission.
To restrain competition by limiting the markets in which affiliates
can operate is simply unnecessary and counter-productive. The
most ardent advocates of such limitations are likely to be the
handful of firms (such as NEV and Eastern Pacific), that fear
competing against such affiliates on a truly level playing field,
and seek to exclude them for their own gains.
Issue No. 1 of the ACR asks about the impact of AB 1890 on the DAWG issues. Edison interprets AB 1890 as generally affirming the broad elements of the restructuring plan advanced by the Commission in its December 1995 Policy Decision. The legislation is also consistent with our company's fundamental restructuring objectives: (1) Equity - for all customers, large and small; (2) Opportunity - to compete on a level playing field; and (3) Cost recovery - of reasonable investments made as part of utility's franchise service obligations.
It is clear from the above list that most of the major issues raised in the DAWG Report still need resolution by the Commission. That resolution must come quickly for the parties to begin the work necessary for implementation of direct access and must focus on what is required prior to January 1, 1998 -- a plan for a gradual phase-in with attendant consumer education. Any attempt to unbundle distribution functions or require immediate direct access for the entire market opens the door to fraud against consumers, systems failures and protracted litigation. The Commission must concentrate on building public confidence that the new electric market will operate smoothly, without impairment of reliability and safety of delivery, rather than on hurling the entire system immediately into the unknown.
Respectfully submitted,
ANN P. COHN JAMES M. LEHRER MEGAN SCOTT-KAKURES
| By: | Megan Scott-Kakures |
Attorneys for
SOUTHERN CALIFORNIA EDISON COMPANY
2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California
91770
Telephone: (818) 302-6855
Dated: October 15, 1996
I hereby certify that, pursuant to the Commission's Rules of Practice and Procedure, I have this day served a true copy of REPLY COMMENTS OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) ON THE SEPTEMBER 30, 1996 COMMENTS ON THE DIRECT ACCESS WORKING GROUP AUGUST 30, 1996 REPORT on all parties identified on the attached service list. Service was effected by means indicated below:
Placing the copies in properly addressed sealed envelopes and depositing such envelopes in the United States mail with firstclass postage prepaid (Via First Class Mail);
Placing the copies in sealed envelopes and causing such envelopes to be delivered by hand to the offices of each addressee (Via Courier);
Transmitting the copies via facsimile, modem, or other electronic means (Via Electronic Means).
Executed this 15th day of October, 1996, at Rosemead, California.
______________________________________________
Megan Scott-Kakures
Attorney
SOUTHERN CALIFORNIA EDISON COMPANY
2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California
91770