---------- Forwarded message ----------
Date: Thu, 27 Jun 1996 16:11:44 EDT
From: George M. Samaniego 
To: seancasey@cpuc.ca.gov
Subject: DAWG TEAM A: PHASE-IN LIMITATIONS - For DRA Web Site


Please post on the DAWG web site.  Thanks.


DAWG TEAM A:  PHASE-IN LIMITATIONS


Proposition:  Any restrictions on implementing full Direct Access or Virtual
Direct Access should be based on technology limitations.  Such limitations
should based upon the number of feasible transactions, not a megawatt
limitation.  An implication of this is that pro-rata allocation of direct
access quantities across customers makes no sense.


Argument For:

The reason for limiting direct access during a phase-in derives from the
technical inability to manage the number of transactions.  Utility billing
systems today are incapable of handling several hundreds of thousands of
transactions on an hourly basis.  However, this has nothing to do with the size
of the customer in terms of load.  The availability of customer choice should
be based upon the number of transactions, not the amount of load.

As an example, San Diego Gas and Electric Company has been ordered to provide
200 MW of direct access.  Theoretically, a single customer of SDG&E could
account for that total.  The transactions would have to be tracked manually in
the billing process, but this would be manageable for one customer.  This
demand on the billing system is no different than if a single family
residential unit had the same service.  200 MW of residential load would
require a large number of people to manually track the tens of thousands of
transactions.

Utilities should provide their best estimates of transaction based
capabilities of their systems, and that should form the floor for the initial
phase of direct access.  If the number is 50,000 transactions, then that is the
corresponding number of customers to target for 1/1/98.

In this construct there is no basis for a pro rationing of load.  A meter is
either taking UDC service or not taking UDC service.  Allocation of
transactions among multi-site entities may require a form of rationing.



Argument Against:

The CPUC Policy decision explicitly adopted a MW limitation for Direct Access
eligibility in 1998.  This is precisely the schedule adopted in the Memorandum
of Understanding.  There is no reason to go beyond the CPUC Order at this time.

Further, while a transaction based system may have some merit, increasing the
number of transactions increases the likelihood that the initial phase will
have serious difficulties and thereby jeopardize the entire program.









dawgamtr.doc/mmm/SDG&E/6-27-96

----------------------------------------------------------
George M. Samaniego - Distribution Management & Strategies
Principal Engineer, X8266, PINS SAMANIEG, Mail CP5203A