To: Jim Price, DRA
From: Toby Tyler, PG&E
Re: Possible Solutions Concerning Load Profiling (DAWG B, 6/3/96)
Date: July 5, 1996

Jim:

Many thanks for your thoughtful paper on load profiling.  I'd like to take
this opportunity to offer some belated comments on PG&E's behalf.
First, I agree, in concept, that if we are to proceed with load profiling
as a means of enhancing consumer choice, stratifying load profiles within
customer classes represents a desirable goal.  Where customer load
patterns differ in a meaningful and identifiable way, we ought to work
toward developing profiles that capture these differences.  But I see this
as unworkable in the near-term for a variety of reasons.

Unbundling our current rates will be litigious and complex enough that
splitting apart rate schedules further may not be achievable by 1/1/98.
You reference PG&E stratifications several times in your paper. I am not
aware that we developed any of those stratifications for the purposes of
developing hourly load profiles. We do not have large enough sample
sizes by industry, distribution planning area, or other strata to develop   
profiles that would minimize cost-shifting to the degree that you claim
(a fact which you note with respect to colleges). Most of the data to which
you refer in section 2 is not available at hourly intervals below the   
class level, an absolute requirement for developing profiles. True, we
distinguish baseline quantities in rates for areas throughout our service   
territory, but not with hourly data.

As you point out, one way to get around data limitations is to increase
our sample sizes. While we may want to do this in the future for
operational reasons, it is neither a trivial task to implement nor
inexpensive. Setting meters to develop large numbers of profiles would
require sufficient customer interest and willing to bear the associated
costs.

We believe that further stratification WOULD require the creation of new
rate schedules, at least for bundled service customers. In principle,
customers should be able to choose between comparable generation
alternatives. Permitting a dry cleaner to use a dry cleaner load profile
that might have more off-peak usage than its existing rate schedule
without developing a similar dry cleaner bundled rate introduces
opportunities for gaming and cost-shifting. We believe this issue of
comparability to be critical.

If a load profiling option is offered to customers, it ought to be   
offered on a rate schedule basis.  If limited to the right set of customers,
load profiling should not have to contribute to any additional cost shifting.

Toby Tyler
e-mail: txt9@pge.com


cc:
Mike Jaske, CEC
Mac McCay, SDG&E (fax)
Carolyn Kehrein, CMA
Tony Wayne, Eastern Pacific (fax)
Sy Goldstone, CEC
Eric Woychik, UCAN
Megan Scott-Kakures, SCE
David Kaplan, PG&E



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