Proposed Position Paper:

Presented by the UTILITY SOLUTIONS Partnership, Inc., a nonprofit corporation representing the end-user stakeholder interests of California hospitals.

Issue:

Phase-in eligibility requirements.

Position:

The only requirements for participating in Direct Access should be limited to:

1) Customers who have installed the required equipment, and

2) Customers who have Direct Access contractual agreements.

Position Statement:

This position is in support of 4.5.4 Alternative #4 of the final DAWG report due August 30, 1996.

There should be no artificial or bureaucratic obstacles to participate in Direct Access. Once CPUC procedures are in place (presumably January 1, 1998), then customers who are ready with their required equipment and contracts in hand should be allowed to start, or stand in the queue. (Perhaps there needs to be separate queues for each customer class so processing large numbers of residential customers will not impede large industrial participation.) The only restraints should be the system's ability to accommodate customers. If the volume of customer requests for Direct Access is greater at any time than can be accommodated, then the customer should be processed on a "first come, first serve" basis. This is merely a practical limitation rather than an arbitrary barrier.

With an anticipated surplus of power, restricting participation on power volume contracts makes no sense. Also, processing customer transactions has no relationship to processing customer's load size. If willing and able customers have approved meters in place and the billing system is ready, then the phase-in rate of participation will take a natural course. Many customers will never leave their utility company, others will wait and see, while those who are eager for Open Access will be among the first to participate. So phase-in over an extended period of time will occur at its own pace. More important is that those who want to participate should be allowed to do so without waiting a year or two because of restrictive oversubscription rules.

Pro:

1) Direct Access is being designed to accommodate customer choices. If both the customer and the system are ready, regulations should not impede the process.

2) Managing the rate of Direct Access participation to accommodate qualified customer response is a reasonable regulatory goal.

Con:

1) The CPUC Direct Access Order specifically limits MW participation in 1998.

2) Many who are designing the system want to start slowly to minimize start-up operational problems.