Response to Load Profiling Workshop Report Draft Outline

Eastern Pacific Energy
Administrative Offices
2923 Saturn St., Ste. A
Brea CA 92821
1-888-353-2427

2. Load Profile Eligibility

    2.1.2 - Customers with peak demand greater or equal to 20 kw

          It is apparent at the present time that the mandating of interval
meters for all customers down to the level of 20kw, may create temporary
barriers for all those wishing to buy electricity on a direct access basis
because interval meters are not presently available in large quantities. At
the least, procuring these meters prior to January 1998 will be a daunting
task. Not only has it yet to be determined what the new meter standards will
be, and even if the requirements were no different than those of existing
interval meters, meter manufacturers would have a difficult time producing
enough interval meters to supply the likely demand. In addition, the
condition is exacerbated by the fact that ESP's will have little time to
install them.

          At present, there is apparently a 6-8 week lead time necessary to
manufacture and deliver even 100 interval meters. Accordingly, the lead time
necessary to obtain the thousands of interval meters needed to fill the
orders for California's Direct Access market will be significantly greater.

          In order to solve this problem, it is Eastern Pacific Energy's
recommendation to use load profiling for all customers requesting Direct
Access until sufficient meters are available for all parties to participate.
At the very least, 50 kw peak users and under should be exempt until
sufficient meters are available to allow these users to implement interval
meters. We can only assume that it is the desire of the CPUC that the larger
users have the first opportunity to purchase interval meters, so that
Schedule Coordinators for the larger users can better schedule these larger
loads.

4. Principles For The Use of Load Profiles

          The most important element for the success of implementing load
profiles is the ability of the ESP to receive historical load profile
information from the IOU's in a timely manner. Any attempt by the IOU's to
impede this process places the ESP's at a disadvantage in correctly
scheduling their hourly load.


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