EDF Load Profiling Proposal (fwd)


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Date: Mon, 2 Jun 1997 21:26:57 -0400
From:Dan_Kirshner@edf.org
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Subject: EDF Load Profiling Proposal

     The Environmental Defense Fund (EDF) is substantially
in agreement with the utilities' proposal with respect to
the following points:

  For 1/1/98 implementation, keep it simple.  Use single
customer-class load shapes based on previous, most recent
rate design filings.
  Defer without prejudice issues of customer class
segmentation and load profiling methodologies until after
1/1/98.
  Certain consistency rules should be enforced.  For
example, retailers/scheduling coordinators must use the
same load profile in dealings with the UDC that they use
for settlements with the ISO (although, as a practical
matter, the ISO settlement process will by default
enforce this).
  The UDCs shall have responsibility for creating load
profiles that may be used by retailers and scheduling
coordinators.

     EDF would make the following amendments to the
utilities' proposal:

  UDCs do not have exclusive rights to development of load
profiles.  If retailers or scheduling coordinators want
to use load profiles for some of their customers for
settlements with the PX or ISO, there should be a process
that enables them to do this.
  The CPUC does not have exclusive jurisdiction over load
profiles.  The PX and ISO have the right to determine
their requirements for the use of load profiles.
  A "bill credit" methodology for direct access customers
should not be assumed as a given.  The unbundling
methodology is still an issue to be decided in the
ratesetting/ unbundling proceeding (A.96-12-009/011/019).
  There should be a date certain, after 1/1/98, for the
consideration of deferred issues.

     A revised version of the utilities' proposal (in
"revision mode") consistent with these points is attached
below.

     EDF hopes the rationale for its proposed modifications
is clear.  In outline, EDF believes that competition,
innovation, and economic efficiency will be best served by
allowing market participants flexibility to develop new load
profiles to suit particular purposes and customer groups.
The responsibility for assuring the accuracy of settlements
lies primarily with the ISO.  The ISO must have the ability
to determine whether a particular load profile methodology
is sufficiently accurate for settlement purposes.  While one
can detect concern on the part of the UDCs that market
participants may try to "game" the use of load profiles, the
UDCs must be sensitive to a reciprocal concern on the part
of other market participants.  The ISO is the correct,
neutral institution to make sure that load profiling is used
properly by all market participants.

     We look forward to further discussions with workshop
participants.
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(See attached file: edflp.doc)

edflp.doc