Draft Report on Load Profiling

June 12, 1997

Dear Toby, Carl, and Bob --

The California City-County Street Light Association (CAL-SLA) has a couple
of comments on the draft report.  They are more editorial in nature.
CAL-SLA plans to present more fully our views on load profiling for street
lights, especially for customer-owned lights, in our comments to the
Commission on the final report.

Regarding Section 2, PRINCIPLES FOR THE USE OF LOAD PROFILES, I believe some
parties expressed the need for evidentiary hearings during 1998 on issues
where there were substantial disagreements.

Regarding Section 5, ELIGIBILITY, I suggest moving the discussion on street
lighting from sub-section 5.2, "Customers with maximum demands between 20 kW
and 50 kW", to sub-section 5.1, "Customers with maximum demand of less 20
kW."  CAL-SLA disagrees with PG&E's and SCE's eligibility designations for
street lighting shown in that sub-section.  Please note, the official name
of the association is the California City-County Street Light Association.

In sub-section 6.2, "Interim segmentation schemes for 1/1/98", please add
CAL-SLA to list of organizations (CEC, ORA, and SPURR-REMAC), on page 17,
that believe additional segmentation should occur on January 1, 1998.  

As a clarification, when you use "rate category" in the report, for example
in sub-section 6.2,  is that synonymous with "rate schedule"?

Hope that these brief comments are helpful.

Reed V. Schmidt
Bartle Wells Associates
415/775-3113


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