ORA Comments for the Draft Report on Load Profiling Eligibility

ORA Comments for the Draft Report on Load Profiling Eligibility

	The following ORA comments are intended to make the draft load
profiling eligibility more accurate and informative:
	
		1)	In the last paragraph on page 9
("DGS/SPURR-REMAC/ORA/CFB"), the draft report states that "The coalition
is also amenable to the UDC proposals for either a temporary exemption
for customers in backlog queue or an interim blanket exemption for all
customers up to 50 kw".  Two things need to be added here.  First, the
"interim blanket exemption" is conditioned upon an agreement that
parties support the UDCs' simplified interim load profiling methodology
proposal.  Second, at least one party,ORA stated that this particular
condition is unacceptable to ORA since, among other things, it is based
on static load profiling.

		2)	In the third paragraph on page 11, the draft
report states "PG&E and SDG&E propose an Interim Blanket Exemption
during 1998 for all customers in the 20 to 50 kW size range,...."  It
should be added here that this proposal is conditioned upon an agreement
that parties support the UDCs' simplified interim load profiling
methodology proposal.

		3)	In the last paragraph on page 11, the draft
report states that "These parties (the coalition) would alternatively
support either the Temporary Exemption or Interim Blanket Exemption
proposals of the UDCs.  It should be added there that ORA stated that
the condition attached to the Interim Blanket Exemption proposal is
unacceptable to ORA.
		
		4)   On the footnote at the bottom of  page 4, the draft
report states " This methodology, proposed by the UDCs in the
consolidated Ratesetting Unbundling applications (96-12-009, 96-12-011,
96-12-019) is recommended for Commission adoption in the proposed
Decision of ALJ Malcolm, dated July 1,1997." It should be noted that
Commission President Conlon has issued alternate pages that reject the
utilities proposal.

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