BEFORE THE PUBLIC UTILITIES COMMISSION
OF THE STATE OF CALIFORNIA

Order Instituting Rulemaking on the 		)
Commission’s Proposed Policies Governing	)			R.94-04-031
Restructuring California’s Electric Services	)
Industry and Reforming Regulation		)
----------------------------------------------------	)
Order Instituting Rulemaking on the 		)
Commission’s Proposed Policies Governing	)			I.94-04-032
Restructuring California’s Electric Services	)
Industry and Reforming Regulation		)
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COMMENTS OF THE 
CALIFORNIA DEPARTMENT OF GENERAL SERVICES
REGARDING THE REPORT ON DIRECT ACCESS
LOAD PROFILING WORKSHOPS

	Pursuant to California Public Utilities Commission (“CPUC” or “Commission”) Decision 97-10-086, the Report on Direct Access Load Profiling Workshops (“Report”) and the extension of time granted on September 28, 1998, the California Department of General Services (“DGS”) hereby offers its comments on the Report.  DGS actively participated in the workshops--held in January and February of  this year--addressed in the Report. As noted in the Report, given the significant passage of time since those workshops and the rapid development of an operational electric marketplace, some issues addressed during workshops have been overtaken by market developments.  Nonetheless, DGS is concerned about certain issues raised in the Report and believe those issues warrant timely Commission action.  
I.	DGS Supports the Report’s Conclusion That There Should Be Consistent Use of “Dynamic Load Profiles” for All Purposes That Require the Use of “Load Profiles.”
	DGS agrees with and supports the Report’s conclusion that dynamic load profiles should be consistently used throughout California for all instances where Commission policy calls for the use of “load profiling.”  As pointed out in a number of places in the Report, consistency in the application of the dynamic load profiling methodology in each UDC territory should required as a matter of equity.  The Commission has correctly concluded that dynamic profiling is the more appropriate approach for load profiling purposes.  To allow some UDC customers to be subjected to statistical load profiling while other customers in the same territory are subject to dynamic may lead to unintended and inequitable results.  Because the concept of statewide consistency and equity run to the heart of this issue, DGS believes the Report’s call for the consistent use of dynamic load profiling should be required by the Commission.
	Regarding the Report’s concern of the potential expense for creating dynamic load profiles for customers over 50 kW (Report page 15), DGS would simply note that there is a significant fraction of Edison load in this class which has switched to direct access, that the metering in place for these customer could possibly provide additional data-points need for dynamic profiling, and that most other non-direct access customers within the largest classes currently take time-of-use service.  Therefore, to avoid expenses related with new load research meter deployments, DGS would suggest that adequate data points may currently exist to implement dynamic profiles for these classes.  While DGS understands concerns regarding confidentiality of customer consumption data, we do believe that it is possible to ensure that customer specific data can be masked adequately to address these concerns.  
	DGS has some concerns that the methodologies employed in the development of load profiles is not consistent across the UDCs.  Consistency would be preferable.  However, in light of the potential expense associated with requiring consistency of methodologies, and considering that the use of load profiling for purposes of CTC collection and determination of the PX Credit should have limited time frame, methodological consistency may not be required in this case.  Nonetheless, the Commission should undertake some steps to ensure that customers of one UDC do not face any systematic bias stemming from the methodology employed.  In this regard, DGS would support a review by the Energy Division within the scope of data and information collection for profiling impact analysis which would disclose any such bias.  If a bias is determined, then the Commission should then consider how customers can be treated equitably.

October 9, 1998					Respectfully submitted, 

							____________________________________
							Christopher T. Ellison
							Andrew B. Brown
							ELLISON & SCHNEIDER
							2015 H Street
							Sacramento, California 95814
							Telephone	916/447-2166
							Facsimile	916/447-3512

							Attorneys for the California
							Department of General Services