SDP Implementation Extension Request

Below is the text of a draft letter to CPUC Executive Director Wes Franklin
asking for an extension of time for the UDCs to implement the Service
Delivery Point (SDP) system required by Decision 98-11-044.  The extension
is to allow implementation to coincide with the transition to EDI format for
meter data and DASR transactions.  This proposal was presented to the Rule
22 group by Lorenzo Kristov at the January 7, 1999 meeting and agreed to by
the group.  Please provide me any comments by Monday, February 8 when I
intend to finalize and send the letter.

Peter Ouborg, Attorney for PG&E

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Dear Mr. Franklin:

Pursuant to your authority under Rule 48 of the Commission's Rules of
Practice and Procedure, Pacific Gas & Electric Company (PG&E), Southern
California Edison Company (SCE), and San Diego Gas and Electric Company
(SDG&E) (the UDCs) request that you grant an extension of time to comply
with certain of the requirements of Decision 98-11-044.  In that decision,
the Commission ordered the three UDCs to implement a service delivery point
(SDP) numbering system within 180 days of November __, 1998, the effective
date of the order.  This SDP system would be used for certain information
exchanges under direct access.  While the UDCs are able to comply with this
directive and change their existing data exchange formats to accommodate the
SDP within 180 days, such an effort would be wasteful since a few months
later these same data exchange formats will be changed to the Electronic
Data Exchange (EDI) format subsequently ordered by the Commission in
Decision 98-12-080 (for meter data) and agreed to by the UDCs as part of the
Rule 22 process (for DASR transactions).  The UDCs believe the costs of
changing current formats to meet the 180 day deadline greatly exceed the
benefits of having the SDPs in general use a few months earlier than the EDI
rollout.  The deadline should therefore be modified to coincide with
operable dates for (1) the use of EDI formats for sending the DASR reply to
ESPs and in new account maintenance DASR transactions; and (2) use of EDI
formats for all relevant UDC-ESP-MDMA-MSP information exchanges.  

In making this request for an extension, the UDCs are not asking to delay
any internal activities they must undertake in developing the SDP numbering
system (Ordering Paragraph 1.a) or the requirement to file reports on SDP
implementation details (Ordering Paragraph 1.f). 

This request for extension of the 180-day deadline in Decision 98-11-044 has
the unanimous support of the Rule 22 Committee, where this issue was
presented by the Rule 22 SDP sub-team on January 7, 1999.

Very Truly Yours, 



Peter Ouborg


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