Re: Joint Stipulation Interruptible Criteria

I circulated the following comments among a few of the active
participants in this discussion a few days ago, and haven't heard any
objections, so I'm now circulating them more broadly.  I expect this
issue will approach resolution soon as we progress through tariff
filings.

> -----Original Message-----
> From:	Price, James E. 
> Sent:	Friday, July 25, 1997 9:16 PM
> Subject:	Re: Joint Stipulation Interruptible Criteria
> 
> The drafts concerning interruptible rates have been progressing well.
> Others in ORA have now reviewed the current draft and, combined with
> my own, we have the following comments:
> 
> (1) In the section titled "Opt-out provision for current program
> participants", add to the fifth sentence so that it reads:  "However,
> since the interruptible program is closed to new customers, customers
> who elect firm service or reduce their level of interruption will not
> be allowed to return to non-firm status or increase their level of
> interruption."
> 
> (2) After the section titled "Limited situations where the UDC may
> need to exercise dispatch control", add a new section called
> "Integration with market functions", as follows:
> 
> "Although the above operating criteria reflect existing load
> curtailment programs' terms and conditions, there are resulting
> impacts on other market functions.  For example, section 390(d) of AB
> 1890 provides a mechanism for payments to non-utility generators that
> requires measurement of the value of capacity, equal to the difference
> between the market clearing customer demand bid at the level of
> generation dispatched by the Power Exchange (PX) and the highest
> supplier bid dispatched.  The removal of interruptible customers from
> demand bidding in the PX may change the value of capacity in the PX
> clearing price to the detriment of ratepayers.  Edison's 7 cents/kWh
> criterion may provide a suitable proxy for the market clearing
> customer demand bid.  Similarly, the removal of interruptible
> customers from bidding for ancillary services may distort balancing
> and real time market prices to the detriment of ratepayers.  The ISO's
> development of load curtailment criteria and protocols should be
> designed to assure that firm customers are not detrimentally affected
> by the application of criteria and protocols to non-firm customers."
> 
> I hope these edits will be acceptable to all of you.  You probably
> know of others who have been reviewing these drafts, and you should
> feel free to recirculate this note to them.  If anyone has any
> concerns, please let us know so we can discuss them.
> 
> I also want to raise another, hopefully minor, issue.  Edison has been
> referring to the drafts as a "stipulation" document.  It doesn't seem
> to us that there is any formal setting is which a "stipulation" is the
> appropriate term, but rather that this text would be part of the
> introductory text of advice letters.  It would be appropriate, if
> desired by the submitters of the advice letters, to describe the text
> as the result of a collaborative effort.
> 
> 
.