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Enron Mail |
Load is up in CA and so is the potential for selling load curtailment
products to customers. BOTTOMLINES: PG&E has asked the CPUC to approve participation of E-19 and E-20 Direct Access customers in the ISO A/S load participation pilot program (filed June 7). SCE has asked the CPUC to approve that all customers on its Large Power Interruptible tariff can participate in the ISO A/S load participation pilot program (filed June 7). FERC approved the ISO's Load Participation pilot progam and pricing on June 14, 2000, calling it an innovative program. This appears to be a total GREEN LIGHT for Enron to move forward with customers. PROCESS: The utilities filed advice letters. Comments are due on June 27. Unless you tell us otherwise, we plan to file and seek expedited treatment. (The CPUC has no required timetable in which to respond.) We expect the CPUC to approve them -- there is pressure from many fronts to DO something about load participation in the market. Both have asked for a July 17 effective date. DETAILS: SCE's is a much better document and makes a good case for CPUC approval, even though the the customers are already benefitting from providing the utilities with the option to curtail during system emergencies. SCE proposes the following approach to prevent "double-dipping" by the customers: If the ISO directs SCE to activate its load curtailment program during the time period that the customer has an accepted bid from the ISO in the A/S market, SCE -- working with the ISO -- will adjust the customer's bill to avoid double payments. SCE provides no more information, but, on principal, this seems fair to me. We'll have to watch to see what the proposed procedure would be. PG&E doesn't say much except that it is "unable" to offer this to bundled customers (oh, gee -- must be more of those "system constraints") until "later" (unspecified). I would expect large customer groups to argue about that -- but it gives us the opportunity to push direct access. PG&E didn't have much to offer on the "double-billing" issue -- it said either PG&E could change the customers bill or the ISO could adjust its payment. FERC threw out all the protests by various parties (e.g., MWD, M-S-R, other munis) and approved the ISO's proposal. The big issues were: supposed improper allocation of demand relief program costs (ISO allocates it to all SCs based on metered demand during all hours of the program);q request to charge those who are out of balance for most of the costs; the need to file pro forma agreement in advance (FERC said ISO doesn't have to); and the supposed overly restrictive program participation. If you want to know more about the order, give me a call. Have fun! Sue Mara
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