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Draft Calif. Decision Would Determine Schedule For New Direct Access Load, Allocation To Wait List Customers

Draft Addresses Proposed Cap On Direct Access Load Within Community Choice Aggregations, Sought By CCA Group

May 6, 2019

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Copyright 2010-19
Reporting by Paul Ring •

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The California PUC has issued a proposed decision which would address various facets of the statutory increase in direct access (DA) load of 4,000 gigawatt-hours

The proposed decision would apportion the new DA load over two years using the 2019 and 2020 waitlists. Under the draft, 2,000 GWh of the DA expansion would be enrolled pursuant to an expedited schedule, and the remaining 2,000 GWh would be enrolled using the 2020 waitlist.

The proposed decision would apportion the new DA load to the three large investor-owned utilities as follows (in kWh): Existing Cap Expanded Cap PG&E 9,520,000,000 11,393,225,285 SCE 11,710,000,000 13,456,866,759 SDG&E 3,562,000,000 3,941,907,956

The draft provides that, to accommodate resource adequacy (RA) planning requirements, the load that is enrolled pursuant to the 2019 Waitlist cannot begin DA service until January 1, 2020, and customers enrolled pursuant to the 2020 Waitlist cannot begin DA service until January 1, 2021.

The draft provides that, by June 14, 2019, the IOUs must notify customers who are on the waitlist that is effective for 2019 and who are eligible to join the DA program they may switch to the DA program. By July 8, 2019, the notified customers must state whether they choose to switch from their current service provider to DA service. By July 31, 2019, customers who choose to switch to the DA program must select an ESP and the ESP must submit the Direct Access Service Request (DASR) form to the incumbent IOU.

"To be clear, to participate in the DA expansion starting on January 1, 2020, each customer’s DASR form must be submitted to the IOU by July 31, 2019," the draft states

To comply with provisions of SB 237, the draft would allow a one-time exception from the requirement in D.18-06-030 that LSEs must submit the 2020 year-ahead load forecast on April 16, 2019. Because the RA program allows LSEs to adjust the 2020 year-ahead forecast in August and the DA expansion represents approximately two percent of peak load, "we find that having the affected ESPs reflect the DA expansion through the adjustment process is reasonable," the draft states

"However, all other requirements of D.18-06-030 remain in place, including submittal of an August revised load forecast for 2020 that reflects migrating load and compliance with 2020 year-ahead and month-ahead RA filing requirements," the draft states

In order to ensure that RA allocations are consistent with load migration resulting from the DA expansion, ESPs gaining customers must provide documentation with their August revised load forecasts that indicates which LSEs will be losing those customers, the draft states.

The 2020 Waitlist will be created by a lottery run in June 2019 for new service in January 2021. The deadline for participation on the 2020 Waitlist would be June 14, 2019

The draft would order that the IOUs must provide CCAs in their service territories with the amount of aggregated load for existing CCA customers who have elected to switch to the DA program.

The draft would find that the PCIA vintage that is assigned to CCA customers should not change if that customer leaves CCA service to join the DA program.

The draft would deny a proposal from the California Community Choice Association (CalCCA) to limit the amount of direct access within CCAs

As summarized in the proposed decision, "CalCCA argues that some CCA service territories that have six to 12 percent of load on the DA waitlist could 'face disparate impacts' as those amounts 'represent a significant volumetric shift for already projected-and procured for—load along with potential changes in overall load profile which would impact procurement planning.' Further, CalCCA asserts, that unlike IOUs, CCAs are not guaranteed cost recovery through mechanisms such as the PCIA and the Cost Allocation Mechanism. To resolve this issue, CalCCA requests that the Commission establish a cap on the amount of customer load that is eligible to join the DA program (CCA Cap) and that the cap should be based on the 'lesser of load currently on the existing waitlist or [the CCA’s] fair share of load.'

The draft would find that, "CalCCA’s proposal would stifle customer choice and provide preferential treatment to certain LSEs (CCAs) over IOUs and ESPs..."

The draft suggests that CCAs address direct access migration risky by, "revising their risk management plans or implementing mechanisms that are similar to the regulatory framework established for the PCIA."

Rulemaking 19-03-009

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