Updated: Calif. PUC Delays Start For 4,000 GWh of Direct Access Expansion

May 31, 2019

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Copyright 2010-19 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com

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The California PUC on May 30 adopted an order addressing various facets of the statutory increase in direct access (DA) load of 4,000 gigawatt-hours.

As first reported by RetailEnergyX.com yesterday, the PUC in its order is delaying the start date for the expanded direct access load from January 1, 2020 to January 1, 2021

The PUC is apportioning the new DA load over two years using the 2019 and 2020 waitlists. Under the decision, 2,000 GWh of the DA expansion is to be enrolled using the 2019 waitlist, and the remaining 2,000 GWh is to be enrolled using the 2020 waitlist.

Under the decision, the cap at Pacific Gas & Electric will increase to 11,393,225,285 kWh from 9,520,000,00 kWh.

The cap at Southern California Edison will increase to 13,456,866,759 kWh from 11,710,000,000 kWh.

The cap at San Diego Gas & Electric will increase to 3,941,907,956 kWh from 3,562,000,000 kWh.

The PUC delayed the service date for customers who enroll in the direct access expansion from January 1, 2020 to January 1, 2021, "to better coordinate this expansion of DA and ensure compliance with the Commission’s Resource Adequacy (RA) rules."

"We are persuaded by the comments on the proposed decision that argue against allowing customers who enroll in the DA expansion to begin service on January 1, 2020, since a 2020 start would only be possible if some LSEs did not have to comply with all of the Commission’s RA forecast requirements. In D.18-06-030, the Commission emphasized the importance of accurately forecasting year-ahead load by stating that '[p]articipation in the year-ahead [RA] forecasting process by all LSEs who plan to serve load in the following year, including accurate forecasting of expanded territory or customer base, will ensure a more equitable allocation of the RA requirements.' With the DA expansion, the customer base of some LSEs will expand as some LSEs who are ESPs that provide DA service will gain load while some LSEs that provide either bundled or CCA service will lose customer load," the PUC said

"[O]n April 19, 2019, LSEs were required to submit preliminary 2020 year-ahead load forecasts. Because the Commission’s allocation of RA requirements is based on the forecasts in the preliminary filings, we find that it is reasonable that some LSEs would have procured the necessary generation resources at that time based on that forecast. If the customers of such LSEs are permitted to join the DA expansion in 2020, those affected LSEs will have over-procured generation resources. For example, EBCE [East Bay Community Energy] states that it expects to lose approximately three percent of its load if the DA expansion is implemented starting in 2020 and, therefore, it is likely that EBCE will be required to 'carry resource adequacy for departing customers.' CalCCA asserts that the procurement costs for departing customers that start service under the DA expansion in January 2020 would be unduly shifted to the remaining customers of CCAs and IOUs," the PUC said

"Thus, even if the ESPs with DA expansion customers are able to demonstrate in their October RA filing that they can procure the requisite generation resources, procurement problems could persist if the DA expansion were to begin in 2020. Affected bundled or CCA LSEs might not able to divest the RA requirement that was procured but is no longer needed. Therefore, allowing customers who enroll in the DA expansion to start DA service in 2020 could frustrate the RA program goal of ensuring that RA requirements are allocated equitably," the PUC said

"Accordingly, we find that implementing the DA expansion does not justify an exception the Commission’s prior determination that '[a]ll load serving entities shall participate in all aspects of the year-ahead RA process for load they plan to serve in the following year,'" the PUC said

The Direct Access (DA) enrollment schedule to enroll 2019 and 2020 waitlist in the DA expansion is as follows:

(1) the deadline for customers to submit a Notice of Intent (NOI) to participate in the DA expansion is June 14, 2019;

(2) by July 29, 2019, each of Pacific Gas and Electric Company, Southern California Edison Company, and San Diego Gas & Electric Company (each an 'IOU') must complete their review, audit and confirmation of the NOI for the 2020 waitlist;

(3) by August 12, 2019, each IOU must notify the eligible 2019 and 2020 waitlist customers in that IOU’s service territory that they may enroll in the DA program and direct these customers to submit their decisions regarding DA service to the IOU on or before September 3, 2019, at 5:00 p.m.;

(4) if a notified customer declines the opportunity to join the DA program, the IOU must notify the next eligible customer in queue for that IOU’s service territory, and direct these customers to submit their decision regarding DA service to the IOU on or before September 3, 2019, at 5:00 p.m.;

(5) if a customer who is allocated the right to take DA service from the 2019 Waitlist declines the opportunity to take DA service at or prior to December 31, 2019, at 11:59 p.m., IOUs should use the 2019 Waitlist to reallocate that customer’s load;

(6) if a customer who is allocated the right to take DA service from the 2019 Waitlist declines the opportunity to take DA service after December 31, 2019, at 11:59 p.m., IOUs should use the 2020 Waitlist to reallocate that customer’s load; and

(7) notified customers who chose to switch to the DA program must select an Energy Service Provider (ESP) and have that ESP submit the Direct Access Service Request form to the respective IOU by February 3, 2020 at 5:00 p.m.

By September 10, 2019, the IOUs shall provide to each affected Community Choice Aggregator (CCA) the aggregate hourly peak demand and hourly load data for the latest entire year to date of 2019 and 2020 waitlist customers who chose to switch from that CCA’s service to the Direct Access program.

By February 10, 2020, the Pacific Gas and Electric Company, Southern California Edison Company, and San Diego Gas & Electric Company shall provide to each affected Community Choice Aggregator (CCA) the aggregate hourly peak demand and hourly load data from January 1, 2019 to December 31, 2019 for 2019 and 2020 waitlist customers who have submitted Direct Access Service Request form.

Rulemaking 19-03-009

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