Calif. Staff Reports on Implementation of Direct Access Re-opening

Some 26,000 requests for direct access were rejected in California's Phase III of the process to implement the expanded direct access cap, according to a PUC Staff report detailing results of the Year 2 and Year 3 Notice of Intent periods (R.07-05-025.).

Accepted and rejected notices during each period are below:

Year 2, Notices submitted July 16, 2010 for service starting Jan. 2011

Year 3, Notices submitted Jan. 31, 2011 for service starting Jan. 2012

Load data in annual GWh. The totals shown for rejected notices exclude duplicate notices already accepted.

The Staff report also confirms that the caps were essentially hit immediately in each of phases, as previously reported:

Furthermore, Staff found that the utilities have occasionally accepted new load after the applicable cap for a specific phase was hit, either due to lower usage opening up room under the cap, or to correct errors.

For example, Pacific Gas & Electric, in mid-September and mid-October 2010, identified additional capacity under the 2011 Direct Access Load Cap sufficient to accommodate additional customers that had submitted notices on July 16, 2010. Southern California Edison in late September 2010 identified processing errors that resulted in customer notices having been erroneously rejected.

The utilities have adjusted upward or downward the amount of load they accept based on available room under the cap (see chart at bottom). For example, the total annual GWh load SCE accepted for Year 2 and Year 3 were both greater than the respective annual allotments of direct access load. Specifically SCE explained that it accepted the additional load in January 2011, "as a result of reduced usage by DA customers and returns to bundled service by some DA customers, as well as some customers with accepted Six Month Notices ultimately not switching to DA, all of which freed up additional space under the existing load limit."

PG&E also explained a processing error that resulted in its load by the end of last year exceeding the cap. The error involved load of customers whose notices were accepted, given an erroneous computation of the customers' load. A customer inquiry uncovered the error. PG&E then performed a wider investigation covering all service accounts [SAs] contained in accepted customer notices and determined that other SAs from other customers should also have been accepted. The additional acceptance of these SAs brought PG&E's acceptances to slightly over the limit set in the tariff for this phase of direct access reopening.

Staff directed that the utility's web pages regarding the cap must be updated at least monthly so customers can see whether room is becoming available under the cap, and that the web page must show the last update date. If room becomes available under the current (Year 2) cap, the utilities are required to notify customers on their web pages, Staff said.

As of the Staff report, all utility web pages state that they are not currently accepting notices. Looking at utility web pages in mid-July, Staff noted that potential direct access customers have no apparent way to be certain that these statements are current. SCE and SDG&E web pages indicate that they were last updated in early February 2011, while the PG&E web page indicates nothing about when the page was last updated.

	Accepted Customers	Accepted Load	Rejected Notices
PG&E	200	1,593	5,241
SCE	375	1,810	8,997
SDG&E	37	156	1,928
Total	612	3,559	16,166

	Accepted Customers	Accepted Load	Rejected Notices
PG&E	66	605	14,288
SCE	83	869	8,617
SDG&E	21	113	3,113
Total	170	1,587	26,018

Time Cap Hit	2011 Cap (min/sec)	2012 Cap (min/sec)
PG&E	2/21	0/5
SCE	0/57	0/47
SDG&E	0/7	0/18

Enrollment Information
Unless otherwise specified, such as "customers," all units are Annual GWh.
					Room Under Cap
Line		PG&E	SCE	SDG&E	PG&E	SCE	SDG&E
1	Load Cap	9,520	11,710	3,562
2	DA Base Line Load	5,574	7,765	3,100
3	30Apr2010 Load	5,498	7,554	3,056
4	Load of Existing DA Eligible customers w/6- mo Notices Between D.10- 03- 022 on 15 Mar 2010 and 9 AM 11 Apr 2010	569	6	0
5	SB 695 DA Load Allowance	3,946	3,946	462
6	Y1 Incremental = DA Allowance x 0.35	1,381	1,381	162
7	Y1 Accepted Load	1,008	1,583	174	373	- 202	- 12
8	Y1 Annual Cap	6,955	9,145	3,262
9	31Jul 2010 Load	6,296	8,255	3,227	659	890	35
10	31Aug2010 Load	6,486	8,579	3,233	469	566	29
11	31Dec2010 Load	6,967	7,747	3,231	- 11	1,398	30
12	Y2 Incremental = New DA Allowance x 0.35	1,381	1,381	162
13	Y2 Accepted Load	1,593	1,810	156
14	Y1+Y2 Accepted Load	3,170	3,399	330	14.77%	23.08%	2.04%
15	Y1+Y2 Allowance	2,762	2,762	323
16	Y2 Annual Cap	8,336	10,526	3,423
17	31Jan2011 Load	7,579	8,972	3,370	757	1,555	53
18	30April2011 Load	8,545	10,141	3,341	- 209	385	82
19	31May2011 Load	8,546	10,119	3,328	- 210	407	95
20	30 June 2011 Load	8,516	10,109	3,317	- 180	417	106
21	Y3 Incremental = New DA Allowance x 0.20	789	789	92
22	Y3 Accepted Load	605	869	113
23	Y3 Annual Cap	9,125	11,315	3,516
24	Total Accepted DA Load post 15 Mar 2010	3,775	4,268	443
25	DA Load Allowance Less Total Accepted DA Load post 15 Mar 2010	171	- 322	19
Notes:
The SB 695 Load Cap (line 1), Base Line DA (line 2), and the DA load allowance (line 5) are taken from Appendix 1 of D.03- 10- 022.
SCE's baseline equals the annual DA load in its service territory as of November 30, 2009, plus Cerritos' set- aside of 137.5 GWh per D.10- 01- 012.