ATTACHMENT A
SUMMARY OF COMMENTS
TDM is concerned that the speed with which major policy changes are considered and adopted here may lead to unintended or harmful consequences. Others express concern whether the policies, even if adopted and implemented now, can achieve the desired goals as quickly as summer 2004.
TURN, SCE, CCSF believe that without adequate information, time and process, the ACR contemplates both (a) fundamental changes in statutory relationships that have been in place for several years, and (b) abrupt changes in policy adopted as recently as January 2004 (in D.04-01-050).
PG&E argues that the solution, if any (a) should not be statewide but should concentrate on specific locational issues; (b) should not be implemented by utilities but can and should be implemented by the CAISO (via designating additional RMR units); but (c) if utilities are expected to participate in the solution, then CAISO must provide clear and specific direction to utilities, with utility-incurred costs fully recoverable from utility ratepayers.
SCE also believes the CAISO can and should take the lead and resolve the issues within existing authority. If further solution is needed, SCE proposes that the CAISO modify its day ahead scheduling procedures to test the feasibility of managing intra-zonal congestion, with any "reliability premium" paid by all grid users, and cost recovery for utilities assured when utilities implement the CAISO's directions.
