ATTACHMENT A
SUMMARY OF COMMENTS
SDG&E supports the ACR's objectives, but is concerned that the short time provided for comments does not permit a full discussion of the complexities raised by the ACR. SDG&E is also concerned that, even with additional information provided by CAISO, utilities will not have the benefit of the full scope of information possessed by CAISO. SDG&E recommends that CAISO post "proxy" locational marginal prices to address congestion costs and mitigation incentives pending implementation of MD02. SDG&E also suggests in the longer term that necessary transmission infrastructure projects be built.
ORA states that it is possible that DWR contracts are complicating the problem since utilities must also dispatch DWR contracts. ORA encourages the Commission to slow down and not rush to judgment without more and better information. ORA recommends that the Commission ask CAISO to provide updated information on the outlook for summer 2004 with Etiwanda Units 3 and 4 as RMR units. If no urgent problem exits, ORA recommends a slower, more deliberate approach to deal with needed improvements, including assessment of options and costs. As a bridge to MD02, ORA suggests considering (a) STRCs and (b) CAISO tariff changes (e.g., SCE and SDG&E proposals).
AReM, NCPA and CMUA generally assert that ESPs and their customers are already fully paying their own costs with regard to system reliability, and reliability related costs should be borne solely by utilities and their bundled customers. NCPA also urges that any solutions be limited to the geographic areas where the problem arises.
