6 Comments on Draft Decision
On June 1, 2001, the draft decision of Presiding Officer and Assigned Commissioner Wood on this matter was mailed to parties in accordance with Section 311(g) of the Public Utilities Code and Rule 77.7 of the Rules of Practice and Procedure. Comments were filed on _____________.
1. SDG&E's proposed RBRP is an opportunity to capitalize on available resources to reduce the impact of rolling blackouts that may occur in Summer 2001.
2. SDG&E's proposed RBRP incentive levels exceed levels available in other programs for largely the same level of load relief.
3. Using SDG&E's assumptions, proposed Schedule RBRP payments are $0.56/kWh to existing BUGS, and $0.61/kWh to new BUGS, while the cost to SDG&E is $0.735/kWh.
4. Tariffs for other SDG&E interruptible programs have been approved only recently.
5. Customer interest and participation in existing interruptible programs is affected by marketing of those programs, and a reasonable opportunity for enrollment.
6. Capacity payments necessitate a penalty structure for noncompliance.
7. SDG&E's proposed penalty structure involves increasing penalties for additional failures to perform, making it complex compared to an energy payment based only on performance.
8. Reliance on BUGs for capacity requires notification of availability of the BUG.
9. Capacity payments compensate BUG owners for the fixed costs of existing, or new, investment.
10. An interconnection allowance provides an incentive to install new BUGs.
11. Existing programs address incentives for distributed generation, including BUGs.
12. An energy payment will provide the necessary incentive for BUG operation during periods of firm load curtailment.
13. Most customers participating in the RBRP have already incurred the fixed costs of their BUG, are able to participate without reducing production, improve their eligibility to achieve compensation under the 20/20 energy savings program, and avoid the high on-peak energy charges they otherwise would incur.
14. Exempting RBRP participants from curtailment if their load reductions are 15% or more conflicts with the same provision in the OBMC program.
15. SDG&E will commit to environmental dispatch of BUGs, to the extent feasible.
16. A customer using a BUG to perform under the VDRP during a firm load curtailment would be paid twice for the same performance if also paid to operate the BUG in the RBRP.
17. Less than 5% of BUGs are likely to be operational prior to Stage 3 in SDG&E's service area.
18. There is little or no overlap between BUGs used to meet the customer's own emergency needs and those that will be used in the RBRP to maintain system reliability.
19. The RBRP will enhance, not detract from, system reliability.
20. The public interest in quickly amending D.01-04-006 to adopt Schedule RBRP, as modified, before Summer 2001 outweighs the public interest in a full 30-day public review and comment of the proposed amendment.
1. SDG&E's emergency petition for modification of D.01-04-006 should be granted in part, and denied in all other respects.
2. Schedule RBRP should be effective for one year, and its continuation should be assessed based on experience during Summer 2001.
3. Schedule RBRP should be effective only in the SDG&E service territory.
4. Schedule RBRP should be triggered only upon implementation of firm load reductions by the CAISO.
5. Schedule RBRP should permit BUG operation from the CAISO forecast clock time for firm load curtailments through 30 minutes after the CAISO advises that firm load curtailments are no longer necessary.
6. Schedule RBRP should include an energy payment $0.20/kWh, subject to modification consistent with VDRP price modifications, but should not include a capacity payment, an interconnection allowance, or a penalty structure.
7. Schedule RBRP should not provide for circuit exemption from rotating outages similar to OBMC circuit exemptions.
8. SDG&E should implement an environmental dispatch of BUGs in its application of Schedule RBRP, to the extent feasible, with BUG engines fired by natural gas, LPG or gasoline dispatched before those fired by diesel fuel.
9. Payments under Schedule RBRP should be only for generation that is not on line when the RBRP is called.
10. BUG operation under Schedule RBRP should offset the amount of firm load curtailment required of SDG&E by the CAISO during Stage 3 events.
11. SDG&E should track RBRP costs through the memorandum account authorized in D.01-04-006.
12. The period for public review and comment on the draft decision should be reduced, pursuant to Rule 77.7(f)(9).
13. This order should be effective today so that Schedule RBRP can be implemented without delay, and potential threat to public health and safety can be mitigated by operation of BUGs under Schedule RBRP.
IT IS ORDERED that:
1. The May 3, 2001 emergency petition for modification of Decision (D.) 01-04-006 filed by San Diego Gas & Electric Company (SDG&E) is granted to the extent provided herein, and denied in all other respects.
2. Within five days of the date of this order, SDG&E shall file and serve an advice letter with accompanying tariff Schedule RBRP. The advice letter and tariff shall implement SDG&E proposed Schedule RBRP with modifications, conditions and clarifications stated in the text, findings of fact, and conclusions of law in this order. The advice letter and tariff shall be in compliance with General Order 96-A. The advice letter and tariff shall become effective five days after filing, unless suspended by the Energy Division Director. The Energy Division Director may require SDG&E to amend its advice letter and tariff to comply with the orders herein.
This order is effective today.
Dated , at San Francisco, California.
