BACKGROUND
On April 15, 1980, the Commission issued D. 91548 dealing with electric curtailments. That decision adopted a priority system for mandatory curtailments and rotating outages. As part of the decision, requirements were established for participation in Binding Mandatory Curtailment Plans. Stating:
J. Binding Mandatory Curtailment Plans
Any customer meeting both the criteria for Economic Damage and those following.
The customer would be required to file with the utility an acceptance binding energy and load curtailment plan. The customer would agree to curtail electric use on his entire circuit 1 by the amount being achieved via rotating outages. The customer's plan would show how reduction on the entire circuit could be achieved in 5 percent increments to the 50 percent level and show how compliance can be monitored and enforced...2
The decision also directed respondent electric utilities to file action plans in compliance with the adopted program.
On June 2, 1982, the Commission issued D. 82-06-021 responding to the action plans filed by the utilities and modifying D. 91548. D. 82-06-021 did not change the OBMC plan requirements adopted in D. 91548.
On September 8, 1982, the Commission issued D. 82-09-028 reducing OBMC plans' required curtailment to 20 percent, from 50 percent. In order to participate in the OBMC program, customers must be able to reduce the total load on their circuit by 20 percent, rather than the previously required 50 percent.
On July 20, 2000, PG&E filed Advice Letter 2019-E requesting approval of tariff sheets OBMC. The proposed plan includes eligibility requirements, rules for monitoring compliance, non-compliance penalties, and a limited term.
PG&E's OBMC eligibility requirements limit the plan to customers on Schedule E-19 (large commercial) or E-20 (industrial) and excludes customers on E-19's voluntary provisions. Customers must be able to reduce electric load on the entire circuit up to 20 percent below baseline. Baseline is the calculated average of the highest circuit load during each of the prior year's summer months, less any non-firm load. The amount of the curtailment shall be rounded up to the nearest five percent increment. Customers must also demonstrate economic damage of at least $250,000 resulting from a rotating outage. OBMC plans are open to direct access customers.
PG&E's OBMC monitoring rules include requiring an interval meter readable by telephone for dedicated circuits. If the circuit is not dedicated, electronic recording equipment is required at PG&E's substation. If that equipment is not present it shall be provided by PG&E at the customer's expense, pursuant to PG&E's Electric Tariff Rule 2, Special Facilities.
PG&E's OBMC non-compliance penalties: (1) are calculated by multiplying the average load on the participant's circuit less the targeted load level, times the PX market clearing price for the load during each hour of the rotating outage; and (2) allow PG&E to terminate any customer at its sole discretion if the customer did not meet the load criteria specified in the OBMC plan.
In Advice Letter 2019-E, PG&E requests a shortened protest and comment period in order to permit approval of the Advice Letter by August 3, 2000.
Rule 77.7(f)(9) of the Commission's Rules of Practice and Procedure permits the waiver of the period for public review and comment where the Commission determines that public necessity requires reduction or waiver of the 30-day period.
1 Emphasis in the original.
2 CPUC 2nd 3 (p. 533)
