PROTESTS
On July 25, 2000, the San Francisco Bay Area Rapid Transit District (BART) protested Advice Letter 2019-E. BART is concerned that modifying the outage curtailment process will likely affect non-participating customers, which could include BART. BART requests that the filing not go into effect until PG&E has demonstrated that its proposed Schedule OBMC will not affect BART's ability to maintain vital public transit services during load curtailments.
On July 25, 2000, the Load Management Subcommittee of the Silicon Valley Manufacturing Group (SVMG) protested and commented on Advice Letter 2019-E. SVMG is concerned the 20 percent reduction in load required by Schedule OBMC was too high and not practical. They support the concept because it rewards customers who reduce their load. SVMG supports reducing the maximum load reduction requirement to 10 percent.
On July 26, 2000, the Office of Ratepayer Advocates of the California Public Utilities Commission (ORA) protested Advice Letter 2019-E. ORA objects to the fundamental premise of the advice letter which ORA contends allows some large customers to receive premium quality service for a majority of their load in exchange for curtailing a small portion of their load. ORA also expressed concern for OBMC's anti-competitive aspects and the complexity it adds to ISO service interruption decisions and operating procedures. ORA goes on to comment that while opposing the proposal, it recommends the following conditions if the Commission chooses to approve it. ORA would charge participants a rate equivalent to the interruptible discount. ORA would require competitive choice for meters and installation of meters. ORA also recommends doubling the penalty for non-compliance.
On August 2, 2000, De Monte Foods filed comments generally supporting the concept of an OBMC.
On August 2, 2000, PG&E filed a response to the three protests to Advice Letter 2019-E. In response to BART, PG&E provided an explanation of how BART's facilities will be treated if rotating outages are called. In response to SVMG, PG&E states the required twenty percent reduction is appropriate but offers two modifications. PG&E proposes to lower the required five percent increments for load reduction to two and a half percent and requests the ability to adjust circuit baselines to account for circuit load growth or circuit rearrangements. PG&E responded to ORA's three recommendations. PG&E disagrees with ORA's request for a premium service charge. It states that OBMC is not a premium service because the participant agrees to reduce load during every rotating outage, not just the ones it would otherwise be subject to. PG&E does not support ORA's suggested meter services, claiming it is a further unbundling. On ORA's suggestion to double the non-compliance penalty, PG&E states the higher penalty may reduce participation, but would provide an impetus for compliance.
On August 9, 2000, BART augmented its protest of Advice Letter 2019-E. In response to BART's initial protest, PG&E supplied BART with its Electric Emergency Plan (Plan). BART claims that PG&E's Plan is not in compliance with D. 91548 because it does not protect BART's system as an essential use under D. 91548. Therefore, BART requests that Advice Letter 2019-E not be approved until PG&E's Plan is brought into compliance. In addition, BART claims Advice Letter 2019-E will shift rotating outages from non-essential uses to BART's essential uses.
On August 16, 2000, PG&E responded to BART's augmented protest. PG&E claims that BART did not properly interpret D. 91548 and D. 82-06-021. PG&E states that the Commission adopted list of essential customers exempt from rotating outages does not include BART, public transportation systems, or rail services. PG&E further argues that the OBMC program will decrease the number of customers within each rotating block, and may well also contribute to reducing the frequency or duration of any necessary rotating outages for non-OBMC participants.
