Merced Irrigation District and Modesto Irrigation District (MID)

MID has one key concern related to the IOUs LTPPs and that is that the IOUs do not procure power or system reliability resources for and incur costs on behalf of municipal departing load (MDL) that the IOUs know, or should know, will take service from publicly owned utilities (POU), such as MID. MID urges the Commission to accomplish this by (1) directing the IOUs to use prudent forecasts of MDL to guide their procurement activities and; (2) to confirm that nonbypassable charges will not apply to prudently forecast MDL.

The Commission does urge the IOUs to use reasonable and prudent forecasts for all departing load, but will not at this time make any further findings on nonbypassable charges. Phase 3 of this Rulemaking, proceeding on a separate, but parallel track, is looking at a variety of cost-shifting issues, including the nonbypassable charge. The Commission defers further consideration of this issue to that Phase.

MID does raise a legitimate point concerning forecasting and that is that the IOUs do not provide the CEC with a detailed MDL forecast, but rather implicitly reduce their bundled load forecasts by the amount of historical MDL, and other departing load, trends. We will consider for the 2008 LTPP whether it would be beneficial for all parties to have the IOUs present their bundled load forecast, and then subtract the projected MDL and even DA and CCA projections so each concerned intervenor can have some assurance of the projected departing numbers for its group.

The bottom line issue for all departing load parties is they want the IOUs to predict, as accurately as possible, departing load, not procure for that customer base, and then there might not be any nonbypassable charges.