4. Proposals

The California Energy Commission (CEC) and The Utility Reform Network (TURN) advocate Commission adoption of emergency voltage reduction plans. In particular, CEC recommends that tariff rules be modified to allow each utility to utilize manual or automatic voltage reduction capability to reduce voltage by up to 2.5% on a selective basis during power emergencies, limited to no less than 117 volts at distribution substations. Power emergencies would generally be when blackouts are imminent, according to CEC. Moreover, CEC recommends that utilities be permitted to provide service as low as 110 volts at the customer meter, as long as there is a plan to restore minimum service to 114 volts at the meter upon conclusion of the emergency. CEC advocates waiver of utility liability if service temporarily drops below 114 volts at the customer meter. Finally, CEC recommends that the Commission study opportunities for voltage reductions by individual customers when the customer owns a substation or distribution transformer.⁹

TURN responded to utilities' proposals. In particular, TURN recommends that SCE be ordered to implement voltage reduction of 2.5% during on-peak Stage 2 and 3 emergencies, with SCE shareholders held harmless for the consequences of this initiative. TURN supports PG&E's efforts to permanently lower voltage for compliance with Rule 2. TURN does not recommend that SDG&E be ordered to implement additional voltage reduction at this time.

The California Farm Bureau Federation (Farm Bureau) opposes voltage reduction. If the Commission wishes to pursue voltage reduction, however, Farm Bureau recommends incremental implementation of voltage reduction to minimize unintended consequences. That is, under Farm Bureau's alternative proposal, voltage would be reduced in increments of 0.5%. Farm Bureau states that the first 0.5% reduction would not need to wait for a Stage 2 event. Data would be collected and analyzed with each incremental reduction, including assessment of the number of customer complaints, until the full 2.5% is reached, or noticeable problems occur. Farm Bureau recommends that the Commission establish a fund or bond to cover the cost of legitimate losses suffered by customers during an emergency voltage reduction event.