Position of UC/CSU

UC/CSU also filed a response in support of the CVP Group motion, noting that the UC Davis campus is a federal preference power customer that has been receiving WAPA power since 1991. After expiration of Contract 2948A on December 31, 2004, UC Davis' power allocation of 15 MW will decline to 6 MW. UC/CSU expresses concern that if CRS is assessed on UC Davis, the university would be forced to pay CRS for WAPA custom product even though it has had a continuous WAPA allocation of at least 15 MW since 1991 and 25 MW from 1996 through June 2001. UC/CSU provided the Declaration of Jill Blackwelder, Associate Vice Chancellor, to support these claims.

As noted by PG&E, U.C. Davis appears to have taken a significant amount of bundled service: 38,012 MWH in 2001 and 82,095 MWH in 2002. PG&E thus contends that receipt of bundled service would make UC Davis a departing load customer under PG&E's Commission-approved electric tariff, subject to the CRS to the extent U.C. Davis replaces its PG&E bundled service with service from another provider.