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's recommendation is similar, proposing implementation of a temporary voltage reduction program to avoid or reduce the effect and duration of blackouts. TURN asserts that SCE is the only utility capable of undertaking this program during emergencies, with the ability to implement voltage reductions remotely at low cost limited to on-peak periods. TURN recommends that SCE be ordered to implement voltage reduction of 2.5% during on-peak Stage 2 and 3 emergencies on circuits where this is feasible, with SCE shareholders held harmless for consequences of this program. TURN states that PG&E and SDG&E should not be ordered to undertake temporary voltage reduction programs 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, as an alternative, that consideration be given to incremental implementation of voltage reduction to minimize unintended consequences. That is, under Farm Bureau's alternate 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.
9 CEC's proposal is presented in direct testimony, with clarification and expansion during cross-examination. (Exhibit 102, and Reporter's Transcript (RT) Volume 7, particularly at pages 422-3, 431-2, and 434-5.) CEC did not file either an opening or closing brief summarizing and supporting its proposal.