6. Comments on Proposed Decision
The Presiding Officer and Assigned Commissioner's proposed decision was filed with the Commission and served on all parties in accordance with Section 311(d) of the Public Utilities Code and Rule 77.1 of the Rules of Practice and Procedure. Comments were filed and served on ________, 2002, and reply comments were filed and served on _________, 2002.
1. The Commission's existing CVR program, as stated in Rules 2 of PG&E, SCE and SDG&E, already requires that most service voltage (at the customer meter) be between 114 and 120 volts (for normal 120 volt service), with limited exceptions.
2. Each utility strives to operate within the limits of Rule 2, and makes necessary corrections when brought to its attention.
3. PG&E and SDG&E do not have automatic or remote capability to quickly implement voltage reduction during system emergencies.
4. The Governor's request to study voltage reduction was initiated under far worse conditions than exist today, with current conditions now including increased supply and decreased demand.
5. The benefits of an emergency voltage reduction program are limited to the remote voltage reduction capability of SCE during its summer on-peak period, saving no more than an estimated 160 MW.
6. The risks of injury, damage and disruption increase as voltages decrease.
7. Emergency voltage reduction can cause injury, damage, and disruption, including increasing the risk and incidence of injury, equipment damage, and equipment maintenance costs; shortening equipment life; causing equipment outages; disrupting or halting business operations; and reducing system operator flexibility.
8. Minimum ANSI C84.1 Range A service and utilization voltages are 114 and 110, respectively, and minimum Range B service and utilization voltages are 110 and 106, respectively.
9. ANSI C84.1 Range A identifies voltages for which electrical systems are designed and operated, and is the expected normal condition, while the occurrence of service voltages outside of Range A should be infrequent.
10. ANSI C84.1 requires that Range B voltages be limited in extent, frequency, and duration, and when Range B occurs, corrective measures shall be undertaken within a reasonable time to improve voltages to meet Range A requirements.
11. If emergency voltage reduction is authorized as recommended, the event might last as long as the entire SCE on-peak period, or up to 6 hours each summer weekday (excluding holidays), for a total of 504 hours in 2002.
12. A program that authorizes Range B up to 504 hours is not consistent with events that are "temporary," "infrequent," and "limited in extent, frequency and duration."
13. Operation in Range B for extended times nearly ensures some customers will see voltages below Range B, with concurrent risk of injury, damage and disruption.
14. The NEC encourages building designers to limit voltage drop to 5% (6 volts on a 120 volt system) compared to 4 volts in ANSI C84.1.
15. The 2 volt difference in allowance for voltage drop within buildings between the NEC and ANSI C84.1 creates a bias for problems, and necessitates caution when lowering overall system voltages below Range A.
16. Emergency voltage reduction places some customers at risk of utilization voltage less than 106 volts, including not only non-essential customers, but also essential customers normally excluded from rotating outages.
17. The Chairman of the Accredited Standards Committee C84 states that service voltage of 114 volts is the minimum voltage to ensure acceptable equipment performance.
18. Unacceptable equipment performance creates risk of injury, damage and disruption.
19. CEC test results have not been published, have not received formal peer review, and were not introduced as evidence.
20. All equipment does not at all times meet current code, reflect proper installation, and have safeguards and safety devices that are fully functional.
21. Waiver of utility liability for injury, damage or disruption resulting from emergency voltage reduction transfers the risk of those outcomes from the utility to its customers, and specifically to the customers who experience injury, damage or disruption.
22. The transfer of risk from the utility to its customers is inequitable, the magnitude of the liability is unknown, and, if those customers are essential customers, it harms not only those customers, but also the broader public health, safety and welfare.
23. Emergency voltage reduction involves unknown effects over potentially long durations without an existing or proposed warning system, while rotating outages are announced before they occur, are of limited duration, and customers have several options available to mitigate their exposure or damage.
24. Investments in alternatives (including investments in new generation, energy efficient equipment, conservation programs, and expanded interruptible rate tariffs) promise more secure benefits with greater potential capacity savings and fewer risks than does emergency voltage reduction.
25. CEC recommends that the Commission study opportunities for customers who own their own substations or distribution transformers to implement voltage reductions in response to system emergencies or energy conservation, but CEC presents no estimate of possible costs or potential savings.
26. Numerous other programs now in place as a result of Executive Orders by Governor Davis, as well as initiatives by this Commission and utilities, have significantly moderated the need to authorize an emergency voltage reduction program.
27. The potential benefits of emergency voltage reduction are modest, the risks are not quantified but potentially great, and reasonable alternatives are available.
1. PG&E, SCE and SDG&E should each continue all reasonable efforts to operate their distribution systems at the lowest peak load voltage levels consistent with Commission orders and Rule 2.
2. PG&E, SCE and SDG&E should each modify their existing voltage regulating devices, as necessary and reasonable, to ensure operation within Rule 2 limits.
3. PG&E, SCE and SDG&E should each explore all reasonable opportunities for additional voltage savings in the normal course of their operations, including implementation of all cost-effective measures to reduce voltage during normal substation related work.
4. The voltage reduction recommendations of the CEC and TURN should not be adopted, but, should the need resurface, parties may propose specific emergency voltage reduction measures for further consideration.
5. This order should be effective today so that utilities may continue all reasonable efforts to pursue voltage regulation and capacity savings within the limits of Rule 2 and ANSI C84.1; the uncertainty of possibly implementing an emergency voltage reduction program is removed; and parties can explore all other alternatives, as necessary, for avoiding rotating outages with Rule 2 and ANSI C84.1 limits without delay.
IT IS ORDERED that:
1. Pacific Gas and Electric Company, Southern California Edison Company, and San Diego Gas & Electric Company shall continue all reasonable efforts to operate their distribution systems at the lowest peak load voltage levels consistent with Commission orders and Rule 2; modify their existing voltage regulating devices, as necessary and reasonable, to ensure operation within Rule 2 limits; and explore all reasonable opportunities for additional voltage savings in the normal course of their operations, including implementation of all cost-effective measures to reduce voltage during normal substation related work.
2. This proceeding remains open for other Phase 2 issues, but is closed regarding emergency voltage reduction plans. Parties may, however, propose further Commission consideration of an emergency voltage reduction plan, as necessary and reasonable, by filing a pleading pursuant to any relevant portion of the Public Utilities Code, including a petition under Public Utilities Code Section 1708.5, if the need to consider such plan resurfaces.
This order is effective today.
Dated , at San Francisco, California.
************ APPEARANCES ************ |
Jennifer Tachera Ann L. Trowbridge |
Lynn M. Haug Jeff Nahigian |
John W. Leslie Janine Watkins-Ivie |
Michael D. Montoya |
|
(END OF APPENDIX A)
