Office of Ratepayer Advocates
California Public Utilities Commission (ORA)
State of California
505 Van Ness Avenue
San Francisco, CA 94102
Tel: (415) 703-2061
Fax: (415) 703-1981

June 5, 1995

Richard Bilas, President
California Public Utilities Commission
505 Van Ness Avenue
San Francisco, CA 94102

Dear President Bilas:

We, the undersigned parties, respectfully request that the Commission issue an Order Instituting Rulemaking (OIR) into the bundling or unbundling of energy and ancillary services injected into the distribution service system, and the role of the Utility Distribution Companies (UDCs) with respect to optimail utilization of distributed generation (DG).

The parties making of this request do so knowing that the Commission already faces a heavy burden with existing proceedings to rsturcture markets in electricity, gas and telecommunications. It is our intention to alleviate, rather than enlarge the Commission's disparate proceedings, and which are bound to demand even more of the Commission's attention in the near future. With a framework for considering these issues in a consolidated manner, we believe the Commission's workload can be better managed.

We have attached the Statement of the Signatories (Statement), which outlines DG regulatory issues which we believe are integral to electric restructuring and to optimal DG implementation. The Statement describes why we believe it prudent to resolve those regulatory issues in an OIR. The Definition of Terms follows. Next, a list of proposed Core Questions is suggsted to the Commission as the basis for an OIR. The Core Questions touch upon distribution unbundling, market power, ratemaking, interconnection and other key issues. The Core Questions also include four possible scenaries of the UDC role in DG for parties to comment upon. Finally, Supplemental Questions are proposed should the Commission wish to consider the role of the distribution companies in DG the context of broader issues and scenarios.

The parties whose signature pages are attached to this letter support the Statement, and at a minimum, the proposed Core Questions. The parties include . . . Additional signature pages may follow.

Attachments:

  • Signature Pages
  • Statement of the Signatories
  • Definition of Terms
  • Core Questions for OIR
  • Supplemental Questions for OIR

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