BILL ANALYSIS                                                                                                                                                                                                              1
          1





                SENATE ENERGY, UTILITIES AND COMMUNICATIONS COMMITTEE
                               DEBRA BOWEN, CHAIRWOMAN
          

          AB 816 -  Reyes                                   Hearing Date:   
          July 8, 2003               A
          As Amended:         July 2, 2003             FISCAL       B
                                                                        
                                                                        8
                                                                        1
                                                                        6

                                      DESCRIPTION
           
           Existing law:  

          1.Authorizes retail competition (direct access) within the  
            service areas of the investor-owned utilities (IOUs) (AB 1890  
            (Brulte), Chapter 856, Statutes of 1996).

          2.Requires the California Public Utilities Commission (CPUC) to  
            suspend the right of IOU customers to acquire direct access  
            service until the Department of Water Resources (DWR) no  
            longer supplies power to IOU customers (AB 1X (Keeley),  
            Chapter 4, Statutes of 2001).  Pursuant to AB 1X, the CPUC has  
            suspended direct access as of September 20, 2001. 

          3.Declares the intent of the Legislature that all customers  
            taking service from an IOU after the enactment of AB 1X bear a  
            fair share of specified DWR costs and that any cost shifting  
            between customers be prevented (AB 117 (Migden), Chapter 838,  
            Statutes of 2002).

           This bill:  

          1.States the intent of the Legislature to enact subsequent  
            legislation conforming to a pending CPUC decision adopting a  
            cost responsibility surcharge (CRS) for customers leaving IOU  
            service for a new municipal utility, provided that the  
            decision will not result in cost shifting to IOU bundled  
            service customers.

          2.Reinstates the AB 1890 direct access statutes by repealing AB  
            1X's direction to suspend direct access.












          3.Establishes additional provisions directing the CPUC to  
            reinstate direct access only for customers with loads of 500  
            kilowatts (kW) or more, subject to five specified conditions  
            which appear to have been met already.

          4.Provides that existing direct access customers who are exempt  
            from the CRS will remain exempt.

          5.Permits aggregation of multiple customers under single  
            ownership to meet the 500 kW threshold.  Directs the CPUC to  
            implement aggregation rules by June 23, 2004.

          6.Requires the CPUC to set the amount of direct access permitted  
            to minimize the potential that an IOU will enter into  
            commitments that will be rendered unnecessary or excessive by  
            customers departing for direct access.

          7.Requires the CPUC to adopt rules to implement the  
            reinstatement of direct access, including notice requirements  
            imposed as a condition of direct access, and provisions to  
            ensure the prompt recovery by an IOU of costs incurred to  
            reinstate and administer direct access.

                                      BACKGROUND
           
          As part of the restructuring of the electric industry, AB 1890  
          authorized direct access.  To avoid the dysfunctional spot  
          market that financially decimated the IOUs and threatened  
          catastrophic rate increases, AB 1X established a structure to  
          permit DWR to buy needed electricity for IOU customers under  
          long-term contracts.  To ensure the predictable revenue stream  
          necessary for long-term contracts, the issuance of  
          ratepayer-backed revenue bonds, and prevent cost-shifting from  
          direct access to bundled service customers, the CPUC was  
          directed to suspend direct access to prevent additional  
          migration of IOU customers.  After a seven-month delay, the CPUC  
          suspended direct access on September 20, 2001.

          Between January and June 2001, the vast majority of customers  
          previously served by direct access providers returned to IOU  
          service, benefiting from retail rates which were lower and more  
          stable than market prices.  However, between July 1, 2001 and  
          September 20, 2001, thousands of predominantly large industrial  










          customers, who had taken service from the state at below-market  
          rates, departed for direct access as market conditions improved.  
           During the July 1 to September 20 period, direct access  
          increased from approximately 2% to approximately 13% of the  
          total IOU load.  Direct access load continues to grow due to the  
          CPUC's liberal interpretation of the Legislature's direction to  
          suspend direct access, including allowing customers to begin  
          direct access service after the suspension date and switch  
          between bundled service and direct access service.

          Meanwhile, the CPUC has proposed to dedicate a share of bundled  
          customer rates to a loan program to defer direct access  
          customers' payment of DWR and IOU procurement costs.  In a  
          decision issued in November 2002 (D.02-11-022), the CPUC capped  
          the payment for these costs applicable to direct access  
          customers at 2.7 cents per kilowatt hour.  The CPUC majority  
          reasoned such a cap was necessary to maintain the viability of  
          existing direct access contracts.

          The 2.7 cent charge won't pay back what direct access customers  
          owe for DWR power already delivered, or for DWR operating costs  
          in the next few years, so a revenue shortfall or  
          "under-collection" results.  Since payment of DWR's costs (bond  
          payment and ongoing revenue requirement) can't be postponed, the  
          CPUC decision shifts the obligation to pay any shortfall from  
          direct access customers to each IOU's bundled customers, be they  
          residential, agricultural, commercial or industrial.  

          According to the CPUC, the direct access shortfall as of January  
          1, 2003 was $609 million.  The shortfall is expected to continue  
          to grow for several years.  Over time, as DWR costs decline,  
          direct access customers' payments are projected to catch up and  
          pay off this under-collection.  In the meantime, IOU customer  
          rates will have to maintained at a level high enough to support  
          this "forced loan" to direct access customers.

          In addition, the CPUC is considering a cost responsibility  
          surcharge applicable to former IOU customers who depart to take  
          service from a new municipal utility.  A proposed decision and  
          two alternate decisions are on the agenda for the CPUC's July 10  
          meeting.

                                       COMMENTS











          1.Conditions and limitations on direct access conflict with  
            existing law.   By repealing AB 1X's requirement that direct  
            access be suspended, the first thing this bill does is  
            functionally reinstate Sections 365 and 366 of the Public  
            Utilities Code, added by AB 1890, which require the CPUC to  
            authorize and facilitate direct access for all customers,  
            without regard to size, recovery of DWR costs, or any other  
            conditions in this bill.  It's not clear what effect the rest  
            of the bill would then have on direct access.  If the  
            additional conditions and limitations contained in the bill  
            are to apply to future direct access,  the author and the  
            committee may wish to consider  placing them instead directly  
            in Sections 365 and 366.

           2.What does "no cost shifting" mean?   This bill incorporates and  
            modifies cost recovery provisions enacted in AB 117 last year,  
            which were intended to prevent cost shifting.  It also  
            essentially endorses the CPUC's existing cost recovery  
            decisions (specifically providing that no new proceedings are  
            required to reinstate direct access).  However, the CPUC  
            decision referenced above requires bundled customers to bear  
            enormous cost obligations which are attributable to direct  
            access customers - in effect requiring bundled business  
            customers to make a loan to their direct access competitors  
            without any assurance of repayment - in order to maintain the  
            viability of existing direct access contracts.  This bill can  
            be read to apply the same cost recovery standard, including  
            the 2.7 cap, to future direct access.

            Given the several hundred million dollar under-collection  
            caused by the CPUC's delay in establishing the CRS, and the  
            additional cost shifting caused by the 2.7 cent cap,  the  
            author and the committee may wish to consider  prohibiting the  
            application of a CRS cap to future direct access transactions  
            and making reinstatement of direct access contingent on  
            repayment of the under-collection attributable to existing  
            direct access customers.

           3.Municipal departing load.   As noted above, an order adopting a  
            cost responsibility surcharge for municipal departing load is  
            pending before the CPUC.  The CPUC's decision will be governed  
            in part by provisions of AB 1X and existing legislative intent  
            that all customers taking service from an IOU after the  
            enactment of AB 1X bear a fair share of specified DWR costs  










            and that any cost shifting between customers be prevented.   
            It's unclear what is added by the provisions of this bill  
            expressing intent to enact subsequent legislation to conform  
            to a CPUC decision which has not yet been issued.   The author  
            and the committee may wish to consider  whether the CPUC needs  
            additional authority or guidance with respect to cost recovery  
            from municipal departing load and, if so, enact operative  
            provisions to address any deficiency identified in existing  
            law, rather than expressing intent to conform to a pending  
            decision that has yet to be approved.

           4.Related legislation  .  SB 888 (Dunn, Bowen and Burton) directs  
            the CPUC to develop, and submit to the Legislature for  
            enactment as a statute, a detailed proposal for implementation  
            of a "core/non-core" model for retail electric service that  
            achieves specified objectives.  SB 888 is pending in the  
            Assembly.

            AB 428 (Richman) reinstates direct access under a  
            "core/non-core" model.  AB 428 is pending in this committee.
           
                                   ASSEMBLY VOTES
           
          Assembly Floor                     (60-1)
          Assembly Appropriations Committee  (22-0)                      
          Assembly Utilities and Commerce Committee                       
          (11-1)

                                       POSITIONS
           
           Sponsor:
           
          Author

           Support:
           
          California Manufacturers & Technology Association

           Oppose:
           
          California Coalition of Utility Employees
          California Municipal Utilities Association
          City of West Sacramento
          Northern California Power Agency










          Southern California Public Power Authority


          










          Lawrence Lingbloom 
          AB 816 Analysis
          Hearing Date:  July 8, 2003