BILL ANALYSIS                                                                                                                                                                                                              1
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                SENATE ENERGY, UTILITIES AND COMMUNICATIONS COMMITTEE
                            MARTHA M. ESCUTIA, CHAIRWOMAN
          

          SB 641 -  Campbell                                Hearing Date:   
          April 26, 2005             S
          As Introduced:  February 22, 2005       FISCAL           B
                                                                        
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                                      DESCRIPTION
           
           Existing law:  

             1.   Authorizes retail competition (direct access) within the  
               service areas of the investor-owned utilities (IOUs). 
               (AB 1890 (Brulte), Chapter 854, 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.   
               The CPUC suspended direct access as of September 20, 2001.
               (AB 1X (Keeley), Chapter 4, Statutes of 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.   Repeals the provisions of AB 1X suspending direct access  
               during the term of DWR contracts and instead requires the  
               CPUC to permit direct access, pursuant to a "core/non-core"  
               structure to be defined by the CPUC.

             2.   Requires the CPUC's core/non-core structure to require  
               direct access customers to bear a fair share of DWR's  
               electricity costs or to accept a proportionate allocation  
               of the electrical generation resources used by the IOU to  











               serve the departing customer.

                                      BACKGROUND
           
          The "core/non-core" approach to utility service is derived from  
          natural gas service, where customers are divided into core and  
          non-core classes according to consumption.  Gas utilities are  
          required to procure and deliver a portfolio of gas supplies  
          sufficient to serve their core (residential and small  
          commercial) customers.  Non-core customers must arrange for  
          procurement and transportation of their own gas supplies.  

          As part of the restructuring of the electric industry, AB 1890  
          authorized direct access.  While customers were allowed to  
          choose alternate providers of energy, the IOUs' obligation to  
          serve all customers remained and customers large and small were  
          entitled to remain with, or return to, bundled IOU service.   
          Historically, IOU electric customers have been entitled to the  
          portfolio of supplies procured to serve them without regard to  
          their size.

          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 has grown since that time  
          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 dedicated 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 (Decision 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 doesn't cover 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.

          According to the CPUC, the current direct access  
          under-collection is about $833 million statewide.  This  
          under-collection is projected to grow to about $1.3 billion  
          before it begins to get paid down.  Over time, as DWR costs  
          decline, direct access customers' payments are projected to  
          catch up and pay off this under-collection.  The CPUC estimates  
          the under-collection will be paid off in 2011 in PG&E territory,  
          2016 in SCE territory, and 2006 in SDG&E territory.  In the  
          meantime, IOU customer rates must be maintained at artificially  
          high levels to support this "forced loan" to direct access  
          customers.






















                                       COMMENTS
           
              1.   Cost shifting provisions duplicative of and weaker than  
               existing law.   This bill requires direct access customers  
               to bear a fair share of DWR's electricity purchase costs  
               (or to accept a proportionate allocation of the energy).   
               Existing law already provides that all customers taking  
               service from DWR, including those who later depart for  
               direct access, should bear a fair share of DWR's  
               electricity purchase costs, as well as existing DWR and IOU  
               contract obligations.  Existing law further expresses the  
               intent of the Legislature to prevent any cost shifting  
               between customers.  While the CPUC relied on these  
               provisions to impose a cost responsibility surcharge on  
               direct access customers, it ignored their clear intent when  
               it capped the surcharge and created the "forced loan" cost  
               shift from direct access customers to bundled customers.   
               This bill's "cost shifting" protections are incomplete and  
               significantly weaker than those already in current law,  
               which have been insufficient to prevent cost shifting  
               decisions by the CPUC.

              2.   Core/non-core undefined, left to CPUC.   This bill  
               doesn't specify any of the terms of the core/non-core  
               structure it requires.  It doesn't even define  
               "core/non-core."  Given the CPUC's record of abusing the  
               limited discretion granted by AB 1X and AB 117 in its  
               effort to sustain direct access through ratepayer  
               subsidies,  the author and the committee may wish to  
               consider  the wisdom of granting the CPUC unfettered  
               discretion over the design of a core/non-core structure.
           
             3.   Fewer customers to carry forced loan.   This bill doesn't  
               address the burden on bundled customers resulting from the  
               CPUC's current direct access program.  If the forced loan  
               is left in place, and additional customers are allowed to  
               move from bundled service to direct access, the  
               per-customer share of the forced loan will increase.  To  
               avoid increasing the burden of direct access customer costs  
               on bundled customers,  the author and the committee may wish  
               to consider  postponing additional direct access until the  
               forced loan is repaid.
           
             4.   Mixed signals to IOUs regarding investments.   AB 57  










               (Wright), Chapter 835, Statutes of 2002, requires IOU  
               procurement plans to "enable the (IOU) to fulfill its  
               obligation to serve at just and reasonable rates."  The  
               IOUs are currently expected to meet load growth and replace  
               the DWR contracts over the next several years via the  
               procurement process initiated by the CPUC pursuant to AB  
               57.  The CPUC has recently approved contracts for new power  
               plants to serve IOU customers which will be completed in  
               the 2006-2009 timeframe.  The IOUs are required to buy  
               additional renewable power under long-term contracts  
               pursuant to SB 1078 (Sher), Chapter 516, Statutes of 2002,  
               the Renewable Portfolio Standard (RPS).  The Governor, the  
               energy agencies and pending legislation have endorsed  
               accelerating the RPS schedule.  Under the CPUC's long-term  
               procurement decision, IOUs will be obligated to build or  
               buy resources to meet a 15-17 percent reserve margin by  
               2006.  The energy agencies have adopted a goal of  
               decreasing per capita energy consumption.  

               The IOUs, and their customers, are the primary vehicle to  
               deliver all of the above.  These initiatives, on top of  
               existing obligations for utility generation, qualifying  
               facilities, and DWR contracts, will make the IOUs'  
               portfolios stable, but also fairly inflexible.

               Against this backdrop, this bill permits the IOU customers  
               who would support all these initiatives to leave for direct  
               access.   The author and the committee may wish to consider   
               how an expansion of direct access can be reconciled with  
               other policy goals embodied in existing law and the Energy  
               Action Plan.

                                       POSITIONS
           
           Sponsor:
           
          Constellation New Energy

           Support:
           
          Sempra Energy (if amended)

           Oppose:
           










          Coalition of California Utility Employees
          The Utility Reform Network







          















          Lawrence Lingbloom 
          SB 641 Analysis
          Hearing Date:  April 26, 2005