|Draft Gap Analysis Released in Customer Choice Project|
The California PUC’s Customer Choice Project Team has prepared a draft Gap Analysis following the issuance in August of the paper entitled “California Customer Choice: An Evaluation of Regulatory Framework Options for an Evolving Electricity Market.” This will be supplemented by an en banc hearing on October 29, 2018. Written comments on the draft Gap Analysis are due November 13, 2018. A draft Choice Action Plan is still under development. The Choice Action Plan will serve as a roadmap of actionable steps for the Commission and other government entities to address identified issues in the Gap Analysis.
The draft Gap Analysis identifies issues in three categories – consumer protection, duty to serve, and reliability and energy procurement – related to the current and expected shifts in the electric market related to significant increases in consumer participation in CCAs, direct access and solar. Each issue is identified, current status of review at the Commission explained, nature of the gap identified, and customer choice action recommendations given.
Within the category of consumer protection, the following issues are identified in the draft Gap Analysis:
*Access to customer-specific data by CCAs, ESPs, and third party DER providers while ensuring consumer protection and privacy is maintained;
*Disclosure of electricity content sold by LSEs, including unbundled RECs and imports;
*Should all LSEs be required to conform to the same protocols for disconnection of nonpaying residential customers (currently only utilities can disconnect for nonpayment);
*Should LSEs in addition to the utilities be responsible for emergency response requirements;
*Provider of Last Resort function and whether utilities should continue to serve in that role;
*Protecting consumers from slamming and cramming by ESPs and CTAs;
*Protecting consumers from predatory sales tactics in the sale of rooftop solar;
*Provision of a centralized online location for residential consumers to compare the rates of all LSEs;
*Impact of rate design on behind-the-meter and other resources;
*Should CCAs default customers to TOU rates;
Within the category of duty to serve, the following issues are identified in the draft Gap Analysis:
*Whether additional issues related to DER should be addressed in Commission proceedings;
*Whether reliability is being sufficiently addressed through resource adequacy requirements;
*Review of existing affiliate transaction rules in view of increasingly disaggregated market;
Within the category of reliability/resource procurement, the following issues are identified in the draft Gap Analysis:
*Contracting for reliability resource requirements;
*Electrification of transportation, buildings and appliances.
The full texts of the Draft Gap Analysis and En Banc Hearing Agenda are available on the NEM Website.