We had been in discussions with SCE a few months back to remove the QF
requirement in their Rule 21.  At the time they said they "could" not
because the construct of their standby rate did not provide adequately
provide recovery for standby service (particularly for non-demand related
tariff schedules).  The rejection was were we left the subject with SCE.
Their move to submit an advice letter on the subject comes as a surprise
to me given their prior response.

We will not be protesting with the presumption that the standby tariff
would not prejudice future work on standby tariff rate design.  Generally
speaking, the QF requirement is ridiculous and should be removed
immediately.  For this reason, we are supportive of it happening now
through this advice filing.  I do not want to see the prohibition against
non-QF facilities for up to another 9 months (rough estimate based on
time-frame articulated in the DG order).



Jeff_Dasovich@enron.com writes:
>
>
>shouldn't this be the subject of the upcoming cec workshops?  isn't the
>timing
>of the filing, well, awkward?  wouldn't it be better if they withdrew and
>brought as a proposal to the workshops?
>
>