On behalf of the Alliance For Lower Electric Rates Today ("ALERT"), we appreciate this opportunity to provide these draft amendments to the Virginia Electric Utility Restructuring Act, SB1269, Chapter 411 of the 1999 Acts of Assembly (the "Restructuring Act"). As with past submissions, we have arranged these proposed amendments by subject matter, and are offering them as an interim "placeholder" to permit the appropriate flexibility as we move into the next session of the General Assembly.
We have participated in numerous meetings with other Stakeholders as we attempt to reconcile conflicting positions. We are not prepared at this time to offer suggestions as to the specifics for reconciling the Stakeholders’ positions, where such reconciliation may possible. Such suggestions as to reconciliation could be read or interpreted to reflect a change in ALERT's position on a particular subject area. As the issues addressed herein are inextricably linked to other restructuring issues, ALERT reserves the right to adhere to or modify its stated positions on these and other issues as the debate moves forward.
Changes To Aggregator Definition/Licensing Provisions:
As with issues related to metering and billing, ALERT continues to work with Staff, the OAG, and other Stakeholders to reconcile positions on changes to the definition of "Aggregator" set forth in §56-576, and, if appropriate, to the licensing provisions for aggregators set forth in §56-588. At this time, ALERT offers the following changes to the definition of "Aggregator" found in §56-576: