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1. Summary

2. Procedural Background

3. Late-Filed Exhibits

4. Summary of the Application

5. Standard of Review and Criteria for Review of Proposals

1. Should the Commission approve SoCalGas's proposed AMI deployment activities and funding, either as proposed in this application or with modifications?

a. Are the various elements of the proposed SoCalGas AMI business case and deployment plan reasonable?

b. Are the technology choices proposed by SoCalGas appropriate and technically feasible? Specific elements of the technology plan that should be evaluated include (but are not limited to):

i. Is the proposed SoCalGas-only communication system reasonable? What if any additional communication options, such as shared communications infrastructure between SoCalGas and other utilities with overlapping jurisdictions, should be considered?

ii. Is the battery proposed to power the AMI system reasonable? What if any additional options for powering the meters and communications systems should be considered?

c. Is the SoCalGas AMI proposal for a gas-only AMI system consistent with state energy policy objectives or desirable for other policy reasons?

d. Is the SoCalGas AMI proposal cost-effective, and will it provide lasting value for SoCalGas's customers?

2. If the proposal meets all of the criteria listed in question 1, above, should the Commission adopt the ratemaking treatment proposed by SoCalGas for the recovery of costs associated with any approved AMI deployment activities?

6. Overview of Party Positions

6.1. DRA

6.2. TURN

6.3. UWUA

7. Reasonableness and Feasibility of Technology Choices

7.1. Communications System

7.1.1. SoCalGas Proposal

7.1.2. Party Positions on Communications System

7.1.3. Discussion of Proposed Communications System

7.2. Battery Choice

7.2.1. Party Positions

7.2.2. Analysis

7.3. Additional Elements

7.3.1. Analysis of Additional Elements

8. Consistency with State Energy Policy Objectives

8.1. Party Positions

8.2. State Policy Supports Development and Implementation of Cost Effective AMI for Gas or Electric Utilities

9. Cost Effectiveness

9.1. Benefits

9.1.1. Terminal Value

9.1.2. Cost Savings from Elimination of SoCalGas Meter Reading Workforce

9.1.3. Conservation Benefits SoCalGas Methodology for Estimating Conservation Benefits Party Positions on Conservation Benefits Discussion of Conservation Benefits

9.2. Costs

9.2.1. Project Contingency Funding

9.2.2. Workforce Impacts and Retention Funding

9.3. The SoCalGas AMI Proposal is Cost Effective

9.4. The SoCalGas AMI Project is Approved

9.5. Ratepayer Protections

9.5.1. Sharing Mechanism

9.5.2. Access to AMI Data

9.5.3. Workshop and Reporting on Conservation Impacts

10. Categorization and Assignment of Proceeding

11. Comments on Proposed Decision

Findings of Fact

Conclusions of Law

· Southern California Gas Company shall reduce its contingency fund from 10% to 7%, resulting in a $68.7 million total allowance for contingencies.

· Southern California Gas Company shall supplement by $1 million its funding for workforce retention and retraining. This fund is established to better protect the employment interests of Southern California Gas Company's meter reading workforce and should be used to extend severance, vocational training, and other transitional opportunities to employees affected by the decision to pursue advanced metering infrastructure.

1 AMI consists of both metering and communications infrastructure.

2 Motion of Utility Workers Union of America, Local 132 to Admit Late-Filed Exhibit, June 10, 2009, at 3.

3 Response of Southern California Gas Company to Motion of Utility Workers Union of America, Local 132 to Admit Late Filed Exhibit, June 24, 2009, at 2.

4 See for example, D.05-09-044 at 5.

5 February 19, 2004 Assigned Commissioner's Ruling in R.02-06-001.

6 SoCalGas Exhibit 1, p. I-4.

7 SoCalGas Exhibit 1, p. I-4.

8 SoCalGas Exhibit 2, p. II-14.

9 SoCalGas Exhibit 4, p. IV-6.

10 SoCalGas Exhibit 3, p. III-37.

11 SoCalGas Exhibit 4, p. IV-7.

12 SoCalGas Exhibit 4, pp. IV-7 and IV-8.

13 SoCalGas Exhibit 4, p. IV-8.

14 SoCalGas Exhibit 2, p. II-7.

15 SoCalGas Exhibit 2, p. II-6.

16 SoCalGas Exhibit 2, p. II-8.

17 Exhibit 2, p. II-7.

18 SoCalGas Exhibit 12, p. III-1.

19 SoCalGas Exhibit 12, p. III-1.

20 SoCalGas Exhibit 12, p. III-3.

21 SoCalGas Exhibit 23, p. III-4.

22 SoCalGas Exhibit 12, p. III-6.

23 UWUA Opening Brief, at 17.

24 DRA Opening Brief, at 37.

25 SoCalGas Exhibit 24, at 10.

26 SoCalGas Exhibit 24, at 10.

27 SoCalGas Exhibit 24, at 7.

28 SoCalGas Exhibit 1, at I-5.

29 SoCalGas Exhibit 1, at I-6.

30 DRA Opening Brief, at 3.

31 SoCalGas witness Mueller RT, Volume 2, at 140, lines 16-19.

32 SoCalGas Exhibit 7, at 8.

33 See California Standard Practice Manual, http://www.energy.ca.gov/greenbuilding/documents/background/07-J_CPUC_STANDARD_PRACTICE_MANUAL.PDF.

34 UWUA Opening Brief, at 9.

35 UWUA Opening Brief, at 10-11.

36 UWUA Opening Brief, at 10.

37 D.09-12-046 at 54.

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