6. Overview of Party Positions
DRA, TURN, and UWUA all participated actively in this proceeding. All three parties oppose the SoCalGas AMI proposal, for a variety of reasons.
6.1. DRA
DRA provided analysis on several issues in this case. DRA focused much of its participation in this proceeding on the cost effectiveness of the SoCalGas AMI proposal. In addition, DRA questions the need for a gas-only AMI system, given that gas does not offer demand response benefits. DRA also disputes several aspects of the SoCalGas cost effectiveness analysis, arguing that SoCalGas overestimates the benefits of its proposal (including the cost savings from elimination of meter readers and benefits attributable to gas conservation enabled by gas usage feedback to customers) and underestimates certain costs.
6.2. TURN
Like DRA, TURN focused much of its participation in this proceeding on the cost effectiveness of the SoCalGas AMI proposal. In addition, TURN rejects the SoCalGas claim that Commission policy as established in the Energy Action Plan and other sources supports deployment of AMI for a gas-only utility. TURN asserts that SoCalGas overestimates the benefits of its AMI proposal. TURN also agrees with the DRA recommendation that the conservation benefits claimed by SoCalGas should be reduced, and asserts that if these changes are made to the business case, the SoCalGas proposal would no longer be cost effective.
6.3. UWUA
Like DRA and TURN, UWUA argues that the SoCalGas AMI proposal is not cost effective. In addition, UWUA notes that a large part of the benefits SoCalGas claims from this project would be due to operational savings from the elimination of meter readers in the post-deployment period. UWUA concurs with DRA and TURN that SoCalGas overestimates certain benefits and underestimates costs, and asserts that most of the costs of the AMI proposal would occur in the near future, whereas the benefits would accrue much later in the analysis period for the business case.
