8. Consistency with State Energy Policy Objectives
SoCalGas asserts that its AMI proposal is consistent with state energy policy objectives, as established in previous Commission actions and documents such as the state Energy Action Plan, as well as in previous Commission decisions on AMI proposals from electric and dual-fuel utilities. SoCalGas points to Commission policy expressed in the Energy Action Plan and elsewhere that favors energy conservation and efficiency measures for both electricity and gas use. Specifically, SoCalGas asserts that a high priority in the Energy Action Plan "is to meet California's energy growth needs while optimizing energy conservation and resource efficiency" for both electricity and natural gas,28 and that demand side management options (including conservation, energy efficiency, and demand response) are preferred ways for meeting future energy needs. SoCalGas argues that by providing customers with frequent consumption information, its AMI proposal will encourage energy conservation and provide customers with opportunities to better manage their energy use, consistent with this policy. In addition to empowering consumers, SoCalGas argues that implementation of AMI in its service territory would result in environmental benefits supported in previous Commission policy statements, such as a reduction in greenhouse gas emissions.29
SoCalGas also notes that the Commission directed SDG&E, Pacific Gas and Electric Company (PG&E), and SCE to develop and submit applications to implement AMI systems, and has now authorized all three of these companies to implement AMI systems throughout their service territories; the systems approved for SDG&E and PG&E include gas as well as electric AMI components. SoCalGas argues that these previous decisions show a Commission interest in encouraging AMI systems (whether for electricity or gas) as a means for increasing demand side management.
8.1. Party Positions
DRA, TURN, and UWUA note that previous Commission statements on the desirability of AMI systems focused on the ability of those systems to support time-differentiated tariffs for electricity. TURN suggests that the Commission originally encouraged AMI systems in order to support dynamic pricing tariffs and encourage demand response and reductions of energy use at specific times of peak electric demand. DRA states that "demand response, the primary electric AMI benefit identified by the [Energy Action Plan], does not apply to natural gas."30 DRA asserts that the fact that the Commission has encouraged AMI for electric and dual fuel utilities does not mean that the same policy would support a stand-alone gas AMI system. Like TURN, DRA argues that statements in favor of demand-side management to meet energy needs in the Energy Action Plan and elsewhere really support these strategies as an alternative to electric generation, and that the same principles do not necessarily apply to reducing gas usage.
8.2. State Policy Supports Development and Implementation of Cost Effective AMI for Gas or Electric Utilities
As noted by DRA and other parties, previous Commission statements about the desirability of AMI systems have focused on their usefulness as a tool for managing electric usage, especially at times of peak energy demand. Despite this initial focus on electricity, however, many of the potential benefits of AMI are equally applicable to natural gas systems. Commission policies in favor of demand-side management, especially conservation and energy efficiency, are as relevant to natural gas usage as to electric usage. This is reflected in existing energy efficiency programs, which are targeted at natural gas as well as electric end uses and customers. Although the absence of demand response benefits from a gas-only AMI system eliminates a potential category of benefits from the business case analysis for such as system, it does not negate our expressed policy interest in encouraging demand side management options to meet the state's existing and future energy needs. This principle applies not only to electric use, but also to natural gas. In addition, conservation results in real (if sometimes difficult to quantify) environmental benefits consistent with Commission policy to reduce greenhouse gas emissions and combat global climate change.
In addition, we favor expanding the information and tools available to consumers in order to empower them to manage their usage of electricity and gas, so they can better and more efficiently meet their own energy needs. Providing consumers with more, and more timely, information on their energy usage enables customers to make more educated choices on conservation, energy efficiency, and energy consumption in general, enabling them to save money on energy bills. We expect a well-designed, cost effective gas AMI system to support Commission policy by educating consumers about their own energy use, and encouraging them to explore options for managing their energy use and saving money.
In these ways, a gas-only AMI system is consistent with Commission energy policy objectives of increasing energy conservation and demand-side management, reducing greenhouse gas emissions, and providing customers with information and tools that allow them to manage and make educated decisions about their energy use.
28 SoCalGas Exhibit 1, at I-5.
29 SoCalGas Exhibit 1, at I-6.
30 DRA Opening Brief, at 3.
