4. Other Issues Pertaining to Deployment Plan and SB 17 that Require Resolution at this Time
4.1. How Should the Commission Consider/Approve Deployment Plans?
SB 17 requires IOUs to file Smart Grid Deployment Plans with the Commission by July 1, 2011 for Commission approval. The Ruling Amending Scope proposed that the IOUs file and the Commission review Smart Grid Deployment Plans in a single regulatory proceeding. The ruling directed parties to provide comments on whether this is the appropriate process for consideration and approval of deployment plans, or whether the Commission should review deployment plans via separate utility applications.
Of the parties that expressed an opinion on this issue, most agree with the Ruling Amending Scope's proposed single-proceeding process for initial deployment plan approval.238 Greenlining supports the proposed process, arguing that:
... a single proceeding will allow parties interested in Smart Grid matters to participate more easily. In addition, the single proceeding can lead to more effective collaboration and a central clearinghouse with information about best practices and other beneficial information. A single proceeding would also better allow parties and the Commission to compare each utility's deployment plan to ensure parity between service territories.239
CLECA similarly argues that a single proceeding would allow utilities to learn from the experiences of other utilities, "as opposed to having [them] all pursue numerous similar initiatives at once."240 TURN agrees, stating that it is "more efficient and sensible to evaluate all utility deployment plans in a single proceeding, so as to best compare the technologies, baselines and plans."241 EDF explains similarly that "having plans considered in the same proceeding ensures[s] that they are based on the same standards and principles across utilities."242
While PG&E supports the review of initial deployment plans in a single proceeding, it also urges the Commission to "allow a good deal of flexibility and leeway in what the plans must contain and demonstrate."243
UCAN does not directly support the single-proceeding review process. Instead, it recommends deferring that issue to the IOUs, two of which have expressly supported it.244 UCAN further states that it "envisions an annual or biannual submission of deployment plans by each utility, akin to the utility Long-Term Resource plans that are currently submitted to the Commission."245 It also urges the Commission to require the IOUs to submit these plans to an organized set of stakeholders similar to the Technical Advisory Panel established for SDG&E's smart meter deployment prior to submission to the Commission.246
SCE agrees that the deployment plans should be evaluated and approved in a single proceeding and further recommends the Commission approve or deny the initial deployment plans within 120 days of submission.247
4.1.2. Discussion: Combined Proceeding with SCE, SDG&E and PG&E
In providing input on how the Commission should consider and approve Smart Grid Deployment Plans, most parties support the single-proceeding process. Some parties, however, confound this issue with how the Commission should consider and approve Smart Grid investments.248 For example, CESA identifies problems with considering Smart Grid investments in GRCs and then recommends against considering deployment plans using that process.249 Review of investments and review of the deployment plans are two different things. CESA, however, seems to reason that because the GRC process may be inappropriate for consideration of Smart Grid investments, it is also inappropriate for consideration of deployment plans.250
Upon our review of the comments, we conclude that a single proceeding involving SCE, PG&E and SDG&E will ensure the most efficient and thorough review of the initial Smart Grid Deployment Plans. Not only will a single proceeding process "help ensure some congruity"251 in the Commission's consideration of baselines, plans, and technologies, but it will also allow interested parties to participate more easily. We therefore reject separate review of each utility's deployment plan. While each utility is required to file a separate application submitting its Smart Grid Deployment Plan, we expect to review the plans in a consolidated proceeding.
In response to parties that confounded the issue of how the Commission should review specific proposed Smart Grid investments with Smart Grid Deployment Plans, we also agree that the GRC process is not appropriate for consideration and approval of Smart Grid Deployment Plans. The GRC process is used by the Commission to determine the reasonableness of investments and is used by the utilities to seek recovery and approval of investment costs. Section 8364(a) requires the IOUs to submit a Smart Grid Deployment Plan for Commission approval by July 1, 2011. The purpose of § 8364(a) is not to approve or deny specific investments, but rather to approve or deny the IOUs' proposed deployment plans.
4.2. How Should the Commission Review Proposed Revisions to Deployment Plans?
The Ruling Amending Scope proposed that approved Smart Grid Deployment Plans be used to establish a baseline for measuring deployment of Smart Grid technologies and capabilities. It also proposed requiring the IOUs to file status reports that update the plan every year starting October 1, 2010 and continuing through October 1, 2020. The ruling proposed that the reports reflect information that is current as of June 30 of the year in which the report is filed.
While the parties agree that the Commission should review and approve initial deployment plans in a single proceeding, there is a wider variety of opinions regarding the Commission's review of annual status reports, including updates to the deployment plans. Most parties agree that the Commission should provide a process for annual approval of deployment plan updates.252 Parties differ, however, on whether this process should take place as part of a single proceeding or via separate advice letter filings or applications.253 These updates are important as a reference point for Smart Grid investments and to inform the Commission's annual report to the Legislature, as required by SB 17.254
SCE argues that:
...updates will...prove critical if Deployment Plans are referenced in reasonableness reviews of specific Smart Grid investment proposals. In order that Deployment Plans effectively serve this function, they must reflect a current description of the policy, operational, and business drivers of Smart Grid development.255
CEERT recommends the Commission review annual deployment plan progress reports and updates as part of a single proceeding.256 PG&E disagrees, arguing that "updates and revisions to individual utility plans should be considered in individual utility proceedings, consistent with the different procedural schedules for utility GRCs and individual applications in which Smart Grid Deployment Plans may be implemented or used."257 EDF, in contrast, asserts that "considering updates in one proceeding allows utilities to learn from each other and the public to better monitor the progress," and "having plans considered in the same proceeding ensures that they are based on the same standards and principles across utilities."258
SDG&E and DRA propose that the IOUs should update deployment plans annually via the advice letter process.259 "SDG&E believes an annual update process can provide for adequate flexibility and opportunity for utilities to refresh and update...their deployment plans" and "will present an opportunity for others to submit suggested revisions and refinements to [their plans]."260 DRA suggests using a Tier 3 advice letter with an extended protest period of 30 days to allow parties the opportunity to comment on updates.261 It further suggests requiring the IOUs to file updates through an application after five years.262 While SDG&E agrees with annual updates, it cautions against "overly burdensome procedures" in response to DRA's proposal to allow thorough vetting of the updates through an extended advice letter process.263 SDG&E is concerned that such a process will enable the re-litigation of earlier agreed-upon deployment plan components.264 Therefore, it agrees with the "need to modify and adapt Smart Grid Deployment Plans to changes in technology and to accommodate consumer behavior" and supports annual updates, but it recommends that these annual submissions serve to "maintain an updated smart grid vision [rather than to] advise the Commission on a [utility's] progress in implementing smart grid activities that have already been addressed."265 SDG&E asserts that thorough vetting can take place in the context of the Commission's review of Smart Grid investments-through GRCs or special applications.266
The Ruling Amending Scope proposes that status reports be filed every year starting on October 1, 2010. PG&E disagrees with this proposed update schedule.267 Instead of "establish[ing] a particular frequency of updating or reporting on Smart Grid progress," the Commission should require an initial status report two years after approval of the initial plans and decide the frequency of subsequent reports based on that report.268 SCE also opposes the Ruling Amending Scope's proposed start date of October 1, 2010 for status report filings. Instead, it recommends these filings begin July 1, 2011 since the IOUs will not have a deployment plan in place to update by October 1, 2010.269 DRA similarly agrees that requiring an update filing on October 1, 2010 is illogical and instead recommends annual updates commence one year from the date the deployment plans are adopted, in 2012.270
The Ruling Amending Scope proposes that annual reports "should also reflect information that is current as of June 30 of the year in which the report is filed." SCE supports annual reporting but recommends that status reports be current as of December 31 of the preceding year because the utility planning cycle and compilation of metrics occurs on a calendar-year basis.271
Finally, in terms of Commission action on annually submitted updates, SCE recommends the Commission decide whether to accept or reject the updates within 75 days of submission.272
4.2.2. Discussion: Commission Will Update Procedure Following Review of Initial Deployment Plans
Due to the importance of the Smart Grid, because this technology is rapidly changing and because the Commission will use deployment plans in assessing proposed investments, it is critical that these plans be up-to-date and "reflect a current description of the policy, operational, and business drivers of Smart Grid development."273 The plans should "be flexible and considered as living documents, which can be updated and revised as necessary when new technologies and standards emerge."274
At this time, we conclude that the best way for the Commission to proceed is to review the first Smart Grid Deployment Plan for each utility, as discussed above, and as part of that proceeding, we will address when and how an update should be filed.
4.3. How Should the Commission Review/Consider Specific Smart Grid Investments?
The Ruling Amending Scope sought comments from parties to determine whether a GRC, special application or some other procedure offers the best venue for the review of Smart Grid investments. The Ruling Amending Scope noted that the parties addressing this issue had not voiced a clear preference on which venue would be best.275 The Ruling Amending Scope invited parties to comment further.
DRA, in its comments argued that "[g]iven the evolving and vague nature of the Plans envisioned by SDG&E, there is no basis for compliance with Plans serving as strong evidence in reviewing specific investment requests.276
SCE argues in support of either GRC or special application reviews of infrastructure investments, stating:
SCE also agrees with the position stated in the Ruling that "Smart Grid expenditures should be considered in GRCs, and in limited cases in special applications." While SCE supports the use of the GRC proceedings to consider many Smart Grid investment proposals, SCE reaffirms its comments made in Phase I of this rulemaking. Our earlier comments indicated that some Smart Grid projects may need to be considered in special proceedings. The Commission's flexibility with regard to regulatory approach is essential.277
PG&E raises the practical issue of timing:
Because utilities are on different GRC schedules, the level of detail available regarding specific Smart Grid projects, investments and programs may vary, depending on whether a utility is ready to propose specific investments and expenditures in their detailed, current GRC applications or other applications.278
4.3.2. Discussion: Application or GRC Offer Appropriate Procedures for Reviewing Smart Grid Investments
Only TURN expressed a preference that any Smart Grid investments should be considered in a GRC rather than in a special application, although PG&E has raised practical issues that arise from the timing of GRCs. Our own conclusion is consistent with these observations - either a review in a GRC or in an application can provide sufficient Commission oversight of an investment.
Furthermore, since SB 17 aims to promote the deployment of a Smart Grid in California, we conclude that a utility may seek approval for Smart Grid investments either in its GRC and/or through separate applications. We believe either review path - as part of a GRC review of investments or in a separate application - offers a practical way to review proposed investments in a manner consistent with the goals of SB 17.
4.4. What Reports Should the Commission Require Pertaining to Smart Grid Investments? When Should They be Filed?
SDG&E states that annual updates "should provide an opportunity for utilities to refresh and update ... their deployment plans without re-litigating" the deployment plans that reflect technology developments and customer needs. Additionally, SDG&E states that it is more important that annual reports maintain "an updated smart grid vision than to advise the Commission on a utilities progress in implementing smart grid activities" already addressed elsewhere.279 SDG&E comments that the Scoping Ruling proposes a status report to be filed by October 1, 2010, but the deployment plan will not be filed until July 2011, so "it is unclear what form this first status report should take, given that each utility will not have yet filed or received approval of their plans."280
SCE supports an annual deployment plan report that will inform the Commission's annual report to the Governor and Legislature. SCE comments that this update will also be critical to the extent a deployment plan is referenced in any reasonableness review of specific Smart Grid investments. SCE disagrees with the Scoping Ruling's proposal that the annual report be "current as of June 30 of the year in which the report is filed."281 SCE states that since the utility planning cycle and compilation of metrics will occur on a calendar-year basis, the annual report should be current as of December 31st of the preceding year.282 Furthermore, SCE argues that since the first deployment plan will not be filed until July 1, 2011, the utilities should not be required to file a deployment plan report until 2012. In the alternative, SCE proposes that for 2010 and 2011, the IOUs file a report based on their adherence to metrics as approved by the Commission, as well as any new metrics that may be appropriate as the Smart Grid develops.283
PG&E argues that the Commission should not "establish a particular frequency of updating or reporting on Smart Grid progress;"284 instead, PG&E proposes to provide an initial status report on the deployment plan two years after approval of its initial deployment plan, or 2013. Only after that report is reviewed should the Commission set a schedule for subsequent reports and updates.285
IREC encourages the Commission to keep this proceeding open as a means to continue identification of evolving infrastructure needs. In order to accommodate this evolving process, IREC recommends that the Commission require updated deployment plans to identify new and additional infrastructure needs and functionalities.286
EDF supports requiring annual reports on the deployment plan.287 Cisco also states support for annual updates "since it is likely that plans will be modified over time."288
CEERT supports requiring an annual status report, including any updates to a deployment plan. CEERT argues that this annual status report would assist the Commission in preparing its annual report to the Governor and Legislature, as required by SB 17. Additionally, CEERT argues that SB 17 does not contain a sunset date and the Commission may want to consider extending utility reporting requirements beyond 2020. Furthermore, CEERT suggests that the Commission may choose to use the updates in a more programmatic fashion, analogous to an approved procurement plan. According to CEERT, this process "can accelerate the maturation of" the Smart Grid.289
DRA supports the submission of annual status reports "to measure progress relative to the baseline that reflects historical developments and includes an update of future plans."290 DRA suggests that the Commission provide more specifics about how the Commission will treat an update of future plans in the case of less cost-effective technology or optimistic forecasts than originally included in the initial deployment plan.291 DRA also recommends that the Commission use annual status reports "as a means to track and review all Smart Grid investments as a whole," that will allow the Commission to evaluate and potentially restructure Smart Grid policy where necessary.292 DRA agrees with SCE and SDG&E that the initial status report should not be filed until 2012, and agrees with SCE that the initial reports should focus on metrics. Additionally, DRA does not oppose SCE's request that annual reports be filed on a calendar year basis.293
TIA states that annual reports will be helpful to the Commission "as utilities continue to adopt and integrate new solutions as they become available." Additionally, TIA comments that the Commission should expect flexibility in the updates as they will change over time.294
4.4.2. Discussion: Annual Reports Are Needed to Prepare an Annual Report to the Legislature
There is general consensus for an annual report on the utilities' deployment actions. However, there is some disagreement about the content of the initial annual reports and when they should start. SCE, PG&E and DRA agree that the first deployment plan report should not occur until 2012. SCE proposes that the 2010 and 2011 annual reports should focus on meeting any adopted metrics, which DRA does not oppose. Additionally, DRA proposes that the 2010 report include the initial baseline assessment.
As discussed above,295 we will reject DRA's request that the 2010 annual report have a baseline measurement; instead, the baseline is to be included in the utilities' initial deployment plan filing on July 1, 2011.
The Commission is sympathetic to the arguments of SCE that since the deployment plans are not scheduled to be filed until July 1, 2011, the 2010 and 2011 annual reports will not contain very much information on the deployment of a Smart Grid.
SB 17 is very clear. The Commission is to file a report with the Governor and the Legislature by January 1, 2011, and every year thereafter, with the Commission's "recommendations for a smart grid, the plans and deployment of smart grid technologies by the state's electrical corporations, and the costs and benefits to ratepayers."296 We anticipate that the January 1, 2011 report will include a review of the steps taken by this Commission and the January 1, 2012 report will be based on the filings made in the utilities' first Smart Grid Deployment Plans that will describe the current state of the grid.
The Commission will require the IOUs to file an annual report that describes their current initiatives in regards to Smart Grid deployments and investments. The first report shall be due on October 1, 2012. Each annual report must include the following:
· A summary of the utility's deployment of Smart Grid technologies during the past year and its progress toward meeting its Smart Grid Deployment Plan;
· The costs and benefits of Smart Grid deployment to ratepayers during the past year; and
· Current initiatives for Smart Grid deployments and investments.
Additionally, as described above,297 the annual reports shall also include updates to a utility's security risk assessment and privacy threat assessment. Furthermore, the Commission will require the annual reports starting on October 1, 2012 to address the utility's compliance with North American Electric Reliability Corporation security rules, as well as future security guidelines and standards as identified by NIST and adopted by FERC. This will allow the Commission to monitor and ensure that the utilities are being pro-active in protecting the grid from security risks or threats.
The parties agree that October 1 of each year is satisfactory for the filing of annual reports. However, SCE requests that the reports be current as of December 31 of the previous year. DRA does not oppose this request. The Commission will reject this request. A nine month gap between the end of the calendar year and filing of the October report would not provide the Commission with timely information to report to the Governor and Legislature, as directed by SB 17. Therefore, the annual reports filed on October 1 of each year shall include information current as of July 1 of each year. This will provide the Commission with the most recently available information on the utilities' Smart Grid actions, and will allow the Commission to provide the Governor and Legislature the best available information. If we were to agree to SCE's request, the Governor and Legislature would be receiving a report using information that is over a year old, which would not be in keeping with the statute.
The Commission expects the annual report to inform the Commission, the public, interested parties and market participants of the utilities' Smart Grid actions. The Commission will use the annual reports as a way to measure utilities' adherence to the vision and roadmap, as well as allowing the Commission to track investments against any adopted metrics.
Finally, CEERT comments that the statute does not contain a sunset provision for an annual report. At this time, the Commission will require a report every year through 2020, beginning in 2012. The Commission may decide to extend this requirement at a future date depending on the progress toward a Smart Grid over the next 10 years. Additionally, depending on the progress made by the utilities and the state, the Commission may choose to seek a sunset provision in the statute.
4.5. Should the Commission Set a Demarcation Point for Utility Investments
The Joint Assigned Ruling sought comments from parties regarding the potential for a Commission determined demarcation point for utility investments. Specifically, the Ruling Amending Scope asked whether the Commission should prohibit utility ownership of devices installed on the customer-side of the meter.298 The Ruling Amending Scope did not propose a solution, but sought comments about how best could the Commission create a "regulatory approach to spur the creation of Smart Grid services, devices, and functions that allow for" interoperability between devices and whether a demarcation point would be an appropriate regulatory response.299
Tendril supports the use of a demarcation point to help the market develop. Tendril comments that there may need to be multiple demarcation points because placing a demarcation point at a central facility or utility office may hinder "the ability of a third-party service provider to effectively participate," and therefore multiple demarcation points "may be advisable in order to anticipate multiple parties and business models."300
CCTA comments that it "may be premature to determine whether a clear demarcation point between utility and consumers is necessary or appropriate" for Smart Grid devices to foster a market.301 Nevertheless, CCTA suggests that the Commission should consider the issues surrounding a demarcation in a future proceeding.302
CLECA strongly believes "that a utility should not own equipment on the customer side of the meter" and that the "utility's ownership should stop at the meter."303 CLECA warns that allowing the utility to provide technology to consumers would likely "stifle innovation and could lead to wasteful investment."304 Additionally, CLECA argues that customers may be unwilling to allow utilities to "reach into their homes and businesses."305
Google supports a demarcation point at the meter, noting that "upstream of the meter has traditionally been viewed as exclusive utility domain while downstream of the meter has traditionally been viewed as an area of customer investment."306 Google comments that no party has "presented a compelling need" to change this structure, and that "there does not appear to be any need for utilities" to own devices that communicate with the meter.307
PG&E does not support the use of a demarcation point, "other than in a legal, jurisdictional sense." PG&E comments that "the appropriate demarcation point between the utility and non-utility will depend on the systems integration function that the utility must perform," and that a demarcation point could discourage competition and investments in Smart Grid technologies.308
SCE also opposes using a demarcation point as it is "impractical and ignores the nature and complexities of the architecture for advanced metering and home area networks," and a demarcation point may be "irrelevant if consumer devices communicate with the electric grid over the internet."309 SCE argues that a demarcation point can be constructed through functional roles, rather than physical interconnection. SCE provides a proposed definition for a "functional demarcation point of utility service."310 Specifically, the utility would be responsible for functions essential to grid reliability, Smart Grid cyber security, and back office support to enable the HAN interface.311 SCE proposes several functions that third parties could provide for a customer, including installation of devices, phone support, in-home support, and demand response.312 SCE comments that any new services or technologies enabled by the Smart Grid "should not interfere with SCE's ability to provide safe and reliable electrical service."313
Wal-Mart supports the meter as the demarcation point.314
Greenlining supports the adoption of a demarcation point as it "would foster participation and innovation by third parties ... to develop technologies and consumer devices that will be compatible and interoperable" with the Smart Grid.315 Greenlining supports the meter as the demarcation point, but it should not be a rigid demarcation point as it "may not be completely appropriate where innovative communications technology may break through the Smart Grid at a different point of interconnection."316 Additionally, Greenlining would not support a prohibition against utility participation on the customer side of the meter, as a utility may be able to out-compete a competitor in services and innovations.317
EnergyHub "does not believe a demarcation point is prudent" due to the early stages of technology development for customers and "care must be taken to ensure maximum flexibility as the market evolves."318
DRA "continues to believe that customers should own all equipment on the customer side of the meter,"319 and that a demarcation point should be set at the meter.320 DRA "sees no need for the IOUs to provide customers" with in-home devices and argues that "the market for consumer-owned devices and energy management tools should be allowed to fully develop."321
TURN supports a demarcation point "for purposes of utility investments."322
CEERT supports the adoption of a demarcation point at the meter, asserting that the utility can provide applications "relevant to delivery services," and that applications "relative to after-the-meter services can be competitively provided by third parties."323 CEERT comments that utilities could also provide these "after-the-meter services," but "should not have an exclusive right to do so."324 Fundamentally, CEERT argues that utilities should "not extend beyond their core competencies at a significant ratepayer cost or inappropriately constrain the ability for third parties ... to provide their services."325
SDG&E supports the adoption of a demarcation point at the meter.326 SDG&E argues that "the demarcation point should be based upon the services that are being provided by the utility and should not create utility obligations with respect to equipment and services that are not provided by the utility."327 However, the Commission "should not prohibit IOU's from participating in activities, or owning equipment, on the customer side of the meter that could potentially facilitate the development of smart grid interoperability."328 The demarcation point should not be set at a place that discourages "development of new consumer interoperability technologies and/or the utility's efficient management of the electric grid."329
EDF does not take a position on a demarcation point, but supports a process for an open and competitive market for providing Smart Grid products and services to customers by a wide variety of providers, including the utility.330 EDF states "that it is essential that third parties are able and encouraged to provide behind the meter services."331
GroundedPower cautions against the adoption of a demarcation point stating that utilities may own certain equipment inside the home such as rental water heaters or direct load control devices.332 GroundedPower suggests that "[t]he question of ownership should be viewed with flexibility to ensure that deployment of smart technologies is encouraged and not impeded."333
AT&T encourages the Commission to set a demarcation point at the meter as "establishing such a demarcation point will promote investment and innovation in the sphere of home energy management."334 AT&T also states that "the location of the demarcation point should confer no advantage to one market participant over another."335
Sigma encourages the adoption of a demarcation point where devices outside a home are the utility's responsibility, but devices inside the home are the customer's responsibility.336 Sigma comments that setting a demarcation point at the home provides several benefits, including enabling innovation, improving price/performance, mitigating privacy issues, increases flexibility, simplifies the grid, clarifies responsibility, and improving security.337
4.5.2. Discussion: Commission Declines to Adopt a Demarcation Point at this Time
All parties support the ability of third parties to provide devices and technology that can be used by customers to become better informed, better manage their own consumption, and obtain new technologies as they become available to customers. Permitting non-utilities to provide devices and technology used by consumers beyond the meter facilitates the deployment of Smart Grid technologies.
In the Ruling Amending Scope, the assigned Commissioner and ALJ sought additional comments from parties regarding the efficacy of the Commission instituting a demarcation point that would effectively prohibit the utility from providing and owning devices located inside a customer's home or establishment. As the Ruling Amending Scope noted, the experience of a demarcation point in the telecommunications industry provides a useful example of how a demarcation point allowed for innovation of technology and overall reduced costs for customers. Many parties, notably PG&E and SCE, caution that the telecommunications industry may not be an accurate comparison, as there are many differences between the telecommunications industry and the electricity industry. Other parties, such as TURN, CLECA and DRA, warn the Commission that without a demarcation point, the utility could be allowed to ratebase investments that not all customers may want or need, thereby raising costs to ratepayers. Parties such as CEERT and Sigma suggest that a demarcation point allows for increased innovation and allows for products to be marketed to customers in a timely manner, without needing to wait for a utility or regulatory body to act.
The Commission declines to adopt a demarcation point at this time. The Commission is certainly aware of the concerns raised by parties advocating for a demarcation point, but this is not the proper vehicle to address those concerns. The Commission does not have a sufficient record to make a decision on this topic at this time. The Commission will re-consider this determination during its review of the Smart Grid Deployment Plans. Nevertheless, the Commission is fully supportive of a competitive and innovative market for customer-owned technology and devices. Should a utility request ratepayer funds for a device or technology that it anticipates owning and operating and that is placed inside a customer's home or establishment, we will expect the utility to fully explain and justify why such an investment is needed, and explain why such devices or technologies have failed to be adopted widely. The Commission has generally supported the contention that costs should be borne by those who will benefit from the product rather than by the ratepayers, and we will expect the utility to justify why the Commission should veer from this preference.338
238 SCE Opening Comments at 8; Greenlining Opening Comments at 14; Tendril Opening Comments at 5-6; CLECA Opening Comments at 5; TURN Opening Comments at 3 and Reply Comments at 1; DRA Opening Comments at 7; EDF Opening Comments at 13 and Reply Comments at 17; CFC Opening Comments at 2; PG&E Opening Comments at 8-10 and Reply Comments at 2; CEERT Reply Comments at 2.
239 Greenlining Opening Comments at 14.
240 CLECA Opening Comments at 5.
241 TURN Opening Comments at 3.
242 EDF Reply Comments at 17.
243 PG&E Opening Comments at 10.
244 SCE Opening Comments at 8; PG&E Opening Comments at 8-10; Reply Comments at 2.
245 UCAN Opening Comments at 4.
246 Id.
247 SCE Opening Comments at 8-9; Reply Comments at 5.
248 TURN Opening Comments at 3; CESA Opening Comments at 6; Tendril Opening Comments at 5-6 (Tendril recognizes that GRCs may be the most appropriate venue for cost recovery issues but may also be too burdensome. It then concludes that a single proceeding should be used to address as many issues as possible. We surmise the Tendril must be referring to approval of the deployment plans); CLECA Opening Comments at 5. (CLECA raises concerns with reviewing Smart Grid investments in GRCs and then concludes that the Commission should review deployment plans in a single proceeding.)
249 CESA Opening Comments at 6.
250 Id.
251 DRA Opening Comments at 7.
252 SCE Opening Comments at 8 and Reply Comments at 5; DRA Opening Comments at 3; SDG&E Opening Comments at 4-5 and Reply Comments at 4; CEERT Opening Comments at 4-5 and Reply Comments at 2; SCE Opening Comments at 5.
253 CEERT Reply Comments at 2 (recommends a single proceeding); EDF Reply Comments at 17 (recommends a single proceeding); PG&E Opening Comments at 8-9 (recommends separate proceedings); DRA Reply Comments at 6-8 (recommends the Commission review updates via advice letter and an application process after the initial five years); SDG&E Reply Comments at 4-5 (recommends the advice letter process).
254 SCE Opening Comments at 4; DRA Opening Comments at 3; CEERT Opening Comments at 4-5.
255 SCE Comments of 3/9/10 at 8.
256 CEERT Opening Comments of 4/7/10 at 2.
257 PG&E Opening Comments at 8-9.
258 EDF Reply Comments at 17.
259 SDG&E Opening Comments at 4-5; DRA Reply Comments at 6-8.
260 SDG&E Reply Comments at 4-5.
261 DRA Reply Comments at 6-8.
262 Id.
263 SDG&E Reply Comments at 3-4.
264 SDG&E Opening Comments at 4-5.
265 Id.
266 SDG&E Reply Comments at 4.
267 PG&E Opening Comments at 7.
268 Id.
269 SCE Opening Comments at 10.
270 DRA Reply Comments at 7-8.
271 SCE Opening Comments at 10.
272 SCE Reply Comments at 5.
273 SCE Opening Comments at 8.
274 DRA Reply Comments at 6-7.
275 Ruling Amending Scope at 17.
276 DRA Reply Comments at 5.
277 SCE Opening Comments at 9, footnotes omitted.
278 PG&E Opening Comments at 10.
279 SDG&E Opening Comments at 5, 7.
280 Id. at 9.
281 SCE Opening Comments at 8.
282 Id.
283 Id. at 22. See also, SCE Reply Comments at 6.
284 PG&E Opening Comments at 7.
285 Id.
286 IREC Opening Comments at 7.
287 EDF Opening Comments at 8.
288 Cisco Opening Comments at 7.
289 CEERT Opening Comments at 4-5.
290 DRA Opening Comments at 3.
291 Id.
292 Id. at 8-9.
293 DRA Reply Comments at 8-9.
294 TIA Reply Comments at 3.
295 See, 3.4.2., above.
296 § 8367.
297 See, 3.4.2. and 3.6.2.
298 Ruling Amending Scope at 26.
299 Id. at 28.
300 Tendril Opening Comments at 10-11.
301 CCTA Opening Comments at 6.
302 Id. at 6-7.
303 CLECA Opening Comments at 11.
304 Id.
305 Id.
306 Google Opening Comments at 9.
307 Id.
308 PG&E Opening Comments at 17.
309 SCE Opening Comments at 23.
310 Id.
311 Id. at 24.
312 Id.
313 Id. at 25.
314 Wal-Mart Opening Comments at 2.
315 Greenlining Opening Comments at 18.
316 Id. at 19.
317 Id. at 20.
318 EnergyHub Opening Comments at 4.
319 DRA Opening Comments at 20.
320 DRA Reply Comments at 16.
321 Id. at 17.
322 TURN Opening Comments at 27.
323 CEERT Opening Comments at 23-24.
324 Id. at 24.
325 CEERT Reply Comments at 17.
326 SDG&E Opening Comments at 25.
327 Id. at 25.
328 SDG&E Reply Comments at 9.
329 Id. at 2.
330 EDF Opening Comments at 20.
331 EDF Reply Comments at 24.
332 GroundedPower Reply Comments at 12.
333 Id.
334 AT&T Reply Comments at 9.
335 Id.
336 Sigma Designs Reply Comments at 1.
337 Id. at 1-3.
338 See, D.10-02-032 at 107 (2010).
