10. Region II Issues
10.1. Advanced Metering Infrastructure
Golden State seeks authorization to test, evaluate, and implement one phase of a $27,179,393 Advanced Metering Infrastructure (AMI) system in Region II.
Golden State seeks $341,292 to hire an outside consultant to perform a program review in 2009; $159,075 to perform a pilot program in 2010; $198,526 for project management by the retained outside consultant during the pilot program in 2010; and $6,620,125 to begin the actual installation of the AMI system in 2011 in Region II. Golden State states that the AMI program is part of an overall strengthening of its water conservation programs. Golden State asserts that AMI is an important tool that gathers data and transfers information to a central database allowing utilities and their customers to view and track water consumption on demand. Golden State states that certain AMI programs contain features that detect leaks and shut off the water, avoiding flooding and water loss.
DRA recommends the Commission deny Golden State's request stating the program is premature and lacks necessary justification. DRA recommends that the Commission open a rulemaking for Class A Water Companies to determine if AMI is beneficial for water utilities.
Specifically, DRA states that Golden State's AMI program lacks a business plan and that the AMI program of SDG&E, upon which Golden State bases its request, contains a significant amount of advance work prior to implementation. DRA states that SDG&E issued five Requests for Proposals (RFP) before presenting its proposal to the Commission. DRA recommends that Golden State follow the recommendation of its own consultant and provide a cost estimate to the Commission that is based on an RFP that incorporates defined criteria and technical requirements.
Golden State acknowledges that it has not provided a detailed business plan or issued an RFP for the implementation of its proposed AMI system. As an alternative to the full AMI program funding, Golden State requests the Commission grant its request for pre-deployment funding of $341,292 to hire a consultant to assist in the preparation and evaluation of a final AMI deployment plan.
The Cities support DRA's critique of the AMI proposal and request that the Commission deny it.
We applaud Golden State's commitment to conservation efforts by requesting implementation of such an innovative program. However, Golden State's plan lacks the requisite pre-planning detail and justification to approve full funding at this time. Golden State's request for pre-deployment funding to hire a consultant is reasonable, therefore we grant pre-deployment funding only, in the amount of $341,292.
