4. Discussion

The issue of whether electric and gas utility customers should be provided an option to opt-out of a wireless smart meter is not unique to SDG&E. As noted in UCAN's application, President Peevey had directed PG&E to file a proposal that would allow its customers to opt-out of a wireless smart meter. We agree with UCAN that an opt-out alternative should not be limited to only customers in one utility's service territory. Consequently, we believe it would be appropriate to consider opt-out options for SDG&E customers.4 However, any option adopted would need to be technologically feasible, offered at a reasonable cost to those customers opting out and consistent with the state's goals to deploy a Smart Grid.

UCAN's application proposes that D.07-04-043 be modified to direct SDG&E to develop a proposal or proposals to allow customers to opt out of installation of a wireless smart meter. The application further proposes that the opt-out option be an electromechanical (analog) meter.5 However, an analog meter opt-out option was only one of four possible options that had been discussed at the September 14th workshop. Neither UCAN nor SDG&E has provided information or costs for any of the options. As such, we cannot reasonably conclude that the analog meter opt-out option is the preferred alternative. Consequently, we believe it would be premature to adopt UCAN's proposed opt-out option at this time.

We disagree with SDG&E's assertions that it does not need to consider offering an opt-out option to its customers. SDG&E's assertions are based on its belief the concerns raised by UCAN have already been addressed. While we take no position on the validity of SDG&E's statement, we do not believe that a customer must have a specific concern in order to opt-out of the installation of a wireless smart meter. Rather, if an opt-out option is offered, a customer should be allowed to select this option for any number of reasons, or for no reason at all.

Based on these considerations, we agree with UCAN that SDG&E should be directed to submit a proposal for customers to opt-out of installation of a wireless smart meter. However, it is important that all possible opt-out options be considered. Therefore, SDG&E's proposal must consider and provide analysis on the technological feasibility and cost to offer each of the following types of alternatives to installation of a wireless smart meter:

This analysis shall include the following:

1. Whether the radio transmission capability of the gas and electric smart meters can be turned off remotely and the associated cost to include that feature.

2. Whether the radio transmission capability of the gas and electric smart meters can be programmed to turn on and transmit data at a specified time each month and the associated cost to include that feature.

3. A comparison of costs to implement each of the alternatives:

a. If an analog meter is currently installed.

b. If a wireless smart meter is currently installed.

4. A comparison of costs when a meter is read:

a. By a utility employee every month

b. By the utility employee on a quarterly basis, with the remaining months being read by the customer

c. By the utility employee on a semi-annual basis, with the remaining months being read by the customer

5. Identification of all costs that would be incurred regardless of how data for the alternative is collected (i.e., read by utility employee, read by customer or read via "snap read").

6. The proposed upfront and monthly fees/rates to be paid by customers under each of the opt-out alternatives. The proposed fees/rates shall also specify the discounted fees/rates to be charged to customers enrolled in the California Alternate Rates for Energy Program.

We understand that SDG&E may not support all the opt-out alternatives listed above. However, it is the only party able to provide the information listed above, and to require intervenors, consumer groups and DRA to request this information through data requests would be potentially time-consuming and a poor use of resources. Therefore, we find that it is necessary and most efficient to have SDG&E provide information on all the opt-out alternatives, not just its proposed alternative.

SDG&E shall file its proposal no later than 14 days after the effective date of this decision. While this may appear to be a short period of time in light of the information to be provided, we remind SDG&E that UCAN's application was filed on March 24, 2011. Additionally, SDG&E has had ample advance notice that it would be expected to file an opt-out proposal.6 Indeed, all the investor-owned utilities, including SDG&E, were directed to consider the opt-out alternatives listed above and to have cost information concerning the alternatives at the September 14th workshop. As such, SDG&E has had ample notice that it would likely be required to submit this information to the Commission. Thus, we do not find the 14-day deadline to be unreasonable.

Finally, UCAN's application seeks to modify D.07-04-043 by adding a Finding of Fact, a Conclusion of Law and an Ordering Paragraph to that decision. UCAN believes this modification is necessary in order to require SDG&E to file an opt-out proposal. We disagree. As evidenced by PG&E's application, we may order a utility to file a proposal to modify its smart meter program to provide customers an option to not have a wireless smart meter installed without first modifying the prior decision authorizing the program. Accordingly, we deny UCAN's application to the extent it seeks to modify D.07-04-043.

4 Pursuant to an Assigned Commissioner's Ruling issued on September 21, 2011, customers who currently have an analog meter may ask to be put on SDG&E's delay list to keep their analog meter while the Commission considers the opt-out options.

5 UCAN Application at 3-4.

6 See Reporter's Transcript (RT) PHC-1 at 32-33.

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