The Application

Joint Applicants claim that, similar to customers in PG&E's and SDG&E's service territories, customers in SCE's service territory have expressed health and security concerns regarding wireless smart meters. Further, they state that SCE has publicly informed the Santa Barbara County Board of Supervisors that it has no intention of proposing an opt-out plan unless ordered to do so by the Commission. Joint Applicants note that citizens in Santa Barbara County are served by both PG&E and SCE. They contend that failing to require SCE to file an opt-out option "would result in an arbitrary denial of opt-out rights to some California citizens based solely on which side of a service territory line they live."⁵

Joint Applicants have requested that if SCE does not file an opt-out plan, the Commission should adopt a plan on its own. Joint Applicants list the minimum requirements they believe should be contained in such a plan. The proposed requirements would include the use of an analog meter in place of a wireless smart meter and no additional charges for customers selecting the opt-out option.⁶

SCE believes that the application is premature and should be dismissed. It notes it will be participating in the September 14th workshop, along with the other IOUs, to consider the various opt-out options proposed by certain parties. It states: "At the conclusion of the workshop, should the Commission determine that it is reasonable for SCE to file an application for Commission approval of a Smart Meter opt-out plan, SCE will leverage the knowledge gained from the workshop to file an application as early as the fourth quarter of this year."⁷ SCE further disputes the health concerns raised by Joint Applicants. Finally, SCE notes that it is in the process of implementing the requirements of D.11-07-056, which established rules to protect the privacy and security of the electricity usage data of SCE, PG&E and SDG&E customers.⁸

⁵ Joint Application at 14.

⁶ Joint Application at 14-15.

⁷ SCE Response at 3.

⁸ SCE Response at 4.