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 SCE. As noted by Joint Applicants, the Commission is currently considering similar applications concerning smart meter opt-out options for customers served by PG&E and SDG&E. We agree that an opt-out alternative should also be considered for SCE customers. 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.
Joint Applicants request that D.08-09-039 be modified to direct SCE to develop a proposal or proposals to allow customers to opt out of installation of a wireless smart meter. The application further proposes the minimum requirements for the opt-out option include the ability for a customer to request SCE to reinstall an analog meter.9 However, an analog meter opt-out option was only one of four possible options discussed at the September 14th workshop. There is currently no information in this proceeding regarding the technological feasibility or costs for any of the options. As such, we cannot reasonably conclude that the analog meter opt-out option is reasonable. Consequently, we believe it would be premature to adopt the minimum requirements proposed by Joint Applicants at this time.
Based on these considerations, we believe that SCE should be directed to submit a proposal for customers to opt-out of installation of a wireless smart meter.10 However, it is important that all possible opt-out options be considered. Therefore, SCE'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:
1. Analog meter.
2 Digital meter with no radio installed.
3. Smart meter with radio transmission turned off.
4. Wired smart meter.
This analysis shall include the following:
1. Whether the radio transmission capability of the electric smart meters can be turned off remotely and the associated cost to include that feature.
2. Whether the radio transmission capability of the 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 SCE 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 SCE provide information on all the opt-out alternatives, not just its proposed alternative.
SCE 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 SCE that at the September 14th workshop, all the investor owned utilities, including SCE, were directed to consider the opt-out alternatives listed above and to have cost information concerning the alternatives available. Moreover, SCE has stated that it could file such an opt-out proposal as early as the fourth quarter of this year.11 Thus, we do not find the 14-day deadline to be unreasonable.
Finally, Joint Applicants request us to modify D.08-09-039 by adding a Finding of Fact, a Conclusion of Law and an Ordering Paragraph to that decision to require SCE to file an opt-out proposal. Although Joint Applicants believe the Commission may order SCE to file a proposal without modifying the decision, they felt it was necessary to make this request for procedural purposes. We agree with Joint Applicants that 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 Joint Applicants' request to modify D.08-03-039.
9 Joint Application at 15.
10 Pursuant to assigned Commissioner's Ruling issued on September 21, 2011, customers who currently have an analog meter may ask to be put on SCE's delay list to keep their analog meter while the Commission considers the opt out options.
11 SCE Response at 5.
