Pursuant to D.11-11-007, SDG&E's opt-out proposal included an analysis on the technological feasibility and related cost to provide the following opt-out options:5
1. Analog meter - Under this option, an electromechanical (analog) meter would be used in place of the wireless smart meter. This option would require the meter to be read manually every month.
2. Digital meter with no radio installed - Under this option, a digital meter, with no radio communications ability, would be used in place of the wireless smart meter. Some of these meters may be able to store interval energy consumption data. This option would require the meter to be read manually every month.
3. Smart meter with radio transmission turned off - This option would retain the existing smart meter, but have the radio transmission capability turned off. Under this option, the meter would need to be read manually every month.
4. Wired smart meter - Under this option, interval energy consumption data would be transmitted to the utility through a traditional telephone line, fiber optic, a power line carrier or other wired technologies. Since this option would allow the meter to communicate with the utility, the meters would not need to be read manually every month.
Of the four options under consideration, SDG&E's preferred solution is "a non-communicating solid state meter with interval read capability."6 SDG&E states that this option "provides the future functionality that would allow [it] to meet future tariff changes."7 It further notes that both a digital meter with no radio installed and a smart meter with the radio transmission capability turned off are warranted products with long-term availability.8
SDG&E states that it does not consider an analog option viable because these meters are no longer being produced by the major meter manufacturers and, thus, would not have satisfactory warranty terms and other conditions.9 It further contends that since analog meters cannot record interval energy consumption data, offering this option could "provide the mechanism to opt-out of future mandatory tariffs" and result in additional costs.10
SDG&E notes that a wired smart meter opt-out option would be the most expensive option to implement, as communication to the meter would need to be through a dedicated communication line. It further notes that this would not be a viable option for its gas meters. Consequently, if this option were adopted for the electric meters, SDG&E would be required to adopt a different opt-out option for its gas meters.
SDG&E estimates that approximately 3,000 residential customers could potentially opt out.11 It further states that radio transmission capability of the smart meter cannot currently be turned off remotely and that there is no capability for the smart meter to be programmed to perform a "snap read" (i.e., remotely turn radios on and off at pre-determined periods to transmit data).12
SDG&E states that it identified seven different cost categories that may apply to all or some of the opt-out options. Its proposal provides a general description of the estimated costs associated with each category, but notes that the actual implementation and other associated costs will depend on the specific opt-out option adopted by the Commission and the actual number of residential customers electing the option. Further, SDG&E's proposal is based on offering a single opt-out option. It states: "If residential customers have the choice of multiple opt-out alternatives, then SDG&E's opt-out program costs will increase."13 Based on its assumptions, SDG&E estimates the costs as follows:
TABLE 1
ESTIMATED COSTS FOR OPT-OUT OPTIONS14
Radio Out |
Radio Off |
Analog |
Wired | |
Cost of Option |
||||
Total Expense |
$2,669,800 |
$2,737,993 |
$2,605,629 |
$6,793,759 |
Total Capital Cost |
$440,366 |
$354,828 |
$397,597 |
$2,672,944 |
Total Cost of Option |
$3,110,166 |
$3,092,821 |
$3,003,226 |
$9,466,703 |
Initial Fee* |
$223 |
$219 |
$202 |
$1,082 |
Monthly Fee* |
$15 |
$15 |
$15 |
$49 |
Exit Fee* |
$78 |
$78 |
$78 |
$78 |
* SDG&E proposes a 20% discount of this cost for CARE customers.
SDG&E requests that its proposed initial and monthly fees be found reasonable. Further, it seeks authority to establish two new two-way interest-bearing balancing accounts to record the up-front charges, on-going fees and actual operations and maintenance and capital costs associated with the adopted opt-out option. SDG&E proposes that recovery of costs in the memorandum account be addressed in its annual Electric and Gas Regulatory Account Balance Update filings, or a proceeding determined by the Commission.
5 D.11-11-007, Ordering Paragraph 2.
6 SDG&E Proposal at 19.
7 Id.
8 Id. at 17-19.
9 Id. at 16-17.
10 Id. at 17.
11 Proposal of San Diego Gas & Electric Company for Customers to Opt-Out of Wireless Smart Meters ("SDG&E Proposal"), filed November 28, 2011 at 5-6.
12 SDG&E Proposal at 6-7.
13 SDG&E Proposal at 20.
14 SDG&E Proposal, Attachment A3.