2. Procedural Background
Decision (D.) 10-06-047, which set Smart Grid Deployment Plan requirements, declined to adopt metrics, stating that there was an inadequate record to create useful metrics at the time that decision was made.2
Subsequently, Commission Staff led efforts to develop metrics. On July 30, 2010, a Joint Ruling was released seeking comment on a staff-proposed set of metrics.3 The Joint Ruling included as an attachment a list of over 80 proposed metrics for discussion.
The Commission received comments on these potential metrics on August 17, 2010 from California Large Energy Consumers Association, the Environmental Defense Fund (EDF), the California Energy Storage Alliance (CESA), Southern California Edison Company (SCE), the Division of Ratepayer Advocates (DRA), The Utility Reform Network (TURN), Pacific Gas and Electric Company (PG&E), the Greenlining Institute (Greenlining), Granite Key LLC (Granite Key), Ice Energy Inc. (Ice Energy), the Utility Consumers' Action Network, San Diego Gas & Electric Company (SDG&E), the California Independent System Operator (CAISO), Certichron Inc., and the Consumer Federation of California.
A workshop to consider the proposed metrics and comments was held on August 25-26, 2010. Based on the discussions at the workshop, Commission Staff agreed to develop a new set of proposed discussion draft metrics that would form the basis for metrics. Commission Staff distributed this discussion draft set of metrics to the service list in this proceeding on September 3, 2010. The discussion draft also directed PG&E, SCE and SDG&E to undertake an internal review of their processes to determine which proposed metrics are either already being reported for other purposes, or could be easily collected and reported. Additionally, PG&E, SCE and SDG&E were directed to report on whether there were any metrics they were not currently collecting for which they could not easily collect the data for reporting purposes.
PG&E, SCE and SDG&E distributed a Joint Straw Proposal on Smart Grid Metrics (Straw Proposal) on September 24, 2010. This Straw Proposal presented metrics based on what can be currently reported to the Commission and what requires further discussion.
Commission Staff subsequently coordinated a series of "webinars" to discuss the attributes of the proposed metrics. Webinar #1 took place on October 8, 2010 and focused on customer and Advanced Metering Infrastructure (AMI) metrics. Webinar #2 took place on October 12, 2010 and focused on utility grid operations. Webinar #3 took place on October 13, 2010 and focused on cyber-security. Webinar #4 took place on October 15, 2010 and focused on environmental issues, electric vehicles and other issues not previously covered.
On October 22, 2010, PG&E, SCE and SDG&E distributed to the service list a "Report on Consensus and Non-Consensus Smart Grid Metrics" (Consensus Report). This Consensus Report identified 19 metrics that it considered consensus, based on the webinar process and additional discussions with parties.
The Consensus Report also listed a number of metrics that were identified as "Non-Consensus." Additionally, the Consensus Report sought clarifications concerning a number of items, including the "base year" for taking the first measurement.
On December 29, 2010, the Administrative Law Judge (ALJ) issued an ALJ Ruling seeking comments on the Consensus Report. The ALJ Ruling included the Consensus Report as Attachment A.4 The ALJ Ruling sought party comments on whether the metrics listed in the Consensus Report are appropriate and reasonable, whether the metrics are accurately listed as consensus or non-consensus, and whether the metrics accurately reflect the input of parties.5 Additionally, the ALJ Ruling asked for comments on the appropriateness of creating "Technical Working Groups" to create metrics on cyber-security, and whether Technical Working Groups are needed for additional topics.6 Finally, the ALJ Ruling sought comments on the appropriate reporting period for the metrics.7
Pursuant to the ALJ Ruling, opening comments were filed on January 24, 2011 by Granite Key and Aspect Labs (filing jointly Granite Key/Aspect Labs), Southern California Gas Company (SoCalGas), Greenlining, CAISO, Ice Energy, SDG&E, Alliance for Retail Energy Markets (AReM), PG&E, DRA, EDF, and SCE.
Reply comments were filed on February 14, 2011 by SDG&E, DRA, Demand Response and Smart Grid Coalition (DRSG),8 SCE, California Energy Efficiency and Renewable Technologies (CEERT), EDF, CESA, and PG&E.
2 D.10-06-047 at 84.
3 Assigned Commissioner and Administrative Law Judge's Joint Ruling, Rulemaking (R.) 08-12-009 (July 30, 2010) (Joint Ruling).
4 Administrative Law Judge's Ruling Seeking Comments on Proposed Interim Metrics to Measure Progress by Pacific Gas and Electric Company, Southern California Edison Company and San Diego Gas and Electric Company in Implementing a Smart Grid, R.08-12-009 (December 29, 2010) (ALJ Ruling).
5 ALJ Ruling at 2-3.
6 Id. at 3-4.
7 Id. at 4.
8 The Motion of Demand Response and Smart Grid Coalition for Party Status (February 14, 2011) was granted via an ALJ e-mail to the service list on February 16, 2011.
