3. Consensus Metrics

The Consensus Report, which is Attachment A of the ALJ Ruling, identified nineteen consensus metrics to be measured as part of the initial Smart Grid Deployment Plans and reported annually as part of the Annual Reports, required by D.10-06-047, to be filed with the Commission by October 1 of each year starting in 2012. The nineteen consensus metrics are as follows:

A. Customer/AMI Metrics

1. Number of advanced meter malfunctions where customer electric service is disrupted;

2. Load impact from Smart Grid-enabled, utility administered demand response programs (in total and by customer class);

3. Percentage of demand response enabled by Automated Demand Response and by individual Demand Response impact program;

4. The number of utility-owned advanced meters supporting consumer devices with Home Area Network (HAN) or comparable consumer energy monitoring or measurement devices registered with the utility (by customer class, customers in the California Alternative Rates for Energy (CARE) program and climate zone);

5. Number of customers that are on a time-variant or dynamic pricing tariff (by customer class, CARE, and climate zone);

6. Number of escalated customer complaints related to (1) the accuracy, functioning, or installation of advanced meters or (2) the functioning of a utility-administered HAN with registered consumer devices;

7. Number of utility-owned advanced meters replaced annually before the end of their expected useful life;

8. Number of advanced meter field tests performed at the request of customers pursuant to utility tariffs providing for such field tests; and

9. Number and percentage of customers with advanced meters using a utility-administered internet or a web-based portal to access energy usage information or to enroll in utility energy information programs.

B. Plug-in Electric Vehicles Metrics

Number of customers enrolled in time-variant electric vehicles tariffs.

C. Storage Metrics

Megawatt (MW) and Megawatt-hours of grid connected energy storage interconnected at the transmission and distribution system level.

D. Grid Operations Metrics

1. The system-wide and total number of minutes per year of sustained outage per customer served as reflected by the System Average Interruption Duration Index (s), Major Events included and excluded;

2. How often the system-wide average customer was interrupted in the reporting year as reflected by the System Average Interruption Frequency Index, Major Events included and excluded;

3. The number of momentary outages per customer system-wide per year as reflected by the Momentary Average Interruption Frequency Index, Major Events included and excluded;

4. Number of customers per year and circuits per year experiencing greater than 12 sustained outages;

5. System load factor and load factor by customer class;

6. Number of and total nameplate capacity of customer-owned or operated, grid-connected distributed generation facilities;

7. Total annual electricity deliveries from customer-owned or operated, grid-connected distributed generation facilities; and

8. Number and percentage of distribution circuits equipped with automation or control equipment, including Supervisory Control and Data Acquisition systems.

3.1. Positions of Parties on Proposed Consensus Metrics

As the title of Attachment A, "Consensus Report," suggests, the comments of parties generally supported the metrics identified. Additionally, commenters recommended relatively minor edits to the metrics as listed, often to ensure clarity. This decision discusses and resolves these recommendations.

The CAISO requested that Customer/AMI Metric 4 be clarified to ensure that non-HAN methods of triggering demand response are also considered.⁹ Additionally, the CAISO asked that the Commission ensure that there is coordination between the policies identified in the metrics and the goals outlined in the California Clean Energy Future Implementation Plan (Plan).¹⁰ According to the CAISO, consistency between the Plan and Smart Grid metrics "will be an important step in ensuring that California's electric utilities and agencies carry out a coherent plan for building a smart electric system for California."¹¹

Ice Energy argued that "metrics should be designed to measure not only the energy storage systems themselves but their grid-wide impacts."¹² Additionally, Ice Energy did not support the Consensus Report because the Consensus Report does not include a metric on thermal storage air conditioning. Ice Energy contended that thermal storage air conditioning is specifically listed in Senate Bill (SB) 17, and "it is essential to collect information through appropriately specific metrics about thermal storage air conditioning's usage, costs, benefits and impact on the grid."¹³ Ice Energy proposed that the following metric be included in any final list of metrics: "The number and percentage of electricity customers and magnitude and percentage of total load served by thermal-storage air conditioning."¹⁴

Greenlining proposed that Customer/AMI Metric 9 information be collected "by customer class, CARE enrollment and climate zone."¹⁵ Greenlining argued that collecting this additional information would help in "understanding if any particular group of customers is taking advantage" of accessing information over the internet more than any other class of customers.¹⁶ Additionally, Greenlining proposed that Customer/AMI Metrics 4, 5 and 9 include collection of data by zip code or census track. Greenlining stated that collecting information by zip code or census track would help in understanding which customers are using information and which customers are not. Further, Greenlining noted that "in order for Smart Grid to succeed, every community in California must contribute to its policy goals."¹⁷

DRA argued for the adoption of the consensus metrics, but advised that the metrics should be considered as preliminary and interim in nature.¹⁸ In addition to its overall argument, DRA provided comments on specific metrics. Notably, DRA cautioned that Customer/AMI Metric 4 does not cover devices that are not registered with the utility, and suggested that this metric be reviewed as the HAN device marketplace evolves.¹⁹

On Customer/AMI Metric 6, DRA noted that there is no definition for the term "escalated complaint" and argued that all utilities should report on this metric using the same definition.²⁰ Further, DRA argued that this particular metric does not clearly state what type of complaint will be tracked and whether or not those complaints are resolved. DRA recommended that the metric be modified to track and classify the types of escalated complaints.²¹

Concerning Customer/AMI Metric 7, DRA asked that this metric be revised to state as follows: "The number of advanced meters replaced before the end of their expected useful life during the course of one year, reported annually." Additionally, DRA requested that the reason for replacement be reported.²²

On Customer/AMI Metric 8, DRA asked that the results of the field tests of the meters be reported, and offered proposed language as follows: "Number of advanced meters field tested at the request of customers pursuant to utility tariffs providing for such field tests that are measuring usage correctly or incorrectly."²³

Finally, DRA requested that the costs of implementing and measuring these metrics be included as part of the metrics requirements.

AReM argued that the metrics should "focus primarily on measuring and evaluating utility performance" in the utility's role as the Utility Distribution Company (UDC). Specifically, AReM requested that the metrics "measure UDC performance and reject metrics that measure other utility functions."²⁴ Further, AReM noted that several metrics focus on bundled customer actions, which are unrelated to the actions of the utility as a UDC.²⁵

EDF generally supported the proposed metrics but recommended that "metrics be further developed to fully measure the ways that utilities use smart grid deployments to comply with" SB 17.²⁶ Additionally, EDF proposed two new metrics related to measuring the environmental benefit of Smart Grid:

Demand Response Benefits: EDF argued that with an ex post analysis of the load impact of demand response, the utility could determine the fuel being displaced and thus the avoided greenhouse gas (GHG) and criteria pollutant emissions; and

Distributed Generation Benefits: EDF argued that by determining the total MWs of distributed generation in their service area and total distributed generation during peak times, utilities can calculate the type and amount of conventional fuel being displaced and the resulting GHG and criteria pollutant reduction.²⁷

Finally, EDF noted that several proposed metrics provide information that, when matched to a generation-fuel profile of the utility at that time and date, can be used to quantify emission impacts.²⁸

SCE argued that the metrics "are appropriate, reasonable, serve the public interest," and will provide the Commission with necessary information to prepare the Commission's annual report to the Legislature, and reflect the input of parties.²⁹ In its Reply Comments, SCE supported two of the modifications offered by DRA. Specifically, SCE supported the revisions to Customer/AMI 6 and 7.³⁰ SCE also argued that several suggestions made by DRA to Customer/AMI 6, 7 and 8 are more appropriate for discussion in a Technical Working Group.³¹ Additionally, SCE noted that discussions around revisions offered by CAISO and Greenlining are also more appropriate for a Technical Working Group.³² SCE agreed with DRA on the topic of storage metrics, noting that any new metrics on storage should wait for direction and further information from the on-going Order Instituting Rulemaking on storage.^33,34 SCE argued that the proposed metrics offered by EDF are not "ready for adoption at this time."³⁵ SCE also proposed that consideration of the applicability of adopted metrics on gas companies "would be best accomplished in a separate forum dedicated to gas systems, as opposed to smart electricity systems."³⁶ Finally, SCE argued that AReM provided no support for its opposition to metrics and that SB 17 does not limit measurement to only the UDC function of the utility. SCE also argued that other issues raised by AReM are more appropriate for other Commission proceedings.³⁷

PG&E stated that the "proposed interim metrics are a useful starting point" for development of the utilities' Smart Grid Deployment Plans, and that it agrees with SCE that the metrics will provide the Commission with sufficient information for the Commission's annual report to the Legislature.³⁸

In Reply Comments, PG&E supported EDF's goal of creating metrics that "take into account the impact of various Smart Grid projects and programs on GHG emissions and other relevant environmental impacts."³⁹ PG&E, however, did not support EDF's proposed metrics. Instead, PG&E proposed that EDF work with other parties to develop a more comprehensive GHG emission metric, using concepts developed in other Commission proceedings.⁴⁰

PG&E also opposed the inclusion of additional metrics on energy storage. PG&E argued that "it is premature" to adopt a metric for measuring performance for thermal air conditioning because "the utilities have no means of managing, operating or measuring the use or market penetration of the technology."⁴¹

Finally, PG&E did not support the proposal of Greenlining to collect data for Customer/AMI Metric 9 at a more granular level. PG&E cautioned that while the proposal "may have merit," it is currently unclear what the burden and cost would be to the utility to meet the proposal. PG&E offered to research the feasibility of Greenlining's proposal and stated it may propose a future revision to Customer/AMI Metric 9 if feasible along the line recommended by Greenling.⁴²

SDG&E stated that it supports the metrics identified in the Consensus Report. Specifically, SDG&E argued that the "proposed set of metrics provide a useful starting point and a preliminary set of metrics to be included in the first Smart Grid Deployment Plan."⁴³

In Reply Comments, SDG&E opposed the inclusion of four cyber-security metrics proposed by Granite Key and Aspect Labs. SDG&E instead argued that the Technical Working Group on cyber-security is the more appropriate forum for discussion of cyber-security metrics.⁴⁴ SDG&E also opposed the request of AReM to limit the smart grid metrics to only the UDC function of the utility.⁴⁵

SoCalGas contended that the majority of the consensus metrics do not apply to gas companies. SoCalGas also argued that as a gas company, it is not required to file a Smart Grid Deployment Plan. SoCalGas argued further that the Commission should either adopt only those metrics that can be applied to the gas company or apply these metrics only on electric companies. SoCalGas identified Customer/AMI Metrics 1, 4, 6, 7, 8, and 9 as applicable to a gas company. Finally SoCalGas supported the position that these metrics be considered as "preliminary and for initial guidance only."⁴⁶

CEERT commented that the proposed consensus metrics "are still insufficient to track the deployment and implementation of California's Smart Grid."⁴⁷ CEERT supported EDF's proposed environmental metrics as well as the inclusion of a metric to measure thermal-storage air conditioning.⁴⁸

The DRSG proposed that Customer/AMI Metric 9 be revised to include the number of customers who use an authorized third-party to provide access to information. Specifically, DRSG would revise Customer/AMI Metric 9 as follows: "Number and percentage of customers with advanced meters using a utility or authorized third-party administered internet or web-based portal to access energy usage information or a utility-authorized internet or web-based portal to enroll in utility energy information programs."⁴⁹ DRSG argued that adding this language supports the Commission's prior action in D.09-12-046 allowing customers to access their data through an authorized third-party.⁵⁰

3.2. Discussion

No party opposed these metrics.

These metrics will provide the Commission, parties and the public with information that will allow for greater understanding of Smart Grid investments and provide a useful starting point in moving forward on the Smart Grid. Furthermore, these metrics will facilitate monitoring and measuring Smart Grid investments made by the utilities. The metrics will also assist the Commission in preparing its annual report on the Smart Grid, which is required by § 8367 of the Pub. Util. Code.

The Commission finds that the proposed metrics are reasonable, adopts the consensus metrics, and makes clarifying edits, as discussed below.⁵¹

There is merit, however, to the issues raised by SoCalGas concerning the applicability of metrics to gas companies. As explained in D.11-07-056, the original scope of this proceeding, and the requirement to file a Deployment Plan pursuant to SB 17, are limited to electric utilities.⁵² Additionally, the decision authorizing SoCalGas to install advanced gas meters is silent on the issue of whether SoCalGas should develop a Smart Grid Deployment Plan.⁵³ Based on these considerations, the Commission declines to apply these metrics to gas companies or gas consumption at this time.

3.2.1. Revisions to Customer/AMI Metrics

On Customer/AMI Metrics 1, 4, 5, 6, 7, 8, and 9, this decision makes minor revisions to those metrics to make the reporting consistent across measures. These revisions direct the utilities to report on the number and percentage of meter malfunctions and replacements, customers enrolled in particular tariff, complaints and HAN installations. These revisions ensure a consistency in reporting requirements and conform to the revised Customer/AMI Metric 9.

This decision also revises Customer/AMI Metric 2 to measure more specifically summer and winter peak reductions that are due to smart-grid-enabled, utility-administered demand response programs.

This decision revises Customer/AMI Metric 3 to add greater clarity to the reporting requirement.

On Customer/AMI Metric 4, the concerns expressed by the CAISO are well-taken. The means by which a customer uses a HAN device will ultimately be up to the customer. Indeed, we agree with DRA⁵⁴ that as the technology progresses and other means of communicating with devices develop, this metric may take on less importance. Nevertheless, we expect that until that time comes, the vast majority of devices will be registered by the customer with the utility. This metric will therefore provide the Commission and other parties with an understanding of the prevalence of HAN-enabled devices, and how well the HAN is progressing across the service territory.

This decision does not adopt the request of Greenlining to require the inclusion of census track information for Customer/AMI Metrics 4, 5 and 9. Although this type of information may be useful in tracking the growth in technology across demographics, PG&E's argument persuades us that it is unclear whether it is it is feasible and cost-effective to collect the information at this time. However, we do not see a similar problem concerning customer class, CARE status, or climate zone. We direct PG&E, SCE and SDG&E to continue working with Greenlining in investigating the feasibility of including zip code or census track measurement as part of the information that they collect and report to the Commission. Any agreed-upon revision to this metric should be made in the time-frames for revision discussed below.

This decision adopts the request of Greenlining to revise Customer/AMI Metric 9 so as to report by customer class, CARE status and climate zone. The Commission agrees that this data may be useful to monitor the types of customers making use of this information.

Additionally, DRSG proposed a revision to Customer/AMI Metric 9 to require an enumeration of the customers who have authorized third parties to have access to the information. Since access to customer information provided by third parties is as important as access provided by the utilities, this decision modifies this metric as requested

On Customer/AMI Metric 6, this decision adopts the request of DRA to revise the definition of an "Escalated Complaint." This decision agrees that this definition should be consistent across the utilities, as that will allow the Commission, Staff, parties and the public to be able to compare utility reports on a meaningful basis. In reply comments, SCE offered a proposed definition.⁵⁵ This decision adopts this proposed definition offered by SCE. The language in Customer/AMI Metric 6 is not changed, but this decision revises the definition of "Escalated Complaint" as follows:

Escalated Complaint: A complaint (written or telephonic) received by the utility's Consumer Affairs Department (or equivalent) regarding the AMI meter or program, or regarding device registration and communication issues.

DRA also requests that the information collected in Customer/AMI Metric 6 be tracked by the type of complaint. This decision finds this proposal reasonable. Customer/AMI Metric 6 should be organized according to the definition of escalated complaint. That is, complaints should be tracked by the following topics: AMI meters, AMI programs, device registration, and communication issues. To the extent that information is available, the reporting of this information can be divided by complaints about utility products, programs or devices and complaints about third-party products, programs or devices.⁵⁶

As the utilities gain more experience with customer complaints associated with Smart Grid-enabled devices, we expect to be able to collect more detailed information on complaints. At this time, however, this decision declines to adopt DRA's full suggestion to track escalated complaints by more specific descriptions.

This decision also adopts DRA's proposed modification to Customer/AMI Metric 7. Additionally, this decision adopts DRA's suggestion that this metric include the reason a meter is replaced. DRA argued persuasively that without including a reason for the replacement, this metric would hold less meaning. At a minimum, the reasons should include meter malfunction, meter installation error, or customer tampering; as the utility gains more experience with collecting and reporting on this metric, the reasons for replacement may be expanded. Customer/AMI Metric 7 is therefore revised to the following:

The number and percentage of advanced meters replaced before the end of their expected useful life during the course of one year, reported annually, with an explanation for the replacement.

3.2.2. No Revisions to Plug-in Electric Vehicle Metrics

There are no revisions to the proposed Plug-in Electric Vehicle Metric.

3.2.3. Revisions to Storage Metrics

The decision revises Storage Metric 1 to measure more accurately the amount of electricity released by a storage unit and reported by the transmission and distribution system.

Ice Energy's proposal to add a second metric to the Storage category is not adopted. As these metrics are designed to be preliminary and interim, the storage metric already identified is sufficient at this stage in Smart Grid development. While SB 17 identifies "thermal-storage air conditioning" as a Smart Grid technology, there is no specific direction to the Commission to include thermal-storage air conditioning as a separate category for measurement. As electric energy storage technologies begin to proliferate throughout the grid, the Commission expects further revisions in this category of metrics to begin measuring the variety of electric energy storage devices installed across the grid. Finally, this decision notes that a separate Commission proceeding is already on-going concerning electric energy storage.⁵⁷ The policies developed in that proceeding will likely have a great impact upon future smart grid storage metrics and this decision defers to that ongoing endeavor.

3.2.4. Revisions to Grid Operations Metrics

This decision revises Grid Operations Metrics 1, 2, 3, 4, and 5 to include a baseline year starting in July 2011 from which to start measuring. Additionally, this decision revises Grid Operations Metric 4 to require the reporting of the percentage of customers and circuits experiencing greater than 12 sustained outages. The data pertaining to "percentages" will allow the Commission to obtain information on the relative frequency of a particular issue.

3.2.5. Other Metrics

EDF's proposal to add two metrics under the Environmental category are not adopted at this time. As discussed below, development of metrics to measure any environmental benefits from Smart Grid implementation should be discussed in the context of a Technical Working Group. The metrics proposed by EDF deserve more attention and consideration than was possible in the record developed in this proceeding up to this point. The Commission expects the utilities, EDF and any other interested party to continue discussions around creating metrics that may be able to measure environmental benefits derived from Smart Grid implementation.

Finally, AReM requested that the Commission state that metrics only apply to the UDC company portion of operations, and that any benefits derived from Smart Grid should accrue to the appropriate entity. The Commission declines to make that determination at this time. AReM provides no suggested edits to the metrics to effectuate its changes and bases its supportive arguments on speculation on potential future benefits from Smart Grid. Thus, we cannot determine exactly what AReM requests. In addition, this decision also agrees with SCE's response that any discussion around the allocation of benefits should take place in the relevant proceedings where the benefits are produced, not here.⁵⁸ AReM is therefore free to reargue for cost and benefit allocation in those proceedings where benefits accrue; this Smart Grid proceeding is not the appropriate proceeding to discuss allocation of costs and benefits derived from Smart Grid investments because they are only rough estimates at this point.

⁹ California ISO Comments to ALJ Ruling at 2.

¹⁰ Id. Note: The California Clean Energy Future Implementation Plan (September 2010) was jointly developed by this Commission, the California Air Resources Board, the California Environmental Protection Agency, the California Energy Commission (CEC) and the ISO. It is available here: http://www.cacleanenergyfuture.org/common/CCEF%20Implementation%20Plan_vFinal_2a.pdf.

¹¹ Id. at 3.

¹² Ice Energy Comments to ALJ Ruling at 1.

¹³ Id. at 2-3.

¹⁴ Id. at 2. Ice Energy notes that this metric was included the initial Staff metric list included in the Joint Ruling.

¹⁵ Greenlining Comments to ALJ Ruling at 1.

¹⁶ Id. at 1.

¹⁷ Id. at 2.

¹⁸ DRA Comments to ALJ Ruling at 2.

¹⁹ Id. at 8.

²⁰ Id. at 8-9.

²¹ Id. at 9.

²² Id.

²³ Id. at 9-10.

²⁴ AReM Comments to ALJ Ruling at 2.

²⁵ Id.

²⁶ EDF Comments to ALJ Ruling at 1-2.

²⁷ Id. at 4.

²⁸ Id. at 5.

²⁹ SCE Comments to ALJ Ruling at 2.

³⁰ SCE Reply Comments at 3.

³¹ Id. at 4.

³² Id. at 4-5.

³³ Id. at 5.

³⁴ See R.10.12-007.

³⁵ SCE Reply Comments at 6.

³⁶ Id. at 6.

³⁷ Id. at 7

³⁸ PG&E Comments to ALJ Ruling at 1.

³⁹ PG&E Reply Comments to ALJ Ruling at 2.

⁴⁰ Id. at 3.

⁴¹ Id. at 3-4.

⁴² Id. at 4-5.

⁴³ SDG&E Comments to ALJ Ruling at 2.

⁴⁴ SDG&E Reply Comments at 2.

⁴⁵ Id. at 4-5.

⁴⁶ SoCalGas Comments to ALJ Ruling at 3-5.

⁴⁷ CEERT Reply Comments at 3.

⁴⁸ Id. at 4.

⁴⁹ DRSG Comments to ALJ Ruling at 1.

⁵⁰ DRSG Reply Comments to ALJ Ruling at 2.

⁵¹ The full list of metrics, including clarifying definitions, is included as Attachment A to this decision.

⁵² Pub. Util. Code § 8364 (directing that "each electrical corporation shall develop and submit a smart grid deployment plan to the commission for approval.").

⁵³ D.10-04-027.

⁵⁴ DRA Comments at 8.

⁵⁵ SCE Reply Comments at 4.

⁵⁶ The Commission does not expect the utilities to be the arbiter of customer complaints associated with third party devices and programs; rather, the purpose of this metric is to understand customer behavior and actions around third party devices and programs.

⁵⁷ See R.10-12-007.

⁵⁸ SCE Reply Comments at 7.