4. Reporting of Metrics
There are two questions posed by the parties regarding the reporting period for metrics. The first involves the filing of the initial set of metrics, and the second involves the subsequent reporting of metrics with the Annual Report. The Commission will address both questions.
4.1. Positions of Parties
PG&E, SCE and DRA support setting the reporting date for the initial set of metrics of July 1, 2011.59
SCE requested that the Commission reconsider using June 30 as the end date for the yearly reporting period. SCE noted that many of their reporting schedules for information that serve as a basis for the Smart Grid metrics are collected annually and argued that having a different reporting period may increase reporting costs.60
PG&E also supported using December 31 of each year as the reporting period date, instead of June 30.61
DRA noted that the Commission decided to use June 30 as the reporting date to have more current information in the creation of the Commission's Smart Grid annual report, which is due to the Legislature every January 1.62 DRA, however, stated that it is concerned about potential increased costs due to reporting metrics as of June 30.63
4.2. Discussion
Utility smart grid annual reports are due to the Commission by October 1 of each year, starting on October 1, 2012. The purpose of the utility annual reports is to describe the current state of the utility's Smart Grid deployments and investments. As previously specified, the utility's annual report must include:
· A summary of the utility's deployment of Smart Grid technologies during the past year and its progress toward meeting its Smart Grid Deployment Plan;
· The costs and benefits of Smart Grid deployment to ratepayers during the past year; and
· Current initiatives for Smart Grid deployments and investments.64
Additionally, the utilities' annual report is the place where the utilities report on their performance using metrics adopted in this decision.
Finally, the utilities' annual report will serve as the basis for the Commission's annual report to the Governor and Legislature. The Commission is required by statute to prepare an annual smart grid report, which is due to the Governor and Legislature by January 1 of each year, beginning in 2011.65 The purpose of the Commission's Annual Report is to "report ... on the commission's recommendations for a smart grid, the plans and deployment of smart grid technologies by the state's electrical corporations, and the costs and benefits to ratepayers."66
In D.10-06-047, the Commission stated that information to be included in the utilities' Annual Report filings should be current as of July 1 of each year.67 The Commission reasoned that a reporting period of July 1 to June 30 for each year would provide "the most recently available information on the utilities' Smart Grid actions, and will allow the Commission to provide the Governor and Legislature the best available information."68 Additionally, the decision explicitly denied SCE's request to use December 31 as the reporting period, noting that using a December 31 reporting period would result in "the Governor and Legislature ... receiving a report using information that is over a year old."69
SCE and PG&E have not persuaded the Commission to revise the reporting period date for the metrics or the Annual Report. This decision reaffirms that using information collected on a calendar year basis and reported 12 months later is not in keeping with the intention of the statute, and it would prove less useful to the Commission, the Legislature, the Governor, parties, or the public. The Commission understands, however, that some information may only be available on a yearly basis, and may be costly to update during the year. SCE, PG&E and SDG&E should provide cost information on those metrics that require a costly mid-year adjustment. During the metrics review process, as discussed below, the utilities may request a change in the reporting period in those situations where it is costly to obtain the information. Nevertheless, until that time, the utilities should continue to report metrics as of July 1 to June 30 for each reporting year.
59 PG&E Comments at 3; SCE Comments at 3, 8-9; DRA Comments at 4-5.
60 SCE Comments at 9.
61 PG&E Comments at 3.
62 DRA Comments at 4.
63 Id. at 4-5.
64 D.10-06-047 at 100.
65 Pub. Util. Code Sec. 8367.
66 Id.
67 D.10-06-047 at 101.
68 Id.
69 Id.
