5. Metrics Review Process

The metrics that are adopted by today's decision are intended to be interim and preliminary, and are expected to be revised and edited over the coming years as advances in technology and infrastructure allow for greater understanding of the grid and consumer behavior. This section will set up a process for the initial review of the metrics.

5.1. Positions of Parties

Concerning the revision of metrics, parties proposed several methods for routinely updating and revising metrics as technology advances. The commenters had much in common - all parties that provided comments on this topic of revising metrics agreed that there should be a yearly process for reviewing and revising the metrics.

SCE proposed a three step process for development of future Smart Grid metrics. SCE suggested that the process include both an informal and formal process, follow specific criteria, and fit within a defined time-line. SCE recommended that an informal Technical Working Group be convened as a starting point for review and revision of consensus metrics.⁷⁰ SCE also proposed that any new metrics be based on certain criteria: consistency with P.U. Code § 8360, consistency with content of the Smart Grid Deployment Plans, reasonable cost of measurement, and consistency across PG&E, SCE and SDG&E.⁷¹ As for the timing of metric reviews, SCE recommended that the review of adopted metrics and the consideration of new metrics be deferred until the filing of their deployment plans on July 1, 2011. By waiting until after the deployment plans are filed, SCE states that the plans will help "determine (i) which subject matter should be prioritized by Technical Working Groups, and (ii) which Consensus Metrics require updating or revision."⁷²

SCE also proposes that Technical Working Groups should be convened to revise the consensus metrics, where necessary, and develop other metrics.⁷³ These working groups can be convened on a yearly basis and recommend revisions and additions to the metrics in time for the yearly report.⁷⁴ SCE proposed a preliminary schedule for the timing of these working group meetings tied to this annual reporting process.⁷⁵

PG&E also supported an annual review and updating of the metrics. PG&E recommended that meetings be convened "for the purpose of periodically reviewing and updating the interim metrics."⁷⁶

DRA stated that the "metrics should be reviewed on a regular basis, with revisions made as necessary."⁷⁷ DRA recommended that the Commission adopt a formal review process and allow for a public comment period before Commission adoption.⁷⁸ According to DRA, metrics should be "revisited prior to filing of the July 2012 deployment plans."⁷⁹ The Commission will be better informed about the plans and the process, and will have reviewed the initial deployment plans.⁸⁰

The CAISO argued that "it is crucial that the metrics be reviewed on an ongoing basis."⁸¹ The CAISO suggested that the Commission establish an annual review process "to ensure that the metrics remain tailored to the state's highest smart grid priorities."⁸²

Granite Key/Aspect Labs supported the holding of a workshop "at a later date" to discuss any potential revisions to the metrics, as well as allow for a forum to discuss "areas of non-consensus."⁸³

5.2. Commission Revisions of Metrics

The request for review and revision of adopted metrics is reasonable and we outline and describe a process below that will address the reports of Technical Working Groups and consider technical revisions to consensus metrics. This approach allows the Commission to gain experience with preparing annual reports and with reviewing metrics and revising them before establishing a rigid review process.

The ability for parties and Commission Staff to review and revise these metrics, where and when appropriate, is of great importance to ensure that the Commission and parties continue to make progress in renewing the grid's infrastructure. The Commission expects that these metrics will be updated, including adding new metrics and removing metrics that are no longer useful, over the course of the next several years. The request of an annual updating of metrics, however, seems overly ambitious. Rather than adopt a specific schedule for the updating of metrics, we commit to workshops and workshop reports that will lead to the adoption of revisions to metrics and to a process for updating metrics.

In order to facilitate the ability of parties to continue developing and revising these metrics, the Commission directs the creation of a Technical Working Group that is designed to focus on the development and review of metrics and measureable goals. This Technical Working Group should be composed of interested parties, including, at a minimum, representatives from PG&E, SCE and SDG&E, DRA, CAISO, CEC and Commission Staff. The Commission expects that additional representatives from consumer groups, end-users, third parties and other advocacy groups will participate. Additionally, the creation of this Technical Working Group does not mean parties cannot discuss proposed revisions outside of the working group process; however, in order for a metric to be considered as "consensus" it must go through the Technical Working Group process.

This Technical Working Group should review metrics by topics as listed in the consensus metrics; this will facilitate the review and creation of any new metrics by those interested in the specific topic areas. The Technical Working Groups should circulate their first report with recommended changes in the consensus metrics to the service list in this proceeding. In addition, the Commission will rely on its staff to bring proposed revisions to the Commission's attention.

To guide the work of the Technical Working Groups, the Commission adopts SCE's proposed criteria for guiding metric development. Specifically, any new metric developed during the working group process should be consistent with the Public Utilities Code, including § 8360, should be consistent across PG&E, SCE and SDG&E, and should be consistent with any metrics or policies in an approved Smart Grid Deployment Plan. Additionally, new metrics should not be too costly to implement or measure. Commission Staff will schedule workshops with this Technical Working Group.

⁷⁰ SCE Comments at 4-5.

⁷¹ Id. at 5-6.

⁷² Id. at 6-7.

⁷³ Id. at 7.

⁷⁴ Id.

⁷⁵ Id.

⁷⁶ PG&E Comments at 2.

⁷⁷ DRA Comments at 3.

⁷⁸ Id.

⁷⁹ Id. at 4.

⁸⁰ Id.

⁸¹ CAISO Comments at 2.

⁸² Id.

⁸³ Granite Key/Aspect Labs Comments at 5.