4. Parties' Comments

CPA proposes that SCE's opt-out plan should "include the substantive and procedural components of the PG&E PD" for purposes of statewide consistency.25 It notes that this would include:

· Offering an analog meter opt-out option;

· Allowing all PG&E customers to select the opt-out option, regardless of whether they currently have a SmartMeter installed;

· Further consideration of whether to allow a community opt-out plan;

· Further consideration of cost and cost allocation issues.26

CPA further asserts that there must be further investigation on the security and privacy of SCE customer data under SCE's wireless mesh network. It notes that there have been news stories discussing how various banking industry databases have been compromised.27 As such, CPA believes review of SCE's opt-out proposal should include a review of SCE's, "as well as those of the other utilities implementing wireless mesh networks, evaluation of privacy and security practices."28

DRA urges the Commission to reject SCE's proposed cost recovery mechanism. DRA notes that while SCE does not explicitly request that the Commission approve its estimated revenue requirement for 2012-2014, the company does request a cost recovery mechanism that would allow full recovery of its costs. DRA recommends that if SCE is authorized to establish a memorandum account, "the decision should include the same protections for ratepayers as recommended in DRA's Comments on Pacific Gas & Electric's Opt-Out Program."29

DRA recommends that an analog meter opt-out option should be offered as a temporary or permanent opt-out option. It believes that if PG&E's customers are offered an analog meter opt-out option, SCE customers would likely be dissatisfied if they were not offered such an option. DRA contends that such an outcome would likely lead to legal challenges, resulting in creates uncertainty for SCE's opt-out program.30

DRA further notes that SCE's filing indicates that the analog meter opt-out option would cost less than radio-off and radio-out options. As such, DRA prefers this option over the radio-out and radio-off options. Further, it notes that there are no mandatory TOU rates for residential customers at this time and maintains that "allowing a small subset of residential customers to retain an analog meter and consumption meter reads may have no impact at all on California's energy policy goals."31 DRA also maintains that since the costs to collect interval energy consumption data increase opt-out costs, this information should not be required unless an opt-out customer participates in a time-variant pricing tariff.32

Finally, DRA maintains that there should be further consideration of potential costs savings associated with allowing customers to self-read meters, with quarterly or semi-annual true ups. DRA believes that SCE has understated the costs associated with customer self-reads, and therefore urges the Commission to further consider the potential cost savings by allowing customer self-read of meters.33

In response to CPA and DRA's comments, SCE states that it is impracticable to offer an analog meter opt-out option as it "has used non-analog, non-smart meters in its service territory for many years."34 Therefore, SCE requests that if the Commission ultimately decides to adopt an analog meter opt-out option for SCE residential customers, it should allow SCE to "reinstall the prior meter form at the customer's premises," which in some cases would be a non-analog, non-smart meter.35

SCE also rebuts DRA's assertion that interval energy consumption data should not be collected until it is necessary to support an opt-out customer's participation in time variant pricing tariffs. It states that most residential customers are currently enrolled in Peak Time Rebate, which is a time variant pricing program.36 As such, SCE maintains that the Commission should not adopt an opt-out option that would restrict the collection of interval energy consumption data, as it would impact the Commission's Smart Grid objectives.37 SCE also recommends that the Commission not allow customer self-reads. It believes that while this may result in lower meter reading costs, any savings would be offset by increased costs associated with billing exceptions.38

SCE further states that it plans to file updated costs associated with offering an opt-out option in the near future and "expects the Commission will find its updated costs reasonable."39 To the extent these costs are found to be consistent with the scope of offering the option, SCE asserts that they should be adopted and not subject to an after-the-fact reasonableness review.40

Finally, SCE contends that CPA's comments regarding privacy and cyber security are outside the scope of this proceeding. It notes that the Commission "adopted rules to protect the privacy of customer data in D.11-07-056" and that cyber security is to be addressed in the Smart Grid Proceeding, Rulemaking (R.) 08-12-009.41

25 The proposed decision addressing PG&E's application to modify its Smart Meter Program was adopted by the Commission on February 1, 2012. This decision is D.12-02-014.

26 Comments of Consumers Power Alliance on Southern California Edison Company's Smart Meter Technological Feasibility and Cost Information Compliance Proposal Pursuant to D.11-11-006 (CPA Comments), filed January 17, 2012 at 6.

27 CPA Comments at 7.

28 CPA Comments at 8-9.

29 Comments of the Division of Ratepayer Advocates on Southern California Edison Company's Smart Meter Opt-Out Proposal (DRA Comments), filed January 17, 2012, at 4.

30 DRA Comments at 5.

31 DRA Comments at 6.

32 DRA Comments at 7.

33 DRA Comments at 7-8.

34 Southern California Edison Company's Response to Comments on Its Smart Meter Technological feasibility and Cost Information Compliance Proposal Pursuant to D.11-11-006 (SCE Response), filed January 27, 2012, at 2. As discussed above, SCWSSM's ex parte comments are not part of the record and not considered in this decision. As such, we do not consider SCE responses to these comments.

35 SCE Response at 2.

36 Under SCE's Schedule D, Peak Time Rebate would apply "upon the installation of an Edison SmartConnectTM meter and the meter is program ready."

37 SCE Response at 3.

38 Id.

39 SCE Response at 4.

40 Id.

41 Id.

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