14. Societal Benefits

DRA raised an issue that PG&E only addressed (1) operational costs and benefits and (2) demand response benefits, but it did not include in this proceeding a value for certain societal benefits that would result from AMI. DRA states that "societal benefits are benefits that probably do not lower the utilities' costs directly." (DRA's Opening Brief, p. 9.) DRA presented several examples: at least two examples should be mentioned now. DRA suggests voltage reduction can occur, based on AMI-derived system data, which could lead to cost reductions. Secondly, DRA suggests there is a potential to reduce the frequency and duration of outages with better information about the current status of the distribution system.

No party disputes societal benefits such as these and others are likely to occur with an AMI deployment, but no one offers a persuasive "hard" value for these benefits to consider in the economic evaluation of AMI. We will therefore acknowledge our expectation of societal benefits but we will not rely on their existence to justify the deployment of AMI. There are sufficient probable operating and demand response benefits to justify deployment.

Additionally, PG&E is agreeable to a DRA proposal to conduct a feasibility analysis of voltage reduction based on AMI-gathered data, although PG&E's testimony indicates various concerns about the practicality of using AMI to regulate voltage. PG&E has indicated that it will work with the AMI system vendors to determine the technical feasibility and costs associated with the use of AMI for voltage reduction. PG&E offers that that if it is reasonable to use AMI voltage measurements to help regulate circuit voltage, then it will collect information on using AMI data to analyze and manage circuit voltage and it will provide a report on these matters in its next general rate case. DRA indicated that PG&E's study proposal is acceptable.58

PG&E proposes to provide reasonable immediate data access to customers and to promptly develop data access structures based on the needs of customers and other stakeholders. PG&E suggests: web (internet) access for all customers to their data up through the previous day; real-time data access devices for customers over 200 kW; offering customers and their energy service providers access to all accounts with a single log-in to be phased in during the first part of the project; and an Automated Data Exchange proposal to be developed and presented to the Commission within 180 days of setting the first AMI meter along with a request for additional funding; and additional PG&E also proposes that it should develop data access structures later, at incremental cost, once the needs of other stakeholders are understood. (PG&E's Opening Brief, pp. 62 - 63.) This comports closely with recommendations by SPURR. (Ex. 401.)

SPURR, SVLG and eMeter filed an opening brief as Joint Parties. These parties propose that PG&E should promptly file an advice letter to implement a tariff for customer access to its detailed account data. They also propose that PG&E should promptly implement an Automated Data Exchange proposal to address SPURR's recommendation that customer data be available to qualified third parties at the same time and on the same terms provided to PG&E's internal departments.

The Joint Parties propose hourly and daily electricity and gas usage data collected via the AMI network should be posted to a data server in an open format immediately following retrieval and any necessary pre-processing. This will allow any qualified (not yet defined) party to retrieve the data automatically over the internet using an automated software process. They suggest two key principles: (1) the data is accessible to customers and to qualified parties at the same time as PG&E's Information Technology systems gain access to the data and (2) qualified party access may be authorized either electronically or by a paper authorization with "wet" signature from the customer. This embryonic proposal, suggested by the Joint Parties, should be further developed by PG&E, the Joint Parties, and any other interested parties and they also propose that this data access system should be filed and approved, by the Commission's informal advice letter process by an advice letter to be filed within 180 days of this decision. (Joint Parties' Opening Brief, pp. 4 - 5.)

We agree in large part that all customers should have prompt access to their own data. But we have no record here, and the advice letter process is too limited to allow the development of an adequate record whereby we might grant third parties access to customer data and create a public interface with PG&E's data systems. An advice letter is also an improper procedure to adopt funding for such a project. We will require PG&E to file an application, with appropriate supporting testimony and underlying work papers to support its proposal, including cost recovery. We will not impose a 180-day deadline from the first meter installation - deployment will take time and the data access interface needs to safeguard customer privacy and further it must also safeguard PG&E's operating data from unnecessary access or damage.

We will further require that prior to filing the application PG&E, conduct only publicly noticed open workshop discussions and that no party or sub-group of parties has greater access than any other stakeholder in the process. We expect and encourage DRA to actively participate, and as necessary, to involve any other staff division (e.g., Energy Division, Public Advisor) that can provide additional advice or input on consumer privacy, or any other relevant issue. We are concerned with protecting both the nascent competition in customer-side-of-the-meter services or products and safeguarding consumer privacy. SPURR's testimony recognized the need to ensure no "undue preference" for PG&E's internal service offerings to those of third-party providers that SPURR may otherwise prefer. (Ex. 401, p. 5.) We agree and will go further to protect all consumers from unwarranted intrusions.

We are also concerned about the cost impact on smaller customers, so we believe that PG&E must focus on providing the lowest cost or even no cost (especially no tariff rate or charge) for the most basic of timely access for residential consumers. Any program feature likely to increase the cost of the system should be focused on the larger customers who are most likely to use and benefit, and therefore should pay for enhanced program features. For the sole purpose of providing individual customers day-after free web access to their own billing data, we will allow PG&E to file an advice letter as soon as possible. No third-party access, aggregation of data, or any funding request, should be included in this limited proposal.

We direct PG&E to conduct an open workshop process and then file a ratesetting application in not less than 180 days and no later than one year from the effective date of this decision.

SPURR proposes that PG&E accommodate customer requests (including requests by third-party energy service providers who provide commodity service) to have selected meters read on a single day in each calendar month. PG&E indicated it will try to accommodate these requests for specific meter reading and billing periods, "subject to various capacity constraints in the measurement, billing, and collection processes." (PG&E Brief, p. 64.) PG&E states it has a limited capacity to do this. PG&E processes an average of 260,000 bills per day and points out that changing metering or billing periods could cause PG&E to incur additional costs. Therefore, we direct PG&E to ensure that all incremental costs are borne solely by those customers or energy service providers who request this special service. PG&E must file a new tariff charge by advice letter to establish this service and recover these costs. This tariff offering is much smaller and therefore more reasonable for an advice letter than the proposal for real-time billing access previously discussed.

While we recognize that PG&E's AMI deployment meets our functionality requirements as set forth, new technology may emerge that offers PG&E and its customers increased reliability and performance enhancements. We expect PG&E to monitor market place developments so, whenever feasible, it can upgrade its AMI system and offer its customers technology upgrades. To enable us to keep abreast of the AMI program, we will require PG&E to provide us with semi-annual assessments of advancements in relevant technology and its AMI deployment, beginning six months after the adoption of this decision. PG&E shall provide this assessment to the Commission's Energy Division, DRA and other parties in this proceeding. These assessments should include general information on advances in metering technology and infrastructure with specific information, when available, on (1) meter/meter module reliability, (2) meter/meter module costs and performance, and (3) movement or adoption of open architecture standards for automated meters.

Through this process, the Commission intends to monitor PG&E's AMI system performance. PG&E's semi-annual assessments must address both system performance and system cost effectiveness. Within 180 days, PG&E is required to establish performance criteria in consultation with the Commission's Energy Division and DRA that can be used by PG&E to monitor and periodically evaluate its system implementation. At PG&E's first semi-annual assessment, PGE should self assess its AMI system based on these performance criteria. We also expect PG&E to continuously review and evaluate its system cost effectiveness - identifying costs and benefits realized versus those projected in the utility's AMI project application as approved. The semi-annual assessments should include PG&E's updated cost effectiveness review. In the future, the Commission may consider incentive mechanisms to encourage PG&E to improve the performance and cost effectiveness of its AMI project.

It is our desire to ensure that both customers and PG&E gain the full benefits of AMI deployment-particularly with the rollout of demand response tools such as time-varying rates. PG&E should also be encouraged to continue to experiment with its own information systems and information services, and regularly reassess customer demand for real-time energy usage information. Therefore, PG&E's semi-annual assessment should examine (1) the ability to provide real-time usage / pricing information to customers and (2) customer interest in accessing real-time usage / pricing. PG&E shall stringently safeguard customer privacy information and protect any market sensitive operating data as needed.

In addition to the semi-annual assessment, PG&E should conduct an annual workshop in conjunction with the California Energy Commission to provide the vendor and intervener community with an opportunity to observe and comment on PG&E's AMI assessment.

As discussed above we will adopt the gas and electric balancing accounts proposed by PG&E. We will adopt PG&E's calculation of per-meter monthly benefits: $1.7722/per meter-month for electric and $1.0366 for gas. We will allow new construction pre-deployment costs in the balancing account at the time of installation and benefits to accrue at the time the new construction territory is converted to the AMI network. We direct PG&E to aggressively pursue all operating and societal benefits and to provide detailed testimony in the next general rate case reporting on the maximum potential for all such benefits.

58 Opening Brief, p. 63, and referencing Ex. 11, p. 20-1.

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