4. Positions of the Other Parties

Briefly, the positions of the other parties are as follows:

4.1. DRA

DRA recommends that PG&E's Upgrade proposal be rejected, arguing that it is not cost-effective. While DRA estimates that the advanced meters with the HAN gateway device, integrated load-limiting connect/disconnect switch and communication device can be procured at a substantially lower cost than estimated by PG&E and maintains that certain other costs estimated by PG&E related to project management, meter retrofits and technology assessment are excessive, its estimates of benefits do not cover its estimates of adjusted costs. DRA accepts PG&E's estimate of operational benefits and a portion of electric conservation benefits, but for various reasons rejects PG&E's estimate of gas conservation benefits, PTR benefits and Title 24 programmable communicating thermostat (PCT) benefits for use in evaluating the cost effectiveness of the Upgrade. DRA also proposes a two tier PTR rate design as opposed to the single tier proposal by PG&E. DRA also recommends that PG&E should further investigate the cost effectiveness of augmenting its SmartMeter Program to allow remote meter reading of customers' water usage for the larger water companies in PG&E's service territory.

4.2. TURN

TURN recommends that the Commission reject this application, asserting that (1) the operational benefits of the Upgrade project do not justify its costs, and the program is highly unlikely to produce the demand response benefits that PG&E expects; and (2) the AMI system with the HAN technology is expected to obtain the same demand response benefits that would have been obtainable with a cheaper, less risky air conditioner (AC) cycling switch and it would be unreasonable to spend $572 million dollars for such results.

If the Commission proceeds with any part of the application, TURN proposes that failure by PG&E to achieve 65% of the megawatt (MW) savings approved in D.06-07-027 and 100% of the additional PTR and PCT MW savings projected in this application should result in penalty payments to ratepayers.

4.3. CCSF

CCSF opposes PG&E's request for a number of reasons including poor technological choices in the original AMI proposal, little evidence to show the estimated benefits will actually occur, and its perception that the actual deployment of meters is not commensurate with the amount of money spent so far on the project.

With respect to DRA's recommendation that PG&E investigate the possibility of remotely reading water meters for water companies within its service territory, CCSF agrees that, to the extent feasible, water and electric utilities should be cooperating and working together in the best interests of their common customers. Because the City's water utility is in the process of implementing its own AMI system, the City indicates it is willing to work with PG&E to avoid system redundancy.

4.4. CAL-SLA

CAL-SLA opposes PG&E's proposal to increase street light rates for the Upgrade costs, because SmartMeters won't be installed in street lights and there are no demonstrated and proven cost benefits to the street light class.