14. DRA's Water Utility Proposal

DRA proposes that PG&E's SmartMeter Program facilitate the automated meter reading (AMR) of its customers' water usage. It is DRA's belief that AMR provides cost savings mainly associated with water meter reading and assists as a tool to promote water conservation. According to DRA, facilitating water AMR is fairly easy to do at the meter endpoints. Also, the amount of additional information involved would not significantly tax the head-end hardware and software given that water meter reads generally only occur monthly. The largest issue is that of PG&E coordinating with the billing departments of various water utilities and providing billing data in an electronic form in a timely and secure manner.

DRA accepts that water metering benefits need not be part of this proceeding, but urges the Commission to order PG&E to try to incorporate this potential benefit into its long term deployment. DRA states that PG&E should hold workshops, as SCE has agreed to do in its AMI settlement, to explore issues related to AMI for water utilities.

14.1. CCSF's Position

CCSF interprets that the purpose of DRA's testimony regarding water metering appears to have been to recommend that the Commission should explore the possibility of using of using PG&E's AMI system for water metering in a separate proceeding and does not object to the recommendation. CCSF states, to the extent feasible, water and electric utilities should be cooperating and working together in the best interests of their common customers. Because CCSF's water utility is in the process of implementing its own AMI system, CCSF states it is willing to work with PG&E to avoid system redundancy. In the event the Commission should decide to hold workshops on this issue, CCSF recommends that the Commission first notify all water utilities and urge them to participate.

14.2. PG&E's Position

Consistent with DRA's recommendation, PG&E supports ongoing dialogue with water agencies and seeks the flexibility from the Commission to pursue these discussions through either multi-party workshops or direct dialogue with the water utilities. PG&E also states that, for the most part, CCSF echoes the recommendations of DRA and, to the extent CCSF does so, PG&E does not disagree with CCSF's testimony. However, PG&E states that it does disagree with the suggestion in CCSF's testimony that it may be cost-effective for PG&E to consider use of CCSF's possible automated water meter reading system.

PG&E indicates that it is highly unlikely that it would ever be cost-effective for PG&E to use a water utility's water meter reading system and cites the following cross-examination of DRA's witness:¹¹⁴

CCSF Counsel: And are they -- the AMI systems being installed by these water companies, could they be used by PG&E instead of the water companies using PG&E's?

DRA Witness Abbott: No. It would normally be the other way around. And the reason for that is that the electric metering application is very data-intensive. There's an awful lot of data processing. In this case we're talking about PG&E doing hourly metering. There's very few cases that I'm aware of in which any water utility would try to deal with hourly water metering at the residential level.

PG&E agrees with DRA on this and recommends that the Commission should not entertain CCSF's suggestion any further.

14.3. Discussion

DRA's recommendation that PG&E pursue water meter AMR with water utilities in its service territory is reasonable and may result in additional benefits for the SmartMeter project. PG&E and CCSF support DRA on this, and we will order PG&E to work with the water utilities, either through multi-party workshops or direct dialogue with the water utilities.¹¹⁵ We suggest that this should be done sooner rather than later and will require that PG&E report back on the status of its efforts and results of its discussions on a quarterly basis.

We understand PG&E's concerns regarding its use of a water utility's AMI system and suspect that it would be an unlikely occurrence, but we will not limit potential discussion and foreclose that possibility.

¹¹⁴ DRA, Abbott, 4 RT 495-496.

¹¹⁵ PG&E should arrange and conduct the workshops similar to what is currently being done by SCE in addressing a similar requirement.