4. The Positions

At their heart, the positions of parties are fairly simple. PG&E believes that it has satisfied the minimum functionality criteria specified by Commissioner Peevey's May 18, 2005 Ruling, has conducted a thorough due diligence process to develop its project, and has proposed an appropriate scope and scale for pre-deployment activities, which honor the Commission's objectives related to pursuing AMI and demand response capabilities in a timely manner. In addition, PG&E believes that it has a pending application
(A.05-06-028) for a highly cost-effective project, and that even if the exact project it recommends is not ultimately adopted, the Commission will approve some form of AMI for PG&E so that all of the pre-deployment expenditures it proposes will be useful to ratepayers.

TURN and ORA believe that the scope and scale of PG&E's proposed pre-deployment efforts is overbroad and unjustified without a finding that moving forward with AMI is cost-effective. They argue that if the Commission decides that ratepayer funding is not appropriate for PG&E's proposed AMI project, the ratepayers will have paid up to $49 million for an integration effort that has no value to ratepayers unless AMI is deployed.

SSJID and Yolo County Parties are pursuing potential municipalization of certain areas in PG&E's current service territory and seek to limit the AMI
pre-deployment and installed metering and communication system costs in the areas where they hope to acquire customers in order to ensure the lowest cost of municipalization possible.