4. Minimum Functionality Criteria

In a May 18, 2005 Ruling in the Commission proceeding on Pacific Gas and Electric Company's (PG&E) application for approval of funding for its own AMI pre-deployment activities (A.05-03-016), President Peevey set forth six minimum functionality criteria that a proposed AMI metering and communications system must meet in order for the Commission to consider approving ratepayer funding of pre-deployment activities. The six minimum functionality criteria described in the ruling indicated that the AMI system should:

· be capable of supporting a wide range of price responsive tariffs;

· collect data at a detail level that supports customer understanding of hourly usage patterns and their relation to energy costs;

· allow access to personal usage data such that customer access frequency does not result in additional AMI system hardware costs;

· be compatible with customer education, energy management, customized billing, and complaint resolution applications;

· be compatible with utility system applications that promote and enhance system operating efficiency and improve service reliability, such as remote meter reading, outage management, reduction of theft and diversion, improved forecasting, workforce management, etc.; and

· be capable of interfacing with load control communication technology.¹

Unlike in the pre-deployment applications of PG&E and SDG&E, no party disputes that SCE's proposed AMI technology meets these minimum functionality requirements. Therefore, the main issues to be resolved in this proceeding are whether any ratepayer funding beyond that provided during Phase 1 should be granted to support SCE's additional pre-deployment activities, and if so, what activities and amount of funding are appropriate.

¹ This list is a condensed summary of the list in Appendix A of the May 18, 2005 ACR in A.05-03-016.