California
Public Utility Commission Develops
Requirement for Direct Access Metering
On December 17, 1998, the California Public Utility Commission rendered a decision regarding permanent standards for metering and meter data. this decision makes California the first state to develop a comprehensive requirement for direct access metering. The decision attempts to not limit creativity and innovation by the industry on the types of metering being used for direct access, but sets up basic equipment requirements and operational guidelines. California has embraced national standards as its foundation while establishing a few unique requirements for new meter type testing.
The AEIC Meter and Service Committee provides the following text of the California decision as an informational tool for use by AEIC members and other interested parties. AEIC does not attest to the accuracy of the document. Accuracy should be verified by contacting the original document authors.
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Decision 98-12-080 December 17, 1998
BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA
| Order Instituting Rulemaking on the Commission’s Proposed Policies Governing Restructuring California’s Electric Services Industry and Reforming Regulation. | Rulemaking 94-04-031 (Filed April 20, 1994) |
| Order Instituting Investigation on the Commission’s Proposed Policies Governing Restructuring California’s Electric Services Industry and Reforming Regulation. | Investigation 94-04-032 (Filed April 20, 1994) |
DECISION REGARDING PERMANENT STANDARDS
Interim meter and meter data standards were initially adopted in Decision (D.) 97-10-087 and D.97-12-048. Today’s decision addresses the recommendations for permanent standards which were contained in the workshop report filed by the Permanent Standards Working Group (PSWG).
In adopting the permanent standards, we have tried to avoid adopting standards which are too narrow in scope, and which limit technology choices. Today’s decision favors an open architecture approach which focus on the continuing safety, accuracy and reliability of meters and meter data. Attachments A, B, C and D of this decision summarize the permanent meter and meter data standards that we adopt. Those attachments reference the pertinent passages in our decisions, and in the appendices to the PSWG’s workshop report, which make up the permanent standards. Attachment E contains a glossary of the various acronyms used in this decision.
Among the permanent standards we adopt are the following:
In D.97-12-048, the Commission ordered the creation of the PSWG. The PSWG was formed to review the interim meter standards that were approved in that decision, and to recommend what permanent meter standards should be adopted by the Commission. The decision also directed the PSWG to determine whether other standards could be expected in the future, and to recommend a process for reviewing possible future changes to the permanent meter standards. D.97-12-048 ordered that a workshop be held, and that the PSWG file a Workshop Report with its recommendations for permanent meter standards.
The Energy Division convened a workshop on January 29, 1998. In order to address the numerous metering issues, the PSWG established the following four subgroups: (1) meter equipment; (2) meter communications; (3) meter data management (MDM) and meter reading; and (4) meter installation, maintenance, testing and calibration. A separate subcommittee was also formed to investigate national issues that might impact California standards.
The four subgroups met once every two weeks. The full PSWG membership met once a month to monitor overall progress, and to vote on the items recommended by the subgroups for approval.
Many different entities, including MSPs, MDMAs, meter manufacturers, ESPs, UDCs, employee representative groups, consumer representatives, and municipal utilities, actively participated in the PSWG process.
The PSWG filed its "Permanent Standards For Metering And Meter Data Used In Direct Access" (Workshop Report) on July 29, 1998. The recommendations contained in the Workshop Report were voted upon by at least
two-thirds of the eligible voting membership of the PSWG. When the recommendations were not supported by 100% of the voting membership, the Workshop Report included the non-majority positions, if those views were expressed.
Comments to the Workshop Report were filed by the California Energy Commission (CEC), Coalition of California Utility Employees (CCUE), Pacific Gas and Electric Company (PG&E), and Southern California Edison Company (SCE). Joint comments to the Workshop Report were filed by the Electric Power Research Institute (EPRI), the Institute of Electrical and Electronics Engineers (IEEE) Standards Coordinating Committee 31 (SCC31), and the Office of Ratepayer Advocates (ORA). In addition, the Executive Board of the Southern California Chapter of the International Association of Electrical Inspectors (IAEI) submitted a September 25, 1997 letter in response to the Workshop Report.
III. Summary of the Workshop Report
In this part of the decision, we provide a summary description of the recommendations that the PSWG voted upon. These descriptions do not fully describe each recommendation or rule. For a full description of the recommendation or rule, one must turn to the appendices which are attached to the Workshop Report.
The first series of recommendations in the Workshop Report address meter equipment. The PSWG reviewed the applicable national standards and made recommendations as to which performance standards should be required. Appendix A to the Workshop Report contains a recommended list of standards that the PSWG suggests should be adopted (Table I-1), and a list of standards which the PSWG recommends not be required (Table I-2). Appendix A of the Workshop Report also contains a list of the tests that are to be performed in connection with the American National Standards Institute (ANSI) C12.1 and C12.20 standards (Table I-3), and the "Certification Testing Requirements" which detail the procedures and criteria that the meter product testing must comply with (Workshop Report, App. A, Section II). All of the members of the PSWG who voted recommended that the meter equipment recommendations be adopted.
The following is a description of the meter equipment standards that the PSWG recommends be adopted:
This provision is the basic accuracy, safety, and performance requirement standard for meters and metering equipment. The PSWG recommends that this standard be used in accordance with the "Certification Testing Requirements" that are contained in Section II of Appendix A of the Workshop Report.
The Certification Testing Requirements address general meter testing requirements, the criteria for defining when a meter product fails, the criteria for rejecting certification of a meter type, test setup procedures, a description of the ANSI C12.1 tests, a description of the ANSI 12.20 tests, and a description of the sunlight interference test. The Workshop Report notes that some of the meters that have not met the Certification Testing Requirements, failed to operate accurately during meter performance trials conducted within California.
The PSWG does not recommend that all meters be required to have a meter socket. However, if a meter is socket mounted, the PSWG recommends that the socket and the associated meter meet ANSI 12.7 to ensure the accuracy and safe installation of socket mounted meters.
This provision is a safety standard for A-Base meters. The Workshop Report states that this standard ensures that A-Base meters do not represent an electrical hazard.
This provision is a safety standard that covers the dimensions and functions of test switches for proper marking and installation.
This standard defines the configuration, accuracy, and performance requirements of electromechanical meters and complements ANSI C12.1-1995.
This provision governs the accuracy and performance requirements for instrument transformers for metering. This standard will ensure that the UDCs continue to install the same accurate metering instrument transformers that the UDCs currently install for their own metering needs.
This standard applies only to meters that have time-of-use (TOU) registers, and defines the accuracy and performance requirements for these registers.
The PSWG does not recommend that optical ports be required. However, if a meter has an optical port that is physically identical to an ANSI Type 2 optical port, then the optical port shall meet all the requirements of ANSI C12.18. Other kinds of optical port types would be exempt from this requirement.
This standard adds additional accuracy and performance requirements to ANSI C12.1. The PSWG recommends that for purchasing consistency in California, this standard be used in accordance with the requirements of Section II in Appendix A to the Workshop Report.
This safety standard adds performance requirements to ANSI C12.1 and ANSI C12.20.
These four provisions are accuracy and safety performance standards that are used in conjunction with ANSI C12.11. These standards will ensure that the UDCs continue to install the same accurate metering instrument transformers as they currently install for their own metering needs.
The PSWG recommends that all of the meters and associated equipment meet all applicable FCC regulations.
The PSWG recommends that the meter manufacturers file with the Commission their meter type self-certification document. The document would state that the meter type meets the Commission certification testing requirements. After the Commission has reviewed and approved the certification, the PSWG recommends that the Commission post on its web site a list of meter types that are in compliance with all Commission-approved metering standards.
The PSWG recommends that the meter manufacturers attach various identifying labels on the meters. For sealing and locking hardware, it is recommended that this hardware be imprinted with the company name and/or logo, and that it be made with a material other than lead. The sealing hardware owned by the MSPs are to be orange in color, and is to be imprinted with the MSP’s certification number.
To identify a customer premise which has a life support system, the sealing hardware is to be white in color and imprinted with a red caduceus (medical symbol). Any stickers to identify the meter as serving a premise which has life support equipment shall also contain the red caduceus.
The PSWG also recommends that a sticker be used to identify a 480 volt service panel and meter. In addition, the PSWG recommends that new meter products be permanently labeled with the manufacturing date.
C. Interconnection, Open Architecture, and Interoperability
The discussion in D.97-12-048 regarding open architecture and interoperability triggered significant discussions by the PSWG. The meter communications subgroup created Diagrams A and B, which appear at pages 14 and 16 of the Workshop Report. Those diagrams visually describe how the meter and meter data systems are interconnected, and identify potential areas where interoperability would be feasible.
Diagram A shows that there are two possible places where open architecture can occur. The first is between the MDM and the retail market participant. The second is between the meter and the meter reading system.
Diagram B is a further detail of the diagram that appeared on page 11 of D.97-12-048.
The PSWG discussed the degree to which interoperability is feasible for direct access, and came to the following conclusions:
The PSWG also concluded that the closer interoperability is to the point of measurement, the easier it is for a customer to switch ESPs. Thus, the PSWG defined a level of interoperability at interface 3 of Diagram B, which is the interface between the meter and the communications modules that connect to the meter reading system.
The majority of the PSWG recommends that interoperability should be available in the following four areas:
Meter communications addresses the communication between the meter and the meter reading device. The objective of the PSWG was to develop standards that will enable a wide number of market participants to access and retrieve data from electric meters. The PSWG makes the following recommendations on meter communication standards to enhance interoperability.
Regarding the ANSI C12.19 recommendation, the PSWG agreed that the meter should communicate in the format specified by that standard, but that the entities should not be required to store the data in the ANSI C12.19 format.
The discussions over the C12.19 standard recognized that if the standard was applied, it may not allow for a "plug and play" environment. That is, some meter products may have to be replaced or retrofitted to accommodate the new communications protocol.
The majority of the PSWG agreed that the C12.19 standard will create a degree of interoperability that will benefit the marketplace. The Workshop Report notes that with current telephone modem technology, this standard would make it possible for customers on telephone-read meters to switch ESPs without having to replace their meters.
The majority also agreed that the C12.19 standard will not be compatible with all radio frequency based technologies. Such a standard will have an impact on bandwidth and response times by increasing the message length and making radio frequency transmissions more expensive.
The PSWG recommends that all meter types released before March 20, 2000 to be exempt from the C12.19 standard. Thus, all new meter types released after March 20, 2000 will be required to meet the C12.19 standard.
E. Meter Data Management and Meter Reading
The PSWG reviewed the interim standards related to meter reading and meter data management. The PSWG recommends that the requirements contained in Appendix C of the Workshop Report be adopted. Each of the recommendations is described below.
The PSWG discussed the functions performed by the MDMA. The PSWG recommends that the functions be separately described as meter reading and MDM functions. (Workshop Report, App. C, Section I.) The Workshop Report notes that separating these functions will facilitate approval processes for these functions.
The functions performed by the MDM entity are as follows:
The functions performed by the meter reading entity are as follows:
One entity voted against the adoption of this recommendation, while three other entities abstained.
The Workshop Report notes that D.97-12-048 requires an MDMA to be used for all required MDM functions. The PSWG believes that while a MDMA should retain full responsibility for all required MDM functions, the MDMA should be able to subcontract sub-functions, such as meter reading, to other approved entities. PSWG recommends that the Commission revise D.97-12-048 "to allow an entity to be approved for all or any subset of MDM functions, but, if approved for a subset, the entity must operate as a subcontractor to an approved MDMA." The PSWG also recommends that an entity does not need to be re-approved to provide such functions to another MDMA as a subcontractor.
One entity opposed the subcontracting recommendation, while three others abstained.
The Workshop Report notes that reprogramming a meter remotely is in some cases more efficient than dispatching a technician to reprogram a meter on site. Typically, the MDMAs have remote communications capability with the meters they read. The PSWG recommends that an MSP should be allowed to subcontract with an MDMA to reprogram its meters remotely. The MSP would remain responsible for the reprogramming of the meter. One entity opposed the recommendation, and five entities abstained from voting. (Workshop Report, App. C, Section III.)
The PSWG discussed the need for the MDMA to provide support to the ESPs and the UDCs. The PSWG unanimously recommends that:
With the experience gained from the market operations of direct access, the PSWG reviewed the current performance requirements associated with the timeliness of the MDMA’s actions. These performance standards were originally adopted in D.97-12-048. It is recommended that the following performance standard for interval meters be changed:
It is also recommended that the following performance standard for non-interval meters be changed:
The PSWG contends that these two performance standards should be modified by reducing the 99.99% standard to 99.0%. The PSWG contends that 99.99% is an unreasonable goal, and it does not reflect the current performance of the market. If the 99.99% standard is retained, one missing account in 5000 would cause an MDMA to be out of compliance. As technology changes, and new systems and processes impact market performance, these standards should be reviewed again. (Workshop Report, App. C, Section V.)
The PSWG also recommends that the first billing cycle by an MDMA be disregarded in calculating the performance standard. The Workshop Report notes that the initial handoff of the customer by the UDC to the ESP sometimes causes information to be delayed. This delay would skew the MDMA’s performance statistics. The tracking of an MDMA’s performance should begin after one complete billing cycle has ended. (Workshop Report, App. C, Section V.)
The Workshop Report states that there are no defined procedures which address the situation of when an MDMA is unable to deliver the data to a server within five days. Since there are no present guidelines or procedures for this, the process is inconsistent and unreliable. The PSWG recommends that the process be formalized and documented by the market participants (MDMAs, UDCs, and ESPs) based on the VEE rules in Appendix C-VEE of the Workshop Report. Section A of Appendix C-VEE would be used for interval data, while Section B of that appendix would be used for monthly data.
No one voted against the recommendations, but three entities abstained from voting. (Workshop Report, App. C, Section V.)
The loss of data, as a result of events beyond the MDMA’s control, such as large catastrophic events and meter failures, were also discussed. The PSWG recommends that the Commission approve the following:
One entity voted against these recommendations while one abstained from voting. (Workshop Report, App. C, Section VI.)
In order to meet the implementation date for direct access, the Commission adopted the Metering Exchange Protocol (MEP) for meter data transmission that was proposed by PG&E. (D.97-12-048, p. 47.) The MEP was to be an interim protocol until the Commission revisited the issue.
The PSWG recommends that there be a migration to EDI to transfer meter usage data. The EDI was developed by the Utility Industry Group (UIG), which provided input into the ANSI Accredited Standards Committee. The PSWG recommends that this migration occur after the development of a consistent, statewide implementation guide by all interested parties. The Workshop Report expects this guide to be developed by January 1, 1999, and recommends that a migration to EDI be completed within 12 months after the completion of the guide, but no later than December 31, 1999.
Two entities opposed the recommendation, while three abstained from voting. (Workshop Report, App. C, Section VII.)
The PSWG also recommends that for any new transactions between MDMAs and market participants, the preferred standard should be EDI. One entity opposed this recommendation, while five abstained. (Workshop Report, App. C, Section VII.2.)
The PSWG recommends that for electronic communications concerning meter-specific information flows, the preferred method is EDI. One entity opposed this recommendation, while five abstained. (Workshop Report, App. C, Section VII.3.)
The VEE subcommittee held a series of conference calls and meetings to review the VEE rules for interval and monthly data. Separate recommendations were reached for interval data, and for monthly data.
The recommendations are based upon the following principles that were developed during the course of the meetings:
The Workshop Report notes that the above principles should also apply to any future suggested changes.
The PSWG recommends that the interval data rules in Section A, and the monthly data rules in Section B, of Appendix C-VEE of the Workshop Report, be adopted.
The PSWG also recommends that the existing requirement to include the estimation algorithm when the data is posted, be eliminated. The Workshop Report notes that any estimated data must always be flagged as estimated data. In addition, the MDMA must record and maintain the estimation algorithm as long as the MDMA is required to store the data, and to make this information available upon request to the appropriate UDC or ESP. The Workshop Report recommends that this requirement be revisited in the future to determine if such a requirement is necessary based on market experience. (Workshop Report, App. C-VEE, pp. 10-11, 31-32.)
The PSWG also recommends that a group composed of UDCs and MDMAs be authorized to resolve these other issues:
One entity voted against the VEE recommendations, and one entity abstained from voting.
The VEE subcommittee developed 11 changes to the interim interval data rules. Of the 11 changes, the PSWG recommends that only the following four changes be required (Workshop Report, pp. 31-32, App. C, pp. 11-12.) :
It is proposed that all four of these changes be instituted 90 days from the Commission’s decision adopting the changes.
The remaining seven changes are optional and may be implemented at the MDMA’s discretion. The seven optional rules cover the following kinds of circumstances:
Section A of Appendix C-VEE of the Workshop Report contains both the required changes and the optional changes described above.
The PSWG recommends that the VEE rules contained in Section B of Appendix C-VEE of the Workshop Report be adopted for monthly data. Monthly data include consumption, demand, and TOU consumption and demand.
The recommended data validation checks are designed to identify things that can go wrong at the meter/recorder, and cause the data that are collected to give a reading that does not reflect actual usage. The following data validation checks would be required:
The Workshop Report states that the PSWG agreed that the "usage for inactive meters" check was not the responsibility of the MDMA and should not be required. An inactive meter is defined in section 3.7 of Appendix C-VEE as a meter "for which there is no customer with financial responsibility."
The PSWG recommends that the estimation rules for monthly data, contained in Appendix C-VEE at pp. 31 to 37, be adopted. These estimation rules are used to estimate usage, demand, TOU usage, and TOU demand, when actual data is not available.
In addition, the PSWG recommends that a group be established to define rules to convert interval data to billing determinants. As part of this process, the monthly data validation and estimation rules would be reviewed to determine the impact of any conversion.
The PSWG also recommends that the UDC/MDMA meeting process address these additional issues:
Appendix D of the Workshop Report contains the recommended permanent standards for meter worker qualifications and certification, meter service provider certification, meter installation and removal, meter maintenance, meter system testing, and calibration. The recommendations in Appendix D of the Workshop Report are intended to replace the interim standards that were adopted by the Commission in D.97-12-048. A brief description of the recommended standards appear below. No one opposed the recommended permanent standards.
The Workshop Report notes that to "ensure the safe and reliable installation of meters, workers need to have the appropriate training and experience for the different levels of metering work." (Workshop Report, p. 36.) The PSWG agreed to use in its recommendations the five meter worker classes that were discussed by the ESPs, MSPs and UDCs in the Fall of 1997. The PSWG recommends that any meter workers performing direct access meter work would have to be certified for the class of work that they perform. The five meter worker classes are as follows:
Class 2: Class 1,
plus installation of poly-phase
self contained meters below 600
volts.
Class
3: Class 2, plus installation of
transformer rated meters below
600 volts and testing of meters
with internal diagnostics.
Class
4a: Class 3, plus in-field
testing of single phase meters up
to 300 volts.
Class
4b: Class 4a, plus in-field
testing of all meters that can be
installed by meter worker classes
1-4.
Class 5: Class 4b, plus installation and testing of metering transformers and equipment above 600 volts. (Workshop Report, App. D, Section I.A.)
It is proposed that after the Commission approves an MSP’s application to be an MSP, and approves the MSP’s meter worker training certification program, the MSP can self-certify Class 1, 2 and 3 meter workers after ensuring that all appropriate meter worker prerequisites have been met.
In order to be certified as a Class 4a, 4b, or 5 meter worker, it is proposed that the meter worker pass a written and practical exam administered by the Commission or by a designated entity. (Workshop Report, App. D, Section I.C.) The Commission or the designated entity is to develop and prepare a number of different tests for each of the three worker classifications, and the tests are to be periodically revised and updated. The initial set of test questions are to be developed based on examples described in Attachment D-2 of Appendix D of the Workshop Report.
The Workshop Report recommends that the Commission create a designated entity to manage the function of certifying the higher skill meter workers. This entity would be known as the Meter Worker Certification Organization (MWCO). The MWCO process is described in Section I.D. of Appendix D of the Workshop Report.
The PSWG envisions that there could be one or more MWCOs. The role of the MWCO would be to develop and administer practical and written tests to certify meter workers in Class 4a, 4b and 5. The Commission could also assign to the MWCO the review of an MSP’s proposed class 1, 2 and 3 training certification program. The MWCO would establish reasonable fees for its work, and would have to arrange for a $100,000 bond, or provide proof of general liability insurance. The bond or insurance would need to meet the specifications set forth on page 18 of Appendix D of the Workshop Report.
In recognition of the fact that MWCOs do not exist today, and because it will take a period of time for an MWCO to administer the qualification process, the PSWG recommends that an interim MWCO process be established. This interim process would involve one volunteer from each of the UDCs and permanently certified MSPs, and would be formed within seven calendar days from this decision. This group would finalize the test contents that would be used to test and certify Class 4a, 4b, and 5 meter workers; establish pass/fail criteria for the tests; identify and assign an entity to administer this testing and certification; and publish information on how to apply for these three meter worker tests. The interim process calls for the completion of all these tasks within 90 days from the adoption of such a process. This interim process also calls for the filing of a brief report to the Commission which would report on what was implemented through this interim process. This report would also be posted on the PSWG website. It is recommended that this interim process remain in place for six months, or until the MWCO is approved and ready to operate, whichever is earlier.
The PSWG also recommends that the MSP certification process that was first established in D.97-12-048 remain in place. However, PSWG recommends that some modifications be made to the 50 joint meet process that was adopted in D.97-12-048. The PSWG recommends that this process no longer be used for MSP certification. Instead, the MSPs will provide a detailed work schedule to each UDC for the first 20 installations by the MSP. The UDC is not required to attend the installation, but may do so in its discretion. The UDC or the MSP can also request that the installation be attended by the other party:
The joint meet forms and logs that were adopted in D.97-12-048 would no longer be required if PSWG’s recommendations are adopted.
The PSWG’s recommendation also calls for a mandatory joint meet "for special types of meter installations, testing, and maintenance as defined by a UDC’s or MSP’s notification published in advance." (Workshop Report, App. D, p. 13.)
The PSWG also recommends that Attachment D-3 of Appendix D of the Workshop Report be used as the application to become a registered MSP.
The PSWG developed a set of minimum standards and procedures that are to be followed during the installation and removal process. These recommendations are set forth in Section II of Appendix D of the Workshop Report. The Workshop Report states that the recommendations will promote consistent installations and enhance safety and reliability. The recommendations cover the following areas:
The PSWG developed recommendations for the routine maintenance and testing of meters. The purpose of the meter maintenance and testing program is to ensure that the meters owned by an entity are accurate while the meters are in service.
Section III of Appendix D of the Workshop Report sets forth the maintenance schedule; when testing and maintenance can be requested; the statistical sampling of meters; the criteria for taking corrective actions; coordination with the MDMA regarding data quality; and clarification of the demarcation point for meter work.
Section IV of Appendix D of the Workshop Report addresses the meter system testing requirements. For the purposes of the testing requirements, the Workshop Report describes the metering system as the meter itself, or the meter and its attached equipment or modules. The purposes of the testing requirements are to: (1) ensure that the accuracy of the overall metering system is within Commission-required limits; (2) ensure safety in meter work procedures; and (3) provide consistent testing.
In general, there are seven meter tests that can be used. The type of tests that are used depends on the type of meter technology that is deployed. Attachment D-1 of Appendix D sets forth a matrix of which tests can be applied to a particular type of meter, and a description of each test procedure. The attachment recognizes that some of the tests may not apply to newer types of meters.
The seven meter tests are:
The test standards contain the standards that are to be used when conducting maintenance testing, and calibration of test standards. These standards are used to test the accuracy of the meters in the field or in the shop. The test standards also cover the situation of when a test standard is found to be out-of-calibration, and which meters need to be retested using an accurately calibrated test standard. These standards are described in Section V of Appendix D of the Workshop Report.
The Workshop Report recognizes that in a direct access environment, meter data will be processed and communicated between many different market players and participants. This exchange of information can lead to data security risks. A summary of the data security issues is contained in Appendix F of the Workshop Report.
The PSWG notes that data security issues are being evaluated by the Data Quality and Integrity Working Group (DQIWG). The PSWG unanimously voted to refer data security issues to the DQIWG.
The PSWG categorized the different subject areas that it reviewed to determine what other issues it needs to address. Appendix E of the Workshop Report contains a list of the subject areas that the PSWG recommends be addressed, and a list of areas that do not require immediate work but can be performed on a "convene as needed" basis. Two entities voted against the recommendations contained in Appendix E of the Workshop Report.
The PSWG states that its review of the following subject areas is now complete, and that the recommendations are contained in the Workshop Report:
The PSWG states that no additional ongoing work is needed with respect to the five subject areas referenced above. However, if a party believes that a change is needed with respect to any of the five subject areas, a party can trigger a possible review by the PSWG if the party files a petition to modify the Commission-approved permanent standard. If a petition is filed, the PSWG suggests that the Commission could issue a decision without the need for technical input from the PSWG. Or, the Commission could order the PSWG to reconvene, have it address the issue, and make a recommendation to the Commission for an eventual Commission decision. The PSWG does not believe, however, that the PSWG should be reconvened more often than once within a six-month period.
The PSWG recommends that the following three subject areas continue to be addressed:
The PSWG notes that the electronic commerce issues are to be addressed by the Rule 22 working group. Ongoing VEE and MDM issues are to be addressed and resolved in the UDC and MDMA meetings that were ordered by the Commission in D.97-12-048.
PG&E recommends that the Commission adopt all of the recommendations of the PSWG, including those which did not have unanimous support. PG&E states that for those recommendations which did not have unanimous support, the overwhelming majority of the PSWG participants still supported the recommendation.
PG&E points out that the recommendations were developed in a fair and open process, and represent a careful balancing of all interests. PG&E asserts that the Commission should not be tempted to adjust the majority recommendations in the report to cater to a few discontented voices.
The CEC believes that truly permanent standards should apply consistently to all providers of any given competitive service, whether that provider is a UDC or another firm. The CEC asserts that the PSWG’s recommendations essentially exempt the UDCs’ bundled services from the permanent standards. The CEC contends that this is fundamentally unfair because it imposes various costs on competitive providers of services by specifying standards for equipment and data processing. In contrast, the UDCs are not obligated to meet the same standards.
The CEC states that D.97-05-039 "clearly permits the three UDCs to enter the competitive metering service, even for bundled service customers." The CEC believes that now is an appropriate time for the Commission to be:
The CEC also contends that the Commission should clarify that the UDCs’ operations should conform to all MSP and MDMA requirements by a date certain for all customer activities, whether direct access, PX hourly price, or bundled service customers. The CEC suggests January 1, 2000 as an appropriate target.
The CEC contends that the presumption of technical competence of the UDCs as an interim measure was an appropriate presumption, but is not one that should carry over as a permanent standard. The CEC recommends that the Commission create and adopt a common set of equipment standards, data management protocols, and employee qualifications for each functional service across the entire industry so as to level the playing field for all market entrants.
The CEC contends that the standards should be designed to achieve well defined functional or performance objectives, or business or regulatory requirements. Some of the recommended standards lack clarity as to what objectives the standards are trying to achieve. If further efforts by stakeholders are necessary, the CEC recommends that the Commission specify the objectives, or the business or regulatory requirements, that it wants to achieve. If that is not possible, the CEC believes the Commission should direct the participants to begin their efforts by reaching a common understanding of the objectives. By defining the objectives, the CEC believes that the working groups will be able to complete their work more efficiently.
SCE recommends that the Commission adopt the unanimously supported recommendations as a new General Order, and that the resolution of any disputed issues be added to the General Order.
The joint parties caution that the Workshop Report must be read with the understanding that it was prepared by a body of stakeholders, many of whom were indifferent, or in some cases opposed to the Commission’s goals for customer choice, interoperability, and national standards.
The joint parties take issue with the statement in the Executive Summary of the Workshop Report which states:
The joint parties assert that the above statement is incorrect. The joint parties point out that relatively short and simple meter data messages can be carried by almost any standard communication network such as telephone, fiber, or radio. These communication networks can accept input from many different devices such as telephone receivers, modems, facsimile machines, etc.
The joint parties state that IEEE Standard 1397 specifies that an interface between a meter and a generic communications network can and should be developed. The IEEE SCC31 has a working group that is addressing a standard that will interface any meter to a radio frequency network, and be compatible with existing and planned Utility Communication Architecture (UCA) -compliant communications networks.
The joint parties also take issue with the statement in the Executive Summary which states:
The joint parties contend that this statement is technically incorrect. The joint parties assert that, in several instances, interoperability using different technologies and existing standards can be achieved. They believe that the standards being developed by the IEEE in support of the UCA activities will make it possible to develop meters that have a high degree of interchangeability within the next few years. The joint parties state that a better and more correct statement is:
The joint parties contend that the PSWG did not discuss or vote on any item that suggested universal interoperability, or that a single meter could be used with any or all communication technologies that are currently on the market. They contend that meters with appropriate interfaces can be designed today to send their messages over nearly all well-designed communication media.
The joint parties contend that the issues of interoperability and open architecture are of concern to customers because they affect the compatibility of the customer’s meter with the metering devices used by other ESPs. The joint parties feel that a direct access customer should be informed at the outset as to whether the customer’s direct access meter will be compatible with the metering systems of other ESPs, should the customer decide to switch.
B. Interconnection, Open Architecture, and Interoperability
The PSWG relied on Diagrams A and B in the Workshop Report to describe the points where standards can be used to define interoperability. Instead of using Diagrams A and B, ORA favors the use of the IEEE 1397 Architectural Reference model as the tool for defining interoperability and open architecture. ORA, as well as the other joint parties, believes that the IEEE model is broader, and provides a greater technical description to current and future component and systems developers.
ORA and the other joint parties also point out that the IEEE model uses the OSI model. According to the joint parties, the OSI model is an industry standard that defines data communication services in the form of seven distinct layers. This layering process allows a change to be made to one given layer, without impacting the remainder of the model. As a result, interoperability can be greatly enhanced without having to define a technology based on the OSI reference model. Diagrams A and B do not contain any references to the OSI model. Due to the incomplete communication specifications in Diagrams A and B, the joint parties contend that other providers who want to facilitate customer choice may face barriers to entry.
The Workshop Report included the comments by ABB, which favors the adoption of ANSI C12.19. ABB states that it was a participant in the development of ANSI C12.19. ABB states that the standard was expressly designed to encourage and enhance competition by reducing the time and effort needed to add new and different metering products. To encourage this, a single data structure standard was used. This data structure can be used with multiple transport schemes.
ABB also states that the data structures were not modified to limit their application to any one media. Instead, the standard was designed so that the data structures could meet the needs of the simplest device and yet be expandable beyond any meter in production today. ABB also points out that the data structure allows manufacturers to keep their tables confidential, while other manufacturers who want to, can allow for interoperability.
NERTEC supports the adoption of ANSI C12.19, but disagrees with the unlimited exemption for existing meter types. NERTEC believes C12.19 provides an adequate structure for data definitions, format definitions, and common syntax, which will assure a level of interoperability, and provides a foundation for further standard development.
NERTEC believes that PSWG’s recommendation to grandfather those meter types produced before March 20, 2000 from the C12.19 standard should be limited to a maximum of two or three years. NERTEC believes that an unlimited exemption may impair interoperability.
ITRON contends that the recommendation to adopt C12.19 will stifle and reduce competition. In addition, such a standard will be expensive to support and has several drawbacks. For example, ITRON points out that ANSI 12.19 was not intended to provide, and does not ensure or guarantee interoperability. Only a portion of the applications layer of the seven layer OSI model uses data models. No other layers of the OSI model have been standardized for meter reading except for some aspects of the optical and telephony physical layers.
ITRON also points out that the C12.19 standard was prepared for a traditional utility monopoly market, i.e., single utility access to multiple meter types, and was not intended to address issues relating to multiple supplier access. ITRON also contends that C12.19 contains mechanisms which increase the data transmission required to communicate information. This has the potential to increase message lengths, resulting in more expensive communication costs, and shorter battery life for battery powered products.
The California Competition Network, Enron, Schlumberger, and CellNet oppose making the ANSI C12.19 standard a mandatory requirement for direct access meters. They cite four reasons in support of their opposition. First, they contend that the standard is not necessary to make the market work. Second, such a standard will result in added costs because new functions will have to be added to existing and new products. Third, the Workshop Report states that C12.19 does not achieve interoperability. The standard would merely add one aspect of standardization to the meter interface, but would not result in an interoperable standard. They also contend that there is no consensus that the level of standardization in C12.19 is the right standard, nor even that it is an improvement. Fourth, the parties who support applying C12.19 to ESP provided meters, voted against applying the standard to UDC provided meters. They contend that for whatever reasons the UDCs had for voting that the standard should not apply to UDC meters, the same reasoning should apply to ESP provided meters.
The California Competition Network, Enron, Schlumberger, and CellNet also disagree with the statement in the Workshop Report that "moving the point of interoperability closer to the customer makes it easier to switch ESPs." They contend that ease of switching depends on maximizing customer convenience and minimizing cost, and that the proximity of interoperability to the customer is not necessarily related to these two factors.
The CEC’s comments take issue with the C12.19 recommendation. The CEC points out that the recommendation will allow unlimited grandfathering of non-conforming meter types because meter types approved before March 20, 2000 may continue to be installed past that date. The C12.19 standard is also a problem for radio frequency systems. In addition, the standard has technical features that permit the meter to be configured to communicate in proprietary protocols, which does not promote the standardization of metering data communications.
The CEC asserts that the C12.19 debate reflects a fundamental disagreement among the parties about whether standardization at the meter communications level will enhance customer choice and facilitate a competitive, innovative marketplace for electricity, metering and related services. The CEC believes that the Commission did not direct the PSWG to standardize meter communications. Instead, the CEC contends that the Commission’s objective in unbundling metering services was to facilitate the direct access market by permitting a customer to choose among the ESPs. What is unclear is whether the meter communication standards furthers this objective. The CEC believes that there needs to be some real experience with the competitive provisioning of metering services before the issue of meter communication standards can be resolved.
PG&E states that it understands the concerns expressed in the minority opinions that the C12.19 standard should be mandated for all meter technologies since for many communication technologies, a C12.19 data format will not allow for interchangeability between meters. However, if a solid state meter using a Type 2 optical port had to comply with C12.19, that would permit interoperability. PG&E states that such a requirement would allow customers to change ESPs, or to default to the UDC, without requiring that their meters be changed.
SCE is unclear about the intent of NERTEC’s comments with respect to the C12.19 standard. If NERTEC’s intent is to require the replacement of all meters that are not C12.19 compliant within three years, then SCE opposes the recommendation. SCE contends that such a requirement would result in increased costs to replace essentially new meters.
SCE points out that other parties oppose C12.19 on the basis that if the standard is required of new meters, it must have value, and therefore should apply to the UDCs’ existing meters. SCE contends that those parties ignore that if the UDCs were required to replace their installed base of meters, this would greatly increase costs for those customers who choose to remain bundled customers. SCE supports the PSWG recommendation that meters installed before March 20, 2000 be grandfathered until the end of their service life.
ORA abstained from voting on the C12.19 standard. ORA points out that the standard addresses the format and communication of data tables of metered data. Although ORA favors a standard which promotes comparable measurement, the vote also included the proposal to grandfather existing non-complying equipment. ORA favors a two- or three-year exemption from compliance, rather than an unlimited exemption. ORA believes that the exemption discourages real customer choice because the meter manufacturers can continue to maintain and sell older equipment which does not have to meet the C12.19 standard.
The joint parties contend that the C12.19 standard should be adopted. The adoption of that standard will allow for the creation of a common data format whereby metering data can be consistently communicated and shared with other systems. The joint parties contend that the C12.19 standard is necessary in order to have "plug and play" capability for the various meter-related components. However, the adoption of just the C12.19 standard is not enough. Instead, a complete set of interfaces must be defined in order to have plug and play components. No single standard can assure interoperability in a complex system. A set of standards is especially important when there are multiple suppliers offering the same kinds of products and services.
Some vendors have suggested that the Commission should let the market decide which standard, technology, or communication protocol is best. The joint parties state that allowing multiple proprietary protocols, and letting the market sort out the winners will work, but that consumers will lose out and end up confused. The joint parties favor the adoption of a common set of interfaces, rather than letting the market decide which protocols to use.
The joint parties disagree with some of the statements made by the parties that oppose the C12.19 standard. One of the statements is that "Interoperability of meters would require selection of a single communications technology…." The joint parties state that the technologies are not the constraining factor in achieving interoperability. Appropriate interface standards can be selected which would enable different vendor products to interoperate. The joint parties assert that if the vendor did not bundle the meter reading, transport, and metering functions into a single product or service using proprietary protocols, that product or service would be able to operate with another vendor’s products. For example, the joint parties point out that several vendors have bundled the transport mechanism into their product and service offerings. As a result, there are many different proprietary transport mechanisms and interfaces. The joint parties contend that the C12.19 standard should be used by the different vendors for base level interoperability.
The joint parties also disagree with the concept that added costs should be the basis of rejecting a standard. That is because all market participants will be required to meet the standard, and competition will determine who is more efficient in meeting the requirements. In addition, standardization normally reduces the cost of products. The joint parties assert that the manufacturers who seek to preserve proprietary protocols do so because they are able to charge consumers a premium price for a unique product.
The joint parties take issue with the comment at page 20 of the Workshop Report that the ANSI C12.19 standard is not compatible with all radio frequency based technologies. That comment is true, but the joint parties point out that this standard is compatible with some radio frequency based technologies and products. They also state that the C12.19 standard does not always result in a longer message length or that the standard results in the use of more bandwidth. The joint parties contend that even if some meter manufacturer’s message length increases slightly, that is a small price to pay for industry-wide interoperability.
The joint parties disagree with Itron’s comment that the current C12.19 standard is flawed. The joint parties contend that the standard is complete, as witnessed by the fact that several manufacturers already have products for sale that incorporate the C12.19 standard. The joint parties state that the so-called "flaws" are in large part due to the changes that certain manufacturers have requested so that the standard can accommodate the needs of their existing protocols.
The joint parties also disagree with Itron’s statement that the adoption of the C12.19 standard will stifle, not encourage competition, and that the standard will assist those firms who already have some aspects of C12.19 in their product. The joint parties contend that several firms have foreseen and actively participated in the development of standards, and may indeed benefit from marketing standard products. However, the joint parties assert that it is not a wise policy to penalize firms who had the foresight to invest their resources in the development of a standard that will benefit all consumers through competition and consequent price reductions.
The joint parties oppose the unlimited "grandfathering" of non-complying metering equipment because it will limit the options of customers if meter manufacturers decide to maintain and sell older equipment. Also, allowing non-complying meters to have an unlimited life seriously compromises the purpose of achieving a minimum level of interoperability. Furthermore, the grandfathering may result in consumers having to pay for the inefficiencies of inflexible and fundamentally obsolete equipment which will have to be later replaced at a consumer and societal cost. The joint parties recommend that the grandfather clause be limited to a maximum of two years.
The Workshop Report states that ABB and NERTEC do not believe that all meters should be required to have a local visual kWh display. They contend that the two reasons for having a local display, the customer’s need to verify the bill, and the UDC’s need for access, can be met by different technologies. For example, a customer with a solid state meter may prefer the convenience of having a display inside one’s home or business, or being able to access the data on a computer rather than walking outside to read the meter. ABB and NERTEC contend that requiring the use of a local visual display will limit product innovation and impose additional costs on the consumer.
PG&E supports the majority recommendation that the meter must have a kWh display on the meter that is accessible to an on-site meter reader. PG&E contends that having a display on the meter provides the most basic level of interoperability because it gives all of the parties an opportunity to retrieve meter usage when other communication systems fail, and allows the customer to visually monitor usage. Without a visual meter display, PG&E asserts that it is more difficult to determine whether a meter is working or not. PG&E also contends that the visual meter display is consistent with bundled service, because UDCs currently require a digital kWh display for bundled customers.
PG&E is opposed to the proposal of ABB and NERTEC that customers be allowed to have a display in their home or business as a substitute for a display on the meter. PG&E contends that their proposal is unacceptable, and will destroy the basic level of interoperability provided by a visual display. In addition, PG&E asserts that the kind of technology favored by ABB and NERTEC has not been proven to be reliable or economic.
The CEC also agrees with the PSWG recommendation to require a visual display on the meter. The CEC, however, opposes the requirement that the display be limited to kWh. If the billing is based on determinant units other than kWh, the customer should be able to visually verify these determinants, and the standard should provide for this capability.
In Section V.4 of the Workshop Report at page 27, the need for "visual meter read requirements" was discussed. SCE contends that this should have read "back-up meter read requirements." SCE also contends that the wording was altered from the original text that was presented and approved at the PSWG plenary meeting on April 30, 1998. SCE asserts that the following is how the recommendation should have appeared: