Although 16 of the parties interested in the UNI issue have proposed a preferred alternative, it is useful to review the comments to the workshop report because they provide an insight into the kinds of issues the Commission needs to be concerned about. Instead of summarizing the individual comments of each of the non-UDC parties, we have grouped their comments by the type of issue that is raised.
Many of the non-UDC parties who filed comments favor the concept of a UNIS, and recommend that immediate steps be taken to implement some form of such a system. These parties believe that the UNIS will result in many benefits such as: (1) facilitating competition; (2) reducing errors associated with SDPs and reducing the possible corruption of data; (3) lowering overall transaction costs; (4) providing a consistent point of reference; (5) improving routine data exchanges; (6) simplifying auditing and tracking procedures; and (7) increasing the certainty with which commercial disputes can be resolved.
These non-UDCs favor the immediate implementation of a UNIS because of the developing direct access market. They comment that the introduction of a UNIS at this stage will not cause major disruptions to the UDC's computer systems or personnel, and that UNIS can be implemented much more quickly because the number of current direct access customers is still relatively small. Also, since the UNIS can affect how other direct access transactions and procedures are designed, the quicker the UNIS is implemented, the better.
Some of the non-UDCs contend that the Workshop Report does not identify the specific actions that are needed to implement a UNIS. Instead, the Workshop Report calls for a process to further discuss the need for a UNIS, the benefits of such a system, the various proposals for a UNIS, and the estimated costs for each proposal. These commenting parties believe that the Commission should immediately adopt a set of minimal steps to implement a UNIS at a modest cost, and direct affected parties to do the following: (1) the UNISWG participants and other interested parties should promptly design the UNI number data field and develop the necessary rules and procedures to ensure that the numbers will be unique and permanent; (2) the UDCs should be directed to create a UNI field in all standard DASR-related transactions; (3) the UDCs should be directed to assign UNI numbers to all DASRs it has processed to date, and on a continuing basis to all future DASRs; (4) the UDCs should be directed to incorporate the UNI field into all standard meter data management transactions; (5) the Permanent Standards Working Group (PSWG) should be directed to incorporate the UNIS into its recommended performance standards for MDMAs; (6) the UDCs should be directed to maintain a master list of all direct access UNI numbers for SDPs on their distribution systems, and that such numbers be readily accessible by all authorized parties; (7) the UDCs should be directed to create SDP records that correspond to each UNI number, and that each SDP record include the UNI number; the identity of the UDC; the physical location of the SDP; and the identity of the ESP serving the SDP, together with the service start and end dates; (8) that the Data Quality and Integrity Working Group (DQIWG) be directed to assume the existence of the UNIS as a given element and to incorporate that assumption into its recommendations for addressing data quality and integrity problems; (9) that anyone interested in performing the activities that are assigned to the UDCs be invited to participate in the event the UDCs cannot implement the system because of cost concerns or operational constraints; (10) in anticipation of extending the UNIS to all SDPs in the UDC's distribution systems, the UDCs should identify and exploit low-cost opportunities to create UNI numbers for those SDPs; and (11) the parties should be directed to design the UNI data field and numbering rules to ensure that the design does not preclude expanding the UNIS to incorporate gas SDPs or its ability to link the California UNIS to a multistate or national system.
The UDCs who commented acknowledge that the UNIS may have benefits, but believe the Commission should take a more cautious approach before a UNIS is adopted. Since each of the UDC's comments raised different concerns, we have summarized each of their comments below.
PG&E acknowledges that there are benefits to a UNIS, but contend that more thought and analysis are needed to understand the costs and design requirements of such a system. PG&E cautions that before the Commission adopts and implements a UNIS, the Commission must consider the cost impact of such a system and determine whether all market participants support such an undertaking. The Commission needs to consider the impact on other Commission-mandated activities that the UDCs are already required to undertake before the Commission orders the implementation of the UNIS. Section 1.2 of the Workshop Report provides a process and timeline to resolve these kinds of concerns.
PG&E contends that the cost estimates and model which are contained in the Workshop Report were developed without the input of PG&E, and that they are unrealistic. PG&E estimates that the programming cost to identify and link the various types of customer information to the UNI numbers will be at least $8 to $10 million. PG&E estimates that the cost to design and establish a database of SDPs will cost an additional $5 million. These costs may increase depending on the final scope of an adopted UNIS implementation plan.
PG&E supports SDG&E's proposal for a limited test of a possible UNIS. PG&E feels that the information gathered from the pilot can be used to assess whether the UNIS should be expanded.
SCE commented that the Workshop Report reflects considerable disagreement between the parties. SCE believes that the cost of implementing a UNIS is likely to be significant. SCE estimates that the cost may range from $3 million to $10 million, and that the cost may increase if the UNIS is linked to other databases. SCE feels that the cost of such a system may exceed the intended benefits, and that since the UNIS is not required for the market to function, customers should not be burdened with additional Public Utilities Code § 376 charges.7
The workshop report contains suggestions that the UNIS be used to track unaccounted for energy losses or distribution losses. SCE contends that the method described in the report will only detect the nonreporting of energy and not any misreporting. SCE believes that any system used to detect misreporting will also capture non-reporting, which makes the UNIS superfluous. SCE believes that the decision to implement a UNIS should wait until the DQIWG decide how UFE and distribution losses can be accounted for.
SCE also responded to the five questions asked in D.97-12-090. In response to the first question, SCE contends that there is disagreement as to whether the UNIS is necessary, and that all the parties first need to agree that the UNIS is needed. The next step then is to estimate the costs of such a system, and whether the participants are willing to pay for such a system. SCE favors the proposal in the Workshop Report which recommends that specific proposals and cost estimates be developed first.
On the second question, SCE does not see the need to create a database of all SDPs. Should the Commission find that a new numbering system is needed, SCE supports working with market participants to develop a numbering system.
Regarding the third question, SCE contends that since the UDC is responsible for creating and maintaining the SDPs, the UDCs should be responsible for assigning the numbers to the SDPs. SCE believes that having other entities assign the numbers would complicate the process, increase costs, and cause delays or errors in assigning the UNIs to each SDP.
In response to the fourth question, SCE states that procedures are already in place to track information between the parties, and that the UNI number would just be an additional informational field. If the UNI numbers are linked to customer and meter information, care must be taken to ensure that ESPs are restricted to only accessing their customer-specific data.
With regard to the fifth question, SCE states that it already has a numbering system that is being used by ESPs for MDMA and DASR transactions. These numbers remain constant so long as the customer resides at the particular SDP. The cost of this system is already in rates. If a new numbering system is implemented, then the UDCs, existing ESPs, and the MDMAs must change their systems from the current functioning system. SCE contends that if a new numbering system is developed, the costs should not be recovered from ratepayers through § 376 costs. Instead, the cost of the new numbering system should be borne by the ESPs and the MDMAs.
SCE agrees that the UNI can serve as an informational tool, but contends that the use of such a number will not reduce the information needed for certain transactions such as submitting DASRS or posting usage information on the MDMA server. SCE also contends that the use of a UNI for each SDP may be a problem if two different customers have financial responsibility for the same SDP during a month, which is frequently the case with apartments. In addition, by assigning a single UNI to each SDP will inevitably lead to mistakes because of human error.
SCE also commented on Appendix A which was attached to the Workshop Report. SCE recommends that the Commission disregard the information in Section A.1 of the Appendix because that information was not discussed at the workshop. SCE states that one of the alleged benefits of a UNI number is that it eliminates the need for service account numbers and meter identification numbers. SCE believes, however, that the identity of the customer at the site is just as important as the identification of the site. Requiring that service account information be provided when a DASR is submitted is one way of reducing slamming since the ESP must obtain the service account information from the customer. If a list of UNIs was used instead, SCE contends that unethical ESPs could more easily submit false DASRs.
Section A.2 of Appendix A describes a process that would compare reported usage to a master UNI list on a daily basis to detect SDPs that have not been accounted for. SCE states that such a process may result in more time being spent comparing the reported usage to the SDPs, than finding an SDP that was not included in a scheduling coordinators' submission to the ISO. In addition, SCE contends that the UNIS offers minimal protection in identifying inaccurate reporting situations, and it would not detect underreporting of a meter's usage or misapplication of distribution loss factors and load. SCE states that it is developing internal systems to detect when an ESP fails to schedule for a customer or under reports usage load. SCE contends that such systems are more feasible and cost effective than an auditing system based solely on a UNI numbering system.
Section A.3 describes the possible cost recovery of the UNIS from direct access customers. SCE does not support that proposal because it places the recovery burden on the UDC. SCE also contends that there should be no pre-set limit on the costs of such a system because § 376 allows the UDC to recover the reasonable costs that are required to implement direct access. SCE also points out that the scope of the UNIS project is likely to change as new issues arise, which will further increase costs. SCE favors a cost recovery proposal that would recover the costs from those who benefit from the system.
Sections A.4 and A.5 of Appendix A discuss proposals to link the UNIS to other information, and that such information be maintained by a central entity. SCE contends that the creation of a new entity is not needed, and that this will simply increase costs and regulatory oversight. SCE also contends that a central database would duplicate the information that the UDCs already have. SCE asserts that if there is a benefit to these two proposals, then it should be left to the marketplace to develop this capability and the costs should be recovered from the entities that want those kinds of services.
SDG&E is of the opinion that the UNIS, as discussed in the Workshop Report, needs extensive additional work before the Commission should support such a concept.
SDG&E generally agrees with the Workshop Report that a UNIS can help in the settlement process. However, SDG&E believes that this goal can be met more simply, inexpensively, and immediately, by a basic numbering system that would be used for direct access accounts. Such a system would use a unique reference number to identify a particular SDP. By adding the UNI to a customer's DASR and MDMA records, SDG&E asserts that all of the necessary elements will be available to facilitate the settlement process. SDG&E does not believe that a more elaborate UNIS is necessary, and additional consultants and clearinghouses should not be employed to develop the UNIS concept.
SDG&E supports the development of a pilot program to test the settlement process with at least one ESP and one scheduling coordinator. SDG&E believes that such an experiment can provide valuable information about the UNIS concept, and can be used to better define costs and benefits. SDG&E is willing to conduct this pilot on its direct access accounts using existing system logic to create a UNI for all these SDPs. If such a proposal is approved, SDG&E will conduct the pilot and report on its results to the Commission and all parties.
7 All code section references are to the Public Utilities Code.
