The opening of the electric industry to competition has resulted in many new information exchanges between the various parties involved in the production, procurement, transmission, distribution and use of electricity. The UDCs presently use a combination of meter numbers, account numbers, and customer names as the SDP identifiers to link the transactions between the various business entities that are involved. There is no single, uniform, permanent numbering system that the UDCs use to identify each SDP. Instead, each UDC maintains its own internal system to track the SDPs. It does not appear that these internal numbering systems are shared with the ESPs and MDMAs when referring to a specific SDP. To minimize these multiple identifiers, and to ensure that such information exchanges remain reliable, the UNI numbering system was proposed.
We are persuaded that a UNIS will be beneficial. One of the advantages of such a system is that a unique number is assigned to each point or site that the UDC, ESP and other entities interact at to provide electricity. The use of such a numbering system will allow all market participants to refer to a particular SDP in an unambiguous manner, rather than using a combination of different identifiers to refer to the same SDP. The assignment of a UNI number to each SDP will also result in an SDP record. The SDP record will reflect the history of the ESPs serving a particular SDP, including the service start and end dates.
Another benefit of moving forward with the adoption of a UNIS is that the other parties who participate in the direct access process will have an incentive to design systems and procedures which utilize the UNI numbering system. For example, if the UDCs are required to develop UNIs and incorporate them into all DASR and MDMA transactions, then the ESPs and MDMAs are likely to utilize the UNI numbers as well. The use of the numbering system by these entities may also influence scheduling coordinators and the ISO to utilize the UNI number in their transactions as well.
We agree with those commenting parties who contend that the Commission should implement a UNIS as soon as possible, rather than adopting a slower implementation schedule. As recognized in D.97-12-090, an immediate response is favored because direct access is still in its developing stages and a window of opportunity exists to adopt and immediately implement a UNI numbering system. The recommendation in Section 1.2 of the Workshop Report will not result in the rapid implementation of a UNIS. Instead, that recommendation takes a much slower and deliberate approach to establishing such a system. We favor a process and a schedule that is patterned after the preferred alternative. Since the preferred alternative is also supported by PG&E, SCE and SDG&E, the rapid implementation of a UNIS does not appear to be a problem for these UDCs.
In order to quickly implement a UNIS, we recognize that the scope of such a system needs to be limited so that the near-term implementation activities minimize the resource and cost impacts on relevant parties. Thus, the system design should take into account some practical considerations. Since each of the three UDCs currently use their own internal numbering system to identify each SDP, the design of the UNIS should recognize this. With some minor modifications, the present numbering system can result in a quick and low cost numbering plan.
The proposed linkage of the UNIS to other existing databases should also be considered. Instead of linking the numbering system to every SDP and other existing databases, the UNI should only be assigned to those SDPs which serve direct access customers. This will reduce the amount of work the UDCs will have to do because they will not be required to immediately change the identifiers for every SDP in their service territories. We recognize that in order for the UDC to assign the UNI number to each SDP, an SDP record needs to be maintained as well. This should not be unduly burdensome since all the UDCs currently maintain some version of an SDP record.
Today's decision adopts a UNIS whereby PG&E, SCE and SDG&E shall be responsible for assigning a unique identifying label to each SDP which serves a direct access end-use customer in their respective service territories. For the purpose of the UNIS, a SDP is defined as the end point of the UDC's electric distribution network, where the energy is delivered by the UDC to the end-use customer. In the event no meter socket exists at the end point, the SDP record shall describe the termination point for the SDP. The unique, identifying label that is assigned to each SDP shall be referred to as the SDP number. The design of the SDP numbers and the assignment of the number to each SDP that serves direct access customers, shall be implemented no later than 180 days from today.
As recommended in the preferred alternative, we will permit PG&E, SCE and SDG&E to use their gen-ID number, installed service number, and premise identifier, respectively, as the basis for the SDP numbering system. The UDCs may prefix their respective identifiers with other numbers or letters to ensure that each UDC's SDP numbers are unique. Since the current identifying system that PG&E uses may change as the customer at a particular SDP changes, PG&E and the other UDCs shall be directed to explore ways in which the SDP numbers can be made permanent for the service life of the SDP.
For SDPs that already serve direct access customers, the UDC shall notify the ESP serving the end-use customer at that SDP of the SDP number through an account maintenance transaction. For any new direct access SDP, the UDC shall inform the ESP of the SDP number in the UDC's response to the ESP's DASR.
Each UDC shall also be required to maintain a SDP record. At a minimum, the SDP record shall consist of the following information: (1) the SDP number; (2) the UDC responsible for that SDP; (3) a description of the SDP's physical location; (4) the ESP serving, and those who have served, the end-use customer at that SDP; and (5) the service start date and service end date of each ESP serving that SDP. This kind of information is contained within the DASRs that are submitted to the UDCs. Once the SDP record is created, it will make it easier for all future metering and billing transactions to simply refer to the SDP number when referring to a customer at a specific SDP.
It is appropriate for the UDCs to assign the SDP numbers and to maintain the SDP record because the UDCs are the entities responsible for the distribution system. The UDC is also the primary point of contact when an ESP signs up a new direct access customer. Upon receipt of a DASR form from the ESP, the UDC will have all of the information that it needs to complete the SDP record. Since the UDC is responsible for these efforts, we do not see a need for an independent, third-party to maintain the SDP numbers and SDP records.
The first three items in the SDP record shall be made available to the ESP who submits a valid DASR form for that SDP. Information regarding any prior ESP serving a particular SDP, and the service start and service end dates, shall only be made available if a billing dispute arises. Under such a circumstance, that information shall only be released to the end-use customer and the ESP with whom the bill is disputed.
We shall also adopt the preferred alternative's recommendation that the SDP number be incorporated into all DASR information exchanges that involve a direct access SDP. The UDCs and the ESPs shall include the SDP number in all DASR-related exchanges. We shall require that the SDP number be incorporated into all such information exchanges within 180 days from today.
The preferred alternative also recommends that the SDP number be incorporated into all MDMA exchanges, including the metered usage data that the ESP passes to the scheduling coordinator. We will require that the UDCs, ESPs and MDMAs include the SDP number in all of the MDMA information exchanges among themselves within 180 days from today.
We authorize PG&E, SCE and SDG&E to track in their electric restructuring memorandum accounts the expenditures related to the SDP numbering system and related activities as discussed in this decision. We conclude that the reasonable costs of such expenditures are recoverable from their customers pursuant to § 376 because the costs are being incurred to implement direct access. The decision as to when these costs can be recovered in rates shall be addressed in the transition costs portion of this proceeding.
As noted in the comments and the preferred alternative, some of the parties believe that the DQIWG, the PSWG, and the UDC-MDMA Working Group, should recommend how the SDP numbers can best be utilized for addressing certain concerns regarding data quality, performance standards and metering. We agree that the working groups should be permitted to develop recommendations as to how the SDP numbers should be utilized. We will address such recommendations in a future decision.
SDG&E has proposed in the Workshop Report and in its comments to conduct a pilot to evaluate the use of including UNIs in the settlement process. SDG&E's pilot proposes to involve at least one ESP and the ESP's scheduling coordinator, and if interested, the ISO. SDG&E believes that the pilot will help define and test how the UNI numbers can be used, and what applications are required for the different market participants.
Since this decision orders the UDCs to immediately implement the SDP numbering system and to include the SDP numbers in the transactions between the UDCs, ESPs, and MDMAs, there is no longer a need for a pilot program that involves the UDCs, ESPs and MDMAs. However, since the use of the SDP numbers does not extend to scheduling coordinators, a pilot program that examines the use of SDP numbers among the scheduling coordinators, the ESPs, and the ISO could be beneficial. If SDG&E still wants to pursue the latter kind of pilot program, SDG&E may file within 90 days from today a motion requesting authorization to do so. The motion shall include a description of the purpose of the pilot program, the kind of entities that will be involved, the duration of the pilot, the estimated costs of conducting the pilot, and the schedule for SDG&E's analysis of the results of the pilot program. The motion shall be filed and served, and responses to the motion may be filed, in accordance with Rule 45 of the Commission's Rules of Practice and Procedure. Should the motion be filed, the Commission will address the motion in a subsequent decision.
As a followup to the implementation of the UNIS, we will require PG&E, SCE, and SDG&E to file and serve either separate or joint reports with the Commission within 180 days from today. The report shall describe each UDC's SDP numbering system; how its numbering system preserves a unique identifier for each SDP; whether each SDP number is permanently assigned to each direct access SDP; and how the SDP numbers will be incorporated into all the different direct access informational exchanges, including the DASR transactions and meter data transactions. Any interested party desiring to comment on the report shall file its comments within 21 days of the filing of the report. Should it be necessary, the Commission shall then issue another decision to address any remaining UNIS issues.
We recognize that at some point, it may be beneficial to extend the SDP numbers to the smaller UDCs, and that consideration be given to extending such a system to municipally owned electric utilities and to other states, as well as to other delivery points for commodities such as natural gas or water. Suggestions have also been made to extend the use of the SDP numbers to transactions involving scheduling coordinators and the ISO. Due to jurisdictional problems and other reasons, today's decision refrains from imposing any requirements or goals with respect to these issues. Should any party believe that these kinds of issues need to be resolved fairly soon, they can raise those issues in their comments to the UDC report as described below.
Since this decision authorizes the UDCs to design and implement the SDP numbering system, there is no longer a need to continue the UNISWG. The UNISWG should therefore be dissolved.
1. The Commission approved the concept of a UNIS in D.97-12-090 and authorized the UNISWG to address the design and implementation issues associated with such a system.
2. The Workshop Report was submitted to the Commission on March 25, 1998.
3. D.97-12-090 recognizes that an opportunity exists to adopt and implement a UNI numbering system during the developing stages of direct access.
4. The August 21, 1998 joint letter to the Commissioners sets forth a preferred alternative for resolving the issues raised in the Workshop Report.
5. The UNIS is described in the Workshop Report as a system for assigning a unique, permanent, non-intelligent identification number to each SDP on the electric utility's distribution system.
6. The SDP is defined in the Workshop Report as the point where regulated pricing of retail delivery services ends and the domain of competitive end-user products and services begins.
7. The Workshop Report recommends that a process be adopted whereby the UNISWG develops specific UNIS proposals for the Commission, together with cost estimates for implementing such proposals.
8. 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.
9. The UDCs who commented recommend that the Commission take a more cautious approach before adopting a UNIS.
10. The preferred alternative proposes that a unique identifying number be assigned to each direct access SDP.
11. The preferred alternative defines the SDP as the end point of the UDC's electric distribution network, where the energy is delivered to the end-use customer by the UDC.
12. The preferred alternative recommends that the SDP number be incorporated into all DASR and MDMA information exchanges involving a direct access SDP.
13. Opening the electric industry to competition has resulted in many new information exchanges between the various parties.
14. The UDCs presently use a combination of meter numbers, account numbers, and customer names as the SDP identifiers to link the transactions between the various business entities that are involved.
15. The use of a UNIS will allow all market participants to refer to a particular SDP in an unambiguous manner, rather than using a combination of different identifiers to refer to the same SDP.
16. Since the preferred alternative is supported by PG&E, SCE and SDG&E, the rapid implementation of the UNIS does not appear to be a problem for these UDCs.
17. There is no need for an independent, third-party to maintain the SDP numbers and SDP records.
18. The Commission should implement a UNIS as soon as possible.
19. PG&E, SCE and SDG&E should be directed to design a SDP numbering system and to assign SDP numbers to each SDP that serves a direct access end-use customer.
20. The ESPs should be required to include the SDP number on all DASR-related and MDMA-related information exchanges.
21. The MDMAs should be required to include the SDP number on all MDMA-related information exchanges.
22. The reasonable costs of the SDP numbering system and related activities are recoverable from their customers because the costs are being incurred to implement direct access.
IT IS ORDERED that:
1. A universal node identifier system (UNIS), as discussed in this decision, is adopted for Pacific Gas and Electric Company (PG&E), San Diego Gas & Electric Company (SDG&E), and Southern California Edison Company (SCE).
a. Within 180 days from today, these three utility distribution companies (UDCs) shall develop and assign a unique, identifying label for each service delivery point (SDP) which serves a direct access end-use customer in their respective service territories, and shall maintain a SDP record for each SDP number in the format described in this decision.
b. For each direct access SDP, the UDCs shall notify the electric service providers (ESPs) serving those SDPs of the corresponding SDP number.
c. The UDCs shall explore ways in which the SDP numbers can be made permanent for the service life of the SDP.
d. Within 180 days from today, the UDCs shall include the SDP number in all direct access service request (DASR)-related information exchanges and in all meter data management-related information exchanges.
e. PG&E, SCE and SDG&E are authorized to track their expenditures for the SDP numbering system and related requirements in their memorandum accounts that were established pursuant to Public Utilities Code § 376.
f. Within 180 days from today, PG&E, SCE and SDG&E shall file and serve either separate reports or a joint report with the Commission regarding the details of the implementation of the UNIS as discussed in this decision.
(1) Any interested party desiring to comment on the report shall file and serve their comments within 21 days of the filing of the report.
2. Should SDG&E decide to do so, it may file a motion seeking authorization to conduct a pilot program involving the use of the SDP numbers in informational transactions among scheduling coordinators, electric service providers, the UDC, and possibly the Independent System Operator.
a. The motion shall contain the information described in the text of this decision and shall be filed within 90 days from today's date.
b. Any responses to the motion shall be filed in accordance with Rule 45(f).
3. Within 180 days from today, all ESPs shall include the SDP number in all DASR-related and meter data management-related information exchanges.
4. Within 180 days from today, all meter data management agents shall include the SDP number in all meter data management-related information exchanges.
5. The Universal Node Identifier System Working Group is dissolved.
This order is effective today.
Dated November 19, 1998, at San Francisco, California.
RICHARD A. BILAS
President
P. GREGORY CONLON
JESSIE J. KNIGHT, JR.
HENRY M. DUQUE
JOSIAH L. NEEPER
Commissioners
