A. Introduction
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.
B. Meter Equipment
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:
1. ANSI C12.1-1995, Code for Electricity Metering
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.
2. ANSI C12.7-1993, Requirements for Watt-hour Meter Socket
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.
5. ANSI C12.10-1997, Electromechanical Watt-hour Meters
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.
13. Registration and Centralized Database
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.
14. Other Requirements
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:
· A degree of interoperability is possible and could be achieved at system levels.
· Interchangeability of all discrete components across technologies is not feasible.
· Technology-specific interchangeability requires specifying a standard at every interface and is not practical for all technologies at this time.
· Adoption of some existing communication standards allows some interchangeability within a technology and provides a foundation for the adoption of future communication standards.
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:
1. MDM: The PSWG recommends that there be a migration to EDI, which is a national data format. (Workshop Report, App. C, Section VII.)
2. Data format tables: The meter device data format allows for basic interoperability and functional continuity for the marketplace. The PSWG recommends that ANSI C12.19 be adopted. (Workshop Report, App. B, Section I.1.)
3. Handshake: The communication mechanism and the physical communication connection shown in Diagram A of the Workshop Report connect the communication device to the meter, and provide the handshake, i.e., the initial communication protocol. The PSWG recommends that ANSI C12.18 be adopted for Type 2 optical ports. (Workshop Report, App. A, Table I-1.)
4. Visual Display: The PSWG recommends that the meter have a visual kWh display. (Workshop Report, App. B, Section III.)
D. Meter Communications
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.
1. ANSI C12.18, Type 2 Optical Port Standard: For meters that use a Type 2 optical port, the PSWG recommends that ANSI C12.18 be adopted. This standard would allow interchangeability at three different layers. All of the voting members of the PSWG agreed to this recommendation.
2. ANSI C12.19, Standard Application: This provision is a data format standard for metering data, and is designed to promote a minimal level of interoperability. This standard uses a metering data structure format which is in the application layer (Layer #7 of the Open System Interconnection [OSI] communications stack). This layer allows the data to be carried by many different communications transport mechanisms, and provides the flexibility to meet a manufacturer's meter design needs. Four entities opposed the use of this standard, while four other entities abstained from voting.
3. ANSI C12.21, Protocol Specification For Telephone Modem, and ANSI C12.22, Meter Interface To Network Protocol Gateway: These two standards have not yet been approved by ANSI. The PSWG recommends that both of these standards be reviewed when they are approved by ANSI. Two entities opposed this recommendation, and one entity abstained from voting.
4. KYZ Contact Output: The PSWG recommends that meters not be required to have a contact output. However, if a meter has a contact output, the PSWG recommends that it should be a KYZ contact in accordance with ANSI C12.1. All of the voting members of the PSWG agreed to this recommendation.
5. KYZ Consumer Protection Regarding Meter Compatibility: The PSWG noted that many of the direct access customers currently have energy management systems which utilize KYZ outputs. The PSWG recommends that direct access customers be notified by their ESP if a meter change will not be compatible with the customer's energy management system. Three entities voted against the adoption of this recommendation, while 11 other entities abstained.
6. Visual Meter Read Requirements: The PSWG recommends that at a minimum, all direct access meters have a visual kWh display, and a physical interface to enable on-site interrogation of all stored meter data. At a minimum, an electronic meter must have a visual display of the total kWh energy consumption. Four entities opposed this recommendation while three others abstained.
7. Meter Password Authorization: There are three types of password authorization: (1) full read and write; (2) billing read and write; and (3) read only. Since the ESPs are responsible for the safety, accuracy, and reliability of the meter used in direct access, the ESPs will have the authority to issue meter passwords at their discretion. ESPs will be required to issue read passwords to the UDCs for audit purposes upon request. ESPs will provide meter passwords in a timely manner for UDCs to perform their scheduled functions. All of the voting members of the PSWG agreed to this recommendation.
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.
1. Definition of MDMA Business Functions
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:
1. Accept raw meter reads from meter reading entity.
2. As necessary, translate data into format for internal processing.
3. Associate meter reads with customer identifiers for use in validation or estimation, if needed.
4. Validate, edit, and estimate data.
5. If necessary, translate data into Commission-approved format prior to posting to MDMA server.
6. Post validated, edited, and estimated data to MDMA server for retrieval by market participants. This might include performing data adjustments, reframing data, or resending previously posted data, as required.
7. Maintain the MDMA server.
8. Archive raw data and validated data for 36 months. (Workshop Report, App. C, Section I.)
The functions performed by the meter reading entity are as follows:
1. Collect data at the meter, including routine meter reads, special reads, and date and time of reads.
2. Transport data to the MDM.
3. Perform any validation that is required to be performed either on site or at the time of reading.
4. Check for and report suspected energy theft.
5. If meter reading is performed locally, check for and report hazardous conditions. (Workshop Report, App. C, Section I.)
One entity voted against the adoption of this recommendation, while three other entities abstained.
2. Subcontracting MDM Functions
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.
3. MSP's Ability to Subcontract Meter Programming to MDMA
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.)
4. MDMA Technical/Business Support to ESPs and UDCs
The PSWG discussed the need for the MDMA to provide support to the ESPs and the UDCs. The PSWG unanimously recommends that:
1. The MDMA provide access to technical and business assistance during normal business hours (8:00 a.m. to 5:00 p.m. Pacific). During such time, the MDMA will have staff available to address questions and concerns on data availability, corruption and adjustments, and systems technical support.
2. The MDMA provide technical assistance via a support pager available 24 hours a day throughout the year to address issues of server availability. The MDMA is to respond and provide a status to all pages within two hours.
3. MDMA server availability or access issues be dealt with as soon as reasonably possible. At the MDMA's discretion, concerns over data availability, data corruption and adjustments, or non-urgent problems, will be addressed during the next business day. (Workshop Report, App. C, Section IV.)
5. MDMA Performance Standards
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:
"(iii) 99.99% of all usage data must be available within five days of the scheduled reading date of the meter." (See D.97-12-048, p. 31.)
It is also recommended that the following performance standard for non-interval meters be changed:
"(iii) 99.99% must be available by 6:00 a.m. on the 5th working day after the scheduled meter reading date." (See D.97-12-048, p. 32.)
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.3 (Workshop Report, App. C, Section V.)
6. MDMA Performance Exemptions
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:
1. In the event of a large catastrophe, such as an earthquake or hurricane, which precludes the MDMA from reading meters, the MDMA should estimate and post the data. The estimated data would be reported separately by the
MDMA in its performance report, and would not be included in any performance penalties assessed against the MDMA.
2. In the event of meter failure where the meter is not accurately recording usage, the estimated data would be reported separately by the MDMA in its performance report, and would not be included in any performance penalties assessed against the MDMA.
One entity voted against these recommendations while one abstained from voting. (Workshop Report, App. C, Section VI.)
7. Electronic Data Interchange (EDI) Implementation
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.)4 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.)
8. Meter Specific Information Flows
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.)
1. Introduction
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 rules should promote fairness in the marketplace.
· The goal of the rules is to provide quality data.
· Solutions must fit the magnitude of the problem. When evaluating solutions, the costs must be considered against the frequency of occurrence and the quality of the data.
· Modifications to the rules should typically be required when they result in a significant improvement in the data quality.
· When modifications to the rules are made, reasonable implementation plans should be defined allowing time for all parties to comply.
· Variations for different technologies should be allowed where appropriate.
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:
· Clarify the rules by adding examples, flow charts, and definitions.
· Review the rules for effectiveness after the market has been operational. The PSWG recommends that the interval rules be reviewed in April 1999, and that the monthly rules be reviewed in June 1999.
· Create a change management procedure, should it be needed, and apply the six principles to any suggested changes.
· Add an additional required code to the MEP, or other approved format, for verified data. Verified data is data which failed at least one validation check, but was determined to be valid. (Workshop Report, pp. 33-34.)
One entity voted against the VEE recommendations, and one entity abstained from voting.
2. Interval Data
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.) :
1. The days on which a power failure occurred shall not be used as reference data for estimation.
2. During meter test mode intervals, the MDMA must not report the test load, and may report zero usage during such time. If the meter is inadvertently left in test mode, the data will be estimated.
3. The selection of reference days for estimation purposes are to be the days that are chronologically closest to the day requiring estimation, whether that is in historical data or the present billing period.
4. The high/low usage check shall always be performed on data that have passed or been verified for previous checks, with no estimated values included. This high/low usage check can also be performed on final data, including estimated values, at the option of the MDMA.
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:
1. Spike check threshold: For very low usage customers, a valid pulse count of a few pulses may result in failing the spike check. An optional minimum threshold was added to allow MDMAs to automate checking for this condition and passing the data.
2. Kilovar-hours (kVARh) check threshold: For very low usage customers, a valid pulse count of a few pulses may result in failing the kVARh check. An optional minimum threshold was added to allow MDMAs to automate checking for this condition and passing the data.
3. Use of partial days as reference data for estimation: Days containing less than 24 hours of good interval data may be used as reference data to estimate data for other days.
4. Use of accurate meter readings to scale estimated intervals: When data are estimated based on historical data, and accurate meter readings or usage are available, the estimated data can be scaled based on the actual usage.
5. Simplified proration algorithm when meter clock is off: A simpler method of prorating data when the meter clock is off is provided in Appendix C-VEE of the Workshop Report.
6. Automating handling of irregular usage customer: Rules are provided to determine which customers have irregular usage, and how special tests can be designed and automated for those customers.
7. kVARh checks: kVARh checks would be required only when the kVARh is used for billing.
Section A of Appendix C-VEE of the Workshop Report contains both the required changes and the optional changes described above.
3. Monthly Data
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:
1. Time check of meter reading device/system. Applies to devices/systems which collect TOU data only.
2. Time tolerance check of meter. Applies to meters collecting TOU data only.
3. High/low usage check. This check is used to validate cumulative kWh consumption
4. High/low demand check. This check compares the demand against historical data as a reasonableness check.
5. TOU check. This usage check compares the sum of the kWh meter readings for all periods against the current season total kWh meter reading. This check must be done in whatever units (kWh or pulse values) are read from the meter.
6. Zero consumption for active meters. This checks for zero usage during the billing month.
7. Number of dials on meter. This check applies to cumulative consumption only. The check ensures that the number of digits reported in the read is consistent with the number of dials or digits on the meter display. This check is performed for both remote and local reads if supported by the meter reading technology. If the meter reading technology does not support this check, it is not performed.
8. Meter read demand decimal quantity difference. This check verifies that the number of demand decimal places displayed on the meter is correct. This check is only performed for on-site meter reads, and is not performed for remote meter reads.
9. Meter identification. This check compares the meter's identification markings with the identification that is expected by the meter reading system. There are two types of meter identification checks, the internal meter identification check and the external meter identification check. The type of check that is used depends on how the meter is read.
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:
· Investigate validation rules for TOU demand and usage.
· Determine what is statistically valid as a minimum density requirement for rules based on similar customers.
· Determine sample calculations for optional trend factors to incorporate climatic and demographic areas in validation and estimation. (Workshop Report, p. 34.)
1. Introduction
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.
2. Meter Worker Qualifications
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 1: Installation of single phase self-contained meters.
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:
"as a means to confirm clarity and ensure a smooth transition on issues such as: DA [direct access] process awareness, verification of the processes used by UDCs and MSPs to install or return meters and documentation, and requirements for effectively communicating essential meter related data." (Workshop Report, App. D, pp. 13-14.)
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.
3. Meter Installation
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:
1. Clarification that all instrument transformers, test switches, and associated wiring up to the meter socket, are to remain the responsibility of the UDCs. However, reconnection of existing wires to a replacement of an existing meter socket, A-base socket adapter, or A-base meter may be performed by either UDCs or MSPs. (App. D, p. 20.)
2. Observation and procedures regarding safety related concerns involving customer life support, electrical hazards, physical hazards, unsafe customer premises, and vermin. (App. D, pp. 20-21.)
3. Observation and procedures regarding meter security and accessibility. (App. D, pp. 22-23.)
4. Observation and procedures regarding site verification. (App. D, pp. 24-26.)
5. The procedures that a meter worker must follow when installing or removing meters. (App. D, pp. 27-28.)
4. Meter Maintenance And Testing Schedule
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.5
5. Meter System Testing
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:
1. Voltage test: this test is necessary to ensure safety in meter work procedures; provide the meter worker with knowledge of the correct service voltage prior to any meter work; and confirm that no short-circuit or hazardous conditions exist in the customer equipment or panel.
2. Light load and full load test or customer-load test: this test is used to ensure that the meter is accurate during various load conditions.
3. Demand test: this test is used to ensure the accuracy of the demand function of the meter.
4. Register verification: this test ensures that the register parts and components are working to provide and retain accurate billing data and information.
5. Phase angle test: this test ensures that the correct wiring is in place for the meter system, which, in turn, affects meter site accuracy.
6. Separate element check: this test ensures that each element of the meter is in good working condition.
7. Burden test: this test is performed to check for proper operating conditions of the current transformer.
6. Test Standards
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.
H. Data Security
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.
I. Future Of The PSWG
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:
· Meter hardware standards
· Meter communication standards
· Meter worker qualifications
· Meter installation procedures
· Meter maintenance, testing and calibration
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:
· Electronic commerce/data flows, including issues regarding information related to meters and meter change outs, meter usage data, direct access service requests, account maintenance, etc.
· Validating, editing and estimating usage data
· MDM issues
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.
3 With respect to the VEE rules in Appendix C-VEE, one entity voted against the VEE rules, and another entity abstained from voting. (Workshop Report, App. C-VEE.) The VEE rules are described in Section E of this decision.
4 The Workshop Report at p. 30 refers to the MEP as the California Metering Exchange Protocol.
5 The demarcation point for meter work was also addressed in the meter installation portion of Section II of Appendix D of the Workshop Report.
