A. Introduction
The work on meter and meter-related data standards was initiated in D.97-05-039 and D.97-05-040 when the investor-owned electric utilities were ordered to confer with interested parties to develop such standards. A workshop on meter and data communications was held in July 1997, and a workshop report on the subject was filed on July 25, 1997. This was followed by the issuance of D.97-10-087. In that decision, the Commission adopted the approach that the provisioning of meter services and MDMA services be provided through the UDC or an ESP. In addition, the Commission adopted some interim metering standards and criteria as part of the direct access tariffs that were approved in that decision.
In D.97-12-048, the Commission further refined the interim metering standards. The refinements were needed to make clear what interim standards all direct access meters would have to meet, to make the meters available to the public in a timely manner, and to allow an unbundled metering environment to occur. The Commission stated that it would revisit the interim standards and develop permanent metering-related standards with the help of the market participants. Today's decision addresses the recommendations in the Workshop Report, and adopts permanent meter and meter data standards.
The process that the Commission and the market participants have gone through to develop recommendations regarding permanent standards have been of immense benefit to the Commission. As the Commission noted in D.97-05-040 at page 48, the review and development of permanent standards should involve all of the market participants since many of the standards are technical in nature and beyond the expertise of the Commission. This process appears to be well suited for reaching resolution of numerous operational issues, and for identifying contested issues
Much of the debate that occurred among the PSWG participants appears to center on what the Commission meant by the terms "open architecture," "interconnection," and "interoperability." Some of the parties feel that the Commission should adopt standards for all possible interfaces. Others feel that the Commission should adopt broad standards, and let the market and the market participants decide what other standards should be adopted.
We noted in D.97-12-048 that open architecture has been described "as an environment where the specifications for interfaces, services, protocols and data formats are vendor-neutral, published, freely available, and agreed upon in an open process under the auspices of a recognized national or international standards body." (D.97-12-048, p. 9.) The Commission stated that open architecture allows interoperability to occur. Interoperability refers to the creation of specifications that allow dissimilar devices or systems to communicate with each other in a way that is transparent to the users. Through interoperability, customers are able to choose from multiple suppliers of electric services.
In adopting permanent metering standards, we want to avoid a situation where the Commission is in a position to dictate what kind of specific technologies manufacturers must use. Such a result would tie the hands of meter manufacturers, and could lead to a situation where a meter meets the California standards but could not be used outside the state. The Commission recognized this tension when it prepared its November 1993 report to the Governor, which was entitled "Enhancing California's Competitive Strength: A Strategy For Telecommunications Infrastructure" (Infrastructure Report).
The Infrastructure Report addressed a strategy for encouraging the development of an advanced public telecommunications network in California. As part of this strategy, the Commission said that "state policy should not dictate specific technologies to deliver advanced telecommunications, nor select specific firms that will be responsible for infrastructure development." (Infrastructure Report, p. 25.) We believe that the same approach should be used in the unbundling of meters and meter-related services, and in the adoption of permanent operating standards.
Many of the same concerns that were expressed in the Infrastructure Report apply to the new direct access electricity market as well. For example, the Infrastructure Report recognized the rapid pace of technological progress, and how advanced telecommunications were relying on the use of computing technology. The report also recognized the following four disadvantages with having the government plan the telecommunications infrastructure:
"First, public decision-making is inevitably slower than that in the private-sector because of due process requirements. Second, government agencies are not generally able to sustain a state-of-the-art level of technical expertise because of budgetary and personnel constraints. Third, many of the most important innovations will continue to emerge from firms outside the universe familiar to regulators as the lines between the telecommunications, computing, information and entertainment industries continue to blur. Fourth, the de facto standardization imposed by a centralized government decision can freeze network innovation, by precluding the incremental and continuous improvement in the state's overall infrastructure that independent decisions made by many different firms can produce." (Infrastructure Report, p. 26.)
The opening of electricity markets to direct access has resulted in technological changes and advancements. Meter manufacturers offer a variety of different products and services, and transfer of meter data has increasingly relied upon Internet protocols and other communication technologies. The concerns about the government planning and regulating technological changes hold true today as well. If we adopt standards which are too narrow in scope, there is a danger that other technological innovations will render our standards obsolete. Thus, the Commission's approach should be one of open architecture, i.e., an open platform, which provides opportunities for all market competitors on an equal basis. The adoption of standards should be broad enough so that no one technology is favored over another. At the same time, the standards must ensure the continuing safety, accuracy and reliability of the meters and the meter data. These safety, accuracy, and reliability concerns are what drives our desire for standards. The standards and requirements which we adopt today meet these objectives.
We decline at this time to adopt SCE's recommendation that the permanent meter and meter data standards be incorporated into a General Order of the Commission. We anticipate that there are likely to be other changes and modifications to the standards as time evolves. Rather than change the General Order each time a change is made to the permanent standards, we would rather make the changes by way of a Commission decision. Perhaps in the future, when the market participants have adjusted to the permanent standards, and no other changes are likely, a General Order could be issued which details all of the permanent standards in one convenient reference.
When the Commission moved to unbundle metering services, many of the "participants expressed confidence that open platform standards could be developed within several months." (D.97-05-039, p. 15.) Although many agreements have been reached among the market participants, there are a number of other issues that still remain contested. It may be that concerns regarding open platform standards should best be left to the marketplace, rather than settled in the regulatory arena. We first turn our attention to the uncontested recommendations.
B. Unopposed Recommendations
1. Meter Equipment
In D.97-12-048, the Commission adopted interim standards for direct access meters. The interim standards required the direct access meters to meet at least one of the four following criteria:
"(1) Existing meters that meet the direct access requirements as detailed in D.97-05-040 and D.97-10-087, and that meet all of the local UDC's installation, safety, accuracy, and reliability criteria as of the date of this decision; or
"(2) Meters which presently meet the applicable sections of the following ANSI standards:
· ANSI C12.1 Code for Electricity Metering
· ANSI C12.6 Marking and Arrangement of Terminals for Phase- Shifting Devices Used in Metering
· ANSI C12.7 Requirements For Watthour Meter Sockets
· ANSI C12.10 Electromechanical Watthour Meters
· ANSI C12.11 Instrument Transformers for Revenue Metering, 10 kV BIL through 350 kV BIL (0.6 kV NSV through 69 kV NSV)
· ANSI C.12.13 Electronic Time-of-Use Registers for Electricity Meters;
· ANSI C12.20 0.2% and 0.5% Accuracy Classes; or
"(3) Meters which meet the Independent System Operator Specification MTR1-96 (Engineering Specification for Polyphase Solid State Electricity Meters for Use on the ISO Grid); or
"(4) Existing in-service meters which meet local UDC's installation, safety, accuracy, and reliability criteria as of the date of this decision, and which can be retrofitted with a device to meet these criteria as well as the direct access requirements as detailed in D.97-05-040 and D.97-10-087. If an optical pick-up type retrofit module is used, the meter shall pass the sunlight interference test described at page 5 of Appendix A of the Meter and Data Workshop Report."
In addition, the meters used for direct access must meet the following requirements:
"(1) If the meter has metering communications capabilities, the meter must meet the applicable provisions of the Federal Communications Commission (FCC) Regulations, Part 15, subpart B (47 Code of Federal Regulations), or it must have a Type 2 optical port or other suitable means of on-site or remote interrogation.
"(2) If the meter or meter devices are certified by the manufacturer, the manufacturer's certification must conform to the applicable provisions of ANSI C12.1 (Code for Electricity Metering) and ANSI C37.90.1 (Surge Withstand Capability (SWC) for Protective Relays and Relay Systems).
"(3) The meter or the meter data system must be capable of providing and storing required interval data for a minimum of 35 days." (D.97-12-048, pp. 14-15, footnotes omitted.)
Attachment A of this decision provides a summary of the permanent meter equipment standards which the PSWG recommends be adopted. The PSWG recommendations are found in Appendix A of the Workshop Report,
which we incorporate by reference.8 Appendix A of the Workshop Report provides a detailed explanation of each "meter product"9 standard; the certification testing requirements that the meter products must comply with; the filing of a meter type self-certification document with the Commission by the meter product manufacturers, and the posting of compliant meter types on the Commission's web site; required stickers, and sealing and locking hardware; labeling of the manufacturing date on the meter product; and the procedures to follow to rebuild, retrofit, or repair meter products.
A comparison of the recommended meter product standards with the interim meter standards that we adopted in D.97-12-048, reveals that the PSWG participants believe that many of the interim standards should remain permanent. In addition, several other ANSI standards have been added to the list of recommended permanent standards. All of the recommended standards appears to related to safety, accuracy, and testing concerns. None of the recommendations appear to prescribe that meter product manufacturers must adhere to a particular type of technology.
No one opposes the adoption of the meter product recommendations. We will adopt the recommendations set forth in Appendix A of the Workshop Report, as summarized in Attachment A of this decision. We will also require that an additional interim standard be made a part of the permanent standards. For meter products which store and provide interval meter data, the meter must be capable of providing and storing the interval meter data for a minimum of 35 days. (See D.97-12-048, p. 15.) This will ensure that the meter is capable of storing the meter data for sufficient periods of time.
Except as provided for below, effective 120 days from today, all direct access meter products shall meet the requirements set forth in Attachment A, in accordance with the timetable set out at page 1 of Appendix A of the Workshop Report.
One of the meter product standards calls for the filing of a meter type self-certification document. The purpose of the document is for the various meter product manufacturers to certify that its meter types meet the Certification Testing Requirements that are contained in Section II of Appendix A of the Workshop Report. (Workshop Report, App. A, Section III.) We must establish internal procedures to handle these kinds of filings. Although the standard calls for the self-certification document to be "filed," we do not believe that the document should be filed with the Commission's Docket Office. Instead, this self-certification document should be submitted to the Energy Division. The Energy Division shall be responsible for developing procedures for accepting and reviewing these kinds of documents. The Energy Division shall also determine how the self-certification document should be phrased, and whether any supporting documents should be required at the time of submission. The Energy Division shall have 90 days from today to develop the procedures that we have just described, and to make those procedures available to all interested persons after the 90 days has elapsed.
During the review process, the staff of the Energy Division shall be entitled to obtain from the meter product manufacturer all backup documentation that is related to the certification testing requirements for the meter that the manufacturer is certifying. If the Energy Division determines that the self-certification document for a particular meter is in order, the Energy Division shall post the model number of the meter type, along with the name of the meter product manufacturer, on the Commission's web site. The design of the Commission's web page needs to adequately describe the purpose of the list so that viewers of the page understand its purpose.
As the name of the self-certification document implies, we shall require that the document be verified by an officer or authorized employee of the manufacturer with the following statement:
" DECLARATION
I, (print name and title) ___________________ hereby certify that I am empowered to act on behalf of __________________ (manufacturer's name) and to submit this self-certification document on its behalf. I declare under penalty of perjury under the laws of the State of California that the above statements are true and correct, and that if any documents are furnished in connection with this self-certification document, that those documents are true and correct copies.
Dated ___________________, at _____________________________.
(date) (place of execution)
Signature: _______________________________"
If the verification is made outside of California, the verification must be made by an affidavit sworn or affirmed before a notary public.
One of the unresolved issues is what should be done about the direct access meters that do not meet the requirements of Attachment A, but do meet the interim standards that we adopted in D.97-12-048. The Workshop Report does not address the issue, and none of the parties who commented on the Workshop Report directly answers this issue.10
The Commission adopted the interim meter standards as a way to ensure that direct access meters would be made available to the public in a timely manner. We should not punish meter manufacturers and the MSPs, who relied upon these interim standards to make meters available to the public, by immediately discontinuing their use. Instead, we should allow MSPs to continue to offer direct access meters which meet at least one of the four meter criteria that are set forth in D.97-12-048 at pp. 14 and 15. The MSPs may continue to offer direct access meters which meet those interim standards for the next 120 days. Direct access meters which only meet the interim standards, as adopted in D.97-12-048, shall be retired from service no later than June 30, 2002.11
It shall be incumbent upon the meter product manufacturers, the UDCs and the ESPs to ensure that meter product standards have been adhered to. Section H(2) of Appendix A of D.97-10-087 provides that it is the responsibility of the ESP or the UDC, as the MSP, to ensure that the interval meter used for direct access complies with the Commission's meter design specifications. The failure to comply with the requirements for meters or meter services can lead to the remedial actions that are provided for in Section H(8) of Appendix A of D.97-10-087. In addition, the Commission could bring an enforcement action against the ESPs or UDCs in accordance with the Public Utilities Code. We will continue to expect that the ESPs and the UDCs, as the MSPs, will ensure that the permanent meter product standards that are summarized in Attachment A are adhered to.
2. KYZ Contact Output
In Section II.1. of Appendix B of the Workshop Report, the PSWG unanimously recommends that if a meter product has a contact output, it should be KYZ pulses in accordance with ANSI C12.1. There is no requirement, however, that the meter product must have a contact output.
We shall adopt that recommendation as reflected in Attachment B of this decision.
3. Meter Password Authorization
The recommendation for the meter passwords allow an ESP to issue varying levels of access to a meter for which the ESP is responsible. The ESP would also be required to issue a password to the UDC for audit purposes and for other scheduled functions. No one voted against the recommendation. (Workshop Report, App. B, Section IV.)
We will adopt the recommendation as reflected in Attachment B.
4. Meter Data Management
The PSWG unanimously recommends that the MDMA provide technical and business support to the ESPs and UDCs during normal business hours. In addition, the recommendation provides that the MDMA will provide access to a support pager, which is to be made available at all times, to address issues about the availability of the MDMA's server. These recommendations are set forth in Section IV of Appendix C of the Workshop.
We will adopt the recommendation for the MDMA technical and business support that is set forth in Section IV of Appendix C of the Workshop Report, and which is summarized in Attachment C.
5. Meter Maintenance And Testing Schedule
Interim meter maintenance standards were discussed in D.97-12-048 at p. 19. During the interim period, the Commission required meter maintenance to be performed in accordance with the UDC's practice. Section III of Appendix D of the Workshop Report contains the meter maintenance and testing schedule. We will adopt these provisions as the permanent meter maintenance and testing schedule for direct access meters. (See Attachment D.)
6. Meter System Testing
The purposes behind the testing of the meter system are described in Section IV of Appendix D of the Workshop Report. Attachment D-1 of Appendix D describes each of the test procedures. No one has objected to the meter tests. We will adopt Attachment D-1 of Appendix D as the permanent meter system tests.
7. Test Standards
The calibration and maintenance of test standards are described in Section V of Appendix D of the Workshop Report. No one has objected to these test standards. These provisions are adopted as the permanent test standards for calibrating and maintaining meter test standards. (See Attachment D.)
8. Data Security
The PSWG recommends that data security issues be addressed by the DQIWG. The DQIWG was formed in D.97-12-090 to evaluate any gaps or flaws in the rules and procedures for data information exchange. We will address data security issues, of the kind that were raised in Appendix F of the Workshop Report, in a decision which addresses the recommendations of the DQIWG. The DQIWG filed an "Interim Report To The CPUC" on August 24, 1998. The final report of the DQIWG is expected shortly.
C. Contested Recommendations
1. ANSI C12.18 Type 2 Optical Port Standard
As part of the permanent meter product standards, we adopted the unanimous recommendation that if a Type 2 optical port is used, the port must meet the C12.18 standard. SCE recommends that if an optical port is used, it must be a Type 2 optical port and meet the C12.18 standard.
We decline to adopt a requirement that would mandate the use of a Type 2 optical port for meter products that use an optical port. Meter product manufacturers should be free to use other kinds of optical port types. The Commission adopted a similar position with respect to meter mounts. In D.97-12-048, the Commission adopted an open architecture platform with respect to meter connections. Instead of limiting meter connections to only meter sockets, the Commission allowed "ANSI approved sockets or other mounting options agreed to between the manufacturer and the UDC and ESP." (D.97-12-048, pp. 11-12.)12 The same type of open architecture should apply to optical ports as well. We believe that this kind of approach will give manufacturers more flexibility in responding to market conditions and demands. If, however, a Type 2 optical port is used, that port will need to meet the C12.18 standard.
2. ANSI C12.19 - Utility Industry End Device Data Table
The debate over the ANSI C12.19 standard was the most heavily contested issue, and the issue with the least consensus. The C12.19 standard involves the issue of whether meter product manufacturers should be required to communicate data in the data format specified by C12.19. The majority of the PSWG members recommend requiring all new meter types released after March 20, 2000 to meet the C12.19 standard. Meter products released before that date would be exempted from the C12.19 requirement for the duration of their commercial product life.
The Workshop Report pointed out several drawbacks with the C12.19 standard. The Workshop Report acknowledged that if the C12.19 standard is adopted, the standard may not by itself allow for a plug and play environment.13 For example, if a customer has a meter which communicates over a microwave frequency, and the customer switches to an ESP that reads meter products via a telephone line, the meter will have to be replaced or retrofitted to accommodate the new communications channel. The Workshop Report also acknowledges that the C12.19 standard "would not be compatible with all radio frequency based technologies," and that it "would have an impact on bandwidth and response times." (Workshop Report, p. 20.)
The positions taken by Itron, and the California Competition Network, Enron, Schlumberger, and CellNet provide some good reasons why the C12.19 standard should not be required. They point out that the C12.19 standard is not necessary to make the market work, nor will it ensure that interoperability will occur. This is supported by the comments of the joint parties, which indicate that various committees are working on a national level to develop communication interface standards for specific technologies. If that is the case, meter product manufacturers will feel the pressure to adopt these kinds of standards on a voluntary basis so that their products can interconnect with other products and services which use the same voluntary standards. In addition, requiring that the C12.19 standard be adopted could unduly influence how these standards are ultimately shaped.
The positions of Itron, Schlumberger and CellNet are also persuasive given their perspective as actual meter product manufacturers. They point out that the adoption of the C12.19 standard will result in added costs because the meters will have to add new functions. They also point out that there is disagreement on whether the C12.19 standard is the right standard to choose, and that the meters of the UDCs will not be required to meet the same standard. We are uncomfortable in mandating a standard that creates a tier of C12.19 compliant meters and a tier of non-complying meters. Unlike industry standards which are voluntary, government standards are not voluntary, and as such, should only be adopted after careful consideration, and only when the public interest demands such action.
We also agree with the opponents of the C12.19 recommendation that exempting meters built on or before March 20, 2000 would result in the continued use and continued availability of meters which are non-C12.19 compliant, and result in additional costs for those manufacturers who have to comply with the C12.19 standard. Also, instead of achieving interoperability, the unlimited exemption of meters built before this date would discourage interoperability because non-complying meters issued before that date could still be used and sold.
Given the acknowledged drawbacks of the C12.19 standard, the concerns that other market participants have raised, the lack of any consensus, and the possibility that voluntary standards may be developed in the near future, we decline to adopt the C12.19 standard for meter communications. Furthermore, this standard is not required to ensure safety, accuracy, or reliability. We are also wary of adopting any standard which is opposed by the manufacturers who will actually be developing and bringing such meter products to the market.
3. ANSI 12.21 and ANSI 12.2214
No one expressed any views about these two communication specifications. Since neither of the two specifications has been approved yet by ANSI, we decline to take any action. Should these specifications be approved by ANSI in the future, and a market participant feels that the two communication specifications should be included as a standard, the participant may file a petition to modify the permanent standards that we adopt in this decision.
4. KYZ Consumer Protection
The Workshop Report notes that most energy management systems utilize KYZ outputs. A majority of the PSWG recommends that if a new direct access meter will not be compatible with a customer's energy management system because of its KYZ outputs, the ESP must notify its customer of this incompatibility. (Workshop Report, App. B, Section II.2.)
We will adopt the notification recommendation. It is important for a direct access customer to know whether a planned meter purchase will operate seamlessly with the customer's other systems. The PSWG recommendation would allow customers to find out ahead of time of possible incompatibilities. Our adoption of this standard is reflected in Attachment B.
5. Visual Meter Read
SCE contends that the intent of this recommendation was to provide for "back-up meter read requirements," and not to provide a visual meter display. As a result, SCE asserts that the meaning of the recommendation has changed because a visual meter display requirement allows back-up meter reading capability for only cumulative meters or peak demand meters. However, for a meter which stores hourly or 15-minute interval data, there must be a physical interface to allow on-site retrieval of data.
We have compared Section III of Appendix B of the Workshop Report with the text that SCE supplied in Attachment A of its comments. It is clear that a discrepancy exists with the title of the recommendation, but the wording of both versions results in the same outcome. Under either version, the meter will be required to have a meter display. For electromechanical meters, dials are sufficient. For an electronic meter, the total kWh that have been consumed must be displayed, at a minimum. If the meter retains stored meter data, the meter must have a physical interface to enable on-site interrogation of all stored meter data. Thus, the requirement of a kWh display, and, if necessary, a physical interface, are necessary whether for reading the meter visually or for back-up reading purposes.
We do not agree with the comments of ABB and NERTEC, which do not favor the requirement of a local display on the meter. They prefer the flexibility of having remote meter reading capabilities from within one's home or office. We view remote meter reading capability as an additional service that some people may want. However, such a service should not be required, nor should it become part of a standard. Simply because some customers may desire a feature or a function is insufficient justification for the Commission to set such a standard. However, having a display at the meter source allows anyone with the appropriate access to read the meter.
We are concerned that the requirement mandates that the meter must have a display in kWh. As the CEC points out, billing on a kWh basis may not be the universal billing unit since other measurement units can be used. We will therefore modify the recommendation of the PSWG to allow electromechanical meters to display in kWh, or if a meter stores meter data, that there must be a physical interface to enable on-site interrogation of the stored data. As modified, the adopted visual meter read standard reads as follows:
"All direct access meters shall have a visual kWh display or a physical interface to enable on-site interrogation of all stored meter data. There are two reasons for requiring a visual meter display: (1) For consumer protection: The consumer can verify that the meter read matches the bill, and (2) For on-site interrogation when other meter communication systems fail: This would enable entities who are responsible for billing/settlements to obtain the meter read when investigating the communications failure. For electromechanical meters, the dials are sufficient for this on-site interrogation. At a minimum, electronic meters must have a physical interface to enable retrieval of all stored meter data."
The above standard will give meter product manufacturers the flexibility of deciding whether the meter should display kWh units, in addition to the stored meter data. Needless to say, if the meter has only a physical interface, the customer must be provided with the means to be able to retrieve the stored meter data in a way that can be understood. In addition, appropriate passwords would need to be issued to allow authorized customers, UDCs, and MDMAs to retrieve the stored meter data.
SCE also seeks to have us define "stored meter data" to mean more than 15 days of data. We do not believe that is necessary. Stored meter data should refer to any meter data stored by the meter.
Sections I, II and III of Appendix C of the Workshop Report all revolve around the issue of subcontracting. Most of the PSWG members who voted recommend that MDMAs be allowed to subcontract functions, such as meter reading, to other approved entities, and that MSPs be permitted to subcontract with MDMAs to reprogram its meters.
We are not opposed to the idea of permitting MDMAs and MSPs to subcontract some of their functions. The CEC, however, correctly points out that the subcontracting issue substantially affects the metering and data management framework that the Commission established in D.97-10-087 and D.97-12-048, and raises data quality and integrity issues as well. We believe that the public and the market participants will be better served if we take a considered and unhurried approach to this issue. Therefore, we will defer the issue of subcontracting MDMA and MSP functions to a future decision.
7. MDMA Performance Standards
The MDMA performance standards are generally addressed in D.97-12-048 at pp. 27 to 33. The Workshop Report did not address two requirements which were included in D.97-12-048. The first requirement is that MDMAs are required to read the direct access meter at least once a month. (D.97-12-048, p. 30.)
The second requirement addresses safety requirements for MDMAs. In D.97-12-048, the Commission stated:
"We will require in the direct access tariffs that all MDMAs comply with the pertinent electrical safety provisions of Cal OSHA and the UDC's safety requirements as they apply to the reading of electric meters. Prior to allowing an ESP, in its role as the MDMA, or a third-party MDMA, to perform meter reading, we will require the UDCs, as discussed below, to review the safety training and procedures that the MDMA and its employees are to follow.
With regard to the recommendation that the MDMA report meter, safety, and hazardous conditions, and that site-specific information be kept, those safeguards are already contained in the direct access tariffs in Sections H(3) and H(8)(e) [of the direct access tariff]."
No one has disputed that both the monthly meter read requirement, and the MDMA safety requirements, should be retained. Since the Workshop Report remained silent on these issues, we will include both of these requirements as part of our permanent meter data management and meter reading standards as reflected in Attachment C.
The PSWG recommends that the percentage of validated meter data that must be made available on the MDMA's server should be reduced from 99.99% to 99% for both interval data and non-interval data. The PSWG points out that the present percentage requirement of 99.99% is an unreasonable goal. If this percentage requirement remains unchanged, one missing account out of 5000 would cause an MDMA to be out of compliance. We will adopt the recommendation of the PSWG for interval meters as follows:
"(iii) 99.0% of all usage data must be available within five days of the scheduled reading date of the meter."
We also adopt the recommendation of the PSWG for non-interval data as follows:
"(iii) 99.0% must be available by 6:00 a.m. on the 5th working day after the scheduled meter reading date."
The other timeliness standards shown in D.97-12-048 at pp. 31 and 32 shall remain unchanged, and shall be incorporated into our permanent standards as reflected in Attachment C.
The PSWG recommends that the first billing cycle after the initial switch should be ignored in determining the timeliness of validated meter reading data. The PSWG points out that during the first month following the initial switch, information is sometimes delayed. If the first billing cycle is considered in how well MDMAs are providing timely meter data, this would skew the performance statistics. We will adopt the PSWG's recommendation, and exempt the first billing cycle following the submission of the direct access service request from having to meet the timeliness standards for validated meter reading data.
The PSWG also recommends that when data cannot be delivered to the MDMA server within five days, the MDMA be permitted to use the VEE rules that are contained in Appendix C-VEE of the Workshop Report for both interval data and monthly data. No comments were filed in opposition to this recommendation. We will adopt the recommendation to use the VEE rules in Appendix C-VEE to estimate meter data that cannot be timely delivered to the MDMA server. Section A of Appendix C-VEE shall apply to interval data, and Section B of Appendix C-VEE shall apply to monthly data.
8. MDMA Performance Exemptions
The PSWG recommends that the Commission adopt two exemptions from having to timely make meter data available on the MDMA's server. The first recommendation would exempt MDMAs from having to include in the MDMA's performance report situations where no meter reads occurred due to a large catastrophe, such as an earthquake or hurricane. If such an event occurred, the MDMA would be allowed to estimate and post the data. The estimated data would be reported separately in the MDMA's performance report, and would not be included in any performance penalties assessed against the MDMA.
No one has objected to the adoption of the first recommendation. This kind of exemption makes practical sense. A natural catastrophe could occur which prevents an MDMA from being able to read the meter during the normal billing cycle. In such cases, the data should be estimated, and the failure to obtain actual meter data should not count against the MDMA.
The second recommendation would allow the MDMA to separately report estimated data if a meter was not accurately recording usage. The estimated data would be separately reported in the performance report, and it would not be included in any performance penalties assessed against the MDMA.
SCE supports the idea that estimated data due to meter failure be exempt from a MDMA's performance record. SCE believes, however, that incentives should be in place so that the ESP and MDMA will take appropriate steps to fix or replace the faulty meter. Thus, SCE recommends that the exemption only apply if two conditions are met: (1) that the exemption only occur after a manual verification reading that the meter has failed and there is no problem with the remote reading technology; and (2) the exemption cannot occur for an account more than once in a 12-month period.
SCE's conditions are reasonable, and will be adopted as part of the second exemption. The first condition is likely to occur regardless of whether the Commission imposes that condition. The second condition will create an incentive for the ESP and MDMA to fix or replace the faulty meter.
Attachment C provides a summary of the above discussion.
9. EDI Implementation
The majority of the PSWG members voted in favor of a migration to the EDI standards for the transfer of meter usage data. The recommendation proposes that there be a migration to the EDI standard following the adoption of an implementation plan that is to be developed by the market participants. The plan would include file format and business rules, and the implementation date for the start of EDI. It is also proposed that the retrieval of data from the servers continue to use HTTP with Secure Sockets Layer. The communication mechanism could change in the future in response to other processes that are addressing standards.
The comments that we received regarding the use of EDI support its implementation although some very practical problems are raised. PG&E points out that the changeover to EDI will require systems programming work, and that having to maintain both the MEP and EDI would be a significant drain on programming resources.
The CEC favors the use of EDI for MDMA data exchanges, but opposes the idea that the Internet be the sole communication mechanism, and that HTTP be the only allowable protocol.
SCE also supports a migration from MEP to EDI, but believes that the migration requires adequate planning and testing. SCE recommends that the MEP-to-EDI transition team develop a project plan for the migration, and that the plan be published by June 1, 1999. The plan should review and comment on the areas of concern, detail a timeline for a transition to EDI, establish an EDI protocol, establish change control procedures, identify support resources, and address data security and integrity.
It is obvious from the comments that an instant cut-over to EDI from MEP cannot take place. Instead, there appears to be a need for a transition period to allow participants to prepare for, adjust to a new standard, and to verify that the EDI format is working properly.
We will adopt the recommendation which calls for all interested parties to work together to create a statewide implementation guide for the use of EDI. We will direct the Energy Division to ensure that this result is achieved through the Direct Access Tariff Review Committee established in D.97-10-087.15 We would like to implement the use of EDI on a trial basis no later than September 1, 1999, with the goal of having EDI as the only standard for transferring meter usage data no later than February 1, 2000. With this in mind, the Direct Access Tariff Review Committee needs to develop a proposed statewide implementation guide, and to file it no later than April 2, 1999. Comments to the report should also be permitted, and should be filed within 21 days of the report's filing. A Commission decision would then issue in June or July of 1999 to address the EDI standards and implementation guidelines. Under such a schedule, market participants can gear up to move toward an EDI format, with the expectation that a trial period will take place in the last four months of 1999 and in January of 2000, and that the MEP data format will be discontinued on February 1, 2000.
We believe that the various EDI comments can be addressed by the Direct Access Tariff Review Committee and in the resulting report. This should result in a proposed implementation guide that addresses the needed resources and cost of implementing EDI; specification of the EDI standards; what communication links and protocols must be used and whether other means will be permitted; the timeline for implementing the changes; testing of the new standards; a procedure to make future changes to the EDI standards; and how EDI will address data security and integrity issues.
We will refrain from adopting permanent EDI standards until after the report and comments have been filed. We will, however, direct the UDCs, ESPs, and MDMAs, to move toward using EDI to transfer meter usage information in accordance with the schedule described above.
As for the PSWG recommendation that any new transactions between MDMAs and market participants use EDI as the preferred method of transferring meter usage data, that idea has merit but, we will address that issue after the EDI report has been filed. As we noted, the migration to EDI will take some time. The participants in the Direct Access Tariff Review Committee are free to develop recommendations on how the implementation of EDI can accommodate new transactions occurring after a certain date.
Similarly, the recommendation that EDI be used as the preferred method of electronic communications for meter-specific information flows, should be addressed in the Direct Access Tariff Review Committee and EDI report as well.
10. VEE Rules (Interval and Monthly)
The interim VEE standards were contained in D.97-12-048 at pp. 41 to 46. 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 as the permanent VEE standards.
The only objection to the proposed permanent standards came from Enron. Enron opposes one of the two procedures for performing a high/low usage check on monthly meter data. (See Workshop Report, App. C-VEE, pp. 20-26.) Enron opposes the procedure, which is based on previous day usage of similar customers, because a large set of data is needed in order to develop a reasonable statistical sample. Enron contends that the UDCs are the only ones who have the information to calculate the parameters needed for this validation test.
PG&E contends that no one disputes the validity or soundness of the procedure. In addition, the procedure is optional, and the MDMAs are free to use the other procedure for performing the high/low validation test. PG&E also asserts that it should have the flexibility to implement the best VEE routines for their customers.
We agree with PG&E on this issue. The high/low usage check permits the use of two different methods to validate kWh consumption. Although the non-utility MDMAs lack the kind of information needed to calculate the previous day usage of similar customers, the non-utilities can use the historical data procedure to validate kWh consumption. We will not delete the previous day usage procedure from the high/low usage check. If, in the future, it appears that the UDCs are using the previous day usage procedure in a way that disadvantages the MDMAs, a complaint with the Commission can be filed, or a petition to modify this decision can be filed.
We adopt the materials contained at pages 1 through 16 of Section A of Appendix C-VEE of the Workshop Report and Attachment C-VEE-A, as the permanent VEE standards for interval meter data. We also adopt the materials at pp. 17 through 37 of Section B of Appendix C-VEE and Attachment C-VEE-B of the Workshop Report as our permanent VEE standards for monthly meter data.
The PSWG also recommends that "the existing requirement to include the estimation algorithm when the data is posted" be eliminated. We assume that the PSWG is referring to the interim standard that we adopted in D.97-12-048 at p. 44 which states: "estimated usage data is to be identified, along with the estimation technique used." Since Appendix C-VEE does not require the estimation algorithm to be included as part of the posted data, the reference at p. 44 of D.97-12-048 is no longer applicable.
The PSWG also recommends that a group be sanctioned through the UDC/MDMA meeting process to perform the following tasks: clarify the permanent meter and meter data standards by providing examples, flow charts and definitions; review the effectiveness of the permanent meter and meter data standards after they have been operational; and propose a procedure for making changes to the permanent VEE standards.
We will direct the Energy Division to convene a workshop within 90 days from today to determine whether there is an interest by the UDCs, ESPs and MDMAs to pursue these additional tasks. If there is no interest in pursuing these tasks, the Energy Division shall prepare a workshop report notifying the Commission of this, and its recommendations on whether the above-described tasks should still be pursued, and if so, in what manner. If the workshop participants are interested in addressing these additional tasks, a workshop report shall be prepared with its proposed recommendations. The workshop report shall be filed and served within 60 days of the conclusion of the workshop. Comments to this workshop report may be filed by interested parties within 21 days of the filing of this workshop report.
11. Meter Worker Qualifications
No one is opposed to the MSP and meter worker qualification standards that are set forth in Section I of Appendix D of the Workshop Report. Although the PSWG recommendation and the various comments suggest that there is a need for a collaborative oversight of the five meter worker classifications, the participants disagree on the type of organization that should be set up over the long term to design and administer the tests for the higher skilled meter worker classes.16
The PSWG recommendation favors the creation of the MWCO. The recommendation contemplates that there could be more than one MWCO. The MWCO would have to be knowledgeable about the meter services that it certifies, and could be a UDC, a MSP, or an entirely independent organization. The recommendation proposes that the MWCO establish reasonable fees for its work.
SCE favors an approach that utilizes representatives from the UDCs and the MSPs. SCE believes that the advantage of the MCAB is that experts in the metering industry will be involved in the review process, and that the process will promote consistency.
As a result of the restructuring of the telecommunications and electricity market, and the unbundling of the products and related services, the Commission has increasingly found itself in a position of creating new advisory bodies, redefining the Commission's role, or experienced the creation of new entities eager to play a role in the restructured marketplace. The testing and certification process for the different meter worker classes is another challenge that we face. The Commission could redefine itself to take on this new challenge, or as the CEC suggests, other state agencies might be able to take on the testing and certification role.17
To solve this problem, we agree with the PSWG's recommendation that it is important that a permanent entity be responsible for the testing and certification of meter workers. We also agree with the CEC and SCE that the entity should receive input from both the UDCs and those MSPs that have already been permanently certified. These companies have the individuals with the kind of collective experiences that are needed to design the tests. Meter product manufacturers and organizations involved in electrical standards could provide assistance and expertise as well. In addition, the entity may need other resources to assist in the design and administration of the tests.
We agree with the PSWG that it will take some time before a permanent entity can design and administer the tests. That means an interim process is still needed. Although the PSWG's recommendation calls for an interim process, we are not so confident that the group could complete all of the contemplated tasks in the time required. Additionally, much of the work that the interim group is expected to undertake would duplicate much of the same work that the permanent entity is expected to do. The advantage of having an interim process up and running within 90 days is that there will be a process to administer tests to meter workers who want to be certified to do Class 4a, 4b and 5 meter work.
Instead of rushing to form an interim group so as to begin the testing and certification process, we believe that the participants should focus their energies on determining what permanent entity should be responsible for testing and certifying activities and for designing proposed certification testing. By doing so, we eliminate having two groups perform substantially the same work.
Although it is desirable to implement the various meter classes, and the testing and certification process as soon as possible, we believe the same safeguards can be implemented in a much quicker fashion by utilizing the framework of our interim standards, adopting the first four subdivisions in each of the five meter worker classes,18 and placing the burden on the ESP to prove to the UDC that the MSP that it is using is capable of performing meter work in the various classes.19 Until the permanent entity is fully functional, i.e., accepting applications for testing, and administering the tests, the procedures for certifying MSPs that was adopted in D.97-12-048 shall continue. Should the UDC question the ability of an MSP to work on a particular meter type, the burden will be on the ESP to prove to the UDC that the MSP that it is using is qualified to work on that particular meter type.
We note that the UDCs will receive notice of any meter installation work as a result of the rules that we adopted in D.97-10-087. In order for an ESP to initiate a meter change, the meter change must be noticed as part of the direct access service request. (D.97-10-087, App. A, Sections E.(3), E.(15); D.97-10-087, App. B, Section 23.) Thus, the UDC and the ESP, as well as the ESP's MSP, will know in advance what meter will be replaced. If the removal or installation involves skills in a higher meter class, the ESP may need to prove to the UDC that the MSP it is using possesses the necessary skill and experience for removing and installing a particular kind of meter. We expect that the ESPs and MSPs will closely monitor the UDCs' actions for any signs of anti-competitive behavior with regard to this process. We therefore adopt as part of our permanent meter worker qualifications, the first four subdivisions in each of the meter worker classes shown in Appendix D at pp. 2 to 11.
As for the permanent entity, we are not yet convinced of the need for the Commission to establish a new advisory body. At this time, we wish to further research whether the Commission or some other state agency can conduct the testing and certification activities.
Once the permanent entity has had an opportunity to do some work, it will be possible to decide whether the certification and testing procedures contained in Appendix D of the Workshop Report should be adopted as the permanent MSP meter worker qualification standards. Since we have not yet adopted the recommended self-certification process for Class 1, 2, and 3 meter workers, the revised application for meter service and installation certification should not be adopted at this time.
The PSWG recommends that the MSP certification process that was established in D.97-12-048 be continued with the exception of the 50 joint meets and required logs, and the provisional certification process. (Workshop Report, App. D, Section I.B.; See D.97-12-048, pp. 26-27.) Instead of requiring the UDC and ESP to meet during the first 50 meter installations, and to keep logs of such meetings, the PSWG recommends that the MSP be required to provide a detailed work schedule to each UDC for the first 20 installations by the MSP. The UDCs may attend the installations should they decide to do so. Except for some MSPs that fall within a certain window period, there would no longer be a provisional MSP certification number. Instead, a permanent MSP certification number would be issued once the MSP application is reviewed for compliance with the MSP certification process.
Presumably, all of the PSWG participants see some value in streamlining the MSP certification process. The detailed work schedule for the first 20 installations by a new MSP will be used instead of requiring or waiving 50 joint meets. Thus, the detailed work schedule essentially acts as a substitute for an actual meeting. In order to ensure that the UDCs have adequate information to make an informed assessment as to whether or not it should attend any of the 20 installations, we will require the work schedule to describe the meter type that is being removed and installed, a description of all the procedures it will follow for removing and installing the meter, and what safety precautions will be taken during these procedures.
We will adopt the MSP certification process described at pp. 22 to 27 of D.97-12-048, except as altered by the above discussion and Section I.B. of Appendix D of the Workshop Report, as the permanent MSP certification process. For those MSPs that have been permanently certified as MSPs prior to today's decision, they shall remain certified, provided the MSPs abide by all the permanent meter and meter data standards that we adopt today.
12. Meter Installation
The IAEI commented that the Commission should clarify that the electric utilities continue to be responsible for the ownership, operation, and maintenance of metering transformers as part of their distribution facilities. The IAEI contends that if customers are responsible for metering transformers, the installation will be covered by the NEC, which will require additional labeling, inspections, and added cost.
The same kind of issue was raised in D.97-10-087, i.e., whether the transformers are considered to be part of the distribution system or part of the meter system. In the Commission's approval of the direct access tariff, we approved the provision which stated: "Potential and current transformers shall be considered part of the distribution system and shall remain the responsibility of the UDC." (D.97-10-087, App. A, Section H.(1)(b).) Thus, the concerns that the IAEI warns of will not occur because the transformers, test switches, and associated wiring up to the meter connection, remain the responsibility of the UDCs as part of their respective distribution systems. However, we agree with the PSWG recommendation that "reconnecting 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." (Workshop Report, App. D, Section II.)
No one else commented on the remaining meter installation and removal procedures. We therefore adopt Section II of Appendix D of the Workshop Report as the permanent meter installation and removal standards.
13. Future of the PSWG
The PSWG indicates that its work objectives have been completed, and that there is no need for the PSWG to meet again unless the Commission needs its assistance to resolve a permanent standard. As mentioned in other sections of this decision, other outstanding issues related to meter data are being addressed by other working groups or are being handled by the additional processes that we have created. Since it appears that the PSWG has completed all of its work, we agree that the PSWG's work is complete. We thank all of the PSWG participants for assisting us to develop permanent meter and meter data standards.
1. In D.97-12-048, the Commission ordered the creation of the PSWG to review the interim metering standards adopted in that decision, and to recommend what permanent standards should be adopted by the Commission.
2. The PSWG workshop was held on January 29, 1998.
3. Many different entities, including the UDCs, ESPs, MSPs, MDMAs, and meter manufacturers, actively participated in the PSWG process.
4. The Workshop Report was filed on July 29, 1998.
5. The recommendations were voted upon by at least two-thirds of the eligible voting membership of the PSWG.
6. The meter equipment recommendations are found in Appendix A of the Workshop Report.
7. The discussion in D.97-12-048 about open architecture and interoperability triggered significant discussions by the PSWG.
8. One of the conclusions of the PSWG is that technology-specific interchangeability requires specifying a standard at every interface, and is not practical for all technologies at this time.
9. The PSWG recommends that interoperability be available in the areas of meter data management, data format tables, the initial communication protocol, and that all meters have a visual kWh display.
10. Meter communications refers to the communication between the meter and the meter reading device.
11. The recommendations for meter communications are found in Appendix B of the Workshop Report.
12. The PSWG recommends that the meter communicate in the format specified by the C12.19 standard, but that the entities should not be required to store the data in the C12.19 format.
13. The discussions over the C12.19 standard recognized that if the standard was applied, it may not allow for a plug and play environment.
14. The PSWG agreed that the C12.19 standard will not be compatible with all radio frequency based technologies.
15. Under the PSWG's recommendation, all meter types released before March 20, 2000 would be exempt from the C12.19 standard.
16. The recommendations concerning meter reading and meter data management are found in Appendix C of the Workshop Report.
17. The PSWG recommends that the functions performed by the MDMA be separately described as meter reading and MDM functions.
18. The PSWG recommends that D.97-12-048 be revised to allow a MDMA to subcontract subfunctions out to other approved entities.
19. The PSWG recommends that an MSP be allowed to subcontract with a MDMA to reprogram its meters remotely.
20. D.97-12-048 adopted the MEP as the interim meter data transmission standard.
21. The recommendations for the permanent VEE standards for interval and monthly data are in Appendix C-VEE of the Workshop Report.
22. 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.
23. Under the PSWG's recommendation, an MSP could self-certify Class 1, 2 and 3 meter workers once the MSP's meter worker training certification program was approved by the Commission, and the meter worker met the appropriate prerequisites.
24. Under the PSWG's recommendation, in order to be certified as a Class 4a, 4b or 5 meter worker, the applicant must pass a written and practical exam administered by the Commission or by a designated entity.
25. It is proposed that the initial set of test questions for Class 4a, 4b, or 5, be developed based on the examples described in Attachment D-2 of Appendix D of the Workshop Report.
26. The PSWG recommends that the Commission designate the MWCO as the designated entity to manage the function of certifying the higher skill meter workers.
27. The PSWG envisions that there could be one or more MWCOs.
28. The PSWG recommends that Attachment D-3 of Appendix D of the Workshop Report be used as the application to become a registered MSP.
29. A summary of the meter data security issues is contained in Appendix F of the Workshop Report.
30. The PSWG recommends that the data security issues be addressed by the DQIWG.
31. The recommendation regarding what the PSWG should do in the future is in Appendix E of the Workshop Report.
32. D.97-10-087 adopted the approach that the provisioning of meter services and MDMA services be provided through the UDC or an ESP.
33. D.97-10-087 adopted some interim metering standards and criteria as part of the direct access tariffs that were approved in that decision.
34. D.97-05-040 recognized that the review and development of permanent standards should involve all of the market participants since many of the standards are technical in nature and beyond the expertise of the Commission.
35. The term open architecture was described in D.97-12-048 as an environment where the specifications for interfaces, services, protocols and data formats are vendor-neutral, published, freely available, and agreed upon in an open process under the auspices of a recognized national or international standards body.
36. Open architecture allows interoperability to occur.
37. Interoperability refers to the creation of specifications which allows dissimilar devices or systems to communicate with each other in a way that is transparent to users.
38. Requiring specific technologies to be used would tie the hands of meter manufacturers and could lead to a situation where a meter meets the California standards but could not be used outside the state.
39. The Infrastructure Report stated that state policy should not dictate specific technologies to deliver advanced telecommunications, nor select specific firms that will be responsible for infrastructure development.
40. Many of the same concerns that were expressed in the Infrastructure Report apply to the direct access electricity market as well.
41. The opening of electricity markets to direct access has resulted in technological changes and advancements.
42. The permanent meter and meter data standards should not be incorporated into a General Order at this time.
43. When the Commission moved to unbundle metering services in D.97-05-039, many of the participants thought that open platform standards could be developed within several months.
44. The interim standards for direct access meters required the meters to meet at least one of four criteria.
45. The definition of "meter product" appears in Appendix A of the Workshop Report.
46. The Energy Division needs to develop procedures for accepting and reviewing the meter type self-certification document that will be submitted by the meter product manufacturers.
47. It is incumbent upon the meter product manufacturers, the UDCs, and the ESPs to ensure that the meter product standards have been adhered to.
48. Data security issues will be addressed in a decision which addresses the recommendations of the DQIWG.
49. Meter product manufacturers should be free to use other kinds of optical ports besides a Type 2 optical port.
50. If a Type 2 optical port is used, then the port must meet the C12.18 standard.
51. The debate over the C12.19 standard was the most contested issue with the least consensus.
52. The 12.21 and 12.22 standards have not yet been approved by ANSI.
53. Convenience features, such as remote meter reading capability, are insufficient justification to mandate that the feature become a permanent standard.
54. Billing on a kWh basis may not be the universal billing unit.
55. Stored meter data refers to any meter data stored by the meter.
56. Since the subcontracting issue affects the metering and data management framework that was established in D.97-10-087 and D.97-12-048, this issue should be resolved in a future decision.
57. The monthly meter read requirement, and the MDMA safety requirements should be retained as part of the permanent standards.
58. An instant cut-over from MEP to EDI is unlikely to take place.
59. The Commission should refrain from adopting permanent EDI standards until after the EDI report and comments have been filed.
60. The high/low usage check allows the use of two different methods to validate kWh consumption.
61. There is disagreement on the type of entity that should be established to design and administer the tests for the higher skilled meter worker classes over the long term.
62. As a result of restructuring and the unbundling of products and related services, new entities have been created, and the Commission has redefined its role in the restructured marketplace.
63. An entity should address testing and certification of meter workers.
64. The UDCs receive notice of any meter installation work to be performed as a result of the rules adopted in D.97-10-087.
65. An entity that receives input from interested market participants regarding the design and administration of meter worker tests will help ensure uniform and consistent testing procedures.
1. The Commission should not dictate what kind of specific technologies must be used for meters and meter data.
2. If the Commission adopts standards which are too narrow in scope, there is a danger that other technological innovations will render the standards obsolete.
3. The Commission's approach to permanent standards should be one of open architecture that provides opportunities for all market competitors on an equal basis.
4. The permanent standards must ensure the continuing safety , accuracy and reliability of the meters and the meter data.
5. All of the provisions which appear in the appendices to the Workshop Report, and which were discussed in this decision and adopted as permanent standards, are incorporated by reference into the permanent standards.
6. The Energy Division should be given access to all backup documentation that is related to the certification testing requirements for the meter type that the manufacturer is certifying.
7. Since government standards are not voluntary, they should only be adopted after careful consideration, and only when the public interest demands such action.
8. The Direct Access Tariff Review Committee should develop and file a proposed statewide implementation guide for the use of EDI.
9. The UDCs, ESPs, and MDMAs are directed to move toward using EDI to transfer meter usage information in accordance with the schedule described in this decision.
10. A workshop should be held to determine the interest in working on some additional VEE issues.
11. Instead of establishing an interim process to design and administer the meter worker tests, the same kind of safeguards can be implemented using the framework of the interim standards, adopting portions of the meter worker recommendations, and placing the burden on the ESP to prove to the UDC that the MSP is capable of performing meter work in the various classes.
12. The Commission should further research whether the Commission or some other state agency can conduct the testing and certification activities.
13. The "detailed work schedule" should contain the information described in the text of this decision.
14. The Commission should adopt the provisions shown in Attachments A, B, C, and D of this decision as the permanent meter and meter data standards.
IT IS ORDERED that:
1. The Commission adopts as the permanent meter and meter data standards those items which are summarized in Attachments A, B, C, and D of this decision, and which reference the specific passages in prior Commission decisions, and in the appendices to the Permanent Standards Working Group's (PSWG) report that is entitled "Permanent Standards For Metering And Meter Data Used In Direct Access" (Workshop Report).
a. All of the investor-owned electrical corporations, electric service providers (ESPs), meter data management agents (MDMAs), meter service providers (MSPs), and meter product manufacturers, shall comply with all applicable standards which affect the product or services that they offer.
b. The investor-owned electrical corporations are authorized to submit advice letters to make any necessary changes to their direct access tariff provisions as a result of this decision.
(1) The advice letter shall be filed with the Energy Division within 30 days from today's date.
(2) Any protests to the advice letter shall be filed with the Energy Division within 20 days of such filing.
(3) The effective date of the advice letter shall be the 40th day after the filing of the advice letter.
c. Should it be necessary, the assigned Administrative Law Judge (ALJ) may issue a ruling which gathers all of the different references to the permanent standards mentioned in Attachments A-D, and to place all of the standards into one document.
2. Except as provided for below, effective 120 days from today, all direct access meter products shall meet the requirements set forth in Attachment A in accordance with the timetable set out at page 1 of Appendix A of the Workshop Report.
a. MSPs may continue to offer for the next 120 days, direct access meters which meet at least one of the four meter criteria that are set forth in Decision (D.) 97-12-048 at pages 14 and 15. After 120 days from today, all meter products used in direct access shall meet the permanent meter product standards that are summarized in Attachment A of this decision.
b. Direct access meters which only meet the interim standards adopted in D.97-12-048, shall be retired from service no later than June 30, 2002.
3. All direct access meter products which meet the permanent meter product standards shall be self-certified by the meter product manufacturers in accordance with the procedures described below.
a. The certification testing requirements shall follow the procedures set forth in Section II of Appendix A of the Workshop Report.
b. The meter product manufacturers shall complete the self-certification form that is to be developed by the Commission's Energy Division. The form states, in essence, that the meter product type has met the certification testing requirements. The meter product manufacturers are to submit the form, together with any required documents, to the Energy Division.
4. The Energy Division is directed to develop the appropriate forms, procedures, and criteria for accepting and reviewing the meter type self-certification form, and for posting the complying meter types on the Commission's web site.
a. The Energy Division shall determine how the self-certification form should be phrased, and whether any supporting documents should accompany the self-certification form at the time of submission. Phrasing of the form shall include the declaration language discussed in the text of this decision.
b. The Energy Division shall have 90 days from today to develop the procedures described above, and to make those procedures available to all interested persons after the 90 days has elapsed.
5. The five meter worker classes, summarized in Attachment D, shall be used to classify the ability of the meter workers.
a. As an interim measure, should a utility distribution company (UDC) question the ability of an MSP to work on a particular kind of meter, the burden will be on the ESP to show that the MSP it is using possesses the necessary skills and experience to perform that kind of meter work.
b. The Commission will explore if it or some other state agency can conduct the testing and certification activities.
6. The UDCs, ESPs, and MDMAs shall take the initiative, in accordance with the schedule discussed in the text of this decision, to move toward using Electronic Data Interchange (EDI) standards to transfer meter usage information.
a. To ensure that this initiative is implemented, the Energy Division shall confer with the Direct Access Tariff Review Committee, and ensure that the Committee files an EDI report which contains a proposed statewide implementation guide for the use of EDI.
(1) This EDI report shall be filed and served no later than April 2, 1999, and shall contain a proposed implementation guide.
(2) Interested parties may file comments within 21 days of the filing date of the workshop report.
7. The Energy Division shall convene a workshop within 90 days from today to determine whether there is an interest to pursue the additional tasks mentioned in the discussion of the validating, editing and estimating rules.
a. A workshop report shall be filed and served no later than 60 days after the conclusion of the workshop.
b. Interested parties may file comments within 21 days of the filing date of the workshop report.
This order is effective today.
Dated December 17, 1998, at San Francisco, California.
RICHARD A. BILAS
President
P. GREGORY CONLON
JESSIE J. KNIGHT, JR.
HENRY M. DUQUE
JOSIAH L. NEEPER
Commissioners
8 We also incorporate by reference all of the other provisions in the appendices to the Workshop Report that we have adopted in this decision.
9 The Workshop Report defines a meter product as: "A device which measures, calculates, records and/or communicates energy consumption data for the purpose of determining the financial obligation for an entity consuming energy. Shall include any optional circuit boards, devices, or modules enclosed within the meter cover." (Workshop Report, App. A, p. 1.)
10 Some of the parties did address the grandfather exemption that the majority of the PSWG members recommended be adopted as part of the ANSI C12.19 recommendation.
11 The web page which lists the meters that are in compliance with the meter product standards shall also contain a description of how meters which meet the interim standards set forth in D.97-12-048 can be used.
12 SCE's comments to the Workshop Report state that non-socket based meters should be prohibited until nationally recognized standards exist for these kinds of meters. We believe that the meter product standards in Attachment A, and the market participants, will ensure that non-socket based meters meet all necessary safety, reliability, and accuracy standards.
13 The plug and play argument is one of the reasons why the proponents favor the C12.19 standard.
14 The C12.21 specification is referred to as the protocol specification for telephone modems, and the C12.22 specification is referred to as the meter interface to network protocol gateway.
15 We understand that this Committee is actively involved in addressing EDI issues.
16 Everyone appears to agree that an interim group should be formed using volunteers from the UDCs and MSPs who have already been permanently certified. This interim group would be responsible for the design and administration of tests for the higher skilled meter worker classes until the Commission or a designated entity could take over this effort.
17 One agency that comes to mind is the Contractors' State License Board. However, its present licensing role would probably need to be expanded to accommodate the testing and certification of meter workers.
18 The first four subdivisions in each of the meter worker classes are: (1) metering types and voltages; (2) work to be performed; (3) essential technical skills; and (4) worker safety and safety equipment.
19 Proof that an MSP is capable of performing meter work for a particular meter type could come from utilizing some of the criteria that are found in the subdivisions for the meter classes which are entitled: "Worker Qualification: How Essential Technical and Safety Skills Are Determined" and from "Experience Requirements." Other criteria that demonstrate that the MSP has employees who are qualified or possess the experience necessary to work on a particular meter type are acceptable as well.
