Customer Information Activities

Points Offered for Discussion:

1. "Customer Information Activities" specified as:
   Customer-specific Metering, include. Meter Maintenance

   Customer-specific Data Communication

   Customer-specific Records Management

   Customer-specific Service Operations, include. Billing & Payments

2. Customer Information Activities should be at least partially unbundled from UDC operating activities.
   Customer-based information is the core attribute of Retailing.

   Distinguished from network-based information, relative to utility distribution operations.

   Fully Unbundled Customer Information Activities...

   May not be feasible by 1998 . . . Very likely feasible by 2003.
   Presumed feasibility/infeasibility should not be the basis for instituting any impediments to unbundling.

   Partially or incrementally unbundled Customer Information Activities should not be a problem:

   So long as unbundling process is driven by Customer Choices.

3. Customer Information Activities should be competitively distributed.
   There is no reason to require a monopoly in these areas.
   The economies of scale which may exist for some AMR, etc., Customer-service systems are not so great as to imply a "natural monopoly".

4. Customers should exercise Choice in Customer Information Activities through competitive negotiation with Retailer.

   1. The Customer should have absolute choice of their Retailer, from among those offering to serve.
      "Aggregator" is another name for Retailer.

   2. The Chosen Retailer, whether Aggregator or legacy UDC, should control Customer Information Activities.
      Retailers should be required to offer non-discriminatory tariffs.

      "Deals" embodied in tariffs should be operationally-based.

      Retail service should be equally-available to all similarly-situated potential customers.

      There should be no reason that new customers should not have to bear any Customer Information Activity capacity-expansion costs, etc.

      CPUC should control "cherry-picking" and prevent "redlining".

5. Metering Standards

   1. Existing Safety & Reliability Standards should be maintained.

   2. Retailers should have option to buy UDC meters at book value.

      "Buy" decision uniform across system, not site specific.

      UDC should be indifferent.

   3. UDC should remain responsible for installation and maintenance of CTs and PTs.

      Calibration, performance, and maintenance of CTs & PTs is independent of that of meters.

   4. Consider: Reassigning CTs and PTs from Meter Equipment to Service Lateral Equipment

      Investigation of meter would remain primary response in case of HBIs.

      CPUC should adopt service-meter interface standards to limit the combinations of voltages and current ranges meter inventories must accommodate.

      Could reduce meter handling to "appliance" status.

   5. Installation of Real-time Meters is a private matter concerning only a Customer and that Customer's Retailer.

      Retailers who desire to offer Real-Time Rates must offer Real-Time Metering.

      Customers who desire to take Real-Time Rates must accept Real-Time Meters.

      Cost-sharing should be negotiated between Customer and Retailer.

6. Data Communication Standards
   CPUC should adopt Open Systems Interconnection reference model.

   See accompanying paper by Jim Price.

7. Records Management Standards

   1. Customer Data should be owned by the Customer.

      Retailer should be construed as Records Management Agent for Customer.

      No transfer of Customer-specific data without free consent of customer.

      Standards for "Non-Customer-specific" data could follow EDD-, BLS-, Census-, etc., type Standards.

   2. Retailer and Distributor should be entitled to fair use of reasonably necessary information.

      No limit on development of Non-Customer-specific data for internal operational planning and control.

      UDC data kept by service location, without Customer-specific ID, could be considered Non-Customer-specific data.

      CPUC should have full and ready access to any data kept by UDC.

   3. Retailer should not be allowed to require additional information as a condition of service.

      Efficient access to electric power should not be hindered or burdened by exploitative marketing practices.

      Retailer may offer Customer optional transactions for additional information rights.

      No limit on development of Customer-specific data for Customer service purposes.

   4. CPUC should establish standards for Customer-specific Records Retention by Retailers.

      Suggested for discussion:

      2 years for RTM and TOU data

      7 years for billing and payment data.

   5. CPUC should establish standards for Operational Data Transfer by Retailers to UDCs.
      UDCs should perhaps receive/maintain data by service location only, no "Customer" specific information.

      CPUC should perhaps establish requirement for barrier between UDC data and data held by legacy UDC Retail operations.

      Cross-subsidization between retail and distribution must be precluded.

8. Billing & Payment Standards
   To be determined.