A Proposal Regarding Customer Information Activities
Draft Circulated July 1, 1996
Revision 1, July 10, 1996
Sponsored by Anthony Mazy, CPUC/DRA
While Direct Access makes Electric Service competitive and, therefore, an appropriate subject for market-determined rates, Electric Service continues to be an essential service and "affected with a public interest".
Since Customers have little choice but to take Electric Service from some entity, they should not be required to give up any data, nor tolerate the development of information by others, as a precondition for receiving Electric Service, except what is absolutely necessary for the safe and reliable operations of the electric system, including reasonable credit standards. Customers must be provided the maximum level of control over Customer-specific Data and Information: they must "own" it.
Electric Service Providers must be able to create and use various data and information in the normal course of their operations. To the extent that the efficacy and efficiency of their primary operations depends upon the quality of the data they acquire and the information they develop and incorporate in their operating systems, Electric Service Providers must have maximum control over the information upon which their business is based: they must be able to own it.
Electric Service Providers should not be allowed to base their primary operations upon inappropriate use of privileged data or information, nor allow any secondary use of any privileged data or information.
Customer-based information, developed from customer-specific data, is the essence of Marketing and the core activity of a Retailing operation. This is to be distinguished from the network-based information of utility distribution operations.
While fully unbundled Customer Information Activities may not be practical by 1/1/98, they are almost certainly partly feasible even then and fully achievable by 2003.
There is no reason to maintain or institute a monopoly in these areas.
The Customer should have an absolute right to choose their Electric Service Provider, from among those willing to serve.
The chosen Electric Service Provider, whether a Generator, an Aggregator, a Retailer, or the legacy Utility, should be the manager of the Metering and Communications systems.
Retailers should have the option to acquire Utility metering equipment at book value; the Utility should be indifferent.
The CPUC should adopt service-meter interface standards to limit the combinations of rated voltage and current range that meter inventories would have to accommodate. The Utility should remain responsible for the installation and maintenance of current transformers (CTs) and potential transformers (PTs) for metering purposes; this may involve reclassifying CTs and PTs from Metering Equipment to Service Lateral Equipment. This could reduce meter handling to "appliance" status. In case of Customers' High Bill Inquiries (HBIs), an inspection or testing of the meter would remain the primary response.
All ESPs should be required to offer publicly-supervised Terms and Conditions of service. Where the Terms and Conditions of Utility service are expressed in filed and regulated Tariff which include Rate regulation, the Terms and Conditions of Market Service would not include Rate regulation and should be called Standard Contracts to emphasize the difference.
Electric Service, by any ESP, should be equally-available to all similarly-situated potential customers. The CPUC has an interest in controlling "cherry-picking" and preventing "redlining". This would not prevent Customers from bearing the appropriate costs of capacity expansion for relevant Customer Information Activities.
See Appendix for proposed definitions.
The essential requirement for any Customer desiring Physical Direct Access to the market for Electric Service is an Electric Service Provider, i.e. a Seller (whether a Generator or a Merchant), with whom the Customer can enter into a Direct Access transaction.
As a practical matter, Direct Access to the hourly Power Exchange or to any Electric Service requiring Transmission Service from the ISO, requires Real-Time Metering.
Unless Direct Access is limited to Transmission-level Customers, any Utility must provide unbundled Distribution Service.
The essential requirement for any Utility Customer desiring Virtual Direct Access to the electric supply market is a unencumbered choice of Rate options, including Average Use, Time-of-Use, and Real-time pricing schemes.
Unless there are reasons to limit a Customer to a single Provider, Customers should be able to make whatever arrangements they can for their Electric Service requirements. To prevent a Utility from inhibiting Customers from taking alternate sources of power, the Utility should be required to offer a Tariff for Partial Requirements.
We should explicitly call out any constraints imposed upon the Metering & Communications component, other than those which are implicit in providing Physical/Virtual DA.
The Open System alternative is described at length in the accompanying CPUC paper sponsored by Jim Price.
The installation of Real-time meters should be a private matter concerning only a Customer and that customer's retailer.
The direct cost of the Open System alternative for Metering and Communications would be allocated among parties by market forces. Ultimately, of course, Customers pay all costs of service. Under an Open System alternative, the actual cost of the Metering and Communication systems would remain a regulated cost for a Utility, but would be proprietary to a Non-utility Provider. That portion of the cost which would be borne directly by any Customer would be expressed in the Terms and Conditions of the service..
Metering and Communication equipment should be controlled by the party which can operate and maintain that equipment effectively and in the most efficient manner. The Customer, the ESP, the UDC, and the public-at-large all have an interest in the equipment's effective operation; so Standards are necessary to insure that all parties' legitimate interests are protected. Efficiency will be given the greatest attention by the party which stands to lose the most from the inefficient operation of that equipment. In a regulated-rate environment, that would most likely be the monopoly UDC; but in a competitive environment this will, ultimately, be the end user. For site- (or, customer-) specific equipment, that would be the Customer; for upstream, i.e., non-customer-specific, equipment, that would be the ESP. Control does not necessarily mean ownership, but it does mean the power to chose whether to rent or to own. The Customer should have the right to elect ownership or rental/lease of site-specific equipment and the ESP should hold the residual right to elect ownership or rental/lease of the remainder of the system.
Consistent with end-user control of the equipment selection, the Market will be expected to supply adequate quantities of equipment meeting appropriate Standards. Any transition period, required for the market to tool-up for necessary production, is expected to be negligible.
Meters usually require little maintenance. Nevertheless, the owner of the equipment would be responsible for maintenance and repair.
Questionable meters could be tested any time at the expense of the party which questions its accuracy. If found out-of-tolerance, meter testing and repair or replacement costs would accrue to the Owner.
Appropriate quality standards would be required for meter maintenance and repair operations.
Appropriate standards would be required for the safety and reliability of metering operations. A Service-Meter Interface Standard would help ensure the safety and reliability of meter installation, maintenance, and repair operations.
Under an Open System, meter reading routines are established by Standard Contract between Customers and ESPs. The ESP would have the responsibility to insure Open System Connectivity, whether manual or automated, with Utility and ISO systems.
The ESP would be responsible for maintaining the Customer Account, informing the Utility that it was servicing particular Service Laterals.
ESPs should be construed as Records Management agent for Customer-specific and Network-specific data.
Customer owns Customer-specific data: ESP should not transfer Customer-specific data without willing consent of Customer.
Utility owns Network-specific data: ESP should not transfer Network-specific information without willing consent of Utility.
The ESP and Utility should have fair use of all reasonably necessary data for safe, reliable, and economic operation of their marketing and distribution systems, respectively.
There would be no limits on development of Non-Customer-specific data for internal operational planning and control.
Utility data kept by service location, without a designation as to a specific customer, would be considered Non-Customer-specific data.
The CPUC should continue to have full and ready access to any pertinent data kept by Utilities.
The CPUC would have much more limited access to data kept by Retailers: perhaps just Metering and Billing practices.
Retailers should not be allowed to require additional information, beyond standard requirements, as a condition of service. Efficient access to Electric Service should not be hindered or burdened by exploitative marketing practices.
The ESP would be the contact point for Customer inquiries or complaints relating to the metering or billing for their service.
Utilities would remain liable for processing public inquiries relating to distribution safety.
APPENDIX . . . PROPOSED DEFINITONS
For purposes of development, terms are arranged by concept, so that appropriately related specifications can be managed. When a final list of needed defined terms is complete, the list should be rearranged alphabetically.
"Customer" should be understood as an Electric Service Customer, unless otherwise specified. See also Transmission Service Customer, Distribution Service Customer, Ancillary Services Customer, etc.
"Electric Service Customer" should be understood as any entity which receives Electric Service from another.
"Utility Customer" should be understood as any Customer who receives any portion of their Electric Service from the Utility.
"Exclusive Utility Customer" should be understood as any Customer who receives all of their Electric Service from the Utility.
"Market Customer" should be understood as any Customer who receives any portion of their Electric Service from any entity other than the Utility.
"Retail Customer" should be understood as any Customer which buys its Electric Service through an intermediary, whether a Utility or a Non-utility Provider.
"Wholesale Customer" should be understood as any Customer who receives any portion of its Electric Service directly from either the Exchange or , via Bilateral Contract, a Generator.
"Bilateral Contract Customer" should be understood as any Customer who receives any portion of its Electric Service directly from a Generator.
"Non-utility Customer" should be understood as any Customer who buys all of their Electric Service from Non-utility Providers.
"Generator" should be understood as a Generation Service Provider.
"Provider" should be understood as an Electric Service Provider, unless otherwise specified.
"Generation Service Provider" should be understood as any entity which produces electric energy or real power for sale.
"Transmission Service Provider" should be understood as any entity which provides federally-regulated interstate transmission service; in California, this will be the Independent System Operator.
"Electric Service Provider", or ESP, should be understood as any entity which provides Electric Service to another. ESPs should be understood to include Non-utility Providers and Utilities. See also Transmission Service Provider, Distribution Service Provider, Ancillary Service Provider, etc.
"Utility Electric Service Provider" should be understood as that portion of a Utility which provides Electric Service, as distinguished from that part which provides Distribution Service.
"Utility" should be understood as Utility Distribution Company unless otherwise specified.
"Utility Distribution Company", or UDC, should be understood as the entity providing, primarily, Distribution Service and, secondarily, Electric Service, under authority of the CPUC in a specified service area.
"Non-utility Electric Service Provider" should be understood as any Provider other than the Utility, comprising both Retail ESPs and Bilateral Contract ESPs.
"Retail Electric Service Provider" should be understood as any entity which provides, directly to Customers, Electric Service produced by others.
"Wholesale Electric Service Provider" should be understood as any entity which provides Electric Service to Retail ESPs or any Generator which provides Electric Service directly to Customers without the services of a Retail ESP.
"Metering Entity" should be understood as the party which actually performs Metering, whether it be the Electric Service Provider or the ESP's agent.
"Aggregator" should be understood as simply any Non-utility Provider which serves more than one Customer.
"Bilateral Contractor" should be understood as either the single Customer or the single Non-utility Electric Service Provider which have contracted bilaterally for the sale and purchase electric service between themselves.
"Service" should be understood as Electric Service, unless otherwise specified. See also Transmission Service, Distribution Service, Ancillary Service, etc.
"Transmission Service" should be understood as the coordination and physical delivery of electric energy and/or real power over federally-regulated interstate transmission lines.
"Distribution Service" should be understood as Local Transmission and Distribution Service, unless otherwise specified.
"Local Transmission and Distribution Service" should be understood as providing the plant and operations for the physical delivery of electric energy and/or real power by UDCs over state-regulated intrastate transmission and distribution lines. See "Distribution Service".
"Ancillary Services" should be understood as any of the outputs of a generation facility, other than energy or real power, which are necessary for to facilitate the stable, reliable, and economic transmission of that energy or real power to its intended load.
"Electric Service" should be understood as the provision of electric energy and/or real power, together with the Marketing of that service, under publicly-supervised Terms and Conditions. "Electric Service" should be understood as comprising Supply Service and Customer Service.
"Marketing" should be understood as all of the activities which facilitate the interaction of a Provider with a Customer: the specification of Electric Service in terms relevant to Customers' requirements; the establishment of Tariff prices and other Terms and Conditions of sale; the Communication between Provider and Customers, concerning their mutual identification and definition, that Electric Service itself, those Tariff prices and other Terms and Conditions, and the establishment and documentation of transactions, i.e., Service Establishment and Billing; and the actual Distribution of Electric Service to Customers, including the verification of quantities delivered, i.e., Metering .
"Supply Service" should be understood as comprising any Non-customer-specific Activity related to establishing adequate Generation for Customer load, together with facilitating the Distribution of that Generation to Customers, irrespective of what Utility actually perform those Distribution Services.
"Customer Service" should be understood as comprising any Customer-specific Activity, and should normally comprise all customer-specific activities, whether they be generation, transmission, distribution, , power conditioning, metering, billing, credit, collections, or any information services.
"Market Electric Service" should be understood as the provision of Electric Service by a Non-utility Provider, under the terms and condition of a Standard Contract, but at market rates. Market Electric Service should be generally open to any operationally- similarly-situated takers.
"Utility Electric Service", or UES, should be understood as the provision of Electric Service by the Utility under the terms and conditions of Tariffs, including Rates, filed with the CPUC. Under appropriate tariffs, UES should be universally open to any takers from the Distribution Service Area.
"Terms and Conditions" should be understood to include any public- or consumer-protection provisions deemed appropriate by the CPUC. Terms and Conditions should be expressed in the Tariffs of a Utility and in the Standard Contracts of Non-utility ESPs.
"Tariff" should be understood as a document controlling the provision of Utility Electric Service, including the Rates under which that service is provided.
"Standard Contract" should be understood as a document controlling the provision of Market Electric Service, but not including the Rates under which that service is provided.
"Rate" should be understood as the schedule of prices applying to the Billing Amounts of various components of Electric Service and other services.
"Time-of-Use Metering", or TOU, should be understood as any operational scheme, including necessary equipment, which serves to register a Customer's Billing Amounts according to the time of use, where there is more than one defined Metering Period within the Billing Period. Includes Real-time Metering.
"Metering" should be understood as the process, including any required Meter equipment, by which any part of a Customer's Usage is detected, measured, and/or recorded for Billing or operational purposes.
"Real-time Metering", or RTM, should be understood as a form of Time-of-Use Metering where the Metering Period, or whole multiples of the Metering Period, exactly correspond to the time period, expected to be one clock hour, during which the ISO settles bulk power transmissions. .
"Direct Access" is the means by which Customers are enabled to arrange to receive any part of their Electric Service from entities other than the Utility.
"Average Use" should be understood as applying to any scheme of Metering where the Metering Period equals the Billing Period.
"Bilateral Contract" should be understood as the means by which a single Customer can arrange to receive Electric Service, or other services, directly from a Generator.
"Metering Period" should be understood as the individual time periods wherein uniform rates apply to the usage metered during that period.
"Meter" should be understood as the device which registers a Customer's Billing Amounts according to Metering Periods; it necessarily includes subsystems to measure instantaneous or cumulative Usage Amounts, to detect Metering Periods, and to accumulate Usage measurements into Billing Amounts.
"Service Lateral" should be understood as that portion of a Distribution System which serves a single physical premises, excluding secondary transformers.
"Meter Appliance Interface Standard" should be understood as a technical standard, to be developed, by which Current Transformers and Potential Transformers would be included within the Service Lateral equipment, as necessary, to minimize the number of diverse meter types which any Metering Entity would be required to have in inventory.