Suggested Principles for Meter Standards

To: Interested Parties

Fr: Chris S. King

As we begin our discussion of meter standards, I thought it might help to
establish a set of principles. First, after a careful review of the
Unbundling and Direct Access decisions, I believe the Commission is
adopting metering standards for two reasons.

The first reason, clearly stated in the Unbundling decision, is to prevent
meters from becoming a barrier to competition, specifically through causing
an obstacle to customer switching.

The second reason is to create an open platform that results in innovation
and diversity and is interoperable.

Based on the Decisions, I have drafted some principles, mostly Mom and
Apple Pie, that should help guide us. I would appreciate any thoughts you
might have on these (thanks!):

Proposed Principles

General:
        1.      Existing, applicable standards should be used if available,
such as CPUC and ANSI.
        2.      Standards should not exclude any existing technologies that
meet relevant ANSI standards and the other minimum requirements of this
standard.
        3.      Standards should ensure safety, reliability, and accuracy.
        4.      Standards should focus on minimum requirements, with
reasonable consideration for obsolescence (i.e., allow for innovation
beyond the minimum requirement). Standards should not go beyond what the
CPUC has asked for in its Direct Access and Unbundling decisions.
        5.      Market participants - UDCs, ESPs, and customers - should
have maximum flexibility in selection of metering systems.
        6.      Standards must allow for technological innovation.
        7.      Standards should promote competition in provision of
metering systems and metering system elements.
        8.      Customers should be able to switch electric suppliers
without changing meters, except that UDC-served customers with peak loads
exceeding 20 kW and who have meters that cannot currently record hourly
consumption must switch to a meter or retrofit device that can record
hourly consumption.
        9.      Customers should have the right to add a retrofit device to
their existing meter, provided the metering system that incorporates that
device meets these standards. Installation of such retrofit devices would
be subject to the meter installation standards adopted by the CPUC in
D-97-05-040 (i.e., competitive installation above 20 kW in 1998, by UDC for
small customers in 1998, competitive for all customers in 1999, and with
installation standards to be specified by the UDCs).
        10.     Metering system elements - communications systems, meters,
and head-end databases - must be interoperable, which means that for a
given communications system, for example, the user should not be locked
into a particular head-end database or a meter device that can be obtained
from only one supplier/manufacturer.

Communications:
        1.      All market participants should have non-discriminatory
access to a base level of services from any metering and data
communications system, including manual meter reading.
        2.      Standards must allow the use of multiple communications
media to collect metering data.

Safety, Accuracy and Reliability:
        1.      Standards must ensure accurate and reliable recording of
usage information, plus timely retrieval of the data.
        2.      All metering systems must pass certification tests prior to
being accepted for use.
        3.      All metering systems must be subjected to ongoing testing
and monitoring to ensure continuing accuracy and reliability.
Functionality:
        1.      Metering systems must deliver a minimum level of
functionality, but there is no restriction on maximum functionality.
        2.      The minimum level of functionality for a metering system is
the collection of sufficient data to enable customer billing, the ability
to retrieve this data from the meter in a timely fashion, and some means of
making this data available to the customer.
        3.      Any metering device installed after the adoption by the
CPUC of these standards should be capable of either of the following:
                *       Delivering the preferred market level of
functionality specified in the DAWG report of hourly data retrieved daily
OR
                *       Delivering a lesser level of functionality (e.g.
hourly data retrieved monthly  or monthly data retrieved monthly) but
having the capability of being upgraded to be able to deliver hourly data
daily without requiring removal of the meter from its socket at the
customer's site (e.g., reprogramming the meter, adding an external
recorder, additional remote processing of the data - such as converting
five-minute interval data to hourly data - or other means as may be
invented in the marketplace)
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