FirstPoint Comments on MDCS WorkShop

Comments from FirstPoint Utility Solutions

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--Conrad Eustis
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Comments of FirstPoint Utility Solutions on MDCS Workshop Report



RE: I.B.3, I.B.4, IV.B.2.a(i), & V.B 

Many locations in the document make reference to requiring UDC standards (for lack of a

national standard).  This is especially apparent in Tables 1 & 2 of this section.  Unspecified

(meaning lacking the definition for any 2 parties to come to the same conclusion as to meaning,

location of documentation, etc.) UDC standards are unacceptable because they give too much

power to the UDC to decide after the fact what is reasonable.  Many locations of the document

refer to certifications, contracts, and agreements, some which have been recently posted, some

which are not yet available.  By definition, these documents could impose additional requirements

when in fact they should only echo requirements of the MDCS, RSIF & DAI reports which have

come under a reasonable amount of review.  We have concerns about non-definitive requirements



FirstPoint does not contest the motive or concept behind these standards.  We object to the

process that accepts for granted the "legacy" of UDCs' current practices.  In general, the UDC

proposal seems overly restrictive with substantial cost burdens for documentation and reporting. 

By contrast consider the standards covering the gasoline pump, another meter that governs the

sale of a different  $20 billion dollar commodity in California.  Electric meters by comparison are

more accurate and  less prone to tampering.  All in all, the gasoline meter survives in the free

market with much less regulation around operations and testing than the UDC's proposal.



A public process should be set up to achieve final agreement, but in the mean time, the

overarching principle of MDCS standards should be delivery of accurate meter data to parties

with a need for this information.  Absent a set of  auditing and enforcement procedures, all of the

non-specific UDC standards in the MDCS document should be taken as guidelines for would-be

meter service providers.  MSP's can then, demonstrate in their certification process that they

employ some percent of experienced workers in their workforce and management.



As a consequence the wording for I.C.5.a should restate for meter installation, maintenance, and

testing to use Section VII.B as guideline for prudent operation.



RE: I.C.5.d, together with timing requirements of VI.B.3.c and  VI.B.3.d

These timing requirements create a barrier to entry for alternative meter service providers and

must be accelerated.  To wit: customers wishing to switch to direct access as soon as possible will

use the UDC metering services in order to avoid delay.  Since new IDR meters must be installed

by the UDC a metering service agreement must be established.  For example SCE's proposed

tariff at Rule 2, J.5.c.(1) state an obligation to pay on that meter for a minimum of ten years.



RE: III.B.4.a(i)

"As a result, meters that provide 15 minute interval data will meet a majority of these needs and

are recommended."  Need to clarify that this is not a requirement.



RE: V.B.1.a.(i)(b), V.B.2.a.(v)(a), V.B.2.c.(ii)

For these and other similar instances, clarify that if UDCs and/or customers who wish to exercise

these options will do so at their expense and according to the Metering Agent's schedule.



RE: V.B.1.a.(i)(b)

As example, this section seems to imply a requirement that applies to every meter, when what is

meant is a new meter design or each model.  Text should be clarified at this instance and similar

examples in Section V.B.1.



RE: V.B.1.e.(vii)(b)

The last sentence should be deleted or parity created to allow ESPs to remove UDC meters under

the same terms.



RE: V.B.1.f.(i)

"Must provide evidence of... compliance" This is vague, I propose something like: each meter

agent will keep on file, certification from their meter supplier (for each meter in their operating

inventory) that the meter design meets the requirements of Appendix A.



RE: V.B.1.a.(vi)

This passage should clarify this is a summary report to CPUC submitted by all meter agents,

including the UDC.



RE: V.B.1.i(i)

"local UDC published...requirements" This raise a generic point that ESPs, MDMA, Billing

Agents, Meter Agents, etc. create a new class of relationships.  Just as we create purchasing

department to deal with vendors and customer service reps to deal with end-users, so UDCs

should be proactive and create a small office to deal with direct access market participants.  When

such an office is created it will provide a single point of contact, so that market participants can

obtain a current set of all regulated tariffs regarding direct access procedures.



RE: V.B.2.a.(iii)(a)

Inspection reports must be made available to ESPs as well.



RE: V.B.2.b.(i)

Meter numbers are only needed for audit purposes and need not be unique, IF the greater need, 

creating unique "Service Delivery Point" (SDP)  identifier system, is met. See FirstPoint Utility

Solutions comments for Retail Settlement Workshop Report..



RE: V.B.2.b.(i)(a)

Not reasonable-- why must new commerce be restricted by antiquated system requirements?



RE: V.B.2.b.(iii)(a)

A separate SDG&E requirement is not justified.  It is not clear why this info must be supplied any

sooner than within 5 days.



RE: V.B.2.c.(ii)

Penalties for failure to perform should not be stated here, but rather in a comprehensive, but not

yet created, document which governs all audit and enforcement  requirements.



RE: V.B.2.c.(iii)(b)

Initially, the frequency should be set only by the ANSI requirement.



RE: V.B.2.c.(iv),V.B.2.c.(vi)-(last sentence, only)

Examples, of unwarranted reporting to UDC.  The cost to prepare duplicate copies, cost of

transmittal, cost by UDC to accept and process-- all unacceptable.  The audit process will access

to this information.



RE: V.B.2.c.(viii)

What documentation is called for here?  Is this simply a transaction following up a meter change. 

This is only the third of a four part transaction required to change meters.  This 4-part transaction

has been noted in the  RSIF transaction process subgroup task force specifications.



RE: V.B.2.e.(iv)

Vague.  After reporting, what documentation is expect here? The report is the document.



RE: V.B.2.e.(v)

Responsibility for correcting diversion in the case of customer premise wiring alterations should

belong to the ESP serving the customer.



RE: V.B.3.a.1(i)

48 hours is too restrictive and is not a least cost approach.  That is, the carrying costs of an idle

meter for 5 working days are less the requirement imposed by requiring a premium paid to ensure

2 day return of the meter.



RE: V.C.1.a

The state certification requirement is reasonable but should be required for UDC meter service

workers also and in any case it should not be required 1/1/98.  Propose: all meter service workers

should have certification within a year after certification process is formally defined.



RE: VI.B.2.a

Prefer CellNet proposal.



RE: VI.B.3.e

Too excessive.  Small changes should either not require acceptance test or all small changes

should be accumulated and then certified on an annual basis.



RE: VI.C.1.a, VI.C.2.a

Need to create economic parity.  These say UDCs incur no new costs but new meter service

providers does.



RE: VII.B.1.a RE the CCES: bullet.

FirstPoint submitted this to CCES.  The intent is that an accurate statistical process to smooth

missing interval data, if it meets, this requirement, can be posted as actual data. (The next

paragraph in the CCES submittal makes the "actual" basis clear.  I.e data not meeting this

requirement of smoothing lost interval data must be reported as estimated.)  There was a further

requirement that 98% accuracy only applies to a month period.  A further requirement is

necessary that the statistical process, or longer periods must not show a sustained plus or minus

bias greater than 0.3%.  (This is to match the quality of raw meter data.)



RE: VII.B.10 

FirstPoint believes that EDI, ANSI x.12 transaction set 867 should be acceptable method for an

MDMA to receive and submit meter data for specific metered accounts.



RE: VII.B.12.c

If the above CCES requirement is not incorporated, then the 10% requirement needs to be

restated.  For monthly meter interval data estimating as much as 10% of the accounts is very

lenient.  But for interval data, particularly for meters read with radio protocols, to miss 1 interval

out of 720 hourly intervals is not the same impact as missing 1 monthly interval out of 1 attempt.



A more reasonable interval requirement would be that no more that 2% of all interval data should

be estimated, but this requirement should apply in the aggregate not account by account.