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      I would like to respond to several points raised by George Roberts on

behalf of Schlumberger in an effort both to correct several points of fact,

as well as to respond to several matters on which there is clearly room for

differences of viewpoint.  On each point of fact, I will issue a challenge

to any reader who questions my statements.  If I can not back the claim, I

will post a statement of retraction on this website.  If I can, I will ask

the challenger to post a statement supporting my claim on this site.

     Points of Fact are most easily addressed first.

     1. George writes of C12.19 that "No accepted guidelines exist for

their use with telephone based communication nor with radio based

communication."  In my earlier response, I noted that this is not correct 

?

there are standards that can be used today on the telephone network with

the architecture that complies with IEEE 1390, developed over two years ago

at AMRA.  This standard is available for purchase from IEEE or AMRA and can

be ordered through their websites.  The hardware that implements these

standards has been commercially available from most phone companies for

over a year.  If any reader doubts this, please EMail me and I will arrange

to have a salesperson contact you - they welcome the leads.  It is only

necessary to contact your phone company to arrange for the support of this

system.  Alternatively, for those not wishing to use derived local channel

service on the phone network, more conventional modem options, such as ANSI

C12.21 will be available soon.  To move our discussion forward, it is vital

that we settle this matter of fact.  If any reader believes me in error,

please contact me.  I will concede your point in a posting on this website

if I can not arrange a sales call from a phone company offering IEEE 1390

compliant service that can also transport C12.19 tables.  In return, when

you have been offered this service, I will ask you to acknowledge this

point in a posting on this website. However, it does not benefit any of us

to talk past one another on an issue so easily and unequivocally proven..

     2. George quotes Jack Pazdon of GE as stating that the C12.19 tables

are standards "only insofar as they are used in conjunction with optical

ports." I will leave it to Jack to respond as he sees fit.  However, as I

thought I had made clear in my last posting on this website, ANSI C12.19

tables are designed to work with far more than an optical port.  These

tables can provide metering data for ANY utility and over any reasonably

flexibly designed standard communication medium (including telephone, RF,

and most other systems.) These tables were developed both for use with

electric meters on an optical port AND for any other transport medium that

was designed to provide envelope service or an end-to-end clear channel

transmission of data streams. It is vital to recognize that these tables

were designed to handle gas, water, and electric.  As someone whose salary

is paid by the gas industry, I would regard myself for having been remiss

if as Chair of SCC31, I had allowed an optical-port-only or an

electric-meter-only standard to be adopted.  If you believe I am incorrect

on this point, please tell me where I am in error.  I claim that I will be

able to find you a manufacturer willing to move gas and/or water and/or

electric metering data using C12.19 tables over a telephone network or an

RF network.  If I can not deliver, I will so state on this site.  If I am

able to deliver on this challenge, I will ask you to so state on this site.

In either case, I suggest we settle the point and move on.  I apologize for

repeating this comment made in my earlier posting on this site, but it is

critical to move the discussion forward.  The telephone standards are

emphatically not "pending, envisioned, under development, or hypothetical".

These standards have already been implemented in most telephone switches.

I am so confident of this point that I offer the following challenge - I

will withdraw this point and refrain from further argument on it if any

major California metropolitan area can not obtain telephone data transport

using ANSI C12.19 in compliance with IEEE 1390 within 6 months.  The key

point is that the telephone standards already exist and are available

commercially.

     3. George states that no guidelines exist for transporting tables with

RF systems.  This statement is partially true.  Several vendors of existing

systems do tell me that their systems can not transport table date

efficiently; such RF systems can not transport tables at all, unless they

are re-designed extensively. The vendors of these systems are present in

force in the PSWG proceedings, as they should be to represent their

interests. I believe it is essential that their needs be addressed and that

they be given time to make the required system modifications.  (For the

last 8 months, standards committees have been meeting to modify the

existing tables to circumvent these difficulties.  This would allow

virtually ANY RF system to carry tables.  Those who are interested in these

issues are invited to attend the next joint AMRA/ANSI/IC ?Tablefest? in

Montreal, July 20-24.)  However, this is only half of the story. It is also

true that there are many other RF systems that are perfectly capable of

moving table data today.  The suppliers of these general purpose RF packet

networks are not present in the PSWG proceedings because their systems need

no protection.  Like the telephone companies, they are as ready to move

packets containing tables without any need for delay.  I am concerned that

PSWG may base its standards on the capabilities of the least flexible RF

systems, rather than RF systems that have average to good flexibility and

are available today.  How confident am I of my facts?  I will again agree

to stop making this claim and make a public statement of agreement with

your position if I am not able to find at least two RF systems that are

available today that can move packets that carry C12.19 tables.  Any reader

of this posting who wishes to take this opportunity silence my comments on

this issues is welcome to do so. All I ask in exchange is the converse - if

I am able to find two such networks, I ask that my challenger make the

public statement that indeed RF systems are able to carry C12.19 tables..

(I note in passing that the systems that are designed in compliance with

UCA standards will have no difficulty carrying C12.19 tables.)

     With respect to issues of opinion, we both agree that it is in the

interest of the utility customers of California to provide the framework

for a "fluid, dynamic electric market".  Since it has now been decided that

whatever standards are adopted for the electric industry will automatically

become the standards for the gas industry, I share this goal.  However, we

do have a serious difference of opinion on how best to achieve this.  As I

argued in my last posting, standardizing at the MDMA-only level is not the

way to achieve this goal.  There is no point in repeating these arguments,

to which I did not see any direct response.  I argued that standardizing at

the MDMA level seriously restricts the ability of all innovators - except

the existing large meter manufacturers - to enter the market. The closest I

could come to a response was the statement that "Making it easy for new

participants to compete with ABB and G.E. is not our charge". (Actually,

these two companies are the strongest supporters of C12.19!)    As a

personal, value judgement, I do not feel that we are framing a "fluid,

dynamic electric market" by raising barriers to new entrants.  I argued in

my last posting that if MDMA's are the ultimate and sole point of

standardization, those who control the few protocols that now exist can

make it difficult for any other company to innovate.  Why? How would an

innovator get its data into the MDMA?  Will each manufacturer agree in

advance to support innovations from other companies? Will we require that

MDMA's accept any and all new comers and convert the new protocols into the

standards at the MDMA level?  Until these points are addressed, I will

remain convinced that innovation will be difficult to effect for any but

existing manufacturers. I apologize if I missed the response to these

arguments.

     I was not able to find a justification for George's statement that

data should "fly through the air in table format just because it is nice to

do so. Doing so achieves utterly nothing for interoperability...It does not

achieve the mythical world of 'Plug and Play', the unicorn of our

proceedings."  I apparently failed in efforts in my previous posting to

show that (ultimately) standardizing at the meter level indeed DOES offer

substantial benefits.  I urge concerned readers to re-read this posting

with an eye to the following arguments. 1.  Standardizing at the meter

level allows customers to access their data without going through the MDMA.

2.  If home automation equipment is to emerge with the capability to use

meter data directly to shift loads or conserve energy, I argued it is

important to have this meter standardized at the meter level, or the

customer will have to call the MDMA each time data is needed.  In response

to this home automation argument, George comments, "We are not gathered

together to decide anything inside people's private residences".  Indeed,

by deciding not to standardize at the meter level, we have done exactly

that. We have denied customers the option of reading their own data

directly or buying equipment that does this for them automatically.  I

argued that MDMA-only standards effectively foreclose these technical and

market options.  I do not feel that we have set up the framework for a

"fluid, dynamic market" by foreclosing options.  This is one of several

reasons why I favor meter standards.  It is NOT "just because it is a nice

thing to do!"

     I welcome a point-by-point discussion of my earlier posting.  I am

ready to concede any point on which I am in error and indeed, I welcome the

better understanding.  However, I also wish to see the discussion move

forward by having accepted those points that can not be effectively

countered.

     I must also respectfully disagree with the CellNet position that there

is no consensus on the need for C12.19.  I note that this consensus

standard was developed over a period of about 5 years jointly by IEEE,

ANSI, and Industry Canada in an open process to which everyone was invited.

Some manufacturers have already begun producing meters that use the tables.

In fact, most of the paricipants in the PSWG support this standard, as

demonstrated that it very nearly passed with a 2/3 majority in voting at

the last session.  It is likely to pass that same vote at the next meeting.

There is a vocal minority that strongly opposes C12.19, but I find it

difficult to reconcile the view that there is no support for C12.19 with

the votes in the PSWG.

     There is one important philosophical framework that should be

recognized as influencing the discussion of these points of contention.

That is - what is the goal of the PSWG?  Is it narrow, in the sense that it

is only to enable a competitive electric metering market and nothing else?

Or is it broader, in the sense of constructing a framework that will allow

technical innovations, new marketing strategies, and new alliances to offer

consumers a wide variety of choices.  If the former is the goal,

standardizing at the MDMA level is a defensible position.  The existing

protocols will become de facto standard inputs to the MDMA, no new

competitors will enter the metering market without the help of existing

meter manufacturers, it will be difficult to add new technical

capabilities, and customers can only access their data through the MDMA..

The PSWG will have enabled a market place, but it does not coincide with my

concept of a "fluid, dynamic market".