RE: Comments on PSWG Minutes
Kirsten,
I'm afraid you missed my point.
a.) I didn't want to dwell on C12.19
b.) I thought economic considerations were the responsibility to be
addressed by those who are making proposals, not those who might disagree
with a proposal.
c.) The discussion of economic impacts and benefits at the referenced
meeting was not meant to be confined to C12.19. It is important that the
minutes of the recent meeting reflect the strong discussion for and against
consideration of impacts.
Also, I thought we agreed months ago that impacts/benefits were to be
addressed in proposals.
d.) re your comments on C12.19 "Star Data never made a formal
presentation on the cost impacts of C12.19" - questions of costs and
economic benefits were repeatedly raised during the PSWG meetings, but they
were never addressed. If there are positive net economic impacts so much
the better.
Although a considerable amount of effort has been spent on the referenced
proposal, I don't think an elaborate economic analysis is needed. But to
address your concern, I'm not aware of anyone making a formal presentation
on the cost impacts of C12.19.
e.) re "At this point, Star Data will need to express cost concerns in
individual comments". It might be better if this recommendation were
applied, if at all, after the PSWG votes on the proposal (the PSWG vote is
now scheduled for June 11).
f.) I don't believe that several meetings were dedicated only to the
discussion of C12.19. It may seem that way though.
The discussion C12.19 could have been limited to one meeting and only voted
on once, not several times with a mixture of some consensus votes no and
once yes.
g.) The mail below seems to raise questions on SDS's position on C12.19.
SDS continues to support appropriate standards and has participated with
others in suggesting standards for consideration. At this point, C12.19
would make an excellent voluntary standard and when it is improved to
become more market viable for direct access, consideration should be given
to review its voluntary status. Secondly, should cost impacts of C12.19 be
considered, yes they should, particularly if they indicate it to be cost
effective.
Kirsten, I hope this helps to clarify my earlier email and addresses your
concerns; please call me if you would like to discuss this further or have
any questions. Also, I'll be glad to help with a simple analysis if rough
estimates of costs and impacts can be supplied; but at this date I doubt if
anything can be pulled together in time for posting the proposal to be
voted on June 11.
Greg
++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++
>Greg,
>
>I will be happy to revise the minutes to include your observation that the
>economic costs should be weighed in making a decision about C12.19.
>
>The group did agree that costs should be reasonable in recommending
>standards. (March 10 meeting)
>
>It is the responsibility of the group members to inform the group if there
>are costs to be considered. We have dedicated several meetings soley to
>discussion of C12.19 and Star Data has had the opportunity to flag economic
>considerations.
>
>Star Data's verbal arguments were not sufficient or specific enough to sway
>the group. Star Data never made a formal presentation on the cost impacts of
>C12.19. You might not be happy with the outcome, but I don't think you can
>fault the process.
>
>At this point, Star Data will need to express cost concerns in individual
>comments.
>
>Kirsten
>> ----------
>> From: Greg Lizak[SMTP:Greg.Lizak@itron.com]
>> Sent: Monday, June 01, 1998 10:24AM
>> To: Stacey, Kirsten; pswg@dra1.cpuc.ca.gov; pswgweb@dra1.cpuc.ca.gov
>> Subject: Comments on PSWG Minutes
>>
>> Kirsten,
>>
>> Last week you asked for comments on the minutes of previous PSWG meetings.
>> I wanted to add one that should be reflected in the minutes. These
>> comments pertain to, I believe the May 12 PSWG Communications sub group
>> meeting.
>>
>> At the meeting there was a discussion regarding that proposals include
>> economic impacts, cost and benefits. This consideration is particularly
>> important for contentious proposals such as C12.19.
>>
>> At a previous PSWG meeting I thought it was agreed that addressing
>> economic/cost implications was to be included in proposals. The meeting
>> minutes should reflect this discussion as well as what I thought was the
>> strong insistence by the ORA (Office of Rate Payer Advocates) that
>> economic
>> considerations such as cost to customers and market participants is not
>> appropriate for consideration and should not be included. Also, the
>> minutes should reflect that no specific CPUC decisions in the Conclusions
>> of Law or Order sections were identified that state the economic
>> considerations including cost to customers or the market are not to be
>> considered. As I stated, I have reviewed these sections and am not able
>> to
>> find any Order or Conclusion of Law that prohibits economic
>> considerations.
>> Perhaps if someone can reference a particular section, I'd be happy to
>> reconsider the issue.
>>
>>
>> Thank you,
>>
>> Gregory Lizak
>> Star Data Services
>>
>>
.
References: