RE: Comments on PSWG Minutes



IN PAUL AUBIN'S PRESENTATION ON C12.19,  WHICH WAS ONE OF THE MOST
COMPREHENSIVE ON THE SUBJECT.  HIS FIRST POINT WAS COST REDUCTION.  THE
ECONOMIC BENIFITS WERE DISCUSSED AND ARE ONE OF THE MOST IMPORTANT REASONS
FOR ADOPTION.

> ----------
> From: 	Greg Lizak[SMTP:Greg.Lizak@itron.com]
> Sent: 	Wednesday, June 03, 1998 3:18 AM
> To: 	Stacey, Kirsten; pswg@dradmin.cpuc.ca.gov;
> pswgweb@dradmin.cpuc.ca.gov
> Subject: 	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
> >>
> >>
> 
> 
> 
.

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