RE: Comments on PSWG Minutes

>X-Sender: bbuckley@mailserver.itron.com
>Mime-Version: 1.0
>Date: Wed, 3 Jun 1998 10:50:53 -0800
>To: "Chartrand, Pymm (ED&C,T&DSS)" <pymm.chartrand@edc.ge.com>
>From: Bill Buckley <bill.buckley@itron.com>
>Subject: RE: Comments on PSWG Minutes
>Cc: "Stacey, Kirsten" <KSM8@pge.com>, pswg@dradmin.cpuc.ca.gov,
>        pswgweb@dradmin.cpuc.ca.gov, Greg Lizak <Greg.Lizak@itron.com>
>
>At 9:13 AM -0800 6/3/98, Chartrand, Pymm (ED&C,T&DSS) wrote:
>>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.
>Pymn:
>
>I agree that cost was mentioned in Pauls presentation.  Cost was also
>mentioned  in Tom Chens presentation on Security.  But you must admit  that
>quantitative data or examples or estimates  were not discussed in either
>case.   In the case of Security I speculate that the PSWG will not
>recommend any of the many security standards, but will state a general
>philosophy (that seens to be the trend of the PSWG).....which is what the
>PSWG should do with C12.19.   We should support the concept of C12.19, not
>the current version but fix the standard so it is more applicable to the
>California or o other competeitive evironments.  A general philosophy
>statement would be more appropriate that advocated the C12.19 concept after
>the standard has been examined and altered.
>
>In the interest of Antitrust issues it would be hard to be specific without
>discussing a specific companies experience  or resources.  I think that all
>Greg is asking for is discussion of relative costs compared to benefits.
>This has not been done and is probably beyond the capability of the current
>attendees.  Is GE going to bring in their controller or testimony from
>customers citing the great savings garnered from adopting C12.19?  We
>should call a "spade a spade."  The benefits to any specific security
>scheme or to C12.19 are very speculative.  I will however concede that
>there may be other non-ecomonic or non quantifiable benefits to adopting a
>standard such as safty, ease of operation maintenance, market aspects,
>additional functions or customer benefit.  Even these issues were not
>examined for C12.19 and certainly at best only assumed for the other
>standards the PSWG has already agreed to recommended to the CPUC.  I do not
>think that we would have time to examine all of these parameters for C12.19
>and in the emotionally charged PSWG forum fail to reach agreement.
>
>Most of the recommendations or support for C12.19 are based on gut feeling,
>relationships, unsupported bias and  personal experience.  Most of the
>group, incuding advocates from both sides have never analyzed or even read
>the C12.19 standard.   I have only read portions myself, it is a very large
>and complex document with lots of loopholes.    The problem with the C12.19
>recommendation is that it is being recommended for emotional or competitive
>reasons more than for any business rationale that would be normally
>considered.  C12.19 may be a start at  interoperability, but it is only a
>start!   Without physical and second layer standards interoperability is a
>promise never realizeable.  In order to get concensus,  C12.19  was
>approved by the Tablefest group of standards bodies only after a scheme was
>included to protect proprietary schemes already developed by some
>participants.    I  find it hard to believe that nost utilities or ESPs
>will insist on compliance to a standard if they truly understand the
>inteoperability offered is only very limited, but will cost them  (some
>unknown amount of time and/or money)!
>
>Delaying or limiting mandatory implementation of the standard may get some
>participants to yield to the mob fever and support the current
>recommendation, but this does not make adopting C12.19 the ethical or
>optimum action for the group.
>
>You misunderstand ITRONs motives for opposing the blanket adoption of the
>exixting C12.19.  If our customers want it ITRON will offer it, but ITRON
>opposes the adoption of a mandatory requirement or law that will bring no
>benefit to our customers.  ITRON responds to the market place when it comes
>to servicing our customers and meeting obligations to its stockholders.  I
>have misgivings that I and my employer, ITRON will in the future be labled
>as participants in an activity that recommemded  this faulty scheme, that
>may be  costly to ESPs, UDCs, and users.  I am not  convinced that the
>participating corporations have allocated resources to analyze the  impact
>of the PSWG recommendation  on the market place for the long term and only
>some have even looked at the short term.
>
>See you in SF
>
>Bill Buckley
> >
>
>
>
>
>
>>> ----------
>>> 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
>>> >>
>>> >>
>>>
>>>
>>>
>
>
>Willam J. Buckley
>Director of Technical Standards
>ITRON
>PO BOX 15288
>SPOKANE, WA 99215
>509-891-3744
>FAX:509 891-3590
>EMAIL: mailto:bill.buckley@itron.com
>Home email:  mailto:Wjbuckley@aol.com
>Home Phone: 509-922-1676
>For More Information on ITRON see our WEB page http://www.itron.com
>
>

Willam J. Buckley
Director of Technical Standards
ITRON
PO BOX 15288
SPOKANE, WA 99215
509-891-3744
FAX:509 891-3590
EMAIL: mailto:bill.buckley@itron.com
Home email:  mailto:Wjbuckley@aol.com
Home Phone: 509-922-1676
For More Information on ITRON see our WEB page http://www.itron.com
 


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