Comments of California Department of General Services
on Utilities’ Phase 1 Common Framework Proposal

I.	Segmentation by rate schedule vs. meter type:   DGS notes that a number of costs appear to be driven primarily by meter type (e.g., reading costs, maintenance, etc.).  DGS is concerned that the utility proposal to assign a predominant meter type may undermine accurate crediting.  DGS is not clear why there is a complete disconnect between customer information and meter information, nor why it should be assumed that this disconnection would continue indefinately.  DGS notes that certain meter specific data may be incorporated to the Universal Node Identifier and/or meter identification systems contemplated in D.97-12-090.  DGS believes that incorporation of some meter-specific identification field or fields is a Phase 1 issue.  Addressing this issue now will avoid subsequent “systems” issues.  Nevertheless, only if the alleged data disconnection is such that timely implementation of a credit is not possible because customer-to-meter data cannot not be mapped, DGS might support using a tariff level proxy as an interim measure.

II.	Access Time Zoning: Are utility zipcode data retained at the “Zip+Four” level, or would zones be mapped only to the primary zip number?  If a customer’s meter reader is instructed about a dog or locked gate, etc., would there be a “zone bump” to reflected the increased time increment?

III.	Gas meter reading: DGS supports the comments of ORA and Enron regarding anticipation of gas meter reading and similar RCS services on the gas side.  This is clearly a phase 1 issue. This comment also applies to Section II D.

IV.	PG&E Telephone Reads: DGS believes that PG&E’s segmentation of manual vs. phone read is a problem similar to the meter-based segmentation.  If the phone / manual distinction is made, we don’t understand why the meter type should not be reflected.

V.	Meter Services and Meter Ownership: As noted above, DGS believes that meter-specific segmentation should be investigated and is a better reflection of costs avoided.  DGS understands that there may be data issues, but believes that from a systems design perspective the crediting mechanism should be designed to incorporate differing values by meter type.

VI.	Billing and Payments: DGS generally supports the billing and payments credit based on bill format types at the rate schedule level.  DGS notes that some metering data information may reflect the ISO or UDC “otherwise applicable” tariff designation (see, D.97-12-090) so weighted average over the long-run may not be necessary and there may be a value in designing the system to incorporate some tariff subclassification in Phase 1.  DGS could support the weighted average approach as long as timing and redetermination of averages is addressed in Phase 2.