Integrating Metering & Information Systems
speak for ORA management, much less the CPUC, I think that it is safe to say that we are very pleased with the [December] metering decision. It adopts, substantially intact and frequently verbatim, the ORA and Joint Parties positions offered in the workshops and in formal comments on record. Many of the positions offered in the decision as derived from the workshop report were, in fact, taken from ORA and other Joint Parties' submissions in that process. While it is gratifying to find our proposals accepted and adopted by the workshop participants, I also take a lot of pride in being part of a group that took the initiative to develop these proposals.
I only found two outright errors in the decision. First, it did not include the names of all of the parties in our group. Others who participated included PacifiCorp and Southern California Gas Co., the energy services provider Illinova Energy Partners, the metering services provider Data and Metering Specialties, the Industry Canada Task Force, and customer representatives Share Plus (a hospital consortium), the U.S. Dept. of Defense (as facilities manager of extensive properties in the state) and the Utilities Consumers Action Network.
Secondly, it was erroneously reported that the Automated Meter Reading Association has rescinded its cosponsorship of our proposals when, in fact, AMRA had never been a cosponor, but IEEE SCC 31 having at one time been incorrectly identified as AMRA.
BWR: Please comment on why the decision makes ESPs and UDCs the MDMA and MSP.
AM: While ORA has recommended near-term empowerment of customers to select their own MSPs and MDMAs, we never expected this to be implemented immediately. Incremental unbundling was to be expected, given the unprecedented scope of electric restructuring.
BWR: Why give discretion to ESPs or UDCs to subcontract to other vendors?
AM: I don't believe that this is anything new, as traditional utilities have always been rather free to apportion their operations between in-house employees and outside contractors as they saw fit, with only broad PUC oversight. "Micromanagement" has been a bad word for some time now.
BWR: Why can't customers choose their own MSP or MDMA?
AM: While we never expected customer choice to be immediately established for all of the so-called "revenue-cycle" services, ORA does recommend this as a goal of restructuring. Customer choice at this level, involving as it does multiple parties, can only take place under sufficient standardization so that all parties can feel comfortable in their expectations for the provided functions. The PUC seems to adopt this approach, in its language at the end of section III.B.2.B. [p. 4]:
"We see merit in eventually allowing customers to choose their own individual metering services from different providers¼ If systems can be developed to address these [safety, reliability, and accuracy] concerns, we would be willing to revisit the further unbundling of metering services in the future."
BWR: Is this what you envisioned with revenue-cycle unbundling?
AM: Establishing the principles of interoperability, open architecture, national standards and an orderly and expeditious migration as the essential requirements for meaningful customer choice was