NOTICES
Smart Meter Procurement and Installation
[42 Pa.B. 7793]
[Saturday, December 22, 2012]Public Meeting held
December 5, 2012Commissioners Present: Robert F. Powelson, Chairperson; John F. Coleman, Jr., Vice Chairperson; Wayne E. Gardner; James H. Cawley; Pamela A. Witmer
Smart Meter Procurement and Installation;
Doc. No. M-2009-2092655
Final Order By the Commission:
The Pennsylvania General Assembly (General Assembly), through Act 129 of 2008 (Act 129) has directed that electric distribution companies (EDCs) with more than 100,000 customers file smart meter technology procurement and installation plans with the Commission for approval. 66 Pa.C.S. § 2807(f). Furthermore, Act 129 requires these EDCs to make available to customers and their designated third parties, including electric generation suppliers (EGSs) and providers of conservation and load management services (CSPs), access to the meter and electronic meter data. 66 Pa.C.S. § 2807(f)(3). With this Final Order, the Commission requires the covered EDCs to implement electronic data interchange (EDI) and other standards consistent with the directives set forth in this Order.
The Commission recognizes that the smart meter technology required by Act 129 provides more information about a customer's electricity use than previous technology. The Commission also recognizes that while this information is intended to empower electricity customers, it can be used for other purposes that raise privacy and security concerns. In fact, the Commission has always been cognizant of customer privacy and security concerns and has promulgated regulations, such as 52 Pa. Code § 54.8 that restrict access to customer information. Specifically, Section 54.8 of the Code restricts an electric company or electric supplier may not release private customer information to a third party, including an affiliate of the electric company or electric supplier, unless the customer has been notified of the intent and has been given a convenient method of notifying the entity of the customer's desire to restrict the release of the private information. 52 Pa. Code § 54.8(a). Furthermore, electric generation suppliers are required to maintain the confidentiality of a consumer's personal information, including the customer's name, address, telephone number and historic payment information. See 52 Pa. Code § 54.43(d). In addition, the Commission has declared that all electric utility customers shall have the right to withhold all customer account and usage data from the Eligible Customer List that is made available to Commission-licensed Electric Generation Suppliers. See Interim Guidelines for Eligible Customer Lists, Final Order on Reconsideration, at Docket No. M-2010-2183412, entered November 15, 2011.
The Commission has also directed its staff and the electric utilities to participate in efforts by national standards groups to address and define business practices and technical requirements, such as data communications, that will preserve the integrity, reliability and security of the national grid, local distribution systems, meters and consumer data. Such groups include the National Institute of Standards and Technology (NIST), the North American Energy Standards Board (NAESB), and the Utility Communications Architecture International Users Group (UCAIUG). See Smart Meter Procurement and installation Implementation Order at Docket No. M-2009-2092655, entered June 24, 2009, at 27.
By adopting this Order, the Commission is in no way revising, limiting or reducing the previously established Commission rules, regulations or precedent regarding the security, confidentiality or use of private customer information, to include the customers personal and electric usage information. The intent of this Order is to facilitate the establishment of a standard electronic format for providing customers and their designated third-party representatives with direct electronic access to the customer's electric usage and price data, with the customer's consent.
Background
On June 18, 2009, the Commission adopted a Smart Meter Procurement and Installation Implementation Order1 (Implementation Order) to establish the standards each smart meter technology procurement and installation plan must meet and to provide guidance on the procedures to be followed for submittal, review and approval of all aspects of filed plans. The Implementation Order also directed EDCs to work through the Electronic Data Exchange Working Group (EDEWG) process to develop EDI transactions to fully achieve the capabilities of smart meter technology.2
Specifically, the Commission directed that all covered EDCs must provide customers and their designated representatives access that fulfills the following requirements:3
1. Non-discriminatory access for retail electric suppliers and third-parties, such as EGSs, and conservation and load management service providers;
2. Open, non-proprietary two-way access for electric suppliers and third-parties, such as EGSs, and conservation and load management service providers; and
3. Full electronic access to customers and their representatives to meter data upon customer consent.
Additionally, the Commission directed the EDCs to address standards and formats for electronic data communications with customers and third parties by implementing EDI enrollment of EGS customers who elect real-time (RT) or time-of-use (TOU) rate programs; develop a new EDI historical interval usage (HIU) transaction for 12-months of data that has been recorded at the meter; and develop and implement a new EDI transaction for monthly, bill-quality interval usage (IU) data recorded at the meter level.4 To achieve these requirements the Commission directed the EDCs to collaborate with the EDEWG to develop appropriate EDI capabilities.5
The EDCs obligated to deploy smart meter technology under Act 129 include the Duquesne Light Company (Duquesne); Metropolitan Edison Company, Pennsylvania Electric Company, Pennsylvania Power Company, West Penn Power Company (collectively FirstEnergy); PECO Energy Company (PECO); and PPL Electric Utilities Corporation (PPL). All of these EDCs have filed a Smart Meter Technology Procurement and Installation Plan (smart meter plan) with the Commission for approval. All of these EDCs have received Commission approval of their respective smart meter plans.6
On December 7, 2009, EDEWG submitted a Preliminary Proposal for the Development of Smart Meter Data Exchange Standards (EDEWG Preliminary Proposal). The EDEWG Preliminary Proposal was developed by an EDEWG sub-team consisting of representatives from Duquesne, FirstEnergy, PECO and PPL. The initial draft version of the EDEWG Preliminary Proposal was published on the EDEWG List Serve for review by all EDEWG participants. The EDEWG Preliminary Proposal was then reviewed and discussed at the December 3, 2009, EDEWG meeting, after which the EDEWG Preliminary Proposal was submitted to the Commission on December 7, 2009.
On June 30, 2011, the Commission adopted a Tentative Order at this docket proposing further direction and clarification for the development of standards and formats for smart meters and access to meter data.7 Comments were due thirty (30) days from the date the Tentative Order was published in the Pennsylvania Bulletin, with reply comments due twenty (20) days thereafter.8 The following parties filed comments: the Demand Response and Smart Grid Coalition9 (DRSG); Duquesne; the Energy Association of Pennsylvania (EAP); the Electronic Data Exchange Working Group Leadership10 (EDEWG Leadership); FirstEnergy; PECO and PPL. The following parties filed reply comments: PECO and FirstEnergy Solutions Corporation (FirstEnergy Solutions). After consideration of the initial and reply comments, we are requiring EDCs to implement EDI and other standards consistent with the directives set forth in this Order.
Discussion
The Tentative Order proposed requirements and provided additional clarification to address the following three topics presented in the EDEWG Preliminary Proposal: (1) data exchange standards for current business processes; (2) data exchange standards for new business processes; and (3) a smart meter standards development process. We will discuss each topic below.
Data Exchange Standards for Current Business Processes
1. Real-Time and Time-of-Use Prices
The EDEWG Preliminary Proposal maintains that changes to existing EDI transactions are not required to establish customers in new rate programs, including RT or TOU programs. Specifically, the EDEWG Preliminary Proposal explains that existing transactions for current business processes, such as enrollment using the EDI 814 E (EDI enrollment transaction) and billing using the EDI 810 (EDI billing transaction), are capable of supporting EGSs' customers under RT/TOU programs and can be satisfied under three billing scenarios currently approved by the Commission: (1) EDC Consolidated Billing/Rate-Ready (Rate-Ready); (2) EDC Consolidated Billing/Bill-Ready (Bill-Ready); and (3) Dual Billing.11 ''Rate-Ready'' refers to the practice in which the non-billing party provides rate information to the billing party sufficient to calculate the non-billing party's charges. ''Bill-Ready'' is a billing practice in which the billing party receives the calculated charge amount(s) directly from the non-billing party in lieu of the billing party calculating it directly from the rate; and ''Dual Billing'' is the billing option in which the EDC and EGS render separate customer bills for the products and services each provides.''12
As proposed in the EDEWG Preliminary Proposal, if a customer elects service on a RT or TOU rate, under Rate-Ready the EGS would specify on the EDI enrollment transaction a Rate-Ready rate code associated with the elected RT or TOU program—a process that assumes that the EDC is capable of billing these complex rates on behalf of the supplier in order to produce a single bill. Under Bill-Ready the EGS would specify on the EDI enrollment transaction that it will calculate its own charges to be consolidated with the bill produced by the EDC and provide the EDC with a Bill-Ready EDI billing transaction. Under Dual Billing the EDC and the EGS each would calculate their own charges and separately bill the customer, hence no special coding is needed on the EDI enrollment transaction and use of the EDI billing transaction is eliminated.
In the Tentative Order the Commission concurred with the use of these existing EDI transactions for enrollment and billing of EGS customers that elect to participate in an RT or TOU program. The Commission, however, proposed an additional requirement for an EDC to submit any appropriate EDI change control request within 30 days of the entry of a Final Order in this proceeding.13 To clarify, the purpose of this additional requirement was to address the possibility that under the Rate-Ready scenario, an EDC may not currently be able to accept and process an EGS's special rate code on the existing EDI enrollment transaction.
DRSG comments that it does not recommend any changes to current business processes unless the new standards are more cost-effective or otherwise beneficial. DSRG notes that it is aware of standards under development for exchanging pricing and usage information by the NAESB Energy Services Provider Interface (ESPI) Task Force (NAESB standards). In addition, DSRG notes that the NIST has published in its Smart Grid Standards Catalog a data model for use with electric usage and pricing data known as Priority Action Plan 10 (PAP10) (NIST standards). DRSG suggests the ESPI and PAP10 standards be among those considered for use in Pennsylvania.14
Duquesne supports approval of Bill-Ready and Dual Billing processes set forth in the Tentative Order, provided that Duquesne may continue its current practice of providing Rate-Ready billing utilizing the appropriate Rate-Ready rate code. Duquesne, however, disagrees with the proposed 30-day deadline to submit an EDI change control request and recommends that any deadline be incorporated into each EDC's smart meter plan.15 FirstEnergy explains that it is currently programmed to function under the Bill-Ready and Dual Billing options and that there is no reason for them to submit an EDI transaction change request.16 EAP agrees with and incorporates by reference the concerns and solutions voiced by its EDC members to that portion of the Tentative Order under the Data Exchange Standards for Current Business Processes heading.17
With regard to current EDI business processes in general, EDEWG Leadership comments that data exchange standards for existing business processes are already defined and that only a small adjustment would be required. EDEWG Leadership asks the Commission to provide further clarification for the Tentative Order directives relating to EDEWG's expanded role, which historically has been to create and maintain EDI for EDCs and EGSs and not for data exchanges between EDCs and their customers, and EDEWG's integration with the separate EDC smart meter plans.18
PECO supports Bill-Ready billing, which it believes would eliminate the need for EGS notification of any rate or pricing option that may be selected by the customer. PECO adds that if an EGS wants bill quality interval data and the EGS configures the existing EDI enrollment transaction with a flag, the transaction requires no modification. PECO asserts that EDEWG, not the EDC, should determine the extent that the EDI enrollment transaction must be modified and suggests that EDEWG be given 90 days to develop any required modifications.19 PECO emphasizes the need for implementation timelines to reflect scheduled deployments under an EDC's smart meter plan to avoid the creation of uncertainty regarding the implementation of those plans. PECO also asks the Commission to clarify that approved EDC smart meter plans are not subject to revision by EDEWG.20
PPL comments that the existing practice for Bill-Ready and Dual Billing scenarios should be approved to support EGS customer participationin RT or TOU pricing programs. PPL states that it does not currently offer Rate-Ready for RT or TOU pricing programs, which it asserts would require significant changes to its customer information and billing systems. PPL maintains that even if it were to offer this billing option in the future, no changes would be required of any EDI transaction.21
Of relative importance are PPL's comments relating to bill quality interval usage. PPL states that advanced metering technologies are being provided by EDCs and not the marketplace and that the company knows of no current complex pricing programs that employ meter level data that would justify an accelerated schedule. PPL recommends that any modifications undertaken be incorporated into each EDC's smart meter plan.22
FirstEnergy Solutions agrees that the EDI enrollment transaction allows an EGS to enroll a customer who chooses RT or TOU service, regardless of whether that customer is under Bill-Ready or Dual Billing. FirstEnergy Solutions also agrees with PPL's statement that no change is required of any EDI transaction for this purpose.23
After review of each of the parties' comments the Commission is convinced that Bill Ready and Dual Billing capabilities present the best option for attaining TOU and RT pricing capabilities for EDC's covered by the smart meter mandate. The Commission acknowledges that Rate Ready systems can provide a solution that can support RT and TOU pricing. However, since almost all EDC's subject to the smart meter provisions already offer Bill Ready and Dual Billing, we believe it would be best to promote uniformity and direct that all EDCs subject to the smart meter provisions propose Bill Ready and Dual Billing functionalities as part of their smart meter plans. If an EDC has already filed its' completed smart meter plan, that EDC shall make a filing within 120 days explaining how and when it will incorporate this requirement into its smart meter plan. This directive does not preclude an EDC from creating or maintaining a Rate Ready system with RT and TOU rate functionality. Additionally, this directive does not preclude EDCs from researching and implementing potential non-EDI data sharing platforms at their own discretion as long as Bill Ready and Dual Billing systems are also offered.
2. Historical Interval Usage
In the Tentative Order we proposed that alternatives to the use of the existing EDI 867 Historical Interval Usage (EDI 867 HIU) transaction be explored for communicating 12 months of interval data that is recorded at the meter level. We further proposed that EDEWG and the covered EDCs should work together to identify a solution that can be implemented within 180 days of the entry date of this Final Order.24
DRSG comments that if new standards are to be considered for any new business processes, the NAESB ESPI and NIST PAP10 standards should be among those considered for use in Pennsylvania.25 Duquesne does not object to exploring alternate solutions for the provision of historic interval usage data at the meter level, adding that a viable solution pursued by EDEWG or any other group should be via the web in a standardized environment and that implementation should be based upon an EDC's smart meter plan.26 EAP comments that 180 days is not an adequate period of time to allow for EDEWG to conduct an analysis of complex customer information and billing system modifications and have EDCs implement the agreed upon solutions.27 EDEWG Leadership states that EDEWG has not developed or maintained standards for communication of customer data directly to EDC customers and notes that this is outside the traditional scope of EDEWG.28
FirstEnergy comments that the use of an alternative to the EDI 867 HIU is practical due to the sheer volume of data for 12 months of 15-minute interval meter reads. To address this need FirstEnergy has placed hourly interval usage data on a secured section of its supplier services website as an efficient short-term solution that it believes is prudent in light of the on-going activities at the NIST. FirstEnergy recommends that a customer portal may be a viable long-term solution and that implementation of such a portal would likely extend beyond 180 days of the Final Order. In addition, FirstEnergy questions if EDEWG is the appropriate organization to explore alternative solutions.29 PPL concurs that an alternative means of transmitting large volumes of historical interval usage data is appropriate, but it believes it is inappropriate to require EDCs to install complex customer information and billing system modifications within a 180-day window.30
PECO supports the proposal to explore alternative solutions for the provision of 12 months of historical interval usage at the meter level. PECO agrees that the use of national standards development organizations such as the NAESB should be leveraged to the extent possible. In particular, PECO suggests that an appropriate role for EDEWG would be to develop implementation level guidelines based on a national standard rather than to create an entirely new standard solely for Pennsylvania. PECO asks the Commission to seek ways to engage additional stakeholders who are not actively involved with EDEWG. PECO believes 180 days may not be adequate to develop and implement this standard.31 PECO also points out that no EGS commented on the appropriate method or timeline for making historical interval usage data available at the meter level. PECO adds that meter level data may not be as helpful for large end-use customers where multiple meters are linked to a single account, asserting that it may be prudent to offer this data only upon request by customers and EGSs.32
FirstEnergy Solutions agrees with the comments of EDCs that the current EDI 867 HIU transaction is not useful. FirstEnergy Solutions believes that alternatives, such as a web-based solution, would facilitate interactions among customers, EDCs and EGSs. FirstEnergy Solutions believes that it is of the utmost importance that EGSs be consulted in developing potential alternative solutions to ensure functionality and practicality from a supplier and customer choice standpoint.33
In resolving this issue we will address pre-smart mater and post-smart meter implementation separately. Concerning pre-smart meter implementation, the Commission understands the challenges presented by data volume associated with historical interval usage data sharing via EDI. However, we believe the present capabilities of a number of EDCs to share 12-months of historical interval data is a significant asset to the market. Consequently, the Commission directs all EDCs covered by the smart meter mandates to install the capability to share a minimum of 12 months of historical interval account level or meter level usage via EDI. These EDCs are directed to file within 120 days under its respective smart meter plan docket, a supplement outlining the EDC's current capability to provide a minimum of 12-months of historical account level or meter level usage data via EDI or which details the EDC's plan to provide this capability within one year.
Concerning post-smart meter implementation, we have determined that the use of a standardized, secure web-based portal will enable interactions among all parties for communicating 12-months of historical interval data on the meter and account level and provide meter or account level data as requested by the customer or the customer's third-party representative. We agree with DSRG, Duquesne, FirstEnergy and PECO that the efforts of national standards organizations should be leveraged to ensure broad industry participation over the long-term. Additionally, the Commission believes that a secure web-based portal presents a viable long-term solution for the sharing of bill quality interval usage data within 24 to 48 hours after daily meter reads.
As such, we direct that the EDEWG to initiate a web-portal working group of all EDCs covered by the smart meter mandate and any other interested stakeholders to develop a standardized solution for acquisition of interval usage data via a secure web-portal. The Commission expects the shorter-term solution will be a system that offers 12-months of HIU data via a secure web platform. The Commission expects the longer-term solution will be a system that provides billing quality interval data within 24 to 48 hours of daily meter reads. We further direct the EDEWG working group to leverage any appropriate NIST and NAESB standards in the development of this secure web-portal. The EDEWG working group shall complete its development standards for the HIU solution by March 1, 2014, after which the EDEWG working group shall have till no later than March 1, 2015 to complete its development standards for the bill quality IU solution. The EDCs shall propose the solutions formed within these EDEWG working groups as part of their smart meter implementation plans.
We note that these directives shall not preclude EDCs from continuing any presently operating or planned website or other non-EDI functionality that permits authorized entities and customers to access historical interval usage data or interval usage data. In fact, the Commission encourages EDEWG to leverage any such EDC initiatives, to the extent possible, within the EDEWG web-portal working group. However, EDCs shall continue to offer such data via EDI as an interim solution until a long-term solution based on national standards is implemented.
3. Bill Quality Interval Usage
In the Tentative Order we proposed the use of a modified EDI 867 Interval Usage (EDI 867 IU) transaction to provide monthly bill-quality interval usage data at the meter level. In addition, we proposed that the deadline for deployment be 12 months in advance of the expiration of the EDCs' 30-month grace period.34
Duquesne comments that it currently provides data at the account level and not at the meter level. Duquesne states that the company is in the process of enhancing its customer care and billing system and asks that the proposed deadline for implementing a modified EDI 867 IU be rolled out as part of its smart meter plan with an expected date of completion of 2013.35
DRSG comments that it does not recommend any changes to current business processes unless new standards are more cost-effective or otherwise beneficial. DRSG suggests that if new standards are to be considered for any new business processes, the ESPI and PAP10 standards should be among those considered for use in Pennsylvania.36
EAP comments that the timeframe for implementing a modified version of the existing EDI 867 IU transaction is problematic. With the exception of West Penn Power Company, EAP states that all EDC grace periods expire in October 2012. EAP recommends that, at a minimum, implementation should be set for a date that aligns with the expiration of individual EDC grace periods.37
FirstEnergy comments that the EDI 867 IU transaction is already designed to communicate monthly bill-quality interval usage that was recorded at the meter. FirstEnergy points out, however, that the provision of meter level detail is optional using this transaction. FirstEnergy adds that for its companies, the account level and meter level are generally the same, except in rare meter installations where multiple meters are totaled for billing all charges in accordance with its tariff. In these rare instances, FirstEnergy asks the Commission to consider the totalized meter data to be meter level data.38
PECO notes that the term ''bill quality'' was not clearly defined and submits that the data that was sourced from an EDC's meter data management system and that has completed the VEE process (has been verified, estimated and edited) associated with such systems should be considered bill quality data. Additionally, PECO recommends that the Commission allow at least six months after the close of the 30-month grace period for implementation of this requirement. PECO notes that this time will be needed for EDCs and EGSs to perform extensive testing of the modified systems before they can become operational. PECO believes that additional input from EGSs is critical, as some EGSs may prefer to continue to receive data at the account level to simplify their data processing.39 PECO emphasizes that it would be prudent to offer bill quality interval data at the meter level only upon request by the EGS. PECO agrees with other EDCs regarding the need to extend implementation timeframes for providing interval data solutions and to coordinate with each EDC's smart meter technology deployment schedules.40 FirstEnergy Solutions supports PECO's suggestion for additional input from EGSs to determine whether certain functionalities are even desired.41
PPL supports the EDEWG Preliminary Proposal for EDEWG to act to make meter level detail a requirement with an apparent effective date that coincides with an EDC's smart meter plan and 30-month grace period. Nevertheless, PPL recommends that any required system modifications be incorporated into each EDC's smart meter plan to assure coordination with other smart meter projects and cost recovery.42
Initially, we note that we will adopt PECO's definition for the term ''bill quality,'' in so far as it is in agreement with the use of this term by NAESB and NIST. We will adopt PECO's definition of ''bill quality data'' and shall define ''bill quality data'' as data that is sourced from an EDC's meter data management system that has completed the process of being verified, estimated and edited, in association with such systems. Furthermore, we will accept the concept of totalized meter data for meter-level data, as requested by FirstEnergy, for IU transactions occurring during the pre-smart meter implementation period.
We also agree with the EDEWG Preliminary Proposal recommendation to make meter level IU data a requirement for the EDCs. In addition, we agree with PPL's proposal to have this requirement incorporated into each EDC's smart meter plan. Furthermore, such meter level data shall only be provided upon request by a customer or the customer's chosen third-party. Consequently, the Commission directs all EDCs to incorporate meter level IU data capabilities within their respective smart meter plan. If an EDC has already filed its completed smart meter plan, that EDC shall make a filing within 120 days explaining how and when it will incorporate this requirement into its smart meter plan.
We stress that this requirement shall not prevent an EDC from providing customers and their designated agents with bill quality interval data more frequently than on a monthly basis. In particular, the Commission continues to endorse the capability to share such information within 24 to 48 hours of daily meter reads, as we did in the Implementation Order.43 We reiterate our expectation that the EDEWG web-portal working group will develop a standardized platform for incorporation into EDC smart meter plans which will provide bill quality IU data within 24 to 48 hours of daily meter reads.
Data Exchange Standards for New Business Processes
In the Tentative Order we proposed that the identification and development of new standards and formats to support Act 129 smart meter statutory requirements, along with the ongoing maintenance of existing standards and processes for this purpose, be developed by EDEWG and presented to the Commission for review. We further proposed that the development and ongoing maintenance of these standards and processes be done in a manner that includes all EDEWG participants, specifically, all EDCs, licensed EGSs, registered CSPs, and all other interested parties.44
Duquesne commits to being an active participant in this analysis and believes it is prudent to follow the standards set forth by NAESB, which is currently examining standardization for third-party access.45 As noted with respect to their comments on current business processes, DRSG also suggests that the NAESB and NIST standards be among those considered relative to new business processes as well.46
EAP commends the Commission for adopting that portion of the EDEWG Preliminary Proposal which recommends that, moving forward, EDEWG should include EDCs and other third parties such as EGSs and CSPs to develop any new system data capabilities that are recognized as necessary and justifiable by EDCs in their respective smart meter plans.47 The EAP asks the Commission to encourage EDEWG to adopt existing national standards where appropriate and provide any necessary Pennsylvania implementation guidelines rather than develop new standards specific to Pennsylvania.48
EDEWG Leadership seeks clarification with regard to integrating the expanded technological scope of the EDEWG with the separate EDC smart meter plans. EDEWG Leadership believes such guidance will be helpful for eliminating barriers previously encountered in the EDEWG sub-team, when EDC representatives eager to move smart meter data access forward were unable to reach consensus as a result of conflicts with their approved smart meter plans.49
PECO agrees that EDEWG should adopt smart meter standards being developed by national organizations such as NAESB rather than writing Pennsylvania-specific standards. PECO notes that EDEWG already set a precedent for adapting national standards when it adopted the Gas Industry Standards Board (a precursor to NAESB) standard for Internet EDI, modifying certain language to comport with Commission orders rather than rewrite the standard. PECO also names three NAESB standards either completed or, nearing completion, that may be useful in the context of Pennsylvania's smart meter implementation. PECO suggests that EDEWG consider inviting experts from the relevant national standards development teams to provide guidance on how the standards were developed and how they can be used.50 PECO asserts that the initial comments reflect substantial consensus among EDCs including the importance of avoiding the creation of uncertainty associated with implementation of smart meter plans and the inherent problems in the scope of work proposed for EDEWG.51
PPL reiterates conclusions presented in the EDEWG Preliminary Proposal, including that it is not possible for EDEWG to develop data exchange standards for undefined business processes. PPL believes that the Tentative Order appears to accept the approach described in the EDEWG Preliminary Proposal, but asks that the Final Order makes clear what is to be delivered by EDEWG.52
FirstEnergy Solutions reiterates its previous statement that it is absolutely critical that input and communication from the EGS community be given serious consideration when discussing smart meter implementation. FirstEnergy Solutions also emphasizes that any sub-teams or groups that may be established should include EGS representatives when considering or discussing possible smart meter processes that relate to customers or retail choice in general. FirstEnergy Solutions agrees with EAP's suggestion that EDEWG should include EDCs and other third parties such as EGSs and CSPs to develop any new system data capabilities that are recognized as necessary and justifiable by EDCs in their respective smart meter plans.53
We agree that national standards being developed for smart meters should be considered where applicable. As such, we direct the EDCs to propose appropriate NAESB and NIST standards in coordination with their respective smart meter plans. We encourage covered EDCs to actively participate in the ongoing development of applicable national standards, including those being addressed by the ESPI Task Force of NAESB. We further encourage covered EDCs to investigate other NAESB and NIST standards, including web-based meter data access initiatives such as NAESB/ESPI PAP2054 for sharing with the EDEWG and potential implementation within their smart meter plans. The Commission believes that active participation by EDCs in the appropriate national standards development organizations will inform the EDCs of any significant impacts that these national standards will have upon the successful deployment of smart meter technology.
In response to comments about the need to clarify the Commission's expectations of EDEWG, we agree with the recommendations of EAP and PECO that it is appropriate for EDEWG to prepare and update statewide implementation guidelines as necessary for the deployment of national standards by EDCs in accordance with their respective Commission approved smart meter plans.
Smart Meter Data Standards Development Process
The EDEWG Preliminary Proposal included a timeline for the development of smart meter data exchange standards that comports with the smart meter 30-month grace period established for covered EDCs in the Implementation Order. The Tentative Order provided clarification of our expectations of the EDEWG Sub-Team that is working on smart meter interaction with customers and authorized third parties.
In the Tentative Order we proposed to specifically task the EDEWG team to review each EDC's respective smart meter plan and identify how customers were to be provided the Act 129 required functionality. Specifically, we proposed that EDEWG report on how the EDCs plan to provide customers with direct access to hourly usage and price information, provide support for automatic control of a customer's electric consumption by the customer, the utility or a customer's agent and provide direct meter access and electronic access to customer meter data by third parties with customer consent. Furthermore, we proposed that EDEWG provide detailed descriptions of any proposed statewide standardized transactions or protocols, if any, for each of the EDCs for providing the required functionality. EDEWG was also to provide estimated system and operational costs, both total and annual, for each utility to provide the required functionality, as well as the ability for a statewide solution with associated costs to provide such required functionality.55
Finally, in the Tentative Order we proposed that this review and analysis be completed with a report to the Commission within 90 days of the entry of a final order. Additionally, to ensure continued EGS engagement in EDC system upgrades and installations, we proposed that EDEWG incorporate these required smart meter functionalities within its current documentation, to include its Implementation Guidelines, Testing and Certification Plans, Revised Plan, Annual Plans, Change Control Request forms and other documentation as deemed necessary by EDEWG.56
Duquesne comments that it needs to progress with its own analysis and developing solutions to propose to the Commission for adoption. Duquesne submits that as statewide or EDEWG solutions become available, Duquesne will decide, with Commission input if needed or advisable, whether it should alter its plan and adopt different options.57
DRSG agrees with the proposal to include all EDEWG participants in the development and ongoing maintenance of new standards and formats to support Act 129 requirements. Regarding standardization efforts, DRSG suggests that ESPI and PAP 10 standards be among those considered and further suggests that a review of other jurisdictions and markets may offer useful examples or lessons learned. DRSG explains that smart meter data is being exchanged among multiple entities today in Texas and Ontario, Canada, with California directing its utilities to implement data exchange with third parties with authorization by consumers.58
DRSG comments that ''direct access'' should mean access by a device in a home or business to information directly from the meter through short-range wireless, power line carrier, or other local communications link. DRSG further comments that ''electronic access'' is understood to mean access to data that was backhauled to the EDC data center, then exchanged via an Internet connection between the EDC and a third party. Regarding automatic control, DRSG presents two primary communications options that are in use in pilot and commercial implementations, a Home Area Network (HAN) and the Internet. DRSG suggests that private wireless or power line carrier networks are other options.59
EAP questions the proposed review of EDC plans by EDEWG, which it believes introduces risk and uncertainty into plans now underway. EAP contends that EDEWG members are technical analysts not policy or cost-benefit analysts and should not be directed to identify data requirements that support identified current and new business processes. EAP expresses concern about tasking a volunteer working group with a 90-day deadline to suggest modifications to smart meter plans.60
EDEWG Leadership asks if it is the Commission's intent to expand the purview of EDEWG to create and maintain new smart meter standards between EDCs and their customers, which to date the sub-group was unable to establish since this is beyond the traditional scope of the EDEWG. EDEWG Leadership comments that standards cannot be defined or fully known until pilot programs are completed or for some EDCs, until their 30-month grace period has expired, since selected technology is being tested during those periods. EDEWG Leadership further comments that EDEWG is confident it can provide descriptions and data exchange standards for newly defined business processes; however, a financial analysis would be beyond the expertise and resources of the volunteers at EDEWG.61
FirstEnergy expresses concern as to whether EDEWG is the appropriate forum for developing smart meter systems or solutions. FirstEnergy suggests that a strategic planning group, such as the collaborative formed at Docket No. I-2011-2237952, relating to the investigation of Pennsylvania's Retail Electricity Market, or a joint venture by EDCs to cover cost sharing, project management, third-party vendor selection and dispute resolution would be better suited for this task. FirstEnergy submits that whatever forum is assigned the task, 90 days is insufficient time for producing a report.62
PECO lists examples of platforms being developed to address direct access information. PECO notes it has invested substantial resources in the implementation of its smart meter plan and to avoid uncertainty among its vendors, contractors and customers, asks that the plan not be subject to revision by EDEWG.63 PECO requests that the Commission clarify whether the Commission is seeking a uniform statewide IT solution or statewide business rules that are more uniform. Even if the request is the analysis of IT aspects of a statewide solution, PECO maintains that 90 days is unrealistic for EDEWG to sort through the differences among the EDCs' internal processes and provide a report. PECO notes that EDEWG lacks the expertise to perform a cost-benefit analysis on the various options and that additional resources or expertise is critical to a meaningful analysis of a statewide solution.64 PECO agrees with the comments of PPL that any new data exchange or access requirements should be incorporated into each EDC's plan and asks that this be accomplished through a focused amendment proceeding that will not subject entire smart meter plans to review and revision.65
PPL is concerned that the activities and timeline proposed by in the Tentative Order are inconsistent with its smart meter plan. PPL believes that only the proposed task relating to standardized transactions and protocols is appropriate for EDEWG and that EDEWG is unable to perform the second task relating to the estimation of PPL's system and operation costs for providing the required functionalities. PPL believes that any effort to develop standards must be driven by the completion of pilots, demonstration of favorable cost-benefit and a decision to proceed with broader implementation in the context of the approved smart meter plans.66
FirstEnergy Solutions asserts that it is imperative to include EGS participation when developing the implementation of smart meter procurement and installation plans. FirstEnergy Solutions supports the implementation of smart meter technology so long as the process takes into account the interests of all stakeholders in the Pennsylvania retail electricity markets.67
After careful consideration of all comments, we find three issues are raised by the parties, the role of EDEWG, the identification of new standards, and the modification of EDCs' smart meter plans. Regarding the role of EDEWG, we believe we sufficiently address this issue and resolve it in the discussions in the preceding section of this Order. We also address and identify potential new standards to be considered for statewide implementation. Specifically, we encourage covered EDCs to engage in the development of NAESB and NIST standards and to incorporate these standards into their respective smart meter plans.
We also strongly encourage EGSs, CSPs and other interested parties to participate in the national standards-setting organizations that are drafting models and standards for direct access and electronic access to smart meters and data for retail markets. Specifically, we encourage EDCs, EGSs, CSPs and other interested parties to actively participate in the NAESB Retail Electric Quadrant Executive Committee's Smart Grid Standards Development Subcommittee, the Smart Grid Standards Subcommittee on Priority Action Plan 10, the Energy Services Provider Interface Task Force, and the joint retail electric/gas Information Requirements and Technical Electronic Implementation Subcommittee (IR/TEIS).68
As PECO comments and others suggest, NAESB has already completed or nearly completed standards that may be useful in the context of Pennsylvania's smart meter implementation.69 The work on the standardized information model for energy usage known as PAP 10 was completed and continues to evolve awaiting technical specifications from the NAESB Retail Energy Quadrant Executive Committee's Information Requirements and Technical Electronic Implementation Subcommittee. In addition, the NAESB\ESPI Task Force is engaged in the standardization of the Open ADE specification, which describes communications between utilities, customers and third-party service providers. The NAESB/ESPI effort is closely coordinated with numerous entities, and the Office of Science and Technology Policy has expressed interest in the standard and has encouraged major utilities to consider it in their implementation efforts.70
We also endorse the Green Button71 initiative and encourage covered EDCs to respond to this endorsement by creating a similar application on their websites.72 Green Button is an industry-led effort based on a common technical standard developed in collaboration with a public-private partnership supported by the NIST.73 Green Button is designed around an open data standard to provide secure customer access to electronic energy usage information.74 It was reported that 20 utilities and major electricity suppliers across the United States and Canada have signed onto this initiative, providing meter data access capability to more than 27 million households secure access to their energy data with a click of an online Green Button.75
Finally, the third issue relates to modifications to EDCs' smart meter plans. The Commission agrees with EAP, PECO and PPL that it is disconcerting to have invested time, money and resources to implement an approved smart meter plan and then have those plans subject to changes and subsequent risks and costs. The Implementation Order provides guidelines and a blueprint for our expectations regarding compliance with Act 129 and the EDCs' smart meter plans. The Implementation Order directed EDCs to work with EDEWG and incorporate identified EDI capabilities in the proposed smart meter plans EDCs would file with the Commission for review. We agree with the comments of EDEWG Leadership and the EDCs, that the approved EDCs' smart meter plans are works-in-progress. Consequently, we will retract our recommendation to have EDEWG review each EDC's smart meter plan for compliance with meeting the required functionalities. We believe that is an issue that should be analyzed by the stakeholders within the context of each EDCs smart meter proceedings. Further, we will retract our recommendation to have EDEWG provide an estimate on the costs incurred by utilities to provide said functionalities.
Conclusion
All smart meter plans were reviewed and approved based upon one or more references by EDCs that they will work with EDEWG on standardization of system capabilities that would be tested or implemented within the 30-month grace period. We look forward to the EDCs providing detailed plans on how they intend to meet all of the Act 129 requirements, including providing customers and their designated third-party representatives with direct electronic access to the customer's electric usage and price data. Therefore,
It Is Ordered That:
1. Electric distribution companies required to submit smart meter technology and implementation plans propose, as part of those plans, Bill Ready and Dual Billing functionalities. If an electric distribution company has already filed its completed smart meter plan, that electric distribution company is directed to file within 120 days under its respective smart meter technology and implementation plan docket a supplement outlining how and when it will incorporate Bill Ready and Dual Billing functionalities into its smart meter implementation.
2. Electric distribution companies required to submit smart meter technology and implementation plans file within 120 days under its respective smart meter technology and implementation plan docket a supplement outlining the EDC's current capability to provide a minimum of 12-months of historical account or meter level usage data via electronic data interchange or which details the EDC's plan to provide this capability within one year.
3. The Electronic Data Exchange Working Group shall convene a web-portal working group including all electric distribution companies required to submit smart meter technology and implementation plans and other interested stakeholders to develop a standardized solution for the acquisition of historical interval usage and billing quality interval usage data via a secure web-portal, as specifically detailed within this Order, for incorporation within each electric distribution company's smart meter technology and implementation plan.
4. Electric distribution companies required to submit smart meter technology and implementation plans propose, as part of those plans, meter level interval usage data capabilities. If an electric distribution company has already filed its completed smart meter plan, that electric distribution company is directed to file within 120 days under its respective smart meter technology and implementation plan docket a supplement outlining how and when it will incorporate meter level interval usage data capabilities into its smart meter implementation.
5. Any directive, requirement, disposition or the like contained in the body of this Final Order that is not the subject of an individual Ordering Paragraph, shall have the full force and effect as if it was fully contained in this part.
6. This Order shall be published in the Pennsylvania Bulletin and served upon the Office of Consumer Advocate, the Office of Small Business Advocate, the Bureau of Investigation and Enforcement, all jurisdictional electric distribution companies, all licensed electric generation suppliers, the Electronic Data Exchange Working Group leadership, and all parties who participated in proceedings at Docket Nos. M-2009-2123944, M-2009-2123945, M-2009-2123948, M-2009-2123950 and M-2009-2123951.
ROSEMARY CHIAVETTA,
Secretary
[Pa.B. Doc. No. 12-2513. Filed for public inspection December 21, 2012, 9:00 a.m.] _______
1 This order was entered on June 24, 2009, at Docket No. M-2009-2092655.
2 Implementation Order at 24-28.
3 Id. at 24.
4 Id. at 25.
5 Id.
6 The status of each EDC's Smart Meter Plan can be obtained by reviewing the proceedings at the following dockets: Duquesne—M-2009-2123948; FirstEnergy— M-2009-2123950 and M-2009-2123951 (West Penn Power Company); PECO—M-2009-2123944 and PPL—M-2009-2123945.
7 See Smart Meter procurement and Installation, Tentative Order at Docket No. M-2009-2092655, entered on July 8, 2011.
8 The Tentative Order was published in the Pennsylvania Bulletin on July 23, 2011 at 41 Pa. Bull. 4066, thus comments were due August 22, 2011, with reply comments due September 12, 2011.
9 The Demand Response and Smart Grid Coalition filed its comments on September 29, 2011, along with a request that its comments be accepted as a late filing, noting that it has sent its comments to Commission staff via email on August 22, 2011. We will grant the request of the Demand Response and Smart Grid Coalition and will accept and consider its comments as part of the record in this proceeding.
10 EDEWG Leadership includes EDC Co-Chair Susan Scheetz (PPL), EGS Co-Chair Matthew Sigg (Constellation NewEnergy, Inc.), and EDI Change Control Manager Brandon Siegel (ISTA North America).
11 Preliminary Proposal at 1.
12 Glossary of EDEWG and EDI Terms, ''Electronic Data Exchange Standards for Electric Deregulation in The Commonwealth of Pennsylvania,'' at 18-19, approved by Tentative Order entered December 8, 2008 at Docket No. M-00960890, F0015.
13 Tentative Order at 5.
14 DRSG Comments at 1-2.
15 Duquesne Comments at 5.
16 FirstEnergy Comments at 3.
17 EAP Comments at 4.
18 EDEWG Leadership Comments at 1 and 2.
19 PECO Comments at 3 and 4.
20 PECO Reply Comments at 1.
21 PPL Comments at 5 and 6.
22 PPL Comments at 9.
23 FirstEnergy Solutions Reply Comments at 1 and 2.
24 Tentative Order at 5.
25 DRSG Comments at 1 and 2.
26 Duquesne Comments at 5 and 6.
27 EAP Comments at 5.
28 EDEWG Leadership Comments at 2.
29 FirstEnergy Comments at 3-5.
30 PPL Comments at 7.
31 PECO Comments at 5.
32 PECO Reply Comments at 2.
33 FirstEnergy Solutions Reply Comments at 2-4.
34 Tentative Order at 6.
35 Duquesne Comments at 6 and 7.
36 DRSG Comments at 1 and 2.
37 EAP Comments at 5 and 6.
38 FirstEnergy Comments at 6 and 7.
39 PECO Comments at 6-8.
40 PECO Reply Comments at 2.
41 FirstEnergy Solutions Reply Comments at 4.
42 PPL Comments at 8 and 9.
43 See Smart Meter Procurement and Installation Implementation Order at Docket No. M-2009-2092655, entered June 24, 2009, at 23.
44 Tentative Order at 6-8.
45 Duquesne Comments at 7.
46 DRSG Comments at 2.
47 Tentative Order at 6 and 7.
48 EAP Comments at 6 and 7.
49 EDEWG Leadership Comments at 3.
50 PECO Comments at 8 and 9.
51 PECO Reply Comments at 1.
52 PPL Comments at 10 and 11.
53 FirstEnergy Solutions Reply Comments at 4 and 5.
54 Green Button is an example of a web-based, end-user meter data access application that is based upon the NAESB/ESPI standards.
55 Tentative Order at 9.
56 Tentative Order at 9 and 10.
57 Duquesne Comments at 8.
58 DRSG Comments at 2.
59 DRSG Comments at 3.
60 EAP Comments at 6-9.
61 EDEWG Leadership Comments at 1-3.
62 FirstEnergy Comments at 8-10.
63 PECO Comments at 9 and 10.
64 PECO Comments at 11 and 12.
65 PECO Reply Comments at 3 and 4.
66 PPL Comments at 11-15.
67 FirstEnergy Solutions Reply Comments at 5.
68 For information on the various NAESB smart grid activities visit: http://www.naesb.org/req/default.asp. For information on how to participate in NAESB visit: www.naesb.org.
69 PECO Comments at 8.
70 NAESB Bulletin Volume 4, Issue 3 (September-December 2011) at 2.
71 For information on the Green Button initiative visit: http://www.greenbuttondata.org/greenabout.html.
72 PUC Chairman, Commissioner Encourage Electric Utilities to Participate in Federal 'Green Button' Initiative, Pa. PUC Press Office (April 12, 2012).
73 Peter Behr, E&E reporter, ''Grid: Downloading energy usage could be one 'green' click away,'' ClimateWire (January 18, 2012).
74 Green Button How To at http://www.greenbuttondata.org/greenabout.html.
75 ''Administration Announces New Tools to Help Consumers,'' Smartgrid.gov, U. S. Department of Energy news.
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