BEFORE THE PUBLIC SERVICE COMMISSION OF MARYLAND

Transcription

1 BEFORE THE PUBLIC SERVICE COMMISSION OF MARYLAND IN THE MATTER OF THE COMMISSION S INVESTIGATION OF ADVANCED METERING TECHNICAL STANDARDS, DEMAND SIDE MANAGEMENT COST EFFECTIVENESS TESTS, DEMAND SIDE MANAGEMENT COMPETITIVE NEUTRALITY, AND RECOVER OF COSTS OF ADVANCED METERS AND DEMAND SIDE MANAGEMENT PROGRAMS Case No REPLY COMMENTS OF TRILLIANT NETWORKS INC. ON THE ADVANCED METERING INITIATIVES AND DEMAND SIDE MANAGEMENT COLLABORATIVE SCOTT H. DEBROFF, ESQUIRE SMIGEL, ANDERSON & SACKS, LLP RIVER CHASE OFFICE CENTER 4431 NORTH FRONT STREET HARRISBURG, PA TEL: (717) FAX: (717) SDEBROFF@SASLLP.COM DATED: JULY 23, 2007 COUNSEL FOR TRILLIANT NETWORKS, INC.

2 BEFORE THE PUBLIC SERVICE COMMISSION OF MARYLAND IN THE MATTER OF THE COMMISSION S INVESTIGATION OF ADVANCED METERING TECHNICAL STANDARDS, DEMAND SIDE MANAGEMENT COST EFFECTIVENESS TESTS, DEMAND SIDE MANAGEMENT COMPETITIVE NEUTRALITY, AND RECOVER OF COSTS OF ADVANCED METERS AND DEMAND SIDE MANAGEMENT PROGRAMS Case No REPLY COMMENTS OF TRILLIANT NETWORKS INC. ON THE ADVANCED METERING INITIATIVES AND DEMAND SIDE MANAGEMENT COLLABORATIVE AND NOW COMES Scott H. DeBroff, Esquire of Smigel, Anderson, & Sacks LLP, on behalf of his client, Trilliant Networks, Inc. ("Trilliant Networks"), and respectfully files these Reply Comments in the above-referenced proceeding. In support of such Reply Comments, Trilliant avers the following: 1. Trilliant Networks, Inc. ("Trilliant Networks") provides open standards-based network solutions to utilities for advanced metering infrastructure (AMI), demand response, and 2

3 grid management. Its solutions enable utilities to better serve their customers, develop new revenue sources, and reduce overall expenses. 2. Trilliant Networks, with its corporate headquarters in Redwood City, California, is primarily focused on advanced metering infrastructure (AMI) solutions, which enable utilities to develop time-of-use (TOU) metering and demand response programs. These programs are transforming the traditional customer-utility relationship through interval based consumption data and 2-way messaging. 3. On or about July 11, 2007, the active parties to this Collaborative filed Comments to the Commission on the issues in this docket. Trilliant filed its Comments and now offers the following Reply Comments on the Commission Issues in the paragraphs ahead. 3

4 REPLY COMMENTS OFFICE OF PEOPLE S COUNSEL 1. In the Comments of the OPC, they indicate that discussions are premature. While we would agree with that, we also believe that the Commission is capable of promoting further process that would accommodate consensus or a litigated proceeding in which these issues would be determined. 2. To the extent that OPC is not certain that AMI should be adopted, we disagree and feel that it is appropriate to adopt AMI as soon as possible. BALTIMORE GAS & ELECTRIC 3. We agree with BGE that the time is ripe in Maryland for both AMI and DSM efforts. 4. BGE stressed the fact that there are several policy decisions that must be addressed prior to adopting AMI such as revenue decoupling, timely cost recovery, and assurance of timely recovery of these costs. While we support adopting AMI, we agree that these policy issues are important. PUBLIC SERVICE COMMISSION STAFF 5. We are supportive of the Staff s position regarding the need for standards and operational capabilities for advanced meters. We are also supportive of the Staff s position that one of the most important features of an effective AMI system includes the promotion of open architecture. 4

5 6. Regarding the appropriate minimum time intervals for the recording and movement of meter data, the Staff indicated that they are considering which time intervals will be appropriate for the AMI system to be able to decipher data. They have also requested that participants to the proceeding perform cost-benefit analyses on their specific time interval of choice in order to recommend which interval is appropriate for Maryland s overall standards. 7. We would agree that there are good reasons to set reasonable minimum standards and support the concept that minimum intervals for data would be set which reflect the AMI system capabilities and the informational needs of the utility. While we understand Staff s position of reserving its recommendation as to minimum standards to be adopted by the Commission for concern that each utility could have differing reasons for different data requirements, Trilliant takes a different position. 8. For purposes of supporting Time of Use (TOU) rates, we believe that hourly interval data is a minimum requirement and that 15 minute interval data would be preferable under particular situations. For purposes of managing effective DSM programs, we believe that 15 minute intervals should be considered as a minimum requirement. In addition, being able to provide even greater amounts of interval data (5 min. or 1 min.) during DSM events (just before, during and after a Critical Peak Power or Curtailment event for example) is highly desirable in order to provide utilities with greater insight on the effectiveness and value of these initiatives. RESA 9. RESA stated in their Comments that they favor a requirement in Maryland that the utilities make 15-minute data available on the utility s web portal the next day. We are very supportive of a call for 15 minute interval data and agree that it brings much value for utilities, 5

6 marketers and customers alike. For Trilliant, 15 minute data involves virtually no added cost to deliver such data to the utility and ultimately to the customer. In the recently approved Texas advanced metering regulations, the Public Utility Commission of Texas (PUCT) set one (1) hour data available the next day as the standard, with a requirement to do a cost-benefit evaluation of 15 minute data. We support that state s efforts. 10. RESA also stated in their Comments that the Commission should adopt rules that establish a minimum threshold of technical capability for advanced meters. We agree and feel that this is an appropriate step in moving forward with utility AMI applications. 11. We also agree that the Commission should take a serious examination of the process as well as the final product that was the Texas Advanced Metering Rulemaking, found at Docket No , when considering adoption of their own standards in Maryland. CHOPTANK ELECTRIC COOPERATIVE 12. We disagree with Choptank s suggestion that each of the distribution utilities should be able to define their own technical standards and operational capabilities of what advanced meters should be. We would certainly support the concept that every utility should be able to identify those operational benefits that they are particularly in need of for their service territory, but we disagree with the concept of allowing each utility to set their own technical standards. We believe that the setting of very limited, minimum technical standards, in regulations, is a very good starting point in terms of implementing advanced meters and creation of an Advanced Metering Infrastructure. 6

7 WASHINGTON GAS LIGHT 13. We support the concept that conservation and energy efficiency programs for application in competitive markets should be analyzed on a multi-fuel and comprehensive basis, taking into consideration all likely impacts of the proposed programs. How such a concept is defined in terms of rules would be up to WGL to suggest. SOUTH RIVER CONSULTING 14. We support the idea of simplicity in the type and amount of information collected and transmitted. We agree with the hourly data being considered as one standard, but would also support, as described earlier in our comments, the ability to value 15 minute data, in order to provide greater capability for customers to participate in DSM programs and have greater visibility into their consumption patterns by having the additional granularity. 15. We support the concept of transparency with customers being able to access their own usage information in a timely manner, particularly current (day after). 16. We agree that cost recovery should be provided for the initial pilot program in an effort to raise general awareness and promote the process of improving information about usage to the residential and other non-interval customers, and we feel that such recovery should take place through rates. WASHINGTON GAS ENERGY SERVICES 17. In their Comments, Washington Gas Energy Services stated that rules that set advanced meter technical standards and operational capabilities will establish an AMI that will support an 7

8 open architecture, provide real-time data access and usage display and facilitate third party addon devices ( AOD ). As stated earlier, we agree that rules should establish a set of minimum technical standards and operational capabilities in the context of AMI to enable cost recovery through rates. 18. We agree that regulatory policies must focus on energy efficiency and conservation and recognize the need for rules that will carry forth such policies in implementing advanced metering technology. 19. We agree that it is highly desirable for advanced meters to capture data at least every fifteen (15) minutes to support effective DSM programs. ENERNOC 20. We agree with EnerNOC and support the deployment of AMI and also feel that it should be done in within the framework of an open, competitive marketplace. 21. Like EnerNOC, we acknowledge that there are security concerns involved with two-way communications. There are NERC standards that cover this type of security in smart meters and we support increased security. CURRENT GROUP 22. We agree with CURRENT in their support of an AMI/DSM open architecture standard that can accommodate different types of metering equipment and DSM devices. Like CURRENT, we are also open to alternative approaches to cost recovery that would encourage AMI/DSM deployments at lower costs. 8

9 Trilliant looks forward to participating in the continuing Collaborative efforts and sharing our thoughts regarding the state of the industry and the capabilities that exist to deliver smart metering. We look forward to being available to provide relevant and current technical information regarding the progress of advanced meter reading (AMR) and the creation of an Advanced Metering Infrastructure (AMI) to this Commission. Respectfully submitted, Dated: July 23, 2007 By: SCOTT H. DEBROFF, ESQUIRE SMIGEL, ANDERSON, & SACKS RIVER CHASE OFFICE CENTER 4431 NORTH FRONT STREET HARRISBURG, PA TEL: (717) FAX: (717) COUNSEL FOR TRILLIANT NETWORKS, INC. 9

10 BEFORE THE PUBLIC SERVICE COMMISSION OF MARYLAND IN THE MATTER OF THE COMMISSION S INVESTIGATION OF ADVANCED METERING TECHNICAL STANDARDS, DEMAND SIDE MANAGEMENT COST EFFECTIVENESS TESTS, DEMAND SIDE MANAGEMENT COMPETITIVE NEUTRALITY, AND RECOVER OF COSTS OF ADVANCED METERS AND DEMAND SIDE MANAGEMENT PROGRAMS Case No CERTIFICATE OF SERVICE I certify that I have by electronic mail and by first class mail, as necessary, provided under the above listed docket numbers, this day served a true and correct copy of the original attached, Reply Comments of Trilliant Networks, Inc. On The Advanced Metering Initiatives And Demand Side Management Collaborative in this proceeding to the Maryland AMI/DSM Collaborative Distribution List. Dated: July 23, 2007 By: SCOTT H. DEBROFF, ESQUIRE SMIGEL, ANDERSON & SACKS, LLP. RIVER CHASE OFFICE CENTER 4431 NORTH FRONT STREET HARRISBURG, PA TEL: (717) FAX: (717) SDEBROFF@SASLLP.COM COUNSEL FOR TRILLIANT NETWORKS, INC.