Request for Approval of Proposal and Cost Recovery for Click- Through Performance Metrics Pursuant to Resolution E-4868

Transcription

1 Erik Jacobson Director Regulatory Relations Pacific Gas and Electric Company 77 Beale St., Mail Code B13U P.O. Box San Francisco, CA Fax: November 22, 2017 Advice 5190-E (Pacific Gas and Electric Company ID U 39 E) Public Utilities Commission of the State of California Subject: Request for Approval of Proposal and Cost Recovery for Click- Through Performance Metrics Pursuant to Resolution E-4868 Purpose Pacific Gas and Electric Company (PG&E) seeks approval from the California Public Utilities Commission (Commission or CPUC) for the proposal and to recover costs to implement systems and build a website to display performance metrics for the clickthrough authentication and authorization processes and associated data delivery used to support Electric Rule 24 (Rule 24). 1 PG&E submits this advice letter in accordance with Ordering Paragraphs (OPs) 21, 26, 27, and 28 of Resolution E-4868 (Resolution), which streamlines and simplifies the direct participation enrollment process and implements an online click-through process that the Commission ordered in Decision (D.) Background D ordered the implementation of Rule 24 for PG&E and SCE and Electric Rule 32 (Rule 32) for SDG&E. Rules 24 and 32 allow third-party DRPs access to retail customers data for purposes of registering them and using their load data in the CAISO 1 Henceforth, any reference made to Rule 24 that refers to the three investor-owned utilities (IOUs) applies to Electric Rule 24 for PG&E and Southern California Edison Company (SCE) and Electric Rule 32 for San Diego Gas & Electric Company (SDG&E). 2 In D , OPs 9 and 10, the Commission ordered the IOUs to convene a meeting with all interested stakeholders to develop an approach to streamlining the direct participation enrollment process. "Click-through" is the process by which a customer authenticates itself with the utility and authorizes the release of its data to a third party, which must start and end on the demand response provider s (DRP) website. The process also authorizes certain actions to take place within the Rule 24 process (e.g., removing C&I customers from the Peak Day Pricing (PDP) program, and reprogramming a residential customer's meter to 15-minute intervals).

2 Advice 5190-E November 22, 2017 market for demand response, but only after obtaining the customer s authorization. This decision ordered the IOUs to work with stakeholders to finalize the Commission staff s proposed Rule 24 and to create related documents to support this rule. The related documents included a specific Customer Information Service Request (CISR) form for DRPs appearing as Electric Form (CISR-DRP), the Service Agreement between the DRP and the utility, the Registration Form for DRPs to register with the Commission, and a standard residential and small commercial customer notification letter that is used for the purposes of Rule 24. On October 10, 2013, PG&E revised the Rule 24 tariff and related documents in Advice 4298-E, 3 which the Commission approved in Resolution E-4630 on March 19, Resolution E-4630 also ordered the IOUs to make modifications to the Form consistent with D (addressing four Petitions for Modification on D ), which were presented to the Commission in Advice 4361-E and 4361-E-A. 4 As described in D , PG&E s process for electronic submission of a CISR-DRP form includes the use of certain third party electronic signature verification vendors, which third-party DRPs criticized as cumbersome for customers. As a result, the Commission found that direct participation is an evolving process that can be improved. 5 The Commission ruled that the utilities should develop a click-through electronic signature process that begins and ends on a third-party DRP s website and provides customer authentication and authorization for the utility to release the customer s data to a third-party DRP. 6 This Decision also ordered the utilities to meet with stakeholders to discuss how to simplify the direct participation enrollment process, and to file a consensus proposal in a Tier 3 advice letter, by November 1, The IOUs and Energy Division hosted the first publicly noticed working group meeting with stakeholders and interested parties on Streamlining and Simplification of Direct Participation Enrollment Process on July 25, Subsequent meetings were held through December 1, DRPs advocated for daily online reporting performance 3 PG&E submitted Advice 4298-E on behalf of the three IOUs. 4 PG&E submitted Advice 4361-E on behalf of itself, SCE, and SDG&E on February 18, 2014, with the revision submitted on April 2, The Commission approved Advice 4361-E and 4361-E-A on April 8, D , Finding of Fact (FoF) D , pages 11-14; FoF 5, 6, and 7; Conclusions of Law (CoL) 2 and 3; OP 1. 7 D , CoL 13; OP 9 and The working group included the utilities, the Energy Division, the Office of Ratepayer Advocates (ORA), Advanced MicroGrid, the California Energy Efficiency Industry Council, Chai Energy, CPower, emotorwerks, EnergyHub, EnerNOC, Mission:Data, NRG, OhmConnect, Olivine, SolarCity, Stem, Sunrun, UtilityAPI, and WeatherBug, as well as individuals interested in the working group discussions but who may not be parties. The Assigned Commissioner s office also attended several of the meetings noticed in the Commission Daily Calendar.

3 Advice 5190-E November 22, 2017 metrics tracking the click-through process, including a list of proposed metrics, within an informal status report filed as a part of the working group process. 9 The IOUs submitted to Energy Division their respective plans for improving the Electric Rule 24 Direct Participation Enrollment Click-Through Process on January 3, PG&E s proposal included posting performance metrics for the click-through authentication and authorization process on a quarterly or monthly basis, due to the time, cost, and complexity required to provide more frequent reporting, and the low priority placed on this topic by stakeholders in the working group. On August 24, 2017, the CPUC issued Resolution E-4868 (Resolution), approving the IOUs respective plans submitted in January 2017, with modifications, including requiring the utilities to develop a publicly available webpage or dashboard to monitor the performance of this click-through solution, which is updated at least daily, with up to a day s delay. Further, the Resolution also required the IOUs to report performance metrics for Rule 24 data delivery, particularly to track missing data or gaps in data, among other aspects. 11 The Commission directed the IOUs to (1) work with stakeholder members of the Customer Data Access Committee (CDAC) to develop a performance metrics website, and (2) submit the consensus proposal to the CPUC s Energy Division within 90 days. 12 The IOUs held several meetings with the CDAC between October 2 and November 14, 2017, to develop the consensus proposal, which is described in detail in this advice letter. 13 Pursuant to Resolution E-4868, D , and D , PG&E hereby submits this request for approval of the consensus proposal and funding authorization 9 PG&E served the Informal Status Report on the service list for A , et. seq. on behalf of the workshop participants on October 12, Appendix E at page 2 described the initial request. 10 PG&E s Advice Letter 4992-E, SCE s Advice Letter 3541-E, and SDG&E s Advice Letter 3030-E were filed in accordance with an extension requested by the IOUs and granted by the Commission s Executive Director on November 1, Resolution E-4868, pp Resolution E-4868, Table 3. In addition, OP 21 ordered the IOUs to capture these performance metrics on an ongoing basis within the Quarterly Report Regarding the Status of Third-Party Demand Response Direct Participation Rule 24 compliance reports, which will be filed through The format of the performance metrics to be added to the quarterly reports will be developed with input by CDAC stakeholder participants. 13 The Energy Division noticed the CDAC meeting with the CDAC list on November 3, 2017, and provided a draft agenda on November 7, On behalf of the IOUs, PG&E noticed stakeholders in A et al and A et al on November 10, 2017, inviting them to participate during the CDAC meeting to discuss this advice letter. PG&E served a subsequent notice on behalf of the IOUs on November 13, 2017, providing an updated time for the discussion of this topic within the CDAC meeting agenda, due to lastminute modifications to the agenda. Several telephone calls were held between the IOUs and one of the stakeholders, Mission:data, which represented the DRPs within the CDAC and served as a point of contact to develop the consensus proposal.

4 Advice 5190-E November 22, 2017 to develop a performance metrics website for tracking the click-through process, data delivery, and data quality. 14 PG&E requests the Commission issue a Resolution approving this Tier 3 advice letter and the proposals contained herein by no later than March 30, 2018, in order to meet Commission requirements, which ordered this performance metrics website to be completed by November 2018 of the click-through project (Phase 3), as described in Table 1 of Resolution E Click-Through Performance Metrics Website Scope and Budget PG&E seeks authorization to (1) build a website to report agreed upon daily aggregated performance metric statistics on user interaction with PG&E-managed authentication and authorization pages, (2) develop systems to capture, aggregate, store, and publish such performance metrics, and (3) incorporate such performance metrics into the Quarterly Report Regarding the Status of Third-Party Demand Response Direct Participation for tracking performance trends over time. The performance metric statistics will be a compilation of page tracking and response times for PG&E-managed, customer-facing web pages that support a DRP s effort in enrolling customers. PG&E will track the number of total visits, as well as the number of unique visitors per page for a particular route a customer takes through the PG&Emanaged portion of the click-through process. PG&E will then compile the response times for its systems, as well as the amount of time a customer spends on the authentication and authorization pages. The following aggregated performance metric statistics will be included in the report: 15 Page views per path Unique visitors per path Response time per page: mean, max standard deviation, and 90 th percentile Dwell time per page: mean, max, standard deviation, and 90 th percentile Performance metric statistics will be updated daily based on the previous day s results, and will aggregate all responses over the selected date range between the prior day and up to 30 calendar days prior. 16 PG&E originally proposed to Energy Division staff to provide the performance metrics on a monthly or quarterly basis. 17 The Commission, however, extended this reporting to 14 See, Resolution E-4868, OP 21, OP 26, OP 27, and OP 28; D , OP 13 and OP 28; and D , OP 3 and OP Resolution, at p. 54. This list also includes metrics developed in the consensus proposal. 16 The data reflected is not specific to individual customers and is effectively anonymized, therefore, it should not be classified as customer data for the purposes of the Commission s minimum aggregation rules. 17 Advice 4992-E, p. 20.

5 Advice 5190-E November 22, 2017 a daily frequency. In addition, the Commission directed the utilities to report the performance metrics via a publicly accessible website, with no more than a day s delay. 18 PG&E, in consultation with DRPs and stakeholders in the CDAC, focused on resolving concerns related to tracking the number of customers taking potential paths through the click-through process, and the time spent between the website redirecting the customer away from the DRP website to the click-through webpage, and then back to the DRP s website. PG&E developed a solution that satisfies the stakeholder s requirements without the unnecessary complexity originally envisioned with the project s scope. 19 Therefore, PG&E does not seek additional cost recovery for this expanded scope, as the budget previously authorized in the Resolution is sufficient to develop this project by Phase 3. Data Delivery Performance Metrics Website Scope and Budget PG&E seeks authorization to recover costs to support the development of performance metrics on data delivery of Rule 24 data items in two categories: (1) aggregate metrics for total synchronous API requests and corresponding response times for the Service Agreements requested, and (2) data availability of key missing data elements under Account Elements, Service Elements, and Demand Response data groups. 20 Metrics will include the following summary statistics on a daily basis, including aggregations over dates up to 30 days prior on a rolling basis, with one day s delay: Synchronous API metrics: Number of total requests Mean response time Median response time Number of requests that resulted in more than 90 second response times Percentage of requests that resulted in more than 90 second response times Account/Service/Demand Response Data Elements: Number of total requests Missing data count Number of requests available within 90 seconds Number of requests available within two days Table 1 describes the incremental budget for the tasks required to develop and report the performance metrics for the data delivery of the Rule 24 data set. These budget 18 Resolution, OP 21 and p On November 14, 2016, Chai Energy provided examples for performance metrics websites from Twitter, Facebook, and Twilio, which would be very costly and complex to develop, and extend far beyond the scope of the needs described in the Resolution and by DRPs. 20 Interval usage and billing data utilize synchronous APIs and are not included in the missing data statistics, however, these metrics will be included in the synchronous API metrics.

6 Advice 5190-E November 22, 2017 estimates are provided within a 50 percent margin of error, and are incremental to previously authorized click-through and Rule 24 budgets. TABLE 1 COSTS TO PROVIDE DATA DELIVERY PERFORMANCE METRICS WEBSITE Line No. Description Cost 1 IT Tasks 2 Data Delivery Performance Metric Website $346,900 3 Project Delivery $8,400 4 Testing $42,000 5 Incremental IT operations and maintenance (O&M) (1st Year) $16,500 6 Total IT Project and IT O&M $413,800 7 Business Tasks $16,800 8 Total IT Project, IT O&M, and Business Tasks $430,600 Cost Recovery Pursuant to OP 28, Table 2, and Table 3 of Resolution E-4868, PG&E seeks recovery of costs totaling $430,600 to fund the performance metrics project described herein within the $10.39 million budget cap approved in D , OP 13, as modified by D PG&E requests flexibility between capital and expense categorization to reduce implementation delays. PG&E plans to use Generally Acceptable Accounting Principles and internal software capitalization principles where applicable under Commission rules. PG&E has already requested $1.914 million of this $10.39 million budget cap in Advice 5014-E to support up to 75,000 Rule 24 registrations 21 and $1.971 million in Advice 5165-E to support costs to modify the CISR-DRP Form and expand the Rule 24 data set. 22 Though the Commission has not yet approved this cost recovery, adequate funds remain to support the incremental funding requested in this advice letter under this cap if the Commission approves both of the other advice letters as filed. PG&E plans to fund a portion of the ongoing operations and maintenance of these projects using funding that PG&E requested authorization in Application (A.) , 21 PG&E proposed to provide 75,000 total Rule 24 registrations, which represents an incremental 35,000 registrations above the Intermediate Implementation Step of 40,000 registrations. As of the date of this filing, this AL has not yet been approved. 22 Advice 5165-E.

7 Advice 5190-E November 22, 2017 under the Direct Participation Electric Rule 24 Operation & Maintenance budget. As of the time of this filing, the Commission has issued a proposed decision on this application, asking for additional information before this funding can be approved. PG&E plans to provide additional information to support this funding request. PG&E clarifies that this project relies on such funding approval in order for the Rule 24 team to support these projects between 2018 and Conclusion and Relief Requested PG&E requests the Commission issue a Resolution by no later than March 30, 2018, approving these proposals and $430,600 of funding to implement systems and build a website to display performance metrics for the click-through authentication and authorization processes. 23 Protests Anyone wishing to protest this filing may do so by letter sent via U.S. mail, facsimile or , no later than December 12, 2017, which is 20 days after the date of this filing. Protests must be submitted to: CPUC Energy Division ED Tariff Unit 505 Van Ness Avenue, 4th Floor San Francisco, California Facsimile: (415) EDTariffUnit@cpuc.ca.gov Copies of protests also should be mailed to the attention of the Director, Energy Division, Room 4004, at the address shown above. The protest shall also be sent to PG&E either via or U.S. mail (and by facsimile, if possible) at the address shown below on the same date it is mailed or delivered to the Commission: Erik Jacobson Director, Regulatory Relations c/o Megan Lawson Pacific Gas and Electric Company 77 Beale Street, Mail Code B13U P.O. Box San Francisco, California See Table 1 of Resolution E-4868.

8 Advice 5190-E November 22, 2017 Facsimile: (415) PGETariffs@pge.com Any person (including individuals, groups, or organizations) may protest or respond to an advice letter (General Order 96-B, Section 7.4). The protest shall contain the following information: specification of the advice letter protested; grounds for the protest; supporting factual information or legal argument; name, telephone number, postal address, and (where appropriate) address of the protestant; and statement that the protest was sent to the utility no later than the day on which the protest was submitted to the reviewing Industry Division (General Order 96-B, Section 3.11). Effective Date Pursuant to General Order (GO) 96-B, D , and Resolution E-4868, this advice letter is submitted with a Tier 3 designation and will be effective upon Commission resolution. Notice In accordance with General Order 96-B, Section IV, a copy of this advice letter is being sent electronically and via U.S. mail to parties shown on the attached list [and the parties on the service list for A , et al., A , et al. and R Address changes to the General Order 96-B service list should be directed to PG&E at address PGETariffs@pge.com. For changes to any other service list, please contact the Commission s Process Office at (415) or at Process_Office@cpuc.ca.gov. Send all electronic approvals to PGETariffs@pge.com. Advice letter filings can also be accessed electronically at: /S/ Erik Jacobson Director, Regulatory Relations Attachments cc: Service List A , et al., A , et al., and R

9 CALIFORNIA PUBLIC UTILITIES COMMISSION ADVICE LETTER FILING SUMMARY ENERGY UTILITY MUST BE COMPLETED BY UTILITY (Attach additional pages as needed) Company name/cpuc Utility No. Pacific Gas and Electric Company (ID U39 E) Utility type: Contact Person: Kingsley Cheng ELC GAS Phone #: (415) PLC HEAT WATER and EXPLANATION OF UTILITY TYPE ELC = Electric GAS = Gas PLC = Pipeline HEAT = Heat WATER = Water (Date Filed/ Received Stamp by CPUC) Advice Letter (AL) #: 5190-E Tier: 3 Subject of AL: Request for Approval of Proposal and Cost Recovery for Click-Through Performance Metrics Pursuant to Resolution E-4868 Keywords (choose from CPUC listing): Compliance, Agreements AL filing type: Monthly Quarterly Annual One-Time Other If AL filed in compliance with a Commission order, indicate relevant Decision/Resolution #: E-4868 Does AL replace a withdrawn or rejected AL? If so, identify the prior AL: No Summarize differences between the AL and the prior withdrawn or rejected AL: Is AL requesting confidential treatment? If so, what information is the utility seeking confidential treatment for: No Confidential information will be made available to those who have executed a nondisclosure agreement: N/A Name(s) and contact information of the person(s) who will provide the nondisclosure agreement and access to the confidential information: Resolution Required? Yes No Requested effective date: Upon Commission Approval Estimated system annual revenue effect (%): N/A Estimated system average rate effect (%): N/A No. of tariff sheets: N/A When rates are affected by AL, include attachment in AL showing average rate effects on customer classes (residential, small commercial, large C/I, agricultural, lighting). Tariff schedules affected: N/A Service affected and changes proposed: N/A Pending advice letters that revise the same tariff sheets: N/A Protests, dispositions, and all other correspondence regarding this AL are due no later than 20 days after the date of this filing, unless otherwise authorized by the Commission, and shall be sent to: California Public Utilities Commission Energy Division EDTariffUnit 505 Van Ness Ave., 4 th Flr. San Francisco, CA EDTariffUnit@cpuc.ca.gov Pacific Gas and Electric Company Attn: Erik Jacobson Director, Regulatory Relations c/o Megan Lawson 77 Beale Street, Mail Code B13U P.O. Box San Francisco, CA PGETariffs@pge.com

10 PG&E Gas and Electric Advice Filing List General Order 96-B, Section IV AT&T Don Pickett & Associates, Inc. Office of Ratepayer Advocates Albion Power Company Douglass & Liddell OnGrid Solar Alcantar & Kahl LLP Downey & Brand Pacific Gas and Electric Company Anderson & Poole Ellison Schneider & Harris LLP Praxair Atlas ReFuel Energy Management Service Regulatory & Cogeneration Service, Inc. BART Evaluation + Strategy for Social SCD Energy Solutions Innovation Barkovich & Yap, Inc. G. A. Krause & Assoc. SCE Braun Blaising Smith Wynne P.C. GenOn Energy, Inc. SDG&E and SoCalGas CalCom Solar Goodin, MacBride, Squeri, Schlotz & SPURR Ritchie California Cotton Ginners & Growers Assn Green Charge Networks San Francisco Water Power and Sewer California Energy Commission Green Power Institute Seattle City Light California Public Utilities Commission Hanna & Morton Sempra Utilities California State Association of Counties ICF Southern California Edison Company Calpine International Power Technology Southern California Gas Company Casner, Steve Intestate Gas Services, Inc. Spark Energy Cenergy Power Kelly Group Sun Light & Power Center for Biological Diversity Ken Bohn Consulting Sunshine Design City of Palo Alto Leviton Manufacturing Co., Inc. Tecogen, Inc. City of San Jose Linde TerraVerde Renewable Partners Clean Power Research Los Angeles County Integrated Waste Tiger Natural Gas, Inc. Management Task Force Coast Economic Consulting Los Angeles Dept of Water & Power TransCanada Commercial Energy MRW & Associates Troutman Sanders LLP Cool Earth Solar, Inc. Manatt Phelps Phillips Utility Cost Management County of Tehama - Department of Public Marin Energy Authority Utility Power Solutions Works Crossborder Energy McKenna Long & Aldridge LLP Utility Specialists Crown Road Energy, LLC McKenzie & Associates Verizon Davis Wright Tremaine LLP Modesto Irrigation District Water and Energy Consulting Day Carter Murphy Morgan Stanley Wellhead Electric Company Defense Energy Support Center NLine Energy, Inc. Western Manufactured Housing Communities Association (WMA) Dept of General Services NRG Solar Yep Energy Division of Ratepayer Advocates Nexant, Inc.