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12-13-11 IN THE MATTER OF THE APPLICATION OFOKLAHOMA GAS AND ELECTRIC COMPANY FOR AN ORDER OF THE COMMISSION GRANTING PRE-APPROVAL OF DEPLOYMENT OF SMART GRID TECHNOLOGY IN ARKANSASAND AUTHORIZATION' OF A RECOVERY RIDER AND REGULATORY ASSET
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IN THE MATTER OF THE APPLICATION OF OKLAHOMA GAS AND ELECTRIC COMPANY FOR AN ORDER OF THE COMMISSION GRA11TING PRE-APPROVAL OF DEPLOYMENT OF SMART GRID TECHNOLOGY IN ARKANSAS AND AUTHORIZATION' OF A RECOVERY RIDER AND REGULATORY ASSET
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DOCKET NO. 10-109-U ORDER NO. 8
ORDER
In this Order, the Arkansas Public Service Commission ("Commission") approves
the Settlement Agreement filed in this docket on June 22, 2011, by the Oklahoma Gas
and Electric Company ("OG&E" or "Company"), the General Staff of the Arkansas Public
Service Commission ("Staff'), the Attorney General of Arkansas ("AG") and Gerdau
MacSteel ("Gerdau") (collectively, "the Parties").
Procedural History
On December 17,2010, OG&E filed in this Docket its Application for an Order of
the Commission Granting Pre-approval of the Deployment of Smart Grid Technology
in Arkansas and Authorizaiicm of a Recovery Rider and Regulatory Asset
("Application"), requesting that the Commission issue an Order granting pre-approval
for the deployment of Smart Grid technology in its service territory in Arkansas; and for
the of a Smart Grid Rider to recover the annual revenue requirement
with the deployment of the Smart Grid technology. In support of its
OG&E filed the initial Direct Testimony of OG&E witnesses Kenneth Grant,
Jesse Langston, Scott Milanowski, and Bryan Scott.
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Docket No. 10-109-U Order No.8 Page 2 of 25
By Order No. 1, issued January 11, 2011, the Commission suspended OG&E's
Application pursuant to Ark Code Ann. § 23-4-407 pending further investigation by the
Commission. By Order No. 4, issued March 14, 2011, the Commission established a
procedural schedule for consideration of OG&E's Application including the setting of an
evidentiary hearing to begin on June 27, 2011.
On May 20, 2011, pursuant to the procedural schedule established by Order No.
4, the Staff ified the Direct Testimony and Exhibits of J. Richard Uornby, Elana Davis,
Gayle Freier, and Diana K. l3renske. Also on May 20, 2011, the AG filed the Direct
Testimony and Exhibits of Barbara it Alexander. On June 3, 2011, OG&E filed the
Rebuttal Testimony of Howard Motley. Additionally, on June 17, 2011, Staff and the AG
filed the Surrebuttal Testimony of their respective witnesses, and Gerdan filed the
Surrebuttal Testimony of Mark E. Garrett.
On June 22, 2011, the Parties filed a Joint Motion to Approve a Settlement
Agre ement supported by the Settlement Agreement Testimony of OG&E witness Donald
R. Rowlett;AG witness M. Shawn McMurray Gerdau witness Mark E. Garrett; and Staff
witness Diana Brenske. The Parties also asked that the Commission excuse from the
scheduled evidentiary hearing all witnesses with the exception of the Settlement
Agreement witnesses. By Order No. 7, issued June 24, 2011, the Commission excused
all non-Settlement Agreement witnesses from the scheduled June 27, 2011, hearing,
with the exception of any OG&E witnesses who were able to address issues regarding the
Company's Customer information Privacy and Security Plan and Customer Education
Plan.
The Commission conducted a public evidentiary hearing regarding the proposed
Settlepient Agreement on June 27, 2011, holding the record open for further
Docket No. 10-109-U Order No. 8 Page 3of25
Commission-directed filings, which were filed in this docket on June 29, 2011, July 1,
2011, July 5, 2011, and July 15, 2011.
OG&E's Application
By its Application, OG&E seeks pre-approval by the Commission of the
deployment of Smart Grid technology in its service territory in Arkansas; the
authorization of a Smart Grid Rider to recover the annual revenue requirement for
Smart Grid deployment until a subsequent OG&E rate case when the revenue
requirement would be incorporated into OG&Es base rates; and the creation of two
regulitory assets - the first for certain Smart Grid operation and maintenance ("O&M")
costs and the second for stranded costs related to the retirement of existing meters.
OG&E also requests suspension of various meter test schedules during deployment of
the Smart Grid system, pointing out that, since all existing electric meters will be
replaced prior to the end of 201, there is no need for such tests under Rule 7.08 of the
Commission's Special Rules - Electric.
OG&E witness Kenneth Grant explains that Smart Grid is the integration of
advanced metering capabilities, communications systems, automation and information
technology on the electric distribution system. This includes digital meters on
customer's premises with the ability to provide both the company and the customer with
usage information regarding energy consumption ("Smart Meters"), monitoring/control
equipment in the distribution system, a communications system to allow remote
monitoring and control over the electric grid, as well as security protocols to protect
both end user information (i.e. privacy concerns) and national security requirements for
critical infrastructure. Direct Testimony of Kenneth Grant, Transcript ("Tr.") at 25-31.
OG&E's proposed Smart Grid program includes all of these components as well as a
Docket No. io-iog-U Order No. 8 Page 4of25
prop sed plan for customer engagement and education that has been deemed essential
to a successful deployment of advanced infrastructure to an industry that has not
significantly updated their business model for customer relations in decades. Id. at 34.
Mr. Grant describes these specific components of the OG&E Smart Grid Plan:
• Distribution System Automation - This is the network of feeder
meters, capacitor bank controllers and fault indicators that is placed on
the distribution network to monitor and control power flows and
outages, as well as to provide efficiency improvements within the
distribution network. The automated Distribution System
communicates with both the Advanced Metering Network and the Data
Management network to provide OG&E with near-real-time data
regarding faults, outages, and flows on the distribution system.
• Advanced Metering Network - This element includes the intelligent
digital meters and the supporting technology infrastructure that allows
for two-way communications, interval billing, remote meter reading,
and remote service activation/deactivation. These meters allow for
faster outage notification and validation of service restoration. They
will also allow customer-enabling technology such as in-home displays,
programmable thermostats, and web based data sources to relay
electric usage information back to the customer. The Advanced
Metering network is further broken down into the following
components:
o The Advanced Metering Communications Network, which
allows near-real-time, two-way communications between the
Docket No. 10-109-U Order No.8 Page 5 of
customer and OG&E. This network includes the digital meter
itself and the communications network that allows the meters to
communicate back to OG&E.
o The Advanced Metering Head End, which is the
communications software interface that allows the
communications from the Advanced Metering Communications
Network to the Meter Data Management System.
o The Meter Data Management System, which is the data
warehouse that allows for interaction with the customer
information system.
o The Home Area Network, which consists of the devices, such as
communicating thermostats and in-home displays that are used
to display price and electricity consumption information to the
customer on the customer side of the meter.
Id. at 27-30. OG&E refers to this integration of advanced technologies and customer
programs, specifically including price response programs, as its Positive Energy® Smart
Grid program. Id. at 25-26.
OG&E has approximately 776,.5oo customers of which approximately 64,700
(8.3%) are located in Arkansas. Application at 1. The Company began evaluating
intelligent digital meters ("Smart Meters") and Advanced Metering Infrastructure in
2007 and conducted a Smart Grid technology pilot in northwestern Oklahoma City in
2008. Id. at 3-4. In July 2009 OG&E received approval from the Oklahoma
Corporation Commission ("0CC") to proceed with a Phase 1 deployment of Smart Grid
Docket No. 10-109--U Order No.8 Page 6 of 25
in Norman, Oklahoma, and deployed approximately 42,000 Smart Meters for
residential and small commercial customers by May 15, 2010. Id. at 4.
In August of 2009 OG&E filed an application seeking federal stimulus grant
funding with the United States Department of Energy ('DOE") which resulted in an
award to OG&E of $13o million to deploy Smart Grid Technology in OG&E's entire two-- -
state footprint. Id. To receive the full amount of funding, OG&E committed to expend
$3574 million over a three-year period starting in 2010 and ending in 2012 for system-
wide deployment of Smart Grid technology. Grant Direct at 10. In July 2010, the 0CC
approved full deployment and cost recovery for Smart Grid technology throughout
OG&'s Oklahoma service territory. AL at 2.
According to OG&E, the federal funds maybe used to match certain expenditures
by OG&E, and restrictions contained in the grant include a window in which OG&E can
receive reimbursement of approved levels of Smart Grid costs. This window extends to
the end of 2012 and includes a portion of the costs for the Norman deployment, the
installation of smart meters across the entire OG&E system, the communications
network, the distribution management system, circuit upgrades on a portion of the
Company's distribution systems, as well as testing for verification of expected Smart
Meter-enabled Demand Response. Application at 4. OG&E states that grant funds
allocated for use in Arkansas for deployment of Smart Grid technology, should its
Arkansas Application not be approved, will be reallocated to the Company's Oklahoma
jurisdiction. Id.
According to Mr. Grant, if its Application is approved, deployment in Arkansas
will begin toward the end of 2011 with the installation of a Wide-Area Network, a part of
the multi-tiered communications network that will support the operational
Docket No. 10-109-U Order No.8 Page 7 of 25
requirements of the Distribution System Automation devices and metering access points
distributed throughout OG&E's system. Grant Direct, Tr. at. 35. Deployment of Smart
Metes and Local-Area Network devices in Arkansas is scheduled to begin by March
2012 and be completed by May 2012. Id. The Local-Area Network is a wireless network
linking the metering access points to the individual Smart Meters installed on buildings
and homes, through which data may flow from meter to meter and from meter to the
access points. Likewise, Mr. Grant states that deployment of Distribution System
Automation equipment in Arkansas is scheduled to begin in 2011 and to be completed in
2012., Id.
Once the Advanced Metering Infrastructure deployment is completed, around
May 2012, Mr. Grant states that OG&E will be able to offer an Energy Information
Website to all customers with a Smart Meter. This website will allow customers to
monitor their usage data, pricing information, and overall energy cost. Id. at 36. OG&E
will offer this tool, along with Variable-Peak or Time-of-Use pricing tariffs to help
customers achieve savings by shifting peak energy usage to off-peak. AL According to
Mr. Grant, OG&E plans to provide a significant amount of education to help customers
use the website and pricing programs effectively. Id.
OG&E estimates that, of the $357.4 million total cost for the program in both
jurisdictions, the DOE grant will cover $126.9 million, or approximately 36% of total
costs of deployment, for a net ratepayer cost of $230.5 million. Id. at 13; Rebuttal
Testimony of Howard W. Motley, Tr. at tot Staff testifies that approximately 8.32% of
the net project cost, amounting to about $19 million, would be allocated to Arkansas
using the system allocation methodology adopted in OG&E's last rate case (Docket No.
10-067-U). Breuske Direct, Tr. at 307.
Docket No. 10-109-U Order No.8 Page 8 of
OG&E asserts that the annual revenue requirement for Arkansas, based upon
OG&l's current authorized rate of return and estimated Smart Grid expenditures offset
by DOE funding and after credit for direct savings from the Smart Grid Program, would
be $4374,5oo for 2oll (Jul.-Dec.), $3,254,889 for 2012, $3,062,248 for 2013, and
$1,38,362 for 2014 (Jan.-Jun.). Scott Direct, Exhibit BJS-i, Tr. Ex. at 14. Based upon
monthly residential consumption of i,ioo kilowatt-hours ("kWh"), the average customer
monthly bill impact (net of fuel and benefits) would be $1.41 in 2011, $1.62 in 2012,
$L37in 2013, and $1.25 in 2014. Scott Direct, Tr at 68 and Tr. Ex at 18-21.
Staff initially recommended approval of OG&E's Application subject to certain
specific conditions summarized in the Direct Testimony of Staff witness Brenske.
Brenske Direct, Tr. at 313-321. AG witness Alexander recommended rejection of
OG&E's Advanced Metering Infrastructure proposal; however, she recommended
several conditions that the Commission should impose if it approves OG&E's
Application. Alexander Direct, Tr. at 236-238.
Staff responded to OG&E witness Howard Motley's Rebuttal Testimony, again
recommending that the Commission impose upon OG&E the conditions outlined in
Staffs Direct, as well as additional conditions recommended in its Surrebuttal
Testimony. Brenske Surrebuttal, Tr. at 326-330, Hornby Surrebuttal, Tr. at 296-299;
Davisl Surrebuttal, Tr. at 356-360, and Freier Surrebuttal, Tr. at 374-377. Ms.
Alexander, for the AG, acknowledged that Staffs recommended conditions "are headed
in the correct direction," although she did not change her overall conclusions and
recommendations. Alexander Surrebuttal, Tr. at 244-245.
Gerdau witness Garrett objected to Staffs proposal to allocate the Smart Grid
Program costs to pU customer classes, supporting instead OG&E's proposal to allocate
Docket No. 10-109-U Order No.8 Page 9 of 25
such costs only among retail customers in Service Classes 3, 4 and 5 "because customers
in these service ... [classes] are distribution-level customers and costs for [the] Smart
Grid Program are primarily distribution-related costs." Garrett Surrebuttal, Tr. at 161.
Mr. Garrett further notes that Service Class 1 and 2 customers were not included in
OO&E's original proposed allocation because these customers are transmission-level
customers and are thus not cost-causers for Smart Grid implementation. Id. at 161-162.
Mr. Garrett proposes an alternative cost allocation that would "fairly assign" the Smart
Grid costs to all rate classes. Id
The Settlement Agreement
Under the Settlement Agreement (appended to this Order) all Parties agree to
adopt Staffs Direct and Surrebuttal case with regard to modifications to the OG&E
proposed SGR Rider, with two further modifications to Staffs recommendations. The
two further modifications would reduce SGR Rider revenue by the level of guaranteed
O&M reductions, and would exclude the O&M expenses incurred for the Norman,
Oklahoma deployment in 2010. The SGR Rider changes recommended by Staff in its
Direct and Surrebuttal case, as outlined in Attachment 1 to the Settlement Agreement,
are as follows:
i. The Rider shall only include historical, prudently incurred incremental
costs associated with the deployment of Smart Grid; Staff witness Fiana
Davis Direct Testimony at 3.
2. The Rider shall be based on the used-and-useful principle, with no costs
included in the revenue requirement and recovered before the cost is
incurred and Smart Grid meters are in service; Id.
Docket No. 10-109-U Order No. 8
Page ia of 25
3. The Rider shall include the formula for calculating the annual revenue
requirement; Id. at 3-4.
4. The Rider shall remain in effect until new rates are implemented as the
result of the planned 2013 rate case; Id. at 4.
5. The regulatory asset for O&M expenses incurred prior to the
implementation of the SGR Rider, without carrying charges, shall be
approved; no O&M expense related to the Norman project which was
incurred in 2010 shall be included; any non-incremental costs shall be
excluded; and the Rider shall include amortization of this regulatory asset
over five years, provided the expenditures are properly documented, and
subject to audit in the Company's next general rate case; Id. at 5.
6. The Rider shall reflect the rate of return approved in Docket No. 10-067-
U; Id. at 6.
7. The Rider shall reflect the depreciation rates recommended on page
Table 3 of the Direct Testimony of Staff witness Gayle Freier; AL
8. A regulatory asset for the early retirement of standard meters shall be
allowed, without accrual of carrying charges, for the balance in the
standard meter account at early retirement. However, the Rider shall not
include any amortization or return amounts for standard meters. The
Commission reserves until OG&E's next rate ease a final determination of:
i) the appropriate amount of the balance in the standard meter account at
early retirement and 2) the period for rate recovery, and no amortization
or return amounts shall be included in the Rider calculations; Id., Freier
Direct at 8-9.
Docket No. 10-109-U Order No.8
Page ii of 25
9. The Rider shall reflect that to the extent OG&E seeks to use different
depreciation rates than those approved in Docket No. 10-067-U' or in this
Docket, OG&E is required to file an application for such changes with
supporting documentation for Commission review and approval; Jreier
Surrebuttal at 2.
10. The Rider shall be reduced annually by the revenue requirement
associated with standard meters as included in the rates in Docket No. 10-
067-U upon retirement of the standard meters and deployment of Smart
Grid; Davis Direct at 7.
ii. The Rider shall be fully credited for any Smart Grid amounts - expenses,
investment, return, etc. - inadvertently included in rates in Docket No. 10-
067-U for the full period of their inclusion; Id.
iz. The Rider shall include the level of Guaranteed O&M Reductions offered
by the Company to reduce the SGR Rider revenue requirement; Id at 8-9.
i. The Rider shall provide that the billing determinants will be the same
methodology as used in the determination of the billing determinants for
the Company's Rider ECR; Id. at 9.
14 The Rider shall allocate Smart Grid costs to all of the service levels within
the classes such that there will be a separate rate calculated for each
service level within each class using an allocator based on Total
Distribution Plant less Acct. 360 land and land rights, consistent with the
Docket No. 10-067-U compliance cost of service study 0-4; Id. at io.
OG&Es most recent rate case proceeding which was resolved by final Order No. 6, issued by the Commission on June 17, 2011.
Docket No. 10-109-U Order No.8
Page 12 of 25
15. The Rider shall provide for the annual true-up to be accompanied by
testimony and workpapers sufficient to fully replicate the calculations of
the revised SGR factors; H. at ii.
16. The Rider shall provide that the Commission explicitly reserves a finding
of value for Smart Grid for ratemaking purposes until a future rate case
when base rate recovery is sought. Id. at 11; and
17. The Rider shall provide that all collections under the SGR Rider be subject
to refund, with interest, after notice and hearing to determine prudence.
Id.
In addition to the changes to the Rider agreed to by the Parties, the Agreement
provides as follows:
• Reporting Requirements. OG&E will report the cost and benefits
associated with the Smart Grid project using the metrics filed in the
Agreement (Settlement Attachment 2). OG&E will establish a baseline
2010 System Average Interruption Duration Index ("SAIDI") and will
report the results to the Conlmission. 2
Meter Testing. Special Rules —Electric Rule 7.08.13 (Meter Testing
Programs and Filing Requirements) should be temporarily waived and
OG&E will file an appropriate revision to its tariff to reflect such
waiver.
2 SATIM is a commonly used reliability indicator in the electric utility industry. SAIDI is usually defined as the average outage duration that each customer will experience over the course of a year.
Docket No. 10-109-U Order No.8
Page 13 of
• Remote Disconnect.
a OG&Es involuntary disconnect process shall not be substantially
changed during this deployment phase in Arkansas. OG&E will
continue to make two phone calls - the first automated and the
second a person-to-person contact - informing residential
customers of an impending involuntary disconnection of service. If
OG&E is unable to contact the customer by phone, an OG&E
representative will visit the customer premises in an attempt to
notify the customer of disconnection and offer a last opportunity to
avoid disconnection. A door hanger informing the customer of the
disconnection of service and how to be reconnected will be left on
the premises if the customer is not home during the attempted
visit. Customers subject to an involuntary disconnection of service
will be assessed the Reconnection Fee and the Collection Fee
pursuant to OG&E's current tariff.
o OG&E will follow the established customer premises visit process
for customers who have not been contacted by telephone prior to
an involuntary disconnect until its next rate case where this
process will be further evaluated. To enable effective evaluation of
that process, OG&E will provide Staff with an annual report
detailing the number of premises visits made pursuant to this
Agreement, the amounts collected via the Reconnection Fee and
the Collection Fee, the costs associated with the premises visits and
any applicable ratepayer benefits pursuant to the Agreement.
Docket No. 10-109-U Order No. B
Page 14 of 25
o OG&E's Reconnection Fee and Collection Fee will be discontinued
on the date the SGR Rider goes into effect, except as associated
with the involuntary disconnection process. However, OG&E is not
precluded from proposing new or revised Reconnection Fee or
collection Fee in any future rate case.
. Customer Eduation Plan. OG&E, with input from all Parties, will
develop a comprehensive Customer Education Plan consistent with the
budget agreed upon by the Parties and presented to the Commission
and will file this comprehensive Customer Education Plan in this
Docket within 90 days of an Order approving this Settlement
agreement. The Customer Education Plan will include a provision that
OG&E will mail a free Home Energy Report to customers who
participate in the Smart Grid Usage programs but who do not have
internet access.
. Customer Information Privacy and Cyber-Security Plan. OG&E will file
in this Docket within go days of an Order approving this Settlement
agreement a comprehensive Customer Information Privacy and Cyber-
Security Plan for the Commission to review and approve.
The Settlement Agreement summarizes OG&E's compliance filing obligations,
providing that, with input from Staff, the AG, and Gerdau, OG&E will within 90 days of
the issuance of the order in this case file the following documents in this docket for
Commission review and approval:
. An SGR Rider reflecting each of the provisions of Staffs testimonies,
modified to reflect the Agreement regarding Guaranteed O&M
Docket No. 10-log-U Order No. 8
Page 15 of 25
reductions and the exclusion of Norman O&M expenses incurred in
2010, as summarized in Attachment 1;
. A detailed reconciliation of all of the Smart Grid costs included in
Docket No. 10-067-U;
,. A detailed reconciliation of the standard meter revenue requirement
included in Docket No. 10-067-U;
A Customer Education Plan;
• A Customer Information Privacy and Security Plan;
Tariff revisions to reflect the waiver of Special Rules - Electric Rule
7.08 B and the application of the Reconnection Fee and Collection Fee;
and
,. The method for calculating System Average Interruption Duration
Index ("SAID!") and the 2010 benchmark.
The Settlement Agreement further provides that the Reporting Requirements
identified in Attachment 2, the SAID! calculation, and the report detailing premises
visits made pursuant to provisions of the Agreement, the amounts collected pursuant to
the Reconnection Fee and Collection Fee, the cost of conducting the premises visits, and
applicable benefits pursuant to the Agreement will be filed annually in this Docket at the
same time as the SGR Rider, along with supporting workpapers, and will be based upon
the previous calendar year's actual data.
The Settlement Agreement Hearing
During the Settlement Agreement hearing conducted on June 27, 2011, the
Commission heard testimony from OG&E settlement witnesses Rowlett, Grant, and
Docket No. 10-109-U Order No. 8
Page i6 of 25
thncrier. Company witnesses provided the following information in response to
Commission questions:
• The Smart Grid application was not a part of the just-concluded OG&E
rate case (Docket No. 10-067-U) because installation of the Smart Grid
equipment is expected to occur well after the end of the test year for
that case. According to Mr. Rowlett, a general rate case looks back at
what has already happened and factors in some future events, but this
project was new and unique and thus fit better in a separate
application. Tr. at 121.
• OG&E agrees with Staff's Direct and Rebuttal case that provides that a
prudence determination will be delayed until the next rate case. Mr.
Rowlett stated that "it was always [OG&E's] intent and be1ief that
there would be a review of what money was spent and cost incurred to
make sure that those were prudent expenditures and it met ... the
general criteria applied at the Arkansas Commission for a prudent
expenditure. Id. at 122.
• OG&R agrees that the Settlement Agreement and preapproval of the
Smart Grid technology and SGR Rider apply only to Phase II of the
project and that no cost recovery of anything in Phase Ill to be
included in rates. Mr. Rowlett testified that Phase II will be beneficial
to ratepayers and to OG&E irrespective of whether Phase lii is ever
approved. Id. at 124.
• Mr. Rowlett testified that one of the revisions to OG&E's initial request
as a result of Staffs ease is that OG&E "won't begin collecting money
Docket No. 10-109-U Order No.8
Page 17 of
through the rider until all of the meters are installed" and that,
although a regulatory asset will be recognized for retired meters, as
requested in the Company's initial case, this asset "will not carry a
carrying charge, and the amortization period and the recovery
mechanism will be determined in the next OG&E rate case, so they will
not be part of the rider." Id. at 131.
. The regulatory asset to capture the development cost for Smart Grid
will not include the 2010 costs incurred for the Smart Grid project or
the pilot project in Norman, but Arkansas customers would pay their
jurisdictional share of the 2009 costs of the Norman project related to
acquiring the DOE grant, and those costs would be included in the
regulatory asset. Id. at 132 and 135-136.
• Arkansas rates will not include of any of the costs of the northwest
Oklahoma City technology demonstration. Id. at 138,
• OG&E has a Customer Education Plan for Oklahoma that would be the
same plan the Company will propose for Arkansas. Id. at 147.
. OG&E has a cyber-security plan that had to be filed with DOE as a part
of OG&E's grant agreement, and it will apply for the Arkansas case. Id.
at 149.
• OG&E will not charge customers for an involuntary disconnection
accomplished remotely, without a premises visit. Id. at 151.
. One of the advantages of OG&E's remote connect is that when
customers go to a payment agent, they usually get reconnected within
Docket No. 10-109-U Order No.8
Page iS of 25
20 to 30 minutes on average and in the evening and over the weekend.
Id. at 152.
• To date, because of its workforce retraining and severance programs,
OG&E has not had to lay off any of its employees as the result of
implementing Smart Grid in Oklahoma and has been able to place over
6o of its former meter readers and field personnel in other entry level
positions. Id. at 153.
Staff witness Diana Brenske supported the Settlement Agreement noting that the
Company's modified proposed SGR Rider with regard to the Guaranteed O&M savings
is reasonable "because it will provide a guaranteed reduction in costs to ratepayers over
the rider period" and "[amy savings in excess of the Guaranteed O&M Savings will be
captured in the next general rate case." Tr. at 336.
During the hearing, Ms. Brenske noted that OG&Es customer education plan
needed more specificity regarding the deployment of customer education in Arkansas,
but that there is time to resolve that issue for the March-May 2012 meter deployment.
Id. at 381. OG&E and the Parties therefore agreed that the Company would provide
both customer information and privacy and cyber-security information within ninety
(90) days so that Staff can review it and get Commission approval prior to the meters
being deployed in Arkansas. Id.
In response to questioning by the Commission, Ms. Brenske testified that, based
upon the evaluation performed by Staffs consultant Richard Hornby, the deployment
and costs of Phase II of Smart Grid are beneficial to Arkansas ratepayers over the long
run (a 15-year period). Id. at 385. However, she added, that she does not believe that
short-term benefits will exceed costs, since program implementation and customer
Docket No. 10-log-U Order No. 8
Page 19 of 25
response will take time. Id. at 386. In short, she agreed that the benefits associated
with distribution automation and demand response are going to contribute to the
overall benefits of the program and thus Phase II lays the ground work for those larger
benefits. Ms. Breuske summed up Staffs position on this point: "We think over the long
run customers will be able to be served at lower costs than they would be otherwise
without smart meters, and so that's why we supported the settlement." Id.
Finally, Ms. Brenske responded to Commission questioning about delaying a
prudence finding, but authorizing expenditures of money on Smart Grid. She noted that
the two-step process contained in the settlement is similar to that used in other dockets
involving power plants and transmission lines, where the company seeks preapproval, in
the first step, to initiate an action based on a budget and a business plan. Id. at 388. In
the second step, once the project is completed, Staff reviews the prudence of the
execution of the project. In the instant case, Staff reserves that finding for the next rate
case, when any imprudent expenditures may be refunded to ratepayers with interest.
Id. She concludes that, based on the current business plan, "we believe that this is going
to be in the public interest." Id.
At the conclusion of the hearing the Commission announced that it would hold
the record open until July 20, 2011, for the Parties to provide a detailed framework of
the Customer Education Plan and budget for Commission approval, noting that this
action would not disturb the 90-day proviso on these matters in the Agreement itself.
Likewise, the Commission directed that OG&E provide under seal the privacy and cyber-
security plan that was provided to DOE, along with the talking points described by Mr.
Rowlett. Tr. at 391.
Docket No. 10-io9-U Order No.8
Page 20 of 25
In accordance with these directives, OG&E submitted the following information
on the following dates:
a June 29, 2011 - A copy of its DOE-approved Cyber-Security Plan for
the Smart Grid System and talking points (filed under protective seal);
• July 1, 2011 - A copy of its Data Privacy Plan and "concepts" document
describing the Cyber Security Plan and Data Privacy Plan expected to
be submitted pursuant to the Settlement Agreement;
. July 1, 2011 - A copy of its NERC Critical Infrastructure Protection
('CIP") Information Plan (filed under protective seal).
• July 5, 2011 - A copy of its initial Education Program talking points
and proposed budget for Smart Grid in Arkansas, to be used by the
parties in developing a formal plan pursuant to the proposed
Settlement Agreement; sample education materials and presentations
that have been used in Oklahoma and are proposed to be used in
education efforts in Arkansas; and OG&E's "Red Flag"/ Identity Theft
Program materials.
On July i, 2011, OG&E, the AG, and Staff filed their Joint Response to
Commission Directive to Submit OG&E Arkansas Smart Grid Outline Detailing
Customer Education Plan and Budget and Cyber Security Plan and Motion for
Approval of the Settlement Agreement ("Joint Response"). The Joint Response notes
that the Joint Parties have conferred and developed a detailed Customer Education Plan
Outline (Attachment 1 to the Joint Response).
The Joint Parties further state that while they have reviewed OG&E's proposed
customer education budget for Phase 11 of Smart Grid deployment filed on July & 2011,
Docket No. 10-109-U Order No.8
Page 21 of 25
"there has been insufficient time to determine if the breakdown of costs within the total
education budget amount is reasonable, since the contents of the consumer education
plan have not yet been developed." Joint Response at 16. Furthermore, the Joint
Parties state their understanding "that cost recovery for consumer education expenses,
as for all costs included in the SGR Rider, shall be subject to refund, under the terms
and conditions spelled out in the Settlement Agreement..." Id. Thus, subject to these
caveats, the Joint Parties agree that OG&E's total customer education budget shall not
exceed the total amount indicated in OG&E's July 5, 2011 filing. However, the Joint
Parties further agree that the breakdown of costs should be subject to further review as
the parties develop the detailed Customer Education Plan that will be filed with the
Commission for approval. As provided in the Agreement, the parties will file a detailed
Customer Education Plan and Customer Information Privacy and Security Plan with the
Commission for its review and approval within 90 days of the Order issued in this case,
and will provided a detailed customer education budget at that time. Id.
Decision
The Commission accepts and receives into the record in this docket OG&E's
filings of June 29, July 1, and July 5, 2011, and the Joint Response of the Joint Parties
filed on July 15, 2011, including Attachment 1 to the Joint Response. Having reviewed
the entire record and having considered the totality of the evidence presented in this
case, including the Application, the pre-settlement testimony and exhibits, the
Settlement Agreement, the post-Agreement filings by OG&E and the Joint Parties, and
the testimony of the witnesses who appeared at the public hearing conducted by before
the Commission on June 27, 2011, the Commission finds that the Settlement
Agreement, as filed on June 22, 2011, is supported by substantial evidence of record
Docket No. 10-109-U Order No. 8
Page 22 0125
(whib contains adequate clarification and reassurance by the Joint Parties of its terms
and the meaning thereof), is just and reasonable and in the public interest,, and is
approved.
The Commission finds that the filings of the Customer Education Plan outline
and budget constitute an adequate framework for consideration of OG&E's commitment
to develop a consumer education plan tailored to the needs of its Arkansas customers.
Likewise, OG&E's filing of its DOE-approved Cyber-Security Plan for the Smart Grid
System, Data Privacy Plan, NERC CIP Information Plan, and initial Education Program
talking points and proposed budget for Smart Grid in Arkansas satisfy the Commission's
directive to provide additional information in support of the Settlement Agreement.
Accordingly, the Commission directs and orders as follows:
1. The Settlement Agreement, as filed on June 22,2010, is hereby approved;
2. The Compliance filings required by this Settlement Agreement shall be filed in
this Docket within ninety (90) days of the date of this Order. These filings shall include:
an SGR Rider reflecting all of the provisions in Staff's testimonies as
modified in the Settlement Agreement to reflect the guaranteed O&M
reductions and the exclusion of the Norman, Oklahoma O&M expenses
incurred in 2010;
. a detailed reconciliation of all Smart Grid costs included in Docket No
10-067-U;
. a detailed reconciliation of the standard meter revenue requirement
included in Docket No. 10-067-U;
. a comprehensive Customer Education Plan developed with the input of
all Parties to this Settlement;
Docket No. 10-109-U Order No.8
Page 23of
. a detailed Customer Information Privacy and Security Plan;
: tariff revisions that reflects the waiver of Special Rules - Electric Rule
7.08.B (Meter Test Programs for In-Service Meters) and the changes in
the application of the Reconnection and Collection Fee provisions of
OG&E's tariff; and
• the method for calculating the System Average Interruption Duration
Index and the wio benchmark.
3. The Reporting requirements in the Settlement Agreement, the System Average
Interruption Duration Index calculation, and the reports on the involuntary
disconnection process shall be filed annually in this Docket along with the supporting
workpapers and will be based on the previous year's actual data. These reports will be
flied annually at the same time as true up of the SGR Rider.
4. Finally, given that OG&E's deployment of Smart Grid technology is the first of
its kind in Arkansas and that its implementation has implications for all of the state's
investor-owned utilities and their customers, the Commission directs the Company to
make the following compliance filings regarding the project in accordance with the
following schedule:
• April 1, 2012 - A report describing:
a how the Smart Grid technology and its energy and demand
savings capabilities relate to or may be integrated into
OG&E's comprehensive Arkansas Energy Efficiency Plans for
Program Years 2011-2013;
3 See Docket No. 07-075-17.
Docket No. 10-109-U Order No.8
Page 24 of 25
o how the Smart Grid technology affects OG&E's achievement
of the incremental, annual energy-savings targets established
by the Commission4 for Program Years 2011-2013; and
o how Smart Grid-related energy and demand savings will be
evaluated, measured, and verified in accordance with
Evaluation, Measurement, and Verification Protocols
expected to be adopted in Docket No. io-on-R.
• October 31,2012— A status report detailing OG&E's progress in the
following areas: installation of the Smart Grid "Distribution System
Automation" and "Advanced Metering Network" elements as
described by OG&E witness Kenneth Grant M. 27-30);
implementation of its comprehensive Customer Education Plan to
be submitted pursuant to this Order; and implementation of its
Customer Information Privacy and Security Plan to be submitted
pursuant to this Order; and
• April 1, 2013, and April 1, 2014 - A status report on the impact of
Smart Grid technology on OG&E customers' rates, bills, and energy
consumption levels, and the costs and benefits of the energy and
demand savings being achieved with the technology.
4 1d.
I
BY ORDER OF THE COMMISSION,
This day of August, 2011.
Docket No. 10-109-U Order No. 8
Page 25 of 25
Colette 1). Honorable, Chairman
Nfc4. f2ei Olan W Reeves, Commissioner
ga-~- 64'w~ Elana C. Wills, Commissioner
of the Commission
fhemb
- oHscSid VIsby dIfl
MA Uft"Wea @doom of gem
Secretaf the Commis&Ofl Date. "3..-t.L
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BEFORE THE ARKANSAS PUBLIC SERVICE COMMISSION
IN THE MATTER OF THE APPLICATION OF OKLAHOMA GAS AND ELECTRIC COMPANY FOR AN ORDER OF THE COMMISSION GRANTING PRE-APPROVAL OF DEPLOYMENT OF SMART GRID TECHNOLOGY IN ARKANSAS AND AUTHORIZATION OF A RECOVERY RIDER AND REGULATORY ASSET
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DOCKET NO. 10-109-U
SETTLEMENT AGREEMENT
Come now the General Staff of the Arkansas Public Service Commission (Staff),
Oklahoma Gas and Electric Company (OG&E), the Consumer Utilities Rate Advocacy
Division of the Arkansas Attorney General's Office (AG). and Gerdau MacSteel,
hereinafter collectively referred to as "the Settling Parties" and being all the parties to
the above-referenced Docket, agree to the following terms in settlement of all
outstanding issues in the above-referenced Docket.
1. PROCEDURAL SCHEDULE AND RECORD DEVELOPMENT
On December 17, 2010, OG&E filed an Application, Direct Testimonies and
Exhibits requesting that the Commission issue an Order granting pre-approval of the
deployment of Smart Grid technology in its service territory in Arkansas; the
authorization of a Smart Grid Rider to recover annual revenue requirement for Smart
Grid until a subsequent OG&E rate case when the revenue requirement would be
incorporated into base rates; and the creation of two regulatory assets, the first for
certain initial Smart Grid operation and maintenance costs and the second for stranded
APSC FLED Tme: 6(2212011 1IAZ5T AM: Reod 6/22(2011 11:37*64j"RTkofflbroc. so
costs related to the retirement of meters. OG&E also requested suspension of various
periodic and selective meter test schedules during the deployment of Smart Grid. On
March 17, 2011 Gerdau Mac Steel filed its Petition to Intervene which was granted on
April 8, 2011. After conducting extensive discovery, Staff, and the AG, filed Direct
Testimony on May 20, 2011. OG&E filed Rebuttal Testimony on June 3, 2011. Staff,
the AG and Gerdau MacSteel filed Surrebuttal Testimony on June 17, 2011.
The Record has been developed fully as reflected in the filed testimonies and
exhibits. In pursuit of settlement, a complete discussion of the issues outstanding was
undertaken among the Settling Parties, each being a strong advocate for its respective
position. The result is that the Settling Parties to this Agreement have agreed to settle
this case based on Staffs recommendations advanced in its Direct and Surrebuttal
Testimonies and Exhibits, as modified and detailed below.
2. SMART GRID RECOVERY RIDER (SGR Rider)
The Settling Parties have agreed to adopt Staffs Direct and Surrebuttal Case
with regard to the SGR Rider with two modifications. The level of Guaranteed
Operation & Maintenance (O&M) Reduction offered by the Company will be used to
reduce the SGR Rider revenue requirement and the Norman O&M expenses incurred in
2010 will be excluded. The SGR Rider shall therefore reflect each of the provisions of
Staffs testimonies, modified to reflect the Agreement regarding Guaranteed O&M
Reductions and the exclusion of Norman O&M expenses incurred In 2010- A summary
of the provisions of the SGR Rider as set forth in Staffs Direct and Surrebuttal
testimonies, modified to reflect the modifications noted above, is included as
Attachment 1.
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3. REPORTING REQUIREMENTS
The Settling Parties agree that the Company will report costs and benefits
associated with Smart Grid using the metrics included in Attachment 2 to the Settlement
Agreement The Company will establish a baseline 2010 System Average Interruption
Duration Index (SAIDI) and report that index to the Commission.
4. REMOTE DISCONNECT
A. The Company will continue to make two (2) phone calls; the first
automated and the second a person to person contact informing the residential
customer of an impending involuntary disconnection of service. If the Company is not
able to contact the residential customer by phone, the Company will visit the customer's
premise to notify the customer of the disconnection of service and offer a last
opportunity to avoid disconnection. If no one is at home, the Company will leave a door
hanger informing the residential customer of the disconnection of service and how to be
reconnected.
B. The settling parties agree that customers who are subject to involuntary
disconnection and receive a premise visit pursuant to paragraph A. above, will be
assessed the Reconnection Fee and the Collection Fee pursuant to the Company's
approved tariffs.
C. The Company will also provide a door hanger to include the Annual
Customer guide and an explanation of the Company's disconnection policy, at the
customers premise when Smart Meters are deployed.
D. The Settling Parties agree that the Company will continue the premise visit
APSC FLED Time: 6122120111 1*4Z57 AM: Rem! 612212011 11:37:54j Ofk 4JDoc 60
to residential customers who are subject to Involuntary disconnection and have not
been contacted by telephone prior to disconnection for a temporary transition period at
least until the conclusion of OG&E's next general rate case. The Settling Parties agree
that the elimination of the required premise visits to customers who are subject to
involuntary disconnection and cannot be reached by telephone prior to disconnection
shall be evaluated and addressed in OG&E's next general rate case. To enable that
evaluation, OWE shall provide an annual report detailing the number of premise visits
made pursuant to the provisions of the Agreement, the amounts collected pursuant to
the Reconnection Fee and Collection Fee, the cost of conducting the premise visits, and
applicable benefits pursuant to the Agreement.
5. CUSTOMER EDUCATION
A. The Settling Parties agree that the Company, with input from the Staff, the
AG, and the intervenor will develop a Customer Education Plan consistent with the
budget included in this case.
6. CUSTOMER INFORMATION PRIVACY AND SECURITY
A. The Settling Parties agree that the Company shall file a Customer Privacy
and Security Plan in this Docket for review and approval by the Commission.
7. OTHER ISSUES
A. The Settling Parties agree that a temporary waiver of Special Rules
Electric, Rule 7.08 B should be granted and the Company shall file a revision to its tariff.
B. Except as provided in paragraph 4.8. above, the Settling Parties agree
that the Reconnection Fee and Collection Fee shalt be discontinued on the date the
SGR Rider goes into effect. However, nothing herein precludes the Company from
0
APSC FILED Time: 612212011 1t42:57 AM: Recvd 6/22/201111.37 -54 .M1 y HDoG. 80
proposing a new or revised Reconnection Fee or Collection Fee in its next general rate
case.
C. The Settling Parties agree that the Company shall provide a Home Energy
Report, free of charge, to customers who participate in demand response programs, but
do not have Internet access to the Company's web portal..
8. COMPUANCE FILINGS The Agreement provides that, with input from the Staff, the AG, and the
intervenor the Company will file in this docket for Commission review and
approval of the following within 90 days of the order issued in this case:
. SGR Rider reflecting each of the provisions of Staffs testimonies,
modified to reflect the Agreement regarding Guaranteed O&M
reductions and the exclusion of Norman O&M expenses incurred in
2010, as summarized in Attachment 1;
. a detailed reconciliation of all of the smart grid costs included in Docket
No. 10-067-U;
a detailed reconciliation of the standard meter revenue requirement
included in Docket No. 10-067-U;
. customer education plan;
. customer information privacy and security plan;
stariff revisions to reflect the waiver of Special Rules Electric Rule 7.08 B
and the application of the Reconnection Fee and Collection Fee; and
the method for calculating SAIDI and the 2010 benchmark.
The Reporting Requirements identified in Attachment 2 to the Agreement, the
APSC FILED Tim: 612212011 11,42:57 AM: Read 612212011 11:37:5jf 50
SAIDI calculation, and the report identified in Section 4.D. Will be filed annually in
this Docket, along with supporting work papers, and Will be based on the
previous calendar year's actual data. The reports will be filed annually at the
same time as the SOR Rider.
9. RIGHTS OF THE SETTLING PARTIES
A. This Agreement is made upon the explicit understanding that it constitutes
a negotiated settlement which is in the public interest Nothing herein shall constitute
an admission of any claim, defense, rule or interpretation of law, allegation of fact,
principle, or method of ratemaking or cost-of-service determination or rate design, or
terms or conditions of service, or the application of any rule or interpretation of law, that
may underlie, or be perceived to underlie, this Agreement.
B. This Agreement is expressly contingent upon its approval by the
Commission without any modification. The various provisions of the Agreement are
interdependent and unseverable. All parties shall cooperate fully in seeking the
Commission's approval of the Agreement. The parties shall not support any alternative
proposal or settlement agreement while this Agreement is pending before the
Commission.
C. Except as to matters specifically agreed to be done or occur in the
future, no party shall be precluded from taking any position on the merits of any
issue in any subsequent proceeding in any Forum. This Agreement shall not be
used or argued as establishing precedent for any methodology or rate treatment
in any future proceeding.
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D. In the event the Commission does not accept, adopt and approve
this Agreement in its entirety and without modification, the Settling Parties agree
that this Agreement may be declared void and of no effect by any party.
In that event, however, the Settling Parties agree that: (a) no party shall be bound by
any of the provisions or agreements hereby contained; (b) all parties shall be deemed
to have reserved all their respective rights and remedies in this proceeding; and
(C) no party shall introduce this Agreement or any related writings, discussions,
negotiations, or other communications of any type in any proceeding.
Respectfully submitted,
GENERAL STAFF OF THE ARKANSAS PUBLIC SERVICE COMMISSION
By: Is/Fran C. Hickman Staff Attorney 1000 Center Street P.O. Box 400 Little Rock, AR 72203-0400 (501) 682-5881
OKLAHOMA GAS & ELECTRIC CO.
By: Is/Lawrence E. Chisenhall, Jr. Chisenhall, Nestrud & Julian 2840 Regions Center 400 W. Capitol Avenue Little Rock, AR 72201 (501) 372-5800
ATTORNEY GENERAL OF ARKANSAS
By: /s/M. Shawn McMurray Senior Asst Attorney General Emon Mahony Asst. Attorney General 323 Center Street, Suite 200 Little Rock, AR 72201 (501) 682-1053
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GERDAU MACSTEEL
By: Is/Thomas P. Schroedter Hall, Estill, Hardwick, Gable, Golden & Nelson, P.C. 320 S. Boston Avenue, Suite 400 Tulsa, OK 74103-3708 (915) 594-0436
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DOCKET NO 10-109-1.1
STAFF'S SGR RIDER, AS MODIFIED BY THE AGREEMENT
1. The Rider shall only include historical, prudently incurred incremental Costs associated with the deployment of Smart Grid (Davis Direct page 3, lines 15-19)
2. The Rider shall be based on the used-and-useful principle with no costs included in the revenue requirement and recovered before the cost is incurred and Smart Gad meters are in-service (Davis Direct page 3, lines 19-21)
3. The Rider shall include the formula for calculating the annual revenue requirement (Davis Direct page 3, line 21 - page 4, line 2)
4. The Rider shall remain in effect until new rates are implemented as the result of the planned 2013 rate case (Davis Direct, page 4, lines 6-10)
5. The regulatory asset for O&M expenses incurred prior to the implementation of the SOR Rider, without carrying charges, shall be approved. No O&M expense related to the Norman project which was incurred in 2010 should be included. Any non-incremental costs shall be excluded. The Rider shall include amortization of this regulatory asset over five years provided the expenditures are properly documented, and subject to audit In the Company's next general rate case. (Davis Direct page 5, line 11 - page 6, fine 2)
6. The Rider shall reflect the rate of return approved in Docket No. 10-067-U. (Davis Direct page 6, lines 8-14)
7. The Rider shall reflect the depreciation rates recommended on page 7 Table 3 of the Direct Testimony of Staff witness Gayle Freier (Davis Direct page 6, lines 15-19)
8. A regulatory asset for the early retirement of standard meters shall be allowed, without accrual of carrying charges, for the balance in the standard meter account at early retirement However, the Rider shall not include any amortization or return amounts for standard meters. The Commission reserves until OG&E's next rate case a final determination of 1) the appropriate amount of the balance in the standard meter account at early retirement and 2) the period for rate recovery, and no amortization or return amounts shall be included in the Rider calculations (Davis Direct page 6, line 19 - page 7. line 2 and Freler Direct page 8, line 14 - page 9, line 2)
9. The Rider shall reflect that to the extent OG&E seeks to use different depreciation rates than those approved in Docket No. 10-067-U or in this Docket, OG&E is required to file an application for such changes with supporting documentation for Commission review and approval (Freier Surrebuttal page 2, tines 13-17)
APSC FILED Time: 612212011 11,42:57 AM: Recvd 612212011 11:37:54fl- Doc. 80
0. The Rider shall be reduced annually by the revenue requirement associated with standard meters as included in the rates in Docket No. 10-067-U upon retirement of the standard meters and deployment of Smart Grid. (Davis Direct page 7, lines 3-15)
11. The Rider shall be fully credited for any Smart Grid amounts - expenses, investment, return, etc. - inadvertently included in rates in Docket No. 10-067-U for the full period of their inclusion. (Davis Direct page 7, lines 16-21)
12. The Rider shalt include the level of Guaranteed O&M Reductions offered by the Company to reduce the SGR Rider revenue requirement.
13. The Rider shall provide that the biking determinants will be the same methodology as used in the determination of the billing determinants for the Company's Rider ECR. (Davis Direct page 9, tines 8-13)
14, The Rider shall allocate Smart Grid costs to all of the service Levels within the classes such that there will be a separate rate calculated for each service level within each class using an allocator based on Total Distribution Plant less Acct. 360 land and land rights, consistent with the Docket No. 10-067-U compliance cost of service study G-4. (Davis Direct page 10, lines 1-15)
15. The Rider shall provide for the annual true-up to be accompanied by testimony and workpapers sufficient to fully replicate the calculations of the revised SGR factors. (Davis Direct page 11, fines 5-11)
16 The Rider shall provide the Commission explicitly reserves a finding of value for Smart Grid for ratemaking purposes until a future rate case when base rate recovery is sought (Davis Direct page 11, lines 15-17)15.
17, The Rider shall provide that all collections under the SGR Rider be subject to refund, with interest, after notice and hearing to determine prudence (Davis Direct page 11, lines 17 - 19)
ATTACHMENT 2
DOCKET NO. 10-1094U
REPORTING REQUIREMENTS
& Execution
Cost to Deploy: Capital vs. total Capital Total capital dollars spent on the AMI deployment deployment cost program inception to date vs. total AMI program capital
budget as a dollar amount and as a ratio by project
Cost to Deploy: O&M vs. total O&M deployment Total O&M dollars spent on the AMI deployment program cost Inception to date vs. total AMI project O&M budget as a
dollar amount and as a ratio by project
DOE Reimbursement - AMI only Portion of Department of Energy Smart Grid Investment Grants received and applied to offset cost of AMI and ratio of total grant
Avoided new capital Investment In new Total dollar value of avoided legacy metering capital costs Installations of the older metering systems due to for new customers and new developments customer growth Avoided planned replacement and maintenance Total dollar value of avoided replacement costs of current costs relating to the older metering system (e.g., metering equipment mechanical meters, ERT devices, etc)
Reduction in manual meter reading costs Cost reductions due to the elimination of meter reading positions (in-house and contract)
Reduction In meter operations costs (e.g., field Meter operations savings due to lower survey meter visits, meter maintenance, etc) activities and ERT battery replacement COStS -
Reduced Theft of Energy The number of Incidents of theft of energy uncovered and the dollar amount billed for theft of energy
Total AMI electric meters installed - Total AMI electric meters installed (physically attached to a premise) expressed as total number and percent of total
Communications & Education
Communications & Education
Communications & Education
Meter Accuracy
Meter Reading Effectiveness Awareness and Understanding
Awareness and Understanding
unity Outreach
unity Outreach
ner Satisfactio,
unity Outreach
ATTACHMENT 2
DOCKET NO 10-109-U
REPORTING REOUIRMENTS
Metric Section ProJect Delivery & Execution Nei Total communication network components Total communication network components installed
Installed (access points & relays) (access points & relays) expressed as total number and percent of total
Total AMI meters used for billing (activated), Total AMI meters used for billing (activated, I.e. communications achieved and used to bill communicating with meter to produce customer bill) monthly expressed as total number and percent of total
Number of avoided truck rolls Number of avoided truck rolls for meter field Inspections. Note: Will include number of deployment truck rolls as a footnote
AMI Meter Sample Internal Test Results Percentage of AMI meters that pass internal accuracy ________________________________________ testing prior to deployment Percentage at interval reads received Number of Intervals reported I total number of possible
Intervals to be reported Percent awareness of AMI technology and Percent awareness of customers based on survey results benefits (survey measurement) target to be determined after baseline established (with
and w1b Internet access) Percent understanding of AMI technology and Percent understanding of customers based on survey benefits (survey measurement) results; target to be determined after baseline established
(with and wIg Internet access) Number of community outreach events Number of events held to educate customers and conducted and number of attendees at events Number of customers attending educational events
Number of articles that appear in local media Number of articles that appear in local media as a result of company Issued press releases
Number of articles in internal newsletter Number of articles in internal newsletter
Number of Meter installation Complaints/Claims Number of Meter Installation complaints/claims
Number of customer organizations contacted Number of customer organizations contacted
Number of customer referrals to energy advisors Number of transfers to energy advisors for information on
ATTACHMENT 2
DOCKET NO. 10-109-U
Recommended