Akbar Jazayeri Vice President, Regulation Operations Southern California Edison Company (SCE) 2244 Walnut Grove Avenue Rosemead, CA 91770

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1 STATE OF CALIFORNIA Edmund G. Brown Jr., Governor PUBLIC UTILITIES COMMISSION 505 VAN NESS AVENUE SAN FRANCISCO, CA March 27, 2013, 2013 Advice Letters: SCE 2662-E-A PG&E 3956-E-A SDG&E 2307-E-A Akbar Jazayeri Vice President, Regulation Operations Southern California Edison Company (SCE) 2244 Walnut Grove Avenue Rosemead, CA Brian K. Cherry Vice President, Regulatory Relations Pacific Gas and Electric Company (PG&E) 77 Beale Street, Mail Code B10C P.O. Box San Francisco, California Ms. Megan Caulson Regulatory Tariff Manager San Diego Gas & Electric (SDG&E) 8330 Century Park Court, Rm 32 C San Diego, CA Fax: mcaulson@semprautilities.com Subject: Smart Meter Home Area Network Implementation Plan Supplemental Filing Mr. Jazayeri, Mr. Cherry, and Ms. Caulson: Energy Division has determined that the Advice Letters Supplements SCE 2662-E-A, PG&E 3956-E-A, SDG&E 2307-E-A filed by SCE, PG&E and SDGE (Utilities) on October 29, 2012, are in compliance with the Resolution E-4527 and the underlying Decision (D.) Energy Division approves the supplemented Advice Letters as filed. Background On November 28, 2011, PG&E Advice Letter 3956-E, SCE Advice Letter 2662-E, and SDG&E Advice Letter 2307-E (collectively referred to as Home Area Network (HAN) Implementation Plans ) were filed by the Utilities in response to Ordering Paragraph 11 of the Customer Data Access & Privacy Decision D (Decision) in California Public Utilities Commission s (CPUC s) Smart Grid Rulemaking R Seven Parties filed protests: Division of Ratepayer Advocates (DRA), TechNet, MyEnersave (now called Bidgley), Direct Access Customer Coalition (DACC) and Alliance of Retail

2 Energy Markets (AReM), Demand Response and Smart Grid Coalition (DRSG), Ember Corporation, and Zigbee Alliance. All protests were received on December 19, 2011, except Bidgley filed on December 18, The Utilities replied on December 27, On September 27, 2012, the CPUC approved Energy Division s resolution E-4527 (Resolution) directing the Utilities, via Ordering Paragraph 1, to submit supplemental filings that incorporate specific implementation requirements (detailed in the ordering paragraph) to address certain deficiencies found by the Resolution in the above Advice Letters in meeting the original intent of Ordering Paragraph 11 of the Decision. On October 29, 2012, the subject supplements were filed by the Utilities in response to the Resolution s order. No protests to the supplements were received. Disposition Energy Division has reviewed the filings and concluded that the supplements are in compliance with the Resolution. The Advice Letters, as supplemented, remain in effect as filed. Sincerely, /s/ Aloke Gupta Aloke Gupta, Senior Regulatory Analyst, Energy Division CPUC Cc: Bidgely, via abhay@bidgely.com; DACC & AReM, via sue.mara@rtoadvisors.com; DRA, via karin.hieta@cpuc.ca.gov; DRSG Coalition, via dan.delurey@drsgcoalition.org; Ember Corp, via skip.ashton@ember.com; TechNet, via jhawley@technet.org; Zigbee Alliance, via trichardson@zigbee.org

3 Akbar Jazayeri Vice President of Regulatory Operations October 29, 2012 ADVICE 2662-E-A (U 338-E) PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA ENERGY DIVISION SUBJECT: Supplemental Filing to Incorporate Additional Requirements From Resolution E-4527 into Advice 2662-E, Smart Meter Home Area Network Implementation Plan Southern California Edison Company (SCE) hereby submits for filing this supplement to its Smart Meter Home Area Network (HAN) Implementation Plan. The Revised HAN Implementation Plan is attached hereto as Revised Attachment A. PURPOSE The purpose of this advice filing is to comply with Resolution E-4527 (the Resolution), which requires SCE to incorporate specified implementation requirements into a supplemental filing modifying SCE s contained in Advice 2662-E, filed on November 29, This advice letter supplements in part the original Advice 2662-E. BACKGROUND On July 29, 2011, the California Public Utilities Commission (Commission) issued Decision (D.) , Decision Adopting Rules to Protect the Privacy and Security of the Electricity Usage Data of the Customers of Pacific Gas and Electric Company, Southern California Edison Company, and San Diego Gas & Electric Company. The Decision adopted rules to protect the privacy and security of customer usage data from P.O. Box Rush Street Rosemead, California (626) Fax (626)

4 ADVICE 2662-E-A (U 338-E) October 29, 2012 smart meters. 1 On November 29, 2011, pursuant to Ordering Paragraph (OP) 11 of the Decision, SCE filed Advice 2662-E describing its (HIP). On September 27, 2012, the Commission adopted the Resolution, which directs SCE to incorporate certain implementation requirements into a supplemental filing by October 29, PROPOSAL To incorpoate the requirements of OP 1a of the Resolution, SCE supplements Section K of the HIP (titled Functionality Independent of the Utility ). To incorporate the requirements of OPs 1b and 1c of the Resolution, SCE supplements Section H ( Device Interoperability ). To incorporate the requirements of OP 1d of the Resolution, SCE adds a new Section N, entitled Customer Education and Outreach. The remaining ordering pararaphs of the Resolution will be addressed in subsequent advice filings consistent with the later due dates provided in the Resolution. TIER DESIGNATION Pursuant to General Order (GO) 96-B, Energy Industry Rule 5.1, this advice letter is submitted with a Tier 1 designation. EFFECTIVE DATE This advice filing will become effective on the date filed. NOTICE Anyone wishing to protest this advice filing may do so by letter via U.S. Mail, facsimile, or electronically, any of which must be received no later than 20 days after the date of this advice filing. Protests should be mailed to: CPUC, Energy Division Attention: Tariff Unit 505 Van Ness Avenue San Francisco, California EDTariffUnit@cpuc.ca.gov Copies should also be mailed to the attention of the Director, Energy Division, Room 4004 (same address above). In addition, protests and all other correspondence regarding this advice letter should also be sent by letter and transmitted via facsimile or electronically to the attention of: 1 Also known as Edison SmartConnect meters.

5 ADVICE 2662-E-A (U 338-E) October 29, 2012 Akbar Jazayeri Vice President of Regulatory Operations Southern California Edison Company 8631 Rush Street Rosemead, California Facsimile: (626) AdviceTariffManager@sce.com Les Starck Senior Vice President c/o Karyn Gansecki Southern California Edison Company 601 Van Ness Avenue, Suite 2030 San Francisco, California Facsimile: (415) Karyn.Gansecki@sce.com There are no restrictions on who may file a protest, but the protest shall set forth specifically the grounds upon which it is based and shall be submitted expeditiously. In accordance with Section 4 of GO 96-B, SCE is serving copies of this advice filing to the interested parties shown on the attached GO 96-B and R service lists. Address change requests to the GO 96-B service list should be directed by electronic mail to AdviceTariffManager@sce.com or at (626) For changes to all other service lists, please contact the Commission s Process Office at (415) or by electronic mail at Process_Office@cpuc.ca.gov. Further, in accordance with Public Utilities Code Section 491, notice to the public is hereby given by filing and keeping the advice filing at SCE s corporate headquarters. To view other SCE advice letters filed with the Commission, log on to SCE s web site at For questions, please contact David LeBlond at (626) or by electronic mail at David.LeBlond@sce.com. Southern California Edison Company AJ:dl:jm Enclosures Akbar Jazayeri

6 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.: Southern California Edison Company (U 338-E) Utility type: Contact Person: Darrah Morgan ELC GAS Phone #: (626) PLC HEAT WATER Disposition Notice to: EXPLANATION OF UTILITY TYPE ELC = Electric GAS = Gas PLC = Pipeline HEAT = Heat WATER = Water (Date Filed/ Received Stamp by CPUC) Advice Letter (AL) #: 2662-E-A Tier Designation: 1 Subject of AL: Supplemental Filing to Incorporate Additional Requirements From Resolution E-4527 into Advice 2662-E, Smart Meter Home Area Network Implementation Plan Keywords (choose from CPUC listing): Compliance AL filing type: Monthly Quarterly Annual One-Time Other If AL filed in compliance with a Commission order, indicate relevant Decision/Resolution #: Resolution E-4527 Does AL replace a withdrawn or rejected AL? If so, identify the prior AL: Summarize differences between the AL and the prior withdrawn or rejected AL 1 : Confidential treatment requested? Yes No If yes, specification of confidential information: Confidential information will be made available to appropriate parties who execute a nondisclosure agreement. Name and contact information to request nondisclosure agreement/access to confidential information: Resolution Required? Yes No Requested effective date: 10/29/12 No. of tariff sheets: -0- Estimated system annual revenue effect: (%): Estimated system average rate effect (%): 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: Service affected and changes proposed 1 : Pending advice letters that revise the same tariff sheets: 1 Discuss in AL if more space is needed.

7 Protests 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: CPUC, Energy Division Attention: Tariff Unit 505 Van Ness Ave., San Francisco, CA Akbar Jazayeri Vice President of Regulatory Operations Southern California Edison Company 8631 Rush Street Rosemead, California Facsimile: (626) Leslie E. Starck Senior Vice President c/o Karyn Gansecki Southern California Edison Company 601 Van Ness Avenue, Suite 2030 San Francisco, California Facsimile: (415)

8 Revised Attachment A Southern California Edison Smart Meter Home Area Network (HAN) Implementation Plan In Compliance With D and Resolution E-4527 October 29, 2012

9 Table of Contents A. SCE s HAN Deployment Guiding Principles... 3 B. HAN Strategic Overview... 5 C. Consistency with the Edison SmartConnect TM Program, Smart Grid Deployment Plan and DR Programs... 5 D. HAN Phase 1 Implementation Plan Customer Enrollments HAN Device Registration Data Access and Granularity Operational and System Impacts Potential Retail Channels Timing and Integration... 9 E. HAN Phase 2 Implementation Plan Customer Enrollments Enhanced HAN Device Registration Load Control Capability Data Access and Granularity Timing and Integration F. Security Risk Mitigation and Best Practices G. Secure HAN Connection H. Device Interoperability I. National Standards and Security J. HAN Certification and Device Testing K. HAN Functionality Independent of the Utility L. Customer Needs and Preferences M. Lessons Learned N. Customer Education and Outreach

10 The purpose of this document is to describe SCE s Home Area Network (HAN) Implementation Plan in compliance with Ordering Paragraph 11 of D The California Public Utilities Commission (Commission) issued D , Decision Adopting Rules to Protect the Privacy and Security of the Electricity Usage Data of the Customers of Pacific Gas and Electric Company, Southern California Edison Company, and San Diego Gas & Electric Company (Decision). The Commission in D directed SCE to file a Tier 3 advice filing to develop a Smart Meter, including an initial roll-out phase (pilot phase) of up to 5,000 HAN devices, allowing for HAN activation for early adopters while full functionality and roll-out awaits resolution of technology and standards issues. The purpose of this advice filing is to provide SCE s HAN Implementation Plan in accordance with that decision. A. SCE s HAN Deployment Guiding Principles This section describes the guiding principles SCE considered in developing its. These guiding principles illustrate SCE s vision for its full-scale HAN deployment. SCE s full scale HAN deployment will offer HAN connectivity with residential customers and non-residential customers SmartConnect meter (<200kW demand). SCE considers HAN connectivity to the Edison SmartConnect meter to be a part of SCE s basic utility service provided to all residential customers who have an operational Edison SmartConnect meter. A customer s HAN will enable them to access near real-time usage data directly from their Edison SmartConnect meter. This will allow customers to take advantage of energy management programs and tools that rely on near realtime access to usage data and can help customers better manage their electricity usage. SCE plans to develop these programs and tools during the 3

11 first phase of the HAN deployment and to integrate the lessons learned from the first phase (including previous HAN field trials) into the final program roll-out. SCE envisions its will allow customers to eventually choose and purchase their own HAN devices. SCE expects to be responsible for program administration, device registration, and customer support for device registration, troubleshooting and other program-related issues. SCE plans to use nationally approved standards of Smart Energy Profile (SEP) 1.0 and SEP 1.1 in the early phases of the HAN deployment. Later phases will employ the SEP 2.0 standard once national ratification is complete and SCE can equip its back office systems and hardware to accommodate that upgrade. Utilizing a national standard ensures interoperability among customer-owned devices. The SEP 2.0 standard has more functionality than 1.0 and 1.1 and is expected to have widest adoption in the long run. However, due to uncertain and long lead times for 2.0, SCE is committed to provide HAN connectivity in the near term with available technology. This approach allows for the greatest flexibility in order to move forward with HAN deployment while also utilizing national standards. SCE is fully committed to an open-han concept whereby interoperability among systems and devices is maximized. In this way, SCE and the other California investor owned utilities (IOUs) can enable a statewide HAN approach that allows for maximum device opportunities and efficiencies in the long run. Consistent with Commission Decision (D.) ordering the IOUs to work together to implement HAN, 1 SCE also encourages the IOUs to share information including lessons learned in order to avoid duplicative efforts. SCE expects that this collaboration will contribute to a successful 1 Ordering Paragraph 4 of D ordered SDG&E shall work with the other major California utilities to strive for statewide, clearly defined and commercially available open standards for Home Area Network (HAN) communications systems. 4

12 HAN deployment and a positive customer experience with this new technology. B. HAN Strategic Overview SCE s strategy to use a two-phased HAN deployment plan with the initial phase beginning in December 2011 and accommodating up to 10,000 devices meets the objectives of D The two phases will address multiple deployment objectives including device registration and connectivity, device and system troubleshooting, marketing, outreach and delivery channels for devices, various forms of information including usage, pricing, and alert/event messaging and load control. SCE s is also consistent with the HAN capabilities envisioned and approved in the Commission s Decision approving SCE s Edison SmartConnect Program (D ) 2. C. Consistency with the Edison SmartConnect TM Program, Smart Grid Deployment Plan and DR Programs SCE's is consistent with the Commission's decision on Edison SmartConnect TM, SCE s Smart Grid Deployment Plan 3 and SCE s Demand Response programs. SCE s Edison SmartConnect Program 4 includes the provisioning of HAN capabilities to customers during the Edison SmartConnect Deployment Period (2008 to 2012). Furthermore, the Edison SmartConnect business case (as approved in D ) provided approximately $61 million for HAN functionalities, including those 2 Decision issued 09/22/2008 adopting a settlement proposed by SCE and the Division of Ratepayer Advocates (DRA) to allow $1.63 billion in ratepayer funding for SCE s proposed Advanced Metering Infrastructure (AMI) Project from 2008 through SCE s Smart Grid Deployment Plan represents SCE s effort to meet the requirements of D and provide a comprehensive description of its plans to deploy smart grid technologies. 4 See id. 5

13 functionalities described in this SCE. As such, much of the pilot activities during Phase 1 will be funded through the Edison SmartConnect Program and appropriately recorded to the Edison SmartConnect Balancing Account. In addition, customer care activities related to HAN registration and customer support were included in SCE s 2012 General Rate Case forecast. In addition, SCE s will enable Smart Grid capabilities through its Advanced Load Control System (ALCS). ALCS can help SCE coordinate notifications about Demand Response events and properly manage responses. Finally, SCE's is designed to work in coordination with the Save Power Day Incentive Program and Summer Discount Plan. D. HAN Phase 1 Implementation Plan Phase 1 is a pilot that is expected to begin in December 2011 and conclude upon the commencement of Phase 2 (which is expected to occur in December 2012). Phase 1 will leverage SEP 1.0 and will support the following HAN functionalities: Ability to support customer enrollments; Ability to pair HAN enabled devices with Edison SmartConnect meter; Ability to register HAN devices; Provide access to demand and price data in near-real time through simple text messages; Provide customers with Save Power Day (also known as Peak Time Rebate (PTR)), alert notifications through HAN text messages; Device and back office systems utilizing SEP

14 1. Customer Enrollments Southern California Edison This phase will support SEP 1.0 In-Home Display (IHD) devices for a roll-out to support up to 10,000 HAN devices, thus satisfying the D requirement in Ordering Paragraph 11 to support up to 5,000 devices. To be eligible for participation in this phase, residential customers must have an Edison SmartConnect meter installed at their premises. The meter must be cut-over to operations and provide interval data to SCE s back office systems, and the customer cannot be critical care. SCE will then manually verify the customer s eligibility and complete the customer enrollment. SCE will provide SEP 1.0 compatible devices at no cost to 500 eligible participants who enroll in the Save Power Day Incentives Plus program and agree to participate in pilot-related surveys and other information gathering and data analysis activities. SCE will be able to perform detailed operational analysis with these participants that will be used to improve the subsequent phase of the roll-out. 2. HAN Device Registration Customers will have access to a dedicated phone line to register their HAN devices and enroll in the Save Power Day Incentives Plus program. More specifically, this process includes securely pairing the HAN device with the customer s smart meter, and enrolling the customer in the Save Power Day Incentives Plus program, which pays a higher incentive than the standard Save Power Day Incentive program when customers with registered HAN-enabled devices 7

15 reduce their usage below their daily average during a Save Power Day (or PTR) event Data Access and Granularity Upon completion of the device registration, the device will receive demand (in kw) and pricing data (in $/kwh). The demand data will be provided in near real-time granularity (updated approximately every ten to twelve seconds). Customers will also receive daily cost, price and tier information via a HAN text message, and the HAN device will receive alert messages notifying the customer of an upcoming Save Power Day event. 4. Operational and System Impacts As part of Phase 1, SCE will provide educational and outreach materials to participating customers. SCE will also provide customer support for participating customers through SCE s call center. 5. Potential Retail Channels As part of Phase 1, SCE will explore retail partnerships that can expand customer awareness of market-ready SEP 1.0 HAN devices that are compatible with SCE s system. SCE expects to launch a retail channel partnership in the third quarter of At the retail store, SCE expects that customers will be able to confirm HAN compatibility and purchase HAN devices. When they bring the HAN device home, the customer will contact SCE to open the meter for pairing and register the device to the back-office systems. Such retail partnerships are expected to enhance the customer experience by 5 SCE s Schedule D Domestic Service sets forth a two-tiered PTR incentive - $0.75/kWh for customers without enabling technologies; and $1.25/kWh for customers with installed qualifying enabling technologies. 8

16 providing retail channels for HAN access, information, and customer support. 6. Timing and Integration SCE expects to begin Phase 1 implementation in December Phase 1 will end upon the commencement of Phase 2, as described in the following section. E. HAN Phase 2 Implementation Plan SCE expects to begin Phase 2 in the fourth quarter of This phase will build upon Phase 1 features by providing the following functionalities: Ability to integrate with load control devices; Ability to communicate to Programmable Communicating Thermostats (PCTs) to trigger temperature set-backs and over-ride event options; Device, back office, and load control systems utilizing SEP 1.1; Integration with SCE s back office systems to provide appropriate billing determinants to enable billing for HAN-enabled programs; Automation of Phase 1 manual processes to enroll and register HAN devices, including automation integration with SCE.com. 1. Customer Enrollments Beginning in the fourth quarter of 2012, SCE will use targeted customer outreach activities to identify and enroll 500 eligible residential customers in the Summer Discount Plan (SDP) 6 with PCTs as the enabling technology. Once SCE determines customer eligibility for these 500 customers, SCE will provide, at no cost to the customer, a SEP 1.1 PCT HAN device and assist the customer in enrolling in SDP. 6 DR program that curtails energy usage by air conditioning during periods designated as emergencies by the CAISO. In return for participating in the SDP program, customers receive an annual credit on their electric bill. 9

17 Customers who purchase their own HAN devices may be eligible for rebates upon successful registration to the SmartConnect meter. In addition, Phase 2 will continue to support HAN devices deployed in Phase 1 (e.g., In Home Displays). With the lessons learned through this limited PCT launch (i.e., 500 eligible residential customers), SCE will expand the HAN deployment to support additional devices and customers in its SDP and other demand response programs. 2. Enhanced HAN Device Registration From the customer s standpoint, the HAN device registration process will be similar to the process described in Phase 1 7 However, in addition to utilizing SEP 1.1 and providing integration with PCTs, Phase 2 is expected to include technology updates to fully automate many of the manual back-office processes used in the initial Phase 1 roll-out. This implementation will enable SCE to support a greater volume of HAN devices. 3. Load Control Capability With the Phase 2 roll-out, customers who enroll in SDP with the enabling PCT technology will receive incentives to participate in load control events. This capability is enabled by an Automated Load Control System (ALCS). Utilizing ALCS, SCE s back office systems will transmit load control events over the Edison SmartConnect network to registered PCTs of customers enrolled in SDP. The customer s PCT will lower the temperature of the central air conditioning unit for a 7 However, in Phase 2 customers will be enrolling in SDP, rather than the PTR-ET enrollments in Phase 1. 10

18 specific duration of time (e.g., 2 degrees during SDP event). If a customer chooses not to participate in the SDP event, pursuant to the SDP tariff the customer has the option to over-ride the load control command through the PCT. 4. Data Access and Granularity Customers participating in Phase 2 will have the same data access and granularity provided for their demand, pricing, and alert messaging. In addition, Phase 2 customers will have additional alert messaging related to SDP events. 5. Timing and Integration SCE expects to begin Phase 2 implementation in December Phase 2 is expected to continue through 2014, upon which participating customers will be integrated into SCE s standard utility service. F. Security Risk Mitigation and Best Practices SCE will utilize four elements to provide security in the Phase 1, Phase 2, and long-term HAN implementation. First, SCE will leverage the security features compliant with SEP. Second, SCE will continue to perform security standards and vulnerability testing as part of the overall Edison SmartConnect Program. Third, the pairing and registration process ensures the HAN device will register only with the particular meter located at the customer s premise. Finally, SCE also performs device interoperability testing which includes security testing to conform to the SEP national standards. 11

19 SCE will also continue to work with other parties and monitor the standards development process to integrate the appropriate best practices into SCE s risk mitigation approaches SCE will also educate customers on issues related to data privacy, consistent with D G. Secure HAN Connection SCE is responsible for providing a secure HAN connection with the SmartConnect meter. The processes and security elements to enable a secure HAN connection were described previously in this plan. More specifically, in Phase 1 and Phase 2, SCE is responsible for and will work with customers to provide a secure HAN connection through the device registration and pairing processes. H. Device Interoperability Consistent with current practices, SCE will continue to test devices for interoperability with SCE s back office systems and communications networks during Phase 1 and Phase 2. To communicate with the HAN interface in the SmartConnect meter, the devices will require ZigBee certification and should be capable of using SEP 1.0 or 1.1. SCE will continue to test for a range of factors that affect compatibility between the HAN device and the SCE network such as meter firmware, device software, and communication standards. Also, SCE continues to work with third party vendors to assist with security testing of the HAN interface and the Edison SmartConnect network. SCE is willing to explore opportunities to collaborate with other third parties, to the extent feasible, to enhance testing of the overall performance and security of the Edison SmartConnect 12

20 system. Consistent with current practices pursuant to D , SCE will share relevant findings with PG&E, SDG&E and other interested parties. Pursuant to Ordering Paragraph 1.b of Resolution E-4527, SCE will collaborate with PG&E, SDG&E, third parties and relevant standards-based organizations, as appropriate, facilitated by CPUC Staff as needed, to develop the following: 1. A common set of reasonable requirements and testing processes for validating interoperability between the IOUs electric smart meters and commercially available HAN devices offered by third parties for the purpose of monitoring in near real-time a customer s electricity usage recorded by a smart meter. 2. A common set of reasonable requirements to be met by a HAN device supplier for its device to be eligible to be validated by an IOU for interoperability with the IOUs smart meters. Pursuant to Ordering Paragraph 1.b.i of Resolution E-4527, SCE, PG&E, and SDG&E will collaborate to publish common validation requirements and testing processes, and common interoperability validation eligibility criteria, in a joint Tier 1 Advice Letter by December 1, CPUC Staff has already initiated the collaboration process by creating a Core HAN Working Group to fulfill those requirements from Resolution E-4527 that require collaboration. The Core HAN Working Group currently includes representatives from SCE, PG&E, SDG&E, DRA, the California Energy Commission (CEC), and the CPUC. The Core HAN Working Group held its initial meeting on October 23, 2012 and will continue to meet on a recurring basis. 13

21 Pursuant to Ordering Paragraph 1.b.ii of Resolution E-4527, SCE may use the HAN device interoperability validation process established by the IOUs to validate commercially available third-party HAN devices for interoperability with SCE s SmartConnect meters on a non-discriminatory, first-come, firstserved basis until an independent third-party laboratory introduces a robust standards-based interoperability certification process. As SCE notes in Section H below, while SCE does validate devices for compatibility with its meters and systems, SCE does not certify devices. Pursuant to Ordering Paragraph 1.b.iv of Resolution E-4527, SCE will collaborate with the other IOUs, CPUC Staff, third parties, the CEC, and relevant standards organizations, as appropriate, to support the establishment of independent third-party laboratories that can test HAN device interoperability with utility smart meters. SCE has no obligation to establish such laboratories. Pursuant to Ordering Paragraph 1.c of Resolution E-4527, by February 1, 2013, SCE will publish on SCE.com a list of at least five commercially available HAN devices that have been validated by SCE for interoperability with SCE s SmartConnect meters. SCE will make reasonable efforts to diversify the list of published devices in terms of the following criteria: Functionality (SCE will strive to include at least one in-home display and at least two that can communicate with the internet independently of SCE) Cost (of the devices that can communicate with the internet, SCE will aim to include one device that has a relatively low manufacturer suggested retail price ) Manufacturer (SCE will strive to include devices from at least three different device manufacturers) 14

22 SCE is not obligated to use the common validation requirements and testing process and the common interoperability validation eligibility criteria to be published in the December 1, 2012 Advice Letter for the initial five devices to be published on SCE s website. SCE will make a reasonable effort to expand the list of validated devices, using the common validation requirements and testing process and the common interoperability validation eligibility criteria, by August 1, When an alternative means becomes available for third parties to communicate information about interoperable HAN devices to customers, SCE will consult with CPUC staff to determine an appropriate time to terminate the published list on SCE.com. Consistent with Ordering Paragraph 1.b.iii of Resolution E-4527, the Commission has determined that SCE will not be held liable for the market success or failure of a third-party HAN device to the extent that device is or is not validated by SCE or listed on its website. SCE is not responsible for completing device validation testing within a specified timeframe. Nor is it obligated to re-test and validate devices with changed specifications, or devices that may no longer be interoperable with SCE s meters after the time of their initial validation. Third parties would need to request that such devices be tested and validated on a first-come, first-served basis. I. National Standards and Security SCE will utilize national standards in developing its HAN capabilities. Phase 1 will utilize SEP 1.0, and Phase 2 is expected to use SEP 1.1. A key component of the SEP national standard is security. SCE has been an active participant in drafting the national standard on HAN security and SCE will comply with the national standard. As the national standard evolves, SCE s security practice will evolve to conform to the national standards when adopted. Furthermore, on an on-going basis, SCE expects to incorporate 15

23 HAN standard updates into SCE s HAN solution, including SEP SCE continues to collaborate and participate in various HAN-related technology alliances and Smart Energy stakeholder groups to develop approaches to mitigate security risks (e.g., SEP specification, network security and device compatibility), guide evolving national standards, and collaborate on overall best practices. These groups and alliances include state and national regulatory agencies, ZigBee Alliance, WiFi Alliance, HAN device vendors and electronic chip manufacturers. As needed, SCE will also collaborate with other interested third parties (e.g., Lawrence Berkeley National Laboratories, California State University-Sacramento). J. HAN Certification and Device Testing Each utility s systems are different, and compatibility with SCE s system does not ensure compatibility with other systems. Thus, although SCE performed testing for interoperability with SCE s back office systems and communications networks, SCE cannot certify particular HAN devices. Consistent with current practices, SCE does not intend to certify HAN devices. As such, SCE recommends that HAN device certification can be best accomplished by the market. In addition, consistent with current practices pursuant to D , SCE intends to share such findings with the PG&E, SDG&E and other interested parties, as requested and for their internal use only. 8 Assuming that SEP 2.0 is commercially available in 2014, SCE expects to incorporate this standard into the SCE network in the 2015 time frame. Incremental costs will likely be necessary to update SCE s network and systems to the SEP 2.0 standard. These costs would only be incurred after the SEP 2.0 standard is ratified, interoperability tested, certified, and ready for market. In addition, additional costs may be incurred if SCE is required to support communications from its back-office systems to the HAN devices through an IP/Gateway solution. Until such time as IP/Gateway protocols are standardized, ratified, and certified (expected with SEP 2.0), SCE will continue to utilize its Edison SmartConnect TM network to communicate to the HAN devices. 16

24 K. HAN Functionality Independent of the Utility For the near term, HAN functionality is not capable of operating completely independent of the utility. In order to enable secure communication channels and receive demand, pricing and load control data, the customer s device must communicate with SCE s smart meter through the HAN. By the fourth quarter 2012, customers may be able to receive their usage, price and load control commands communicating through an independent third party (e.g., WiFi) to downstream devices. This method of data access will require collaboration between third party vendors and SCE s processes to enable HAN functionality independent of the utility. This is a solution SCE will further describe in conjunction with SCE s application establishing third party data access to a customer s usage data via the utility s back-haul systems when authorized by the customer. Pursuant to Ordering Paragraph 1.a of Resolution E-4527, on October 23, 2012, SCE began accepting requests from customers to activate the HAN function of the customer s SmartConnect meter to enable the customer to use a commercially available HAN device of their choosing and obtained independently of SCE. Customers can currently make such requests by calling a SCE Customer Service Representative. By February 1, 2013, customers will be able to make such requests via a web page on SCE.com. Through the Core HAN Working Group established by CPUC Staff, SCE will work with PG&E and SDG&E to achieve as much consistency as is reasonably possible in the IOUs processes for accepting customer requests to open their smart meter for pairing with a HAN device. Pursuant to Ordering Paragraph 1.a.ii, for devices that SCE has validated to be interoperable with SCE s SmartConnect meters, SCE will not be responsible for the performance or quality of the customer s independentlyobtained HAN device as long as SCE has made the customer s SmartConnect 17

25 meter available for pairing. For devices that have not been previously validated by SCE for interoperability with SCE s SmartConnect meter, SCE is under no obligation to provide support beyond opening the customer s SmartConnect meter for pairing. Pursuant to Ordering Paragraph 1.a.i, SCE will establish and maintain a technical infrastructure sufficient to support a cumulative number of activation requests meeting or exceeding the levels specified in the following table, after which the number of activation requests will be unrestricted. Date # of Activation Requests June 30, ,000 December 31, ,000 December 31, ,000 L. Customer Needs and Preferences SCE has analyzed feedback regarding customer needs and preferences gained from its 2010 In-Home Display Field Trial, 9 SCE has considered this information 10 in developing this. Consistent with this approach, as part of Phase 1, SCE expects to monitor customer feedback and inquiries provided to SCE s call center, and perform customer surveys to measure satisfaction with specific program and technology attributes. The Phase 1 findings will be used to inform the planning and development of 9 Field trial to test functionality and RF capability of HAN devices used in SmartConnect TM HAN deployment 10 Customer feedback from the IHD Field Trial includes the following: (1) Customers find the capability to view current usage as well as the previous day energy usage very useful; (2) Displaying real-time cost information based on their billing tiers and specific tariff is important to the customer; (3) Customers desire the ability to compare their usage to similar households, (4) Customer interest by customers to view usage data diminished over time. 18

26 Phase 2. Similarly, Phase 2 customer findings will be evaluated and incorporated into SCE s future HAN program and services. M. Lessons Learned During Phase 1 and Phase 2, SCE plans to analyze the lessons learned related to operational processes, device registrations, customer conservation, customer education, communication issues (e.g., HAN devices dropped from the communications network), and retail channels. SCE plans to use Phase 1 and Phase 2 operational data and customer survey data to gain a better understanding of customer responses to near-real time data, and information provided in the text and alert messages. This will further SCE s understanding of customer behavior related to HAN devices and energy conservation. Consistent with D , SCE plans to work with PG&E, SDG&E, and Energy Division to share such findings on a statewide level. N. Customer Education and Outreach Pursuant to Ordering Paragraph 1.d of Resolution E-4527, beginning December 15, 2012, SCE will collaborate with the other IOUs, third parties, and CPUC Staff to provide basic education to customers about the HAN function available with their SmartConnect meters and its potential applications and benefits. For those customers who express interest in HAN, SCE will communicate the potential interoperability risks associated with HAN devices (both those that have gone through interoperability validation testing and those that have not). SCE will also communicate to those customers who express interest in HAN the respective responsibilities of SCE, the customer, and the third-party HAN device supplier in achieving device pairing with the SmartConnect meter, meeting device performance and quality expectations, and protecting customer usage data, network(s), and appliances. 19