SOCALGAS REBUTTAL TESTIMONY OF RENE F. GARCIA …€¦ · 21 to extend the AMIBA is appropriate...
Transcript of SOCALGAS REBUTTAL TESTIMONY OF RENE F. GARCIA …€¦ · 21 to extend the AMIBA is appropriate...
Company: Southern California Gas Company (U904G) Proceeding: 2016 General Rate Case Application: A.14-11-004 Exhibit: SCG-239-Garcia
SOCALGAS
REBUTTAL TESTIMONY OF RENE F. GARCIA
(ADVANCED METERING INFRASTRUCTURE POLICY)
June 2015
BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA
Doc# 297610
TABLE OF CONTENTS
I. INTRODUCTION................................................................................................................ 1 II. REBUTTAL TO PARTIES’ O&M PROPOSALS ........................................................... 2
A. SoCalGas proposes to file a Tier 2 advice letter in lieu of a Tier 3 advice letter shall the need to revise the per meter benefit arise. .................................................... 2
B. ORA mistakenly claims that SoCalGas can reallocate meter reading funding for MSA inspections; AMI-related meter reading savings are already accounted for in customer rates. ............................................................................................................... 3
III. REBUTTAL TO PARTIES’ CAPITAL PROPOSALS ................................................... 4 A. SoCalGas’ size 1-3 replacement meter purchases for 2014-2016 should be
authorized as requested since ORA ignored the impacts of AMI during Base Year (“BY”) 2013. ................................................................................................................... 4
IV. CONCLUSION .................................................................................................................... 7 APPENDIX A ............................................................................................................................ A-1
i Doc# 297610
SOCALGAS REBUTTAL TESTIMONY OF RENE F. GARCIA 1
(ADVANCED METERING INFRASTRUCTURE POLICY) 2
SoCalGas and Party Comparison 3
I. INTRODUCTION 4
Office of Ratepayer Advocates (“ORA”) issued its revised report on SoCalGas Advanced 5
Metering Infrastructure (“AMI”) Policy on May 11, 2015.1 The following is a summary of 6
ORA’s position(s): 7
• ORA agrees with SoCalGas’ request to “extend the Advanced Metering Infrastructure 8 Balancing Account (“AMIBA”) beyond project completion through 2018 or until the 9 full AMI costs and benefits can be reflected in a subsequent GRC”;2 and 10
• ORA recommends that the California Public Utilities Commission (“Commission”) 11 require SoCalGas to file a Tier 3 advice letter in the unlikely event the Commission 12 adopts Test Year (“TY”) 2016 General Rate Case (“GRC”) operating and 13 maintenance (“O&M”) expense levels that reflect AMI benefits already included in 14 the AMI revenue requirement.3 15
ORA also issued its report on SoCalGas’ Customer Services and Gas Distribution on April 24, 16
2015.4, 5 Though these reports do not explicitly discuss AMI, the following is a summary of 17
ORA’s positions as it relates to SoCalGas’ AMI Policy. 18
• ORA claims that SoCalGas should “incorporate/reallocate” meter reading savings in 19 order to fund Department of Transportation (“DOT”) mandated meter set assembly 20 (“MSA”) inspections and associated call volume increases in the TY 2016;6 and 21
• ORA claims that SoCalGas’ capital expenditure forecast request for meter 22 replacements is “excessive and inadequately supported.”7 23
24
1 Exhibit ORA-23-A Post-Test Year Ratemaking (“PTYR”) and SCG AMI, (“ORA-23-A”). 2 Exhibit ORA-23-A, at p.23, lines 5-7. 3 Exhibit ORA-23-A, at pp.24-25, lines 23,1-2. 4 Exhibit ORA-13 Customer Services (“ORA-13”). 5 Exhibit ORA-10 SoCalGas Gas Distribution (“ORA-10”). 6 Exhibit ORA-13, at p.60, lines 14-17 “SCG’s testimony does not discuss why it is not able to incorporate/reallocate embedded costs associated with activities performed by its meter reader positions (that will be phased out and have historically performed DOT MSA inspections) to fund its FSAs that will take over the compliance work.” and Exhibit ORA-13, at p. 77, lines 5-16. 7 Exhibit ORA-10, at p.62, lines 4-5.
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II. REBUTTAL TO PARTIES’ O&M PROPOSALS 1
A. SoCalGas proposes to file a Tier 2 advice letter in lieu of a Tier 3 advice 2 letter shall the need to revise the per meter benefit arise. 3
ORA agreed with SoCalGas’ request to extend the AMIBA beyond project completion 4
through 2018 or until the full AMI costs and benefits can be reflected in a subsequent GRC.8 5
ORA also agrees with SoCalGas’ proposal to file an advice letter seeking to revise the per meter 6
benefit used to calculate AMI benefits “in the unlikely event the Commission adopts TY 2016 7
O&M expense levels that reflect AMI benefits already included in the AMI revenue 8
requirement.” 9 9
However, ORA recommends that the Commission require SoCalGas to file a Tier 3 10
advice letter if the situation were to arise.10 SoCalGas disagrees with ORA’s recommendation to 11
file a Tier 3 advice letter and requests that the Commission allow SoCalGas to file a Tier 2 12
advice letter instead. Advice Letter (“AL”) 4110,11 a Tier 1 advice letter, established the 13
AMIBA, updated the revenue requirement and modified existing tariffs to implement Decision 14
(“D”) 10-04-027 per Ordering Paragraph (“OP”) 7. AL 4110 was filed after an extensive AMI 15
business case proceeding which entailed thorough Commission review and an intervening 16
process including discovery, data requests and hearings prior to being authorized in D.10-04-17
027. The Commission determined that AL 4110 was appropriate for Tier 1 advice letter filing 18
and any advice letter submitted for purposes to revise the per meter benefit would simply be a 19
modification of what was already submitted and approved in 2010. Use of a Tier 2 advice letter 20
to extend the AMIBA is appropriate because revising the AMIBA would not result in a rate 21
increase but would instead offset costs not authorized in the TY 2016 GRC decision that would 22
be associated to AMI benefits.12 23
8 Exhibit ORA-23-A PTYR and SCG AMI Policy, at p.5, lines 15-17. 9 Exhibit ORA-23-A, at p. 24, lines 19-23. 10 Exhibit ORA-23-A, at pp.24-25, lines 23, 1-2. 11 AL 4110, U 904 G, effective April 8, 2010. AL 4110 was approved by letter dated August 4, 2010. 12 SoCalGas assumes that ORA recommends filing a Tier 3 advice letter under the rules established in GO 96-B 5.3 (4) where the change would result in an increase to rates. Except for a change that may be submitted by advice letter pursuant to Industry Rules 5.1(1), 5.1(3), 5.1(7), 5.2(1), or 5.2(2), a change that would result in an increase to a rate or charge or a more restrictive term or condition, which change has been authorized by statute or by other Commission order to be requested by advice letter.
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B. ORA mistakenly claims that SoCalGas can reallocate meter reading funding 1 for MSA inspections; AMI-related meter reading savings are already 2 accounted for in customer rates.13 3
Once AMI deployment is completed, the meter reading function will be all but 4
eliminated.14 During deployment, costs that are “phased out” that are associated to the attrition 5
of the meter reading workforce are tracked as benefits in the AMIBA.15 ORA claims that 6
SoCalGas should reallocate meter reading savings in order to fund DOT MSA inspections in the 7
TY 2016, stating: 8
SCG’s testimony does not discuss why it is not able to incorporate/reallocate 9 embedded costs associated with activities performed by its meter reader positions 10 (that will be phased out and have historically performed DOT MSA inspections) 11 to fund its FSAs that will take over the compliance work.16 12
ORA also states that meter reading funding can be re-allocated to SoCalGas’ CCC – Operations 13
to cover costs of incremental calls resulting from the MSA inspection program, stating: 14
Additional funding over 2013 expense levels is not required for this activity. 15 SCG’s Meter Reading Department currently handles DOT MSA inspection 16 activity. SCG plans to eliminate its Meter Reading department, and the ratepayer 17 funding currently used by this department can be reallocated to SCG’s CCC – 18 Operations when the work is transferred to CCC – Operations.17 19
As AMI benefits associated with the meter reading function are already accounted for in 20
customer rates, meter reading funding is not available for SoCalGas to reallocate to MSA 21
inspections. ORA’s recommendation to reallocate meter reading funding that is already 22
accounted for as benefits in customer rates would essentially “double count” those savings. In 23
D.13-05-010, the Commission concluded that adopting certain O&M forecasts which already 24
incorporate AMI operating benefits would “result in a double reduction to SoCalGas’ revenue 25
requirement.”18 In addition, ORA’s recommendation contradicts Witness C. Tang’s position in 26
Exhibit ORA–23-A where it was acknowledged that it would be “unlikely” that the Commission 27
13 As a result of D.10-04-027, authorized project costs of $1.05 billion and O&M benefits of $184.8 million are currently being collected in rates, while actual costs and benefits are recorded in the AMIBA. 14 By 2018, SoCalGas customers, except those customers enrolled in the Opt-Out Program, will receive monthly bills based on AMI’s automated meter reads and no longer require a manual read done by a meter reader. 15 Exhibit ORA-13, at p. 60, line 16. 16 Exhibit ORA-13, at p. 60, lines 14-17. 17 Exhibit ORA-13, at p. 77, lines 9-14. 18 D.13-05-010, at p. 508.
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would adopt TY 2016 O&M expense levels that reflect AMI benefits already included in the 1
AMI revenue requirement.19 Hence, benefits associated with AMI, including meter reading 2
benefits, are already embedded in rates and therefore cannot be considered available funding in 3
TY 2016 GRC. To further clarify, the MSA inspection related costs forecasted by Witness Sara 4
Franke in Exhibit SCG-10 and by Witness Evan Goldman in Exhibit SCG-11 are incremental to 5
costs already authorized in D.10-04-027. As stated by Witness Franke, the “additional costs are 6
associated with performing required MSA inspections, post-AMI implementation.”20 7
III. REBUTTAL TO PARTIES’ CAPITAL PROPOSALS 8
A. SoCalGas’ size 1-3 replacement meter purchases for 2014-2016 should be 9 authorized as requested since ORA ignored the impacts of AMI during Base 10 Year (“BY”) 2013. 11
In D.10-04-027, AMI was authorized funding to replace 650,000 “accelerated” PMCs 12
during the project deployment period, through 2017. Accelerated PMCs are meters that would 13
normally have been replaced in the five-year period after AMI deployment (2018 through 2022). 14
By accelerating PMCs into the deployment period, SoCalGas avoids additional costs related to 15
revisiting the retrofitted meter (i.e. the existing meter in the field with a gas meter module 16
installed on it during deployment) to install a replacement meter (with a module married to it) 17
within five years after the AMI deployment period. 18
During the AMI deployment period Gas Distribution must also purchase 650,000 meters 19
for PMCs, as requested in TY 2012 GRC and as is being requested in TY 2016 GRC, i.e. 20
“business as usual” meters. Since funding for "business as usual" meter installations and 21
replacements is forecasted in a GRC, these meters would have been installed or replaced absent 22
AMI deployment. Since the two GRC periods overlap with the AMI deployment period, the 23
650,000 PMC meters equate to 130,000 meters per year as requested in TY 2012 GRC and 24
authorized in D.13-05-010 as well as 130,000 meters per year as requested in TY 2016 GRC. In 25
addition, RMCs continue to be worked by SoCalGas’ Customer Services Field and funded by 26
Gas Distribution. RMC purchases, as authorized in D.13-05-010, and as requested in TY 2016 27
GRC equate to a total of 250,000 meters or 50,000 meters per year for the five-year deployment 28
period. 29
19 Exhibit ORA-23-A, at p. 24, lines 19-23. 20 SCG-10, at SAF-10, lines 23-26.
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In Exhibit ORA-10, ORA takes issue with SoCalGas’ capital forecast for meter purchases 1
due to relatively low activity in BY 2013. ORA claims that SoCalGas’ proposal, which is “84% 2
above the 2013 recorded level, is excessive and inadequately supported.”21 ORA states: 3
In the base year of 2013, SoCalGas replaced less than 100,000 meters from both 4 the PMC and RMC programs, yet for the test year period SoCalGas proposes to 5 purchase almost 200,000 meters, close to twice the number of meters replaced in 6 2013.22 7
SoCalGas disagrees with ORA’s position. Compared to prior GRC periods, annual meter 8
purchases are lower for regular operations in 2013. However, 2013 represents the first full year 9
of the AMI deployment. In addition, in previous data request responses to ORA, SoCalGas 10
explained the relationship between SoCalGas’ AMI and GRC funded meter purchases23 where 11
size 1-3 meter purchases and replacement timelines for regular operations are affected by the 12
AMI project deployment.24 13
For example, as explained in response to ORA-SCG-DR-12-DAO, Question 5.a,25 the 14
majority of the small meters that were purchased in 2013 were funded by AMI. While AMI 15
funded more meters in 2013 and the GRC funded fewer meters in 2013, purchase quantities will 16
ultimately balance out during the full AMI deployment period (2013-2017). The response to 17
Question 4.a in ORA-SCG-DR-12-DAO further explains the reason as to why there were fewer 18
GRC funded meters in 2013, as stated: 19
Note, in addition to CSF-completed small meter replacements, the Advanced 20 Metering Infrastructure (AMI) project team has also been performing small meter 21 replacements in order to fully integrate with the scheduling and routing of AMI 22 deployment. The number of small meter changes completed by CSF in 2013 23 excludes a total of 241,041 small meter changes that were completed as part of 24 SoCalGas’ Advanced Metering Infrastructure (AMI) implementation. 25
In order to adhere to the AMI implementation schedule, beginning in 2013, the 26 AMI project assumed responsibility for above-ground PMCs, including both 27 planned and accelerated meter changes, and Customer Service Field (“CSF”) 28 shifted its focus to curb meter changes. This trade-off (i.e., the AMI project team 29 focusing on above-ground meters and CSF focusing on curb meters) enabled a 30
21 Exhibit ORA-10, at p. 62, lines 3-4. 22 ORA-10, p. 60, lines 12-15. 23 See SoCalGas’ response to ORA-SCG-DR-064-DAO, Question 29 in Appendix A, Attachment A1 and ORA-SCG-DR-064-DAO, Question 42 in Appendix A, Attachment A2. 24 Size 1-3 meters include planned meter changes (“PMCs”) and routine meter changes (“RMCs”). 25 See SoCalGas’ response to ORA-SCG-DR-012-DAO, Question 5.a in Appendix A, Attachment A3.
RFG-5 Doc#
better match between the work and employee skill sets. Over the course of the 1 AMI deployment period (2013-2017), all GRC- and AMI-funded PMCs will be 2 completed.26 3
Although AMI purchased the majority of the size 1-3 meters in 2013, AMI will fund no 4
more than the 650,000 meters for accelerated PMCs as authorized in D.10-04-027 and the GRC 5
will fund the purchase of 650,000 “current” year PMCs over the five-year deployment period. 6
Table 1 below, as provided in the response to ORA-SCG-DR-012-DAO, Question 5.a, illustrates 7
the authorized or forecasted small meter replacements by year. 27 8
Table RFG-1 9
Authorized or Forecasted Small Meter Replacements 10 11
2013 2014 2015 2016 2017 Total GRC- PMCs 130,000 130,000 130,000 130,000 130,000 650,000 GRC-RMCs 50,000 50,000 50,000 50,000 50,000 250,000 GRC Total 180,000 180,000 180,000 180,000 180,000 900,000 AMI-Accelerated PMCs (2018-2022) 130,000 130,000 130,000 130,000 130,000 650,000
As provided in ORA-SCG-DR-012-DAO, Question 5.a, Table 2 below illustrates the actual and 12
estimated distribution of meter purchases during the AMI deployment period. SoCalGas would 13
like to clarify that the 91,107 GRC funded meters in 2013 as provided in ORA-SCG-DR-012-14
DAO, Question 5.a represents size 1-3 RMCs and PMCs as well as size 4+ PMCs. In Exhibit 15
ORA-10, Table 10-35, the 91,107 meters for 2013 suggests that it only includes size 1-3 meters 16
and excludes size 4+ PMCs. 17
Table RFG-2 18
Actual or Estimated Small Meter Purchases for Meter Replacements, by Year 19 20
Actual 2013
Estimated 2014 2015 2016 2017 Total
GRC Funded 91,107 160,000 216,298 216,298 216,298 900,000 AMI Funded 288,232 195,000 166,768 - - 650,000 *GRC meters purchased in 2013 include size 4 meters which are typically purchased in small volumes
26 See SoCalGas response to ORA-SCG-DR-012-DAO, Question 4.a in Appendix A, Attachment A4. 27 See SoCalGas’ response to ORA-SCG-DR-012-DAO, Question 5.a in Appendix A, Attachment A3.
RFG-6 Doc#
Subsequently, ORA-SCG-DR-064-DAO was issued requesting 2014 meter purchases; SoCalGas 1
provided actual purchases at that time. Table 3 below is consistent with what was provided in 2
the response to ORA-SCG-DR-064-DAO, Question 29.28 3
Table RFG-3 4
Meter Purchases in 2014 5 6
Provided in the table in the response to ORA-SCG-DR-064-DAO, Question 29
GRC Funded-
New Business
Meter Sets
GRC Funded- Historical PMCs
and RMCs (Meters Purchased in 2014 Less New
Meter Sets)
GRC Funded Total Meters
Purchased
Size 1 - 3 Meters 29,934 191,945 221,879 Size 4+ Meters 2,524 7,376 9,900 Total 32,458 199,321 231,779
As illustrated in Table 3, GRC-funded size 1 through 3 meter purchases for PMCs and RMCs in 7
2014 exceed the GRC forecast of 180,000 annual meter purchases which is consistent with 8
SoCalGas’ response to ORA-SCG-DR-012-DAO, Questions 4.a. and 5.a.29 SoCalGas is also on 9
track to purchase the amount of meters authorized in D.10-04-027 for AMI. Ultimately, AMI 10
and GRC meter purchases will balance out by the end of the full AMI deployment period (2013-11
2017). Meaning, by the end of the AMI deployment, AMI will purchase 650,000 meters for the 12
“accelerated” PMCs and regular operations will purchase 650,000 meters for the “current year” 13
PMCs and 250,000 meters for RMCs. Therefore, the size 1 through 3 replacement meter 14
purchases requested by Witness Frank B. Ayala, Exhibit SCG-04, are consistent with planned 15
forecasts and ORA’s proposed disallowance should be rejected. 16
IV. CONCLUSION 17
SoCalGas appreciates ORA’s acceptance of the AMI Policy proposals. In the unlikely 18
event the Commission adopts TY 2016 O&M expense levels that reflect AMI benefits already 19
included in the AMI revenue requirement, SoCalGas requests authorization to file a Tier 2 20
Advice Letter. In addition, SoCalGas disagrees with ORAs recommendation in the Customer 21
28See SoCalGas response to ORA-SCG-DR-064-DAO, Question 29 in Appendix A, Attachment A1. 29 See Appendix A, Attachment A3 and Attachment A2.
RFG-7 Doc#
Services area, represented by Witness Sara Franke (Exhibit SCG-10) and by Witness Evan 1
Goldman (Exhibit SCG-11), to reallocate avoided meter reading funds to the proposed MSA 2
inspection program as meter reading benefits are already in rates and are not available for 3
reallocation. Moreover, doing so would result in a double counting of benefits and would 4
require an adjustment to the current AMIBA and benefits per meter calculation via advice letter. 5
Finally, SoCalGas rejects the suggested decrease in capital funding in the Gas Distribution area 6
for small meter replacements (sizes 1-3) since ORA ignored relevant and supporting facts 7
provided to them in Data Requests. As such, SoCalGas requests authorization of capital funding 8
for small replacement meters as presented in the Gas Distribution Testimony of Witness Frank 9
Ayala (Exhibit SCG-04). 10
This concludes my prepared rebuttal testimony. 11
RFG-8 Doc#
APPENDIX
TO
REBUTTAL TESTIMONY
OF RENE F. GARCIA
ON BEHALF OF SOCALGAS
ADVANCED METERING INFRASTRUCTURE POLICY
RFG-A-1
APPENDIX ATTACHMENTS
A. Responses to Data Requests
1. ORA-SCG-DR-064-DAO, Question 29
2. ORA-SCG-DR-064-DAO, Question 42
3. ORA-SCG-DR-012-DAO, Question 5.a
4. ORA-SCG-DR-012-DAO, Question 4.a
RFG-A-2
Attachment A1
ORA-SCG-DR-064-DAO, Question 29
RFG-A-3
ORA DATA REQUEST
ORA-SCG-DR-064-DAO
SOCALGAS 2016 GRC – A.14-11-004
SOCALGAS FINAL RESPONSE
DATE RECEIVED: FEBRUARY 12, 2015
DATE RESPONDED: MARCH 18, 2015
29. Referring to page 163 of the workpapers, please provide the number of meters purchased by
size for (i) installation at new customers’ premises, (ii) replacements due to meter accuracy,
age or operation, (iii) replacements due to a pre-determined replacement cycle based on
meter capacity, size, and performance.
SoCalGas Response:
The number of meters purchased is not tracked by the type of installation. An estimated
breakdown of the meter purchases by installation type is shown in the table below. This is the
same estimation method that was used for the historical meters in Supplemental Workpaper
SCG-FBA-CAP-SUP-009 beginning at page 171 of the capital workpapers exhibit SCG-04-
CWP_GDIST.
Meter Size New
Business
Meter Sets
Historical PMCs and RMCs
(Meters Purchased in 2014
Less New Meter Sets)
Total
Meters
Purchased
Size 1 - 3 Meters 29,934 191,945 221,879
Size 4+ Meters 2,524 7,376 9,900
Total 32,458 199,321 231,779
The numbers presented in the above table are those that are funded in the GRC. In addition,
294,583 small meters (above- ground and curb) and 2,248 size 4+ meters were purchased in
2014 that were funded by SoCalGas AMI. Please refer to the response to ORA-SCG-DR-012-
DAO, Question 5.a., for discussion of how SoCalGas is managing the purchase of small meters
during the AMI deployment period (2013-2017).
RFG-A-4
Attachment A2
ORA-SCG-DR-064-DAO, Question 42
RFG-A-5
ORA DATA REQUEST
ORA-SCG-DR-064-DAO
SOCALGAS 2016 GRC – A.14-11-004
SOCALGAS FINAL RESPONSE
DATE RECEIVED: FEBRUARY 12, 2015
DATE RESPONDED: MARCH 18, 2015
42. Provide the total amount of funding SoCalGas receives for AMI deployment each year from
2013-2017. Of this total, provide the annual amount received for meters and for regulators
broken down by labor and non-labor elements.
SoCalGas Response:
Prepared by AMI Policy Witness Rene Garcia (Exhibit SCG-39)
See attachment “ORA-SCG-DR-064-DAO-Q.42 Attachment.xlsx” for:
1. A high-level summary of SoCalGas’ funding for AMI deployment between 2010-2017
(Refer to the tab titled: ORA-SCG-DR-064-DAO Q42 Attach A);
2. The detailed funding by year authorized in SoCalGas AMI D.10-04-027 (Refer to the tab
titled: ORA-SCG-DR-064-DAO Q42 Attach B); and
3. The amount funded for meters and regulators for years 2013-2017, broken down by labor
and non-labor (Refer to the tab titled: ORA-SCG-DR-064-DAO Q42 Attach C).
The table below is a high-level summary of SoCalGas’ funding and the associated projected unit
counts for AMI deployment.
AMI Deployment Plan by
Unit Type
AMI Funding by Unit
Type - In 2013 $000s 4
In 2013 Direct Dollars
(with Vacation & Sick)
Total Total
AMI Module Purchases & Module Installations
Module Purchases (for both Field & Factory retrofits) 6,047,397 $300,174
Module Installation - Field Retrofit 3,695,441 $83,026
Module Installation - Factory Retrofit 2,351,956 $11,153
Meter Replacements Due to AMI Deployment 1 1,052,092 $160,931
"Business As Usual" Meter Installations/Replacements 2 1,299,864 $ -
Regulator Replacements 233,502 $19,591
Other AMI Funding (Network, Information Technology,
etc.) N/A $364,119
Total 5
$938,994
1 AMI requested and was approved funding for the cost of meters being replaced as a result of AMI
deployment that would not have been replaced otherwise
2 Funding for "Business As Usual" meter installations and replacements is forecasted in a GRC; these
meters would have been installed or replaced absent AMI deployment; e.g., growth meters, PMCs,
RMCs. Only the cost of the modules and the factory retrofit (i.e., the marrying of the communications
module to the meter) associated with these meters are included in AMI funding.
RFG-A-6
ORA DATA REQUEST
ORA-SCG-DR-064-DAO
SOCALGAS 2016 GRC – A.14-11-004
SOCALGAS FINAL RESPONSE
DATE RECEIVED: FEBRUARY 12, 2015
DATE RESPONDED: MARCH 18, 2015
Response to Question 42 (Continued)
3 AMI requested and was approved funding for regulators associated with the meter replacements being
performed as a result of AMI deployment; regulator replacements performed as a normal course of
business regardless of AMI deployment are forecast in a GRC.
4 Although ORA did not request approved funding for 2011-2012, it is included in this response in order
to tie to total approved funding for SoCalGas AMI per Decision 10-04-027.
5 In order to be comparable to the TY 2016 GRC, the amounts provided are shown in 2013 direct dollars
with Vacation and Sick, excluding overheads; whereas, the authorized $1.05 billion is in nominal dollars
with all overheads.
RFG-A-7
OR
A-S
CG
-DR
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OR
A-S
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ttach
A
2011
2012
2013
2014
2015
2016
2017
Tot
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MI M
odul
e Pu
rcha
ses &
Mod
ule
Inst
alla
tions
Mod
ule
Purc
hase
s (fo
r bot
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eld
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ry re
trofit
s)1,
040,
718
1,
322,
806
1,
343,
640
1,34
7,11
4
99
3,11
9
6,
047,
397
Mod
ule
Inst
alla
tion
- Fie
ld R
etro
fit59
2,05
6
84
4,26
9
86
0,71
7
862,
277
53
6,12
2
3,
695,
441
Mod
ule
Inst
alla
tion
- Fac
tory
Ret
rofit
448,
662
478,
537
482,
923
48
4,83
7
456,
997
2,35
1,95
6
19
6,88
7
21
9,84
4
22
1,42
5
221,
627
19
2,30
9
1,
052,
092
"Bus
ines
s As U
sual
" M
eter
Inst
alla
tions
/Rep
lace
men
ts 2
251,
775
258,
693
261,
497
26
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1
264,
688
1,29
9,86
4
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men
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,558
49
,533
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50
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76
233,
502
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N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
2011
2012
2013
2014
2015
2016
2017
Tot
alA
MI M
odul
e Pu
rcha
ses &
Mod
ule
Inst
alla
tions
Mod
ule
Purc
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s (fo
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$
-
$
50
,211
$
65
,552
$
67,0
26$
67
,229
$
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55$
300,
174
$
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Ret
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-$
-$
13,3
02$
18,9
68$
19
,338
$
19,3
73$
12
,045
$
83
,026
$
Mod
ule
Inst
alla
tion
- Fac
tory
Ret
rofit
-$
-$
2,12
7$
2,
270
$
2,
291
$
2,30
0$
2,
166
$
11
,153
$
-$
-$
29,7
85$
33,7
51$
34
,073
$
34,1
55$
29
,166
$
16
0,93
1$
"Bus
ines
s As U
sual
" M
eter
Inst
alla
tions
/Rep
lace
men
ts 2
-$
-$
-$
-$
-
$
-
$
-$
-
$
Reg
ulat
or R
epla
cem
ents
-$
-$
3,58
7$
4,
142
$
4,
182
$
4,18
9$
3,
491
$
19
,591
$
Oth
er A
MI F
undi
ng (N
etw
ork,
Info
rmat
ion
Tec
hnol
ogy,
etc
.)24
,472
$
58
,206
$
50
,697
$
52
,205
$
55,3
88$
57
,038
$
66,1
13$
364,
119
$
24
,472
$
58
,206
$
14
9,70
8$
17
6,88
9$
18
2,29
9$
184,
283
$
16
3,13
7$
93
8,99
4$
1 AM
I req
uest
ed a
nd w
as a
ppro
ved
fund
ing
for t
he c
osts
of m
eter
s bei
ng re
plac
ed a
s a re
sult
of A
MI d
eplo
ymen
t tha
t wou
ld n
ot h
ave
been
repl
aced
oth
erw
ise
4 Alth
ough
OR
A d
id n
ot re
ques
t app
rove
d fu
ndin
g fo
r 201
1-20
12, i
t is i
nclu
ded
in th
is re
spon
se in
ord
er to
tie
to to
tal a
ppro
ved
fund
ing
for S
oCal
Gas
AM
I per
Dec
isio
n 10
-04-
027
5 In
ord
er to
be
com
para
ble
to th
e TY
201
6 G
RC
, the
am
ount
s pro
vide
d ar
e sh
own
in 2
013
dire
ct d
olla
rs w
ith V
acat
ion
and
Sick
, exc
ludi
ng o
verh
eads
; whe
reas
, the
aut
horiz
ed $
1.05
bill
ion
is in
nom
inal
dol
lars
with
all
over
head
s.
AM
I Dep
loym
ent P
lan
by U
nit T
ype
2 Fun
ding
for "
Bus
ines
s As U
sual
" m
eter
inst
alla
tions
and
repl
acem
ents
is fo
reca
sted
in a
GR
C; t
hese
met
ers w
ould
hav
e be
en in
stal
led
or re
plac
ed a
bsen
t AM
I dep
loym
ent;
e.g.
, gro
wth
met
ers,
PMC
s, R
MC
s. O
nly
the
cost
of
the
mod
ules
and
the
fact
ory
retro
fit (i
.e. t
he m
arry
ing
of th
e co
mm
unic
atio
ns m
odul
e to
the
met
er) a
ssoc
iate
d to
thes
e m
eter
s are
incl
uded
in th
e A
dvan
ced
Met
er B
usin
ess C
ase.
3 AM
I req
uest
ed a
nd w
as a
ppro
ved
fund
ing
for r
egul
ator
s ass
ocia
ted
with
the
met
er re
plac
emen
ts b
eing
per
form
ed a
s a re
sult
of A
MI d
eplo
ymen
t; re
gula
tor r
epla
cem
ents
per
form
ed a
s a n
orm
al c
ours
e of
bus
ines
s reg
ardl
ess o
f A
MI d
eplo
ymen
t are
fore
cast
in a
GR
C
Met
er R
epla
cem
ents
Due
to A
MI D
eplo
ymen
t 1
Met
er R
epla
cem
ents
Due
to A
MI D
eplo
ymen
t 1
AM
I Fun
ding
by
Uni
t Typ
e - I
n 20
13 $
000s
4
In 2
013
Dir
ect D
olla
rs (w
ith V
acat
ion
& S
ick)
OR
A-S
CG
-DR
-064
-DA
O Q
42 A
ttach
A
RFG-A-8
OR
A-S
CG
-DR
-06
4-D
AO
-Q.4
2 A
tta
ch
men
t.xls
m
OR
A-S
CG
-DR
-06
4-D
AO
Q4
2 A
tta
ch
B
OR
A-S
CG
-DR
-06
4-D
AO
Ques
tion 4
2 W
ork
pap
er
Att
achm
ent
"A"
- S
oC
alG
as A
pp
roved
Fundin
g 2
01
1-2
01
7
20
13
20
14
20
15
20
16
20
17
Tota
l2
01
12
01
22
01
32
01
42
01
52
01
62
01
7T
ota
l
SoC
alG
as
Con
nec
ted
Met
er C
ou
nt
per
AM
I B
usi
nes
s C
ase
1,0
40
,71
8
1,3
22
,80
6
1,3
43
,64
0
1,3
47
,11
4
99
3,1
19
6,0
47
,39
7
AM
I M
od
ule
Pu
rch
ase
s &
Mod
ule
In
sta
lla
tion
s
Module
Purc
has
es (
for
both
Fie
ld &
Fa
cto
ry r
etro
fits
)1
,04
0,7
18
1,3
22
,80
6
1,3
43
,64
0
1,3
47
,11
4
99
3,1
19
6,0
47
,39
7
-$
-$
50
,21
1$
65
,55
2$
67
,02
6$
67
,22
9$
50
,15
5$
30
0,1
74
$
Module
Inst
alla
tion -
Fie
ld R
etro
fit
59
2,0
56
84
4,2
69
86
0,7
17
86
2,2
77
53
6,1
22
3,6
95
,44
1
-$
-$
13
,30
2$
18
,96
8$
19
,33
8$
19
,37
3$
12
,04
5$
83
,02
6$
Module
Inst
alla
tion -
Fa
cto
ry R
etro
fit
44
8,6
62
47
8,5
37
48
2,9
23
48
4,8
37
45
6,9
97
2,3
51
,95
6
-$
-$
2,1
27
$
2,2
70
$
2,2
91
$
2,3
00
$
2,1
66
$
11
,15
3$
Ga
s M
eter
s
Inco
mp
atib
le M
eter
s
Curb
Met
ers
34
,68
3
44
,08
4
44
,77
8
44
,89
4
33
,09
7
20
1,5
36
-$
-$
9,1
84
$
11
,68
6$
11
,87
4$
11
,90
8$
8,7
81
$
53
,43
3$
Ab
ove
Gro
und (
AG
) M
eter
s (n
o a
vai
lab
le g
as A
MI
module
)2
4,9
29
35
,54
8
36
,24
1
36
,30
6
22
,57
4
15
5,5
97
-$
-$
2,8
85
$
4,0
52
$
4,1
33
$
4,1
42
$
2,6
35
$
17
,84
8$
Med
ium
and L
arge
Met
er R
ebuil
ds
1,0
43
1,3
25
1,3
46
1,3
50
99
5
6,0
59
-$
-$
3,1
02
$
3,1
02
$
3,1
02
$
3,1
02
$
3,1
02
$
15
,51
0$
Met
ers
Dam
aged
Duri
ng M
odule
Inst
alla
tion (
req
uir
ing m
eter
chan
ge)
6,2
32
8,8
87
9,0
60
9,0
77
5,6
43
38
,89
9
-$
-$
65
0$
92
8$
94
8$
95
1$
59
2$
4,0
70
$
5-Y
ear
Post
Dep
loym
ent
PM
Cs
(20
18
-20
22
acc
eler
ated
PM
Cs)
13
0,0
00
13
0,0
00
13
0,0
00
13
0,0
00
13
0,0
00
65
0,0
00
-$
-$
13
,96
4$
13
,98
2$
14
,01
6$
14
,05
2$
14
,05
6$
70
,06
9$
Su
b-t
ota
l M
eter
Rep
lace
men
ts1
96
,88
7
21
9,8
44
22
1,4
25
22
1,6
27
19
2,3
09
1,0
52
,09
2
-$
-$
29
,78
5$
33
,75
1$
34
,07
3$
34
,15
5$
29
,16
6$
16
0,9
31
$
"B
usi
nes
s A
s U
sua
l" M
eter
In
sta
lla
tion
s/R
epla
cem
ents
2
New
Busi
nes
s M
eter
Inst
alla
tions
(gro
wth
met
ers)
62
,33
4
69
,25
2
72
,05
6
73
,77
0
75
,24
7
35
2,6
59
-$
-$
-$
-$
-$
-$
-$
-$
Curr
ent
Yea
r M
eter
Chan
ges
Siz
e 0
1-0
3 (
PM
Cs
and R
MC
s)1
80
,00
0
18
0,0
00
18
0,0
00
18
0,0
00
18
0,0
00
90
0,0
00
-$
-$
-$
-$
-$
-$
-$
-$
Curr
ent
Yea
r M
eter
Chan
ges
Siz
e 0
4+
(P
MC
s &
RM
Cs)
9,4
41
9,4
41
9,4
41
9,4
41
9,4
41
47
,20
5
-$
-$
-$
-$
-$
-$
-$
-$
Su
b-t
ota
l "
Bu
sin
ess
As
Usu
al"
Met
er I
nst
all
ati
on
s/C
ha
ng
es2
51
,77
5
25
8,6
93
26
1,4
97
26
3,2
11
26
4,6
88
1,2
99
,86
4
-$
-$
-$
-$
-$
-$
-$
-$
Tota
l M
eter
In
sta
lla
tion
s D
uri
ng
AM
I D
eplo
ym
ent
Per
iod
44
8,6
62
47
8,5
37
48
2,9
23
48
4,8
37
45
6,9
97
2,3
51
,95
6
Reg
ula
tors
3
Curb
Reg
ula
tors
(5
0%
of
curb
met
er r
epla
cem
ents
)1
7,3
42
22
,04
2
22
,38
9
22
,44
7
16
,54
8
10
0,7
68
-$
-$
1,9
15
$
2,4
35
$
2,4
73
$
2,4
79
$
1,8
27
$
11
,12
9$
AG
Reg
ula
tors
(1
5%
of
"incr
emen
tal"
AG
sm
all
met
er r
epla
cem
ents
)2
4,1
74
26
,16
5
26
,29
5
26
,30
7
23
,73
3
12
6,6
75
-$
-$
43
2$
46
8$
47
0$
47
0$
42
4$
2,2
64
$
Med
ium
and L
arge
Reg
ula
tors
1,0
43
1,3
25
1,3
46
1,3
50
99
5
6,0
59
-$
-$
1,2
40
$
1,2
40
$
1,2
40
$
1,2
40
$
1,2
40
$
6,1
98
$
Oth
er A
MI
Fu
nd
ing
(N
etw
ork
, In
form
ati
on
Tec
hn
olo
gy
, et
c.)
N/A
N/A
N/A
N/A
N/A
N/A
24
,47
2$
58
,20
6$
50
,69
7$
52
,20
5$
55
,38
8$
57
,03
8$
66
,11
3$
36
4,1
19
$
Tota
l A
MI
Fu
nd
ing
24
,47
2$
58
,20
6$
14
9,7
08
$
17
6,8
89
$
18
2,2
99
$
18
4,2
83
$
16
3,1
37
$
93
8,9
94
$
1 A
MI
req
ues
ted a
nd w
as a
pp
roved
fundin
g f
or
the
cost
s of
met
ers
bei
ng r
epla
ced a
s a
resu
lt o
f A
MI
dep
loym
ent
that
would
not
hav
e b
een r
epla
ced o
ther
wis
e
3 A
MI
req
ues
ted a
nd w
as a
pp
roved
fundin
g f
or
regula
tors
ass
oci
ated
wit
h t
he
met
er r
epla
cem
ents
bei
ng p
erfo
rmed
as
a re
sult
of
AM
I dep
loym
ent;
reg
ula
tor
rep
lace
men
ts p
erfo
rmed
as
a norm
al c
ours
e of
busi
nes
s re
gar
dle
ss o
f A
MI
dep
loym
ent
are
fore
cast
in a
GR
C
4 A
lthough O
RA
did
not
req
ues
t ap
pro
ved
fundin
g f
or
20
11
-20
12
, it
is
incl
uded
in t
his
res
ponse
in o
rder
to t
ie t
o t
ota
l ap
pro
ved
fundin
g f
or
SoC
alG
as A
MI
per
Dec
isio
n 1
0-0
4-0
27
5 In
ord
er t
o b
e co
mp
arab
le t
o t
he
TY
20
16
GR
C, th
e am
ounts
pro
vid
ed a
re s
how
n i
n 2
01
3 d
irec
t doll
ars
wit
h V
acat
ion a
nd S
ick, ex
cludin
g o
ver
hea
ds;
wher
eas,
the
auth
ori
zed $
1.0
5 b
illi
on i
s in
nom
inal
doll
ars
wit
h a
ll o
ver
hea
ds.
2 F
undin
g f
or
"Busi
nes
s A
s U
sual
" m
eter
inst
alla
tions
and r
epla
cem
ents
is
fore
cast
ed i
n a
GR
C;
thes
e m
eter
s w
ould
hav
e b
een i
nst
alle
d o
r re
pla
ced a
bse
nt
AM
I dep
loym
ent;
e.g
., g
row
th m
eter
s, P
MC
s, R
MC
s. O
nly
the
cost
of
the
module
s an
d t
he
fact
ory
ret
rofi
t (i
.e. th
e m
arry
ing o
f th
e co
mm
unic
atio
ns
module
to t
he
met
er)
asso
ciat
ed t
o t
hes
e m
eter
s
are
incl
uded
in t
he
Advan
ced M
eter
Busi
nes
s C
ase.
AM
I D
eplo
ymen
t P
lan b
y U
nit
Typ
e
AM
I F
undin
g b
y U
nit
Typ
e -
In 2
01
3 $
00
0s
4
In 2
01
3 D
irec
t D
oll
ars
(wit
h V
acat
ion &
Sic
k)
Met
er R
epla
cem
ents
Du
e to
AM
I D
eplo
ym
ent
1
OR
A-S
CG
-DR
-06
4-D
AO
Q4
2 A
tta
ch
B
RFG-A-9
OR
A-S
CG
-DR
-064
-DA
O-Q
.42
Atta
chm
ent.x
lsm
OR
A-S
CG
-DR
-064
-DA
O Q
42 A
ttach
C
OR
A-S
CG
-DR
-064
-DA
O Q
uest
ion
42 W
orkp
aper
Atta
chm
ent "
C"
- SoC
alG
as A
ppro
ved
Fund
ing
for M
eter
s & R
egul
ator
s Bro
ken
Dow
n by
Lab
or &
Non
-labo
r Ele
men
ts 2
013-
2017
2013
2014
2015
2016
2017
Tota
lA
MI F
unde
d G
as M
eter
Rep
lace
men
tsLa
bor
8,16
7$
9,24
4$
9,33
7$
9,36
4$
8,02
5$
44,1
38$
Non
-labo
r21
,618
$
24,5
07$
24
,736
$
24,7
91$
21
,141
$
116,
793
$
Tot
al29
,785
$
33,7
51$
34
,073
$
34,1
55$
29
,166
$
160,
931
$
AM
I Fun
ded
Reg
ulat
ors 1
Cur
b R
egul
ator
s1,
915
$
2,
435
$
2,
473
$
2,
479
$
1,
827
$
11
,129
$
A
bove
Gro
und
Reg
ulat
ors
1,67
2$
1,70
7$
1,70
9$
1,71
0$
1,66
4$
8,46
2$
T
otal
Non
-labo
r3,
587
$
4,
142
$
4,
182
$
4,
189
$
3,
491
$
19
,591
$
AM
I Fun
din g
In 2
013
Dire
ct D
olla
rs (w
ith V
acat
ion
& S
ick)
In
000
s
1 The
regu
lato
r rep
lace
men
ts in
clud
ed in
the
AM
I bus
ines
s cas
e ar
e as
sum
ed to
be
perf
orm
ed in
con
junt
ion
with
an
incr
emen
tal
met
er re
plac
emen
t. T
he ti
me
and
labo
r cos
ts a
ssoc
iate
d w
ith th
e re
gula
tor r
epla
cem
ent i
s em
bedd
ed in
the
met
er re
plac
emen
t lab
or
cost
s
OR
A-S
CG
-DR
-064
-DA
O Q
42 A
ttach
C
RFG-A-10
Attachment A3
ORA-SCG-DR-012-DAO, Question 5.a
RFG-A-11
ORA DATA REQUEST
ORA-SCG-DR-012-DAO
SOCALGAS 2016 GRC – A.14-11-004
SOCALGAS RESPONSE
DATE RECEIVED: NOVEMBER 24, 2014
DATE RESPONDED: DECEMBER 15, 2014
5. Referring to page 171 of the workpapers, please provide the following:
a. An explanation for the significant increase from 91,107 meters SoCalGas replaced in
2013 and the utility’s forecast of 180,000 replacement each year from 2014-2016.
Please include any and all workpapers and/or calculations used to support SoCalGas’
forecasts.
b. Provide a breakdown of the 180,000 size 1-3 meter replacements planned for each
year from 2014-2016 for the (i) RMC and (ii) the PMC.
c. Did SoCalGas perform any replacement of size 4+ meters as part of its PMC
program? If yes, please provide the number of size 4+ meters replaced each year
from 2009-2014 YTD as part of the PMC program. If no, please explain why it has
not done so in previous years.
d. Did SoCalGas perform any replacement of size 1-3 meters as part of its PMC
program? If yes, please provide the number of size 1-3 meters replaced as part of its
PMC program. If no, please explain why it has not done so in previous years.
SoCalGas Response:
NOTE: This question raises issues that extend beyond the scope and subject matter expertise of
the Gas Distribution area. As stated on page FBA-125 of Exhibit SCG-04, “Field labor costs
associated with SoCalGas’ planned small meter replacement program are covered in the prepared
direct testimony of Sara Franke, Exhibit SCG-10.” As such, SoCalGas’ response has been
bifurcated as such:
response to 5a was prepared by the Customer Services Field and AMI Policy witnesses
(Sara Franke and Rene Garcia);
responses to 5b and 5d were prepared by Customer Services Field;
response to 5c was prepared by Gas Distribution.
Any further inquiries should therefore be addressed to the responsible witness areas.
RFG-A-12
ORA DATA REQUEST
ORA-SCG-DR-012-DAO
SOCALGAS 2016 GRC – A.14-11-004
SOCALGAS RESPONSE
DATE RECEIVED: NOVEMBER 24, 2014
DATE RESPONDED: DECEMBER 15, 2014
Response to Question 5.a.:
Prepared by Customer Services Field (SCG-10) and AMI Policy (SCG-39):
To clarify, the 91,107 meters shown in column [D] of Table 1 on page 171 of SCG-04-CWP
are the number of meters purchased in 2013 with GRC capital funding. This is different than
the number of small meters that were replaced in 2013. The number of meters replaced
varies from year to year but, on average, SoCalGas expects to incur the cost of replacing
approximately 180,000 meters per year, which consists of approximately 130,000 PMCs and
50,000 RMCs. The forecast is consistent with projected meter failure/replacement rates
adopted by the Commission in Decision 13-05-010.
As explained in response to question 4.a. above, the vast majority of small meters replaced in
2013 were performed by the AMI project team. In addition, the majority of the small meters
that were purchased in 2013 were funded by AMI. While AMI funded the purchase of more
meters in 2013 and the GRC funded fewer meters in 2013, the timing of the purchases will
ultimately balance out during the AMI deployment period (2013-2017) such that AMI will
fund only the AMI authorized 650,000 meter replacements (explained below) and GRC will
fund a comparable 650,000.
AMI was authorized funding to replace 650,000 “accelerated” PMCs in Decision (D.) 10-04-
027. These accelerated PMCs are meters that would normally have been replaced in the 5
year period following AMI deployment (2018 through 2022) or approximately 130,000
accelerated PMCs each year of deployment. In conjunction with this, SoCalGas was
authorized funding to replace 130,000 small meters (PMCs) annually in the 2012 GRC. In
2013, AMI purchased the majority of the meters, however, AMI will fund no more than the
650,000 meters that were authorized in D.10-04-027 and the GRC will fund the purchase of
650,000 “current” year PMCs over the 5-year deployment period (approximately 130,000
each year). The following tables provide an illustration of this.
RFG-A-13
ORA DATA REQUEST
ORA-SCG-DR-012-DAO
SOCALGAS 2016 GRC – A.14-11-004
SOCALGAS RESPONSE
DATE RECEIVED: NOVEMBER 24, 2014
DATE RESPONDED: DECEMBER 15, 2014
SoCalGas Response to Question 5.a., (Continued):
Prepared by Customer Services Field (SCG-10) and AMI Policy (SCG-39):
2013 2014 2015 2016 2017 Total
GRC- PMCs 130,000 130,000 130,000 130,000 130,000 650,000
GRC- RMCs 50,000 50,000 50,000 50,000 50,000 250,000
GRC Total 180,000 180,000 180,000 180,000 180,000 900,000
AMI- Accelerated PMCs
(2018-2022) 130,000 130,000 130,000 130,000 130,000 650,000
Authorized or Forecasted Small Meter Replacements
Actual
2013 2014 2015 2016 2017 Total
GRC Funded 91,107 160,000 216,298 216,298 216,298 900,000
AMI Funded 288,232 195,000 166,768 - - 650,000
* GRC meters purchased in 2013 include size 4 meters which are typically purchased in small volumes
Actual or Estimated Small Meter Purchases for Meter Replacements *
Note: Currently, AMI funded meters are used to replace current year PMCs and accelerated PMCs that are
completed by AMI. Once the AMI funding for the total number of accelerated PMC meters that was authorized in
SoCalGas' AMI D.10-04-027 is exhausted, GRC will fund the remaining small meter replacements (current year
PMCs and RMCs and the accelerated PMCs that have not been completed).
Estimated
RFG-A-14
Attachment A4
ORA-SCG-DR-012-DAO, Question 4.a
RFG-A-15
ORA DATA REQUEST
ORA-SCG-DR-012-DAO
SOCALGAS 2016 GRC – A.14-11-004
SOCALGAS RESPONSE
DATE RECEIVED: NOVEMBER 24, 2014
DATE RESPONDED: DECEMBER 15, 2014
4. Please respond to the following:
a. Provide the 2009-2014 YTD labor and non-labor expenses and the number of meters
replaced associated with SoCalGas’ planned small meter replacement program as
referenced on lines 23-24 of page FBA-125.
b. When did SoCalGas first begin to capture field labor expenses for the small meter
replacement program with Customer Services Field Department?
c. Is the small meter replacement program different and separate from the Planned
Meter Change-outs Program (PMC) or the Routine Meter Change-Outs Program
(RMC)? Please identify and explain why there is a separation between this program
and the PMC or RMC in SoCalGas forecasts.
SoCalGas Response:
NOTE: This question raises issues that extend beyond the scope and subject matter expertise of
the Gas Distribution area. As stated on page FBA-125 of Exhibit SCG-04, “Field labor costs
associated with SoCalGas’ planned small meter replacement program are covered in the prepared
direct testimony of Sara Franke, Exhibit SCG-10.” As such, SoCalGas’ response has been
bifurcated as such:
response to 4a was prepared by the Customer Services Field and AMI Policy witnesses
(Sara Franke and Rene Garcia);
response to 4b was prepared by Customer Services Field;
response to 4c was prepared by Gas Distribution.
Any further inquiries should therefore be addressed to the responsible witness areas.
RFG-A-16
ORA DATA REQUEST
ORA-SCG-DR-012-DAO
SOCALGAS 2016 GRC – A.14-11-004
SOCALGAS RESPONSE
DATE RECEIVED: NOVEMBER 24, 2014
DATE RESPONDED: DECEMBER 15, 2014
Response to Question 4.a.:
Prepared by Customer Services Field (SCG-10) and AMI Policy (SCG-39):
Customer Services Field (CSF) can provide the number of meter replacements for 2009-
2013, but does not track expenses at the level of detail requested. Notwithstanding, to
provide some estimate of associated labor expenses for those years, please see below.
Estimates of non-labor expenses are not available. 2014 data is not available.
Small Meter Replacements Completed by CSF
2009 2010 2011 2012 2013
Number of Small Meter Replacements* 160,715 163,639 137,864 116,196 77,899
Estimated CSF Labor Costs**
(Shown in Thousands of 2013 Dollars) $3,461 $3,612 $2,933 $2,475 $2,173
*Small meter replacements include planned meter changes (PMCs) and routine meter changes (RMCs).
** The estimated labor expenses for the small meter replacements completed by CSF are derived by using the
average recorded on premise time per small meter change and the average 2013 labor rate for CSF technicians
who perform small meter replacements. The costs exclude drive time and other ancillary costs not associated
with the time to perform the activity. In 2009-2012 all labor was charged to O&M. Beginning in 2013, for curb
meter replacements only, labor was split 50/50 between O&M and capital. Labor is charged 50/50
capital/O&M for curb meter replacements because the existing curb meters are incompatible with AMI
technology.
Note, in addition to CSF-completed small meter replacements, the Advanced Metering
Infrastructure (AMI) project team has also been performing small meter replacements in
order to fully integrate with the scheduling and routing of AMI deployment. The number of
small meter changes completed by CSF in 2013 excludes a total of 241,041 small meter
changes that were completed as part of SoCalGas’ Advanced Metering Infrastructure (AMI)
implementation.
In order to adhere to the AMI implementation schedule, beginning in 2013, the AMI project
assumed responsibility for above-ground PMCs, including both planned and accelerated
meter changes, and CSF shifted its focus to curb meter changes. This trade-off (i.e., the AMI
project team focusing on above-ground meters and CSF focusing on curb meters) enabled a
better match between the work and employee skill sets. Over the course of the AMI
deployment period (2013-2017), all GRC- and AMI-funded PMCs will be completed.
Please refer to the testimony and workpapers of witness Sara Franke, Ex. SCG-10 and SCG-
10-WP, CSF and Meter Reading, for additional information regarding forecasted CSF meter
changes (testimony pages SAF-9, SAF-11, and workpaper pages 52-54).
RFG-A-17