With the ruling of the assigned Administrative Law Judge (ALJ) issued on January 6, 2009, So Cal Gas will not receive its requested pre-deployment funding and must show the feasibility of a stand-alone natural gas AMI system. So Cal Gas, throughout the continuing California Public Utilities Commission (CPUC) proceeding scheduled to take place for the better part of 2009, is expected to produce evidence – rather than vendor assertions - showing that an independent AMI system is a viable solution.

The Company’s AMI implementation is currently on hold and those members in classifications that would be affected by this technology can breath a temporary sigh of relief.  The battle is not over yet - it’s just been temporarily delayed. For now, So Cal Gas will have to forego any preliminary implementation until they can show the California Public Utilities Commission (CPUC) how the stand-alone natural gas AMI technology and real-time information on consumption would benefit its residential consumers.

Our concerns for members and residential customers:

       So Cal Gas’ proposed stand-alone natural gas AMI system may not be of any benefit and financially burdensome to low- and fixed-income residential consumers.  Households which may already exercise tight-budgeting controls due to a limited income may be forced to pay additional fees for this technology even if they are living below the poverty level.

       Those individuals who do not have discretionary income may be forced to avoid usage during peak times such as during periods of extreme cold temperatures.  This will undoubtedly lead to public health issues as people may trade-off their own safety because of the inability to afford higher rates.

       The technology that So Cal Gas has proposed is unproven and as such there can be no certainty that the use of such technology will in fact lead to a decrease in energy consumption during peak periods.  As a matter of fact, So Cal Gas, in its own application, has noted that AMI is an emerging technology.

       Reduction of positions which provide face-to-face interaction between the utility and its customers.  Meter Readers and Field Representatives perform an important role in terms of educating residential users and identifying safety problems which otherwise might not be discovered and could either pose a risk to public safety or impact efficiency.  Both, Meter Readers and Field Representatives are qualified to identify abnormal operating conditions and communicate their findings to residential consumers and the appropriate department to remedy the situations. By removing this human interaction, there will be less opportunities to directly educate consumers on issues of safety and immediately remedy potential risks. 

      With the implementation of a stand-alone natural gas AMI system and the elimination of meter readers, as well as field representatives and office positions, residential consumers will interact largely with technology.  The reduction in visits by utility employees will result in the loss of a significant public service to the extent that such employees may address consumer concerns in person and report safety issues which may only be detected through regular field visits.

The Company’s proposed stand-alone natural gas Advanced Metering Infrastructure (AMI) system would be a technology which allows two-way communications. So Cal Gas exerts its AMI system would serve as an informational and operational tool for residential consumers and help it (the Company) meet the state’s environmental goals. The Company also claims AMI can boost demand response programs, and help customers save energy and reduce their bills but So Cal Gas cannot offer any support documentation other than vendor assertions but not that a stand-alone natural gas AMI system is a proven technology in the real world.

The Union is committed to participating in the CPUC proceedings, and once AMI is implemented, to ensure So Cal Gas will retain, retrain and redeploy employees impacted by the transformation of its business caused by the implementation of AMI technology.