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April 2012 Comment: Pepco and Delmarva

April 2012 Comment: Pepco and Delmarva

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Published by: msmaorg on Jul 04, 2012
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07/04/2012

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I
Pepco
Holdings.
Inc
Douglas
E.
Micheel
Assistant General Counsel
David
J.
CollinsExecutive SecretaryMaryland Public Service CommissionWilliam Donald Schafer Tower6 St. Paul Street,
16th
FloorBaltimore, Mary land 21202Dear Mr. Collins:April 6, 2012
Re: Case No, 9207
EPII32
701
Ninth Street. NW
Suite
1100,
1oth
Floor
Washington.
DC
20068202 872-2318202 331-6767 Fax
dcmicheel@pepcoholdings.com
Enclosed please find an original and seventeen (17) copies, five three hole punched,
of
the Comments
of
Potomac Electric Power Company and Delmarva Power
&
Light Company'son an "opt-out" option for smart meters.Please contact me
if
you should have any questionsuglas E. MicheelDEM/pmhEnclosurecc: Parties
of
Record
 
IN
THE
MATTER OFBEFORE
THE
PUBLIC SERVICE COMMISSIONOF MARYLANDPotomac Electric Power Companyand Delmarva Power
&
LightCompany Request for the Deployment
of
Advanced Meter Infrastructure
)
)))))
Case No. 9207
COMMENTS
OF POTOMAC ELECTRIC
POWER
COMPANY AND
DELMARVA
POWER
&
LIGHT COMPANY IN RESPONSE
TO
THE
NOTICE OF HEARING ANDOPPORTUNITY TO COMMENT
ON AN
"OPT-OUT" OPTIONFOR SMART METERS
Potomac Electric Power Company ("Pepco" or the "Company") and Delmarva Power
&
Light Company ("Delmarva Power")' hereby files this response to the Commission's February29, 2012 Notice
of
Hearing and Opportunity to Comment on
an
"Opt-Out" Option for SmartMeters
in
Case No. 9207.IntroductionPursuant to Commission Order Nos. 83532 and 83574 Pepco is currently installing
an
Advanced Metering Infrastructure ("AMI") system in its Maryland service territory. Pepco'sAMI system
isan
inter-related system
of
meters, communications devices and IT systems.
As
recognized by the Commission
in
Order
No.
83532, Pepco's full deployment
of
AMI will allowthe Company to provide improved reliability, to improve its ability
to
identity and remediate
1
Delmarva Power,
an
affiliate
of
Pepco,
is
a party to Docket No. 9207 and has pending before the Commission arequest for approval
of
full deployment
of
an Advanced Metering Infrastructure system. Because Delmarva Powerhas not yet received the approvals necessary
to
deploy smart meters, the comments contained herein are focused onthe impact opt out would have on Pepco's deployment. Similar impacts would reasonably be expected for DelmarvaPower. Delmarva Power supports the comments contained herein.
 
problem areas before power is lost, to restore service outages more quickly and efficiently,
and
to
enhance Pepco s ability to serve and communicate with its customers.The Company does not support opt out from smart meter deployment. Smart meters arean essential element
of
Pepco's overall Smart Grid strategy. As will be discussed in more detailbelow, allowing customers to opt out would eliminate many
of
the benefits
of
implementing
an
AMI system for those customers and could adversely affect the way the system performs for thecustomers who have smart meters and erode operating efficiencies for the Company. However,
if
the Commission ultimately decides to allow opt out, customers who make this election shouldpay the full incremental costs associated with requesting this non-standard service option. Pepcoaddresses below each
of
the specific issues identified in the Commission's Notice.
a.
The effect
of
such an option on the overall smart meter project's costs andbenefits, including the effect
on
energy savings, outage detection,
and
management andincremental costs.
Establishing an opt out provision for smart metering will increase the cost
of
theCompany's AMI system and it may reduce the expected benefits in aggregate and for individualcustomers. Smart meters and AMI are the foundational element
of
the Smart Grid, and providethe platform necessary to optimize the grid integration
of
Demand Response, energyconservation, and renewable energy use.
Overall Smart Meter Project Cost
If
a decision
is
made
to
have an opt out program, the Company would incur the followingfixed cost: development
of
a system to track opt outs, IT system modifications, customereducation material development including new customer information package, increasedprogram management expense and increased staffing for customer contact. These costs areincurred regardless
of
the number
of
customers that actually elect
to
opt out. Opt out customers
2

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