Thursday, March 27, 2014

Smart - or not: Ontario's Regulator calls for more new meters

I looked into an Ontario Energy Board (OEB) Notice of Proposal after seeing a tweet:
The Board is of the view that, given the current metering infrastructure and pricing environment, it is appropriate to ... require a distributor to install a MIST [Metering Inside the Settlement Timeframe] meter on any installation that is forecast by the distributor to have a monthly average peak demand during a calendar year of over 50 kW.
The comments the OEB has received on the proposal are informative - as is the omission of comments from a couple of well-paid government organizations that should have an opinion.

This is, I assume, a complex subject - particularly for people under the impression all of Ontario's electricity consumers already have "smart" meters.

They don't.
The OEB proposal addresses, for better or worse, a gap in policy.

Essentially all residential consumers should now have "smart" meters reporting through designed protocols and networks.  According to the most recent OEB Annual Yearbook of Electricity Distributors, about 90% of all customers fall into the residential category, but they don't account for even 30% of overall demand.

The next consumption category is for customers with an average annual monthly peak less than 50kw. Adding this class with the residential customers means total consumption of ~40% of all generation, but the class has well over 98% of all customers.

I'll assume this 40% of all generation reports to the Smart Metering Entity which maintains the Meter Data Management and Repository (MDM/R) that is populated from smart meter data communicated through the Advanced Metering Infrastructure (AMI).

At the other end of the spectrum, where the MIST meters exist, are Ontario's largest consumers of electricity with average monthly peak demand exceeding 5000kW (5megawatts).  A MIST meter is apparently smarter than smart - but maybe not as smart as we'd map the requirement if properly planning a grid for the future.  Regardless, between wholesale customers in the IESO market and customers embedded in distribution networks, these few (~0.003% of customers) account for ~16.5% of all consumption. In Global Adjustment mechanism parlance, these qualify as class A customers and their interval meters are required to establish a share of total demand during the 5 highest daily peaks (which in 2012 was, collectively, 10.04%).

It's important to note the hardware, communication standards and data requirements of the measuring device categories (smart/interval/MIST) are different.
Concerns of many of the local distribution companies is that the OEB directive will require spending money on new assets that strand old assets, and require significant technology spending to provide and manage worse data.

The OEB notice of proposal cited above is for customers with average monthly peaks over 50kW and under 5000kW.  This ignored group is a little over 1% of all consumers, but they appear to account for over 40% of demand.

Starting with this absurdity -that the nearly 99% of customers comprising around 40% of consumption were the target of a metering policy allegedly allowing for poorly targeted demand reduction programming - the much larger customers were not necessarily transferred to new metering devices (some have no interval metering and yet they may be charged time-of-use rates based on mocked up demand curves).

The local distribution company objections to the policy proposal stem from the direction in the quote above -"to install a MIST meter" - coupled with:
The Board expects that distributors will install interval metering systems that communicate through the distributor’s Advanced Metering Infrastructure installed as part of Ontario’s smart meter initiative.
It appears the regulator is cherry-picking: big-story meters and little-data smart meters.  From one submission noting that's problematic:
  • There will also be additional costs for the Advanced Metering Interface (“AMI”) or MV90 systems to handle the new data stream. In some cases, the existing MV90 system would not be capable of handling the large increase in interval meters within the LDC. 
  • If the Board were to require these meter reads to go through the Meter Data Management/Repository (“MDM/R”) there would be required changes to processes and file structures. It is not clear if this is the Board’s intent and the Utilities could not support this suggestion.
The big question might be: "if all these problems can be resolved, what should the interval of data collection be, who would it be of value to, and what access is required to add value."

I think the big answer is provided in the submission from Rodan Energy Solutions:
  • Metering installations to have a customer-accessible communication port...
  • Interval resolution of 5 minutes...
The Independent Electricity System Operator has been identified, for reasons I fail to understand, as capable of managing smart meter data, and now (more perplexing again) as capable of entering into procurement of supply including designing market policies for things such as net metering. The IESO's failure to champion the policies co-ordinating data collection with the market's 5-minute interval is an indication of ignorance about where markets must head to "facilitate CDM/DSM participation."

The failure of the Ontario Power Authority to comment is, provided their enormous conservation program budget, insulting to ratepayers.

There's no harm in the Ontario Energy Board distributing a notice of proposal, particularly if they honestly evaluate the comments.
The Board should evaluate proposals conscious that it did not "protect the interests of consumers" in the residential smart meter roll-out, as per its legal mandate.  They should feel a need to do better this time - and they'll need to do much better again if "net metering" plans are not accompanied by revised plans allowing a fairer recovery of the costs of transmission and distribution from all users of the grid.

Hourly billing has been ridiculous - in that the Ontario Power Authority/IESO tandem hasn't been able to identify a single hourly charge for the global adjustment (see the Global Adjustment/Ontario Roulette story)

Stats for this post, including references to base documents, are in this spreadsheet.

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