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AUG I ARKANSAS PUBUC SERVICE COMMISSION

IN THE MATTER OF THE APPLICATION OF OKLAHOMA GAS AND ELECTRIC COMPANY FOR AN ORDER OF THE COMMISSION GRA11TING PRE-APPROVAL OF DEPLOYMENT OF SMART GRID TECHNOLOGY IN ARKANSAS AND AUTHORIZATION' OF A RECOVERY RIDER AND REGULATORY ASSET
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DOCKET NO. 10-109-U ORDER NO. 8

ORDER In this Order, the Arkansas Public Service Commission ("Commission") approves the Settlement Agreement filed in this docket on June
22, 2011,

by the Oklahoma Gas

and Electric Company ("OG&E" or "Company"), the General Staff of the Arkansas Public Service Commission ("Staff'), the Attorney General of Arkansas ("AG") and Gerdau MacSteel ("Gerdau") (collectively, "the Parties"). Procedural History On December 17,2010, OG&E filed in this Docket its Application for an Order

of

the Commission Granting Pre-approval of the Deployment of Smart Grid Technology

in Arkansas and Authorizaiicm

of

a Recovery Rider and Regulatory Asset

("Application"), requesting that the Commission issue an Order granting pre-approval for the deployment of Smart Grid technology in its service territory in Arkansas; and for the of a Smart Grid Rider to recover the annual revenue requirement with the deployment of the Smart Grid technology. In support of its OG&E filed the initial Direct Testimony of OG&E witnesses Kenneth Grant, Jesse Langston, Scott Milanowski, and Bryan Scott.

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Docket No. 10-109-U Order No.8 Page 2 of 25 By Order No. 1, issued January 11, 2011, the Commission suspended OG&E's

Application pursuant to Ark Code Ann. 23-4-407 pending further investigation by the Commission. By Order No. 4, issued March 14, 2011, the Commission established a procedural schedule for consideration of OG&E's Application including the setting of an evidentiary hearing to begin on June 27, 2011. On May 20, 2011, pursuant to the procedural schedule established by Order No. 4, the Staff ified the Direct Testimony and Exhibits of J. Richard Uornby, Elana Davis, Gayle Freier, and Diana K. l3renske. Also on May 20, 2011, the AG filed the Direct Testimony and Exhibits of Barbara it Alexander. On June 3, 2011, OG&E filed the Rebuttal Testimony of Howard Motley. Additionally, on June 17, 2011, Staff and the AG filed the Surrebuttal Testimony of their respective witnesses, and Gerdan filed the Surrebuttal Testimony of Mark E. Garrett. On June 22, 2011, the Parties filed a Joint Motion to Approve a Settlement
Agre ement supported by the Settlement Agreement Testimony of OG&E witness Donald

R. Rowlett;AG witness M. Shawn McMurray Gerdau witness Mark E. Garrett; and Staff witness Diana Brenske. The Parties also asked that the Commission excuse from the scheduled evidentiary hearing all witnesses with the exception of the Settlement Agreement witnesses. By Order No. 7, issued June 24, 2011, the Commission excused all non-Settlement Agreement witnesses from the scheduled June 27, 2011, hearing, with the exception of any OG&E witnesses who were able to address issues regarding the Company's Customer information Privacy and Security Plan and Customer Education Plan. The Commission conducted a public evidentiary hearing regarding the proposed Settlepient Agreement on June 27, 2011, holding the record open for further

Docket No. 10-109-U Order No. 8 Page 3of25

Commission-directed filings, which were filed in this docket on June

2011, July 5, 2011,

29, 2011, July 1,

and July 15, 2011. OG&E's Application

By its Application, OG&E seeks pre-approval by the Commission of the deployment of Smart Grid technology in its service territory in Arkansas; the authorization of a Smart Grid Rider to recover the annual revenue requirement for Smart Grid deployment until a subsequent OG&E rate case when the revenue requirement would be incorporated into OG&Es base rates; and the creation of two regulitory assets - the first for certain Smart Grid operation and maintenance ("O&M") costs and the second for stranded costs related to the retirement of existing meters. OG&E also requests suspension of various meter test schedules during deployment of the Smart Grid system, pointing out that, since all existing electric meters will be replaced prior to the end of 201, there is no need for such tests under Rule 7.08 of the Commission's Special Rules - Electric. OG&E witness Kenneth Grant explains that Smart Grid is the integration of advanced metering capabilities, communications systems, automation and information technology on the electric distribution system. This includes digital meters on customer's premises with the ability to provide both the company and the customer with usage information regarding energy consumption ("Smart Meters"), monitoring/control equipment in the distribution system, a communications system to allow remote monitoring and control over the electric grid, as well as security protocols to protect both end user information (i.e. privacy concerns) and national security requirements for critical infrastructure. Direct Testimony of Kenneth Grant, Transcript ("Tr.") at 25-31. OG&E's proposed Smart Grid program includes all of these components as well as a

Docket No. io-iog-U Order No. 8 Page 4of25

prop sed plan for customer engagement and education that has been deemed essential to a successful deployment of advanced infrastructure to an industry that has not significantly updated their business model for customer relations in decades. Id. at 34. Mr. Grant describes these specific components of the OG&E Smart Grid Plan: Distribution System Automation - This is the network of feeder meters, capacitor bank controllers and fault indicators that is placed on the distribution network to monitor and control power flows and outages, as well as to provide efficiency improvements within the distribution network. The automated Distribution System communicates with both the Advanced Metering Network and the Data Management network to provide OG&E with near-real-time data regarding faults, outages, and flows on the distribution system. Advanced Metering Network - This element includes the intelligent digital meters and the supporting technology infrastructure that allows for two-way communications, interval billing, remote meter reading, and remote service activation/deactivation. These meters allow for faster outage notification and validation of service restoration. They will also allow customer-enabling technology such as in-home displays, programmable thermostats, and web based data sources to relay electric usage information back to the customer. The Advanced Metering network is further broken down into the following components: o The Advanced Metering Communications Network, which allows near-real-time, two-way communications between the

Docket No. 10-109-U Order No.8 Page 5 of

customer and OG&E. This network includes the digital meter itself and the communications network that allows the meters to communicate back to OG&E. o The Advanced Metering Head End, which is the communications software interface that allows the communications from the Advanced Metering Communications Network to the Meter Data Management System. o The Meter Data Management System, which is the data warehouse that allows for interaction with the customer information system. o The Home Area Network, which consists of the devices, such as communicating thermostats and in-home displays that are used to display price and electricity consumption information to the customer on the customer side of the meter.
Id. at 27-30. OG&E refers to this integration of advanced technologies and customer

programs, specifically including price response programs, as its Positive Energy Smart Grid program. Id. at 25-26. OG&E has approximately 776,.5oo customers of which approximately (8.3%) are located in Arkansas. Application at
1.

64,700

The Company began evaluating

intelligent digital meters ("Smart Meters") and Advanced Metering Infrastructure in

2007 2008.

and conducted a Smart Grid technology pilot in northwestern Oklahoma City in

Id. at 3-4. In July 2009 OG&E received approval from the Oklahoma
1

Corporation Commission ("0CC") to proceed with a Phase

deployment of Smart Grid

Docket No. 10-109--U Order No.8 Page 6 of 25

in Norman, Oklahoma, and deployed approximately residential and small commercial customers by May In August of
2009

42,000

Smart Meters for

15, 2010.

Id. at 4.

OG&E filed an application seeking federal stimulus grant

funding with the United States Department of Energy ('DOE") which resulted in an award to OG&E of $13o million to deploy Smart Grid Technology in OG&E's entire two-state footprint. Id. To receive the full amount of funding, OG&E committed to expend $3574 million over a three-year period starting in
2010
-

and ending in
10.

2012

for system-

wide deployment of Smart Grid technology. Grant Direct at

In July 2010, the 0CC

approved full deployment and cost recovery for Smart Grid technology throughout OG&'s Oklahoma service territory. AL at
2.

According to OG&E, the federal funds maybe used to match certain expenditures by OG&E, and restrictions contained in the grant include a window in which OG&E can receive reimbursement of approved levels of Smart Grid costs. This window extends to the end of 2012 and includes a portion of the costs for the Norman deployment, the installation of smart meters across the entire OG&E system, the communications network, the distribution management system, circuit upgrades on a portion of the Company's distribution systems, as well as testing for verification of expected Smart Meter-enabled Demand Response. Application at 4. OG&E states that grant funds allocated for use in Arkansas for deployment of Smart Grid technology, should its
Arkansas Application not be approved, will be reallocated to the Company's Oklahoma

jurisdiction. Id. According to Mr. Grant, if its Application is approved, deployment in Arkansas will begin toward the end of
2011 with the installation of a Wide-Area Network, a part of

the multi-tiered communications network that will support the operational

Docket No. 10-109-U Order No.8 Page 7 of 25

requirements of the Distribution System Automation devices and metering access points distributed throughout OG&E's system. Grant Direct, Tr. at. 35. Deployment of Smart Metes and Local-Area Network devices in Arkansas is scheduled to begin by March
2012 and be completed by May 2012.

Id. The Local-Area Network is a wireless network

linking the metering access points to the individual Smart Meters installed on buildings and homes, through which data may flow from meter to meter and from meter to the access points. Likewise, Mr. Grant states that deployment of Distribution System Automation equipment in Arkansas is scheduled to begin in 2011 and to be completed in
2012.,

Id.
Once the Advanced Metering Infrastructure deployment is completed, around

May 2012, Mr. Grant states that OG&E will be able to offer an Energy Information Website to all customers with a Smart Meter. This website will allow customers to monitor their usage data, pricing information, and overall energy cost. Id. at 36. OG&E will offer this tool, along with Variable-Peak or Time-of-Use pricing tariffs to help customers achieve savings by shifting peak energy usage to off-peak. AL According to Mr. Grant, OG&E plans to provide a significant amount of education to help customers use the website and pricing programs effectively. Id. OG&E estimates that, of the $357.4 million total cost for the program in both jurisdictions, the DOE grant will cover $126.9 million, or approximately 36% of total costs of deployment, for a net ratepayer cost of $230.5 million. Id. at 13; Rebuttal Testimony of Howard W. Motley, Tr. at tot Staff testifies that approximately 8.32% of the net project cost, amounting to about $19 million, would be allocated to Arkansas using the system allocation methodology adopted in OG&E's last rate case (Docket No. 10-067-U). Breuske Direct, Tr. at 307.

Docket No. 10-109-U Order No.8 Page 8 of

OG&E asserts that the annual revenue requirement for Arkansas, based upon OG&l's current authorized rate of return and estimated Smart Grid expenditures offset by DOE funding and after credit for direct savings from the Smart Grid Program, would be $4374,5oo for
2oll

(Jul.-Dec.), $3,254,889 for

2012,

$3,062,248 for

2013,

and

$1,38,362 for 2014 (Jan.-Jun.). Scott Direct, Exhibit BJS-i, Tr. Ex. at 14. Based upon monthly residential consumption of
i,ioo kilowatt-hours ("kWh"), the average customer
2011, $1.62 in 2012,

monthly bill impact (net of fuel and benefits) would be $1.41 in

$L37in 2013, and $1.25 in 2014. Scott Direct, Tr at 68 and Tr. Ex at 18-21.

Staff initially recommended approval of OG&E's Application subject to certain specific conditions summarized in the Direct Testimony of Staff witness Brenske. Brenske Direct, Tr. at 313-321. AG witness Alexander recommended rejection of OG&E's Advanced Metering Infrastructure proposal; however, she recommended several conditions that the Commission should impose if it approves OG&E's Application. Alexander Direct, Tr. at 236-238. Staff responded to OG&E witness Howard Motley's Rebuttal Testimony, again recommending that the Commission impose upon OG&E the conditions outlined in Staffs Direct, as well as additional conditions recommended in its Surrebuttal Testimony. Brenske Surrebuttal, Tr. at 326-330, Hornby Surrebuttal, Tr. at 296-299; Davisl Surrebuttal, Tr. at 356-360, and Freier Surrebuttal, Tr. at 374-377. Ms. Alexander, for the AG, acknowledged that Staffs recommended conditions "are headed in the correct direction," although she did not change her overall conclusions and recommendations. Alexander Surrebuttal, Tr. at 244-245. Gerdau witness Garrett objected to Staffs proposal to allocate the Smart Grid Program costs to pU customer classes, supporting instead OG&E's proposal to allocate

Docket No. 10-109-U Order No.8 Page 9 of 25

such costs only among retail customers in Service Classes 3, 4 and 5 "because customers in these service ... [classes] are distribution-level customers and costs for [the] Smart Grid Program are primarily distribution-related costs." Garrett Surrebuttal, Tr. at Mr. Garrett further notes that Service Class
1 161.

and

customers were not included in

OO&E's original proposed allocation because these customers are transmission-level customers and are thus not cost-causers for Smart Grid implementation. Id. at 161-162. Mr. Garrett proposes an alternative cost allocation that would "fairly assign" the Smart Grid costs to all rate classes. Id The Settlement Agreement Under the Settlement Agreement (appended to this Order) all Parties agree to adopt Staffs Direct and Surrebuttal case with regard to modifications to the OG&E proposed SGR Rider, with two further modifications to Staffs recommendations. The two further modifications would reduce SGR Rider revenue by the level of guaranteed O&M reductions, and would exclude the O&M expenses incurred for the Norman, Oklahoma deployment in
2010.

The SGR Rider changes recommended by Staff in its

1

Direct and Surrebuttal case, as outlined in Attachment are as follows:

to the Settlement Agreement,

i. The Rider shall only include historical, prudently incurred incremental costs associated with the deployment of Smart Grid; Staff witness Fiana Davis Direct Testimony at 3.
2.

The Rider shall be based on the used-and-useful principle, with no costs included in the revenue requirement and recovered before the cost is incurred and Smart Grid meters are in service; Id.

Docket No. 10-109-U Order No. 8 Page ia of 25

3. The Rider shall include the formula for calculating the annual revenue requirement; Id. at 3-4. 4. The Rider shall remain in effect until new rates are implemented as the result of the planned 2013 rate case; Id. at 4.

5. The regulatory asset for O&M

expenses incurred prior to the carrying charges, shall be

implementation of the SGR Rider, without

approved; no O&M expense related to the Norman project which was incurred in
2010

shall be included; any non-incremental costs shall be

excluded; and the Rider shall include amortization of this regulatory asset over five years, provided the expenditures are properly documented, and subject to audit in the Company's next general rate case; Id. at 5. 6. The Rider shall reflect the rate of return approved in Docket No. U; Id. at 6.
10-067-

7. The Rider shall reflect the depreciation rates recommended on page

Table 3 of the Direct Testimony of Staff witness Gayle Freier; AL

8. A regulatory asset for the early retirement of

standard meters shall be

allowed, without accrual of carrying charges, for the balance in the standard meter account at early retirement. However, the Rider shall not include any amortization or return amounts for standard meters. The Commission reserves until OG&E's next rate ease a final determination of: i) the appropriate amount of the balance in the standard meter account at early retirement and
2)

the period for rate recovery, and no amortization

or return amounts shall be included in the Rider calculations; Id., Freier Direct at 8-9.

Docket No. 10-109-U Order No.8 Page ii of 25

9. The Rider shall reflect that to the extent OG&E seeks to use different depreciation rates than those approved in Docket No. 10-067-U' or in this Docket, OG&E is required to file an application for such changes with supporting documentation for Commission review and approval; Jreier Surrebuttal at 2. 10.The Rider shall be reduced annually by the revenue requirement associated with standard meters as included in the rates in Docket No.
10-

067-U upon retirement of the standard meters and deployment of Smart Grid; Davis Direct at 7. ii. The Rider shall be fully credited for any Smart Grid amounts - expenses, investment, return, etc. - inadvertently included in rates in Docket No. 067-U for the full period of their inclusion; Id.
iz. The Rider shall include the level of Guaranteed O&M Reductions offered
10-

by the Company to reduce the SGR Rider revenue requirement; Id at 8-9. i. The Rider shall provide that the billing determinants will be the same methodology as used in the determination of the billing determinants for the Company's Rider ECR; Id. at 9. 14 The Rider shall allocate Smart Grid costs to all of the service levels within the classes such that there will be a separate rate calculated for each service level within each class using an allocator based on Total Distribution Plant less Acct. 360 land and land rights, consistent with the Docket No. 10-067-U compliance cost of service study 0-4; Id. at io.
OG&Es most recent rate case proceeding which was resolved by final Order No. 6, issued by the Commission on June 17, 2011.

Docket No. 10-109-U Order No.8 Page 12 of 25

15. The Rider shall provide for the annual true-up to be accompanied by testimony and workpapers sufficient to fully replicate the calculations of the revised SGR factors; H. at ii. 16. The Rider shall provide that the Commission explicitly reserves a finding of value for Smart Grid for ratemaking purposes until a future rate case when base rate recovery is sought. Id. at 11; and 17. The Rider shall provide that all collections under the SGR Rider be subject to refund, with interest, after notice and hearing to determine prudence.

Id.
In addition to the changes to the Rider agreed to by the Parties, the Agreement provides as follows: Reporting Requirements. OG&E will report the cost and benefits associated with the Smart Grid project using the metrics filed in the Agreement (Settlement Attachment 2). OG&E will establish a baseline
2010 System Average Interruption Duration Index ("SAIDI") and will

report the results to the Conlmission. 2 Meter Testing. Special Rules Electric Rule 7.08.13 (Meter Testing Programs and Filing Requirements) should be temporarily waived and OG&E will file an appropriate revision to its tariff to reflect such waiver.

SATIM is a commonly used reliability indicator in the electric utility industry. SAIDI is usually defined as the average outage duration that each customer will experience over the course of a year.
2

Docket No. 10-109-U Order No.8 Page 13 of Remote Disconnect.

a OG&Es involuntary disconnect process shall not be substantially changed during this deployment phase in Arkansas. OG&E will continue to make two phone calls - the first automated and the second a person-to-person contact - informing residential customers of an impending involuntary disconnection of service. If OG&E is unable to contact the customer by phone, an OG&E representative will visit the customer premises in an attempt to notify the customer of disconnection and offer a last opportunity to avoid disconnection. A door hanger informing the customer of the disconnection of service and how to be reconnected will be left on the premises if the customer is not home during the attempted visit. Customers subject to an involuntary disconnection of service will be assessed the Reconnection Fee and the Collection Fee pursuant to OG&E's current tariff. o OG&E will follow the established customer premises visit process for customers who have not been contacted by telephone prior to an involuntary disconnect until its next rate case where this process will be further evaluated. To enable effective evaluation of that process, OG&E will provide Staff with an annual report detailing the number of premises visits made pursuant to this Agreement, the amounts collected via the Reconnection Fee and the Collection Fee, the costs associated with the premises visits and any applicable ratepayer benefits pursuant to the Agreement.

Docket No. 10-109-U Order No. B Page 14 of 25

o OG&E's Reconnection Fee and Collection Fee will be discontinued on the date the SGR Rider goes into effect, except as associated with the involuntary disconnection process. However, OG&E is not precluded from proposing new or revised Reconnection Fee or collection Fee in any future rate case. . Customer Eduation Plan. OG&E, with input from all Parties, will develop a comprehensive Customer Education Plan consistent with the budget agreed upon by the Parties and presented to the Commission and will file this comprehensive Customer Education Plan in this Docket within 90 days of an Order approving this Settlement agreement. The Customer Education Plan will include a provision that OG&E will mail a free Home Energy Report to customers who participate in the Smart Grid Usage programs but who do not have internet access. . Customer Information Privacy and Cyber-Security Plan. OG&E will file in this Docket within go days of an Order approving this Settlement agreement a comprehensive Customer Information Privacy and CyberSecurity Plan for the Commission to review and approve. The Settlement Agreement summarizes OG&E's compliance filing obligations, providing that, with input from Staff, the AG, and Gerdau, OG&E will within 90 days of the issuance of the order in this case file the following documents in this docket for Commission review and approval: . An SGR Rider reflecting each of the provisions of Staffs testimonies, modified to reflect the Agreement regarding Guaranteed O&M

Docket No. 10-log-U Order No. 8 Page 15 of 25

reductions and the exclusion of Norman O&M expenses incurred in

2010, as summarized in Attachment 1;

. A detailed reconciliation of all of the Smart Grid costs included in Docket No. 10-067-U;

,. A detailed reconciliation of the standard meter revenue requirement

included in Docket No. 10-067-U; A Customer Education Plan; A Customer Information Privacy and Security Plan; Tariff revisions to reflect the waiver of Special Rules - Electric Rule 7.08 B and the application of the Reconnection Fee and Collection Fee; and ,. The method for calculating System Average Interruption Duration

Index ("SAID!") and the 2010 benchmark.

The Settlement Agreement further provides that the Reporting Requirements

identified in Attachment

2, the SAID! calculation, and the report detailing premises

visits made pursuant to provisions of the Agreement, the amounts collected pursuant to

the Reconnection Fee and Collection Fee, the cost of conducting the premises visits, and
applicable benefits pursuant to the Agreement will be filed annually in this Docket at the same time as the SGR Rider, along with supporting workpapers, and will be based upon the previous calendar year's actual data. The Settlement Agreement Hearing During the Settlement Agreement hearing conducted on June 27, 2011, the Commission heard testimony from OG&E settlement witnesses Rowlett, Grant, and

Docket No. 10-109-U Order No. 8 Page i6 of 25

thncrier. Company witnesses provided the following information in response to Commission questions: The Smart Grid application was not a part of the just-concluded OG&E rate case (Docket No. 10-067-U) because installation of the Smart Grid equipment is expected to occur well after the end of the test year for that case. According to Mr. Rowlett, a general rate case looks back at what has already happened and factors in some future events, but this project was new and unique and thus fit better in a separate application. Tr. at 121. OG&E agrees with Staff's Direct and Rebuttal case that provides that a prudence determination will be delayed until the next rate case. Mr. Rowlett stated that "it was always [OG&E's] intent and be1ief that there would be a review of what money was spent and cost incurred to make sure that those were prudent expenditures and it met ... the general criteria applied at the Arkansas Commission for a prudent expenditure. Id. at 122. OG&R agrees that the Settlement Agreement and preapproval of the Smart Grid technology and SGR Rider apply only to Phase II of the project and that no cost recovery of anything in Phase Ill to be included in rates. Mr. Rowlett testified that Phase II will be beneficial to ratepayers and to OG&E irrespective of whether Phase lii is ever approved. Id. at 124. Mr. Rowlett testified that one of the revisions to OG&E's initial request as a result of Staffs ease is that OG&E "won't begin collecting money

Docket No. 10-109 -U Order No.8 Page 17 of through the rider until all of the meters are installed" and that, although a regulatory asset will be recognized for retired meters, as requested in the Company's initial case, this asset "will not carry a carrying charge, and the amortization period and the recovery mechanism will be determined in the next OG&E rate case, so they will not be part of the rider." Id. at 131. . The regulatory asset to capture the development cost for Smart Grid will not include the
2010

costs incurred for the Smart Grid project or

the pilot project in Norman, but Arkansas customers would pay their jurisdictional share of the
2009

costs of the Norman project related to

acquiring the DOE grant, and those costs would be included in the regulatory asset. Id. at 132 and 135-136. Arkansas rates will not include of any of the costs of the northwest Oklahoma City technology demonstration. Id. at 138, OG&E has a Customer Education Plan for Oklahoma that would be the same plan the Company will propose for Arkansas. Id. at 147. . OG&E has a cyber-security plan that had to be filed with DOE as a part of OG&E's grant agreement, and it will apply for the Arkansas case. Id. at 149. OG&E will not charge customers for an involuntary disconnection accomplished remotely, without a premises visit. Id. at 151. . One of the advantages of OG&E's remote connect is that when customers go to a payment agent, they usually get reconnected within

Docket No. 10-109-U Order No.8 Page iS of 25 20

to 30 minutes on average and in the evening and over the weekend.

Id. at 152.

To date, because of its workforce retraining and severance programs, OG&E has not had to lay off any of its employees as the result of implementing Smart Grid in Oklahoma and has been able to place over 6o of its former meter readers and field personnel in other entry level positions. Id. at 153. Staff witness Diana Brenske supported the Settlement Agreement noting that the Company's modified proposed SGR Rider with regard to the Guaranteed O&M savings is reasonable "because it will provide a guaranteed reduction in costs to ratepayers over the rider period" and "[amy savings in excess of the Guaranteed O&M Savings will be captured in the next general rate case." Tr. at 336. During the hearing, Ms. Brenske noted that OG&Es customer education plan needed more specificity regarding the deployment of customer education in Arkansas, but that there is time to resolve that issue for the March-May
2012

meter deployment.

Id. at 381. OG&E and the Parties therefore agreed that the Company would provide

both customer information and privacy and cyber-security information within ninety
(90)

days so that Staff can review it and get Commission approval prior to the meters

being deployed in Arkansas. Id. In response to questioning by the Commission, Ms. Brenske testified that, based upon the evaluation performed by Staffs consultant Richard Hornby, the deployment and costs of Phase II of Smart Grid are beneficial to Arkansas ratepayers over the long run (a 15-year period). Id. at 385. However, she added, that she does not believe that short-term benefits will exceed costs, since program implementation and customer

Docket No. 10-log-U Order No. 8 Page 19 of 25

response will take time. Id. at 386. In short, she agreed that the benefits associated with distribution automation and demand response are going to contribute to the overall benefits of the program and thus Phase II lays the ground work for those larger benefits. Ms. Breuske summed up Staffs position on this point: "We think over the long run customers will be able to be served at lower costs than they would be otherwise without smart meters, and so that's why we supported the settlement." Id. Finally, Ms. Brenske responded to Commission questioning about delaying a prudence finding, but authorizing expenditures of money on Smart Grid. She noted that the two-step process contained in the settlement is similar to that used in other dockets involving power plants and transmission lines, where the company seeks preapproval, in
the first step, to initiate an action based on a budget and a business plan. Id. at 388. In

the second step, once the project is completed, Staff reviews the prudence of the execution of the project. In the instant case, Staff reserves that finding for the next rate case, when any imprudent expenditures may be refunded to ratepayers with interest.
Id. She concludes that, based on the current business plan, "we believe that this is going

to be in the public interest." Id. At the conclusion of the hearing the Commission announced that it would hold the record open until July
20, 2011,

for the Parties to provide a detailed framework of

the Customer Education Plan and budget for Commission approval, noting that this action would not disturb the 90-day proviso on these matters in the Agreement itself. Likewise, the Commission directed that OG&E provide under seal the privacy and cybersecurity plan that was provided to DOE, along with the talking points described by Mr. Rowlett. Tr. at 391.

Docket No. 10-io9-U Order No.8 Page 20 of 25

In accordance with these directives, OG&E submitted the following information on the following dates:
a

June 29,

2011

- A copy of its DOE-approved Cyber-Security Plan for

the Smart Grid System and talking points (filed under protective seal); July 1, 2011 - A copy of its Data Privacy Plan and "concepts" document
describing the Cyber Security Plan and Data Privacy Plan expected to

be submitted pursuant to the Settlement Agreement; . July

1, 2011

- A copy of its NERC Critical Infrastructure Protection

('CIP") Information Plan (filed under protective seal). July 5,

2011

- A copy of its initial Education Program talking points

and proposed budget for Smart Grid in Arkansas, to be used by the parties in developing a formal plan pursuant to the proposed Settlement Agreement; sample education materials and presentations that have been used in Oklahoma and are proposed to be used in education efforts in Arkansas; and OG&E's "Red Flag"/ Identity Theft Program materials. On July i, 2011, OG&E, the AG, and Staff filed their Joint Response to
Commission Directive to Submit OG&E Arkansas Smart Grid Outline Detailing Customer Education Plan and Budget and Cyber Security Plan and
Motion for

Approval of the Settlement Agreement ("Joint Response"). The Joint Response notes

that the Joint Parties have conferred and developed a detailed Customer Education Plan Outline (Attachment 1 to the Joint Response). The Joint Parties further state that while they have reviewed OG&E's proposed
customer education budget for Phase 11 of Smart Grid deployment filed on July
& 2011,

Docket No. 10-109- U Order No.8 Page 21 of 25

"there has been insufficient time to determine if the breakdown of costs within the total education budget amount is reasonable, since the contents of the consumer education plan have not yet been developed." Joint Response at 16. Furthermore, the Joint Parties state their understanding "that cost recovery for consumer education expenses, as for all costs included in the SGR Rider, shall be subject to refund, under the terms and conditions spelled out in the Settlement Agreement..." Id. Thus, subject to these

caveats, the Joint Parties agree that OG&E's total customer education budget shall not
exceed the total amount indicated in OG&E's July 5,
2011

filing. However, the Joint

Parties further agree that the breakdown of costs should be subject to further review as the parties develop the detailed Customer Education Plan that will be filed with the Commission for approval. As provided in the Agreement, the parties will file a detailed Customer Education Plan and Customer Information Privacy and Security Plan with the Commission for its review and approval within 90 days of the Order issued in this case, and will provided a detailed customer education budget at that time. Id. Decision The Commission accepts and receives into the record in this docket OG&E's filings of June 29, July 1, and July 5, 2011, and the Joint Response of the Joint Parties filed on July
15, 2011,

including Attachment 1 to the Joint Response. Having reviewed

the entire record and having considered the totality of the evidence presented in this case, including the Application, the pre-settlement testimony and exhibits, the Settlement Agreement, the post-Agreement filings by OG&E and the Joint Parties, and the testimony of the witnesses who appeared at the public hearing conducted by before the Commission on June Agreement, as filed on June
27, 2011, 22, 2011,

the Commission finds that the Settlement is supported by substantial evidence of record

Docket No. 10-109-U Order No. 8 Page 22 0125

(whib contains adequate clarification and reassurance by the Joint Parties of its terms and the meaning thereof), is just and reasonable and in the public interest,, and is approved. The Commission finds that the filings of the Customer Education Plan outline and budget constitute an adequate framework for consideration of OG&E's commitment to develop a consumer education plan tailored to the needs of its Arkansas customers. Likewise, OG&E's filing of its DOE-approved Cyber-Security Plan for the Smart Grid System, Data Privacy Plan, NERC CIP Information Plan, and initial Education Program talking points and proposed budget for Smart Grid in Arkansas satisfy the Commission's directive to provide additional information in support of the Settlement Agreement. Accordingly, the Commission directs and orders as follows: 1. The Settlement Agreement, as filed on June
22,2010,

is hereby approved;

2. The Compliance filings required by this Settlement Agreement shall be filed in this Docket within ninety (90) days of the date of this Order. These filings shall include: an SGR Rider reflecting all of the provisions in Staff's testimonies as modified in the Settlement Agreement to reflect the guaranteed O&M reductions and the exclusion of the Norman, Oklahoma O&M expenses incurred in 2010; . a detailed reconciliation of all Smart Grid costs included in Docket No 10-067-U; . a detailed reconciliation of the standard meter revenue requirement included in Docket No. 1 0-067-U; . a comprehensive Customer Education Plan developed with the input of all Parties to this Settlement;

Docket No. 10-109-U

Order No.8

Page 23of

. a detailed Customer Information Privacy and Security Plan; : tariff revisions that reflects the waiver of Special Rules - Electric Rule 7.08.B (Meter Test Programs for In-Service Meters) and the changes in the application of the Reconnection and Collection Fee provisions of OG&E's tariff; and the method for calculating the System Average Interruption Duration Index and the wio benchmark. 3. The Reporting requirements in the Settlement Agreement, the System Average Interruption Duration Index calculation, and the reports on the involuntary disconnection process shall be filed annually in this Docket along with the supporting workpapers and will be based on the previous year's actual data. These reports will be flied annually at the same time as true up of the SGR Rider. 4. Finally, given that OG&E's deployment of Smart Grid technology is the first of its kind in Arkansas and that its implementation has implications for all of the state's investor-owned utilities and their customers, the Commission directs the Company to make the following compliance filings regarding the project in accordance with the following schedule: April 1, 2012 - A report describing: a how the Smart Grid technology and its energy and demand savings capabilities relate to or may be integrated into OG&E's comprehensive Arkansas Energy Efficiency Plans for Program Years 2011-2013;
3

See Docket No. 07-075-17.

Docket No. 10-109-U Order No.8 Page 24 of 25

o how the Smart Grid technology affects OG&E's achievement of the incremental, annual energy-savings targets established by the Commission4 for Program Years 2011-2013; and
o

how Smart Grid-related energy and demand savings will be evaluated, measured, and verified in accordance with Evaluation, Measurement, and Verification Protocols expected to be adopted in Docket No. io-on-R.

October 31,2012 A status report detailing OG&E's progress in the following areas: installation of the Smart Grid "Distribution System Automation" and "Advanced Metering Network" elements as described by OG&E witness Kenneth Grant M. 27-30); implementation of its comprehensive Customer Education Plan to be submitted pursuant to this Order; and implementation of its Customer Information Privacy and Security Plan to be submitted pursuant to this Order; and April 1, 2013, and April 1, 2014 - A status report on the impact of Smart Grid technology on OG&E customers' rates, bills, and energy consumption levels, and the costs and benefits of the energy and demand savings being achieved with the technology.

1d.

Docket No. 10-109-U

Order No. 8 Page 25 of 25

BY ORDER OF THE COMMISSION, This

day of August, 2011.

Colette 1). Honorable, Chairman

Nfc4. f2ei
Olan W Reeves, Commissioner Elana C. Wills, Commissioner

a-~- 64'w ~

of the Commission
fhemb
-

MA Uft"Wea @ doom of

oHscSid VIsby dIfl gem

Secretaf the Commis&Ofl

Date.

"3..-t.L

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60

BEFORE THE ARKANSAS PUBLIC SERVICE COMMISSION IN THE MATTER OF THE APPLICATION OF OKLAHOMA GAS AND ELECTRIC COMPANY FOR AN ORDER OF THE COMMISSION GRANTING PRE-APPROVAL OF DEPLOYMENT OF SMART GRID TECHNOLOGY IN ARKANSAS AND AUTHORIZATION OF A RECOVERY RIDER AND REGULATORY ASSET

DOCKET NO. 10-109-U

SETTLEMENT AGREEMENT Come now the General Staff of the Arkansas Public Service Commission (Staff), Oklahoma Gas and Electric Company (OG&E), the Consumer Utilities Rate Advocacy Division of the Arkansas Attorney General's Office (AG). and Gerdau MacSteel, hereinafter collectively referred to as "the Settling Parties" and being all the parties to the above-referenced Docket, agree to the following terms in settlement of all outstanding issues in the above-referenced Docket.

1. PROCEDURAL SCHEDULE AND RECORD DEVELOPMENT On December 17, 2010, OG&E filed an Application, Direct Testimonies and Exhibits requesting that the Commission issue an Order granting pre-approval of the deployment of Smart Grid technology in its service territory in Arkansas; the authorization of a Smart Grid Rider to recover annual revenue requirement for Smart Grid until a subsequent OG&E rate case when the revenue requirement would be incorporated into base rates; and the creation of two regulatory assets, the first for certain initial Smart Grid operation and maintenance costs and the second for stranded

APSC FLED Tme: 6(2212011 1IAZ5T AM: Reod 6/22(2011 11:37*64j"RTkofflbroc.

so

costs related to the retirement of meters. OG&E also requested suspension of various periodic and selective meter test schedules during the deployment of Smart Grid. On March 17, 2011 Gerdau Mac Steel filed its Petition to Intervene which was granted on April 8, 2011. After conducting extensive discovery, Staff, and the AG, filed Direct Testimony on May 20, 2011. OG&E filed Rebuttal Testimony on June 3, 2011. Staff, the AG and Gerdau MacSteel filed Surrebuttal Testimony on June 17, 2011. The Record has been developed fully as reflected in the filed testimonies and exhibits. In pursuit of settlement, a complete discussion of the issues outstanding was undertaken among the Settling Parties, each being a strong advocate for its respective position. The result is that the Settling Parties to this Agreement have agreed to settle this case based on Staffs recommendations advanced in its Direct and Surrebuttal Testimonies and Exhibits, as modified and detailed below. 2. SMART GRID RECOVERY RIDER (SGR Rider) The Settling Parties have agreed to adopt Staffs Direct and Surrebuttal Case with regard to the SGR Rider with two modifications. The level of Guaranteed Operation & Maintenance (O&M) Reduction offered by the Company will be used to reduce the SGR Rider revenue requirement and the Norman O&M expenses incurred in 2010 will be excluded. The SGR Rider shall therefore reflect each of the provisions of Staffs testimonies, modified to reflect the Agreement regarding Guaranteed O&M Reductions and the exclusion of Norman O&M expenses incurred In 2010- A summary of the provisions of the SGR Rider as set forth in Staffs Direct and Surrebuttal testimonies, modified to reflect the modifications noted above, is included as Attachment 1.

APSC FILED line: 6/2212011 11A257 AM: Recd 812212011 11 :37:64

60

3.

REPORTING REQUIREMENTS The Settling Parties agree that the Company will report costs and benefits

associated with Smart Grid using the metrics included in Attachment 2 to the Settlement Agreement The Company will establish a baseline 2010 System Average Interruption Duration Index (SAIDI) and report that index to the Commission.
4. REMOTE DISCONNECT

A.

The Company will continue to make two (2) phone calls; the first

automated and the second a person to person contact informing the residential customer of an impending involuntary disconnection of service. If the Company is not able to contact the residential customer by phone, the Company will visit the customer's premise to notify the customer of the disconnection of service and offer a last opportunity to avoid disconnection. If no one is at home, the Company will leave a door hanger informing the residential customer of the disconnection of service and how to be reconnected. B. The settling parties agree that customers who are subject to involuntary

disconnection and receive a premise visit pursuant to paragraph A. above, will be assessed the Reconnection Fee and the Collection Fee pursuant to the Company's approved tariffs. C. The Company will also provide a door hanger to include the Annual

Customer guide and an explanation of the Company's disconnection policy, at the customers premise when Smart Meters are deployed. D. The Settling Parties agree that the Company will continue the premise visit

APSC FLED Time: 6122120111 1*4Z57 AM: Rem! 612212011 11:37:54j

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to residential customers who are subject to Involuntary disconnection and have not been contacted by telephone prior to disconnection for a temporary transition period at least until the conclusion of OG&E's next general rate case. The Settling Parties agree that the elimination of the required premise visits to customers who are subject to involuntary disconnection and cannot be reached by telephone prior to disconnection shall be evaluated and addressed in OG&E's next general rate case. To enable that evaluation, OWE shall provide an annual report detailing the number of premise visits made pursuant to the provisions of the Agreement, the amounts collected pursuant to the Reconnection Fee and Collection Fee, the cost of conducting the premise visits, and applicable benefits pursuant to the Agreement. 5. CUSTOMER EDUCATION A. The Settling Parties agree that the Company, with input from the Staff, the

AG, and the intervenor will develop a Customer Education Plan consistent with the budget included in this case. 6. CUSTOMER INFORMATION PRIVACY AND SECURITY A. The Settling Parties agree that the Company shall file a Customer Privacy

and Security Plan in this Docket for review and approval by the Commission. 7. OTHER ISSUES A. The Settling Parties agree that a temporary waiver of Special Rules

Electric, Rule 7.08 B should be granted and the Company shall file a revision to its tariff. B. Except as provided in paragraph 4.8. above, the Settling Parties agree

that the Reconnection Fee and Collection Fee shalt be discontinued on the date the SGR Rider goes into effect. However, nothing herein precludes the Company from

APSC FILED Time: 612212011 1t42:57

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proposing a new or revised Reconnection Fee or Collection Fee in its next general rate case. C. The Settling Parties agree that the Company shall provide a Home Energy

Report, free of charge, to customers who participate in demand response programs, but do not have Internet access to the Company's web portal.. 8. COMPUANCE FILINGS The Agreement provides that, with input from the Staff, the AG, and the intervenor the Company will file in this docket for Commission review and approval of the following within 90 days of the order issued in this case: . SGR Rider reflecting each of the provisions of Staffs testimonies, modified to reflect the Agreement regarding Guaranteed O&M reductions and the exclusion of Norman O&M expenses incurred in 2010, as summarized in Attachment 1; . a detailed reconciliation of all of the smart grid costs included in Docket No. 10-067-U; a detailed reconciliation of the standard meter revenue requirement included in Docket No. 10-067-U; . customer education plan; . customer information privacy and security plan; stariff revisions to reflect the waiver of Special Rules Electric Rule 7.08 B and the application of the Reconnection Fee and Collection Fee; and the method for calculating SAIDI and the 2010 benchmark. The Reporting Requirements identified in Attachment 2 to the Agreement, the

APSC FILED Tim: 612212011 11,42:57 AM: Read 612212011 11:37:5jf

50

SAIDI calculation, and the report identified in Section 4.D. Will be filed annually in this Docket, along with supporting work papers, and Will be based on the previous calendar year's actual data. The reports will be filed annually at the same time as the SOR Rider.

9. RIGHTS OF THE SETTLING PARTIES A. This Agreement is made upon the explicit understanding that it constitutes

negotiated settlement which is in the public interest Nothing herein shall constitute

an admission of any claim, defense, rule or interpretation of law, allegation of fact, principle, or method of ratemaking or cost-of-service determination or rate design, or terms or conditions of service, or the application of any rule or interpretation of law, that may underlie, or be perceived to underlie, this Agreement. B. This Agreement is expressly contingent upon its approval by the

Commission without any modification. The various provisions of the Agreement are interdependent and unseverable. All parties shall cooperate fully in seeking the Commission's approval of the Agreement. The parties shall not support any alternative proposal or settlement agreement while this Agreement is pending before the Commission. C. Except as to matters specifically agreed to be done or occur in the

future, no party shall be precluded from taking any position on the merits of any issue in any subsequent proceeding in any Forum. This Agreement shall not be used or argued as establishing precedent for any methodology or rate treatment in any future proceeding.

APSC FILED Tkne: 12212011 114257 AM: Recvd 6/22120111 l:3ls4fJIfI4ffl.00c.eO

D.

In the event the Commission does not accept, adopt and approve

this Agreement in its entirety and without modification, the Settling Parties agree that this Agreement may be declared void and of no effect by any

party.

In that event, however, the Settling Parties agree that: (a) no party shall be bound by any of the provisions or agreements hereby contained; (b) all parties shall be deemed to have reserved all their respective rights and remedies in this proceeding; and
(C)

no party shall introduce this Agreement or any related writings, discussions,

negotiations, or other communications of any type in any proceeding. Respectfully submitted, GENERAL STAFF OF THE ARKANSAS PUBLIC SERVICE COMMISSION By: Is/Fran C. Hickman Staff Attorney 1000 Center Street P.O. Box 400 Little Rock, AR 72203-0400 (501) 682-5881 OKLAHOMA GAS & ELECTRIC CO. By: Is/Lawrence E. Chisenhall, Jr. Chisenhall, Nestrud & Julian 2840 Regions Center 400 W. Capitol Avenue Little Rock, AR 72201 (501) 372-5800 ATTORNEY GENERAL OF ARKANSAS By: /s/M. Shawn McMurray Senior Asst Attorney General Emon Mahony Asst. Attorney General 323 Center Street, Suite 200 Little Rock, AR 72201 (501) 682-1053

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GERDAU MACSTEEL By: Is/Thomas P. Schroedter Hall, Estill, Hardwick, Gable, Golden & Nelson, P.C. 320 S. Boston Avenue, Suite 400 Tulsa, OK 74103-3708 (915) 594-0436

APSC RLEDThe: 612212011 11:42:57 AM: Recvd 8/2212011 11:37:54

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DOCKET NO 10-109-1.1

STAFF'S SGR RIDER, AS MODIFIED BY THE AGREEMENT 1. The Rider shall only include historical, prudently incurred incremental Costs associated with the deployment of Smart Grid (Davis Direct page 3, lines 15-19) 2. The Rider shall be based on the used-and-useful principle with no costs included in the revenue requirement and recovered before the cost is incurred and Smart Gad meters are inservice (Davis Direct page 3, lines 19-21) 3. The Rider shall include the formula for calculating the annual revenue requirement (Davis Direct page 3, line 21 - page 4, line 2) 4. The Rider shall remain in effect until new rates are implemented as the result of the planned 2013 rate case (Davis Direct, page 4, lines 6-10) The regulatory asset for O&M expenses incurred prior to the implementation of the SOR 5. Rider, without carrying charges, shall be approved. No O&M expense related to the Norman project which was incurred in 2010 should be included. Any non-incremental costs shall be

excluded. The Rider shall include amortization of this regulatory asset over five years provided the expenditures are properly documented, and subject to audit In the Company's next general rate case. (Davis Direct page 5, line 11 - page 6, fine 2) 6. The Rider shall reflect the rate of return approved in Docket No. 10-067-U. (Davis Direct page 6, lines 8-14) 7. The Rider shall reflect the depreciation rates recommended on page 7 Table 3 of the Direct Testimony of Staff witness Gayle Freier (Davis Direct page 6, lines 15-19)
8. A regulatory asset for the early retirement of standard meters shall be allowed, without accrual of carrying charges, for the balance in the standard meter account at early retirement

However, the Rider shall not include any amortization or return amounts for standard meters. The Commission reserves until OG&E's next rate case a final determination of 1) the appropriate amount of the balance in the standard meter account at early retirement and 2) the period for rate recovery, and no amortization or return amounts shall be included in the Rider calculations (Davis Direct page 6, line 19 - page 7. line 2 and Freler Direct page 8, line 14 page 9, line 2)
9. The Rider shall reflect that to the extent OG&E seeks to use different depreciation rates

than those approved in Docket No. 10-067-U or in this Docket, OG&E is required to file an application for such changes with supporting documentation for Commission review and approval (Freier Surrebuttal page 2, tines 13-17)

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The Rider shall be reduced annually by the revenue requirement associated with 0. standard meters as included in the rates in Docket No. 10-067-U upon retirement of the standard meters and deployment of Smart Grid. (Davis Direct page 7, lines 3-15)

11. The Rider shall be fully credited for any Smart Grid amounts - expenses, investment, return, etc. - inadvertently included in rates in Docket No. 10-067-U for the full period of their inclusion. (Davis Direct page 7, lines 16-21)
The Rider shalt include the level of Guaranteed O&M Reductions offered by the 12. Company to reduce the SGR Rider revenue requirement. 13. The Rider shall provide that the biking determinants will be the same methodology as used in the determination of the billing determinants for the Company's Rider ECR. (Davis Direct page 9, tines 8-13) 14, The Rider shall allocate Smart Grid costs to all of the service Levels within the classes such that there will be a separate rate calculated for each service level within each class using an allocator based on Total Distribution Plant less Acct. 360 land and land rights, consistent with the Docket No. 10-067-U compliance cost of service study G-4. (Davis Direct page 10, lines 115) 15. The Rider shall provide for the annual true-up to be accompanied by testimony and workpapers sufficient to fully replicate the calculations of the revised SGR factors. (Davis Direct page 11, fines 5-11) 16 The Rider shall provide the Commission explicitly reserves a finding of value for Smart Grid for ratemaking purposes until a future rate case when base rate recovery is sought (Davis Direct page 11, lines 15-17)15. 17, The Rider shall provide that all collections under the SGR Rider be subject to refund, with interest, after notice and hearing to determine prudence (Davis Direct page 11, lines 17 19)

ATTACHMENT 2
DOCKET NO. 10-1094U

REPORTING REQUIREMENTS

Cost to Deploy: Capital vs. total Capital deployment cost

Total capital dollars spent on the AMI deployment program inception to date vs. total AMI program capital budget as a dollar amount and as a ratio by project

Cost to Deploy: O&M vs. total O&M deployment Total O&M dollars spent on the AMI deployment program cost Inception to date vs. total AMI project O&M budget as a dollar amount and as a ratio by project DOE Reimbursement - AMI only Portion of Department of Energy Smart Grid Investment Grants received and applied to offset cost of AMI and ratio of total grant

Avoided new capital Investment In new Total dollar value of avoided legacy metering capital costs Installations of the older metering systems due to for new customers and new developments customer growth Avoided planned replacement and maintenance Total dollar value of avoided replacement costs of current costs relating to the older metering system (e.g., metering equipment mechanical meters, ERT devices, etc) Reduction in manual meter reading costs Cost reductions due to the elimination of meter reading positions (in-house and contract)

Reduction In meter operations costs (e.g., field Meter operations savings due to lower survey meter visits, meter maintenance, etc) activities and ERT battery replacement COStS Reduced Theft of Energy The number of Incidents of theft of energy uncovered and the dollar amount billed for theft of energy
-

& Execution

Total AMI electric meters installed

Total AMI electric meters installed (physically attached to a premise) expressed as total number and percent of total

ATTACHMENT 2

DOCKET NO 10-109-U

REPORTING REOUIRMENTS Metric Section ProJect Delivery & Execution Nei

Total communication network components Installed (access points & relays)

Total communication network components installed (access points & relays) expressed as total number and percent of total Total AMI meters used for billing (activated, I.e. communicating with meter to produce customer bill) expressed as total number and percent of total Number of avoided truck rolls for meter field Inspections.

Total AMI meters used for billing (activated), communications achieved and used to bill monthly Number of avoided truck rolls

Note: Will include number of deployment truck rolls as a footnote

Meter Accuracy Meter Reading Effectiveness Awareness and Understanding Awareness and Understanding AMI Meter Sample Internal Test Results Percentage of AMI meters that pass internal accuracy ________________________________________ testing prior to deployment Percentage at interval reads received Number of Intervals reported I total number of possible Intervals to be reported Percent awareness of AMI technology and Percent awareness of customers based on survey results benefits (survey measurement) target to be determined after baseline established (with and w1b Internet access) Percent understanding of AMI technology and Percent understanding of customers based on survey benefits (survey measurement) results; target to be determined after baseline established (with and wIg Internet access) Number of community outreach events Number of events held to educate customers and conducted and number of attendees at events Number of customers attending educational events Number of articles that appear in local media Number of articles in internal newsletter Number of articles that appear in local media as a result of company Issued press releases Number of articles in internal newsletter

Communications & Education Communications & Education Communications & Education

unity Outreach unity Outreach ner Satisfactio, unity Outreach

Number of Meter installation Complaints/Claims Number of Meter Installation complaints/claims Number of customer organizations contacted Number of customer organizations contacted

Number of customer referrals to energy advisors Number of transfers to energy advisors for information on

ATTACHMENT 2 DOCKET NO. 10-109-U