BEFORE THE
VERMONT PUBLIC SERVICE BOARD
IMPLEMENTATION OF THE FEDERAL
ENERGY POLICY ACT OF 2005
DOCKET NO.
COMMENTS OF HUNT TECHNOLOGIES, INC.
REGARDING NEXT STEPS FOR A PROCESS TO CONSIDER SMART
METERING AND TIME-BASED RATES
AND NOW COMES Scott H. DeBroff, Esquire of LeBoeuf, Lamb, Greene & MacRae
LLP, on behalf of his client, Hunt Technologies, Inc. ("Hunt") and avers the following:
1. Hunt Technologies delivers industry-leading advanced metering infrastructure (AMI)
solutions to the electric, water and natural gas utilities markets. With world headquarters in
Pequot Lakes, Minnesota, Hunt develops and supports hardware and software for more than 480
customers worldwide.
2. Hunt has been involved in smart metering issues in more than ten (10) states and has a
significant interest in the outcome of this proceeding.
3. The Federal Energy Policy Act of 2005 requires each state public utility commission to
consider and make a determination regarding four "standards," unless the state already has a
comparable standard in effect, or the state commission has already conducted a proceeding
considering implementation of a comparable standard, or the state legislature has already voted
on the implementation of a comparable standard.
4. Of particular importance to Hunt is the fourth standard, which says that each electric
utility shall offer each of its customer classes, and provide individual customers upon customer
request, a time-based rate schedule under which the rate charged by the electric utility varies
during different time periods and reflects the variance, if any, in the utility's costs of generating
and purchasing electricity at the wholesale level. The time-based rate schedule shall enable the
electric consumer to manage energy use and cost through advanced metering and
communications technology. Each electric utility shall provide each customer requesting a timebased rate with a time-based meter capable of enabling the utility and customer to offer and
receive such rate, respectively.
5. The Board asked parties to file comments on whether the Board should adopt each of the
standards, or whether the Board should conduct a process (or processes) to consider them. The
Board received seven comments.
6. On January 20, 2006, the Board held a workshop to discuss, among other items, the four
standards included in EPAct. After the workshop, the Board issued a memorandum requesting
agenda items and possible speakers for a future workshop that would explore technological and
other issues related to the Board's consideration of the smart metering and time-based rates
standard. The Board received six comments in response to this memorandum.
7. On February 21, 2006, the Board issued a memorandum setting forth the next steps in its
process for considering the smart metering and time-based rate standard.
8. On February 24, 2006, comments were filed on a draft agenda for the March 15, 2006
workshop on smart metering and time-based rate issues.
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9. On March 10, 2006, the Board received filings by the electric distribution utilities with
summary information on current and pending time-based rates, current and planned use of smart
metering technologies, and recent or planned utility-specific analyses regarding smart metering
and/or time-based rates.
10. On March 15, 2006, the Board hosted a workshop on smart metering and time-based rate
issues, of which Hunt attended and participated.
11. Near the end of that workshop, parties briefly discussed what the next steps should be in
the Board's consideration of the Federal Energy Policy Act of 2005's proposed "standard"
regarding smart metering and time-based rates. The possible next steps that were mentioned
included another workshop, a pilot program, and the separation of the smart metering and rate
design components.
12. However, there was insufficient time to conclude this discussion. Therefore, the Board
agreed to provide the parties with an opportunity to file written comments on what the next steps
should be. Accordingly, any party wishing to file such written comments should do so on or
before April 14, 2006. These are Hunt's comments.
13. Based on the well done presentations at the first workshop on March 15th, and
considering the lack of time to really undergo any significant discussions, Hunt believes that the
Board should, as a next step, consider hosting another workshop. This time, the Board should
schedule an entire day to conduct such and put out a request to parties to suggest what kinds of
speakers and discussion topics around smart metering and demand response should be offered.
There were some discussions and one presentation that touched on the "technology" piece, and
we would support a more involved discussion of the changes and benefits of technology that
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exist today. In addition, we felt that the interactive discussion periods were a great opportunity
for parties who had not had the opportunity to make a presentation, to be able to weigh in on the
speakers and the topics discussed. Hunt would also recommend a continuation of that practice.
14. In terms of steps beyond another workshop, Hunt has started to participate in other state
"EPACT" processes, and each state, while different, attempts to combine the basic requirements
as set forth in the PURPA requirements from 1978. There is a hearing process that has certain
notice requirements, and that process allows for all interested parties to be able to speak to the
issues of concern and then allows for the Commission to run the process and make
determinations regarding smart metering based on the input from the parties to the hearing. Hunt
believes that many of the questions posed to the utilities in the early stages of this process before
the Board were good jumping off points for the kind of information that would be relevant in a
hearing process. Hunt also believes that the hearing process would allow other interested parties
to have an opportunity to present their information into the forum, ultimately providing the
Board with a well-rounded picture of the smart metering issues, fully preparing it to make a
ruling on the subject.
15. Finally, following a hearing process, Hunt also believes that parties should be entitled to
follow up by filing Comments and/or Reply Comments regarding the positions taken in the
hearings. The end of the process would be a Board decision on what rules and guidelines it
wishes to implement in the State of Vermont.
16. There are, of course, many versions of a "process" that will surely be suggested. Hunt
looks forward to working with the Board, the utilities, and the other parties to this proceeding, in
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finding a process that works for everyone, allowing all of the relevant information regarding
smart metering and time-based rate options to be presented.
17. Attorney DeBroff will represent Hunt in this case, and on the basis of this notice, we
request that copies of each document hereafter issued by this Board in the above-captioned
matter be directed to the Harrisburg, Pennsylvania office of LeBoeuf, Lamb, Greene & MacRae
LLP at the address listed below.
Respectfully submitted,
Dated: April 14, 2006
By: _______________________________
Scott H. DeBroff, Esquire
LeBoeuf, Lamb, Greene & MacRae, L.L.P.
200 North Third Street, Suite 300
P.O. Box 12105
Harrisburg, PA 17108-2105
Tel: (717) 232-6453
Fax: (717) 232-8720
eMail: sdebroff@llgm.com
Counsel for Hunt Technologies, Inc.
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BEFORE THE
VERMONT PUBLIC SERVICE BOARD
IMPLEMENTATION OF THE FEDERAL ENERGY
POLICY ACT OF 2005
DOCKET NO.
_____________________________________
CERTIFICATE OF SERVICE
_____________________________________
I certify that I have by mail, and a courtesy copy by electronic mail to the parties to
which an electronic mail address has been provided the appropriate Service List, this day served
a true copy of the original attached "COMMENTS OF HUNT TECHNOLOGIES, INC." on
all parties of record in this proceeding or their attorneys of record.
Respectfully submitted,
Dated: April 14, 2006
By: _______________________________
Scott H. DeBroff, Esquire
LeBoeuf, Lamb, Greene & MacRae, L.L.P.
200 North Third Street, Suite 300
P.O. Box 12105
Harrisburg, PA 17108-2105
Tel: (717) 232-6453
Fax: (717) 232-8720
eMail: sdebroff@llgm.com
Counsel for Hunt Technologies, Inc.
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SERVICE LIST
E-Mail Service List for Smart Metering and Time-Based Rates Materials
Abendroth, Harry Vermont Electric Cooperative habendroth@vermontelectric.coop
Adler, Aaron Department of Public Service aaron.adler@state.vt.us
Allard, Todd Vermont Marble Todd.Allard@omya.com
Allen, Riley Department of Public Service riley.allen@state.vt.us
Becker, John Department of Public Service john.becker@state.vt.us
Bentley, Bruce Central Vermont Public Service Corp. bbentley@cvps.com
Bishop, Ann Public Service Board abishop@psb.state.vt.us
Brown, Jim Green Mountain Power brown@gmpvt.com
Brown, Vickie Vermont Electric Cooperative vbrown@ppeclaw.com
Burke, John Public Service Board jburke@psb.state.vt.us
Burns, Chris Burlington Electric Department cburns@burlingtonelectric.com
Coen, David Public Service Board dcoen@psb.state.vt.us
DeBroff, Scott LeBoeuf, Lamb, Greene, MacRae sdebroff@llgm.com
Emerson, Eli 14 Munis eemerson@ppeclaw.com
Enterline, Shawn Burlington Electric Department senterline@burlingtonelectric.com
Gidney, Ennis Public Service Board egidney@psb.state.vt.us
Janson, Kurt Public Service Board kjanson@psb.state.vt.us
Levine, Sandra Conservation Law Foundation slevine@clf.org
Lyle, Tom Public Service Board tlyle@psb.state.vt.us
Perry, Kevin Vermont Electric Cooperative kperry@vermontelectric.coop
Plett, Fred Tantalus Systems Corporation fplett@tantalus.com
Powell, Bill Washington Electric Cooperative billp@washingtonelectric.coop
Pratt, Randy Public Service Board rpratt@psb.state.vt.us
Richards, Patty Burlington Electric Dept. prichards@burlingtonelectric.com
Silver, Morris Central Vermont Public Service Corp. mlsilver@sover.net
Underhill, Chuck Vermont Public Power Supply Authority cunderhill@vppsa.com
Volz, Jim Public Service Board jvolz@psb.state.vt.us
Welch, Carole Department of Public Service carole.welch@state.vt.us
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