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The ESP Handbook
Chapter 17
Energy Consumption Reconciliation
Version 3.8
December 9, 2005
17.1. Background
A major concern facing the new electric market is the potential misreporting of end-
use customers’ energy consumption. In its December 16, 1997, decision
concerning the Retail Settlement and Information Flow (RSIF) Workshop Report
(D97-12-090), the CPUC stated that failing to schedule electricity through a
scheduling coordinator may amount to the theft of utility services. If the value of the
services obtained exceeds $400, the offending party could be charged with a
felony. The decision continues, stating that until the feasibility of a statewide
detection system can be assessed:
“This potential problem should be left in the interim to the UDCs to solve.
Since the Commission’s jurisdiction over scheduling coordinators is
limited, the UDCs should establish internal systems to detect when an
ESP is no longer scheduling the delivery of electricity to an end-use
customer. The UDC will have the name of the ESP’s scheduling
coordinators, the load data provided to the scheduling coordinators by the
ESP, and historical records of past usage. If there is a wide variation
between past usage and the load data provided to the scheduling
coordinator, the UDC could investigate this discrepancy.”
Furthermore, the CPUC approved the following provision in Section 18,
Unauthorized Use of Energy (Energy Theft), of the ESP Service Agreement:
“The ESP represents and warrants that for each of its Customers, and at all
times during which it provides Direct Access services as an Energy
Service Provider, the ESP shall completely, accurately, and in a timely
manner account for each of its Customer’s loads with a duly authorized
Scheduling Coordinator. Load data not accounted for in this manner may
provide grounds for termination of this Agreement. For verification
purposes only, the UDC shall have complete access to the identity of the
Scheduling Coordinator and the load data provided to it by the ESP.”
17.2. SCE’s Response
In response to the RSIF directive, Southern California Edison (SCE) has
implemented a system to monitor the accuracy of reported energy consumption
information. The system compares ESP aggregated settlement quality meter data
sent by Scheduling Coordinators (SCs), on behalf of ESPs to the ISO against
similar usage information independently calculated from internal SCE billing system
data.
17.3. General ESP Requirements
All ESPs are required to submit to SCE, or cause to be submitted, the aggregated
settlement quality meter data generated for submission to the ISO. As defined in
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the Meter Data Exchange Format (MDEF) data requirements, settlement quality
meter data is actual consumption, aggregated by hour, for your customers, with the
appropriate distribution loss factors applied.
The information must be submitted electronically on a daily basis for each hour of
each day, consistent with data exchange guidelines delineated in the ISO protocols.
The SCE system has been designed to utilize ESP data in similar formats and
timing requirements as already necessary for submission to the ISO, thereby
minimizing the incremental costs for gathering, processing, and transmitting this
data to SCE.
A secure FTP server has been set up by SCE for the purpose of receiving usage
data from ESPs. Strict confidentiality will be maintained for all data files received.
A unique login ID and password will be provided to ESPs by SCE sometime after
ESPs begin operations. The login ID and password will be sent in a separate
mailing in a cover letter similar to the one contained in Section 17.7 “Sample
Notification”. In cases where a SC is submitting data on behalf of several ESPs, it
is important that the correct ESP login Ids and passwords be utilized, and the
appropriate data transmitted, on behalf of each respective ESP.
17.4. Specific ESP Requirements
Data may be submitted by demand zone, load group, or take-out point. Only data
for the SCE demand zone (SCE1) needs to be submitted. ESPs who use more
than one SC may aggregate usage into a single file, or submit separate files for
each SC. In cases where an SC is preparing the settlement quality meter data, it
may be more efficient to authorize the SC to submit the files to SCE. Each file may
consist of one or several trade dates. A file containing settlement quality meter data
for more than one trade date must reflect usage for consecutive days. Multiple
submissions in a day are acceptable. For example, this may be done on Mondays
and days after national holidays to report usage for weekends and holidays, or at
other times when it becomes necessary to provide multiple submissions. Partial
day submissions will not be accepted. Data submitted must comply with the MDEF
guidelines. For detailed information on the MDEF format, please refer to the ISO
web page (www.caiso.com). Slightly different than the ISO requirements, it is
mandatory to populate the Customer ID (CM_CUSTID) field in the main header
section of the MDEF file. Populating this field will allow us to identify the source of
the settlement data. Subsequent Customer ID fields in the remainder of the MDEF
file may be left blank.
All data submissions to the ISO must be done by midnight of each day, for usage 45
days prior to the reporting date. For example, usage for January 1, 2001 must be
reported no later than 12:00 midnight on February 15, 2001. Meter data files should
be provided to SCE at the same time they are submitted to the ISO. In addition, any
subsequent resubmission of corrected meter data to the ISO must also be provided
to SCE following the same process as outlined below.
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Version 3.8, December 9, 2005
During transfer of data, an ESP will be required to enter a valid login ID and
password in order to submit data to the secured FTP server. SCE will provide the
following information to all ESPs so that they may access the server and download
their meter data files:
• SCE FTP server host name
• A unique login ID to access the FTP server
• A unique password to access the FTP server
17.5. FTP Login & Data Transfer Instructions
As mentioned above, a secure FTP server has been set up by SCE for the purpose
of receiving usage data from ESPs. Strict confidentiality will be maintained for all
data files received. Please use the login ID and password provided by SCE to
transfer data files to the SCE server.
§ After establishing a path to the FTP server, login using the appropriate IP
address. Type 192.213.104.50 and then press <Enter>. This connects to your
secured IP address and will allow access past the SCE firewall. You will only
have file transfer privileges for data files to the SCE server.
If connection with the ftp server is complete, you will see the following dialogue:
“Only authorized SCE users may use this service for company
business. Violations or misuse of this service are grounds for
termination. Check point FireWall-1 Secure FTP server running on
go2fw01.
Name(192.213.104.50:root):”
§ After the above dialogue is complete, enter your login ID after the prompt as
loginID@loginID@192.213.104.50 and then press <Enter>.
§ At the password prompt, enter your password as password@password and
then press <Enter>.
§ If there was a successful login, you will see the following dialogue:
“User (your User ID) logged in. Access restrictions apply.”
§ At the ftp prompt, type put to transfer your file and then press <Enter>
§ At the local-file prompt, type the name of the file you want transferred and then
press <Enter>.
§ At the remote-file prompt, type the file name and extension the way you wish to
save the file on the SCE server and then press <Enter>. You may employ the
same file naming convention used for submitting data to the ISO. However,
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Version 3.8, December 9, 2005
please ensure that all files have an extension of .dat. After a successful transfer
of the file, you will see the following dialogue:
“Port command successful. Opening binary mode data connection for
(your file name.extension). Transfer complete.”
The file transfer is now complete. You may logout of the FTP session. SCE will now
load and process this file. If there are any problems, you will be contacted by an
SCE representative. Please note that you will not receive confirmation of file receipt
during this login session.
In summary, a successful file transfer process would occur as follows:
1. Dial in to FTP server
2. FTP >192.213.104.50
3. Name (192.213.104.50:root) >loginID@loginID@192.213.104.50
4. Password >password@password
5. FTP >put
6. (local-file) >filename.dat
7. (remote-file) >filename.dat
8. Port command successful
9. Quit application
Note:
Login Ids and passwords are case sensitive and must be input exactly as shown on
the cover letter. In addition, for steps 3 and 4, the loginID and password must be
repeated, separated by an @ symbol. (i.e. loginID@loginID@192.213.104.50, and
password@password).
17.6. Questions
As mentioned above, an SCE representative will be contacting you after you begin
operations as an ESP to assist you in fulfilling the requirements of our Energy
Consumption Reconciliation Process. For your convenience, we will be happy to
work with your scheduling coordinator as your designated agent in submitting your
settlement data to SCE. If that is your desire, you should inform our representative
of the name, address, e-mail, and telephone number of your SC’s employee that we
should contact.
If you have questions concerning our reconciliation process you should contact:
Jim Knik
SCE Finance Department
(626) 302-1181 or James.Knik@SCE.com
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Version 3.8, December 9, 2005
17.7. Sample Notification
** ESP Name **
ESP Settlements Representative Name
Representative’s Address
In compliance with the CPUC decision concerning the Retail Settlement and
Information Flow Workshop Report, attached are the detailed data requirements for
submitting settlement- quality meter data to Southern California Edison.
In addition to the specific requirements included in the attachment, you have been
assigned a unique login ID and password for accessing the secured FTP server
and downloading your meter data files. The unique login ID and password assigned
to you are:
Login ID: xxxxx
Password: xxxxx
To properly identify your data files, the following ESP identifier has been assigned
to you:
Customer ID: xxxxx
Please include this ESP identifier in the Customer ID (CM_CUSTID) field in the
main header section of all MDEF files submitted to SCE. For our purposes, this
field is mandatory, as there is no other way to identify the data as belonging to a
specific ESP. The data files can be submitted by either you or your Scheduling
Coordinator, on your behalf.
Our records indicate that a series of your accounts went active starting mm/dd/yy.
That being the case, we need to institute a process whereby we start receiving your
settlement files for trade day mm/dd, up to and including the current settlement date.
Please begin submitting settlement files in accordance with the attached data
requirements no later than mm/dd/yy. If you require additional time to establish
the required data communications link, please contact me to discuss a mutually
acceptable start-up schedule.
If you have any further questions concerning our process or the specific data
requirements, please contact your account manager, or me at (626) 302-1181 or
via e-mail at James.Knik@sce.com.
Jim Knik
SCE Finance Department
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17.8. Energy Reconciliation Process
The data you submit to SCE will be compared to similar data extracted from SCE’s
internal metering and billing systems.
Usage episodes for your customers will be identified through a monthly query. The
data from this query is then processed through SCE’s aggregation system. This is
the same system SCE uses to produce the Settlement Quality Meter Data (SQMD)
for bundled service customers that it submits to the ISO. This processing:
§ Applies the appropriate load profiles to cumulative meter reads.
§ Applies the appropriate Distribution Loss Factors (DLFs) to all usage.
§ Aggregates usage by hour for each ESP.
The data that we use for the energy reconciliation process is the same data that
SCE has provided to you on our MDMA server if we are the meter reader for the
accounts, or the data that we have received from your designated MDMA if
someone else is reading the meter. As a result, the usage calculated by SCE
should match the usage data you submit to the ISO. Section 17.11, below,
identifies potential causes of variances in the two sets of data.
17.9. Energy Reconciliation Data Packages
Energy reconciliation data packages are provided to ESPs on a quarterly basis by
the ESP Services Account Manager.
The data packages include:
§ A narrative summary of the results for the calendar quarter, with our input as
to the possible causes of variances between your reported use and the
SCE calculated use.
§ A chart that summarizes your reported use, the SCE calculated use, the
variance quantity, and the variance quantity stated as a percentage of your
reported use. The chart presents this data for each day of the quarter. It
then totals this usage data by month and quarter, and calculates daily
averages for individual months and the quarter.
§ A graph comparing your reported daily use to the SCE calculated use for
the calendar quarter and a graph that tracks the daily variance for the
quarter These graphs provide an overview for the entire quarter.
§ Individual monthly graphs that compare your daily reported use to the SCE
calculated use and track the daily variance in MWhs and as a percentage
of the reported use. These graphs allow a closer viewing of the daily
results.
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§ Average monthly time-of-use graphs. These graphs compare an average
daily profile of the usage you reported for each hour to a similar average
profile of the SCE calculated use. These average monthly profiles are
compiled by determining the average of all usage reported for Hour 1 for
the month, Hour 2, Hour 3, etc. In addition to the average monthly usage
profiles, graphs are also included of the average variance profile, stated in
MWhs and as a percentage of your reported use. The purpose of these
graphs is to help identify the time of day when variances occur and to
identify any shifts in the time-of-use reporting.
§ Additional graphs as determined appropriate to better display unusual
trends or results, suspected reporting errors, etc.
In addition to the quarterly data packages, we provide interim results via e-mail on a
monthly basis, or as potential reporting problems are identified.
17.10. Timing
Our goal for providing quarterly data packages is to provide them to you within 90
days of the end of the calendar quarter. Although it may not appear to be, this is
actually a fairly aggressive goal for us.
Meter data is not submitted to the ISO until T+45. In some cases, delays occur in
obtaining meter data files from your scheduling coordinator.
We update our reconciliation system on a monthly basis. The query of our internal
systems occurs sometime between the 10th and the 19th of the month. The usage
data is processed through SCE’s aggregation system on the 19th, and the results
are used to populate our energy reconciliation system. The query typically captures
meter reads that are recorded in our system through the first week of the month.
The earliest that all of the applicable meter reads can be captured is the second
monthly query following the end of the quarter. If you have many customers,
however, chances are increased that meter reads for some of your accounts will not
be available until the third monthly query is run.
Quarterly data packages are prepared as data becomes available, and it is verified
for reasonableness. We normally would not provide you a data package until we
have determined that the SCE calculated usage is reasonably complete, or until we
can provide you a perspective on the account activity that we believe to be excluded
from the SCE calculated usage data.
Interim results are provided monthly as data become available. If we suspect a
significant problem exists with your meter data reporting, we will attempt to
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communicate it to you as soon as we become aware of the situation and can
sufficiently validate the reasonableness of the data involved.
17.11. Typical Meter Data Reporting Errors
Some of the typical types of errors in data submitted by ESPs that can result in UFE
and that can be identified through SCE’s energy reconciliation process include:
§ Failure to include all Direct Access accounts in the aggregation process.
§ Failure to estimate usage for Direct Access accounts for which actual meter
reads or meter specific estimates do not exist.
§ Failure to add or apply a Distribution Loss Factor (DLF).
§ Application of the wrong DLF to an account or group of accounts.
§ Incorrect or inappropriate application of load profiles.
§ Shift in the application of the DLF, typically by one hour. (Both PG&E and
SDG&E post DLFs with an end-of-the-hour time stamp. SCE posts DLFs
with a beginning-of-the-hour time stamp.)
§ Inaccurate processing of interval meter data posted on SCE’s MDMA server
during periods of Daylight Saving Time due to misunderstanding of SCE’s
posting standards.
§ Introduction of time shifts in which usage is reported in a different hour than it
occurred. The most common time shifts include:
- A one-hour time shift usually associated with the time change between
Pacific Standard Time and Daylight Saving Time.
- An eight-hour time shift caused by failure to realize that meter data is
posted to the MDMA server in Greenwich Mean Time (GMT).
In addition to the potential processing errors identified above, there are two
possible reasons, other than a processing error, why the data that the ESP
submitted to SCE might vary somewhat from the data extracted from SCE’s internal
metering and billing systems:
§ The ISO time-frame for submitting meter data (T+45) can be very
challenging. If an actual meter read is not available at T+45, you are
required to estimate the missing usage. Our energy reconciliation
process is not limited by the same time constraints. It uses only the
actual billed usage, and it continues to be updated with any subsequent
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meter reads or subsequent billing corrections, regardless of when they
occur. This may result in a variance since we could be using data not
available to you at the time you were required to submit your SQMD to
the ISO.
§ SCE’s energy reconciliation process tends to be conservative. As a
result, it is unusual for the usage for an ESP’s customers to be
overstated, although this can occasionally happen. The more common
occurrence is that usage episodes will be missed in the query of SCE’s
metering and billing system, thus understating SCE’s estimate of the
ESP’s usage. In most cases, we have found these errors to be less than
0.5% of the ESP’s reported use, but it can be slightly higher for individual
ESPs.
17.12. Assistance
The primary purpose of our energy reconciliation process is to identify the cause of
errors that contribute to Unaccounted For Energy (UFE). The ISO’s authorized time-
frame for resubmission of inaccurate meter data makes it difficult to identify, and
communicate possible error situations in sufficient time to allow investigation and
resubmission. As a result, our primary purpose becomes identification of the cause
of recurring errors, so action can be taken to prevent similar errors in future meter
data reporting.
The data we provide should serve as an effective gauge of the accuracy of the
SQMD you submit to the ISO. If a significant variance exists between the SQMD
you submitted and the SCE calculated data, it is prudent to investigate the possible
cause. Errors could be costing you money, or unfairly burdening other market
participants with increased UFE charges.
If there is a significant variance, we can provide assistance identifying the cause.
We can provide you detailed reports of your customer activity used in generating the
SCE calculated usage. This will allow you to compare the account level detail to the
data used in your aggregation process.
The ISO allows resubmission of data until approximately T+70. Although this often
limits your ability to correct the entire period affected by errors, there is generally an
opportunity to correct some portion of the period involved. If you have questions
concerning resubmission of SQMD, contact your scheduling coordinator, or your
ISO account representative.
17.13. ISO Scheduling Coordinator Audit
The ISO requires all scheduling coordinators to perform an annual self-audit. The
data we provide you can assist you with your audit. The quarterly data packages
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provide an assessment of the accuracy of the SQMD submitted to the ISO on your
behalf and can reduce the time and testing required for your scheduling
coordinator’s auditors.
If requested, SCE can provide your scheduling coordinator’s auditor the data from
our energy reconciliation process to assist him or her with the required testing.
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