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Stakeholders urge CPUC harmonization of data formats, sampling rules and re‑examination of NEM exclusion

3113207 · April 24, 2025
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Summary

In discussion panels IOUs and vendors asked the CPUC to align data formats (ESPI vs CSV/SFTP), clarify acceptable transport protocols, and reconsider annual sampling and the exclusion of net energy metering customers from submetering. SDG&E described the practical CSV/SFTP files it needs to onboard MDMA partners.

Industry and utility participants pressed the California Public Utilities Commission for clearer, harmonized rules covering data format, secure transfer and device certification, and called for a targeted review of the decision that excludes NEM customers from submetering.

SDG&E project manager James McCloskey described the operational exchanges his billing system expects: “there's effectively 3 CSV files of note, 2 that are inbound and 1 that is picked up by the EVSP … the inbound 1 is the meter data file that's used for billing. And then there's an enrollment file … and then we have an enrollment response.” McCloskey said SDG&E implemented secure file transfers (SFTP) for daily file pickup and that CSV/SFTP is a baseline that allowed the utility to build automated enrollments for single‑customer (S‑core) use cases.

On data formats and security

The transcript shows differing stakeholder preferences for standardized machine‑readable formats: the CPUC’s submetering protocol references ESPI (the PEV profile of the Energy Service Provider Interface) as one option, while utilities and vendors have used CSV files and SFTP or considered API approaches. McCloskey argued that CSV/SFTP is a pragmatic baseline for broad participation, while APIs and TLS‑based exchanges are technically feasible for more sophisticated participants. He said the utilities do not generally share personally identifiable information in the transfers because customer identifiers are aliased in the MDMA enrollments.

On certification and sampling

MDMAs and vendors asked the CPUC to reconsider the burden of annual field sampling and certification. Vendors noted that many commercial metering programs employ long recertification intervals (for sealed, certified meters) and said annual sampling imposes high per‑device costs when MDMA meter counts are small. SDG&E and other IOU speakers emphasized the utilities’ responsibility to ensure billing accuracy and said they will validate data quality and provide feedback to MDMA partners.

On NEM exclusion

Multiple participants urged the CPUC to revisit the decision that excludes NEM customers from submetering. Vendors argued that the exclusion prevents sites with rooftop solar or storage from participating even when separate submeter subtraction could be performed accurately. GridTractor and other MDMA speakers said the exclusion reduces addressable markets and urged a carefully scoped review to allow submetering arrangements for NEM customers where the metrology and data flows can ensure correct billing and exported‑energy accounting.

Ending

Stakeholders recommended the CPUC adopt a pragmatic, layered approach: accept CSV/SFTP as a baseline interchange format for MDMA integration, allow secure API/TLS options for advanced participants, convene a working group on sample‑plan and certification intervals that considers MDMA scale, and open a targeted review of the NEM exclusion to permit limited, verifiable submetering use cases.