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CASE 10-E-0285 Consider Regulatory Policies Regarding Smart Grid Systems and the Modernization of the Electric Grid

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CASE 10-E-0285 Consider Regulatory Policies Regarding Smart Grid Systems and the Modernization of the Electric Grid Before the STATE OF NEW YORK PUBLIC SERVICE COMMISSION Proceeding on Motion of the Commission to CASE 10-E-0285 Consider Regulatory Policies Regarding Smart Grid Systems and the Modernization of the Electric Grid COMMENTS OF QUALCOMM INCORPORATED Dean R. Brenner Vice President, Government Affairs John W. Kuzin Senior Director, Regulatory Qualcomm Incorporated 1730 Pennsylvania Avenue, NW Suite 850 Washington, DC 20006 (202) 263-0020 Dated: September 15, 2010 SUMMARY Qualcomm is pleased to respond to the New York State Public Service Commission’s inquiry into the appropriate requirements and regulatory policies to encourage electric utilities to implement Smart Grid systems. Qualcomm’s comments focus on the communications requirements of the Smart Grid, which, as this Commission recognizes, is the “essence” of the Smart Grid that enables “the multitude of energy services” envisioned for next generation energy management technologies. In these Comments, Qualcomm explains how commercial wireless technologies can satisfy the varied and increasing communications needs of electric utilities, businesses and consumers. Qualcomm looks forward to continuing to work with its electric utility and communications industry partners on Smart Grid issues as these technologies are further integrated into our electrical networks. For more than two decades, Qualcomm has enabled the introduction of countless wireless technologies and products that many utilities use today to support the smart delivery and consumption of energy. Qualcomm believes that these technologies also will enable the swift, broad, and cost-effective implementation of the Smart Grid. Indeed, as the Commission appreciates, Smart Grid communications must benefit businesses, consumers, and utilities alike by transporting the information required to wisely manage energy use. Commercial cellular technologies, which currently offer mobile broadband service to approximately 98% of all Americans, see FCC National Broadband Plan, must play a key role in the continued development of the Smart Grid to fully realize the Commission’s goals set out in the Notice of Inquiry, namely (i) improved reliability and power quality; (ii) reduction in peak demand and in transmission congestion costs; (iii) increased energy efficiency; (iv) greater environmental benefits through increased asset utilization; (v) increased security; (vi) greater ability to accommodate more renewable energy, and (vii) increased durability and ease of repair in response to attacks and natural disasters. Commercial cellular technologies, and the enhancements to these technologies that are being rapidly developed and deployed, should play an integral role in supporting the communications requirements of the Smart Grid. Many key Smart Grid applications can take full advantage today of the enormous sunk and ongoing investments in commercial cellular technology – from automated meter reading to demand response (i.e., the ability of the customer to alter energy usage through remote control of customer equipment based on, for example, time of use and critical peak pricing) to remote electric power connects and disconnects to remote fault detection and isolation to net metering (i.e., the means of monitoring energy from a customer’s solar panel system or wind farm back to the utility grid). To launch the Smart Grid in a timely and cost-effective manner, electric utilities should take advantage of the substantial economies of scale and other benefits of cellular technology already in heavy use throughout America. There is no other available broadband communications technology that can meet the unique combination of requirements for the Smart Grid, including reliability, security, full coverage, and global harmonization and interoperability, other than today’s cellular technology. Cellular technology can be used to meet New York’s Smart Grid broadband needs in two ways. First, existing commercial cellular networks can be used, thereby taking advantage of the massive investments the wireless carriers have made and will continue to make. These virtually ubiquitous networks deliver high speed, low latency mobile broadband service where the overwhelming majority of New Yorkers live, work, and travel, and these networks are constantly being expanded and upgraded. In fact, this Commission has strongly encouraged “utilities to -ii- work with established network providers to leverage their available infrastructure and operational expertise in deploying smart grid communications solutions.” See American Recovery and Reinvestment Act of 2009- Util. Filings for N.Y. Economic Stimulus et al., Order Authorizing Recovery of Costs Associated with Stimulus Projects, NY Pub. Serv. Comm’n, CASE 09-E-0310 (July 27, 2009) at 41. Second, if a particular utility determines that, notwithstanding the tremendous past, present, and future network investments by commercial cellular carriers, those networks will not meet their own requirements for reliability, coverage, performance, and security, they can acquire spectrum rights and build their own cellular wireless networks. A utility that plans to follow this second path, however, should demonstrate to the Commission that the utility has given serious consideration to whether commercial cellular networks can cost-effectively support its Smart Grid communications needs. The California Public Utilities Commission requires just such an analysis. See California PUC Decision Adopting Requirements For Smart Grid Deployment Plans Pursuant To Senate Bill 17 (Padilla), Chapter 327, Statutes of 2009, Section 3.5.2 available at http://docs.cpuc.ca.gov/PUBLISHED/FINAL_DECISION/119902.htm. Commercial cellular carriers are expanding their coverage every day. And, to reach areas that would be unduly expensive to cover with terrestrial mobile broadband, Qualcomm has developed satellite-based technology that will be included in the same wireless chipsets that support terrestrial mobile broadband. Mass-market, hybrid satellite-terrestrial devices using these chipsets can access to mobile broadband anywhere in New York State and be used to fill coverage holes in terrestrial mobile broadband networks. The result will be truly ubiquitous high speed wireless broadband coverage, which may be necessary to cover the countless devices that are expected to access the Smart Grid. -iii- Beyond developing technology for universal mobile broadband coverage, Qualcomm is working to enable the use of mobile broadband for the Smart Grid in other ways. For example, several companies produce 3G-based modules using chips supplied by Qualcomm CDMA Technologies (“QCT”), the world’s largest supplier of chips for wireless devices. These miniaturized modules are embedded into computers, dongles attached to computers and other consumer devices, and a variety of machines and equipment that provide high speed wireless broadband connectivity for Smart Grid applications, among other uses. In addition, QCT’s Gobi module provides multi-mode mobile broadband connectivity so it can be used on any commercial 3G mobile broadband network. In this way, Gobi would permit a utility to use multiple 3G network technologies for Smart Grid applications and allow the provider to choose the most cost-effective 3G network in any given area. Gobi is particularly well-suited for the most prevalent Smart Grid applications: (i) automated meter reading, particularly at the “concentrator” level, where the data aggregated from hundreds of homes are collected and transmitted to the utility; (ii) demand response systems, and (iii) remote fault detection and isolation. Another QCT module, known as inGeo, integrates Assisted GPS and wireless connectivity to report position location data from a very small, extremely low-power device. inGeo also allows for the integration of sensors that, for example, can measure pressure and temperature and report those readings back to a utility’s network control center in near real time. This capability is perfect for remote monitoring, sensing, and control systems that support Smart Grid reliability improvements and limit the need for expensive site visits to remote sites. Qualcomm hopes that the Commission finds this submission helpful as it studies the communications requirements for sustaining and modernizing New York State’s power grid. As -iv- summarized above and as detailed herein, cellular technology should continue to serve an essential role in supporting the communications needs of our nation’s 21st century electric utility infrastructure. -v- TABLE OF CONTENTS SUMMARY ..................................................................................................................................... i I. Cellular Communications Technology And Networks Are Essential To The Successful Deployment And Evolution Of The Smart Grid ................................................2 A. Overview of Qualcomm’s Role In The Development Of Cellular Technology ......2 B. Cellular Technology Is Continually Being Upgraded to Deliver Faster Data Rates, Lower Latency, and Greater Capacity .....................................................................6 1. Faster Data Rates ........................................................................................ 6 2. Wider Coverage .......................................................................................... 7 3. Lower Latency ............................................................................................ 8 4. Expanded Capacity/Improved Performance ..............................................
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