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Paul Alvarez over 2 years ago

When measuring utility performance, setting performance targets, or tracking performance over time, I suggest the Commission consider benchmarking. Electric distribution IOU performance benchmarking, of the type available from the Utility Evaluator (www.utilityevaluator.com), offers several advantages over performance targets based on historical trends for a subject utility. 1) Historical data for a subject utility provides a single reference point for a domain, while benchmarking incorporates a range of performance within a domain by multiple utilities. 2) Subject utility targets (such as customer satisfaction) do not provide for changing assumptions (such as commodity costs), while benchmarking's relativity readily accommodates changes experienced by all utilities in a peer group. 3) Benchmarking can incorporate peer grouping for maximum relevance and credibility. 4) Use of publicly-available data (FERC Form 1 and EIA Form 861) can reduce reporting and measurement burdens. 5) It is difficult if not impossible to manipulate performance data reported by hundreds of utilities when used as a benchmark for subject utility performance evaluation.

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