The Region of Peel thanks the Ministry of Energy for the opportunity to provide feedback on the Regulatory Proposal for Province-Wide Implementation of Green Button (EBR Registry Number: 013-1874).
The Region of Peel supports the Province’s vision and efforts to move towards province-wide implementation of the Green Button initiative as it aligns with our 2015-2018 Term of Council Priority to “adapt and mitigate to the effects of climate change” and will support our efforts to achieve our community GHG reduction target of 80% below 1990 levels by 2050.
With the introduction of CMD and DMD it is recommended to have the energy billing information made available at the same time line item by line item. The Region would benefit from having an electronic string of data available for entry into our energy management software or Accounts Payable system. The electronic data can be used by different departments for other purposes such as utility billing error management, consumption forecasting, energy procurement planning, budgeting and recording energy use for benchmarking and performance monitoring.
Comments on the Regulation
The Region supports the efforts of the Ministry of Energy in the implementation of CMD and DMD. It is recommended that the metered data should be available with 24 to 48 hours after actual usage to be beneficial for energy management and environmental initiatives and financial decisions.
The Region currently has energy management software in place that collects “kW.h delivered interval” in five minute intervals and “kVAr.h delivered interval” in five minute intervals. The software produces the proper outputs for demand (kW) and consumption (kW.h/hr). The Region would be an active participant in the Green Button CMD program through our vendor who would collect all the data streams and populate the energy management software database. The decision to use single integrated implementation or some other software solution should be left to the end user.
3.Solution Provider and Utility Registration
For customers that have multiple utilities, it is preferential to have a single point of registration. For example, The Region works with four electric utilities, one gas utility and one water utility and would have a point of contact with our software vendor that would make the arrangements to download the data and transfer this information to our software.
4.Formal Green Button Certification
The Region supports the formal Green Button certification as all data is to be treated as confidential in nature. While dealing with privacy concerns the Province should be mindful of community energy projects and work to create a solution that will not be so restrictive that future energy opportunities could be foregone.
5.Phase-In and Timing
All utilities should introduce the Green Button at the same time. This ensures consistency and ensures that customers have access to their information at the same time.
6.Implementation and Maintenance
The Province already has a single hub for data transfer from the electric utilities and the electrical suppliers for the billing of electricity. We believe that this hub should be used for all utility data including all line item billing data. The existing hub for data transfer would be the best solution since it already is in place and operating.
[Original Comment ID: 211969]
Submitted February 15, 2018 2:59 PM