1)Data Limitations :
Recommendation: Currently, the proposed data is of limited value to the City and likely any large account holder in the province seeking effective management of account data. The City recommends that the Province introduce a system that includes consumption, demand (transmission and distribution, if applicable), and all relevant details from utility bills. This would include account number, billable line items with associated dollar value, statement date, due date, and any other relevant information needed to pay invoices.
Allowing for this would enable multi-account businesses to collect and pay invoices in a timely fashion, while maintaining high quality energy data for analysis.
2) Accessing Multiple Accounts with One Login:
Recommendation: The City of Toronto Recommends that the Province include a regulation for utility providers to provide access to multiple accounts under one login. Currently, many LDC’s including Toronto Hydro require a single login for each business account, while allowing a single login for multiple residential accounts. The City manages over 1200 hydro accounts and 800 natural gas accounts; a single login per utility provider would lessen the effort to collect relevant data.
Comment: The only reporting platform identified as part of Ontario's Benchmarking regulation is Portfolio Manager, and currently this platform does not offer the ability to upload Green Button files or create a Green Button 'Connect My Data' setup for energy data. As such Green Button implementation will offer limited support to participants from a data gathering point of view.
Portfolio Manager does however allow users to download back electricity data (once inputted manually)in Green Button Format, and as such the City can continue to promote the Green Button initiative during the post reporting phase (as part of our recommendations) as an ongoing means to monitor the participants' electrical consumption and help stimulate behavioural change.
4) Real Time Data access
Recommendation: The City of Toronto recommends that the Ministry expand the Green Button regulation and include a timeline requiring electricity distributers to provide real time data access for commercial and Industrial consumers.
Current Provincial regulations including "Class A" Industrial Conservation Initiative and "Class B" demand charges, incent commercial and industrial consumers to manage and reduce electrical demand. Previous experiences accessing real time data have been an expensive and time consuming process, limiting the implementation of real time data logger projects and potential energy savings opportunities.
This enhanced Green Button and forecasted electricity demand savings may further reduce electricity system costs by shifting resource adequacy requirements associated with the Ontario Reserve Margin. These system costs savings will benefit all Ontario consumers.
[Original Comment ID: 212082]
Submitted February 15, 2018 3:00 PM