January 19, 2018…

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   January 19, 2018

  Erin Thompson

 Senior Policy Adviser

 Ministry of Energy

 Conservation and Renewable Energy Division

 Conservation and Energy Efficiency Branch

 77 Grenville Street, Floor 5

 Toronto, ON M7A 2C1

  Re:  Regulatory Proposal for Province-Wide Implementation of Green Button – EBR-013-1874

  Dear Ms. Thompson:

  Attached please find Cornerstone Hydro Electric Concepts Association’s (CHEC) comments with respect to the Ministry’s invitation to comment on the regulatory proposal for the province-wide implementation of Green Button.  This submission addresses the several sections outlined in the proposed amendment dated November 29, 2017 and follows the same format (Attachment A).

  CHEC is an association of seventeen (17) local distribution companies (LDC’s) that have been working collaboratively since 2000.  The comments over the following pages express the views of the CHEC members.

  We trust these comments and views are beneficial to the Ministry’s initiative.  CHEC looks forward to continuing to work with the Ministry in this matter.

  Yours truly,

   Kenneth B. Robertson CPA, CGA, MBA

 Finance/Regulatory Analyst


  Definitions – Under the proposed regulation, ENERGY would seek to further define terms used in the proposed enabling legislative amendments. For example, ENERGY would seek to further define “energy” as electricity and natural gas, and an “energy provider” as a licensed electricity distributor or natural gas distributor. For greater clarity, ENERGY is considering further defining “natural gas distributors” as Enbridge Gas Distribution Inc., Union Gas Limited, Natural Resource Gas Limited, Utilities Kitchener and Kingston Utilities. ENERGY would also seek to define “account holder” as a person or entity who has an account with an energy provider.

  CHEC has no issue with this proposed regulation section.  The more clarity provided the better.

  Through the proposed regulation, ENERGY would also seek to clarify the definition of “energy data” to align with all of the required data specified in the requirements for the DMD and CMD certification program.

  CHEC has no issue with this proposed regulation section.  The more clarity provided the better.

  Requirement to make energy data available – ENERGY would propose to require that energy providers make available to account holders all energy data necessary to meet the requirements for certification to Green Button DMD. At a minimum, this would mean providing account holders’ energy consumption quantities for discrete intervals. In addition, ENERGY would propose that energy providers make energy data available to third parties, subject to the consent of account holders, to meet the requirements for certification to Green Button CMD.

  CHEC is supportive of standardization, but is also very concerned with the cost of implementing Green Button when there is currently little customer uptake on this initiative.  This situation is further exacerbated considering that many utilities already have systems in place that provide consumption information and bill comparisons to those customers who require or request the data. In today’s “hydro” sensitive environment, it would make more sense to allow utilities to continue on their current paths rather than introduce the additional costs required to implement Green Button.

  ENERGY would propose a deadline of July 1, 2020 for utility implementation of Green Button. Utility implementation would include the procurement or development of a software platform as well as obtaining Green Button DMD and Green Button CMD certification (see certification requirements outlined below).

  If utilities are required to move forward with this initiative, CHEC sees no issue with the current deadline of July 1, 2020 for implementation of Green Button.

  Certification Requirements – ENERGY would propose to require that energy providers obtain Green Button Data Custodian DMD certification and Green Button Data Custodian CMD certification through the Green Button Alliance (GBA) certification program.

  The primary objective here is to meet the requirements for standardization (DMD and/or CMD) rather than to get certified to a standard.  Certification just adds unnecessary cost to the implementation process.  Even the Green Button Alliance website acknowledges that actual certification is more for marketing purposes than anything else.

  As an alternative, CHEC would propose that utilities use the free testing offered by the Green Button Alliance to ensure that the requirements of Green Button DMD (CMD is expected to be available soon) are met.  This would ensure standardization without the extra cost required for certification.

  Exemptions – Under the proposed regulation, ENERGY is considering exempting Hydro One Remotes Communities Inc., Attawapiskat Power Corporation, Fort Albany Power Corporation and Kashechewan Power Corporation from the proposed requirements due to the unique nature of their service territories and/or infrastructure.

  CHEC has no comment on this proposed regulation section.

  Extensions – ENERGY would propose that the Ontario Energy Board (“Board”) may extend the time period as it determines is reasonable for when an energy provider would be required to comply with the proposed requirements. ENERGY would propose that an energy provider could seek an extension from the Board if there are technical or operational reasons or other special circumstances impacting the energy provider’s ability to meet the proposed requirements on time or cost-effectively.

  CHEC has no issue with this proposed regulation section.

[Original Comment ID: 212083]