RE:  Comments regarding…

   RE:  Comments regarding draft regulations requiring Green Button Connect My Data - Support

  Dear Ministry of Energy:

  The Mission:data Coalition applauds the Ontario Ministry of Energy on its Green Button initiative. The Ministry’s proposal to empower utility customers of all types with innovative digital services will significantly contribute to the province’s achievement of its energy efficiency and climate protection goals, as well as its technology leadership generally. We strongly support the proposal to mandate implementation of certified Green Button Connect My Data (CMD) uniformly across the entire province. In addition to our endorsement, we offer our constructive feedback on certain details of the proposal.

  By way of background, Mission:data is a national coalition of more than 35 technology companies in North America delivering data-enabled services that focus on providing direct energy and carbon savings to all utility consumers (residential, commercial, industrial and institutional customers). These services range from detailed energy usage analysis and energy information feedback technologies, to demand response and device control.  Our members are the leading innovators in the industry, representing over $1 billion per year in sales of advanced energy management.  We have been active in over 14 states in the U.S. helping to craft data access policies. For more information, please visit www.missiondata.org.

  Mission:data believes all consumers should have convenient access to the best available information about their energy usage and costs (including both historical interval information and, where available, real-time information directly from advanced meters) and the ability to share that data with any third parties of their choice.

  We have organized our comments in three sections: (1) The importance of a good user experience, (2) billing and cost information, and (3) recommendations on performance and data quality.

  (1) User experience. As we mentioned in previous comments to ENERGY, the role of the customer experience in achieving Ontario’s laudable goals of being a leader with regard to Green Button Connect My Data (GBCMD) should not be underestimated.

  With any IT project, it is easy for utilities to be overwhelmed by technical requirements and implementation challenges and lose sight of the end user.  How does the customer actually make the system work? Where will customers get confused and abandon the authorization process? Are the customer’s tasks being completed in the fewest number of steps? How long does it take the customer to complete a common function, and can that time be reduced? The benefits of GBCMD won’t be realized if customers can’t easily interact with the system.

  Mission:data thus emphasizes to ENERGY that a truly functional implementation of GBCMD requires that it include the customer experience in its regulations.  We recommend considering an authorization process in which the customer can begin and end the process on the third party’s website or mobile app. In addition, the information required to be provided by the customer should not be obscure, and the process must be simple, straightforward, and short.  This will be particularly important for achieving some of the Ministry’s stated goals, including acquisition of data by users with multiple sites and utilities.  California is in the midst of implementing such a customer- and third-party centric system precisely to improve enrollment rates in a residential demand response program, because many customers found the utilities’ websites to be clumsy, difficult to use, and unpredictable on mobile devices and tablets, despite GBCMD ostensibly being available.

  Third parties are experts in customer experience since they regularly interface with customers and are incentivized to optimize the experience for customer retention. These third parties should be consulted in evaluation of the customer experience as it significantly affects the success of their programs and consequently the options for customers to engage in energy management programs.

  In addition to customer experience, Mission:data also emphasizes the importance of the third party’s experience in integrating with the Green Button system.  Good technical documentation, a clear registration and enrollment process, short response times to technical support requests and a simple, easy-to-use website for troubleshooting problems are essential ingredients to a successful platform.  In our view, it is insufficient to merely mandate GBCMD; certain levels of responsiveness, availability of documentation, and a simple, consistent registration process across Ontario are important as well.

  (2) Billing and cost information. While we recognize that the focus of Green Button is on energy usage data, billing and cost information is important as well for many applications.  Multifamily properties and commercial properties have an interest in streamlining cost management applications, which today often involve expensive services that manually read PDFs of bills and type in information by hand.  As long as utilities are being made to implement GBCMD for energy usage data, the incremental effort and cost to include billing information is not large.  We note that California utilities, who pioneered GBCMD in North America in 2015, provide billing history via GBCMD using the “retailCustomer” schema that is an optional part of GBCMD.

   (3) Recommendations on performance and data quality. Our experience in the U.S. is that any utility’s GBCMD roll-out is never flawless. The biggest vulnerability is uptime of the utilities’ GBCMD servers. If the servers are not rigorously maintained, interruptions in data flow will lead to a lack of trust on the part of third parties that could lead to consumers not experiencing GBCMD’s benefits.  We have recommended in several states that regulators mandate an uptime requirement of 99.9%, which translates into approximately nine (9) hours of downtime per year. Virtually all information technology services today come with a service level agreement (SLA) from their provider.  In our view, utilities providing GBCMD should be no different in this respect.  At a minimum, utilities should be required to report periodically on the up-time of their systems so that the Ontario Energy Board, ENERGY, third parties and other stakeholders have access to information (ideally on a publicly-available website) about the performance of their GBCMD implementation.

  Data timeliness: One of the challenges across multiple utilities is that each utility’s advanced metering system and meter data management system is somewhat unique. One source of variation between utilities is how quickly meter data can be collected, processed and transmitted to an authorized third party.  In most locations in the U.S. with GBCMD, there is a one-day delay from meter reading to transmission to a third party.  Mission:data believes ENERGY should require a one-day delay as a maximum.  While it may be difficult or expensive to mandate quicker response times than one day, it is also important to prevent multiple days of delay from creeping into utilities’ GBCMD implementations.

  The second aspect of timeliness has to do with how quickly customer data is transmitted to a third party after the customer clicks the final “submit” button.  In our experience, this period of time varies tremendously – some utilities do not transmit energy data for days or weeks following customer authorization.  We strongly recommend that ENERGY require delivery of historical energy data within 90 seconds of authorization by a customer for all utilities in Ontario.  Without a specified time interval, software providers could be waiting for unknown periods to get a response from a utility, their customers can see no immediate results from their enrollment in such services, and this uncertainty has negative impacts on the uptake and impression of innovative new services

  Data quality:  Finally, the last important element of GBCMD is an optional parameter in Green Button called “QualityOfReading,” which denotes the quality of the meter data.  If meter data are not “billing quality” or “settlement quality,” then it cannot be used for demand response settlement purposes at the IESO.  In our experience, utilities in California originally provided non-billing quality data via GBCMD and this was a significant obstacle to demand response growth in the state.  Given that “QualityOfReading” is optional, utilities could be certified as complying with GBCMD but still fail to provide data that enables precisely the type of energy management services that ENERGY seeks to promote in the province.  Therefore, we strongly recommend that ENERGY include a requirement to provide revenue-quality data via GBCMD.

   In conclusion, Mission:data stands ready to assist the Ministry in implementation of Green Button CMD across the province. We look forward to working with you and thank you for the opportunity to provide comments.

   Sincerely,

  Bob King

 Board member, Mission:data Coalition

 Good Company Associates

 3101 Bee Caves Road St 135

 Austin, TX 78746

 rking@goodcompanyassociates.com

 (512) 279-0751

[Original Comment ID: 212131]