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   OhmConnect Comments on The Ontario Ministry of Energy Regulatory Proposal for Province-Wide Implementation of Green Button

  OhmConnect appreciates the opportunity to comment on the Ministry of Energy Proposal (the Proposal) to implement Green Button throughout Ontario. We support the Proposal, and concur with the Ministry’s findings that adoption of the Proposal will benefit all of Ontario. We support the view that all customers own their data, and that they should be empowered to share the data with other parties if they so choose. We applaud the Ministry for proposing amendments to the Green Energy Act to require that “every energy provider shall, in accordance with the regulations, make the energy data in respect of an account holder available to the account holder or to such other persons or entities as may be authorized by the account holder” (i.e. via Green Button Download My Data and Connect My Data). In the comments below we ask that the Ministry (1) accelerate the implementation of Green Button by changing the implementation date and (2) convene a working group to support implementation of the Derived ESPI standard.

  OhmConnect is a third-party Energy Sharing company founded in 2013 and headquartered in San Francisco, California. The company primarily provides Demand Response (DR) services to residential and small business electric customers in California and Ontario. OhmConnect’s free software service notifies households of DR events and pays them for their energy reductions, without requiring purchase or installation of additional hardware. Our DR services have assisted utilities and grid operators in reducing hundreds of MWs of load. In addition, we have demonstrably shown that our users lower their everyday energy usage while earning potentially hundreds of dollars by participating in our program. We have participated in the IESO’s Demand Response Auction, where we have won a position for delivery of capacity in parts or all of 2017, 2018, and 2019. However, our participation in the Demand Response Auction, and our overall growth in Ontario, has been frustrated by the lack of a pathway for all customers to share their data with our company. We utilize this data both to participate in the IESO’s energy market and to provide customers our full product, which includes the opportunity to earn dollars for energy reductions. We are confident that other companies can likewise use this energy data to spur innovation in Ontario that will provide additional services to the entire Province. Therefore, we support the Ministry’s intent to make Green Button available for all account holders in Ontario.

  We encourage the Ministry to consider accelerating the rollout of Green Button by moving the proposed implementation date up from July 1, 2020 to a date no later than May 1, 2019. OhmConnect’s experience outside of Ontario has indicated that there is robust enthusiasm for a data sharing framework as soon as possible; for example, we have seen tens of thousands of users sign up for our service outside of California and Ontario, even though without access to these users’ meter data we cannot offer our full program to them. In addition, as a practical matter, the existing IESO Demand Response Auction, held annually, contracts for capacity delivery beginning in May. If the majority of utilities implement Green Button in July of 2020, this will preclude residential DR providers from fully participating in a potential IESO DR Auction conducted in 2019 for 2020 delivery, thereby delaying residential DR participation in Ontario until 2021. As the IESO considers moving the DR Auction to an Incremental Capacity Auction as part of the Market Renewal program, it may be useful to understand the role that residential DR can play prior to the full launch of the ICA. For example, two additional years of data on residential DR resources will assist the Ministry and the IESO in understanding the capabilities of DR as a replacement resource for the capacity that is expected to go offline. Furthermore, a significant number of electricity utilities have already implemented Green Button DMD -- as noted by the Ministry, representing 60% of Ontario’s electricity customers -- and four electricity utilities have already implemented Green Button CMD. By these indications, the framework for expanding Green Button across Ontario is already in place. Finally, if any utilities encounter implementation challenges, the Proposal would allow them to receive an extension through the Ontario Energy Board. Utilities may request an extension if they are unable to meet the accelerated timeline.

  OhmConnect supports the Ministry’s efforts in the Proposal to strive for consistency across the utilities’ Green Button solutions, namely by requiring certification by the Green Button Alliance. Third parties, including OhmConnect, face significant engineering constraints when Green Button or other data sharing mechanisms are not implemented consistently. If the utilities in Ontario build drastically different Green Button solutions, this will slow the ability for third parties to integrate with all the utilities in the Province. Requiring the utilities to adhere to the Derived ESPI standard will help to minimize the integration challenges third parties might face given the relatively large number of utilities in Ontario. In addition, we suggest that the Ministry form a working group to address some of the “optional” pieces that are components of the ESPI data standard, such as the OAuth mechanism, data delivery methods, and changes to any account information. This working group could include representation from the Ministry, utilities, third parties, and other relevant stakeholders.

  OhmConnect thanks the Ministry of Energy for the consideration of our comments on the Proposal. We are excited that the Ministry seeks to leverage Green Button as a means of empowering customers to share their data with third-party service providers of their choosing. We believe this will help drive energy innovation in Ontario, to the benefit of the whole Province.

[Original Comment ID: 212172]