On November 29, 2017 the…

   On November 29, 2017 the Ministry of Energy (“Ministry”) posted a notice to amend Ontario Regulation 20/17 and 397/11 made under the Green Energy Act, 2009 (the “Act”). The purpose of the amendments is to mandate the province-wide implementation of Green Button Download My Data (“DMD”) and Connect My Data (“CMD”) by electricity and natural gas utilities to support increased conservation initiatives and energy efficiency, and remove barriers for consumers to have access to their data.

  The proposed amendments follow governments commitment dictated in the 2013 Long Term Energy Plan to give consumers access to their electricity consumption data and connect with apps to help analyze and manage their electricity consumption. The province reaffirmed these commitments to Green Button initiatives in the 2017 Long Term Energy Plan as a way to “empower consumers with access to data and tools” to put conservation first and manage energy costs.

  Toronto Hydro appreciates the opportunity to comment on the above noted regulation and provides the following comments.

  Definition:

  Toronto Hydro supports the Ministry’s proposed definition for “energy” as electricity and natural gas, and “energy provider” as a licensed electricity distributor or natural gas distributor.

 Requirement to make energy data available:

  The proposal if adopted will require energy providers to make available to third parties all energy data necessary to evaluate energy consumption of account holders subject to their consent. While Toronto Hydro supports this initiative and will comply with the requirements if implemented, we note our concerns for protecting customer consumption information and recommend that the regulation specify a requirement that third parties provide evidence of consent by the account holder to share energy consumption data by the energy provider.

   Implementation deadline:

  Toronto Hydro will be able to implement the necessary software to ensure Green Button DMD and CMD certification by July 1, 2020.

  Furthermore, Toronto Hydro appreciates the flexibility provided by the Ministry for DMD and CMD implementation types.

   Should you have any questions please contact the undersigned.

  Andrew J. Sasso

 Director, Regulatory Affairs

 Toronto Hydro-Electric System Limited

 regulatoryaffairs@torontohydro.com

  :AS/KR:MS

[Original Comment ID: 212203]