COMMENT 1: the 2020…

   COMMENT 1: the 2020 timeline is quite far out and will likely result in industry (commercial sector) looking for alternate means to meet their data needs between now and when the data is made available in 2020. This will result in reluctance to use a new Green Button (GB) enabled data access process when it does get made available.

  SUGGESTION 1: Since majority of the Green Button value is unlocked through the commercial sector adoption use case(s) - including EWRB reporting, we would suggest getting the CLD group and union and enbridge have a 2018 completion date, which would then allow the market place an opportunity to leverage the Green Button Data feed for their reporting requirements.

   COMMENT 2: It is critical that certification is a key requirement of implementation because if we have different implementations across utilities this will be a total waste of time for any user of the data.

  SUGGESTION 2.1: Utility cost recovery for GB from the Ontario Energy Board (OEB) should be contingent on getting GB certification.

  SUGGESTION 2.2: As there is only one certification body in the market today with a very lengthy and slow implementation track record for developing Green Button certifications, this dependancy without an articulated/established back up certification plan poses a huge risk to the entire initiative. This should be developed and communicated to utilities and the GBA which would help put some pressure on the alliance to meet the timelines that keep shifting.

   COMMENT 3: Extensions for utilities pose a large risk to the success of the initiative (especially the larger utilities) because if a large piece of the Ontario market is delayed (Toronto, Alectra, Enbridge etc) then businesses will not end up realizing the efficiencies that the standard's business case is counting on capturing.

  SUGGESTION 3: Make it extremely difficult/impossible for the larger utilities (CLD group, Enbridge and Union) who are needed to unlock majority of the Green Button value to get extensions on the GB adoption date

   COMMENT 4. Water municipalities have not been mandated to adopt the standard because it is not cost effective to have hundreds of water utilities pay for the cost of adopting the standard, especially when water readings and meter data is so infrequently collected and available.

  SUGGESTION 4.  The govt, should consider requiring water utilities/municipalities to adopt GB for water if they are procuring or upgrading their water meters to smart meters (like Toronto, Ottawa, Peterborough etc) where they are putting in place a digital water data management system. Green Button DMD and CMD should be included in the procurement by default as the cost of doing so is negligible at that time as opposed to retrofitting these systems after the deployment is complete.

   COMMENT 5: There are no timelines for when the  "Technical Advisary Services for the Green Button Initiative" consultant will provide the Support Documents to guide Ontario utility adoption. Lack of definition and delays in the completion of these Support Documents could jeopardize utility adoption timelines. In fact it could prevent utilities from starting adoption work until these support documents are made available

  SUGGESTION 5. Timelines for these Support Documents should be made available as part of the GB policy direction. Clear guidance should also be provided to utilities which parts of implementation can be initiated before the 'Support Documents' are made available.

   GENERAL SUGGESTION: There is a good opportunity for the govt. to 'walk the talk', where it can lead by example by adopting the GB standard across all its energy agencies by stating that all CDM / DSM framework data collection, reporting that uses energy data should be done using the Green Button data format by default. Presently IESO, OEB and Ministry and their associated programs all request data from utilities in different formats - all of these organizations should be adopting the GB data format by default (to the extent that can provide the info needed) would be a good way to drive market adoption and lead by example.

[Original Comment ID: 212207]