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Commenting on behalf of

Cornerstone Hydro Electric Concepts (CHEC)

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I've organised the comments into sections. As CHEC represents 19 electricity utilities in Ontario, these are the consolidated responses based on a few questions asked to our members.

1. Utility and Customer Types - thoughts on the draft proposal to require all electricity companies to implement both DMD and CMD for all customer classes:

Our primary concern is whether or not the Green Button Initiative is currently suitable for all utilities and all customer classes. At the present time, there appears to be insufficient empirical evidence to support wide-spread customer use of either the DMD or CMD initiatives. For example, there appears to be some interest among the larger industrial and commercial customers, but the 2016 Green Button pilot program indicates that there has been very little uptake from the residential sector.

A secondary concern has to do with whether or not data standardization is even necessary. Most utilities already have some form of DMD and/or CMD in place, although you will find the standard provided to customers will vary from utility to utility. Is here a need to standardize when customers that want the data are already being supported by their utilities?

If status quo is not an option, one possible solution would be to focus on formalizing only existing data channels within a utility. Perhaps a better solution would be to focus only on those utilities and customers where interest in the Green Button Initiative can be readily identified as cost effective. Additional research and analysis, utilising additional input from the utilities and the public sector, could be conducted to determine where efforts should be best focused or if they should be focused at all for every utility in Ontario. Otherwise the Green Button Initiative could involve significant costs to the utilities that only benefits a few or a select group of consumers.

2. Implementation Type - thoughts on a single integrated (hosted) implementation:

There are pros and cons to each implementation type proposed by the draft policy:

• The single integrated (hosted) option may be the lower cost option, but it also creates a monopoly where there is little incentive to provide good service, innovation, or be cost effective.
• At the other end of the scale, the In-House option provides more flexibility and promotes competition, but it is more expensive to implement and more prone to complications when it comes to promoting standardization across the utilities.

A better solution would be to define the Green Button requirements for the service providers but leave the choice of the provider to the utility. This is like the approach taken with the provision of Operational Data Store (ODS) services during the phase-in of smart meters. The benefit will be more innovation and cost-effective services as service providers compete for business. Any complication with respect to standardization could be mitigated by ensuring the required standards are properly set.

3. Certification - thoughts on the draft proposal to require a formal Green Button certification and seal for utilities with optional certification and seal for solution provider technical certification and solution provider privacy certification:

CHEC is supportive of utility certification providing utilities have the ability to decide how DMD and CMD are implemented. Utility certification provides confidence that an implementation complies with the standard and that it is comparable/interoperable with other Green Button products and services. CHEC is also supportive of not requiring certification for service or registration providers. Certification for these providers is seen as an additional cost that provides little value in the end. That said, there is a concern that utility certification will be construed as utility expertise when it comes to how the data is utilized or on the technical capabilities of a particular service. This could increase the administrative burden on utilities as there is already a pre-established relationship whereby customers rely on the utility for their expertise on services offered. Clear distinctions would have to be made to ensure utilities are only certifying they are in compliance with a standard, while services providers are the experts when it comes to their service offerings.

4. Other Thoughts:
In order to be fully supportive of the Green Button Initiative, utilities would need firm confirmation from the OEB that all costs associated with the roll out of this initiative would be recoverable through the IRM and/or rate application process.