The Government of Ontario…

ERO number


Comment ID


Commenting on behalf of

Energy Transformation Network of Ontario (ETNO)

Comment status

Comment approved More about comment statuses


The Government of Ontario should enact regulation to require the implementation of the Green Button data standard by all Local Distribution Companies and natural gas distributors

ETNO believes that the implementation of a standardized approach to enable better access to customer energy usage data is a building block for future grid modernization efforts. While some progress has been made, Ontario needs to make significant strides in this area in order lay the required foundation for a data and technology focused energy sector that promotes greater consumer choice, competition, and value. To do this, ETNO recommends that the Government of Ontario enact regulation to require the implementation of the Green Button data standard across the province’s LDCs and natural gas distributors.

Green Button is a data standard owned by the North American Energy Standards Board (NAESB), which includes a common format for energy data, called Download My Data (DMD), and a sharing protocol for that data, called Connect My Data (CMD). Using the Green Button standard, energy data from the distributor’s systems can be leveraged in a user-friendly format in an effort to both help customers better understand and manage their energy consumption, and to allow authorized third parties to access that data in a secure manner.
Implementing Green Button province-wide would address many of the key barriers to improving access to data (standardization, efficiency, cost effectiveness and security) by:

• Enabling electricity and natural gas customers in Ontario to access their energy consumption more quickly to support efforts in demand management

• Provide a standard format that third party developers can use to develop and offer customers innovative solutions to help better understand and manage consumption patterns to reduce energy bills

• Securely transferring energy data from utilities to customer-authorized third party entities and applications and allowing customers to define the length of data access authorization and revoke authorization at any time

• Enabling distributors to work with developers who can offer standardized solutions that give customers access to information on a variety of platforms from online to mobile

• Providing a platform for distributors to use for internal data exchange needs and as a development platform for internal business processes requiring time series data input.

In addition to the benefits of Green Button related to standardization, ease and security of customer and third party access and cost effectiveness, the data standard provides a solid platform upon which future grid modernization efforts can be built. For example, as the prevalence of energy related smart home and industrial devices grow, customers will demand a seamless relationship between their energy data and these devices, including DERs; something that can be accomplished via a data standardization method such as Green Button. Green Button could also assist large energy consumers in meeting provincial energy reporting requirements established under the Energy and Water Reporting Benchmarking (EWRB) initiative in the future as current platforms are enhanced to accept data in new formats.

The government of Ontario has considered regulation to enact Green Button in the past and on October 8 issued a new regulatory proposal on the Environmental Registry of Ontario which again considers proposing regulation to require the standard to be implemented province-wide across electricity and natural gas distributors. Past efforts to implement Green Button were put on hold for two main reasons: 1) the version of the Green Button standard in effect at the time was under revision to incorporate a schema for retail customers, and 2) the lack of an established certification process to validate compliance with the standard. Both of these issues were addressed in 2019, paving the way for a full-scale implementation across Ontario’s electricity and natural gas distributors. ETNO recognizes that the implementation of Green Button would entail costs being incurred by LDCs and distributors (and by extension, their customers). As such, ETNO further recommends that distributors be allowed to recover implementation costs when they arise and that the beneficiaries of Green Button bear the cost of implementation and operation, consistent with general regulatory principles. This could mean, for example, that some portion of costs for the Connect my Data standard are borne by the third parties that would use it.

As was previously determined when the Ontario Ministry of Energy, Northern Development and Mines examined the implementation of Green Button in 2017, the overall cost benefit for implementation was seen to be net positive for electricity and natural gas data even after accounting for implementation costs. Further, ensuring that implementation of Green Button is applicable across all LDCs and natural gas distributors may provide opportunity for cost reductions. London Hydro, for example, has made significant progress with the rollout of Green Button and has engaged other LDCs including Festival Hydro and Whitby Hydro (now Elexicon) in a utility consortium in order to use a shared service model that reduced the one-time implementation costs per customer by 50%. This experience points to the benefits that can come from a coordinated approach to implementing Green Button across multiple entities simultaneously.

ETNO members highlighted that the business case for the implementation of Green Button in their service territories was not likely to be equal in all cases. For example, for an LDC with a high volume of residential customers and a low volume of commercial industrial customers may realize less immediate benefits or uptake from the implementation of Green Button. ETNO believes the government should be cognizant of this fact and consider the allowance of a phased implementation of Green Button, potentially allowing LDCs and natural gas distributors flexibility in determining which classes of customers should be included and timing of deployment. Any flexibility incorporated into requirements should be balanced with the understanding that the benefits of a data standardization approach like Green Button are necessarily reduces as implementation moves away from universal application.

Some ETNO members highlighted the value of refreshing the cost-benefit analysis that was previously conducted by the Ministry. These members also identified supplementary research and analysis, including a business case and assessment of customer preferences, as being required to ensure that both the fact and timing of regulation to implement Green Button is appropriate at this time. The need for this additional analysis was not agreed to by all ETNO members.