FirstFuel Software, Inc…

   FirstFuel Software, Inc.

 420 Bedford St., Suite 200

 Lexington, MA 02420

  Via Electronic Delivery

  December 27, 2017

  Erin Thompson

 Senior Policy Adviser

 Ministry of Energy

 Conservation and Renewable Energy Division

 Conservation and Energy Efficiency Branch

 77 Grenville Street, Floor 5

 Toronto, Ontario, M7A 2C1

  Re: Ontario Ministry of Energy - Regulatory Proposal for Province-Wide Implementation of Green Button

  On November 29, 2017, the Ontario Ministry of Energy (ENERGY) released a regulatory proposal that would require new rules for gas and electric utilities to implement Green Button Download My Data (DMD) and Green Button Connect My Data (CMD) by July 1, 2020.  FirstFuel Software (FirstFuel) appreciates the opportunity to provide input and respectfully submits the following comments on the proposed regulation.

  FirstFuel Software is the global leader in business customer engagement for utilities, using advanced analytics to help 30 energy providers in North America and Europe improve business customer satisfaction, drive sales and revenue, and reduce service costs. Combining data science, building science, and software, our business customer engagement platform derives intelligence from over 4 million meters, transforming energy providers into trusted advisers to their business customers. Our Software-as-a-Service (SaaS) solutions deliver accurate, insightful, and cost-effective results at scale.  FirstFuel’s technology and services are delivered through utilities and provide commercial customers with the energy management tools to understand their energy use, benchmark and assess building energy performance, identify efficiency opportunities, and increase customer participation in conservation programs.  FirstFuel regularly works with utilities to support Green Button DMD and CMD for their entire

 commercial customer base to ensure they have ability to connect and manage their electricity, gas, and water in one tool.  FirstFuel also provides Energy Star Portfolio Manager (ESPM) data services to ensure easy compliance with benchmarking and energy reporting regulations.

  FirstFuel engages in regulatory proceedings across North America, and provides input on grid modernization and data access policies.  In August 2016, FirstFuel participated in the Ministry of Energy’s consultation session on Green Button and submitted written comments on the Policy Workshop. “FirstFuel has been supporting the Green Button standard through a SaaS platform since at least 2012, and we are well prepared to implement services on behalf of utility and government clients across the province.  For examples of our work in this area with the U.S. General Services Administration and the U.S. Department of Energy, please visit: https://energy.gov/sites/prod/files/2014/05/f15/fupwg_may2014_gsa_update.pdf.”(1)

  FirstFuel strongly supports the regulatory proposal to require a province wide implementation of Green Button.  The Green Button standard is a best practice known by many industry stakeholders to be the most scalable way to provide individual customer data to customers and customer-authorized third parties.(2)  This proposal would build on Ontario’s leadership among Canadian provinces and many leading U.S. utilities that are implementing DMD and CMD for commercial customers and distributed energy resource (DER) providers.  Customers benefit from increased transparency of their energy data and custom analyses that can be developed by third party engagement tools. Utilities benefit from Green Button implementation through cost-efficiencies related to reduced data processing efforts, and increased self-service of data access encourages call avoidance.  In addition, Green Button creates another digital channel utilities can pursue to gain trust and increase customer satisfaction with their customers.(3)

  FirstFuel is encouraged by the regulatory proposal and will focus comments on four topics:

  • Timing: Ontario is an early adopter when it comes to implementing Green Button. The province initiated Green Button in 2012 among 10 utilities and now 60% of electricity customers have access to this functionality.  Further, many utilities have been piloting CMD and are familiar with the regulatory requirements to ensure secure data transfer.  We support an implementation date of July 2020 and we would encourage this to happen sooner given the experience in the region.

 • Implementation: The proposal is agnostic on the implementation model of software platforms to support Green Button. “FirstFuel supports a single hosted implementation of Green Button via a SaaS provider to ensure consistency of service across the province, which is a major benefit to customers and energy providers. In addition, by implementing Green Button via SaaS, utilities can be assured that the IT infrastructure behind the Green Button implementation does not go quickly out of date or lack interoperability across utilities. Instead, through the SaaS model, updates can be pushed to all utilities and customers simultaneously, ensuring that every utility customer has the latest version.  Utilities are also likely to appreciate the benefits of a province-wide implementation on their internal processes. A single implementation relieves some of the burden from their IT departments. The SaaS model also enables utilities to “white-label” Green Button data sharing portals, so that they retain their brand identity with customers. In addition, utilities may choose to offer additional value-added services, such as basic data interpretation/analytics for customers, which can improve the value proposition for customers utilizing the Green Button Platform and improve the utility-customer relationship.” (4)

 • Procurement: The proposal provides flexibility for energy providers to enter into a procurement process or develop software internally.  FirstFuel strongly recommends a competitive procurement process for a software platform that specializes in Green Button to ensure a superior customer experience. From our experience, energy providers that endeavor to build specialized software products tend to underestimate the time and cost it takes to develop the desired functionality.

 • Funding:  New regulations and rule changes will require necessary updates to utility IT systems and data infrastructure to meet the new secure data exchange requirements.  FirstFuel recommends additional funding for utilities so they have the resources to operationalize the regulation.

 FirstFuel commends the Ministry of Energy for taking up this important issue and strongly urges the swift passage of the proposed regulation.  We look forward to supporting the Ministry of Energy and utilities, and other stakeholders in future implementation of Green Button and customer engagement solutions within the region.

  Sincerely,

  /s/ Jordana Temlock

 Director of Market Development

 FirstFuel Software, Inc.

  (1) FirstFuel Comments on Green Button Stage 2 Policy Workshop, August 12, 2017.

 (2) Advanced Energy Economy (AEE) Comments on Hawaiian Electric Companies' Final Grid Modernization Strategy, Docket No. 2017- 0226, p.11. Also available here: https://dms.puc.hawaii.gov/dms/OpenDocServlet?RT=&document_id=91+3+ICM4+LSDB15+PC_DocketReport59+26 +A1001001A17I14B02647F0002818+A17I14B35944F046841+14+1960

 (3) Accenture. The New Energy Consumer: Unleashing Business Value in a Digital World. (2015).

 (4) FirstFuel Comments on Green Button Stage 2 Policy Workshop, August 12, 2017.

[Original Comment ID: 211636]