ecobee appreciates the…

   ecobee appreciates the opportunity to comment on the Ministry of Energy’s (“ENERGY”) Regulatory Proposal for Province-Wide Implementation of Green Button.  ecobee also appreciates that ENERGY has continued to seek ecobee’s input on this matter.[1]

  Empowering customers to access and share their energy information in a simplified, user-friendly, timely and consistent manner, across utilities, is vital to ensuring that Ontario’s consumers can make better decisions about their energy use as the Ontario government intends.[2]  How these principles are applied to a province-wide implementation of Green Button Download My Data (DMD) and Connect My Data (CMD) will continue to be of importance to ecobee.  This is because ecobee’s data-driven corporate strategies and product designs enable hundreds of thousands of consumers to conserve energy, reduce demand and carbon impacts on a daily basis.  Further, giving consumers control over their data is a core value at ecobee.  From this company’s beginning, ecobee has given its customers the ability to easily access and share their thermostat data to derive actionable insights about their home’s energy use and performance. This has been in line with ecobee’s belief that customers own their data and should dictate who can access it.

  ecobee will continue to provide, enhance and expand these data-based services in the months to come.  These near- and mid-term efforts are expected to further support the Ontario government’s Climate Change Action Plan and 2017 Long-Term Energy Plan (LTEP) goals.  The following comments have been prepared with these expectations mind.  They also draw upon ecobee’s data services and conservation and demand management program expertise.

  FOOTNOES FOR THIS SECTION:

  1.  ecobee was among stakeholders who participated in ENERGY’s GREEN BUTTON consultations, which the ministry held between March to July 2016.

  2.  In releasing the 2017 Long-Term Energy Plan in October, the province committed to providing more choice to consumers through information, tools and access to energy data noting that the tools and technologies that facilitate more choice will help consumers to have more control over their energy use. Government of Ontario, Ministry of Energy, October 2017, “Ontario’s Long-Term Energy Plan 2017: Delivering Fairness and Choice,” Ministry of Energy p. 98, https://www.ontario.ca/document/2017-long-term-energy-plan.

   1. ecobee strongly encourages ENERGY to include wording in the draft bill that will address the user experience to facilitate user-friendly CMD platform design outcomes

  ecobee urges ENERGY to include wording within the proposed legislative amendments that will provide for CMD customer experiences that are ultimately simple and user-friendly.  ecobee suggests that the intent behind such wording should be to ensure that electricity and natural gas utilities, as the energy providers, construct the CMD customer authorization journey in a manner that will encourage Ontario consumers to easily understand the authorization process, and complete it.

  ecobee suggests that this wording specifically require energy providers to design the CMD user experience in ways that align with ENERGY and/or Ontario Energy Board (OEB) permitted best practices.  ecobee-supported examples of industry-recognized CMD best practices include:

  - A CMD platform design that allows customers to quickly identify and access the CMD (or data sharing) authorization option;

  - A CMD user experience and standardized design that allows customers to quickly and easily authorize the sharing of their data in fewer than four steps – with ecobee’s preference being a minimum of two steps;

  - A CMD implementation policy framework and platform design that provides customers with the option to authorize third-party use of their energy data through the third party’s native application. For example, the customer journey can begin and end on the third-party’s application or website;

 - Consistency and uniformity across CMD platform architecture and design to ensure that a seamless, positive and customer-centric user experience, which aligns with the best practices referenced in the bullets above, is available to all participating customers.

  ecobee applauds ENERGY for including implementation of support documentation in its Green Button planning.  ecobee also recognizes that a Technical Working Group will inform the implementation documents.  However, the proposed legislative amendments do not explicitly articulate the importance of implementing CMD platform approaches that encourage a positive consumer experience, while also discouraging consumer abandonment.

  The use of the implementation support documentation appears to be a clear means to achieve this objective.  However, ENERGY has not included wording within the draft bill that explicitly instructs energy providers to align their implementations with the support documents (or possible services) that would be made available.  Recognizing that ENERGY may use a variety of approaches to articulate and/or direct energy providers to pursue user-friendly CMD designs, below are suggested paths:

  - ENERGY specifically address the customer experience in its regulation;

  - ENERGY include wording within the regulation that requires the OEB to incorporate user experience criteria in its evaluation of whether energy providers are compliant with the regulation’s requirements. This evaluation can be informed by or directly align with ENERGY’s implementation support documents.  Note: In this case, ecobee suggests that ENERGY take great care to capture and incorporate third party energy data recommendations within the Technical Working Group that informs this documentation.

   2. ecobee supports and favors Green Button approaches that will result in timely DMD and CMD implementations by Ontario’s electricity and natural gas utilities

  ENERGY has proposed that the OEB may to extend the time required for energy providers to comply with the regulation “as it determines is reasonable” should an energy provider seek an extension from the OEB for technical or operational reasons, or due to special circumstances.[3]  ecobee believes that this element of ENERGY’s proposal, as written, will serve to invalidate the proposed July 1, 2020 Green Button implementation deadline if it does not include clear criteria that addresses what the OEB would determine “reasonable.”

  ecobee recognizes that certain energy providers will encounter technical and operational challenges that may result in DMD and CMD delays.  However, this company finds it difficult to believe that many of Ontario’s electricity and natural gas utilities, particularly those with large customer bases, do not have the infrastructure to meet the proposed compliance deadline.  This potential for multiple utility exemptions also brings the Ontario Green Button investments and projects that have been implemented to date into question.  For example, the ministry has stated that it is seeking to procure Green Button technical consulting services to provide implementation support documents and related services.  It is also worth considering that Ontario’s energy industry will continue to have the opportunity to learn from and build on the efforts of the electricity utilities who have deployed Green Button DMD and/or CMD in the province. This includes Hydro One and London Hydro who have piloted both the DMD and CMD platforms.

  If the legislation passes, ecobee strongly encourages ENERGY and the OEB to communicate the specific criteria the OEB will use to evaluate energy provider extensions and also seek stakeholder input before it is finalized.  Additionally, ecobee suggests that any criteria used include a provision that utility extensions will not exceed a specific timeframe.

  ecobee and other third parties are offering products and services now, in Ontario and across North America, that are designed to help consumers understand, manage and make better decisions about their energy use.  Further, energy data access needs only stand to increase and expand as more complex use cases for energy management and smart devices emerge.  Considering the speed of innovation and energy management technology adoption, more third-party products and services will be available to consumers in the coming months that will require DMD and CMD to be readily available and broadly accessible.

  FOOTNOES FOR THIS SECTION:

  3. Government of Ontario Environmental Registry, Ministry of Energy “Regulatory proposal for province-wide implementation of Green Button,” November 29, 2017, https://www.ebr.gov.on.ca/ERS-WEB-External/displaynoticecontent.do?noticeId=MTMzOTk1&statusId=MjAzO DI3&language=en.

   3. ecobee favors Green Button legislation and province-wide approaches that will result in consistent and streamlined DMD and CMD implementations

  As noted above, ecobee supports consistent and streamlined DMD and CMD implementations that align with industry best practices.

  ecobee acknowledges that ENERGY’s conclusions about province-wide approaches to the Green Button implementation were informed by its related 2016 consultations and cost-benefit analyses.  Still, ecobee cautions ENERGY against wholly recommending an implementation approach that would not require an energy provider to pursue a certain implementation type.

  ecobee again strongly encourages ENERGY to articulate the importance of user experience and user-friendly best practices within the proposed legislative amendments as detailed above.  ecobee does not believe such Green Button best practices can be carried out successfully if an Ontario-wide Green Button implementation results in disparate and multiple DMD and CMD platforms and formats.  Among other possible challenges, this may require third parties to frequently adjust their operations and services to align with the different and disparate platform designs.  As noted, this can affect and diminish the end-user experience.  It can also affect the development of future products and services that depend on CMD and/or DMD data.

   4. ecobee encourages ENERGY to ensure that CMD-specific amendments reflect input and consensus from third parties on their CMD energy data needs

  ecobee encourages ENERGY to fully consider the broader data needs of third party product and service providers.  This will ensure that province-wide CMD deployments fairly and comprehensively support the variety of third party products and services that are and can be available. Accordingly, ecobee suggests ENERGY adjust and/or enhance the legislative amendments, as needed, to recognize broader and diverse DMD and CMD data requirements.  These amendments should also indicate that ENERGY will seek consensus-based third-party stakeholder input.

  ecobee does not believe that ENERGY should define “energy data” solely through what will be required to achieve the Green Button Alliance’s (GBA) CMD certification.  ecobee also generally cautions against ENERGY relying on this certification to determine what CMD data will be necessary.

  The risks to defining energy data in this manner are particularly greater now because, as of this writing, the GBA’s CMD certification has not been released.  Considering this, ecobee would suggest that ENERGY cannot know, in full, the specific data requirements that will be included in the CMD certification.  It follows that this would be the same for industry participants, including third parties, who need access to a variety of energy data such as billing and rate information.  At the very least, ecobee suggests that ENERGY ensure broader CMD data requirements are collected and vetted through the Technical Working Group it has proposed.

[Original Comment ID: 212106]