January 22, 2018…

   January 22, 2018

  Via Electronic Submission

  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: Comments of the North American Energy Standards Board (NAESB) on the Regulatory Proposal for Province-Wide Implementation of Green Button – EBR Registry Number 013-1874

  Dear Ms. Thompson:

  The North American Energy Standards Board (NAESB) is pleased to provide these comments in response to the Regulatory Proposal for Province-Wide Implementation of Green Button issued by the Ontario Ministry of Energy (Ministry) on November 29, 2017.  NAESB appreciates the Ministry’s acknowledgement in the proposal of the NAESB REQ.21 Energy Services Provider Interface (NAESB ESPI Standard) as the bedrock standard for the Green Button and is committed to facilitating the use of the standard for electricity and natural gas utilities to implement Green Button Download My Data (DMD) and Connect My Data (CMD).

  NAESB is an American National Standards Institute (ANSI) accredited, non-profit standards development organization formed in 1994 for the purpose of developing voluntary consensus standards and model business practices that streamline the transactional processes of the natural gas and electric industries.  Over the past twenty-four years, NAESB and its predecessor organization, the Gas Industry Standards Board, have developed more than four thousand voluntary consensus standards for the energy industry with the support of the U.S. Department of Energy, the Federal Energy Regulatory Commission, the North American Electric Reliability Corporation, the National Association of Regulatory Utility Commissioners, and state utility commissions, among other government and industry entities.  The NAESB standards support the Canadian markets in numerous areas, from contracts standards and models to standards addressing the scheduling of wholesale electricity.  NAESB maintains a membership body of over three hundred corporate members who represent the wholesale gas, wholesale electric, retail gas, and retail electric markets, including the Ontario Ministry of Energy, and a volunteer base of over two thousand participants who are active in the standards development process.  All of the NAESB standards development activities, including the 2018 initiative to update the NAESB ESPI Standard, are open to any interested party despite membership within NAESB, and NAESB encourages robust participation by both members and non-members.

  Since the first ratification of the NAESB ESPI Standard by the NAESB membership in 2011, the copyright-protected XML schema contained in the appendix of the standard has been modified outside of the NAESB process to reflect various implementations of Green Button applications employed by the utility industry – one such modified version is the Derived ESPI.  As such, the Derived ESPI schema referenced in the Ministry’s proposal is not currently incorporated as part of the NAESB ESPI Standard; however, NAESB has initiated efforts at the urging of the Ministry, the Green Button Alliance, and the U.S. National Institute of Standards and Technology to work through the NAESB process to update the NAESB ESPI Standard and schema to support the interoperable data provided by Green Button applications.  This critical undertaking within NAESB will ensure consistency with and supersede the Derived ESPI.

  In early 2018, NAESB will hold a series of meetings/conference calls to embark on this effort, resulting in one comprehensive and up-to-date NAESB ESPI Standard to support the gas, electric, and water industries.  This work is done through a standards development task force and NAESB is optimistic that it can be done in an expedited manner within the first or second quarter of 2018.

 NAESB looks forward to responding to any guidance or comments provided by the Ministry and will diligently work through the NAESB standards development process to complete the update.

  Respectfully Submitted,

  Jonathan Booe, NAESB Executive Vice President and Chief Administrative Officer

  North American Energy Standards Board

 801 Travis Street, Suite 1675

 Houston, Texas 77002

 (713) 356-0060

 jbooe@naesb.org

   cc:Rae McQuade, NAESB President

 Michael Desselle, Chairman of the NAESB Board of Directors

 William P. Boswell, NAESB General Counsel

[Original Comment ID: 212175]