RE:  EBR Registry Number…

   RE:  EBR Registry Number 013-1874: Proposal for Province-Wide Implementation of Green Button

  The Electricity Distributors Association (EDA) supports the 2017 Long-Term Energy Plan’s emphasis on strengthening Ontario’s commitment to energy conservation and efficiency. EDA's submission concerns empowering customers to access data and tools, such as Green Button, and to support decision making on conservation and efficiency. LDCs strive to improve customer choice by providing them with access to the data they need to make informed decisions around energy management and conservation.

  A number of LDCs have already successfully implemented Green Button Download My Data (DMD) and, albeit to a lesser extent, Connect My Data (CMD) or have undertaken other processes to make data accessible to customers.  These LDCs can help provide lessons learned as Ontario moves forward with province-wide implementation of Green Button.

  The EDA offers the recommendations below in response to the above named regulatory posting.

  Certification of Third Parties and Third Party Applications

  The EDA recommends the Ministry consider extending the Green Button certification requirements for CMD outlined in the regulatory posting to third parties. Certification of third parties should also include privacy and security requirements associated with customer data. This will support province-wide implementation using a consistent standard, ensure compliance with the Green Button CMD standard and provide customers with a ‘seal of approval’ that all participants, including third parties, are adhering to privacy and data protection practices.  Certification on the platform side can also address potential security and privacy concerns. We understand that Green Button Alliance intends to make available a third-party CMD certification process; the EDA would be interested in following-up on this recommendation with the Ministry.

  Support for Implementation Flexibility

  The EDA supports the Ministry’s proposal to allow LDCs flexibility to choose the most cost-effective implementation option to meet the requirements of this posting (i.e. to choose to enter into a procurement process, contract or arrangement to acquire, use or develop a software platform etc.) rather than mandating a specific implementation.

 Providing LDCs flexibility on how to implement and allowing LDCs to own their processes will be important as this initiative moves forward.  Leveraging the people, investments and processes in place currently at respective utilities will be essential to advancing customer driven solutions related to Green Button.

  The EDA notes however that in the context of having various LDC deployments, clarity will be needed on how to approach situations when a customer who spans multiple LDC territories requests information in a standard and aggregated way.

  Interpretation of the Green Button Standard

  The EDA supports the government’s intention to provide documentation of an Ontario-specific interpretation of the “Derived ESPI Implementation” standard and recommends that any future updates to the standard be coordinated across all utilities, registered third parties and other affected stakeholders. A common application of the published standard is expected to avoid various interpretations, and associated conflicts.

  Cybersecurity Considerations

  The EDA understands that Green Button incorporates security by design and enables data sharing (e.g., between consumers and app developers, consumers and solution providers) in a secure and privacy-enabled way. The EDA recommends that the Ministry review the alignment between this initiative and the OEB’s Cyber Security Framework.

  Cost-Recovery

  Green Button CMD and DMD deployment will support a range of service offerings from LDCs to customers.

  LDCs will incur one-time and ongoing costs to implement Green Button CMD and DMD. The provision of information, whether through Green Button or other means, is an ongoing service whose costs should be eligible for recovery.  The EDA specifically recommends that the OEB set LDC rates on an individualized basis and not apply a default or baseline rate.

  The EDA emphasizes that costs will be incurred prior to re-basing and are expected to be eligible for recovery.  The EDA proposes that the OEB authorize a deferral account to record all Green Button costs.  This will be an important consideration moving forward given recent and prospective merger activities. The EDA acknowledges that the deferral account must be designed appropriately and looks forward to working collaboratively with all affected stakeholders in a timely manner.

  The EDA further reinforces that the costs of all cost-effective deployments should be eligible for recovery through rates. This would also be consistent with LDCs being provided the flexibility to choose the method of implementing Green Button CMD and DMD.  All costs related to implementation, including communications and consumer education related costs, should be eligible for recovery.

  Extensions

  The EDA supports the Ministry’s proposal that the OEB may extend the time period for when an energy provider would be required to comply with the proposed requirements and that an LDC could also seek an extension for technical, operational or other reasons. There is little value in meeting a prescribed deadline if consumers will be frustrated or consider the information provided unsuitable. The EDA requests that the Ministry/OEB clarify the requirements for requesting an extension.

  The EDA recommends that the process for requesting extensions be simplified and that requests be processed in a reasonable, fair and balanced way.

  Timeline

  The EDA notes that the Ministry is proposing a deadline of July 1, 2020 for utility implementation of Green Button.

  The EDA emphasizes that LDCs have differing abilities to implement the technical changes that fulfill this regulatory posting by the provided timeline.  For example, LDCs acting on planned system changes (e.g., to billing systems), that are undergoing or have planned mergers or that lack automated processes may require extensions.

  The EDA would also ask the Ministry to take into consideration the following when finalizing decisions on timing:

 •Timing of technical working groups and guidance documents:  The implementation guidance that will be prepared and disseminated by the Ministry of Energy will be vital for LDCs to move forward with internal planning processes.

 •Time associated with LDCs assessing the most cost-effective implementation method: To assess which implementation method to move forward with, LDCs will likely conduct cost-benefit analysis and may have discussions with other LDCs to inquire about potential collaboration options. •Compliance with other requirements and how this might impact an LDC’s implementation timeline: For example, as of August 21, 2020, the OEB is requiring interval meters to be installed for all larger business customers. Complying with this transition might be a necessary first step for some LDCs before they integrate all aspects of Green Button CMD.

 •Customer classes: There are a number of LDCs that store each class of customer data in different repositories; meaning that different interfaces for each will need to be updated and revised to facilitate Green Button functionality.  This may cause delays and inhibit an LDC’s ability to implement by the proposed deadline.

 Ongoing Implementation Support and Maintenance Activities

  The EDA is pleased that the Ministry will establish technical working groups to support and inform the development of implementation documents and that the working groups will be comprised of utility staff members. The EDA recommends that guidance documents provide clarity on the following:

 •step-by-step guidance on how to implement both Green Button DMD and CMD;

 •guidance on implementation among various customer classes;

 •an outline of the various implementation options and potential risks, opportunities and cost considerations associated with each;

 •guidance as to the type/form of customer authorization that will be needed and how best to ensure customer privacy is protected; and

 •guidance on marketing and customer education on Green Button.

  The EDA notes that beyond the development of implementation documents, it will be important for utilities to have ongoing access to guidance and support (e.g., for implementation, maintenance activities). The EDA seeks to clarify the entity, or entities, who will be responsible for providing this ongoing support. The EDA recommends that an industry led forum, whose members are drawn from all the affected stakeholders and form a representative sample of the affected stakeholders, may be suitable. Such a forum could also act as an Ontario body of knowledge on Green Button and maintain a link with the technical working groups.

  The EDA also understands that the Ministry will be developing an umbrella committee and would welcome the opportunity to participate to represent LDC needs moving forward.

  The EDA also reinforces the importance of utilities having a contact at the Ministry who can answer questions related to Green Button CDM and DMD and thereby facilitate the implementation of the regulatory requirements.

  Communications & Education

  A broad government led consumer education strategy on Green Button CMD and DMD will be an important component in the roll out of the initiative. It will inform customers of the initiative and how they can use their data in innovative ways.  Local utility outreach will be necessary to educate customers about what’s available and ensuring they are fully aware of their privacy rights. Provincial educational efforts should emphasize that utilities are a gateway for innovation. LDCs’ educational efforts will include educating their customer service departments to deliver key messages and to answer common customer questions.  The EDA recommends that the Ministry distribute communication support tools to utilities such as key message documents and Q & As or FAQs. Communications should also clarify that LDCs are not liable for third party applications or privacy and security of customers’ data within third party applications; LDCs should be held harmless of any indemnification issues.

  Sharing Lessons Learned

  The Ministry should consider continuing to host events and webinars for utilities to share lessons learned from Green Button DMD and CMD pilots, to review the various requirements of the Green Button standard, to offer guidance on various implementation options and to continue to share the work of the earlier Energy Data Access Working Group. Hosting such initiatives in the near term, while documents are being drafted, can provide utilities with the clarifications they need to confidently move forward with implementation decisions.

  The engagement and webinars provided to date have been well received and provided valuable information to utilities. The EDA would be happy to assist in facilitating such initiatives.

  Additional Considerations

  Energy, Water, Reporting and Benchmarking (EWRB)

  The EDA notes that the Green Button initiative has the potential to support compliance with the energy and water reporting requirements applicable to large buildings that are set out in O. Reg. 20/17.  A number of LDCs are already preparing and testing internal processes to be able to respond to building owner’s requests for energy consumption data (e.g., developing dashboards on their websites). Although some of these initiatives will be compatible with Green Button, it is important for LDCs to avoid, or minimize, duplicative processes or additional infrastructure. As Green Button will be a standard, utilities should be provided guidance on how Green Button can interact with EWRB, to achieve cost-efficiencies in providing information to consumers.

  Supporting Distributed Energy Resources (DERs)

  With investments being made to make Green Button CMD and DMD a standard, the province should have a strategic and long-term view of how such initiatives can also support a broader DER strategy in the province. This can include considering how Green Button may support policy innovations such as virtual net metering, how existing conservation programs can be enhanced or how to support customers in their efforts to reduce greenhouse gas emissions (for example utilizing Green Button to reward and incentivize customers that use cleaner energy). Green Button can also set the stage for LDCs to offer additional value-added behind-the-meter services to customers through processes like using cloud computing for real time data and analytics behind the meter.  All these solutions can be identified by LDCs and LDCs can support and further these innovations by providing accurate data in a timely manner.  LDCs are increasingly improving their ability to analyze data and to use cutting-edge technologies to modernize the grid. LDCs will increasingly play in the space of using data and analytics to improve customer offerings.

  The EDA looks forward to working with the Ministry to help advance the implementation of Green Button province-wide while ensuring LDCs have the supports in place to assist in this transition.

  Again, thank you for your consideration.

[Original Comment ID: 212186]