Alectra is pleased to…

Alectra is pleased to provide this submission to MENDM’s regulatory proposal for the requirement of electricity distributors to implement Green Button which contains our comments and recommendations.

We appreciate the opportunity to highlight key areas for your consideration:

1. Alectra understands that while the implementation runway put forth by the Ministry is two years, there are concerns surrounding a single-date implementation province-wide as we are aware this may place a significant strain on resources. These resources include Customer Service teams who will be fielding calls from customers setting up Green Button, as well as resolving IT issues that may arise. Alectra suggests a staggered rollout of the Green Button program in order to alleviate the potential strain on resources for LDCs across the province. This will ensure that we are able to deliver efficient customer service without long wait times for all customers using Green Button.

2. It is Alectra’s view that in order for the Green Button program to be truly beneficial to our customers, it should utilize a simple, user-friendly interface that gives customers self-serve access to their electricity consumption data. To advance the government’s objectives on red tape reduction and improving the customer experience related to Green Button, Alectra suggests that utilities will need to account for the cost to integrate “push” notifications into the platform. The ability to provide reliability reports to customers that are relevant to their individual usage patterns would also be useful. We believe that the inclusion of historical usage data would enhance the customer experience of the Green Button program.

3. Alectra understands that Green Button Connect My Data (CMD) is expected to allow customers to share their utility data with third-party applications and/or service providers. We believe that CMD should allow customers to provide explicit permission for third-party downloading of usage data. CMD should also contain a tool for revoking consent for any usage data sharing, should the customer wish to opt out at a later point in time. It would be beneficial if this can be done through the utility’s online billing portal where customers can access bills and other usage information pertaining to their own accounts.

4. Alectra believes the absence of draft regulatory language in the proposed regulation makes it challenging for stakeholders to provide feedback, particularly when the matter deals with back-end technical issues and customer privacy. Alectra suggests that MENDM allow all stakeholders the opportunity to comment on draft regulatory language regarding the Green Button implementation before they are adopted as final regulations. This would allow all stakeholders to evaluate the proposed regulation in detail, while ensuring that the topics discussed are clearly understood and cannot be misinterpreted in any way.