Regulatory proposal for province-wide implementation of Green Button

The Ontario Ministry of Energy, Northern Development and Mines (ENDM) is considering proposing a regulation to require electricity and natural gas utilities to implement Green Button Download My Data (DMD) and Connect My Data (CMD) – together referred to as “Green Button”. To implement Green Button, these utilities would be required to procure from a third-party or develop internally a software platform; and obtain Green Button DMD and CMD certification. Green Button is a data standard that can empower households and business with access to their utility data (i.e. DMD) and allow them to authorize the automatic, secure transfer of their own data from their utility to applications or third-parties.

The proposed regulation would be brought forward under the existing legislative authority in the Electricity Act, 1998. A plain language description of the proposed regulation follows:

Definitions

Under the proposed regulation, ENDM would seek to further define terms used in the enabling legislation included in the Electricity Act, 1998. For example, ENDM would seek to further define energy as electricity and natural gas, and an energy provider as a licensed electricity distributor or natural gas distributor. For clarity, ENDM is considering further defining natural gas distributors as Enbridge Gas Inc., EPCOR Natural Gas Limited Partnership (formerly Natural Resource Gas Limited), Utilities Kitchener and Kingston Utilities. ENDM would also seek to define account holder as a person or entity who has an account with a prescribed energy provider.

Through the proposed regulation, ENDM would provide for a definition of energy data that aligns with all of the required data specified in the requirements for the DMD and CMD certification program.

Requirement to make energy data available

ENDM would propose to require that energy providers meet the requirements to be certified for Green Button DMD and CMD. At a minimum, this would mean providing account holders’ energy consumption quantities for discrete intervals directly to customers in Green Button format (DMD), while also making energy data available to third parties in Green Button format (CMD), subject to the consent of account holders.

Implementation Approach

ENDM would propose that electricity and natural gas utilities have two years to implement both DMD and CMD from the date that a regulation is enacted. Utilities would have the option of either procuring a third-party to implement Green Button on their behalf, or they could implement Green Button with existing internal resources. Utilities would also be required to obtain Green Button DMD and Green Button CMD certification (see certification requirements outlined below).

ENDM is considering different implementation approaches for smaller electricity utilities who may be challenged to meet the prescribed implementation timeline in a cost-effective manner. For smaller utilities (e.g. utilities who serve less than 25,000 customers), this could include either a longer implementation period (e.g. three years instead of two) that would provide more time to implement Green Button in a cost-effective manner, potentially in collaboration with other utilities who have already implemented the standard, or the continuation of a voluntary compliance approach.

To obtain a copy of the Green Button standard for evaluation purposes, contact the North American Energy Standards Board (NAESB) office at naesb@naesb.org or 713-356-0060. NAESB offers temporary access for evaluation purposes, or the standard can be purchased for $250 US.

Certification

ENDM would propose to require that energy providers obtain Green Button Data Custodian DMD certification and Green Button Data Custodian CMD certification through the Green Button Alliance (GBA) certification program (see link below for more information).

Customer Experience

ENDM would propose to require that utilities implement additional features not included in the Green Button standard to help reduce red tape and increase usability for Green Button users. Examples of potential features include inclusion of historical data, and requirements (e.g. a maximum number of computer ‘clicks’) that would need to be followed to make it as easy as possible for customers to obtain their data and provide authorization to third-parties to access their data on their behalf.

Exemptions

Under the proposed regulation, ENDM is considering exempting Hydro One Remotes Communities Inc., Attawapiskat Power Corporation, Fort Albany Power Corporation and Kashechewan Power Corporation from the proposed requirements due to the unique nature of their service territories and/or infrastructure.

Extensions

ENDM would propose that an energy provider could seek an extension from the OEB if there are technical or operational reasons or other special circumstances impacting the energy provider’s ability to meet the proposed requirements on time or cost-effectively.

Purpose

The purpose of the proposed regulation would be to mandate the implementation of Green Button DMD and CMD by electricity and natural gas utilities as the common standard for energy data and protocol for the secure transfer of energy data, upon authorization by the customer, to third-parties of the customer’s choice.

The province-wide implementation of Green Button would be expected to:

• Support increased conservation and energy efficiency. Greater consumer access to energy data is expected to encourage behavioural changes, such as reducing and shifting energy use, and energy efficiency retrofit improvements. In addition, allowing consumers to authorize the secure transfer of their data to a third party would facilitate the use of software and apps, making it easier for consumers to understand their energy data, and to identify opportunities for conservation and energy efficiency retrofits.
• Create economic development opportunities by fostering the development of innovative and interactive energy management software tools and apps to make the data available to customers in more engaging ways.
• Increase process efficiencies and reduce costs for consumers and third-party service providers to access energy data from electricity and natural gas utilities.
• Reduce utility customer care effort and increase conservation program efficiencies and innovations for electricity and natural gas utilities (e.g. easier access to data to conduct audits and evaluate programs; innovations to existing programs based on increased consumer access to data).
• Support energy reporting and benchmarking by removing barriers and reducing effort/cost for consumers who need access to their data to comply with O. Reg. 506/18 and O. Reg. 507/18 under the Electricity Act, 1998, which require large building owners and the broader public sector, respectively, to report annually on the energy consumption of their buildings. Because the energy data would be in a common format, software tools and apps could support the aggregation of data for multiple energy accounts, facilitating building-level reporting for multi-metered properties.