Regulatory proposal for province-wide implementation of Green Button

ERO number
019-2564
Notice type
Regulation
Posted by
Ministry of Energy
Notice stage
Decision
Decision posted
Comment period
October 8, 2020 - November 22, 2020 (45 days) Closed
Last updated

This consultation was open from:
October 8, 2020
to November 22, 2020

Decision summary

The government has established a regulation to require electricity and natural gas distributors to implement Green Button Download My Data (DMD) and Connect My Data (CMD)

Decision details

The government has established a regulation that will require Ontario’s electricity and natural gas utilities to implement Green Button Download My Data (DMD) and Connect My Data (CMD). The regulation will come into force on November 1, 2021 and will include the following requirements:

  • Utilities must implement the Green Button standard and obtain certification from the Green Button Alliance for DMD and CMD by November 1, 2023.
  • Certain utilities are exempted from this requirement (e.g. small entities without smart metering infrastructure).
  • Utilities may apply to the Ontario Energy Board (OEB) for an extension to the prescribed implementation deadline for reasons set out in the regulation.

The regulation also enables the OEB to establish certain requirements related to energy data, third-party data sharing authorization, customer privacy and utility extension requests.

Comments received

Through the registry

18

By email

0

By mail

0
View comments submitted through the registry

Effects of consultation

Comments were generally supportive of province-wide Green Button implementation. This supportive feedback included:

  • Green Button would increase transparency, innovation and choice provided to customers.
  • Green Button would help to empower customers to be in control of their energy usage while also focusing on conservation and energy efficiency.

Select comments suggested that further analysis be conducted to confirm the benefits that could be expected from Green Button implementation before proceeding with a province-wide implementation mandate. It was also suggested that Green Button could be duplicative of existing utility data analysis offerings. In considering this feedback, the Ministry of Energy (“the Ministry”) determined that Green Button would enable customers to utilize energy analysis applications regardless of what utility they are served by because customers would have access to their data in a common format. Further, utilities will be provided a two-year implementation period to incorporate Green Button into their customer offerings.

The new regulation includes certain provisions that enable the OEB to establish requirements related to Green Button implementation. Many of the comments received through this posting are relevant to the consultation the OEB initiated to implement this change for November 1, 2021. The government will work with the OEB to share the content of the feedback received for consideration as part of this consultation.

Analysis of Regulatory Impact:

Since the opportunity to access energy data in Green Button format is customer-driven, customers will need to determine whether they want to access their energy data in Green Button format or authorize a third-party application to receive this data on their behalf. This regulation does not introduce a new mandatory administrative burden on energy customers since the initiative is voluntary.

Green Button would provide Ontario electricity and natural gas customers an additional tool to help them reduce their costs, cut red tape and find efficiencies in their existing processes. A joint report completed by Mission: Data Coalition and More Than Data found that energy savings of 6-18% energy savings could be achieved when users have access to meter data, which Green Button can help enable, coupled with new technologies such as smart controls. While customers would not be compelled to interact with Green Button if they do not wish to do so, the following range of benefits would be expected following the province-wide implementation of the standard:

  • Increased conservation and energy efficiency.
  • Creation of economic development opportunities
  • Increased process efficiencies and reduced costs
  • Reduced utility customer care effort
  • Enable opportunities to streamline energy reporting and benchmarking
  • Supporting Distributed Energy Resources (DERs)

Costs associated with the implementation of Green Button, as with other OEB-approved costs that electricity and natural gas distributors incur in serving their customers, would be  anticipated to be fully recoverable by these energy utilities through rates that are included in the Delivery line of a customer’s electricity bill or the Customer Charge line of a customer’s natural gas bill. As a result, it is not anticipated there will be any direct compliance costs to utilities from this proposal, since approved costs would be recovered from ratepayers.

The Ministry completed a ratepayer impact analysis which found that, in most cases, upfront implementation costs would have a minimal impact on rates. For example, it is estimated that residential electricity customers would see an increase of between 0.06% to 0.82% in their monthly bills, while residential natural gas customers would see an increase of about 0.08%. It should be noted that these represent one-time, upfront costs that customers would incur in the year of their utility’s green button implementation and would vary depending on utility size and implementation approach. Similarly, annual maintenance costs for Green Button are also expected to have a minimal impact on rates. For example, it is estimated that residential electricity customers would see an increase of between 0.01% to 0.35% in their monthly bills, while residential natural gas customers would see an increase of about 0.03%.

Ontario’s London Hydro electricity utility implemented Green Button in 2014 and demonstrated significant benefits to local ratepayers.

Based on available information to date, the costs to implement Green Button are outweighed by the expected savings resulting from enabling consumers and small businesses more control over their own energy use.

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Original proposal

ERO number
019-2564
Notice type
Regulation
Posted by
Ministry of Energy, Northern Development and Mines
Proposal posted

Comment period

October 8, 2020 - November 22, 2020 (45 days)

Proposal details

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

DMDDMD 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.

Supporting materials

View materials in person

Important notice: Due to the ongoing COVID-19 pandemic, viewing supporting materials in person is not available at this time.

Please reach out to the Contact listed in this notice to see if alternate arrangements can be made.

Comment

Commenting is now closed.

This consultation was open from October 8, 2020
to November 22, 2020

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