May 23, 2016
UtilityAPI presented at the CPUC’s Data Access Workshop for Distribution Resources Plans [DRP | R. 14-08-013]. Other presenters included SCE, PG&E, SDG&E, SolarCity, Stem, Enphase, and Mission:Data. The workshop was an effort for the commission to better understand the data needs of energy technology companies. Heidi Lubin presented and took questions on behalf of UtilityAPI.
Below are excerpts from UtilityAPI’s official comments to the CPUC:
UtilityAPI recommends that regulatory bodies adopt clear standards regarding access to energy usage and billing data that will allow the market to continue to develop and evolve to meet policy targets. Lack of access to data continues to limit the growth of this sector and will preclude market ability to meet policy targets. Accordingly, we formally request that these standards be updated as detailed below. We request that the CPUC standardize the rigor and process by which authorization is granted, what login information is required to access data, what data is provided and how data is secured. UtilityAPI respectfully recommends the following:
Secure, synchronous access to comprehensive, accurate and clear energy usage and billing data is fundamental to fulfilling commitments to clean energy policy locally, nationally and globally.
Currently mandated data sharing requirements do not yet meet the needs of the DERs and other stakeholders, including utilities. Data and standard data sharing processes are crucial to fulfilling state and federal policy objectives for climate, energy affordability and economic growth targets. Lack of clarity around data sharing requirements adds cost and creates confusion as each utility has interpreted the standards for the provision of data and rolled out its data interface quite differently.
At UtilityAPI, we aim to vastly improve the exchange and flow of energy billing and usage data to facilitate the evaluation, measurement, verification and fulfillment of these efforts. We have identified, developed and market-tested best practices in the sharing and exchange of energy billing and usage data amongst utilities, utility account holders and third-parties of the utility account holders’ choosing, especially distributed energy resource (DER) providers.
To date, we have collaborated effectively with numerous utilities; specifically, we are the only third party that has built integrations with all current and scheduled Green Button Connect implementations and we are compliant with the U.S. DOE DataGuard privacy standard. We serve as a trusted data intermediary with best-in-class uptime, at a lower cost to ratepayers and with optimized user experience. We estimate savings of upwards of $2 million annually to California ratepayers because we have reduced the number of manual data requests utilities have to process.
Attention: President Picker & Commissioner Florio
Cc: Energy Division Director Ed Randolph
California Public Utilities Commission
505 Van Ness Avenue
San Francisco, CA 94102
Dear President Picker & Commissioner Florio,
We are writing in support of two proceedings currently in progress at the California Public Utilities Commission (the “CPUC”) that have the potential to significantly improve access to energy data. Decision 16-06-008 in the Commission’s Demand Response proceeding, A.14-06-001 et al, outlines the appropriate forum and timeline for planning and implementation of data access solutions. While the DRP proceeding (R. 14-08-013) has touched upon these issues, the Demand Response proceeding already ordered an implementation that should be a universal solution that would apply to all fuel types and energy programs, including, but not limited to, demand response, energy efficiency, solar, energy storage, microgrids, and building energy management. The DRP proceeding should reference this Decision and clarify that the data solutions developed should be available for purposes of distributed energy resource development in the DRP context as well.
Secure, synchronous access to comprehensive, accurate and clear energy usage and billing data is fundamental to fulfilling commitments to clean energy policy locally, nationally and globally. California has a comprehensive regulatory approach to consumer energy data access and privacy; the only state within the country, and even internationally, to do so. California led the way by adopting and supporting the Green Button standard. While significant resources were invested in the deployment advanced metering hardware in California; software and universal data standards and access protocols are needed to reap the benefit of this investment.
The growth of new energy technologies providing products and services would be greatly enhanced by standardizing the implementation of data sharing platforms to meet the needs of the market. Growth, jobs, and innovation would be faster if California, again, led the way in utility data access. The growth of new energy technologies providing products and services would be greatly enhanced by standardizing the implementation of data sharing platforms to meet the needs of the market.
We affirm our support for the guiding principles needed to improve access to energy billing and usage data:
We thank you for your efforts on behalf of the citizens of the great State of California.
On behalf of:
Appendix A: Suggested Standard Data Set for Energy Usage & Billing Data
Ideally Also: Capacity Reservation Level (CRL) for CPP/PDP customers, Demand Response program name and nomination, if fixed, Standby reservation if a customer has on-site generation, and sublap for wholesale nomination.
Appendix B: Proposed Security Standards for Data Sharing and Data Storage
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