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:
- Standardize the rigor and process by which authorization to access energy usage and billing data is granted. Utilities have implemented GB interfaces with varied interpretations; yet the market requires an industry best-practice OAuth user experience (see left) deployed to facilitate legal, secure, synchronous, authorized access to energy billing and usage data, and based on a legal third-party agency standard that meets requirements under AB1274, Civil Code Section 1798.98, U.S. DOE DataGuard best practices, and other applicable standards.
- Require utilities to redirect to or to host a cloud-based user interface for data sharing that does not require login credentials; many utility account holders would prefer to appoint a third party agent as they do not have the time, desire or comfort with online utility interfaces.
- Require utilities to provide a requisite set of data (see suggested list Appendix A, infra). The Customer Data Sharing standard should be updated to provide the requisite data set. The GreenButton Standard (GB) is a flexible, voluntary standard and implementation by CA IOUs do not meet the needs of the DERs. UtilityAPI, to date, has been the only automated and DataGuard compliance source of data that DERs require, in addition to providing a high level of service to DERs and utility account holders. Moreover, GB efforts at utilities have been incredibly underfunded which compounds the difficulty of data access, and burdens already overburdened IT departments, which are not the core competency of our hardworking utility colleagues. We are active participants in the GreenButton Alliance.
- Impose security standards for data sharing and data storage to include elements such as: U.S. DOE DataGuard compliance; secure storage of utility account holder data (see Appendix B) with DataGuard.
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.