Activities index
Activities index
Data PORTABILITY Policies
U.S. Department of Energy
Rebates: DOE issued a Request for Information (RFI) about how it should structure rebate programs from the Inflation Reduction Act’s $4.3 billion Home Energy Performance-Based, Whole-Home Rebates (HOMES) and $4.5 billion High-Efficiency Electric Home Rebate Program (HEEHRP). See our response in which we urge DOE to quickly adopt data access guidelines and to focus on two efforts in parallel: Aggregated energy usage (and savings) reports, and permission-based usage data exchanges.
Grants: On November 18, 2022, the Department of Energy (DOE) issued a Funding Opportunity Announcement (FOA) for $3.9 billion. According to the FOA, “DOE will require that projects support data standards (e.g., Green Button Connect), interoperability, and non-discriminatory data access on a real-time basis.” Congress appropriated funding for three (3) areas under the Infrastructure Investment and Jobs Act (IIJA); “Smart Grid Grants” (Section 40107), totaling $1.08 billion, are contingent upon utilities offering data portability. See our data portability guidelines, which satisfy the Inflation Reduction Act’s provisions that “The Secretary [of Energy] shall develop and publish guidelines for States relating to residential electric and natural gas energy data sharing.”
DataGuard: There is also DOE’s DataGuard privacy program. Due to there no longer being accessible on DOE’s website, we have published DataGuard here.
Webinars
Got Data? Experts in Energy, Finance and Healthcare Show How Data Access is Done
We dissect Blue Button, Green Button and Open Banking. Led by Steven Boms, Executive Director of FDATA North America (an advocate for open banking) and Ryan Howells, Principal of the CARIN Alliance (an advocate for patient-directed healthcare data exchange), we offer insights from leaders in the cleanweb, fintech and healthcare industries on the policies and practices that make data portability work for consumers. View the recording.
Our STATE-LEVEL Activities:
Arizona, with some smart meters installed, is examining its rules for utilities governing customer information in light of privacy and confidentiality concerns related to smart meters.
California, an early adopter of smart meters, has addressed both the Home Area Network (HAN) and Green Button Connect.
2015 Energy Efficiency Investment Proposals (Phase 1) - Comments on R.13-11-005 (April 7th, 2014)
Protest to Advice Letters on Customer Data Access (April 7th, 2014), aka Green Button Connect - in response to program details filed by PG&E, SCE and SDG&E.
The utilities respond to the protest - PG&E, SCE and SDG&E. PG&E has a much better response, addressing revenue quality of the data by using the "quality of reading" flag.
Distribution Resource Plans (Public Utilities Code Section 769):
Opening comments in R.14-08-013 (Sept 5th, 2014)
Comments regarding DRP draft guidelines (Dec 12th, 2014)
Response to ALJ's data request (May 13th, 2016)
Presentation at Data Access workshop at CPUC (May 23rd, 2016)
Comments regarding Cmr. Picker's proposal for addressing Track 3 issues (Aug 22nd, 2016)
Protest to Advice Letters on AB793 implementation (Aug 29th, 2016)
The utilities respond to the protest - PG&E, SCE, SDG&E and SoCal Gas
Demand Response Click-through Working Group
Informal report of IOUs, DR parties and Mission:data (Oct 12th, 2016)
Energy Division guidance on Nov 1st tariff filing (Oct 18th, 2016)
Draft Resolution E-4828 Click-Through Authorization Process (Jul 11, 2017)
Colorado has approved AMI, but on December 23, 2020, Mission:data filed a motion to re-open the Advanced Grid Infrastructure and Security (“AGIS”) case regarding advanced metering infrastructure and the Home Area Network (“HAN”) case, in order to address “distributed intelligence” capabilities of smart meters and fair competition. On February 28, 2022, the parties filed a unanimous settlement agreement.
Smart metering application. Xcel filed application 16A-0588E for $562 million of smart meters, voltage optimization and other grid modernization components.
Settlement agreement with Xcel, in which Xcel states it will offer Green Button Connect in 2020, as 1.5 million smart meters are to be deployed (May 8, 2017)
Rulemaking (2014-2015).
Following our informal comments on 7/11/2014 regarding consent forms (e.g., we supported an electronic option and elimination of an archaic requirement for a Colorado address for process serving), Mission:data supported third party access and streamlined consent (Sept 15th, 2014)
Mission:data comments on Xcel's application #15A-0789E regarding data access and privacy (Nov 5th, 2015)
Settlement agreement with Xcel, in which Xcel states Green Button Connect would cost only $1.5M-$2.0M to implement (Apr 22nd, 2016), and the Motion to Approve Settlement (Apr 22nd, 2016)
Illinois, with seven million smart meters currently being deployed, was petitioned by the Citizens' Utility Board (CUB) and Environmental Defense Fund (EDF) to open on a docket on a so-called Open Data Access Framework.
Customer Authorization Process (ICC Docket No. 15-0073):
Mission:data initial comments on the customer authorization process (March 9th, 2015)
Reply comments on the authorization process (April 20th, 2015)
Sur-reply comments on the authorization process (May 4th, 2015)
Final comments on the authorization process (June 24th, 2015)
The ICC issued its Proposed Order (Dec 23rd, 2015). Mission:data filed a Brief on Exceptions (Jan 15th, 2016), and a Reply to Briefs on Exception (Jan 26th, 2016).
The ICC issued its Final Order (Mar 23rd, 2016), and an Amendatory Order clarifying that certain terms and conditions do not apply to small business customers (May 10th, 2016)
Workshop presentation on streamlining the authorization process (Aug 16th, 2016)
Maryland began Public Conference 44 on "transforming Maryland's electric distribution systems to ensure that electric service is customer-centered, affordable, reliable and environmentally sustainable in Maryland."
Mission:data comments on maximizing AMI's benefits for Maryland ratepayers (Oct 28th, 2016)
Massachusetts's Department of Public Utilities (DPU) is proposing to require utilities to develop grid modernization plans that "achieve advanced metering functionality" within 3 years. The DPU proposes to address in a separate proceeding, timing TBD, "privacy and access to meter data" (p.4).
Mission:data comments highlighting how data access will help achieve the Department's goals (Jan 17th, 2014).
Michigan has pursued AMI. Mission:data filed comments on DTE Electric Company's report on education, marketing and outreach regarding time-of-use rates (Dec 18th, 2015)
Mission:data comments on proposed consumer standards and billing practice rule, Case No. U-18120 (Oct 13th, 2016)
Minnesota has a grid modernization proceeding (E999/CI-15-556):
Mission:data initial comments on the customer energy usage data working group second report (Sep 16th, 2016)
New Hampshire passed SB284 in 2019 requiring the PUC to consider a state-wide, multi-use energy data platform.
Approval of settlement agreement by the NHPUC (March 2nd, 2022)
New York's historic "Reforming the Energy Vision" (REV) proceeding is wide-ranging. In seeking to promote distributed energy resources, REV presents an opportunity for highlighting the role of data access in streamlining transactions and supporting low-cost efficiency.
Mission:data informal comments to NY PSC's Consumer Advocate regarding the consumer benefits of data access (June 13, 2014)
Mission:data comments to the Commission regarding Track 1 issues (July 18th, 2014)
Mission:data comments on staff's Straw Proposal on Track 1 issues (Sept 22nd, 2014)
Mission:data comments on Track Two staff whitepaper (Oct 26th, 2015)
Mission:data comments on Distributed System Implementation Plan Guidance (Dec 7, 2015)
NY PSC issues its REV Track 2 Order that prohibits the utilities from charging fees to access meter data (May 19th, 2016)
Con Edison "Customer engagement plan" (Jun 2nd, 2016), revised customer engagement plan (July 15, 2016)
Mission:data comments on utilities' initial Distributed System Implementation Plans (DSIPs) in Case 16-M-0411 (Sept 12th, 2016)
Joint Principles on Residential Fixed Charges in New York (Sept 27, 2017), endorsed by Mission:data
Reply comments of Mission:data and Advanced Energy Management Alliance on PSEG Long Island's "Utility 2.0" Annual Update (Nov 1st, 2017)
North Carolina's utilities - Duke Progress, Duke Carolinas and Dominion North Carolina Power filed smart grid deployment plans on October 1st, 2014 in docket E-100, sub 141 per Commission Rule R8-60.1, "Smart Grid Technology Plan."
Pennsylvania has about 7 million smart meters. Like Illinois, retail electric generation suppliers (EGSs) need access to their customers' meter information. Act 129, passed by the state legislature in 2008, states that smart meter information must be available not only to EGSs but also to third parties authorized by the customer.
Texas's Smart Meter Texas website allows (in theory) any user with a smart meter (virtually all residential, and the majority of commercial customers) to view their 24-hour lagged meter data. Third party access has been challenging due to poor technical support of SMT. The Commission investigated these issues (but did not make any ruling) in Project #42786. Subsequently, two dockets were created that will result in rulings: Project #46206, "Rulemaking regarding governance, performance and funding of Smart Meter Texas" and Project #46204, "Rulemaking regarding third party authorization to access Smart Meter Texas data."
The PUC solicited input Smart Meter Texas governance; Mission:data responded (Oct 8th, 2014).
Staff requested price quotes on five different scenarios for SMT operations. ERCOT and the Joint Development Operating Agreement (JDOA) utilities responded. Mission:data replied with comments that, regardless of governance, SMT's technical shortfalls must be remedied (April 1st, 2016).
Presentations at the Joint RMS/WMS Workshop at ERCOT (July 24th, 2015)
Presentations at the Joint RMS/WMS Workshop at ERCOT (Oct 16th, 2015)
Project #46206, Mission:data comments on staff straw proposal (Nov 4th, 2016)
Project #46206, Mission:data reply comments on staff straw proposal (Nov 18th, 2016)
Also, Entergy Texas, Inc. (ETI) applied for cost recovery of 477,000 advanced meters in its non-ERCOT territory in #47416.
Washington, D.C., with 100% penetration of advanced meters, has a grid modernization proceeding (Formal Case No. 1130). Mission:data filed comments on data-driven energy efficiency and how companies can make the electric grid more "interactive." (Aug 31st, 2015)
NARUC: Nov 18th, 2014 (San Francisco). Panel discussion with CPUC staff and members EnerNOC (1.6MB PDF), Lucid (2MB PDF), Bidgely (4.6MB PDF).