While Americans are focused on today’s election, today’s post looks at our northern neighbor. Ontario, Canada’s provincial regulation 633/21 calls for all electric and gas utilities in Ontario to offer Green Button Connect (GBC) by November 1, 2023. So, now that we’re one year into this policy, how are things going?
First some background. Ontario’s Green Button policy is unique in North America due to the sheer number of utilities that are involved - about 57. According to our Green Button Explorer, the USA has only 27 utilities with a GBC mandate. Thus, Ontario is a laboratory for the widest range of implementation types across North America. This variety essentially stress-tests the concept of standardization: supposedly, the regulation requires each utility to be certified by the Green Button Alliance. So our first-year review is also asking the question: Is certification working?
Mission:data has registered as a third party at a dozen Ontario utilities including Alectra, Enbridge, Hydro One and London Hydro. Our direct experience informs our analysis, the details of which are captured in the Green Button Scorecard™ (to see a specific utility’s Scorecard, go to the Green Button Explorer and click on the utility shown on the map). Due to the dynamic environment in Ontario, we attempt to make regular updates to the Scorecard as we detect bugs and issues with utilities’ implementations.
The Bad News: Utilities Are “Certified,” But…
Alectra, serving over 1 million customers, shuttered its first Green Button attempt and started over with a new Green Button vendor on October 29, 2024. The result was that (i) every customer authorization using the previous vendor was cancelled and (ii) third parties were required to start over and re-register with Alectra. Needless to say, this is a significant interruption and appears to be a violation of the Green Button regulation. In response to our questions, Alectra confirmed the above, but did not say how this disruption squares with O. Reg. 633/21.
Enbridge does not work for commercial accounts with multiple meters. Last month, Enbridge experienced “token failures” that result in requests for data returning a 403 error (“forbidden”) and other sporadic errors, such as 500 (a non-specific server error). Enbridge technical support said they “don’t have an ETA yet” for fixing the problem.
London Hydro authorizations take a very long time to process, and often it is impossible to link energy usage, which is delivered in one file, with a premise address, which is delivered in another. This is particularly challenging for commercial customers with multiple sites, and it undermines the purpose of Green Button in the first place, which is to decrease, not increase, the cost and time associated with making energy data usable. Approximately ten utilities in Ontario use London Hydro’s Green Button software, and one such utility, Niagara Peninsula Energy, is returning an error when requesting data; as of last week, a fix has not been issued.
Across the province, there was limited end-to-end testing done in our experience, because if there had been, gaps would have been identified. According to the Green Button Alliance (GBA), certification testing is done on the utility’s production system. However, changes can occur afterwards that are unknown to GBA. It is the utility’s responsibility to report any issues to GBA in order to determine if re-certification should take place. Ultimately, the Ontario Energy Board must enforce compliance on an ongoing basis, but to our knowledge, there have been no regulatory demands to any utility to re-certify.
Despite the problems mentioned above, OEB stated that all but one utility in the province have “confirmed implementations” of Green Button, leaving the casual observer with the impression that everything is fine.
University research shows energy data discrepancies of up to 10 ORDERS OF MAGNITUDE, causing confusion and impaired decision-making
The University of New Brunswick (UNB) published a white paper titled “Investigating Anomalies in Energy Data: A Case Study on Five Utilities in Ontario using Green Button and EBT Data.” The study found significant discrepancies between interval usage data obtained via Green Button and interval usage data obtained via electronic business transactions (EBT), the legacy method created about twenty years ago for retail electric suppliers. For the same electric meters and the same time period, you would think the information delivered via these two channels would be identical. But often it wasn’t: Some of the kWh measurements for the same customer in the same time interval differ by a factor of 10^10, or tens of billions. The discrepancies did not seem to follow any discernible pattern.
The obvious question is: Which source should be believed? The economic consequences of one of the sources being incorrect are severe: Either EBT is wrong, which means that the information retail suppliers use to plan their purchase needs on the wholesale market is faulty; alternatively, if Green Button is wrong, decision-making regarding energy efficiency investments is impaired, such as building retrofits. Electrification efforts will be stymied by this uncertainty.
Ultimately, trust in energy data is what’s at stake. On this point, OEB agrees with us, at least in theory. Last year, OEB told utilities that “For some customers, including those with mandated energy-based reporting requirements and those that participate in demand response or conservation programs, the use of Green Button is likely to depend on the level of trust in the data made available.” OEB stated they expect utilities to commit to “best available data” in their terms and conditions.
However, not a single Ontario utility fully complies with this provision to our knowledge. Last week, Alectra modified its terms to heavily qualify its “best available” commitments by adding caveats and preventing private court actions by third parties. (Alectra’s Scorecard has been updated.)
During the time allotted for the study, UNB was only able to study seven (7) electric accounts where Green Button and EBT data could be obtained. So it’s too early to make any sweeping statements about the success or failure of energy usage data consistency. Nevertheless, these initial results are deeply concerning. The success of Ontario’s Green Button policy will depend upon significantly more analysis, accountability and enforcement.