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Texas PUC Staff Raises Cost Concerns On Use Of Green Button Connect My Data For Third Party Access To Customer Smart Meter Data, Stresses Privacy In Discussing Alternative LOA Process

November 15, 2017

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Copyright 2010-17 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com

Staff of the Public Utility Commission of Texas filed a statement of position regarding a review of the Smart Meter Texas (SMT) portal, including third-party (non-REP of record) access to customer data

Staff noted that, currently, in order for a competitive service provider (CSP) [e.g. not the REP of record] to obtain a customer's meter data directly from SMT, the customer must follow a six-step process to retrieve an Account Authorization Code and provide that code to the CSP.

"However, it may be possible for the Commission to streamline this process," Staff noted

As an initial matter, Staff supports the continuation of existing functionality for customers' meter data to be maintained and transmitted consistent with the Green Button data format standards. Currently, SMT has deployed a non-standard implementation of the Green Button Download My Data standard, which allows a customer to download the customer's own meter data in a specified data format. Staff intends to support allowing CSPs to access meter data in the Green Button standardized format directly from SMT once the CSPs have obtained appropriate authorizations.

"However, Staff continues to evaluate the best means by which CSPs should obtain authorization to access this data," Staff said

"Green Button Connect My Data (GBC) may be a good method for CSPs to obtain customers meter data directly from SMT, but Staff is concerned with and continues to evaluate whether GBC is cost-effective and feasible to implement," Staff said

GBC is an industry standard that provides (1) a standardized format for the collection of electricity consumption data, (2) a common interface for the exchange of this data, and (3) a method to securely authorize a third-party's access to customer usage information.

GBC includes a standard method for customer authentication and a method for customers to grant authorization for SMT to share a customer's meter data with a CSP.

Staff noted that, "The direct testimony of Mission:data witness Michael Murray describes an implementation of the GBC standard in which a customer who has accessed a CSP's website can be automatically forwarded to SMT's website for customer authentication and authorization, after which the customer is automatically returned to the CSP's website to continue the enrollment process. Mr. Murray also describes a workflow in which a customer is able to authenticate the customer's identity and authorize access to the customer's meter data using only the CSP's website, meaning the customer would not be forwarded to SMT's website as an intermediary step. Staff believes it is likely that the former workflow will be superior to the latter workflow."

"However, Staff remains concerned regarding whether GBC will be feasible and cost-effective to implement. As Office of Public Utility Counsel witness Michele Gregg notes, the costs to date for SMT have been significant, and these costs are recovered only from customer classes eligible for deployment of Advanced Metering System meters. As a result, Staff intends to closely monitor the evidence admitted in this proceeding, including reviewing parties rebuttal testimony, to see if these concerns can be resolved sufficiently for Staff to recommend the implementation of GBC for the purpose of authenticating CSPs to access customers' meter data," Staff said

Staff further said that, "If GBC's automated authentication standard is not cost-effective or feasible to implement, Staff notes several parties have supported the extension of the existing LOA [letter of authorization] process, in which third-parties certify that they have obtained an LOA from the customer. For example, Joint Transmission and Distribution Utilities witness Donny R. Helm supports allowing CSPs to use an LOA to obtain the ability to access customers' meter data, but Mr. Helm testifies that CSPs should be required to register with and be overseen by the Commission in order to take advantage of the LOA process. Similarly, ENGIE Resources LLC witness Ray Cunningham supports modifying business requirement no. 22 so that a proposed LOA process would be available to CSPs as well as retail electric providers. However, under Mr. Cunningham's proposal, a CSP would merely be required to check an online box which represents and warrants that the CSP has obtained the customer's consent to access the customer's meter data."

"Customer privacy is an extremely important consideration in this proceeding, and Staff does not intend to support any party's proposed modification to the existing business requirement that would impair customer privacy and protections. Staff's understanding is that the GBC authentication workflow, as described by Mr. Murray, may provide superior customer privacy protections compared to some proposals using an LOA process. Staff continues to evaluate this issue, and Staff does not know at this time whether it will support GBC, an LOA-only process, or a combination of GBC and the use of LOAs for authenticating access to SMT. Staff will continue to evaluate these proposals based on the evidence that is admitted in this proceeding," Staff said

Docket 47472

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