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Texas Stakeholders Agree On New Process For Third Party Providers To Access Smart Meter Texas Customer Data

Intended To Simplify Process For Third Parties To Access Customer Data

January 30, 2018

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

Stakeholders have reached, except for one issue saved for litigation, consensus for new requirements for Smart Meter Texas (SMT), including a new process by which a customer affirms an agreement to share its SMT data with a Competitive Service Provider ("CSP", an entity other than the REP of Record).

The stipulation was signed by Texas PUC Staff, the TDUs, several REP groups, and several non-LSE energy service providers and no party has registered opposition to the stipulation.

Under this new process for providing CSPs with access to SMT, the customer will no longer be required to establish an SMT account before being able to share his or her SMT data with a CSP. "This change is intended to simplify the process by which a customer can grant access to its SMT data to CSPs," the stipulation states

The one remaining issue that was not resolved in the stipulation is whether SMT should allow a Residential Customer or a Business Customer that is not a Large Business Customer to grant a CSP access to the customer's SMT data for a term longer than 12 months.

The new process for CSPs to access SMT data includes new customer authorization requirements.

Under such process, required customer authentication information for CSP access and/or customer account creation shall include the Electric Service Identifier ID ("ESI ID"), meter number, and REP of Record ("ROR") certificate number. The required ROR certificate number and name will be provided in a drop-down list for customers and CSPs on the Graphical User Interface.

A CSP seeking access to customer data must send the authentication information specified above to SMT, and SMT will then authenticate the premises based on the information provided.

The CSP must provide the email address of the customer to SMT for initial customer affirmation of a data sharing agreement between the customer and the CSP and for renewals of that agreement.

The customer affirmation process is as follows:

a. The customer will receive an email from SMT with a request to affirm the customer's agreement to share data with a CSP for a specified term.

b. The customer shall acknowledge the required SMT customer disclosures.

c. Large Commercial Customers (identified as commercial customers whose maximum monthly kWh for the prior 12 months meets or exceeds 15,000 kWh) may agree to a term for data sharing up to 36 months, which shall be renewable for an additional term equal to the original term (renewal to occur via an affirmative email consent accomplished through one click by the customer, with no additional verification required).

d. All customers shall affirmatively opt-in to sharing data with a CSP.

e. The customer shall have the options to opt-out or report the email as spam.

f. The customer affirmation email link shall time out in five weekdays.

g. The opt-in email confirmation shall be subject to machine language protection technology.

SMT shall authenticate required customer information and retain records of all customer affirmations

The customer will not be required to establish an SMT account in order to authorize CSP data sharing. The customer may create an account on SMT to access its own data or to terminate an agreement with a CSP.

To prevent abuse of the process, criteria shall be established for monitoring CSP agreements, including, at a minimum:

a. monitoring unique IP addresses to eliminate mass enrollments/acknowledgments by a CSP;

b. monitoring rejections, including differentiating between a customer's failure to acknowledge an authorization and a customer affirmatively rejecting authorization;

c. ongoing controls regarding inappropriate behavior; and

d. monitoring attempts by CSPs to authenticate customer information.

The SMT Management Committee shall immediately suspend or revoke data access based upon Commission approved standards of "red flag" behaviors. The SMT Management Committee shall notify a CSP of its suspension, but not revocation, based on information provided in the CSP's registration with SMT. Examples of potential "red flag" behaviors include, but are not limited to, the following:

a. interfering with or falsifying customer affirmation;

b. receiving customer data that has not been authorized by the customer;

c. falsifying IP addresses;

d. failure to terminate data access at customer direction or customer termination;

e. sharing, selling or distributing customer data without customer authorization; and

f. modifying or altering customer data.

The Commission may direct the SMT Management Committee by and through Oncor, CenterPoint Energy Houston Electric, AEP Texas, or TNMP to suspend or terminate a CSP's access to SMT after notice and appropriate Commission procedure.

Most parties favored a 12-month limit on residential and non-large business customer authorizations for CSPs to access their SMT data. Texas PUC Staff favored such a limit as part of the stipulation, which represented a holistic compromise. Several REP groups and OPUC also favor a 12-month limit for such customers

Brasovan Energy's Electricity Users Coalition favors allowing, for all customer sizes, a CSP's authorization for access to a customer's meter data to last for up to 36 months.

Docket 47472

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