California Utilities File Plans for Provide Third Parties with Access to Customer Info

Consistent with a prior PUC decision, the large California investor-owned utilities have submitted plans to provide third-parties with access to customers' electricity usage data via the utility's backhaul, when authorized by the customer.

Pacific Gas & Electric
PG&E's Customer Data Access Project will provide third parties with access to a customers' electricity usage data via PG&E's backhaul when authorized by the customer, as required by the Commission's D.11-07-056.

The Project will use a common data format to the extent practicable and will be consistent with ongoing national standards for energy data access, including the Open Automated Data Exchange (OpenADE) Energy Service Provider Interface (ESPI) standard. The new data access services provided to customers and third parties under the Project will include "strict but streamlined" eligibility criteria to ensure that access to customer data is secure and consistent with the policies adopted in D.11-07-056, including the Commission's Rules Regarding Privacy and Security Protections for Energy Usage Data.

The Customer Data Access Project will implement an electronic customer authorization verification process that will provide affirmative confirmation from customers regarding their authorization of third parties to access their electricity usage data, including not only customer consent, but also customer specification of the scope and duration of the third party access, and the customer's ability to revoke or limit the third party access at any time. This customer authorization will be comparable to the customer consent forms and process that the Commission has required the utilities to implement in hard copy form for over twenty years under the Commission's prior customer privacy rules.

In addition to this electronic customer authorization process, PG&E recommends two other enhancements to the Commission's privacy protections under the Customer Data Access Project.

First, PG&E requests approval to implement a "modest" customer outreach and education program on an on-going basis to inform customers of how the Customer Data Access Project will work and the importance of the customer being fully aware of their privacy rights and protections before authorizing a third party to access their private electricity consumption data.

Second, in response to the Commission's guidance in D.11-07-056 regarding procedures for ensuring that third parties protect customer data from unauthorized disclosure, PG&E recommends that the Commission implement a self-certification process for third parties to certify to the Commission that they meet industry-accepted standards for protecting the security of customer information that they seek to access under the Customer Data Access Project. This "customer security self-certification" process would be administered directly by the Commission and would be modeled on similar self-certification filings that the Commission has required in other proceedings, such as the independent verification and registration requirements for direct access providers under Public Utilities Code Sections 366.5 and 394, and the self-certification requirements for compliance by non-utilities with the Commission's greenhouse gas emissions performance standard under Senate Bill (SB) 1368 and Public Utilities Code Section 8340, et seq.

PG&E Application

Southern California Edison
SCE's application proposes a technology platform that enables customer-authorized third parties to access usage data in a secure, automated manner, consistent with national standards adopted by the North American Energy Standards Board (NAESB). The proposed platform is expected to support customer authentication, a streamlined mechanism for customers to authorize third parties to receive their interval usage data, and a convenient and fast way for third parties to establish technical compatibility to interface with SCE's data exchange platform.

SCE's proposal requires a one-time authorization by the customer, and then the ongoing access of data by the designated third party will continue unless otherwise directed by the customer, the third party, or the Commission (in the exercise of its proper oversight of third parties consistent with Commission-approved tariff rules).

SCE proposes that third parties be deemed to have default "eligibility" if they successfully demonstrate technical compatibility with SCE's data transfer system, provide basic contact information, and acknowledge receipt of the Commission-approved tariff rules governing third-party access to customer usage data. However, SCE can and will reject as "ineligible" third parties under the following two conditions: (1) if the Commission, in the exercise of its oversight functions, deems that the third party should be denied the privilege of accessing customers' data usage from SCE; or (2) if SCE receives a complaint or other information causing it to suspect that the third party may have violated SCE's tariff rules regarding third-party data access and should, as a result, be suspended pending a Commission investigation.

Commission oversight should include the responsibility to communicate to the IOUs the names of any third parties it has deemed to be "ineligible" to access customer usage data, and to resolve customer and/or third-party complaints and other disputes regarding third-party access to customer data.

SCE does not propose a formal Commission-administered "registration process" for third parties as currently exists for Direct Access providers, and instead proposes that third parties with technical eligibility may obtain customer authorization to access their data unless the Commission bars the third party as ineligible

SCE expects to develop the systems necessary for this platform in 2012 (following adoption of a final decision on this Application) and the first half of 2013, and to launch the service to enable requests for usage data leveraging the platform by mid-2013.

SCE Application

San Diego Gas & Electric
SDG&E proposes to create a "registration process" to ensure that the third party that receives the data agrees to follow the Rules Regarding Privacy and Security Protections for Energy Usage Data adopted in Attachment D of the Privacy Decision.

SDG&E recommends that the CPUC be responsible for verifying the eligibility of all registered third parties who wish to participate in the backhaul service of the IOUs, as this would allow for state-wide uniformity. Moreover, when registering third parties, the CPUC can require the third parties abide by reasonable regulations, including but not limited to minimal technical, security and privacy, and customer support requirements), SDG&E said.

If approved, the backhaul program will be introduced to the public under the umbrella term "Customer Energy Network (CEN)."

The CEN was developed by SDG&E in 2009 to provide a platform to allow access by third parties to a customer‘s hourly Smart Meter energy usage data with their authorization. CEN Phase 1 took the first step by developing the authorization and access protocols for data sharing for a pilot with Google. Through the Google PowerMeter gadget, customers who sign up can view their online usage display as part of their iGoogle home page, providing the added convenience of being incorporated into a website the customer already views daily.

This project expands the capability of the CEN to add more third parties, providing additional choices to SDG&E customers who want to save energy and cost by monitoring their daily energy usage patterns online. The scope of the project will include modifying the existing CEN to accommodate multiple third party providers and expanding eligibility to include small commercial customers, customers with more than one Smart Meter installed and customers with more than one account registered within My Account. In addition, enhancements would be made to streamline the enrollment and cancellation processes and to allow for customer feedback upon cancellation so that issues can be identified and addressed."

SDG&E Application