Delay Sought in Retail Supplier Smart Meter Data Portal due to Customer Confidentiality Concerns

The PP&L Industrial Customer Alliance has requested that PPL Electric Utilities delay implementation of the Supplier Portal Pilot, which will allow retail suppliers to access customer data without the need for an EDI transaction, pending resolution of customer information disclosure issues.

The industrials said that a recent presentation by PPL raised concerns regarding the unauthorized disclosure of customer information retained by PPL through the portal.

"Despite prior representations to the contrary, it appears that PPL's pending Supplier Portal Pilot will allow Electric Generation Suppliers ('EGSs') to access customer data in situations where a customer has exercised the right to opt-out of the Eligible Customer List ('ECL')," industrials said.

Industrials said that PPL had previously confirmed in its smart meter plan that the Supplier Portal Pilot would, "create a secure data environment wherein EGSs, and potentially other third parties, can, with appropriate customer authorization, access usage data directly without need for an EDI request and response." (emphasis by PPLICA). The industrials noted that the PUC's order on the PPL smart meter plan recognized that access to customer meter data should be provided only upon receipt of "appropriate customer authorization."

"Despite the Commission's clear guidance to the contrary, it appears that the Supplier Portal Pilot, as currently structured, may allow EGSs to access customer data without appropriate authorization. As described by PPL at the February 27, 2013 stakeholder meeting, the Supplier Portal Pilot modifies the methodology for accessing customer data. PPL's existing Electronic Data Interexchange ('EDI') technology requires PPL to affirmatively 'push' data to an EGS upon EGS request. Conversely, the proposed Supplier Portal Pilot will allow EGSs to 'pull' customer data without any further action from PPL. In discussing the mechanics of the new technology, PPL confirmed that an EGS must possess customer account information to acquire data from the Supplier Portal Pilot. Generally, EGSs may access customer account information provided through the ECL to obtain usage information from the Supplier Portal Pilot. However, if an EGS otherwise obtains customer account information, e.g. through records retained from former customers, the Supplier Portal Pilot will not otherwise restrict access to the customer's usage data," the industrials said.

"This potential for disclosure of restricted customer data violates the Commission's ECL Order and raises unacceptable privacy, financial and trade secret concerns for PPL's customers, including risking dissemination of internal business information that is considered to be proprietary and highly sensitive by some Large C&I customers. The Commission's ECL Order clearly and unambiguously states that 'all Electric Distribution Company (EDC) customers shall have the right to withhold all customer account and usage dat[a] from the Eligible Customer List that is made available to Commission-licensed Electric Generation Suppliers (EGSs),'" the industrials said.

"This determination is particularly important to the business operations of PPL's Large C&I customers. For many industrial facilities, disclosure of usage information can reveal critical and confidential operational details to competitors. This data qualifies as a trade secret that the customer has a right to protect from disclosure. Therefore, any disclosure of such information to a third-party poses unacceptable risks. As PPL's Supplier Portal Pilot may result in unauthorized disclosure of customer data to EGSs, and potentially other third-parties, it is imperative that PPL refrain from any implementation of the Supplier Portal Pilot pending resolution of the authorized disclosure concerns," the industrials said.

Docket No. M-2009-2123945