Earlier this month, the California investor-owned utilities (IOUs) filed with the Public Utilities Commission (CPUC) their plans for implementing a Green Button API. Also known by the mouthful of acronyms Open Automated Data Exchange (OpenADE) and the Energy Services Provider Interface (ESPI), the March 5th filings demonstrate that California is forward-thinking in engaging third party software providers such as Lucid to promote energy efficiency. But the filings also reveal painful bureaucratic hurdles in the utility regulatory process that are a drag on progress.
First some background. Last fall, the White House challenged utilities to provide energy consumption data in a portable, machine-readable format through a “Green Button.” Since then, numerous utilities including the California IOUs have signed on to the initiative. Today the White House announced nine new utility supporters, including NSTAR (Boston), ComEd (Chicago), PECO (Philadelphia) and Baltimore Gas & Electric, among others. Primarily focused on the residential sector, the Green Button allows homeowners to download their consumption history in an XML format and then upload that file to third party service providers.
We at Lucid have been supporters of Green Button from the beginning, although we have emphasized the importance of commercial customers in addition to residential. (Pacific Gas & Electric, for instance, implemented the Green Button for small and medium commercial ratepayers.) Downloading your data in a portable, standardized format is a big step in the right direction, but it still requires a manual process. The next logical step is the automated transmission of energy data to third parties at the customer’s request. Enter the Green Button API.
Proponents of liberating data from utilities such as Lucid have long waited for the day in which customers have access to a wide array of simple, low-cost energy management tools at the click of a button. In California, the IOUs’ recent filings indicate that we could have such a system as early as mid-2013. But there’s a catch: It’s going to cost money, it could take one year (!) to get CPUC approval, and it’s unclear when, after approval, the data will finally start flowing.
Proposed oversight of third parties
Self-certification of vendors, presumably by mailing signed paperwork to CPUC similar to Direct Access Minimal. Third parties would simply register at SCE website and agree to certain privacy and security provisions; however, CPUC could terminate connections due to complaints or violations. Led by CPUC; registration process to ensure compliance with privacy and security guidelines (Attachment D of CPUC decision D-11-07-056).
My first reaction was sticker shock upon seeing the price tag: $19.4 million for PG&E and $9.1 million for SCE. That seems very high, since PG&E implemented Green Button voluntarily last fall in 90 days, seemingly with little difficulty. PG&E, evidently, is keen to convince the regulators that the extra burden of adding an API on top of the pre-existing Green Button data is worthy of an eight-figure wad of cash. Meanwhile, SDG&E asks nothing of the ratepayers to implement the API. [6/12/2012 update: SDG&E is not requesting additional funds under this proceeding; apparently, its Green Button Connect implementation is to be funded under a pre-existing tariff increase.]
Also of note is that the CPUC has signaled that it might begin to regulate software companies who access energy data through the Green Button API. The CPUC has the undisputed authority to regulate the IOUs and force them to abide by certain privacy and information security policies. However, when energy data begins to change hands, CPUC jurisdiction becomes murky. Although the CPUC’s ruling last July (D-11-07-056) punted on the question of jurisdiction, the CPUC asked the IOUs to propose a system of oversight in their recent filings. SCE proposes minimal oversight, whereas SDG&E wants a full-blown third-party registration system administered by the CPUC.
We believe that implementing the Green Button API is among the most powerful steps a utility can take to enable conservation efforts. With many other utilities across the country taking California’s lead, it is all the more important that we succeed in implementing the Green Button API inexpensively and without incident.Stay tuned as we provide feedback to the CPUC on this issue and track its development on our blog.