New York PSC requires data access with ConEd’s smart meter deployment
The New York Public Service Commission yesterday approved ConEd’s AMI business plan to deploy 3.5 million electric meters and 1.2 million gas meters through 2022, with the condition that the utility provide both HAN functionality and implement Green Button Connect. This, combined with the fact that at least hourly data will be provided without charge, represents a significant win for Mission:data companies. The Order gave substantial attention to the points we raised, as well as those of others supporting data access, such as Environmental Defense Fund and the Association for Energy Affordability.
One issue that will require us to be on guard is that ConEd still wants to charge a fee for some types of data access. ConEd asked for $15 million to implement GBC, and the utility indicated hourly data would be without charge, but the issue is not off the table for more granular data, such as 15-minute readings. The Commission’s order addresses overall implementation of AMI, but stops short of resolving the issues of what fees, if any, would be appropriate. The Commission is addressing utility revenue streams in the REV Track 2 proceeding and another pending rate case, #16-E-0060. But not to worry: Mission:data will work hard to build a coalition united against fees!
When implemented, this will expand the number of meters for which data access has been enabled to more than 28 million nation-wide.
To summarize, yesterday’s Order requires that:
Each meter will contain a Zigbee radio [p. 34]. The Commission embraced our position that “a lesson learned from other jurisdictions is that the failure to deliver clear and apparent customer benefits is a cause of criticism that surrounds many deployments of AMI.” The Order requires that AMI deployment be accompanied by “contemporaneous availability of initial applications that provide customers with an opportunity to better manage their energy use” [p. 35].
Noting Mission:data’s support, the Order directs ConEd to implement Green Button Connect, to be detailed in a customer engagement plan due July 29, 2016 [p. 41]. The Order states that customers will have access to 15-minute interval data [p. 40]. Mission:data members may recall that ConEd has committed to provide hourly data without charge, but the Order is silent on whether finer granularities would be without charge.
The customer engagement plan must also include privacy principles that incorporate opt-in consent [p. 43].
AMI must enable all customers to participate in demand response programs. This is important because it implies that “billing quality” meter data must be available to demand response providers.
Mission:data will continue to collaborate closely with EDF, AEA and others on the AMI docket at the PSC. At a minimum, we are planning to comment on the engagement plan in July to make sure the proposed privacy rules and implementation details are favorable.
ConEd provides a big endorsement of
Green Button Connect
ConEd’s position on Green Button changed dramatically over the past year, from strong resistance to strong support. Yesterday’s Commission decision was a momentous one, but it’s not as though the Commission overruled a recalcitrant ConEd and forced implemention of Green Button against its wishes. In fact, ConEd’s position had evolved so much that when the Commission ruled yesterday on the AMI plan, the decision largely assented to the utility’s position.
Here’s how it happened. In 2014 and 2015, the REV proceeding featured Track 1 and Track 2 orders that hinted at the importance of data access in reaching DER “market animation.” But ConEd still offered only Green Button Download and was silent on Connect. In October 2015, ConEd broke the silence in its AMI Business Plan, but continued to resist Green Button Connect (GBC): it would hypothetically support GBC, but only for a fee, which was not specified. ConEd said the matter needed to be resolved in the REV proceeding, not the AMI proceeding, and that no funding for GBC was included in its AMI plan. In other words, GBC wasn’t going to happen.
Mission:data fought hard: We instigated technical workshops on data access in Albany in December 2015 and January 2016. We filed a vigorous objection to the AMI plan in December 2015, highlighting the insanity of a $1.29 billion proposal that doesn’t meet the central REV objective of market animation. We also stressed that a “wait until later” approach didn’t work well in California, where GBC implementation lagged 10 years behind the approval of AMI. Supportive comments were filed by Environmental Defense Fund, the New York Energy Consumers’ Council and others.
And then ConEd’s SVP of Customer Operations laid out a strong case for GBC in testimony: it gives customers control over their data. It is a national standard. It is secure and opt-in, meaning it protects customer privacy. The testimony is worth reading: the good stuff begins on page 39, reading like a great synopsis of the arguments we’ve been making for years!
There is still more work to do, but we want to express our gratitude and shout outs to (1) our members who met with Chair Audrey Zibelman or helped explain the benefits of data access to the Commission: BrightPower, EnergyHub, EnerNOC,ThinkEco, UtiliSave, and FS Energy; (2) to Cameron Brooks who worked relentlessly to educate the Commission and successfully push for, and speak at, the workshops; and (3) to everyone who contributed to the development of Mission:data’s six rounds of comments and presentations.
The Mission:data Team