Friday, March 5, 2010

Christine Hertzog: Consumers Must Opt-In (or Not)

Thank you for requesting comments.

The question about who owns home energy usage data should be reframed to ask who owns home energy production or consumption data to accommodate the growing number of residential ratepayers who produce as well as consume energy. Regardless of production or consumption classification, the consumer owns the data. The consumer authorizes 3rd party service providers to access data. As a side note, a similar set of questions should be posed about EV/PHEV charging/discharging transactions, data ownership, and privacy.

2. Yes, consumers and authorized 3rd party service providers have the right to access energy usage data directly from the meter, but it should not interfere with the ability to collect all data needed to accurately account for home production and consumption of energy. However, this should not be the only information gateway for production/consumption data.

3. Yes, it is technically feasible, but as noted above I would not presume that it is the primary gateway for obtaining data. If I am a consumer and I am using a Home Energy Management system solution with a web portal, that would be my primary interface for accessing meter data.

4.There are several actions that can be taken to build and maintain consumer confidence:
a. Require that transmission of home production and consumption data does not include any personally identifiable information
b. Require that all meter data be encrypted from meter to utility or from meter to 3rd party
c. Require that utilities and 3rd party service providers notify consumers of any unauthorized breaches of consumer information (personally identifiable information or production/consumption data) – similar to the notification that credit card companies must provide.
d. Require that energy service providers and 3rd party service providers apply Payment Card Industry Security Standards to consumer energy data in their possession.
e. Require that all consumer production/consumption data, with the exception of what is necessary for energy services billing, be managed on an opt-in basis. ChristineHertzog 2010-03-05

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