As the statutory representative of District of Columbia ratepayers and consumers, the Office of the People’s Counsel for the District of Columbia (“OPC” or “Office”) respectfully files these comments before the Office of Science and Technology Policy to address questions 4 and 5 posed by the Office of Science and Technology Policy.
4. a) Who owns the home energy usage data?
b) Should individual consumers and their authorized third-party service providers have the right to access energy usage data directly from the meter?
In the context of AMI, the consumer owns the data because it is a profile of their energy usage. However, as a matter of practical necessity, there are other entities who need to use the data in one form or another. Therefore, it is incumbent upon regulators and legislators (state and federal) to establish rules to outline the permissible uses for each entity who uses to the data to ensure the consumer’s data is not compromised.
The utility company has a stake in the data because they need to, at a minimum, bill for the service and to compile aggregate data to determine jurisdictional load profiles. However, the utility company should not be allowed to send customer data to appliance manufacturers unless they are given permission by the customer.
Apartment building owners will need the customer data in some form for a variety of reasons. Specifically, they will need the data to comply with LEED certification mandates and to make capital improvements decisions in order to be more energy efficient (i.e. the purchase of new appliances, replacing windows and furnaces). However, the apartment building owners should be restricted from selling the customer’s data to an appliance manufacturer without the customer’s consent.
Consumers need the data to understand their home energy load profile, specifically which appliances are using the most energy. They also need the data so it can be analyzed by a variety of third party vendors such as Google or Microsoft. In order to protect the consumer’s data when it is in the third party vendor’s possession, there needs to be a set of laws established to define the permissible uses of a third party vendor as it applies to the data.
b) Individual consumers should have the right to access energy usage data directly from the meter if the utility is using a meter that will allow such access.
5. How are low-income consumers best served by home-to-grid technology?
Like any other customer, low-income consumers want an opportunity to reduce energy consumption and save money. However, low-income consumers are limited because of their income from investing in some of the enabling technology that can automate the process of reducing energy consumption. Therefore, regulators should look to LIHEAP type programs to distribute in-home displays that will give low-income consumers information to control their energy usage.
Elizabeth A. Noel, People's Counsel
Laurence C. Daniels & Jennifer L. Weberski
Assistant People's Counsels
D.C. Office of the People's Counsel
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