Wednesday, March 3, 2010

Larry Lackey: Treat Energy Serivces Information as Personally Identifiable Information (PII)

(1) Who owns the home energy usage data?

Let’s think of usage as Personally Identifiable Information (PII), and for a first cut the consumer owns it, the utility may use PII usage information solely for billing, and any other access to PII usage information requires the consumer’s specific permission for the specific user and purpose – a sort of informed consent.

(2) Should individual consumers and their authorized third-party service providers have the right to access energy usage data directly from the meter? Consumers can now walk outside and read their meter. In a future world, a “smart” equivalent is a digital interface for real-time usage information without any third part involvement. Fortunately, this demands little of a meter. A consumer could then provide third party access to the information through the consumer’s own Energy Services Interface or authorize the utility to share PII usage information with specific third parties, possibly for a reasonable fee.

(3) If the smart meter, via the utility network, is the primary gateway for obtaining residential energy usage data, will it be technically and commercially feasible for consumers and their authorized third-party service providers to access the data easily and in real time? Please see item 2.

(4) What types of policies are needed to gain consumer confidence that personal energy usage data is secure and not subject to abuse? A strict legal framework for maintaining the confidentially of PII usage information at all times by any recipient and for sharing only with informed, specific consent of the consumer or by court order for any other specifically permitted release of the information. Note that this implies that when the consumer associated with a meter changes ALL permissions to share PII usage information are immediately revoked.

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