The following comments are submitted by the Association of Home Appliance Manufacturers (AHAM).
1. Should the smart meter serve as the primary gateway for residential energy usage data, price data, and demand response signals? What are the most important factors in making this assessment, and how might those factors change over time?
2. Should a data gateway other than the smart meter be used for all or a subset of the data described in question 1?
3. If the smart meter, via the utility network, is the primary gateway for the data described in question 1, 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?
AHAM’s response to questions 1-3 is that Smart Grid enabled homes will have varying levels of sophistication, depending on the type of appliances, devices, and networks that are installed. There are many configurations, combinations, and options for energy management inside the home. Some possibilities could include a simple email notice for a manual demand response by the consumer, a smart meter directly communicating with a specific appliance to ask it to turn on and off, or a meter communicating with a Programmable Communicating Thermostat allowing for temperature adjustment. As a more sophisticated example, a smart meter communicates with an Energy Management System (EMS) home controller inside the house. This EMS home controller could wirelessly connect in-home Smart Appliances simultaneously to the Smart Meter and to the demand response backend system over the Internet using an existing broadband connection. An Internet-based approach also could provide users with control and flexibility to define their energy saving profiles, and an established, secure suite of communication protocols that manages several Smart Appliances while connecting to the Internet to receive messages and rate information. With so many flexible options, there must be standardized communication protocols available that allow proper interaction from utilities demand response systems to the smart meters, home controllers, gateways, displays, and devices.
4. Who owns the home energy usage data? Should individual consumers and their authorized third-party service providers have the right to access energy usage data directly from the meter?
Communication or interaction inside the home should be under the control of the consumer.
5. How are low-income consumers best served by home-to-grid technology?
The goal of a Smart Grid, as it relates to consumers, is to manage energy use more efficiently, save money on electricity, and provide technology and processes that are integrated into the appliances and devices consumers use in their everyday lives – all without causing significant disruption. A successful Smart Grid will allow consumers to receive valuable and understandable information that enables them to make intelligent and informed choices about how they use energy, all while minimizing consumer cost and out-of-pocket expenses that could arise with the implementation of the Smart Grid. The willingness of consumers to accept and participate in the Smart Grid could be severely impaired if the cost outweighs the benefits.
6. What alternative architectures involving real-time (or near-real-time) electricity usage and price data are there that could support open innovation in home energy services?
The Time of Use (TOU) tariff creates the conditions that encourage the consumer to change their or the appliance’s behavior by using appliances when the rates are lower, which if properly developed will save the consumer money on their total electricity bill. There are other benefits when the consumer is incentivized by the rate structure to intelligently manage energy usage. If the consumer can receive information relating to what type of power is available, in addition to the price, choices can be made to utilize renewable energy sources when they are available. For example, if there is a strong wind blowing across a wind turbine generation facility, it may be advantageous to consume power during that time so that it is not used when a higher emission alternative may be the only option.
In order to be effective, dynamic pricing requires the following:
• Clear standards are required to describe dynamic pricing information across the United States. A FERC report on demand response & advanced metering surveyed the various time-based rate programs around the country and found that only 20 programs fit the commission’s definition of critical peak pricing programs. The programs that fit FERC’s definition are small in size and few in number. Model tariffs and rate structures guidelines should be developed to fully enable the potential of Smart Appliances. Each utility should harmonize according to standards that apply across the United States. A fragmented system of tariff structures across the more than 3,000 utilities would present an impediment to the interstate commerce and use of consumer products. Tariffs, while approved regionally, must collectively provide benefits to consumers that invest in Smart Appliances.
• The pricing structure must allow manufacturers to build devices or appliances that are capable of managing this benefit and provide consumers with the proper incentives. For example, rate charges based on energy (kilowatt-hours) could encourage consumers to “shift” their energy use over time. Similarly, rate charges based on power (watts) could incentivize the consumer to “spread-out” their overall usage.
• Timely delivery of the pricing information from the utility is required for the consumer to make well-timed decisions about energy usage.
• The consumer must be able to easily set rules defining their preferences to govern their usage of electricity in the home. This applies to many possible architectural configurations, e.g., from a single Smart Appliance in the homes to including a comprehensive home energy management system. Some configurations may require a more sophisticated panel or display in the home or the assistance of web services outside the home.
7. Some appliance manufacturers have announced plans to market Smart Grid-enabled appliances in late 2011 provided that appropriate communication standards are defined in 2010. What standard data communications interfaces(s) should be supported by appliances and the smart meter or data gateway so that appliance manufacturers can cost-effectively produce smart appliances that can communicate with the Smart Grid anywhere in the nation? How can communication between smart appliances and the Smart Grid be made “plug and play” for consumers who do not have the skills or means to configure data networks? If gateways or adapters are needed, who should pay for them: The utility or the consumer?
One of three essential requirements outlined in AHAM’s December 2009 Smart Grid White Paper, The Home Appliance Industry’s Principles & Requirements for Achieving a Widely Accepted Smart Grid (found at www.aham.org/smartgrid), is that communication standards must be open, flexible, secure and not so numerous that they become burdensome, confusing, and conflicting. Significant effort is being expended by the Department of Energy and the NIST to identify standards that are applicable to the Smart Grid.
Appliance manufacturing is an investment-intensive activity that results in standardized products for national distribution. Customizing products for every proprietary communication protocol would be impractical. Moreover, every time a consumer moves or otherwise relocates to another utility service area they should not be forced to replace or change appliances in order to accommodate the specific technology being utilized by the utility in their service territory. AHAM strongly encourages the adoption of a single common Home Area Network communication standard for communication from/to the meter.
For these reasons, AHAM has begun a technical evaluation of communication standards and protocols as they relate to the development and interoperability of the Smart Grid and what standards and protocols would be most effective for the appliance industry. The Smart Appliance Communication Standard study will evaluate and narrow the number of protocols that best meet the appliance industry requirements.
Some meter manufacturers have developed proprietary protocols for communicating with devices inside the residence. These proprietary protocols create challenges for appliance and device manufacturers. Gateways and adapters that are required to communicate with the meter should be limited in number in the home to minimize costs. Many of the remaining details, including who will pay, will be determined by the market.
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