Reliant Energy: The View from Texas

March 12, 2010
Comments of Reliant Energy Retail Services, LLC to the OSTP Questions
Background of Reliant Energy
Reliant Energy Retail Services, LLC, (“Reliant Energy”), a competitive retail electric provider, is a wholly owned subsidiary of NRG Energy, Inc., a national wholesale power generation company with over 24,000 MW of generation in 13 states. Reliant Energy provides electricity and energy related products to more than 1.6 million customers in Texas.
Smart Grid, as it relates to enabling informed participation by end-use customers, has been a focus of Reliant Energy’s business for the past three years. Reliant Energy’s involvement in the Smart Grid is focused on the Distribution, Customer and Service Provider domains, as depicted in the NIST Conceptual Reference Model [1], through two primary activities: (1) active involvement in the development of interoperable Smart Grid standards between these domains of interest, and (2) developing and offering retail products enabled by the Smart Grid that allow customers to become more active participants in their consumption of energy. Reliant Energy has been an active participant in facilitating the Smart Grid market design and developing business requirements both in Texas and nationally, through various stakeholder processes, including the Public Utility Commission of Texas (PUCT) Advanced Metering Implementation Team, North American Energy Standards Board (NAESB), UCAIug OpenSG , ZigBee Alliance, Smart Grid Interoperability Panel (SGIP) and the SGIP Governing Board (SGIPGB). These forums accelerate the development and adoption of national and international Smart Grid standards that ensure interoperability between the components of the Smart Grid system, especially with the Customer domain.
In October 2009, Reliant Energy was selected for a DOE Smart Grid Investment Grant (SGIG) to accelerate the development and deployment of a suite of retail products that will enable informed participation in the Smart Grid for Texas residential customers. The success of Reliant Energy’s SGIG Project is dependent upon a reliable and interoperable consumer interface with the Smart Grid. This interface must provide for the secure bi-directional transfer of information, including energy usage and other messages to home-area-network devices.
Responses to Questions
Reliant Energy appreciates the opportunity to provide the following comments in response to the OSTP’s request.
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?
Answer: The smart meter is an integral part of the Smart Grid that provides a new communication interface between the Distribution and Customer domains and between the Service Provider and Customer domains as shown graphically in Figure 1. The importance of this interface should not be underestimated. It should be the primary interface / gateway for customer energy usage data, price data, and demand response signals.
Figure 1 Interaction of actors in different Smart Grid Domains through Secure Communication Flows and Electrical Flows.[2]
Alternative “gateways” to provide customer energy usage information should be supported and encouraged, but not to the exclusion of the smart meter interface. For example, broadband internet service is often described as an alternative for communication of energy information. Yet, not all customers have broadband service and an internet / broadband interface requires the customer to have an additional technology service provider and home area network device to collect the near real time energy consumption information from the smart meter. Therefore using broadband as an alternative interface represents an added cost to the customer.
NIST describes the Smart Grid interface to the Customer Domain as being composed of “two distinct elements that, together, provide the interface to the Customer Domain: the meter and the Energy Services Interface (ESI)” [3]. The meter functions “to measure, record, and communicate energy usage” [4] and is owned by the utility, which is solely responsible for providing data to support both retail energy billing and wholesale energy settlement. The ESI [5] provides the security - and often the coordination functions - to enable secure interactions between the home area network (HAN) devices (e.g. electric meter, programmable communicating thermostats, displays, smart appliances, energy management systems, plug-in electric vehicles (PEV), etc.) and the Service Provider (e.g. utility, retail electric provider, Demand Response providers, Energy Service Providers, etc.) over the utility AMI communications network. In smart meter deployments in Texas, the ESI is located in the smart meter. Through the ESI, HAN devices can receive, display, and respond to real-time energy usage information accessed directly from the smart meter. Once a customer securely joins a HAN device to the ESI, the device can receive real-time usage information independent of any Service Provider program.
The ESI is the unique interface between the Customer domain and the Distribution domain. The ESI can also serve as the secure interface between the Service Provider and Customer domains for communicating price data, demand response signals, and other information associated with a specific Service Provider retail program (e.g. smart appliance, DR, pre-pay, PEV, etc.). Although a Service Provider may use an alternative communication path (e.g. internet, broadband, etc.) to send price data and demand response signals to consumer HAN devices, at least one HAN device must be present and securely joined to the ESI, to tie the price or demand response signal to the consumer’s real time energy consumption when needed to verify customer participation in the Service Provider’s program.
Other interfaces may be available to consumers for other purposes. For example, a business to business back office interface, such as described by Open Automatic Data Exchange (OpenADE) can provide billing quality day-after energy usage data, retrieved from the smart meter and subjected to a utility validation, editing and estimation (VEE) process.
Important factors Service Providers and Customers should consider in making a decision on which interface to utilize are program specific and relate to the need for timely data (e.g. real-time usage data, day-after historical data), the accuracy of the data (e.g. real time non-billing usage data, VEE billing quality usage data) and the need to validate a customer’s participation in a specific program. Also, whether or not the consumer is willing to incur the additional cost for an alternative interface should be considered.
In conclusion, other interfaces could be available and utilized by Service Providers to supply customer price data and demand response signals but the smart meter / ESI provides the unique secure interface between the Distribution and Customer domains and the Service Provider and Customer domains for real-time usage data accessed from the smart meter.
2. Should a data gateway other than the smart meter be used for all or a subset of the data described in question 1?
Answer: An additional data gateway, other than the smart meter / ESI, may be used by the Service Provider and Customer but should not be required. As discussed in question 1, an internet gateway may be used by the Service Provider for price data and demand response signals, but this gateway must be securely joined to the ESI to tie the price data or demand response signal to real time customer usage. Also, whether or not the customer has the ability to provide an alternative cost effective communication path (e.g. internet, broadband service, etc.) to the Service Provider should be considered.
3. If the smart meter, via the utility network, is the primary gateway for the data described in question 1, will consumers and their authorized third party service providers be able to access the data easily and in real time?
Answer: If the smart meter / ESI is the primary gateway, then customers will be able to access their data easily and in real time if the ESI and the customer’s HAN devices conform to the requirements of an interoperable standard. Whether or not an authorized third party service provider has access through the smart meter / ESI interface is governed by jurisdictional regulatory and legislative rules. In the regions of Texas with retail competition, customers have access to their real-time usage data through the smart meter / ESI interface and can grant third party service provider’s access to their data through an OpenADE type interface. This access is required by PUCT rules and is enabled by the use of interoperable standards. NIST has recognized the requirements standard for home-area networks and devices, UtilityAMI 2008 Home Area Network System Requirements Specification v1.04 [6] (“OpenHAN SRS”), which includes specific requirements for the ESI and HAN devices that enable customers to access data easily and in real time, where appropriate.
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?
Answer: Customer access to their electrical usage data is governed by regulatory and legislative rules in the jurisdictions in which they live. In the regions of Texas with retail competition, this policy question has been answered in Public Utility Regulatory Act (PURA) Sec. 39.107 (b), which provides in pertinent part: “All meter data, including all data generated, provided or otherwise made available, by advance meters and meter information networks, shall belong to a customer…”. Additionally, PUCT Substantive Rule 25.130(j) requires a utility to provide customers access to their usage data and allows customers to make their data available to a third-party service provider of their choice. In the regions of Texas with retail competition, consumers who have smart meters may access non-billing usage data in real time through the smart meter / ESI and billing quality usage data on a day-after basis through an OpenADE type interface (i.e., Smart Meter Texas, an early version of the OpenADE interface). Customers may also grant a third party service provider access to their usage data through the Smart Meter Texas. Both of these methods to access usage data are enabled by the PUCT requirement to utilize interoperable standards.
5. How are low-income consumers best served by home-to-grid technology?
Answer: Low-income consumers are best served by home-to-grid technology when barriers to participation are minimized; out-of-pocket investments should not be required to take advantage of Smart Grid enabled products. Universal deployment of a standard interoperable interface will allow a HAN device to easily and securely join the ESI at any premise. Moreover, interoperability will drive HAN device manufacturers to innovate and differentiate their product offerings such that competitively priced HAN devices will be readily available.
The key to delivering Smart Grid benefits to low-income customers are (1) to ensure customers are not required to have access to an additional communication technology (e.g. internet, broadband, etc) or advanced technology like an energy management system; and (2) through interoperability standards, to encourage competitive innovation among HAN device manufactures that drives down prices to a point at which the savings realized by a low-income consumer quickly offsets the price of a device.
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?
Answer: The OpenHAN SRS identified several technology independent architectural scenarios which support innovation in home energy services. These scenarios enable customer choice by supporting architectures that include both traditional utility programs and programs offered by third party providers. The OpenHANSRS includes a broad set of platform- and technology- independent requirements that enable applications such as display of customer consumption and billing, remote load control, energy management and optimization, plug-in electric vehicles, and distributive energy resources. In addition, the OpenHAN SRS provides a mapping of requirements to the functionality of devices to serve as guidance to HAN device vendors.
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?
Answer: A widely acknowledged and referenced set of requirements for Smart Grid data communications interface to customer devices was set forth in theOpenHAN SRS published in 2008 and recognized by NIST as a low hanging fruit and in NIST standards Roadmap v 1.0. The purpose of the OpenHAN SRS is set forth on page 10 of the document:
“The UtilityAMI 2008 Home Area Network System Requirements Specification:
- Promotes open standards-based HANs that are interoperable
- Provides the vendor community with a common set of principles and requirements around which to build products
- _Ensures reliable and sustainable HAN platforms
- _Supports various energy policies in a variety of states, provinces, and countries
- _Empowers citizens with the information they need to make decisions on their energy use by enabling the vision of a home energy ecosystem”___
This requirements specification is currently being updated in an open collaborative process which includes participation from appliance manufacturers, other original equipment manufacturers (OEMs), software developers, utilities, and many other participants.
As mentioned, the OpenHAN SRS is technology independent. Therefore, technology companies and organizations should be called upon to implement the requirements from OpenHAN to develop “plug and play” technology and products for customers, including certification processes. One example of this occurrence is the efforts of the ZigBee Alliance and its members which produced the ZigBee Smart Energy profile as the first implementation of a standard data communication interface based on the OpenHAN SRS. The ZigBee Alliance also provides certification for ZigBee Smart Energy products to ensure customers and equipment manufacturers realize a “plug and play” interoperable experience. ZigBee Smart Energy HAN device products connected to the Smart Grid are available and being installed in customer homes today in the regions of Texas with retail competition. These devices are being used s without any additional gateways or adaptors between the Smart Grid and the HAN devices.
[1] NIST Framework and Roadmap for Smart Grid Interoperability Standards, Release 1.0, page 33.
[2] Ibid, page 33
[3]Ibid, page 41
[4] Ibid
[5] Utility AMI 2008 Home Area Network System Requirements Specification v 1.04, page 13
[6] OpenHAN SRS v1.4 was identified as a requirements standard by NIST in the NIST Framework and Roadmap for Smart Grid Interoperability Standards, Release 1.0, page 58. One of the audiences of this document are vendors that make consumer products like communicating thermostats, energy management systems, load control switches, in-home displays, smart appliances, plug-in hybrid-electric vehicles, and distributed generation resources.