Rish Ghatikar: It Is Not Simple

Organization Name Demand Response Research Center,
Lawrence Berkeley National Laboratory (DRRC, LBNL)
Organization URL http://drrc.lbl.gov/ and http://www.lbl.gov/
Contact: Mary Ann Piette and Rish Ghatikar (AutoDR@lbl.gov)

Fundamental Requirements:

There are several fundamental principles, separate and apart from responses to the six (6) OSTP questions, that any gateway or information access rules should include, specifically:

1.) Information flowing to the home, whether it be, (1) price and/or reliability (includes emergency) signals, and/or (2) usage data in near real-time or delayed, should not be restricted to any physical channel, communication protocol, or technology. It should be published so that consumers and consumer-authorized parties can subscribe via any physical channel that suits their needs. Published price and reliability information should be available to all physical channel operators so that they can map the information into their channel. Published usage data should be secure and similar to banking data and only be available to consumers whose data it is.

2.) Information flowing from inside the home should be controlled and authorized for use only by the consumer who owns the data. Information from the facility meter should be immediately available to the utility and the consumer directly from the meter (although possibly on different physical channels and/or systems).

3.) Every segment of the information chain should be delivered in a well-defined, secure client-server model.

4.) Standardized gateway applications within the home should be capable of being implemented on existing platforms such as individual appliances, IT routers, set-top boxes, security panels, lighting controls, circuit breakers, entertainment devices, wall warts, etc.

5.) The requirements (e.g. HAN) specifying these guiding principles should not restrictive to the consumers and other stakeholders involved in these transactions. These requirements, as comprehensive as they are, should allow consumer choice and allow opportunities for open innovation.

Office of Science and Technology Policy Questions - Responses< Question 1a. Should the smart meter serve as the primary gateway for residential energy usage data, price data, and demand response signals? Response: We think that the smart meter should serve as the “only” gateway for DR signals. This includes, price, usage data or other signals for any class of customers. The rationale behind this response is covered in responses to Question 1b. Question 1b. What are the most important factors in making this assessment, and how might those factors change over time? Response: These factors are as follows: • A fundamental question is whether services from the electricity provider should include functionality that goes beyond the service drop and into the customer premise. This issue is almost identical to the “demarcation point” concerns addressed in the telecom industry in the early 1980’s. AT&T claimed that allowing customers to connect their own equipment or allowing third-party vendors to develop other equipment, would compromise the telecom network and create security problems. That argument was not sustained, which resulted in development of a very competitive, equipment, and application rich telecommunications environment – including the Internet. The telecom network(s) were not compromised. In fact the ensuing voice, data, and video networks that evolved redefined and established new, more sophisticated and more secure security and privacy capability. • Making the meter communication network the only gateway makes the “smart meter” system a gatekeeper and bottleneck that can result in issues related to third-party access to the customer and potential ability to provide aggregation, information, and end-device services. • The use of the meter communication network as a carrier for all metering, system operational, and all other residential price, data, and other functions needs testing on a system wide basis. Potential congestion, latency, and functional conflicts have to be addressed. Locking into a single network without first testing and addressing these issues creates substantial operational and other risks for both the essential meter functions as well as all smart grid customer oriented functions. • Making the meter communication network the primary gateway provider will force all third-party providers to funnel some or all of their applications through the electricity service provider. This approach creates a significant competitive barrier and lack of innovation to smart grid development. Question 2. Should a data gateway other than the smart meter be used for all or a subset of the data described in question 1? Response: There is no technical reason for establishing a single gateway. Gateways are a carryover from early days of home automation where there were limited communication options and limited and expensive processing capabilities. Individual appliances or end-uses with embedded controls or retrofit devices on existing appliances are capable of receiving price, event or control signals directly from multiple communication sources. A gateway would be necessary only to provide signal translation services, home automation integration capability, or to act as an interface with multiple networks or systems in a premise. Bridge clients (devices/systems that can translate information, physical channels, etc.) on the grid-side of the meter can translate an open standards based utility provided set of price and other signals or for that matter, access to meter data, at low cost, while also providing interoperability – allowing companies to begin now to develop and market controls, information devices and other services. Question 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? Response: For authorized third-party to access the data, there are certain of issues that need to be addressed. The issues as follows: a. First, access to the real-time data from the meter may not be the only solution, nor is there any research or other justification to indicate it is for residential or small commercial and industrial applications. If near real-time access is provided to customers, options should also focus on software applications (API’s) that can be provided at low cost and with flexibility to adapt to multiple display devices and other customize customer services. b. The only data accessible through the meter network in near real-time will be whole premise usage. This data will not align with usage data presented in the customer bill, which will cause rationalization problems and measurement of energy by end-uses. c. Third-party access to customer near-real-time data can only come from three sources (Table 1). Each potential source has different customer choice, security and privacy, and management issues. Unfortunately, only data access from the electricity service provider (choice #1) has been discussed or is being considered. Access through a customer portal (choice #3) should be considered a more preferred option because it improves and expands customer options, puts the customer in direct control and ownership of their data, and will be the lowest cost option. Table 1: Three Sources for Third-party Access to Data
Data Access Option Operational and Cost Issues [1] Customer Choice [2] Security and Privacy [3] Management

1 Electricity Service Provider – via Meter Data Management System (MDM).

a. Customer must notify the electricity service provider to authorize (start) or prohibit (stop) access for each third-party provider.

b. Customer limited to MDM content, whole premise data.

a. Electricity service provider and customer must both be parties to the authorization.

b. Electricity service provider incurs primary responsibility for security and privacy a. Electricity service provider must establish process for maintaining proper authorizations and changes.

b. Electricity service provider as the provider may expose MDM to broad hacking and abuse options.

2 Electricity Service Provider – direct from the meter. Same as Option 1. Same as Option 1.

a. Same as 1.3.a

b. Exposes meter to potential hacking and abuse.

3 Customer-direct from a customer portal (inside the premise).*

* Customer portal would allow customer to assign temporary passwords to provide third-party access.

a. Customer retains full authority and choice regarding all third-party service providers

b. Customer has unlimited choice regarding what monitoring equipment and what data to provide.

a. Customer retains full and total authority for establishing and maintaining security and privacy.

b. Customer controls all third-party access and authorization.

a. Electricity service provider has no responsibility with regard to third parties.

b. Responsibilities limited to MDM and electricity service provider specific billing and operational functions.

c. Lowest cost option.

d. There is an added cost to the customer to get access to meter data through the meter. A bridge client to boost meter signals will almost certainly be required as will a dedicated display unit. In such cases, electricity service providers should disclose these costs and/or alternatives that will mitigate or reduce/eliminate these costs.

Question 4a. Who owns the home energy usage data?

Response: The customer owns the energy usage data from their premise. The electricity service provider, as a condition of supplying electric service is provided with the right to use this data for billing and other direct service related functions. Any other use of customer data should require specific authorization from the customer.

Question 4b. Should individual consumers and their authorized third-party service providers have the right to access energy usage data directly from the meter?

Response: As the data is owned by the customers, they and their third-party providers should have the right to access energy usage data directly from the meter or through a customer provided portal to the meter (See reply to Question 3)– with a caveat. The caveat is that access to the meter should be through a secure port or other means that does not compromise or expose the revenue meter or electricity service provider to any functional or other risks.

As an example, existing regulations in California with regard to large Commercial and Industrial (C&I) customers and their use of KYZ ports on meters provides a template for this access. Currently, all interval meters for large C&I (>200kW) in California, have KYZ ports that allow the customer to obtain a direct feed of meter data in real time into their own in-facility computer/processing or energy management system. The KYZ port is a physical port in the meter. Current meter design requires the electricity service provider to first install an isolation relay that prevents any customer action that might damage or interfere with metering functions. This KYZ port could easily be replaced by a wireless 802.14 capability that would allow the customer with the use of a password, to directly access their data wirelessly. Customers could then provide a portal through their own internal computer system or other add-on bridge client, where they provide one or more third party service providers with temporary passwords for accessing meter data directly.

Question 5. How are low-income consumers best served by home-to-grid technology

Response: Low income and all other customers would be best served by two options:

• A wireless access option from the meter that uses open standards like that mentioned in the response to Question 4, with a customer portal and customer selected data security requirements (that meets their privacy requirements). This would allow the customer to provide access to meter data to any third-party provider or directly to an appliance with embedded applications that might need this data. Third-party providers like cable, telecom, home security companies and appliance vendors might choose to develop API’s that the customer could authorize and/or prohibit individually with a password based on their own assessment of the value and cost of each application.

• One solution would be to publish the price and reliability event signals over a public network/service that could be received through low-cost customer owned devices or through subsidized utility provided control units – not requiring Internet access. Such a solution would also allow entities such as the public broadcast would provide low cost access and would allow third-party service providers and appliance vendors to embed logic or to develop API’s that do not require Internet Protocol (IP).

Question 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?

See the notes and response to Question 3.