The Utilities Telecom Council hereby comments in response to the Department of Energy (DOE) request for information on data access, third party use, and privacy.
In summary, UTC submits that the innovative deployment by energy utilities of smart meters and smart control systems will create a smart energy grid that will unlock the value of what has been called the Energy Information Economy2. Smart energy grids will create an environment in which consumers will have greater abilities to manage their own energy usage and utilities will have new tools to affect grid-wide energy efficiencies never before possible. The key to all this is data. How to provide secure access to it for customers and their agents is the crux of this RFI’s questions and the focus of our responses. The Energy Information Economy will bring with it an inevitable and exponential increase in data as well as new costs. The challenge for utilities, regulators, consumers, service providers, technology manufacturers, and others is to provide the right balance between enabling this new era of energy management with both the net value of the applications and the privacy rights of consumers. UTC believes that depending upon the particular utility and applications chosen, the smart grid can provide huge net benefits for consumers, but as is the fundamental principle for both regulated and unregulated utilities, the value of applications has to be measured against the costs which will ultimately be borne by consumers. Similarly, the development and distribution of consumer consumption data must be carefully weighed against the privacy rights of consumers, as already implemented by utilities and state regulatory authorities. Policies on data access must be driven by the need to provide benefits for consumers, not the financial gains of third party participants.