September 6, Via electronic mail

Transcription

1 September 6, 2017 Via electronic mail Executive Secretary Michigan Public Service Commission P.O. Box Lansing, MI Re: Mission:data Coalition comments on U-18014, In the matter of DTE Electric Company for authority to increase its rates, amend its rate schedules and rules governing the distribution and supply of electric energy, and for miscellaneous accounting authority Mission:data Coalition, Inc. ( Mission:data ) is pleased to provide these comments in the above referenced proceeding concerning DTE Electric s ( DTEE ) Distribution Operations Five- Year ( ) Investment and Maintenance Plan Draft Report ( Draft Report ), dated July 1, Mission:data Coalition is a national coalition of over 35 technology companies delivering data-enabled energy savings for homes and businesses. We represent a growing and vibrant ecosystem of innovative technology companies with sales in excess of $1 billion per year that have developed many products leveraging advanced meter data to benefit residential, commercial and industrial customers. Mission:data is focused on empowering consumers with convenient access to their energy usage data and the ability to quickly and conveniently share that data with third parties of their choice. As Michigan considers modernizing its distribution grid, it is imperative to provide consumers with greater control and a broad choice of energy management tools to take full advantage of new energy technologies. While Michigan is well-positioned for leadership having already invested in Advanced Metering Infrastructure ( AMI ) we highlight several areas where the Draft Report fails to address how customers can become greater participants in a more reliable, cleaner and cheaper electricity system. In particular, the Draft Report does not detail how AMI will be leveraged to increase reliability or potentially defer capital investments. The Draft Report also does not describe how energy efficiency or demand response can be used

2 to provide system-wide benefits to the distribution grid. Aside from a brief discussion about pilot projects, there is no discussion of integrating energy efficiency and demand response into distribution planning processes. Below, Mission:data structures our comments around the four questions posed by the Notice of Opportunity to Comment, dated August 4, I. Does the company s draft distribution planning report provide a transparent review to identify and make cost-effective grid modernization and aging infrastructure investments necessary to support improved reliability, power quality, and future growth? Do the proposed investments provide a clear strategic path to address resiliency, reliability, and grid modernization, consistent with the Commission s stated goals as outlined in recent electric rate case orders? It is notable that of the Draft Report s 173 pages, only three pages discuss AMI, and most of these three pages are given to explanations for why further upgrades are needed (due to cellular carriers retiring 3G towers in favor of 4G, and a needed firmware upgrade) and retrospectively enumerating the benefits of AMI that are supposedly already being experienced by consumers. There is no substantive discussion about how AMI will be used over the five year period to help customers manage their bills or reduce peak demand, or how AMI will be used to integrate new technologies that can reduce costs for customers. As a investment and maintenance plan, the Draft Report only addresses minor tweaks to existing AMI features. As such, it is more a maintenance-only plan than a comprehensive investment plan. One of the promises of AMI is a vast trove of data that can be mined for multiple purposes. Digital assets offer the possibility of reducing the costs of physical assets for example, datadriven distributed energy resources ( DERs ) on the customer side of the meter can, if wellcoordinated, provide many of the services that would otherwise be more costly to deliver. The Draft Report does little to incorporate DERs. Rather than proposing an investment plan for true DER integration, the Draft Report dismisses DERs by blaming a metering problem: Without near real-time metering being installed at a distributed resource site and an integrated control system in the ADMS [advanced distribution management system], DTEE cannot use DERs as active grid resources Draft Report at p. 97.

3 Instead, a comprehensive investment plan from DTEE should discuss how AMI can be used to create a modern grid that fully engages customer-sited DER and makes maximum use of energy efficiency and demand response. One of the investments that DTEE should be required to put in its plan is a data-sharing platform that enables customers to share their energy usage and billing history with any DER provider of their choice. One costly barrier to DER adoption is the lack of available customer-specific energy data, even when customers provide authorization. As described in our report, Got Data? The Value of Energy Data Access to Consumers and attached hereto, the lack of easily-accessible, opt-in, standardized energy data across utilities nationwide is a significant obstacle to the growth of cost-effective DERs. There are three elements to the data-sharing platform we describe above. First is the provision of time-stamped electrical usage data to customer-authorized third parties. Using the technical standard known as Green Button Connect My Data ( GBC ), energy data can be instantly and securely transmitted over the internet to a solar provider, an energy efficiency company with a smartphone app, or a demand response provider. Mission:data notes that the Michigan Commission s website today says: In the future, AMI meters could enable features for consumers like personalized electricity plans that fit your lifestyle and energy use. Perhaps smart phone apps will let you manage your home s energy use, control your thermostat, or maybe even retrieve your grocery list from your smart refrigerator. 2 It appears the Michigan Commission shares many parts of Mission:data s vision for the future. Entrepreneurs and innovators have already created many smartphone apps but they will never reach Michigan customers and help them to understand their energy usage when access to energy usage data is restricted by DTEE. By requiring DTEE to adopt the GBC standard, DTEE can realize the Commission s goals of personalized electricity plans and tailored smartphone apps that use individual customer s energy histories to make targeted recommendations for conservation. We note that over 25 million meters nationwide have GBC policies; utilities in the states of California, Colorado, Illinois and New York provide GBC to their customers precisely so that consumers and businesses can realize more value from AMI investments. We ask the Commission to require DTEE to implement GBC, following the national standard and documented best practices. The second component of a data-sharing platform is enablement of the Home Area Network ( HAN ) in smart meters. The HAN, using the Zigbee communications protocol, 2 See

4 provides real-time meter readings to authorized devices inside the customer s home or business. Real-time data made available to customers every few seconds enables disaggregation, the use of algorithms to identify energy used in a household by device. Appliances have unique electricity usage signatures that allow algorithms using high-interval, real-time data to identify the device being used and its energy performance (e.g., whether it is an ENERGY STAR refrigerator working well or an old clunker that needs to be replaced). Today, we understand that DTEE only permits HAN devices from Powerley, DTEE s spin-off or affiliated company, to collect real-time readings. It is clearly anti-competitive for a monopoly electric utility to extend its monopoly into an area outside the distribution of electricity and into customer energy management. Mission:data notes that Michigan public utility law does not appoint DTEE the sole provider of smartphone apps that use energy information from smart meters. And yet DTEE has a de facto monopoly on this technology within its territory by prohibiting non-dtee devices from connecting to advanced meters. Indeed, DTEE brags in the Draft Report that the direct customer benefits from AMI are accessible only by downloading the DTE Insight app. 3 This unfortunate situation, which deprives Michigan consumers of access to new technologies that cost-effectively manage their energy usage, can be remedied by the Commission requiring DTEE to enable HAN connectivity to any device the customer wishes. Just as AT&T was required to allow any manufacturer s telephone to connect to the network that is, not just telephones sold by AT&T following the Federal Communications Commission s 1968 Carterfone decision, and just as cable companies are required to allow any DOCSIS-compliant set-top box to connect to the cable network, the Michigan Commission should mandate that DTEE provide connection to any customer-provided HAN device. The third component of a data-sharing platform is electronic access to historical bills and, where the utility is the commodity provider, rate information in machine-readable form. Historical bills can be provided to customer-authorized third parties (such as bill payment providers for commercial and industrial customers) using the GBC standard. GBC accommodates every line item of monthly bills in XML format. As for rates, Mission:data recommends that the Commission require DTEE to publish its approved, up-to-date rates in the National Renewable Energy Laboratory s ( NREL ) Openei.org database. OpenEI already contains over 40,000 rates from across the country, but it is difficult to maintain an accurate database of all possible rates from so many utilities. Given that NREL has already done the technical work of creating a standard that accommodates every conceivable rate structure, it would be wise for the Commission to take advantage of this work and simply require utilities to actively upload its rates to OpenEI whenever they are approved by the Commission. 3 Draft Report at p. 62.

5 To summarize, DTEE s Draft Report fails to provide a clear strategic path to address grid modernization. The first step to increasing the adoption of cost-effective DERs such as energy efficiency and demand response is to provide a robust data-sharing platform as part of DTEE s customer portal. With over 25 million utility meters nationwide participating in Green Button Connect My Data data-sharing platforms, it is time for DTEE to join the ranks of its peers and provide the same high-quality digital services that consumers expect in the modern age. II. Do the plans identify system upgrades or investment strategies and concrete, measurable performance targets and timeliness in areas such as safety and reliability? No comment. III. Are there longer term enhancements to the plan or the planning process that the Commission, utilities, and stakeholders should be considering in future rounds? No comment. IV. Any other feedback for the Commission s or Commission Staff s consideration. As described above, Mission:data believes that customer data held by the utility should be portable and electronically accessible to any authorized third party. That means the utility must provide the digital infrastructure for easily transmitting customer information such as energy usage and historical bills in electronic form, consistent with national standards. However, as we have seen in other states, the quality of these digital platforms varies widely. Some utilities make it easy for customers to share their energy data for example, these utilities incorporate online user experience best practices, reduce the number of actions or clicks required by consumers to complete the process, and optimize their websites for mobile devices that have

6 smaller screen sizes. However, high-quality utility websites are not ubiquitous. If the customer is required to fill out complex forms (and possibly mail hard copies to the utility) to be processed manually in a timescale of days or weeks, it will not be surprising that very few customers will have the patience to follow through. In a world in which smartphone apps and websites offer seamless, immediate, one-click experiences in fields such as banking, e-commerce and travel, it becomes all the more important for the utility to provide a comparable experience that meets customer expectations in their digital lives. A clumsy process for authorizing a third party to access energy information will greatly inhibit the flow of benefits from Michigan s investment in advanced metering because fewer customers will adopt DERs. It is difficult to overstate the positive impact on DER enrollment rates of a streamlined process for customers: One whitepaper by residential demand response leader EnergyHub found that participation rates increased from 3% to 40% of eligible customers when the enrollment process was dramatically simplified and much fewer steps were required. 4 Therefore, we believe it is essential that the Commission consider the customer experience and the quality of the utility s data-sharing platform over the long term as customer expectations change over time. Informed consent in the modern digital age is quite different from the past. Fifteen years ago, few would imagine that people would be consenting to share very personal information such as photos and geolocation information with social networking websites simply by clicking a button. As the new technologies are adopted, our notions of informed consent and online consumer protections need to adapt. The best way to ensure that utilities are not seen as dinosaurs is to benchmark their user experiences with other, more dynamic industries. Today, online and automated processes that optimize the customer experience are critical in empowering customers and driving customer satisfaction. We note that California is in the midst of implementing a streamlined authorization process for data-sharing and demand response enrollment, after a lengthy, four-page legal form in hardcopy was determined to be an obstacle to enrolling over 100,000 households in demand response. 5 Michigan can learn from these experiences, and Mission:data is willing to help the Michigan Commission in whatever way we can. 4 Optimizing the demand response program enrollment process. White paper by EnergyHub, Inc. dated April, Available at 5 California Public Utilities Commission. Decision D , dated June 9,

7 Respectfully submitted, for The Mission:data Coalition /s/ Michael Murray 1752 NW Market Street, #1513 Seattle, WA (510) Attachment: Got Data? The Value of Energy Data Access to Consumers