Availability of Aggregated Customer Usage Information: An Overview of D.14-05-016

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Availability of Aggregated Customer Usage
Information An Overview of D.14-05-016

• California Public Utilities Commission
• Presentation before the California Energy
  Commission
• April 14, 2015

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History of Privacy Decisions in Smart Grid
Rulemaking

• December 2008 Issued Order Instituting
  Rulemaking (R.08-12-009)
• July 29, 2011 Final Decision adopting Privacy
  Rules and directing utilities to enhance third
  party access to customer information.
  (D11-07-056)
• Adopts Privacy Rules consistent with Federal Fair
  Information Practice Principles
• Directs utilities to file applications to enable
  third party access to customer usage information
  with customer consent
• August 31, 2012 Final Decision extends Privacy
  Rules and access to usage data to natural gas
  companies, CCAs, and ESPs that serve small
  business and residential customers (D.12-08-045)
• May 5, 2014 Final Decision adopting Privacy
  Rules directed at accessing Energy Usage and
  Usage-Related Data While Protecting Customer
  Privacy (D.14-05-016)

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CPUC Privacy Rules

• Based on Fair Information Practice Principles
• Applies to utilities, utility contractors, and
  third parties that obtain data from the utilities
• To be enforced via utility tariffs
• Development of rules mostly result of consensus
  amongst parties (notably, utilities, privacy
  advocates, and consumer advocates)
• Goals of rules are both to protect customer
  privacy, but also enable customers to access
  usage data and share that data with authorized
  third parties to promote future conservation and
  grid management activities
• Primary Purpose/Secondary Purpose structure
• Primary purposes are provision or billing of
  electricity or gas, provide for system, grid, or
  operational needs, provide services required by
  state or federal law or as directed by the CPUC,
  and plan, implement, or evaluate demand
  response, energy efficiency or energy management
  programs
• Secondary purpose is anything that is not a
  primary purpose
• Primary Purposes do not require customer consent

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Short Overview of D.14-05-016

• Decision accomplishes six things
• Directs release of usage information to
  educational institutions for research purposes
• Directs IOUs to post total monthly sum and
  average customer electricity and natural gas
  usage by zip code and by customer class
• Directs IOUs to make available to local
  governments yearly, quarterly, and monthly usage
  and usage related data by data request provided
  data results meet certain thresholds for privacy
  protections
• Directs IOUs to provide energy data to state and
  federal government entities to fulfill statutory
  obligations and request data
• Creates a process to allow entities to request
  energy usage information and related data from
  utilities
• Creates a Energy Data Access Committee to advise
  utilities on improvements and best practices and
  help mediate disagreements between utilities and
  requestors.
• Decision also considered 12 use cases that helped
  inform the decision.

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Data Aggregation

• Aggregation and anonymization can help lower risk
  of reidentification of individual customers.
• Risks to reidentification vary depending on
  certain factors
• Granularity of data (1 hour, daily, monthly)
• Geography (individual residence, census block,
  zip code)
• Timeframe (over an hour, day, month, or year)
• Customers (customer classes pose different level
  of risks)
• The Commission adopted several aggregation
  methodologies based on this premise.

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Public Posting of Data

• For residential customers, the zip code must have
  100 or more residential customers. For zip codes
  that lack 100 residential customers, the utility
  is directed to aggregate the data with a
  bordering zip code until the aggregation includes
  at least 100 residential customers.
• For commercial or agricultural customers, the zip
  code must have 15 or more commercial or
  agricultural customers, with no single account
  constituting more than 15 of the total
  consumption in any month. For zip codes that do
  not meet this standard, the utility is directed
  to aggregate the consumption with a bordering zip
  code until the area contains at least 15
  commercial or agricultural customers, with no
  single account constituting more than 15 of the
  total consumption in any month for the combined
  zip codes.
• For industrial customers, the zip code must have
  15 or more industrial customers, with no single
  account constituting more than 15 of the total
  consumption. For zip codes that do not meet this
  standard, the utility is directed to aggregate
  the consumption with a bordering zip code until
  the area contains at least 15 industrial
  customers, with no single account accounting for
  more than 15 of the total consumption for the
  combined zip codes.

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Local Government Access

• For residential, commercial, or agricultural
  customers, the request must have 15 or more
  customers, with no single account accounting for
  more than 20 of the total consumption in any
  interval requested and the data must not contain
  personal identifying information pertaining to
  any account. For requests that do not meet this
  standard, the utility is directed to work with
  the requestor to include additional customers
  until the requirement is met.
• For industrial customers, the request must have
  five or more industrial customers, with no single
  account accounting for more than 25 of the total
  consumption in any interval requested equal to or
  greater than a month and the requested data must
  not contain identifying information pertaining to
  any account. For requests that do not meet this
  standard, the utility is directed to work with
  the requestor to include additional customers
  until the requirement is met.
• For yearly, quarterly, and monthly anonymized
  data The request must have 100 or more
  customers, with no single account accounting for
  more than 10 of the total consumption in any
  requested interval equal to or greater than a
  month and the data must not contain personal
  identifying information pertaining to any
  account. For requests that do not meet this
  standard, the utility is directed to work with
  the requestor to include additional customers
  until the requirement is met.

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Data Request and Release Process

• IOUs to create a one-stop process for providing
  data to eligible entities
• Single point of contact for requests
• Data website to eventually include a catalog of
  requests made, fulfilled, and/or denied.
• Process
• Within 1 business day of receiving request, IOU
  to acknowledge receipt of request
• Within 7 business days, IOU will verify
  completeness of form or identify additional
  information needed
• Within 15 business days, IOU to notify whether
  data request can be fulfilled and provide a
  proposed schedule for providing data. If IOU
  cannot provide data, IOU to state specific
  reasons why not. Any disagreements can be heard
  in the EDAC.
• Prior to receiving data, requestor to complete an
  NDA.
• Local Governments exempted from NDA, but must
  accept certain terms of service.
• IOU to notify CPUC Executive Director of its
  proposed action.
• All data to be provided in standard formats
  (i.e., XML or CSV).
• Delivery of data should be in a secure and
  standardized format, and should leverage use of
  Energy Services Provider Interface (NAESB REQ
  21).
• No fees shall be assessed, but IOUs can request a
  change in the next scheduled GRC

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Energy Data Access Committee

• To provide assistance to IOUs energy data access
  programs
• Consider informally any disputes between
  requestors and IOUs (CPUC retains authority to
  officially arbitrate disputes)
• Consist of representatives of the IOUs, CPUC,
  ORA, CEC, researchers, customer and privacy
  advocacy groups, and other interested parties.
• Will meet at least once a quarter for first two
  years, then as needed thereafter.
• First meeting was held earlier this month.
• The goal of this Committee is to serve as a
  forum for evaluating progress, informally
  resolving disputes, considering next steps,
  introducing new ideas, and identifying problems
  with the utilities implementation of the orders
  in this decision, and thus, narrow the scope of
  differences considerably. D.14-05-016 at 99.

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For Further Information

• CPUC Smart Grid webpage
• http//www.cpuc.ca.gov/PUC/energy/smartgrid.htm
• Chris Villarreal
• Policy and Planning Division
• Phone [phone]
• Email crv_at_cpuc.ca.gov