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Comments to California Public Utilities Commission

Comments submitted on October 26, 2009
Comments submitted on February 9, 2009

Proceeding R08-12-009
(Filed December 18, 2008)

Order Instituting Rulemaking to Consider Smart Grid Technologies Pursuant to Federal Legislation and on the Commission’s Own Motion to Actively Guide Policy in California’s Development of a Smart Grid System

COMMENTS OF GOOGLE INC. ON PROPOSED POLICIES AND FINDINGS PERTAINING TO THE SMART GRID POLICIES ESTABLISHED BY THE ENERGY INFORMATION AND SECURITY ACT OF 2007

Google Inc. files these comments in response to the Assigned Commissioner and Administrative Law Judge’s Joint Ruling Inviting Comments on Proposed Policies and Findings Pertaining to the Smart Grid Policies Established by the Energy Information and Security Act of 2007, issued September 28, 2009 (Joint Ruling). Our comments address three issues raised by the Joint Ruling:

• How to facilitate customer access to near real-time energy usage and pricing information;
• Additional steps the Commission should take to provide customers access to energy usage and pricing information;
• Potential rules regarding the relationship between the IOU, customers and third-party providers.

One of the central benefits of the smart grid is its ability to empower consumers with better information and tools for managing their energy use. To do so, policies must ensure that advanced metering infrastructure (AMI) provides consumers energy usage and pricing information in a manner that is relevant, easily accessible, understandable and actionable. Policies should also foster the development of an ecosystem of energy-saving applications and programs that will benefit both consumers and the grid.

California has been at the forefront of smart grid development in this country, largely due to the leadership of this Commission and the state’s three major investor-owned utilities (IOUs) and other utilities in moving forward with advanced metering. Now that AMI deployment is underway, the Commission must act without delay to ensure that consumers can easily access the information captured by their advanced meters and use that information to save energy and money.

At Google, we believe that the smart grid is as much about defining new ways to generate and exchange useful information as it is about finding smarter ways to deliver and use energy. Therefore, successful principles that have guided the deployment of information networks may be a useful guide as the Commission establishes policies for accessing energy information. These include open standards, competition, consumer choice and empowerment, and encouraging and keeping pace with rapid changes in technology while protecting consumer privacy and security.

With these principles in mind, we offer the following comments:

I. Access to near real-time data

The Joint Ruling seeks comment on how to facilitate customer access to near real-time energy information. The approved AMI projects for the three IOUs anticipate that consumers will be able to access usage and pricing information in near-real time directly from the meter via a home area network (HAN). However, as the Commission recently noted in a filing to the Federal Communications Commission, although 1.5 million smart meters have been installed in California, "the utilities have not yet activated the HAN signal on these meters as some of the key standards and security protocols (necessary to ensure a robust experience by the consumer) are yet to be completed by the respective standards bodies."¹

As the National Institute of Standards and Technology (NIST) and other standards bodies continue to move forward on the standards process regarding HANs, we understand why there is a desire to delay HAN enabled devices until the standard settles a bit more to help avoid stranded assets - both for consumers as well as utilities. However, consumers should not wait an indeterminate amount of time before they start seeing the benefits of their investment in the smart grid. The standards process for home area networking has made significant progress since the Commission approved the AMI rollouts. At least one nationally recognized standard for HANs has already been released (Zigbee 1.0) and a second version (Zigbee 2.0) with improved networking and security protocols should be available next year. Most advanced meters can be remotely upgraded as standards evolve. For these reasons, the Commission should not delay moving forward with plans for enabling the HAN environment.

To this end we recommend that the Commission set a deadline – the end of 2010 at the latest – to ensure that consumers will be able to access their meter data directly so that the HAN environment continues to make rapid forward progress. By that time, improved networking and security protocols should be available. We further recommend that the Commission initiate a process now to ensure the timely development of rules and procedures for how consumers will securely pair their HAN devices with their advanced meters. As part of these rules, the Commission should ensure that any consumer who purchases a HAN device that is compatible with their meter should be able to access their meter data directly upon request.

II. Widespread access to energy information

The energy savings captured by giving consumers direct feedback about their energy usage are well documented and are on the order of 5-15 percent, simply from behavioral changes.² For California to truly capture this vast untapped energy efficiency resource, Commission policy must seek to maximize the total number of consumers who are using this information to save energy. As the Commission notes in its Joint Ruling, once a residential customer has received a meter, he or she will have access to energy usage information in one-hour intervals via utilities’ websites with a one-day lag. The Commission should ensure that this data collected from the meters by the utilities (i.e., "backhaul data") can be easily accessed by customers. Although typically not available in near real-time, it is useful and should be made easily accessible to customers who choose not to purchase HAN devices. To maximize the number of customers who access the data, the Commission should ensure that it can be made available through third party providers (with consumer permission) in addition to utility websites.

Secure access to this data by consumers and consumer-selected third parties can be facilitated in a number of ways. For example, the Texas Public Utility Commission has approved the development of a common web portal and data repository that will allow customers to access their electricity consumption data beginning in early 2010. Utilities will be required to make 15-minute interval meter data available to the portal within 24 hours. Customers will be able to establish accounts on the portal that will allow them to access their energy information or select a third-party energy information provider. The portal will also be used to register in-home HAN devices. The system includes a number of measures to protect privacy and security, including independent security audits of the portal.³

In California, utilities have proposed creating their own online systems to facilitate access to interval data generated from advanced meters. For example, San Diego Gas and Electric (SDG&E) has proposed using a "Customer Energy Network" (CEN) service to facilitate customer and third party access to interval data. The CEN service will allow for electronic authorization and transmittal of customer data to authorized third party providers at their request. According to SDG&E, the CEN will initially utilize data format standards developed with their third party providers. SDG&E expects to migrate to a generally accepted, open-standard once such a format is established and made available.⁴ PG&E has proposed allowing customers and customer-authorized third parties to access account data through an "Automated Data Exchange" (ADE). However, the initial ADE application was postponed for two years and a second request has been made to delay implementation of the system for another two years until national standards are developed.⁵

As we note above, we believe that the national standards process is not a sufficient reason for delaying plans to facilitate consumer and third party access to advanced meter data, particularly given the progress that has been made on developing standards in this field. For interoperable data exchanges like those that would be used to facilitate backhaul data, a nationally recognized data standard is currently under development by the OpenADE Committee of the Utility Communications Architecture (UCA) users group and expected to be released next year. In the meantime, utilities such as SDG&E and the State of Texas have developed their own data formats and are not delaying plans to make backhaul data available to customers and customer-selected third party providers in a manner that protects customer security and privacy.

We recommend that the Commission act without further delay to initiate and develop plans to ensure consumers have easy access to backhaul data via utility websites and third parties they choose. The Commission should look at the work of our own IOUs, the State of Texas, and others for possible models on how to best facilitate easy and widespread access to this data by consumers and consumer-selected third parties and should ensure that consumer privacy and security are protected.

As part of this process, we also encourage the Commission to examine how to improve the quality of the data made available to consumers. For example, information provided in 15- minute instead of one-hour increments, even if a day old, can enable consumers to make even better informed energy decisions by giving them a greater ability to identify specific appliances based on a recollection of when they were used. As the Commission develops guidelines for how to facilitate access to data, it should consider how to ensure that consumers see improvements in granularity and timeliness of data as networking technology improves and costs come down. The pace of change of innovation and technology -- particularly networking technology -- is fast. The Commission's policies should keep pace with these changes. Success should be defined as growing numbers of consumers reaping the energy benefits from information at low or no additional cost.

III. Third party access

The Commission has asked for feedback on potential rules regarding the relationship between IOUs, customers and third party providers. Third party service providers offer the means to better engage consumers by making data available to them in ways that can be integrated into the daily lives of consumers (e.g, internet, smart phones). Third parties can also bring even greater innovation to the system through energy-saving applications and services. For example, a third party provider could offer consumers a service that analyzes energy use, identifies inefficient appliances, provides appliance discounts or suggests energy management practices.

To drive innovation and customer choice, the Commission should ensure that its policies maximize the opportunities for third party participation. As a general principle, the customer should have the opportunity to choose which third party he or she uses and the customer should have many choices. "One size fits all" solutions which lock in a single third party service provider or a single solution for all of a utility’s customers will almost certainly stifle innovation and consumer choice.

As we note above, the Commission should initiate a process to provide clarity on rules for customer and customer-selected third party access to usage and pricing data. As part of this effort, the Commission should ensure that its policies will keep pace with changes in technology, encourage innovation, and ensure that consumers can reap the full benefits of metering and information technology. For example, to facilitate rules and resolve technical issues expeditiously, the State of Texas employed a facilitated, stakeholder process to address issues around development of a centralized web portal, third party access to data, and privacy and security.⁶ Other options for the Commission to consider include hosting workshops, holding periodic reviews and launching targeted pilots.

IV. Conclusion

California has been a leader in energy efficiency programs and advanced smart grid deployment. We have the technology and the skills to ensure that California consumers will be first in the nation to get the best technologies and the most effective control over energy consumption. The Commission should continue to push for quick implementation of the necessary policies. We know that Commission action has brought innovation, competition and the highest energy savings per capita in the country. Google strongly urges California to sustain our frontrunner status.

Respectfully submitted,

MICHAEL TERRELL
Policy Counsel
Google Inc.
1600 Amphitheatre Pkwy.
Mountain View, CA 94043
Ph: 650-214-6398
Fax: 650-253-0001
mterrell@google.com

October 26, 2009

Proceeding R08-12-009

Order Instituting Rulemaking to Consider Smart Grid Technologies Pursuant to Federal Legislation and on the Commission’s own Motion to Actively Guide Policy in California’s Development of a Smart Grid System.

COMMENTS OF GOOGLE ON SMART GRID TECHNOLOGY DEPLOYMENT IN CALIFORNIA

I. Introduction and Summary

Pursuant to the Order Instituting Rulemaking in this docket dated December 18, 2008, Google Inc. (Google) respectfully submits responses to questions concerning smart grid policy posed by the California Public Utilities Commission (Commission).1 

Google’s mission is to organize the world's information and make it universally accessible and useful.  Our philanthropic arm, Google.org, uses the power of information and technology to help solve major global challenges, such as climate change.  We believe that by building a "smarter" electricity grid, we can use the synergies of information and technology to give consumers better tools to track and reduce their energy use and, by doing so, save money and reduce greenhouse gas emissions.  We believe that consumers have the right to know how much energy they are using and how much it costs, and to have that information available in a format that is easily accessible and understandable.  We also believe that smart grid policy should facilitate the development of tools and programs that will enable consumers to make informed choices about their energy use and participate in third-party demand-response programs. 

Accordingly, Google urges the Commission to include the following principles in its smart grid policy, discussed in greater detail below:

• Consumers should have direct access to real-time electricity usage information.
• Electricity usage information should be freely available to consumers.
• Electricity usage data should be made available in a standardized, open format, freely available to third-parties with permission from the consumer. 

Commission policy should ensure that utility smart grid installations and technology are open and compatible with tools and products that could help consumers manage their energy demand in ways that benefit everyone.  In particular, California’s smart grid strategy should pursue the goal of providing consumers with real-time feedback on their electricity usage, ideally as part of a Home Area Network (HAN).  This data should be made available in a standardized, open format to facilitate the development of a range of products to help consumers decrease and manage their energy demand, saving them money and reducing the utility’s load demand, especially at peak times.

Currently, the utility owns the electricity meter and generally provides customers with aggregated meter information only once a month, with little context or analysis that might help customers understand their home energy consumption.  If this practice continues, "smart meter" deployment could miss the opportunity to educate consumers about energy use and encourage energy savings and support for cleaner energy sources. 

Google is pleased that California has been at the vanguard of deploying Advanced Metering Infrastructure (AMI), and hopes that the Commission will focus on related issues discussed in these comments as it develops smart grid policy.  This proceeding occurs during a critical time as the country debates how to reframe our national energy strategy.  Transforming the nation’s electricity grid is high on the list of energy priorities for the new Administration and Congress.  Major support for smart grid investments is part of the economic stimulus legislation currently under consideration in Washington.  Abroad, several countries are moving forward with major AMI deployments and grid rebuilding efforts of their own.  Given California’s leadership on energy efficiency, and most recently on large-scale AMI deployment, this proceeding is an ideal forum to inform and advance these national and international efforts.  Accordingly, we hope this proceeding will produce a detailed strategic plan for smart grid that articulates a long-term vision and goals and identifies clear strategies for achieving those goals.  We hope the end result will empower consumers with more information, more tools and more choices to manage their energy use.

II.        Benefits of Providing Real-Time Electricity Usage Data

Federal smart grid policy recognizes the importance of providing consumers with access to electricity usage information.2  California is at the forefront of smart grid policy development in the United States and we encourage the Commission to go beyond the federal standard to ensure that consumers have access to their electricity consumption data in real-time.  Research consistently shows that providing consumers with real-time information about their electricity usage triggers a reduction in electricity demand.  One review of research on the effects of providing immediate feedback on electricity usage found that overall demand reductions generally ranged from 5 to 15%.3 

A pilot study of real-time energy use feedback monitors in Ontario, for example, followed the electricity consumption of over 400 pilot participants and control customers over a 2.5 year period.4  The average reduction in overall electricity consumption across the sample was 6.5%, and energy demand reductions continued throughout the study period.  Because participants were not given any price or conservation incentives beyond the expected reduction in the monthly electricity charge from decreased usage, the researchers believe this is the minimum demand reduction that would be expected and would likely be increased with the provision of educational materials, tips on conservation or dynamic pricing measures.

Such energy savings can be enhanced when combined with programmable appliances and dynamic energy pricing.  A study conducted by the Pacific Northwest National Laboratory5 gave customers in Oregon and Washington access to energy consumption information broken down by appliance every fifteen minutes, and allowed them to program their water heaters and thermostats to respond to changes in electricity prices.  Participants received cash when they operated their household loads in collaboration with the needs of the grid—i.e., when they reduced their energy usage at times of peak energy demand.  Over the year of the study, peak load on the grid was reduced by approximately 15% and consumers saved approximately 10% on their electricity bills as compared to the previous year.  Based on these results, the authors determined that if all customers nationwide were engaged in reducing peak loads, peak electricity prices would be substantially reduced and approximately $70 billion in new generation, transmission, and distribution systems could be avoided, with the savings passed along to ratepayers.

The benefits of consumer energy savings in the 5-15% range scale up very quickly both in terms of cost savings and CO2 emission reductions.  As the average U.S. residential customer spends about $1,200 a year on electricity,6 a real-time feedback monitor could save a consumer $60 to $180 per year.  If just half of U.S. households cut their demand by 10%, the electricity savings would be greater than today’s total U.S. wind and solar power output.7  The CO2 emissions avoided would be equal to taking approximately 8 million cars off the road.8  And with the addition of dynamic pricing, programmable appliances, and other incentives, the potential for savings could be significantly greater.

III.       Options for Delivering Electricity Usage Data

Electricity usage information can be provided to customers in a wide variety of ways, ranging from displays in the home to online formats.  Google has developed a software tool called Google PowerMeter, now in prototype, which draws data from utility smart meters and energy management devices to give people access to their home electricity consumption.  The default view shows the current day’s energy consumption compared to the previous day’s, but the graph can easily be extended further back in time to look for peaks, troughs and other outlying data points.  Our tool is free and scalable, and we plan to release the technical specifications (application programming interfaces or API) so anyone can build applications from it.  Importantly, however, the Google tool is only one of many ways to provide consumers with this information.  Our primary goal is for consumers to get this information, whether through our tool or another source.

IV.       Access to Electricity Data and Open Data Format

We commend the Commission for moving forward with the AMI initiative for the State’s investor owned utilities.  We believe that any long-term plan for smart grid development in California should include the following additional elements:

1.   Access to data

• Consumers should have easy access to real-time electricity usage data.  Real-time usage data provides consumers with immediate feedback on how their behaviors are affecting their electricity consumption.  Consumers should have easy access to this information so they can make more informed decisions about their energy use.  And down the road, consumers should have access to additional information such as the source and mix of their power.
  
  In order to achieve the greatest potential for energy savings, consumers should receive information as part of an open ecosystem of hardware and software for energy monitoring, home automation, device control and demand response that uses the data available via a smart meter.  For that to happen, the data from the smart meter needs to be available to the consumer in real-time and in a non-proprietary format.  While we recognize there are some limitations today on the ability of utilities to provide data to customers in this manner (even with AMI), we believe that advances in Home Area Network technologies will make this entirely possible in the near future. 
  
• Consumers should have similar access to electricity pricing information, including 24-hour electricity price forecasting.  Better pricing information will allow electricity consumers to make more rational consumption choices, resulting in cost savings for consumers and reduced peak demand for utilities.  As the Commission’s State Pricing Pilot demonstrated, dynamic pricing combined with technology to automate demand response can reduce peak demand on critical days by as much as 27%.9  Reducing peak demand also reduces the need for extra generation to meet spikes in energy demand.
  
  
• Electricity usage information should be freely available to consumers since it belongs to them.  The Commission should provide clarity on ownership of data and ensure that consumers do not incur any direct costs for accessing their data.  If the consumer grants permission, this information should be provided free of charge to third-parties to enable the implementation of electricity usage feedback tools and related demand side management technologies.

2.   Open data format 

• Electricity usage and pricing data should be made available in a standardized, open format.  Consumer data should be made available (with permission from the consumer) to third parties in a standardized, open format – i.e., a format that is standardized, freely published, and unencumbered by a patent or proprietary claim.  The goal is to foster a thriving ecosystem of partners where third-parties develop and provide products to help consumers decrease and manage their energy demand and save money.  For example, a third-party could offer a service that analyzes a household's electricity usage data, identifies inefficient appliances or practices in the home, and offers tips on how to reduce energy or provides special discounts on efficient appliances or electronic equipment.  
  
  
• Consumer electricity usage data should be kept private unless the consumer grants permission for a third-party to access the information. Consumers should have full control over who is given access to their data. 

The Public Utility Commission of Texas has also recognized the importance of these consumer information policies.  Under Texas policy, AMI must be capable of providing consumers with direct, real-time access to electricity usage data, and that data must be stored on the meter in a form that complies with nationally-recognized non-proprietary standards.  The AMI must also be capable of communicating with other devices on the premises, such as monitoring devices, load control devices, and prepayment systems.   Further, the Texas legislature has established that consumers own their energy usage data.10  As AMI is deployed in the state of Texas, consumers will not have to pay an additional fee or have to obtain special permission to view their data.11  We believe the Texas legislature and PUC’s analyses of these issues are sound, and should be given careful consideration.

V.        Conclusion

Google strongly urges the Commission to continue to develop smart grid capabilities in California, and to adopt policies that direct the provision of electricity usage data to consumers in real-time.  This will allow consumers to have greater understanding of, and control over, their electricity usage, and will reduce energy demand and the need to build new generation.  Electricity demand reductions will in turn produce savings for consumers and utilities and reduce greenhouse gas emissions.  Towards this end, one of the principles that should guide the Commission’s decisions in this proceeding is the interoperability of a smart grid with end user services that will facilitate consumer demand management.  As we shift to a smart grid and advanced metering devices, it is essential that Commission policy encourages innovation and allows customers free and straight-forward access to their energy usage information.

Google appreciates the opportunity to present these comments and looks forward to participating further in this important proceeding. 

Respectfully submitted on the 9th of February 2009,

Bill Coughran
Senior Vice President, Engineering
Google Inc.

Dan Reicher
Director, Climate Change and Energy Initiatives 
Google.org

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