To implement the Inflation Reduction Act (IRA) Home Energy Rebate Programs, state energy offices will need to address how to obtain access to consumer energy data and use it to better inform program design and customer outreach. Energy data can provide insight into customer energy use and behaviors. Unlocking this data can enhance energy efficiency programs by identifying new ways to save energy and can foster equitable program design and delivery. Additionally, making data accessible can educate and empower customers to better manage their own energy use in homes, large buildings, and even entire communities.
Many states do not have programs to access, protect, and utilize data. To help in this effort, the DOE’s Utility Data Access Guidelines detail requirements and optional best practices for utility data management practices. The guidance asks states to submit a data access plan, in partnership with utilities, that will determine how to gather data safely and securely and standardize access.
The guidance lists six key areas of a successful utility data access plan:
- Security and Safety of Energy Consumption Data
- Consent, Notification, and Revocation Process
- Eligibility of Third Parties
- Data Aggregation and Anonymization
- Quality and Accessibility of the Data (Quality/Frequency)
- Oversight and Enforcement
These guidelines focus on ensuring that customer data is shared only with relevant stakeholders (policymakers and third-party implementers) to keep personal data as secure as possible. Effective communication of data sharing arrangements between states, utilities, customers, third parties, and any other relevant stakeholders is crucial to building a trustworthy data sharing ecosystem.
There are several elements that states must include in their data access plans:
- Security information:
- Descriptions of encryption used during data transfers and for data at rest
- Third-party authentication procedures for accessing data
- Protocols by which the organization adheres to the established security guidelines and data classification system
- Framework for identifying and responding to data security incidents
- Defined process by which customers can provide consent to data sharing prior to participation.
- Defined purpose of energy consumption as primary or secondary (when providing data to third parties).
- Primary purpose consumption is defined as data use to perform “essential functions based on program path such as measuring energy savings or fulfilling program and legal requirements.”
- Secondary purpose consumption is defined as the “use of customer data in outreach and education and additional product offerings that the customer does not already receive or has not authorized.”
By providing these up-front ground rules around how data will be kept secure, which parties will have access, and how data will be used, data can be shared in ways that benefit all stakeholders.
Given the degree to which states may also work with third parties in different aspects of energy programs, it is also important to lay out guidelines for third-party eligibility criteria for any entity that will be using customer utility data. States are encouraged to establish processes and enforcement mechanisms that govern third parties’ ability to handle data safely and implement effective programs. There are existing resources that states can use as examples when establishing these criteria:
- DOE’s 2015 Voluntary Code of Conduct: Final Concepts and Principles for Data Privacy and the Smart Grid or a similar nationally accepted eligibility standard approved by the regulator
- Existing eligibility criteria developed by utilities, regulators, or other programs (e.g., California, New York, and Texas)
Finally, it’s important that data access plans enforce accountability for third parties that participate in data sharing arrangements. States should designate an organization or regulatory authority to police third parties that are not adhering to all program protocols. Data access plans should also describe processes for handling complaints against third parties; methods by which utilities can review, terminate or suspend third-party implementers; and contractual terms that protect customers from potential bad actors. The DOE recommends looking at enforcement procedures from utility contracts with third parties, as well as specific examples from California, New Hampshire, and Texas.
- Develop secure data protection and install protocols to demonstrate an ability to safely transfer data to relevant stakeholders. The DOE recommends using Green Button’s Connect My Data standards and the North American Energy Standards Board (NAESB)’s model business practices guides as models for effective policies.
- Implement a benchmarking strategy to be able to assess building energy usage over time. The EPA Benchmarking and Building Performance Standards Policy Toolkit provides helpful advice and resources for developing benchmarking policies, and the EPA’s Energy Star team is available to provide technical assistance upon request.
- Design rules governing data aggregation and anonymization, which allow for the compilation of customer data and permit third-party use without risking compromising customer privacy. The DOE recommends using the EPA Portfolio Manager Tool to create data collection practices and methodologies to deliver the data to relevant requestors.
- Outline the customer consent, notification, and revocation process by which utility customers are informed of data sharing and can decide whether to participate. There are multiple ways to structure this process, such as opt-in, opt-out, and aggregated models (more detail on each can be found in the DOE Data Access Guidelines).
There are many other helpful suggestions in the full Data Access Guidelines - we recommend reading the whole piece (only nine pages!) to get a comprehensive overview.
Energy Sector Transformation
Laying the groundwork for a strong data sharing arrangement allows states to create lasting change in their energy sectors by improving efficiency, lessening strain on the electric grid, and lowering energy burden for customers. NEEP, the DOE, and the EPA are but a few of the many sources that offer technical assistance in developing these plans. By using IRA funding, states will be able to make proactive investments in energy infrastructure that will provide returns for both utilities and ratepayers for years to come.
Please register for NEEP's October 19 Ready, Set, Scale webinar on data access to learn more.