Implementing the National Broadband Plan by Empowering Consumers and the Smart Grid: Data Access, Third Party Use, and Privacy, 26203-26206 [2010-11127]
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Federal Register / Vol. 75, No. 90 / Tuesday, May 11, 2010 / Notices
Emery LLP, 600 13th Street, NW.,
Washington, DC 20005. A final decision
will be made on this application after
the environmental impacts have been
evaluated pursuant to the National
Environmental Policy Act of 1969, and
a determination is made by DOE that the
proposed action will not adversely
impact on the reliability of the U.S.
electric power supply system.
Copies of this application will be
made available, upon request, for public
inspection and copying at the address
provided above, by accessing the
program Web site at https://
www.oe.energy.gov/
permits_pending.htm, or by e-mailing
Odessa Hopkins at
Odessa.hopkins@hq.doe.gov.
Issued in Washington, DC, on May 5, 2010.
Anthony J. Como,
Director, Permitting and Siting, Office of
Electricity Delivery and Energy Reliability.
[FR Doc. 2010–11131 Filed 5–10–10; 8:45 am]
BILLING CODE 6450–01–P
DEPARTMENT OF ENERGY
Implementing the National Broadband
Plan by Empowering Consumers and
the Smart Grid: Data Access, Third
Party Use, and Privacy
AGENCY:
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ACTION:
Department of Energy.
Request for Information.
SUMMARY: The Department of Energy
(DOE) is seeking comments and
information from interested parties to
assist DOE in understanding current and
potential practices and policies for the
states and other entities 1 to empower
consumers (and perhaps others) through
access to detailed energy information in
electronic form—including real-time
information from smart meters,
historical consumption data, and
pricing and billing information. This
request for information (RFI) asks
interested parties, including industry,
consumer groups and State
governments, to report on State efforts
to enact Smart Grid privacy and data
collection policies. This RFI also seeks
input regarding individual utility
practices and policies regarding data
access and collection; third party access
to detailed energy information; and the
role of the consumer in balancing the
benefits of access and privacy. Finally,
this RFI seeks comment on what
policies and practices should guide
policymakers in determining who can
1 e.g. municipalities, public power entities and
electric cooperatives.
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access consumers’ energy information
and under what conditions.
DATES: Comments must be postmarked
by no later than July 12, 2010. Reply
comments must be postmarked by no
later than July 26, 2010.
ADDRESSES: You may submit comments,
identified by ‘‘NBP RFI: Data Access,’’ by
any of the following methods:
Federal eRulemaking Portal: https://
www.regulations.gov. Follow the
instructions for submitting comments.
E-mail: broadband@hq.doe.gov.
Include ‘‘NBP RFI: Data Access’’ in the
subject line of the message.
Mail: U.S. Department of Energy,
Office of the General Counsel, 1000
Independence Avenue, SW., Room
6A245, Washington, DC 20585.
FOR FURTHER INFORMATION CONTACT:
Maureen C. McLaughlin, Senior Legal
Advisor to the General Counsel (202)
586–5281; broadband@hq.doe.gov.
For Media Inquires you may contact
Jen Stutsman at 202–586–4940.
SUPPLEMENTARY INFORMATION:
Introduction
The promise 2 of the Smart Grid is
enormous and includes improved
reliability, flexibility and power quality,
reduction in peak demand, reduction in
transmission congestion costs,
environmental benefits gained by
increased asset utilization, increased
security, increased energy efficiency
and increased durability and ease of
repair in response to attacks or natural
disasters. But the Smart Grid also
presents new challenges. In particular,
many of its benefits could be reduced or
delayed and avoidable harms caused
unless the Smart Grid adequately
respects consumers’ reasonable—and
often widely differing—expectations of
privacy, expectations that could be
compromised if detailed household
energy consumption data is made too
readily available, too inaccessible, or
incorrectly anonymized. The Smart Grid
is also likely to create a far more
interactive relationship between utilities
and consumers that will raise new
questions about how to ensure that
detailed energy data is properly
collected, reported, managed, shared
and disclosed in ways that are both
lawful and adequately transparent to
consumers.3
2 A smart meter is a good example of an enabling
Smart Grid technology that can empower both
utilities and consumers to extract value from twoway communications and real-time access to usage
data. Smart meters play an important role in the
success of the Smart Grid because they can generate
an array of useful data including historical energy
consumption data, real-time data, and price-anddemand-response data.
3 Dep’t of Energy, What the Smart Grid Means to
Americans, 2, 23 (Aug. 31, 2009), available at
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This RFI seeks to collect information
and open a dialogue about the
challenges inherent in empowering
consumers, utilities, and third parties to
realize the many potential benefits of
the Smart Grid, while protecting
reasonable consumer expectations of
privacy and security, and ease-of-access
and providing the flexibility to manage
both.
In the context of the Smart Grid,
privacy and access are not so much
conflicting goals as they are
complementary goods: the value of the
Smart Grid to consumers, utilities, and
third parties depends upon its capacity
to encourage and accommodate
unpredicted innovations while making
usage data reasonably available to those
who should have it and respecting
consumers’ reasonable interests in
choosing how to balance the benefits of
access against the protection of personal
privacy and security. Only solutions
that accommodate all of these critical
values will maximize the value of the
Smart Grid to consumers, utilities,
third-party service providers and
innovators, and State and Federal
governments.
Background
In early 2009, Congress directed the
Federal Communications Commission
(‘‘FCC’’) to create the recently released
National Broadband Plan (‘‘NBP’’).4 As
Congress instructed, the NBP makes
recommendations to various
government entities, including
Executive Branch agencies like DOE. In
particular, the NBP recommended that
DOE should consider consumer data
accessibility policies when evaluating
Smart Grid grant applications, report on
states’ progress toward enacting
consumer data accessibility policies,
and develop best-practices guidance for
the states.5 More generally, the NBP’s
recommendations seek to modernize the
electric grid with broadband by
increasing reliability and efficiency, to
unleash energy innovation in homes
and buildings by making energy-usage
data readily accessible to consumers,
and to improve the energy efficiency
and environmental impact of the
Information and Communication
Technologies (ICT) sector by integrating
broadband into the developing Smart
Grid.
These new recommendations
recognize and build upon DOE’s years
https://www.oe.energy.gov/DocumentsandMedia/
ConsumerAdvocates.pdf.
4 Fed. Commc’n Comm’n, Connecting America:
The National Broadband Plan, https://
www.broadband.gov/plan/ (last visited Apr. 26,
2010).
5 Id.
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Federal Register / Vol. 75, No. 90 / Tuesday, May 11, 2010 / Notices
of ongoing efforts to assess, implement
and deploy Smart Grid technologies.
These ongoing efforts implement
existing legislation intended to
encourage the use of such technologies
to attain greater energy independence
and security.
The Energy Independence and
Security Act (EISA) of 2007 established
‘‘modernization of the nation’s
electricity transmission and distribution
system’’ as a U.S. policy goal.6 Among
other things, EISA directed DOE to
establish a Smart Grid Task Force whose
responsibilities include developing
widely accepted smart-grid standards
and protocols.7 EISA also directed the
National Institute of Standards and
Technologies (NIST) to develop a
framework of standards and protocols to
ensure interoperability and security for
the Smart Grid.8 Once the Federal
Energy Regulatory Commission (FERC)
concludes that NIST has developed
‘‘sufficient consensus,’’ EISA then
directs FERC to ‘‘institute a rulemaking
proceeding to adopt such standards and
protocols as may be necessary to insure
smart-grid functionality and
interoperability in interstate
transmission of electric power, and
regional and wholesale electricity
markets.’’ 9 On July 16, 2009, FERC
issued a Policy Statement on Smart Grid
Policy, which acknowledged that EISA
does not make any such standards
mandatory and gave FERC no new
authority to enforce such standards.10
For more than two years, DOE–NIST–
FERC coordination on these standards
has been ongoing through the Federal
Smart Grid Task Force, the EISAmandated group that involves agencies
from across the Federal government.11
Section 1307 of EISA also amended
section 111(d) of the Public Utilities
Regulatory Policy Act (PURPA) by
adding two paragraphs regarding the
Smart Grid, paragraphs 18 and 19 in 16
U.S.C. 2621(d).12 As amended, PURPA
requires states and other entities to
decide whether to adopt a policy
requiring its electric utilities to show
why they did not invest in qualified
smart grid technologies before investing
in non-advanced grid technologies.13 In
6 42
U.S.C. 17381 (2010).
Section 17383.
8 Id. Section 17385(a).
9 Id.
10 Smart Grid Policy Statement, 128 F.E.R.C. ¶
61,337, at 61,060–359 (Jul. 16, 2009).
11 Cyber Security: Before the S. Comm. On Energy
and Natural Resources, 111th Cong. 1 (May 7, 2009)
(Statement of Patricia Hoffman, Acting Assistant
Secretary, Office of Electricity Delivery and Energy
Reliability, U.S. Department of Energy).
12 Public Utilities Regulatory Policy Act of 1978,
16 U.S.C. 2621(d) (2010).
13 Id. Section 2621(c)(16).
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7 Id.
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addition, states and other entities must
consider imposing requirements for
information disclosure to customers and
others regarding price, usage, intervals
and projection, sources and customer
access to their own electric
consumption information at any time
through the Internet or other means
elected by the utility for Smart Grid
applications. EISA requires that states
and other entities make such decisions
no later than 2 years after December 19,
2007.14
DOE’s Preliminary Review of Some
Ongoing Federal and State Efforts to
Implement the Smart Grid-Related
Obligations Imposed by EISA and
PURPA
To advance its ongoing policies and
programs, to implement certain
recommendations in the NBP, and to
focus this RFI, DOE initiated an
informal, high-level review of the status
of ongoing Federal, State, and private
efforts to implement the Smart Grid
related provisions of EISA and PURPA.
Even this informal review reveals some
of the important issues arising as
Federal, State and private entities have
begun developing, deploying, and
implementing Smart Grid technologies.
The following summary is intended to
highlight a few of these issues.
Various entities are consulting an
array of guidelines and principles when
framing their approaches to access-andprivacy issues. For example, to further
coordinate development of a framework
to achieve interoperability of Smart Grid
devices and systems, including
protocols and model standards for
information management, NIST released
Draft Interagency Report 7628 (Feb.
2010)—Smart Grid Cyber Security:
Strategy and Requirements.15 This Draft
NISTIR was developed by members of
the Smart Grid Interoperability PanelCyber Security Working Group (SGIP–
CSWG).16 The Draft Report focuses on
security and privacy, two areas that will
be important to the success of SmartGrid development, deployment and
implementation.17
The SGIP–CSWG Privacy Sub-group
conducted a high-level privacy impact
assessment (PIA) for the consumer-toutility portion of the Smart Grid and
considered the privacy impacts and
risks throughout the entire Smart Grid
structure. While the evolving Smart
14 Id.
Section 2622(b)(6).
Coordination Task Group, Smart
Grid Cyber Security Strategy and Requirements,
Draft NIST Report 7628 (Feb. 2010), available at
https://csrc.nist.gov/publications/drafts/nistir-7628/
draft-nistir-7628_2nd-public-draft.pdf.
16 Id. at 3.
17 Id. at 1.
15 Cybersecurity
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Grid will provide enormous societal
benefits including better asset
utilization and grid reliability, it will
also present potential privacy risks. The
ability to access, analyze and respond to
much more precise and detailed data
from all levels of the electric grid is one
of the major benefits of the Smart Grid,
but those benefits could be lost or
substantially delayed unless consumers
recognize that Smart Grid technologies
also respect their reasonable
expectations of privacy and data
security, particularly when usage data
and data extrapolations can be
associated with individual consumers or
locations.18 The PIA also noted that
State utility commissions currently lack
formal privacy policies or standards
related to the Smart Grid, and that
comprehensive and consistent
definitions of privacy-affecting
information with respect to the Smart
Grid typically do not exist at State or
Federal regulatory levels, or within the
utility industry.19
As a result of the assessment, the
Privacy Sub-group developed a
preliminary set of privacy principles
using the following sets of widely
accepted privacy principles: The OECD
Privacy Principles, the Generally
Accepted Privacy Principles (GAPP),
and principles from the international
information security standard ISO/IEC
27001. The Sub-group considered these
to be very general privacy principles
designed to be applicable across a broad
range of industries; they are not
mandatory requirements.20 These
privacy principles are: Management and
accountability; notice and purpose;
choice and consent; collection and
scope; use and retention; individual
access; disclosure and limiting use;
security and safeguards; accuracy and
quality; and, openness, monitoring, and
challenging compliance.21
Another potential framework for
considering privacy and consumer
security issues is the Fair Information
Practice Principles (FIPPs) adopted by
the U.S. Department of Homeland
Security (DHS).22 The FIPPs form the
basis of the Department’s privacy
compliance policies and procedures
governing the use of personally
identifiable information (PII). These
18 Id.
at 8.
at 103.
20 Id. at 104.
21 Id. at 104–109.
22 Cal. Pub. Util. Comm’n, 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, Pub. Util. No. 08–12–009 (Dec. 18, 2009),
available at https://docs.cpuc.ca.gov/published/
FINAL_DECISION/95608.htm.
19 Id.
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principles are: Transparency, Individual
Participation, Purpose Specification,
Data Minimization, Use Limitation, Data
Quality and Integrity, Security, and
Accountability and Auditing.23
The FIPPs are a widely accepted
framework that implement the core
provisions of the Privacy Act of 1974
and are mirrored in the laws of many
U.S. states, as well as the laws of many
foreign nations and international
organizations.24
While Federal entities have been
analyzing the privacy and security
implications of the Smart Grid, State
public utilities commissions have been
conducting their own inquiries and
rulemakings on consumer access to
energy-usage data. For example, on
December 29, 2009, the California
Public Utilities Commission issued
Decision 09–12–046, Decision Adopting
Policies and Findings Pursuant to the
Smart Grid Policies. 25
The decision adopts policies for the
three major investor-owned public
utilities (SCE, PG&E, and SDG&E) on
consumer access to usage and price
information that will be available
through California’s Smart Grid
infrastructure; these include a policy
goal that SCE, PG&E, and SDG&E
provide consumers with access to
electricity price information by the end
of 2010. The decision also requires that
SCE, PG&E, and SDG&E provide
consumers and third parties approved
by consumers with collected usage data
by the end of 2010, as well as requiring
that SCE, PG&E and SDG&E provide
those customers with smart meters and
authorized third parties with access to
usage data on a near real-time basis by
the end of 2011.26 The Commission held
a separate workshop on March 19, 2010
to consider the best methods for
providing access to electricity prices
and usage data, due to the high level of
interest in the proceeding.
In 2007, The Public Utility
Commission of Texas adopted, among
other things, a new rule that addressed
the importance of balancing the
interests of customers, Retail Electric
Providers (REPs), and electric utilities,
with respect to advanced metering.
Texas consumers own all meter data,
23 Department of Homeland Security, Privacy
Policy Guidance Memorandum 2008–01 (2008),
available at https://www.dhs.gov/xlibrary/assets/
privacy/privacy_policyguide_2008–01.pdf.
24 Id. at 2.
25 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, https://
docs.cpuc.ca.gov/published/FINAL_DECISION/
95608.htm.
26 Id. at 3.
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including data from advanced meters
and meter information networks.27 In
March 2010, CenterPoint Energy and
other Texas Utilities launched a Smart
Meter Texas common portal and data
repository to give consumers with smart
meters more control over their
electricity use. Consumers with
installed smart meters can now view
their electric usage history down to 15minute intervals on the Internet. The
Web portal was developed and is
operated by IBM Corp.28
Pennsylvania enacted legislation
requiring electric distribution
companies with over 100,000 customers
to file smart-meter-technology
procurement and installation plans for
approval by the Public Utility
Commission.29 The Pennsylvania Public
Utilities Commission staff drafted a
proposal for implementing Act 129
plans, including nondiscriminatory
access to information by third parties.30
Finally, in 2000, the National
Association of Regulatory Utility
Commissioners (NARUC) adopted a
resolution urging the adoption of
general privacy principles for State
commissions when assessing the
privacy implications of third-party use
of utility-customer information.31
However, it does not appear that many
State utility commissions have
completed their assessments of accessand-privacy issues related to the Smart
Grid.
All of these examples illustrate both
common themes and variations in the
approaches that numerous entities are
taking to address the privacy and
security issues inherent in the
development, deployment, and
implementation of Smart Grid
technologies. As a result, DOE is
publishing this RFI to seek broader
public and private input on the privacy
and security issues inherent in the
development, deployment, and
implementation of Smart Grid
technologies. We seek comment on
these specific approaches as well as
27 Tex. Util. Code Ann. § 39.107(b) (Vernon Supp.
2009).
28 Houston Business Journal, CenterPoint, state
launch Smart Meter portal, March 22, 2010,
available at https://houston.bizjournals.com/
houston/stories/2010/03/22/daily28.html.
29 Act 2008–129, 66 Pa. C.S. § 2807(f) (Nov. 14,
2008).
30 Lisa Schwartz, State Policies on Smart Grid,
(2009), available at https://www.raponline.org/docs/
RAP_Schwartz_StatePolicyonSmartGrid_
2009_05_13.pdf.
31 National Association Of Regulatory Utility
Commissioners, Resolution Urging the Adoption of
General Privacy Principles For State Commission
Use in Considering the Privacy implications of the
Use of Utility Customer Information, available at
https://www.naruc.org/Resolutions/
privacy_principles.pdf.
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26205
information on additional approaches
that are not listed here.
Request for Information
Smart Grid technologies should
ensure that both states and consumers
retain the flexibility to strike a range of
reasonable compromises between the
benefits of data collection and access,
and the protection of personal privacy.
As the California Public Utilities
Commission noted in their December
2009 Decision, the availability of
information on usage and prices in a
consistent format can lead to energy
management solutions that at this time
we can only begin to imagine.32
Balancing these important interests
remains an important challenge for
Smart Grid development, deployment,
and implementation processes. In this
RFI, DOE thus seeks input on how to
best achieve this desire to foster
flexibility, innovation, and consumer
privacy and choice.
In addition, DOE also seeks to
promote the development of Smart Grid
technologies in ways that accommodate
both its important national and local
implications. The Smart Grid will play
a critical role in achieving national
priorities like enabling new ways to
enhance energy efficiency, enhancing
national competitiveness, improving
national security by increasing our
energy independence, and developing
sustainable, long-term energy strategies
that protect our environment and
economy. But flexibility to experiment
is also one of the critical benefits arising
from our dual system of Federal-State
sovereignty. Federal law already
recognizes that Smart Grid technologies
implicate traditional State interests in
autonomy, utilities-regulation and
privacy-management. DOE thus seeks
guidance on how to best balance the
complementary private and public
interests implicated by Smart Grid
technologies.
Finally, this request for information
seeks to survey whether and how the
states are implementing these
obligations; whether implementation
efforts support the conclusion that the
requirements set out in PURPA meet the
current and potential needs of utilities,
consumers, and third parties; what
efforts are being made to implement
these requirements; and whether
patterns, common practices or
consensuses emerge from analysis of
32 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, https://
docs.cpuc.ca.gov/published/FINAL_DECISION/
95608.htm at 4.1.2.
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existing implementations of these
requirements.
List of Questions for Commenters
The following list of questions
represents a preliminary attempt to
identify and respond to the issues that
have been raised in a variety of public
and private forums, including but
limited to: DOE’s historic investment in
Smart Grid technology through the
Smart Grid Investment Grants and the
Smart Grid Demonstrations projects;
Smart Grid Forum blog initiated by the
Office of Science and Technology policy
titled ‘‘Consumer Interface with the
Smart Grid 33’’; and the National
Broadband Plan regarding the Smart
Grid and issues of data access and
collection, third party access to detailed
energy information, and privacy. This
list is to assist in the formulation of
comments and is not intended to restrict
the issues that might be addressed in the
comments.
In addressing these questions or
others, commenters must also recognize
that this RFI is intended to assist and
inform DOE’s efforts to address the
aspects of these questions that most
directly implicate the duties and
responsibilities assigned by law to DOE
and the Secretary of Energy. This
qualification is important because the
global concept of a Smart Grid
inevitably implicates the jurisdiction
and expertise of many other Federal
agencies as evidenced in the
composition of the Federal Smart Grid
Task Force, not to mention Federal law
enforcement agencies, and others. DOE
fully intends to respect the jurisdiction
and expertise of these and other Federal
entities. Consequently, comments
directed to matters deemed more
relevant to the jurisdiction and expertise
of other Federal entities will provide
little assistance relevant to this RFI.
(1) Who owns energy consumption
data?
(2) Who should be entitled to privacy
protections relating to energy
information?
(3) What, if any, privacy practices
should be implemented in protecting
energy information?
(4) Should consumers be able to opt
in/opt out of smart meter deployment or
have control over what information is
shared with utilites or third parties?
(5) What mechanisms should be made
available to consumers to report
concerns or problems with the smart
meters?
(6) How do policies and practices
address the needs of different
33 TMCnet, Consumer Interface with the Smart
Grid, https://sip-trunking.tmcnet.com/news/2010/
02/09/4613238.htm (last visited Apr. 27, 2010)
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communities, especially low-income
rate payers or consumers with low
literacy or limited access to broadband
technologies?
(7) Which, if any, international,
Federal, or State data-privacy standards
are most relevant to Smart-Grid
development, deployment, and
implementation?
(8) Which of the potentially relevant
data privacy standards are best suited to
provide a framework that will provide
opportunities to experiment, rewards for
successful innovators, and flexible
protections that can accommodate
widely varying reasonable consumer
expectations?
(9) Because access and privacy are
complementary goods, consumers are
likely to have widely varying
preferences about how closely they
want to control and monitor third-party
access to their energy information: what
mechanisms exist that would empower
consumers to make a range of
reasonable choices when balancing the
potential benefits and detriments of
both privacy and access?
(10) What security architecture
provisions should be built into Smart
Grid technologies to protect consumer
privacy?
(11) How can DOE best implement its
mission and duties in the Smart Grid
while respecting the jurisdiction and
expertise of other Federal entities, states
and localities?
(12) When, and through what
mechanisms, should authorized agents
of Federal, State, or local governments
gain access to energy consumption data?
(13) What third parties, if any, should
have access to energy information? How
should interested third-parties be able to
gain access to energy consumption data,
and what standards, guidelines, or
practices might best assist third parties
in handling and protecting this data?
(14) What forms of energy information
should consumers or third parties have
access to?
(15) What types of personal energy
information should consumers have
access to in real-time, or near real-time?
(16) What steps have the states taken
to implement Smart Grid privacy, data
collection, and third party use of
information policies?
(17) What steps have investor owned
utilities, municipalities, public power
entities, and electric cooperatives taken
to implement Smart Grid privacy, data
collection and third party use of
information policies?
(18) Should DOE consider consumer
data accessibility policies when
evaluating future Smart Grid grant
applications?
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Issued in Washington, DC on May 5, 2010.
Scott Blake Harris,
General Counsel.
[FR Doc. 2010–11127 Filed 5–10–10; 8:45 am]
BILLING CODE 6450–01–P
DEPARTMENT OF ENERGY
Implementing the National Broadband
Plan by Studying the Communications
Requirements of Electric Utilities To
Inform Federal Smart Grid Policy
Department of Energy.
Request for information (RFI).
AGENCY:
ACTION:
SUMMARY: The Department of Energy
(DOE) is seeking comments and
information from interested parties to
assist DOE in understanding the
communications requirements of
utilities, including, but not limited to,
the requirements of the Smart Grid. This
RFI also seeks to collect information
about electricity infrastructure’s current
and projected communications
requirements, as well as the types of
networks and communications services
that may be used for grid
modernization. Specifically, DOE seeks
information on what types of
communications capabilities that the
utilities think that they will need and
what type of communications
capabilities that the communications
carriers think that they can provide.
DATES: Comments must be postmarked
by no later than July 12, 2010. Reply
comments must be postmarked by no
later than July 26, 2010.
ADDRESSES: You may submit comments,
identified by ‘‘NBP RFI:
Communications Requirements,’’ by any
of the following methods:
Federal eRulemaking Portal: https://
www.regulations.gov. Follow the
instructions for submitting comments.
E-mail: broadband@hq.doe.gov.
Include ‘‘NBP RFI: Communications
Requirements’’ in the subject line of the
message.
Mail: U.S. Department of Energy,
Office of the General Counsel, 1000
Independence Avenue, SW., Room
6A245, Washington, DC 20585.
FOR FURTHER INFORMATION CONTACT:
Maureen C. McLaughlin, Senior Legal
Advisor to the General Counsel (202)
586–5281; broadband@hq.doe.gov.
For Media Inquiries you may contact
Jen Stutsman at 202–586–4940.
SUPPLEMENTARY INFORMATION:
Background
In early 2009, Congress directed the
Federal Communications Commission
(FCC) to create the recently released
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Agencies
[Federal Register Volume 75, Number 90 (Tuesday, May 11, 2010)]
[Notices]
[Pages 26203-26206]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2010-11127]
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DEPARTMENT OF ENERGY
Implementing the National Broadband Plan by Empowering Consumers
and the Smart Grid: Data Access, Third Party Use, and Privacy
AGENCY: Department of Energy.
ACTION: Request for Information.
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SUMMARY: The Department of Energy (DOE) is seeking comments and
information from interested parties to assist DOE in understanding
current and potential practices and policies for the states and other
entities \1\ to empower consumers (and perhaps others) through access
to detailed energy information in electronic form--including real-time
information from smart meters, historical consumption data, and pricing
and billing information. This request for information (RFI) asks
interested parties, including industry, consumer groups and State
governments, to report on State efforts to enact Smart Grid privacy and
data collection policies. This RFI also seeks input regarding
individual utility practices and policies regarding data access and
collection; third party access to detailed energy information; and the
role of the consumer in balancing the benefits of access and privacy.
Finally, this RFI seeks comment on what policies and practices should
guide policymakers in determining who can access consumers' energy
information and under what conditions.
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\1\ e.g. municipalities, public power entities and electric
cooperatives.
DATES: Comments must be postmarked by no later than July 12, 2010.
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Reply comments must be postmarked by no later than July 26, 2010.
ADDRESSES: You may submit comments, identified by ``NBP RFI: Data
Access,'' by any of the following methods:
Federal eRulemaking Portal: https://www.regulations.gov. Follow the
instructions for submitting comments.
E-mail: broadband@hq.doe.gov. Include ``NBP RFI: Data Access'' in
the subject line of the message.
Mail: U.S. Department of Energy, Office of the General Counsel,
1000 Independence Avenue, SW., Room 6A245, Washington, DC 20585.
FOR FURTHER INFORMATION CONTACT:
Maureen C. McLaughlin, Senior Legal Advisor to the General Counsel
(202) 586-5281; broadband@hq.doe.gov.
For Media Inquires you may contact Jen Stutsman at 202-586-4940.
SUPPLEMENTARY INFORMATION:
Introduction
The promise \2\ of the Smart Grid is enormous and includes improved
reliability, flexibility and power quality, reduction in peak demand,
reduction in transmission congestion costs, environmental benefits
gained by increased asset utilization, increased security, increased
energy efficiency and increased durability and ease of repair in
response to attacks or natural disasters. But the Smart Grid also
presents new challenges. In particular, many of its benefits could be
reduced or delayed and avoidable harms caused unless the Smart Grid
adequately respects consumers' reasonable--and often widely differing--
expectations of privacy, expectations that could be compromised if
detailed household energy consumption data is made too readily
available, too inaccessible, or incorrectly anonymized. The Smart Grid
is also likely to create a far more interactive relationship between
utilities and consumers that will raise new questions about how to
ensure that detailed energy data is properly collected, reported,
managed, shared and disclosed in ways that are both lawful and
adequately transparent to consumers.\3\
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\2\ A smart meter is a good example of an enabling Smart Grid
technology that can empower both utilities and consumers to extract
value from two-way communications and real-time access to usage
data. Smart meters play an important role in the success of the
Smart Grid because they can generate an array of useful data
including historical energy consumption data, real-time data, and
price-and-demand-response data.
\3\ Dep't of Energy, What the Smart Grid Means to Americans, 2,
23 (Aug. 31, 2009), available at https://www.oe.energy.gov/DocumentsandMedia/ConsumerAdvocates.pdf.
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This RFI seeks to collect information and open a dialogue about the
challenges inherent in empowering consumers, utilities, and third
parties to realize the many potential benefits of the Smart Grid, while
protecting reasonable consumer expectations of privacy and security,
and ease-of-access and providing the flexibility to manage both.
In the context of the Smart Grid, privacy and access are not so
much conflicting goals as they are complementary goods: the value of
the Smart Grid to consumers, utilities, and third parties depends upon
its capacity to encourage and accommodate unpredicted innovations while
making usage data reasonably available to those who should have it and
respecting consumers' reasonable interests in choosing how to balance
the benefits of access against the protection of personal privacy and
security. Only solutions that accommodate all of these critical values
will maximize the value of the Smart Grid to consumers, utilities,
third-party service providers and innovators, and State and Federal
governments.
Background
In early 2009, Congress directed the Federal Communications
Commission (``FCC'') to create the recently released National Broadband
Plan (``NBP'').\4\ As Congress instructed, the NBP makes
recommendations to various government entities, including Executive
Branch agencies like DOE. In particular, the NBP recommended that DOE
should consider consumer data accessibility policies when evaluating
Smart Grid grant applications, report on states' progress toward
enacting consumer data accessibility policies, and develop best-
practices guidance for the states.\5\ More generally, the NBP's
recommendations seek to modernize the electric grid with broadband by
increasing reliability and efficiency, to unleash energy innovation in
homes and buildings by making energy-usage data readily accessible to
consumers, and to improve the energy efficiency and environmental
impact of the Information and Communication Technologies (ICT) sector
by integrating broadband into the developing Smart Grid.
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\4\ Fed. Commc'n Comm'n, Connecting America: The National
Broadband Plan, https://www.broadband.gov/plan/ (last visited Apr.
26, 2010).
\5\ Id.
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These new recommendations recognize and build upon DOE's years
[[Page 26204]]
of ongoing efforts to assess, implement and deploy Smart Grid
technologies. These ongoing efforts implement existing legislation
intended to encourage the use of such technologies to attain greater
energy independence and security.
The Energy Independence and Security Act (EISA) of 2007 established
``modernization of the nation's electricity transmission and
distribution system'' as a U.S. policy goal.\6\ Among other things,
EISA directed DOE to establish a Smart Grid Task Force whose
responsibilities include developing widely accepted smart-grid
standards and protocols.\7\ EISA also directed the National Institute
of Standards and Technologies (NIST) to develop a framework of
standards and protocols to ensure interoperability and security for the
Smart Grid.\8\ Once the Federal Energy Regulatory Commission (FERC)
concludes that NIST has developed ``sufficient consensus,'' EISA then
directs FERC to ``institute a rulemaking proceeding to adopt such
standards and protocols as may be necessary to insure smart-grid
functionality and interoperability in interstate transmission of
electric power, and regional and wholesale electricity markets.'' \9\
On July 16, 2009, FERC issued a Policy Statement on Smart Grid Policy,
which acknowledged that EISA does not make any such standards mandatory
and gave FERC no new authority to enforce such standards.\10\ For more
than two years, DOE-NIST-FERC coordination on these standards has been
ongoing through the Federal Smart Grid Task Force, the EISA-mandated
group that involves agencies from across the Federal government.\11\
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\6\ 42 U.S.C. 17381 (2010).
\7\ Id. Section 17383.
\8\ Id. Section 17385(a).
\9\ Id.
\10\ Smart Grid Policy Statement, 128 F.E.R.C. ] 61,337, at
61,060-359 (Jul. 16, 2009).
\11\ Cyber Security: Before the S. Comm. On Energy and Natural
Resources, 111th Cong. 1 (May 7, 2009) (Statement of Patricia
Hoffman, Acting Assistant Secretary, Office of Electricity Delivery
and Energy Reliability, U.S. Department of Energy).
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Section 1307 of EISA also amended section 111(d) of the Public
Utilities Regulatory Policy Act (PURPA) by adding two paragraphs
regarding the Smart Grid, paragraphs 18 and 19 in 16 U.S.C.
2621(d).\12\ As amended, PURPA requires states and other entities to
decide whether to adopt a policy requiring its electric utilities to
show why they did not invest in qualified smart grid technologies
before investing in non-advanced grid technologies.\13\ In addition,
states and other entities must consider imposing requirements for
information disclosure to customers and others regarding price, usage,
intervals and projection, sources and customer access to their own
electric consumption information at any time through the Internet or
other means elected by the utility for Smart Grid applications. EISA
requires that states and other entities make such decisions no later
than 2 years after December 19, 2007.\14\
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\12\ Public Utilities Regulatory Policy Act of 1978, 16 U.S.C.
2621(d) (2010).
\13\ Id. Section 2621(c)(16).
\14\ Id. Section 2622(b)(6).
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DOE's Preliminary Review of Some Ongoing Federal and State Efforts to
Implement the Smart Grid-Related Obligations Imposed by EISA and PURPA
To advance its ongoing policies and programs, to implement certain
recommendations in the NBP, and to focus this RFI, DOE initiated an
informal, high-level review of the status of ongoing Federal, State,
and private efforts to implement the Smart Grid related provisions of
EISA and PURPA. Even this informal review reveals some of the important
issues arising as Federal, State and private entities have begun
developing, deploying, and implementing Smart Grid technologies. The
following summary is intended to highlight a few of these issues.
Various entities are consulting an array of guidelines and
principles when framing their approaches to access-and-privacy issues.
For example, to further coordinate development of a framework to
achieve interoperability of Smart Grid devices and systems, including
protocols and model standards for information management, NIST released
Draft Interagency Report 7628 (Feb. 2010)--Smart Grid Cyber Security:
Strategy and Requirements.\15\ This Draft NISTIR was developed by
members of the Smart Grid Interoperability Panel-Cyber Security Working
Group (SGIP-CSWG).\16\ The Draft Report focuses on security and
privacy, two areas that will be important to the success of Smart-Grid
development, deployment and implementation.\17\
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\15\ Cybersecurity Coordination Task Group, Smart Grid Cyber
Security Strategy and Requirements, Draft NIST Report 7628 (Feb.
2010), available at https://csrc.nist.gov/publications/drafts/nistir-7628/draft-nistir-7628_2nd-public-draft.pdf.
\16\ Id. at 3.
\17\ Id. at 1.
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The SGIP-CSWG Privacy Sub-group conducted a high-level privacy
impact assessment (PIA) for the consumer-to-utility portion of the
Smart Grid and considered the privacy impacts and risks throughout the
entire Smart Grid structure. While the evolving Smart Grid will provide
enormous societal benefits including better asset utilization and grid
reliability, it will also present potential privacy risks. The ability
to access, analyze and respond to much more precise and detailed data
from all levels of the electric grid is one of the major benefits of
the Smart Grid, but those benefits could be lost or substantially
delayed unless consumers recognize that Smart Grid technologies also
respect their reasonable expectations of privacy and data security,
particularly when usage data and data extrapolations can be associated
with individual consumers or locations.\18\ The PIA also noted that
State utility commissions currently lack formal privacy policies or
standards related to the Smart Grid, and that comprehensive and
consistent definitions of privacy-affecting information with respect to
the Smart Grid typically do not exist at State or Federal regulatory
levels, or within the utility industry.\19\
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\18\ Id. at 8.
\19\ Id. at 103.
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As a result of the assessment, the Privacy Sub-group developed a
preliminary set of privacy principles using the following sets of
widely accepted privacy principles: The OECD Privacy Principles, the
Generally Accepted Privacy Principles (GAPP), and principles from the
international information security standard ISO/IEC 27001. The Sub-
group considered these to be very general privacy principles designed
to be applicable across a broad range of industries; they are not
mandatory requirements.\20\ These privacy principles are: Management
and accountability; notice and purpose; choice and consent; collection
and scope; use and retention; individual access; disclosure and
limiting use; security and safeguards; accuracy and quality; and,
openness, monitoring, and challenging compliance.\21\
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\20\ Id. at 104.
\21\ Id. at 104-109.
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Another potential framework for considering privacy and consumer
security issues is the Fair Information Practice Principles (FIPPs)
adopted by the U.S. Department of Homeland Security (DHS).\22\ The
FIPPs form the basis of the Department's privacy compliance policies
and procedures governing the use of personally identifiable information
(PII). These
[[Page 26205]]
principles are: Transparency, Individual Participation, Purpose
Specification, Data Minimization, Use Limitation, Data Quality and
Integrity, Security, and Accountability and Auditing.\23\
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\22\ Cal. Pub. Util. Comm'n, 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, Pub. Util. No. 08-
12-009 (Dec. 18, 2009), available at https://docs.cpuc.ca.gov/published/FINAL_DECISION/95608.htm.
\23\ Department of Homeland Security, Privacy Policy Guidance
Memorandum 2008-01 (2008), available at https://www.dhs.gov/xlibrary/assets/privacy/privacy_policyguide_2008-01.pdf.
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The FIPPs are a widely accepted framework that implement the core
provisions of the Privacy Act of 1974 and are mirrored in the laws of
many U.S. states, as well as the laws of many foreign nations and
international organizations.\24\
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\24\ Id. at 2.
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While Federal entities have been analyzing the privacy and security
implications of the Smart Grid, State public utilities commissions have
been conducting their own inquiries and rulemakings on consumer access
to energy-usage data. For example, on December 29, 2009, the California
Public Utilities Commission issued Decision 09-12-046, Decision
Adopting Policies and Findings Pursuant to the Smart Grid Policies.
\25\
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\25\ 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, https://docs.cpuc.ca.gov/published/FINAL_DECISION/95608.htm.
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The decision adopts policies for the three major investor-owned
public utilities (SCE, PG&E, and SDG&E) on consumer access to usage and
price information that will be available through California's Smart
Grid infrastructure; these include a policy goal that SCE, PG&E, and
SDG&E provide consumers with access to electricity price information by
the end of 2010. The decision also requires that SCE, PG&E, and SDG&E
provide consumers and third parties approved by consumers with
collected usage data by the end of 2010, as well as requiring that SCE,
PG&E and SDG&E provide those customers with smart meters and authorized
third parties with access to usage data on a near real-time basis by
the end of 2011.\26\ The Commission held a separate workshop on March
19, 2010 to consider the best methods for providing access to
electricity prices and usage data, due to the high level of interest in
the proceeding.
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\26\ Id. at 3.
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In 2007, The Public Utility Commission of Texas adopted, among
other things, a new rule that addressed the importance of balancing the
interests of customers, Retail Electric Providers (REPs), and electric
utilities, with respect to advanced metering. Texas consumers own all
meter data, including data from advanced meters and meter information
networks.\27\ In March 2010, CenterPoint Energy and other Texas
Utilities launched a Smart Meter Texas common portal and data
repository to give consumers with smart meters more control over their
electricity use. Consumers with installed smart meters can now view
their electric usage history down to 15-minute intervals on the
Internet. The Web portal was developed and is operated by IBM Corp.\28\
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\27\ Tex. Util. Code Ann. Sec. 39.107(b) (Vernon Supp. 2009).
\28\ Houston Business Journal, CenterPoint, state launch Smart
Meter portal, March 22, 2010, available at https://houston.bizjournals.com/houston/stories/2010/03/22/daily28.html.
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Pennsylvania enacted legislation requiring electric distribution
companies with over 100,000 customers to file smart-meter-technology
procurement and installation plans for approval by the Public Utility
Commission.\29\ The Pennsylvania Public Utilities Commission staff
drafted a proposal for implementing Act 129 plans, including
nondiscriminatory access to information by third parties.\30\
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\29\ Act 2008-129, 66 Pa. C.S. Sec. 2807(f) (Nov. 14, 2008).
\30\ Lisa Schwartz, State Policies on Smart Grid, (2009),
available at https://www.raponline.org/docs/RAP_Schwartz_StatePolicyonSmartGrid_2009_05_13.pdf.
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Finally, in 2000, the National Association of Regulatory Utility
Commissioners (NARUC) adopted a resolution urging the adoption of
general privacy principles for State commissions when assessing the
privacy implications of third-party use of utility-customer
information.\31\ However, it does not appear that many State utility
commissions have completed their assessments of access-and-privacy
issues related to the Smart Grid.
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\31\ National Association Of Regulatory Utility Commissioners,
Resolution Urging the Adoption of General Privacy Principles For
State Commission Use in Considering the Privacy implications of the
Use of Utility Customer Information, available at https://www.naruc.org/Resolutions/privacy_principles.pdf.
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All of these examples illustrate both common themes and variations
in the approaches that numerous entities are taking to address the
privacy and security issues inherent in the development, deployment,
and implementation of Smart Grid technologies. As a result, DOE is
publishing this RFI to seek broader public and private input on the
privacy and security issues inherent in the development, deployment,
and implementation of Smart Grid technologies. We seek comment on these
specific approaches as well as information on additional approaches
that are not listed here.
Request for Information
Smart Grid technologies should ensure that both states and
consumers retain the flexibility to strike a range of reasonable
compromises between the benefits of data collection and access, and the
protection of personal privacy. As the California Public Utilities
Commission noted in their December 2009 Decision, the availability of
information on usage and prices in a consistent format can lead to
energy management solutions that at this time we can only begin to
imagine.\32\
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\32\ 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, https://docs.cpuc.ca.gov/published/FINAL_DECISION/95608.htm at 4.1.2.
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Balancing these important interests remains an important challenge
for Smart Grid development, deployment, and implementation processes.
In this RFI, DOE thus seeks input on how to best achieve this desire to
foster flexibility, innovation, and consumer privacy and choice.
In addition, DOE also seeks to promote the development of Smart
Grid technologies in ways that accommodate both its important national
and local implications. The Smart Grid will play a critical role in
achieving national priorities like enabling new ways to enhance energy
efficiency, enhancing national competitiveness, improving national
security by increasing our energy independence, and developing
sustainable, long-term energy strategies that protect our environment
and economy. But flexibility to experiment is also one of the critical
benefits arising from our dual system of Federal-State sovereignty.
Federal law already recognizes that Smart Grid technologies implicate
traditional State interests in autonomy, utilities-regulation and
privacy-management. DOE thus seeks guidance on how to best balance the
complementary private and public interests implicated by Smart Grid
technologies.
Finally, this request for information seeks to survey whether and
how the states are implementing these obligations; whether
implementation efforts support the conclusion that the requirements set
out in PURPA meet the current and potential needs of utilities,
consumers, and third parties; what efforts are being made to implement
these requirements; and whether patterns, common practices or
consensuses emerge from analysis of
[[Page 26206]]
existing implementations of these requirements.
List of Questions for Commenters
The following list of questions represents a preliminary attempt to
identify and respond to the issues that have been raised in a variety
of public and private forums, including but limited to: DOE's historic
investment in Smart Grid technology through the Smart Grid Investment
Grants and the Smart Grid Demonstrations projects; Smart Grid Forum
blog initiated by the Office of Science and Technology policy titled
``Consumer Interface with the Smart Grid \33\''; and the National
Broadband Plan regarding the Smart Grid and issues of data access and
collection, third party access to detailed energy information, and
privacy. This list is to assist in the formulation of comments and is
not intended to restrict the issues that might be addressed in the
comments.
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\33\ TMCnet, Consumer Interface with the Smart Grid, https://sip-trunking.tmcnet.com/news/2010/02/09/4613238.htm (last visited Apr.
27, 2010)
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In addressing these questions or others, commenters must also
recognize that this RFI is intended to assist and inform DOE's efforts
to address the aspects of these questions that most directly implicate
the duties and responsibilities assigned by law to DOE and the
Secretary of Energy. This qualification is important because the global
concept of a Smart Grid inevitably implicates the jurisdiction and
expertise of many other Federal agencies as evidenced in the
composition of the Federal Smart Grid Task Force, not to mention
Federal law enforcement agencies, and others. DOE fully intends to
respect the jurisdiction and expertise of these and other Federal
entities. Consequently, comments directed to matters deemed more
relevant to the jurisdiction and expertise of other Federal entities
will provide little assistance relevant to this RFI.
(1) Who owns energy consumption data?
(2) Who should be entitled to privacy protections relating to
energy information?
(3) What, if any, privacy practices should be implemented in
protecting energy information?
(4) Should consumers be able to opt in/opt out of smart meter
deployment or have control over what information is shared with
utilites or third parties?
(5) What mechanisms should be made available to consumers to report
concerns or problems with the smart meters?
(6) How do policies and practices address the needs of different
communities, especially low-income rate payers or consumers with low
literacy or limited access to broadband technologies?
(7) Which, if any, international, Federal, or State data-privacy
standards are most relevant to Smart-Grid development, deployment, and
implementation?
(8) Which of the potentially relevant data privacy standards are
best suited to provide a framework that will provide opportunities to
experiment, rewards for successful innovators, and flexible protections
that can accommodate widely varying reasonable consumer expectations?
(9) Because access and privacy are complementary goods, consumers
are likely to have widely varying preferences about how closely they
want to control and monitor third-party access to their energy
information: what mechanisms exist that would empower consumers to make
a range of reasonable choices when balancing the potential benefits and
detriments of both privacy and access?
(10) What security architecture provisions should be built into
Smart Grid technologies to protect consumer privacy?
(11) How can DOE best implement its mission and duties in the Smart
Grid while respecting the jurisdiction and expertise of other Federal
entities, states and localities?
(12) When, and through what mechanisms, should authorized agents of
Federal, State, or local governments gain access to energy consumption
data?
(13) What third parties, if any, should have access to energy
information? How should interested third-parties be able to gain access
to energy consumption data, and what standards, guidelines, or
practices might best assist third parties in handling and protecting
this data?
(14) What forms of energy information should consumers or third
parties have access to?
(15) What types of personal energy information should consumers
have access to in real-time, or near real-time?
(16) What steps have the states taken to implement Smart Grid
privacy, data collection, and third party use of information policies?
(17) What steps have investor owned utilities, municipalities,
public power entities, and electric cooperatives taken to implement
Smart Grid privacy, data collection and third party use of information
policies?
(18) Should DOE consider consumer data accessibility policies when
evaluating future Smart Grid grant applications?
Issued in Washington, DC on May 5, 2010.
Scott Blake Harris,
General Counsel.
[FR Doc. 2010-11127 Filed 5-10-10; 8:45 am]
BILLING CODE 6450-01-P