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Smartgrid – AMI Data Rulemaking
October 30, 2024 was the deadline for stakeholder comments in the New Jersey BPU’s draft AMI data access rulemaking. Comments were submitted by the electric utilities, EEANJ, Mission:data, Competitive Suppliers (joint comments by RESA and NRG Energy, Inc.), Advanced Energy United, and Recurve. A recording of the stakeholder meeting is available here and more information is available in the Notice.
Most recently on October 30, 2024 parties fil ed comments on the proposed AMI standards (10/30/24).
Of note:
(1) the electric utilities said, “the proposed rules raise complex technological and policy issues concerning the capabilities of AMI meters generally and the specific capabilities of the AMI meters installed in the EDCs’ service territories. These technological issues would best be addressed by a working group of EDC personnel and interested stakeholders who have the expertise in AMI technology.” The utilities also claimed the proposed rules do not adequately protect customer data; they are seeking more strenuous cybersecurity and data privacy standards for eligible third parties to access customer data;
(2) a group of competitive suppliers objected to the sole use of Green Button Connect saying it “…cannot be the primary data sharing method for TPSs who serve thousands or even tens of thousands of customers because it is not a practical approach for TPSs to gain access to a large volume of customers’ AMI data at one time.” The suppliers want data access through EDI and csv flat files. Suppliers also requested that if the utilities have the capability to do so, they should provide suppliers with AMI data more quickly than 48 hours as proposed. Suppliers also want customers to continue to be able to authorize their supplier to access their data through their customer agreement rather than having to sign a new form. Finally, suppliers urged the BPU to not allow the utilities’ to charge third parties or customers a fee for data access nor should the utilities share information with third parties that would release confidential supplier rate information;
(3) Rate Counsel warned “…a potential hacker could access the AMI data of any customer using a vulnerable energy monitoring device. Rate Counsel recommends that the Board require the electric distribution company (‘EDC’) to allow customers to connect only those devices and communication systems that provide robust cybersecurity measures, and meet certain industry standards for safety from hacking or manipulation by threat actors”; and
(4) Mission:data Coalition said, “The potential for EDCs to exploit loopholes in the definitions of certain terms is serious. In our experience, without clear and unambiguous rules, EDCs retain the incentive to unfairly declare reliability problems or cybersecurity risks that are pretextual in nature and not genuine, resulting in competitive harms. The result can be abuses of dominance by EDCs as they deny data to certain entities at the EDCs’ whim.”
(BPU Docket No. EX24090717)
