On October 8, 2020, the Ontario Ministry of Energy, Northern Development and Mines (Ministry of Energy) issued a regulatory proposal indicating that electricity and gas utilities across the province will be required to implement “Green Button”. “Green Button” is a tool that was first implemented in the United States in 2011, which allows electricity and natural gas consumers to access and better monitor their consumption data. Green Button consists of two functions: “Download My Data” (DMD), whereby consumers can directly access their consumption data, and “Connect My Data” (CMD), whereby consumers can authorize the secure transfer of their data to third parties.

The first electricity utility in Ontario to incorporate the Green Button initiative into its operations was London Hydro in 2016. Since then, the implementation of Green Button has remained voluntary for Ontario utilities. However, the proposal of the Ministry of Energy, should it be implemented, would mandate that the large majority of utilities in Ontario implement Green Button within the next two years.

Should it not be practically feasible for utilities to implement Green Button within that timeline, the proposal contemplates the provision of an extension. Further, for smaller utilities that serve fewer than 25,000 customers, the timeline for compliance may be extended, or, alternatively, compliance may be made voluntary. The proposal also suggests exempting Hydro One Remote Communities Inc., Attawapiskat Power Corporation, Fort Albany Power Corporation and Kashechewan Power Corporation because of the unique nature of the territories or infrastructure concerned.

One of the suggested benefits of the proposal is that consumers will be incentivized to adjust their consumption behaviour after reviewing their usage data. It is also suggested that the mandated Green Button initiative will allow software and app developers to create tools which break down, analyze and present consumer data in a user-friendly way. In this way, consumers will be better able to identify where they can increase conservation and energy efficiency, such as by implementing energy retrofits.

The proposal also suggests that easier access to data would be helpful for those carrying out audits and evaluations of consumption data. For large building owners and the broader public sector, it is suggested that software tools and apps could facilitate energy reporting and benchmarking, and be of particular help with building-level reporting for properties with multiple meters.

By putting in place a common standard for collecting and reporting energy consumption data, the Green Button proposal aims to increase efficiencies and reduce the costs involved with obtaining data for consumers and third parties. However, there will be costs for utilities to implement Green Button. For example, utilities are required to develop a software platform, or procure a third party to do so, and obtain Green Button certification.

The consultation period during which time the Ontario Ministry will receive comments on the proposal will continue until November 22, 2020 (a 45-day window, altogether).

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