1. Privacy of Home Energy Usage Data Jim Williams June 26, 2012 Jim Williams June 26, 2012

2. Privacy Protection  Traditional regulatory role in protecting customer personal information  Expanded regulatory role in protecting customer information in retail competition  Emerging regulatory role in protecting customer information from unauthorized third-party disclosure  Advocacy in state and federal proceedings

3. Traditional Regulatory Role  Protection of customer privacy from unauthorized access  Simple relationship between utility/ customer  Regulatory requirements to protect information such as identity, SSN, account-specific information, payment and credit history  Energy usage information primarily collected for billing purposes  Commission mandated disclosure requirements prior to the release of any customer information –Credit purposes –Participation in Federal and State assistance programs

4. Expanded Regulatory Role (Retail Competition)  Protection of customer privacy from unauthorized access  More complex relationship utility/ supplier/ customer  Commission rules for release of generic load and customer information to competitive suppliers  Contractual disclosure: –Customer specific information –Utility account number –Energy usage data  Utilities and suppliers required to protect customer privacy  Usage information needed for marketing and billing purposes  Enforcement of privacy protections through supplier certification process 4

5. Emerging Regulatory Role (Smart Grid) 5  Protection of customer privacy from unauthorized access  More complex relationship utility/ customer/ supplier/ third-party provider  Types of products and services offered by third- party providers  Identification of the specific customer information that requires protection  Defining how unauthorized access might occur  Assessing impact of unauthorized access  Disclosure requirements  Customer education requirements

6. General Issues  Potential exists for customer energy usage information to be provided to third-party providers by utility/ supplier/ customer  Disclosure requirements need to be defined concerning: –how and what customer information will be released –how the information will be used and protected  How customers are informed and educated about risks  Implicit vs. explicit authorization  Marketing standards  Written (or other means) of consent by the customer  Opt-in vs. opt-out participation in programs  Enforcement 6

7. Conclusion  Potential for customers to be harmed through unauthorized access of customer information including energy usage data  Consumer protection rules and policies need to be developed to mitigate this risk  Customers need to be educated and informed on effective ways to protect privacy

8. Privacy of Home Energy Usage Data Thank You! Jim Williams June 26, 2012 Jim Williams June 26, 2012