Data Privacy & Access

1. This page will provide information about the workgroup on development of a data privacy and access framework. This page will include relevant documents to assist the work of the workgroup.
   
   1. Utility Statement:
      
      EAL, OG&E, AECC, and SWEPCO provide the attached draft alternative “Access to Advanced Meter Data” strawman rule and request that you distribute it to all parties in the DER Working Group for their review and comment. EAL, OG&E, AECC, and SWEPCO submit that the “Customer and Third-Party Data Access and Privacy” strawman that has been the subject of discussion at the last two working groups is overly broad and should focus on providing reasonable standards for secure customer and third-party access to AMI usage data. The attached alternative Access to Advanced Meter Data strawman is based at its core on the Texas PUC AMI data access rule (16 Tex. Admin. Code § 25.130), and it is designed to provide requirements for secure customer and third-party access to AMI data while providing electric utilities flexibility in the implementation of that access. It also provides a more reasonable framework for access to aggregated AMI data reports.
      
      EAL, OG&E, AECC, and SWEPCO believe that privacy issues regarding data use, notice and disclosure are properly addressed pursuant to existing law and in the electric utility service policies, company-specific data privacy and protection policies, and individual company terms and conditions for data access. For example, Arkansas law already provides that customer data must remain confidential unless the customer gives consent to disclosure (See Ark. Code Ann. § 23-2-304(a)(10)(A).) There is no need for the complicated and burdensome use, notice and disclosure rules prescribed in the Customer and Third-Party Data Access and Privacy strawman, which itself is the subject of a contested rulemaking proceeding in North Carolina that does not appear to have the full support of the Public Staff or the North Carolina electric utilities. It also appears to be based largely on California data access and privacy rules that have not been shown to be applicable to Arkansas as well as some aspirational data access and privacy frameworks, like the DOE’s DataGuard, which has been adopted by at most a handful of utilities and no state commissions of which we are aware.
      
      As has been made apparent from the discussions on the Working Group calls, the Customer and Third-Party Data Access and Privacy strawman’s rules for providing third-party access to AMI data are onerous, complicated and not well understood by the utilities that will be tasked with implementing them, and efforts by at least one utility to offer extensive edits were largely rejected. There also has been no evaluation of what may be the considerable costs for designing, testing, and implementing the information technology systems that would be required to provide access to third parties under the Customer and Third-Party Data Access and Privacy strawman. Likewise, there has been no demonstration of customer support for providing such access to justify the costs. On more than one occasion, the facilitators in this proceeding have asked about “low-hanging fruit” that may offer areas of compromise among the parties. The alternative Access to Advance Meter Data strawman offers a document that exceeds this objective and is based on provisions that strike a reasonable balance between the electric utilities who have to administer the access and the third parties seeking to access AMI data. Accordingly, EAL, OG&E, AECC, and SWEPCO submit that the attached Access to Advanced Meter Data is a more reasonable approach to designing a workable solution for secure access to customer AMI data in Arkansas.
      
   2. Final Facilitator Report on Data Privacy and Access Working Group to Arkansas Public Service Commission
   3. Attachments to Faciliator Reports in Docket 16-028-U
   4. DRAFT Facilitator Report on Data Privacy and Access Working Group
      Attachment 1
      Attachment 2
      Attachment 3
      Attachment 4
      Attachment 5
   5. ARPS-Data Access and Privacy workshops-Strawman proposal issues matrix 8.13.2020
   6. Access to Advanced Meter Data Strawman Final
   7. SWEPCO Comments on draft data privacy and access strawman- June 20, 2020
   8. North Carolina AGO introduction to rule
   9. DRAFT Arkansas data access rules strawman
   10. MissionData and North Carolina AG Proposal
   11. DRAFT AR data access rules strawman 430
   12. Illinois Open Data Access Framework
   13. CPUC 2011 Privacy Order Attachment
   14. CPUC Privacy Order July 2011
   15. CPUC Privacy Order May 2014

Interconnection

1. FINAL Facilitator Report on Interconnection Working Group to the Arkansas Public Service Commission
2. Attachments to Faciliator Reports in Docket 16-028-U
3. DRAFT Facilitator Report on Interconnection Working Group
   Attachment 1
   Attachment 2
   Attachment 3
   Attachment 4
4. Interconnection Topics from Working Group Participants
5. Update from Utilities on Interconnection Review
6. Presentation from Tom Key, EPRI
7. Minnesota Distributed Energy Resources Interconnection Process
8. State of Minnesota Technical Interconnection and Interoperability Requirements
9. Prentation of Michelle Rosier of Minnesota PUC on Minnesota interconnection update