Privacy of Customer Energy Usage Data: Protecting

Consumers and Giving Them the Tools with which to

Protect ThemselvesAryeh B. Fishman

Director, Regulatory Legal AffairsEdison Electric Institute

A few basic questions

Why are we talking about privacy? Why do we care?

What has really changed because of Smart Grid technologies?

Do laws and regulations need to change?

Utilities care about privacy

Developed data access and privacy guidelines CEOs Organized and engaged CIO EAC on these issues

Submitted comments in DOE proceeding on data access

Participated in SGIP CSWG Privacy Subgroup activities

Worked to shape NAESB model business practices (REQ.22)

Engaged White House Office of Science Technology Policy (OSTP) & DOE on these issues

Is SG technology really a game changer for privacy?

Digital meters collect customer energy usage data – same type of data, but different frequency of collection.

What prevents existing law/regulations from being applied to this situation? utilities 3rd parties

Key issues

How to safeguard data and maintain customer trust and satisfaction while allowing for innovation?

How to avoid “recommended” policies and practices that may increase costs?

Would a federal regime for enforcing codes of conduct on privacy practices help?

Particular concerns

Individual control

Transparency

Authorization/verification

Security

Access and accuracy

Accountability

Current situation

White House Green Button initiative DOE survey and map illustrating utility data

access policies and practices

NIST-SGIP Privacy Subgroup efforts to develop 3rd party best practices and NAESB REQ.22 gap analysis

White House Consumer Privacy Bill of Rights Multi-stakeholder process to develop and

implement enforceable codes of conduct

EEI going forward

Continue participating in NIST-SGIP and NAESB efforts on data access and privacy

Revisit EEI data access and privacy guidelines with Members

Help shape direction of Consumer Bill of Privacy initiative Help determine forum for electric industry Preserve reasonable flexibility for compliance with

codes of conduct Outreach to States and consumer advocates

Consider working with Future of Privacy Forum on its Smart Grid consumer privacy seal program