Access to Customer Information

DRAFT for DAWG-B Discussion

2 July 1996 - LAX

(L. Kristov - CEC)

Issues and options for the near term, to support 1/1/98 initial implementation of Direct Access.

1. Rules and mechanisms to enable fair access to utility-held customer information by all eligible parties.

1.1 Which parties are eligible for access to customer information? CPUC decision orders fair access for "all competitors in the generation sector." DAWG should consider interpreting this broadly to include energy efficiency providers, as they will need to compete with generation providers. Should other parties be eligible for access?

1.2 Mechanisms and timing for providing information to eligible parties. Main options are of two types: direct provision of data by utilities to eligible parties, and establishment of an electronic bulletin board to which eligible parties have access. Choice of option may depend on type of data to be released. DAWG-B should assess which types are needed to facilitate fair competition in 1998. In addition, DAWG-B should consider timing of information release. A "window of access" to customer data prior to 1/1/98 may be an appropriate way to facilitate entry of new competitors.

1.3 What types of information should be made available?

1.3.1 Personal Information; i.e., with customer identification.

Customer Lists (name, address, utility account numbers, but no phone numbers) - May be provided in spreadsheet format, on disk, to all eligible providers. Customers may be given an opportunity to opt out of this, as noted in item 2.1.

Personal Usage Data (usage history from metering data, plus customer name, address, account number) - Much more useful for provider, and much more sensitive for customer. Perhaps maintain this data on an EBB, with access by password.

Categorized Customer Lists (customer lists, for specified groups of customers, perhaps based on total monthly usage, peak demand, load factor, etc.) - This is intermediate, in both usefulness and sensitivity, between the previous two types of information, but probably requires additional processing to sort customers into yet-to-be-defined categories.

Complete Customer Usage Records (previous item, plus DSM participation, energy audit data, building characteristics, etc.) - Maybe not needed if eligible parties are just generation suppliers, but maybe needed if efficiency providers are considered as "competitors" with generators.

Customer Payment / Credit Records - Is this info relevant for 1/1/98?

1.3.2 Impersonal Information; i.e., customer is not identified or identifiable.

Individual Usage Histories - May require special safeguards to ensure customer is not identifiable.

Aggregated Usage Histories - Load profiles for specific customer groups.

Aggregate Statistics - DSM participation, building characteristics, etc.

1.4 Cost of providing information and means of collection. Part of the cost is obtaining customer permission to release the data. How much should users of information pay for it?

2. Rules and mechanisms to protect customer privacy.

2.1 Mechanisms for acquiring customer permission to release information. Main options are of two types: opt-in or opt-out. Opt in means the customer must give explicit permission for data to be released. If the customer does not respond to request, the default is not to release the data. Opt out means the customer must explicitly prohibit release of the data. If customer does not respond to request, the default is to release the data.

The choice between these two options reflects the desired balance between protecting privacy and facilitating the competitive market. Opt in gives greater privacy protection, and will likely result in a relatively small percentage of customers releasing their data, maybe 20 percent. This may be increased by offering customers incentives to release their data; e.g., Pacific Bell Awards program.

Opt out contributes more to market activity, and will likely result in a relatively large percentage of customers releasing their data, maybe 80 to 90 percent. Opt out can be implemented easily in conjunction with a solicitation of interest in direct access. In New Hampshire, a customer who signed up for the pilot simultaneously gave permission to release name, address and account number to all competitors.

2.2 Rules governing parties' uses of the information, such as limits on marketing practices and on further dissemination or sale of the information. What are the rights and responsibilities of "custodians" of customer information?

2.3 Enforcement and complaint-resolution mechanisms. Whose responsibility is this? How should it be implemented to ensure ease of access, fairness and prompt resolution?

3. Rules to prevent privileged access to utility-held information, particularly by competitive divisions or affiliates of the utilities.

See article, "New Hampshire PUC Adopts Strict Code of Conduct," Electric Power Alert, 6/19.