The Right to Energy Data – An Emerging Environmental Justice Issue

Author: Seth Mullendore, Clean Energy Group | Projects: Resilient Power Project, Energy Storage

The simplest things often stand in the way of progress.

A case in point is energy data and battery storage. For utility customers to understand how batteries could lower their electric bills, they need to understand how their building uses energy throughout the day. But in many places across the country, it’s extremely difficult, if not impossible for customers to get access to that basic information. In many cases, utilities don’t even have the data. When the data is available, it can be time consuming or costly to retrieve.

This is a growing problem. Utilities are increasingly shifting their customers to more complex rates structures, such as time-of-use (TOU) rates that vary electricity pricing throughout the day and demand charges that bill customers for the highest rate they use electricity.

Despite the added complexity of these rates, the only insight many ratepayers have into their energy usage are a few line items on a monthly bill – leaving them with little to no idea how to go about responding to utility pricing signals and reducing their electricity expenses. Customers are forced to pay these charges without any information about how to reduce them – an energy Catch-22.

This issue can hit small nonprofit organizations, like affordable housing providers and those providing essential services to disadvantaged communities, the hardest. These organizations face the same electric charges as larger companies but often have less access to their electricity data and fewer resources to obtain and interpret the data if it does exist.

It is unfair and inequitable. Smarter policies need to be enacted to correct this injustice.

As for battery storage, simply put, utility customers need access to detailed (at least hourly) energy usage data to determine the value of batteries for their home or business. Today, lack of access to this data represents a major barrier to many customers across the country. Without knowing exactly when a building is using electricity and how much electricity it is using at different times throughout a day or billing cycle, customers are left in an information dark alley.

Without access to information about their energy use, customers can’t reliably determine the value proposition for advanced energy management tools like energy storage or even the true value of solar –especially under TOU rates or net-metering structures where exported energy is compensated at less than the retail rate. This means that customers can’t maximize savings on their bills. It also undercuts the potential for solar and storage to deliver other benefits, such as providing energy resiliency in a storm.

This exact data barrier was cited in arguments against residential demand charges proposed and, despite extreme opposition, approved in Massachusetts in 2018. As argued by the northeastern advocacy group Acadia Center, “Given the lack of sophisticated metering in Massachusetts, there is no way for consumers to know what time this peak [demand] occurred and what actions could be taken to manage these charges. As a result, consumers will be paying the highest possible rate for this [demand] charge without being provided the information needed to understand the cause of these costs.”

This data problem is in no way limited to Massachusetts consumers. A 2017 report issued by the Federal Energy Regulatory Commission (FERC) estimated that, by the end of 2015, only around 40 percent of utility meters were capable of recording detailed electricity usage data, often referred to as “interval data”.

Within those numbers, FERC found wide disparities in advanced metering deployment – ranging from less than 10 percent of commercial customers in the greater New England region to more than 80 percent coverage in Texas. Since 2015, the penetration of advanced metering has risen to around two-thirds of customers but access to data has remained a persistent issue.

Oddly enough, these advanced utility meters are missing in the most unexpected places. New York raised the bar for state energy storage goals with its 1.5-megawatt target and is often held up as a leader in energy innovation due to its ongoing Reforming the Energy Vision (REV) process. Despite these innovative goals, in New York City, there is a severe lack of advanced meters among affordable housing and community services facilities.

That means the owners and operators of these buildings, many of which face some of the highest demand charges in the country, don’t have the most fundamental information to judge whether battery storage technologies could help reduce operating expenses, while potentially adding much needed resilience benefits.

Other regions are leading the way on data access. Some utilities, such as California’s three big investor-owned utilities, have made interval data access relatively simple and easy. Each of the utilities allows for customers to access their data through a service called Green Button. (The Green Button standard was initially created with support from the U.S. Department of Energy and the National Institute of Standards & Technology to give customers easy access to their energy data in a consumer-friendly format.) Through Green Button, California utility customers can download their data and analyze the economics of storage with free software like the National Renewable Energy Laboratory’s REopt Lite optimization tool or share it with a third party for analysis.

But California may be more the exception than the rule as far as data access goes. Through our work on the Resilient Power Project, Clean Energy Group has encountered data access issues time and time again when trying to assist affordable housing owners and critical community facilities in figuring out if solar and battery storage makes economic sense for their properties. Many of the groups we work with are initially unaware of whether interval data is even available for their property, much less how to go about accessing it.

In Portland, Oregon, a partner of ours spent several months going back and forth with the local utility, Portland General Electric (PGE), to gain access to interval data for several low-income properties being evaluated for solar and battery storage. PGE has the data and knows how to get it, but the process of identifying the right person to talk to and which forms to file was aptly described as an “exercise in persistence”. Data access posed a needless barrier to the work, sucking up time and resources that many organizations cannot afford to spend.

Back to Massachusetts. For those customers fortunate enough to already have advanced metering in place at their facility, the process has been simple. Boston-area customers can submit a request to the utility, Eversource, and, for a small fee, data access is allowed for a limited time. Not ideal for folks interested in continually or even periodically monitoring energy usage, but at least functional for a one-time analysis.

Those without advanced metering have a difficult choice to make. Despite being subject to very high demand charges, accounting for more than half of electricity expenses for some customers, many Eversource customers don’t have advanced meters installed.

We’ve worked with several affordable housing providers in the Boston area struggling with this issue. Their limited options are:

  1. Do nothing and potentially miss out on thousands of dollars in savings each year.
  2. Switch to a TOU rate that would include free installation of advanced metering but could result in higher energy expenses (which they can’t accurately determine without access to interval data).
  3. Pay around $2,000 to have an advanced meter installed by the utility, then wait months to gather enough data to see if storage might make economic sense.
  4. Install an energy data logger (which may cost a similar amount as the utility meter) and again wait for the data to come in.
  5. Run a generic economic analysis using modeled representative electricity usage data (not the sort of thing recommended as the basis for big investments).

It’s not the most promising list of options. Paying for utility meter upgrades or energy data loggers can be prohibitively expensive for many organizations.

The solutions to this data problem should be simple.

  • If a utility customer is subject to rates where how and when they use electricity makes a difference, like time-varying rates or demand charges, they should have simple, open access to the data that can help them respond to those rates.
  • Utilities should be required to install meters capable of measuring and recording such data and to provide an intuitive, free platform for consumers to access that data, such as through Green Button.
  • If, for some reason, this is not feasible, government agencies should support funding for implementation of measures such as data loggers that customers would purchase and install to track and record usage information, particularly for public facilities and those serving low-income and vulnerable communities.
  • This should be a fundamental demand of any environmental justice advocacy effort in major cities – to get city or state policies and funding in place to ensure that data is free and accessible.

Flat rates are increasingly becoming a relic of the past. As the grid and corresponding utility rate structures evolve, customers should have a right to access to their own electricity usage data to respond to and evolve with them. This should be implemented as a default, standard practice for every electric utility consumer, not a decision left to the whims of utility executives and shareholder interests.

Free access to this energy data should be a basic right in today’s changing energy regulatory environment.


This blog post was also published in Renewable Energy World.

Maryland’s New Resiliency Program Could Serve as a Model for Other States

Author: Seth Mullendore, Clean Energy Group | Project: Resilient Power Project

Photo Credit: Millenius /

There’s a lot to like about the Maryland Energy Administration’s (MEA) new $5 million program to support community resiliency hubs powered by solar and battery storage. It recognizes the value of providing basic services in an emergency, prioritizes low-income communities, provides adequate levels of funding for solar and batteries as well as related electrical work and components, allows for flexible use cases, and sets realistic goals.

MEA’s program has been a long time in the making. Back in 2014, Clean Energy Group (CEG) suggested the City of Baltimore invest in solar and storage to strengthen the resilience of low-income communities in its report, Clean Energy for Resilient Communities: Expanding Solar Generation in Baltimore’s Low-Income Neighborhoods. Since then, both MEA and CEG have been working to support the development of the first resiliency hubs in Baltimore. This new program will help ensure those effort continue and, if properly implemented, the program could serve as a model for accelerating the development of community resilient power systems across the country.

Let’s start with the goal of MEA’s program: energy resilience to support basic services for low-income populations when the grid is down.

MEA defines a resiliency hub as a facility that is located within short walking distance from economically disadvantaged populations and that can serve as a heating and cooling center, provide refrigeration for medications and milk for nursing mothers, and allow for charging of small devices, like cell phones and computers. Buildings such as schools, religious institutions, community centers, senior centers, and affordable housing buildings with community spaces are recommended examples of suitable facilities. The hubs are meant to be meeting places and information centers for the surrounding community during an outage. They are intended to strengthen the resilience of local communities, not to replace emergency shelters or hospitals.

Now on to the funding.

Grants are available to provide $1,300 per kilowatt of the system, based on the size of the solar array. So, a 30-kilowatt solar array paired with 40 kilowatt-hours of storage would be eligible for $39,000 in grant funding, which should be enough to cover most, if not all, of the installed cost of the battery. For reference, California’s successful Self-Generation Incentive Program offers a storage incentive of $350 per kilowatt-hour.

Additionally, the grant will cover up to $700 per kilowatt to pay for a critical load panel, rewiring critical loads to the panel, disconnect switches, and other equipment and work needed to allow the system to island from the grid and operate independently during an outage. This added level of funding support sets MEA’s program apart from typical solar and storage incentives that don’t account for the added cost of isolating critical loads and making a system resilient.

According to the National Renewable Energy Laboratory (NREL), these additional resilience-related expenses can increase the cost of a solar+storage installation by anywhere from 10 to 50 percent. The grant also covers up to $1,000 in fees that a city or county office of emergency management may charge to review the project.

Finally, the program is flexible, not restricting use cases or system configurations.

The resiliency hub program is designed to incentivize resilient solar+storage systems, but it does not limit functionality to backup power alone. Program guidelines specifically state that the solar+storage systems can also be used to reduce electric bills, both through solar generation offsetting electricity use and through batteries managing demand to reduce utility demand charges. The battery system can also expressly participate in providing grid services, such as frequency regulation. The only stipulation is that the battery must be at least 90 percent charged prior to any known severe weather conditions that could result in a power outage.

The program also recognizes that, while traditional generators have a record of failing during emergencies, fossil-fuel backup generators are still often the default technology for resilience. The MEA funding will not pay for a traditional generator or cover the cost of integrating generators into a resilient solar+storage system, but it also does not exclude systems that choose to incorporate fossil-fuel generation. This is important to allow facilities with additional high-power loads or existing backup power strategies to have an opportunity to participate in the program.

So, there are a lot of good elements in MEA’s program, but it’s not perfect.

To apply for funding, projects need to submit solar+storage system sizing details and a one-line design diagram. This level of detail can be difficult for facilities owned and operated by small non-profit organizations to provide. There are some free tools out there that can help with system sizing – MEA suggests NREL’s online tool, REopt Lite. (For organizations not familiar with REopt Lite, this webinar is good place to start. Clean Energy Group offers free training on the tool for non-profit organizations serving disadvantaged communities.)

That still leaves the issue of the one-line diagram. Generating a one-line diagram requires at least some level of engineering support, and that costs money. Few community organizations have the in-house expertise or resources to identify and engage an energy expert to satisfy this requirement.

Ideally, MEA’s program would provide upfront support to prospective applicants to offset these costs and identify trusted sources of expertise. This type of predevelopment funding gap has been a consistent problem with programs aiming to reach disadvantaged populations. Through its Resilient Power Technical Assistance Fund grant program, Clean Energy Group has worked to bridge this gap for dozens of projects across the county, but our resources can only go so far in supporting this pivotal stage of the early development process.

It may be that these issues will be worked out before the program is fully up and running.

In any case, MEA’s $5 million program is an excellent start to address the need for resilient power hubs in Maryland, but the funding will likely only be enough to reach a limited number of communities. With a cap of about $500,000 per project, as few as ten hubs could exhaust this initial round of program funding.

By comparison, Puerto Rico recently proposed devoting $500 million in Community Development Block Grant – Disaster Relief funds toward advancing resilient solar+storage and resiliency hubs for its about 3.5 million residents. Maryland has a population of more than 6 million.

Despite these limitations, MEA’s new resiliency hub program represents a great step in the right direction. This type of proactive measure, designed to prepare disadvantaged communities for the next wave of extreme weather events instead of just responding in the wake of another climate-induced humanitarian crisis, is encouraging. Hopefully, the success of MEA’s program will serve as a model for other states to follow and implement.


This blog post was also published in Renewable Energy World.