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Comments on the Report to NIST on the Smart Grid Interoperability Standards Roadmap

Comments on the Report to NIST on the Smart Grid Interoperability Standards Roadmap

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Published by futureofprivacy

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Published by: futureofprivacy on Sep 16, 2009
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09/15/2009

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B
EFORE THE
 DEPARTMENT
 
OF
 
COMMERCE
NATIONAL
I
NSTITUTE OF STANDARDS AND TECHNOLOGY
 
Request for Comments
 R
EPORT TO
NIST
ON THE
S
MART
G
RID
D
OCKET
#
 
0906181063-91064-01I
NTEROPERABILITY
S
TANDARDS
R
OADMAP
 C
OMMENTS OF THE FUTURE OF PRIVACY FORUM
 J
ULES
P
OLONETSKY
 
CO
-
CHAIRMAN AND
D
IRECTOR
 
CHRISTOPHER WOLF
 
CO
-
CHAIRMAN
 
FUTURE OF PRIVACY FORUM
 919
 
18
TH
ST
,
SUITE
925
WASHINGTON
,
DC
20006
202-263-2579
JULY
30,
 
2009
 
 INTRODUCTION
Information is what will charge the smart grid. The many ways in which data aboutconsumer demand will be used for smarter electricity provision have the potential torevolutionize the electricity industry and to benefit society. However, this very same informationabout consumers will create major concerns if consumer-focused principles of transparency andcontrol are not treated as essential design principles from start to end of the standardsdevelopment process. Principles of privacy by design must be part of the overall design for smartgrid data flows. NIST should create a stakeholder group that can be positioned to look at the griddata flows as a whole and from a consumer perspective. Flagging privacy risks by specifictechnology or business need is unlikely to allow for useful guidance that captures the range of potential impacts to consumers.
OVERVIEW
Smart meters are being installed throughout homes across the country. The FederalEnergy Regulatory Commission (FERC) recently reported that 52 million smart meters will beinstalled throughout the country over the next five to seven years. As a result of these devices,detailed information about consumer electricity usage will travel from residences to electricutilities and other providers. Electric utilities and other providers may have access toinformation about what customers are using, when they are using it, and what devices areinvolved.Furthermore, as plug-in hybrid electric vehicles are deployed and customers engage inelectricity sales on the grid outside of their homes, an electricity usage profile could become asource of behavioral information.Responsible management of this information could support energy efficiency efforts anddemand-side management initiatives. However, insufficient attention to transparency andconsumer control, given the could lead to consumer resistance due to privacy concerns.,If information is gathered responsibly, in keeping with consumer-centric principles of transparency and control, advancing demand side initiatives, efficiency investments, andconservation efforts will all be possible. A loss of consumer trust would create significantopposition to smart grid deployment efforts. It is thus essential that all actors in the smart gridrecognize the user centric customer focus that must underlie interoperability decisions planning.The NIST Standards Roadmap can ensure consumer trust by ensuring that privacy is addressedin more than a piecemeal manner.We applaud the fact that, in numerous locations in the document, the draft interimStandards Roadmap recognizes the importance of protecting the privacy of consumerinformation. NIST should create an advisory group of advocates, academics and businessexperts who can be positioned to look at the grid data flows as a whole and from a consumerperspective. Flagging privacy risks by specific technology or business need is unlikely to allowfor useful guidance that captures the range of potential impacts to consumers. Principles of privacy by design must be part of the overall design for smart grid data flows.ii
 
 The Future of Privacy Forum (FPF) is a Washington, DC based think tank that seeks to advanceresponsible data practices. The forum is led by Internet privacy experts Jules Polonetsky andChristopher Wolf and includes advisory board comprised of leading figures from industry,academia, law and advocacy groups. FPF was launched in November 2008, and is supported byAOL, AT&T, Deloitte, eBay, Facebook, Intel, Microsoft, The Nielsen Company, Verizon andYahoo.iii

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