October 12, 2007

Ms. Kirsten Walli

Secretary

Ontario Energy Board

P.O. Box 2319, Suite 2700

2300 Yonge Street, 26th Floor

Toronto, Ontario

M4P 1E4

Re:          EB-2007-0750 Application for the Smart Metering Entity Licence Board

Dear Ms. Walli:

I’m writing in response to the Board’s request for comments. AMPCO is a not-for-profit consumer interest organization that advocates for competitive electricity rates and superior electricity services.

As major power consumers, AMPCO members participate directly in the IESO administered market or are large customers of distribution companies. Major power consumers generally are not affected directly by the smart metering initiative of the Board. As a customer interest organization, however, AMPCO strongly supports the principle that information about customers belongs first to customers and second, and then only as far as necessary, to other parties. 

Without a clear right and means of access to their own data, customers would be at a disadvantage to electricity suppliers. Easy access to consumption information will help customers understand their bills and decide how best to conserve energy. Customers should not be required to negotiate for this information with suppliers whose interests may not be aligned with their own.

Neither the interim nor proposed licenses as drafted specifically require that the smart metering entity make customer consumption data available directly to customers. We submit that “other persons” is not an appropriate category for consumer interests and, we submit, implies that were such information to be provided, it would be in exceptional circumstances. Our view is that the architecture developed to capture and manage the data collected by these meters should be designed to provide easy access by individual consumers to their own consumption data from the outset. We have too much experience with constraints imposed by existing rules and systems to believe that this functionality readily could be added at a later date.

AMPCO respectfully suggests that the license proposed by the IESO be amended by adding consumers to section 10.1 as follows:

10.1 The Licensee shall provide and promote non-discriminatory access, on appropriate terms and subject to any conditions in its licence relating to the protection of privacy, by consumers, distributors, retailers, the OPA and other persons to the (i) information and data related to the metering of consumers’ consumption or use of electricity in Ontario.

Sincerely yours,

 Adam White

President