CDT Files Detailed Smart Grid Comments to the Department of Energy

Yesterday, CDT filed comments at the U.S. Department of Energy (DOE) in which we recommended privacy rules for the Smart Grid. The DOE, the California Public Utilities Commission (PUC) and other federal agencies have been conducting a series of inquiries aimed at spurring implementation of the Smart Grid, which is intended to improve the collection and use of information about home energy consumption in order to improve energy management and efficiency.

Since this energy usage data can be so detailed that it will reveal personal activities in the home, CDT, joined by the Electronic Freedom Foundation, has been urging policymakers to adopt privacy rules based on the set of concepts known as the “Fair Information Practice” principles (“FIPs”). At both the state and federal level, a wide range of stakeholders have agreed that the FIPs are the best available framework for developing privacy and security rules for household energy usage data.

Up until now, however, while everyone has talked about the FIPs, no one has really spelled out what they would mean in reality. In an October 15 filing with the California PUC, CDT and EFF laid out, for the first time ever, a very specific set of policies and procedures that translate the FIPs into practical and useable rules.  Yesterday, we submitted those proposed rules to the DOE, so that they could achieve nationwide attention and adoption.