By Gwen Brown, Vice President of Communications, Interstate Renewable Energy Council 

Access to data about conditions on the electric grid is an essential ingredient for a successful transition to a grid powered by clean, renewable energy. Grid data can help developers understand the best locations to site renewable energy projects, electric vehicle chargers, and other resources necessary for a clean and equitable energy transition. The data can also help guide system design and operation to minimize grid impacts and facilitate faster deployment of these resources.  With interconnection delays increasingly cited as one of the leading barriers to clean energy deployment, the importance of grid data cannot be overstated. 

Yet a concerning trend is emerging. Utilities are increasingly resisting the move towards greater grid transparency. This resistance is framed as a concern that sharing grid data could present a threat to grid security. While grid security is of utmost importance, these specific concerns have not been sufficiently vetted and the proposed solution—to make grid data less publicly available—is not backed by data or research. 

Grid security is a critically important issue. Real risks to grid security have been documented, including an increase in physical attacks on grid infrastructure. The Interstate Renewable Energy Council (IREC) strongly supports taking the necessary measures to ensure the security of critical infrastructure. However, decisions to limit access to grid data must be evidence-based. To date, no research has supported restricting access to general grid data as the solution or indicated a link between this data and grid security threats.  

This article explores the concerning trend of burdensome restrictions to grid data access in the name of grid security, as exemplified by developments in Minnesota and new resources from the National Association of Regulatory Utility Commissioners (NARUC). We examine why this presents a threat to equitable and efficient grid access for clean energy, and why it is essential that regulators base grid access and grid security decisions on evidence and not hyperbole.

Background: Why Is Grid Data Transparency Important for Clean Energy Adoption?

What do we mean when we refer to grid data, and why is access to that data important for enabling a clean energy transition? To put it simply, the grid data we are referring to is data that provides transparency into the conditions on the electric distribution grid, such as how much electrical capacity is available at different points on the grid, the types of equipment located in different areas of the grid, and the different times of day and year when there is more or less electricity consumption (load) which can impact when capacity is available. It does not include any personally identifiable customer information.

Benefits of Grid Data for Clean Energy Customers and Developers

This data is vital for communities and developers of clean energy systems because it can allow them to select appropriate locations for their projects—particularly, locations where they are more likely to be approved to interconnect their projects to the grid. It is also crucial for enabling smarter deployment of resources that respond to grid conditions.  For example, this data can help identify the optimal times for solar and storage to export energy to the grid, or conversely, the best times for electric vehicles to charge. Enabling these “smart” behaviors is a crucial way to lower the costs of clean energy deployment while maximizing the benefits. 

Already, interconnection is a time-consuming process that is regularly cited as one of the primary barriers to efficient deployment of distributed energy resources (DERs). It is not uncommon for clean energy projects to spend multiple years in the “queue” waiting for their interconnection requests to be reviewed by their utility. Without visibility into grid conditions, developers may wait in these long queues only to find, when their project is finally studied, that they cannot interconnect without expensive upgrades that make their project financially infeasible. 

Societal Benefits of Accessible Grid Data

It is not only clean energy customers and developers that benefit from the availability of grid data, however. Making this data accessible also offers societal benefits, such as reducing the need for expensive infrastructure investments, the costs of which are passed on to all utility customers. As more and more renewable energy and electrification load is added to the grid, more sections of the grid will require equipment upgrades to accommodate the additional load and generation. 

We can reduce the need for these upgrades, however, if projects have access to data on grid conditions. In addition to helping developers site projects in areas of the grid that can better accommodate them, this data makes it possible to design clean energy systems to operate in more sophisticated ways that respond to grid conditions at different times. But this is impossible without access to data to inform those design and operating changes. 

A third-party expert in a regulatory case on this topic in Minnesota noted that “making distribution grid data more available would increase ease of interconnection to the grid, attract additional renewable energy development, and provide benefits to ratepayers by reducing costs, improving reliability, decreasing emissions, and providing jobs related to projects enabled by [Inflation Reduction Act] incentives.”

Benefits of Accessible Grid Data for Utilities and Regulators 

Regulators and utilities can also benefit from making grid data accessible. When developers lack insight into grid conditions, they may be more likely to submit “speculative” interconnection applications to see where projects will be approved. They also are hindered in proposing projects that are designed to operate in sync with grid needs. This creates added work for utility staff. Utilities already face challenges in filling positions, and many have significant backlogs of interconnection applications pending review. 

Finally, this data is essential to the core responsibilities of the regulators who oversee utility operations. Regulators need access to grid data to be able to effectively analyze utilities’ investment decisions. If this data remains confidential, it impairs regulators’ ability to regulate in a publicly transparent manner.

What Are the Stated Grid Security Concerns About Making Grid Data Available? 

In recent years, some utilities have argued that public access to grid data should be severely restricted on the basis that it presents threats to the security of the electric grid. 

While grid security is a very important issue, these claims have not been rooted in evidence or data. Many reports have been issued in recent years emphasizing the need for grid security and making specific recommendations in this area. These include reports from the U.S. Department of Energy and the U.S. Government Accountability Office. None have recommended making the grid data in question private.

Attacks on the grid can take two likely forms: physical or cyber. Physical attacks target grid equipment. Generally, this equipment can be identified in other ways than using grid data published by utilities. For example, transformers and other grid equipment can be directly seen by people driving or walking by them, or identified with other publicly available data like Google Maps. Cyberattacks, on the other hand, typically target grid control systems; the grid data at issue here does not enable greater access to grid control systems. 

Additionally, significantly more data about grid conditions is made available for the electric transmission grid, the high-voltage bulk power system regulated by the federal government. Attacks on the transmission system would have even more devastating effects than attacks on the distribution grid, yet federal regulators have not found that restricting access to this vital data is a suitable approach to protecting grid security, indeed the federal government itself publishes some of this grid data. 

New Resources from Association of Regulators Recommend Burdensome Framework for Making Grid Data Available 

As grid data—and the professed concerns of some utilities about the security implications of sharing this data—have become hot topics in utility regulation, the National Association of Regulatory Utility Commissioners (NARUC) has sought to provide guidance for utility regulators

In 2022, NARUC formed the Grid Data Sharing Collaborative to explore this topic. IREC participated in the Collaborative, alongside other stakeholders including state utility regulators, utility leaders, DER developers, and cybersecurity subject matter experts. In November 2023, the collaborative published the results of its work: the Grid Data Sharing Playbook and a variety of other related resources. 

Recognizing that there are differing circumstances and priorities in different states that may influence the appropriate path for grid data sharing, the Playbook does not make specific recommendations. Instead, it establishes a proposed decision-making framework for regulators to use when weighing how much grid data to require utilities to make public. 

Unfortunately, the framework proposed in NARUC’s Playbook is an unnecessarily resource- and time-intensive process that is unlikely to result in meaningful benefits but is likely to significantly delay access to grid data if regulators choose to restrict such access until the process is complete. 

This kind of process advantages utilities, who are pushing for data restrictions; less-resourced public interest entities and other stakeholders will face barriers to participating in such a lengthy process. It also is not clear that the framework will make it easier for regulators to make well-informed and prudent decisions. 

Framework Should Acknowledge the Need for Additional Information 

The intensive framework laid out by NARUC is based on the assumption that sharing grid data is risky, and conveys the impression that sharing grid data presents grid security risks, despite the aforementioned lack of concrete evidence to support that position. The Playbook does not directly acknowledge a scarcity of data on this topic or that additional research would be beneficial to inform regulators. 

The NARUC document does not reference any papers tying grid security risks to the public disclosure of distribution grid data. Nor is there literature cited establishing that making the data confidential is the best method to ensure grid security. Nor does the document take a look at the existing regulatory framework at the federal level and the various existing resources that identify steps that regulators and utilities should take to secure the grid (see comments filed by IREC in Minnesota for a summary of this literature).  Additionally, regulators in New York and California have both issued orders that strongly affirm that grid data (in the form of hosting capacity maps) should be made public with few restrictions. 

IREC would have liked to see NARUC acknowledge the dearth of information on this topic and call for more research on whether there are any links between grid data accessibility and grid security risks, as well as whether making data confidential is an appropriate mechanism for maintaining security.  

Regulatory processes like the one laid out by NARUC are resource-intensive for the Commission and the stakeholders. Before launching such a process, Commissions should first evaluate the merits of the underlying arguments to determine the appropriate focus for its efforts to enhance grid security. IREC believes that such evaluation will determine that grid security is a critical issue, but that the research suggests focusing on whether utilities are following recommended cyber and physical security measures. Thus, regulators should invest resources into ensuring those recommendations are followed rather than focusing on how to redact grid data, which is not a recommended grid security strategy.

Grid Security Proceedings in Minnesota Exemplify Deference to Utility Claims of Data Risks Without Sufficient Evidence 

Grid security proceedings in Minnesota present a real-world example of the problems with these assumptions and the cumbersome approach proposed by the NARUC report. Several years of work by stakeholders, including IREC, still have not resulted in a decision on whether to enable the publication of grid transparency data that is vital for clean energy development and regulation of utilities in Minnesota. 

In June 2023, after over three years of work by numerous parties, the Minnesota Public Utility Commission further delayed a decision on increasing access to grid data. Instead, the commission opted to initiate an 18-month working group process to continue exploring the issue. As of late February 2024, eight months after the ruling to extend the process, a working group had not yet been created. 

The commission opted to delay a decision even though utilities did not provide convincing evidence of grid security reasons to restrict data access, despite ample opportunity to do so over three years. The commission took this approach even though a report by a third-party grid security expert retained by IREC concluded that making this distribution grid data more available would have numerous benefits for ratepayers, clean energy development, and the process of interconnecting to the grid. It also ignored the numerous government reports that point to specific grid security strategies, none of which include redacting grid data. The commission’s decision hinders DER development in the state and represents a problematic level of deference to utility preference when such preference runs counter to credible research. 

The distribution grid data that is currently publicly available in Minnesota varies across the state. The Commission has required Xcel Energy to publish a hosting capacity map. Other utilities in the state have not published hosting capacity maps and may make some information available via pre-application reports or informal conversations. Xcel Energy’s hosting capacity map contains some valuable information for interconnection customers, but it still does not include some data that regulators have previously requested the utility to publish. 

Additionally, Xcel has opposed the publication of additional data that is important to facilitate DER development. For example, their hosting capacity map currently only includes information for generation but not new load (increased electricity demand, as occurs with the installation of electric vehicle chargers and building electrification measures). Furthermore, Xcel has taken the position that even some data that is currently available should be made confidential in the future. This is at odds with practices in other states; to IREC’s knowledge, no other state has approved the kinds of data restrictions Minnesota utilities are requesting. 

The years-long decision-making process employed in Minnesota, which is similar to the framework NARUC has laid out, shows how time-consuming and resource-intensive such an approach will be. This approach, and the refusal of regulators to make a decision despite significant contributions by expert parties and a robust regulatory record, creates a situation in which public interest advocates face significant hurdles to continued participation. These decision-making delays are also at odds with the urgency of climate change mitigation and resilience needs. 

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Accessible grid data is a key ingredient for an equitable and efficient transition to clean energy. Recent arguments by utilities that public access to distribution grid data should be restricted to protect grid security lack supporting evidence. Yet the traction this argument has gained, first in Minnesota and more recently in NARUC’s framework, presents a threat to states’ ability to expand clean energy use. Continuing down this path will undermine the transition to clean energy and customers’ rights. 

IREC strongly supports addressing grid security risks and urges regulators to focus on the risks that federal regulators and agencies have identified, rather than nebulous and unsubstantiated claims. Based on available evidence, the benefits of making this data available outweigh the risks.