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CUB continues to push for Access to Utility Data 

Published March 14, 2024

In August 2019, CUB filed a petition with the Public Utilities Commission (PUC) to adopt Open Data Access Standards. The Standards would allow certain third parties to access customer energy use data that is aggregated or anonymized to protect customers’ privacy. As we have previously written, this data is instrumental for energy researchers studying opportunities to reduce waste, save consumers money, identify and eliminate inequities in the energy system, and cut greenhouse gas emissions.  

In November 2020, the PUC adopted CUB’s proposed Standards, subject to some additional requirements. A copy of the Standards then approved are attached to the PUC’s written order

This blog post provides an update on CUB’s latest efforts to push for Open Data Access Standards. 

What data is available so far?

Open Data Access Standards that CUB proposed set rules about when third parties can request, and utilities generally must share, data about customers’ energy use. Under the Standards, certain third parties (like local governments, researchers, and nonprofits like CUB) can request customer energy use data from large, regulated utility companies. This data can only be shared if it is presented in a way that protects customer privacy in one of two ways: it must either be “aggregated,” combining multiple customers into a single data point, or “anonymized,” including many customers so that no single customer can be identified from a group. As in other states that have instituted similar rules: each data set must include a minimum number of customers, and no single customers’ energy use may constitute more than a certain percent of the usage in the data set. The Standards also restrict who can request data from a utility, set limits on the geographic boundaries by which data can be requested, and take additional steps to protect customer privacy. 

In 2020, the PUC adopted CUB’s proposed Standards for access to energy data. The PUC has been implementing the Standards incrementally since then. To start, the PUC required utilities to share energy use data aggregated at the building level with building owners, local units of government, and nonprofit organizations for the purpose of public interest research or energy benchmarking.   

In 2023, the PUC took another incremental step to implement the Standards by making aggregated data available at all geographic scales. This action allowed local governments to use community-level energy data to inform city and county greenhouse gas reduction planning and enabled researchers to develop resources such as the Regional Indicators Initiative

The last portion of the Standards that remains to be implemented deals with anonymized data.  

The value of anonymized energy use data 

Anonymized energy use data is essential to understanding and addressing inequities in utility rates and programs. Data about an “average” customer can hide severe inequities in affordability, rate design, and program delivery that likely align with Minnesota’s deep racial disparities. Multiple studies suggest that such disparities extend to energy affordability. However, detailed analyses of disparities in Minnesota utilities’ rates and programs are limited by the fact that Minnesota utilities (with good reason) do not generally collect demographic information on their customers. 

Analysis of anonymized customer energy use data can help fill this gap.  

For example, a 2019 analysis done by the Citizens Utility Board of Illinois found that low-income households in the Chicago area generally use little electricity during the most expensive, peak-demand hours. As a result, low-income households paying typical flat electric rates (in which electricity costs the same at all times of day) are paying more than their fair share and subsidizing their higher-income neighbors. 

Separately, researchers who examined anonymized use data from the Salt River Project in Arizona found that low-income and BIPOC households limit their use of energy compared with wealthier households, revealing ‘’hidden energy poverty.” 

These and other analyses of anonymized energy usage data provide important insights that cannot be gleaned from the higher-level summary data that is typically available to third parties in Minnesota today. Such analyses are very important as Minnesota weighs options like time-of-use rates and considers proposed utility rate increases. 

The current PUC comment period 

The PUC is now requesting comments about whether and how to allow access to anonymized data by implementing the final portion of the Open Data Access Standards. In our comments, CUB discussed the important value that anonymized data access will bring and reiterated the multiple ways in which the Standards protect the privacy of individual customers. We proposed some minor edits to the Standards in order to make their implementation smoother. 

We are hopeful this latest round of comments will give the PUC the information it needs to fully implement the Standards and to allow qualifying parties to request and utilize anonymized data.  

Any party or member of the public has until April 29 to file reply comments responsive to CUB’s (and others’) recently filed initial comments. The Commission will then hold another hearing to discuss various parties’ recommendations and make additional decisions on further refining and implementing the Standards. 

Get involved 

Anyone can file public comments on the Open Data Access Standards. If you would like to support the Standards or share your questions or concerns with the PUC, you can submit a comment online or send an email to, and reference Docket No. 19-505. Please note that everything in your comment will become part of the public record. Comments should be submitted before April 29, 2024. 

Keep an eye on our blog and social media pages for additional updates on this topic. Meanwhile, if you have questions about the use of CEUD, feel free to contact us at  


Author: Brian Edstrom

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