An Evaluation of the Motivations Regulating the Privacy of Utility Customer Data Through Legal Philosophies and Precedents

Vivian Luk. Sustainable Los Angeles Grand Challenge URSP. Mentors: Dr. Stephanie Pincetl, Sebastian Solarte, Lauren Strug

In California, the dissemination of utility customer data (UCD) is regulated by the 15/15
Rule, a 2014 decision by the California Public Utilities Commission. Under the 15/15 Rule, the
state of California anonymizes the UCD of non-residential (e.g. commercial and industrial)
customers if there are less than 15 customers in a region and one customer accounts for more
than 15 percent of consumption (N = 15). In contrast, for residential customers, the aggregation
threshold is higher (N = 100) and as a result, much less stringent. This decision was made in an
effort to protect the privacy of consumers and the security of information, but it primarily
benefits non-residential customers. Since the consumption patterns of the biggest players cannot
be publicly revealed, this masking of information undermines the ability to develop policies for
the needs of the public and the achievement of Los Angeles’s sustainability goals. Through an
exploration of existing legal philosophy and precedents regarding privacy, the current regulatory
framework governing utility customer data and its motivations can be properly evaluated. Many
legal scholars concur that commercial businesses and corporations are not entitled to the same
personal privacy rights as individuals. Based on this rationale, the 15/15 Rule is inefficient
because it prioritizes the privacy of non-residential entities, which primarily consist of
businesses, over individuals and hinders the development of policies to promote sustainability
for the public good.

Presentation | 2022

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