As with the comments submitted to the USDOT we offer the following action plan to summarize our recommendations:
Government assistance to Puerto Rico should focus on the public asset the modernized grid represents, and make the grid easy for private entities to connect DER projects under programs like On Bill.
All stakeholders involved in building and/or maintaining the energy infrastructure, and the DER projects, should be required to utilize federally recognized machine readable data standards like XBRL, and to utilize standardized forms and data sets generated under the DOE Orange Button.
All stakeholders involved in building and/or maintaining the energy and transportation infrastructure should be required to utilize federally recognized machine readable data standards like XBRL, and to utilize standardized forms and data sets as outlined to USDOT on July 17th
Public and private entities, including US Customs and utilities, should leverage the capability enabled by data analytics to better quantify risk and exposure for improved data management and administration for better alignment of financial products to financial obligations to reduce unnecessary burden and excess costs that undermine solar bankability.
DHS hosts an XBRL-CET meeting in DC with USDOE, USDOT, Treasury, SBA and others to explore two Pilot projects
DOE – Puerto Rico / Orange Button / AGC - Bonding small solar installation contractor and On Bill financing
DOT – City of Tracy / Caltrans / AGC – Highway Interchange at Tracy Gateway – Bonding small contractors
XBRL-CET Memo to Homeland Security
Modernizing Energy and Transportation Infrastructure
Emergency Response for Puerto Rico
December 10, 2017
The nation is transitioning to digital communications and electronic transactions, driven largely by government mandates and compliance requirements, and supported by XBRL US by expanding the XBRL taxonomy as a public and private resource beyond just financial reporting to the SEC, but also as a foundation for secure and reliable data exchange between any stakeholder to support true B2B commerce without imposed proprietary systems or similar constraints for most effectively and cost efficiently modernizing the nation’s energy and transportation infrastructure.
The XBRL-CET working group has been active in connecting various public and private activities to promote utilization of the XBRL resource for construction of energy and transportation projects, and to break down the silos between stakeholders for multi-industry data interoperability that promotes innovation and enables risk management data analytics to facilitate the most cost effective and efficient financing and building of the nation’s infrastructure.
XBRL is now embraced by the surety industry, and the DOE has funded the expansion of the XBRL taxonomy under the Orange Button to include data from both the Contractors Open Standards Alliance/ Construction Progress Coalition and the International Electrotechnical Commission to synergize the financial markets with the construction industry to unleash the power and potential of data interoperability for building solar projects, and to make solar more bankable.
Leveraging XBRL and data standards for modernizing infrastructure
XBRL-CET has a Data Exchange Pilot underway that will facilitate the solar system construction and performance data being exchanged between the project owners, the contractors building the system, the contractors maintaining the system, and the financial markets that provide project financing, letters of credit and/or surety for financial guarantees, along with insurance and associated risk management strategies.
Collectively the improved administration and risk management will not only make solar more bankable, it will streamline the construction and financing process that will improve efficiency, reduce costs plus improve access to surety and bank credit for small business to expand opportunities for everyone.
On July 17, 2017 XBRL-CET responded to a USDOT request for ways to reduce burdens on building transportation projects. The suggestions and action plan included the USDOT synergizing with the USDOE for leveraging XBRL data interoperability for implementing consistent federally recognized machine readable data standards, and for transitioning away from manual paper processes to electronic transactions, including standardized electronic surety bonds.
Leveraging XBRL for Emergency Response Through Efficiency
The situation in Puerto Rico is a perfect example of where greater efficiency can impact the rebuilding of not only the islands energy infrastructure, the energy grid, but also encourage private enterprises to install solar and renewable energy projects than can utilize the modern grid.
Regardless if a solar project is public or private, utility scale or a rooftop system, they both have a construction phase followed by an operational phase, both can leverage the same data standards now part of XBRL and both would benefit from standardized policies and procedures for digital communication and electronic transactions.
More importantly it would allow the government to focus on the energy infrastructure, and promote the private sector to focus on the individual projects with private financing and competitive approaches like the DOE On Bill program / On Bill Pilot that combine to create a sustainable, resilient energy infrastructure and widely implements DER by both private and public entities.