The U.S. Department of Energy
Office of Energy Efficiency and Renewable Energy
Solar Energy Technologies Office (SETO)


Request for Information:

Challenges and Opportunities for the American Solar Industry

Summary Recommendation
The DOE should continue its active leadership and engagement in establishing and promoting federally recognized machine readable data standards for digital communications and electronic transactions for the construction and operations of the Smart Grid infrastructure to promote ConstrucTech, InsurTech and FinTech innovation and competition enabled by the cost effective and reliable Orange Button data exchange, and to prevent silo approaches, proprietary systems, endorsements or exclusivity given to any provider of products or services.    

Jonathan Previtali
Director of Technology & Technical Services
Wells Fargo Renewable Energy & Environmental Finance

Board member - Wells Fargo’s Innovation Incubator

     Orange is the New Green (Button)


Responders

Other Comments Submitted


Comments to US Department of Transportation 
Transportation Infrastructure:

Notice of Review of Policy, Guidance and Regulation

Reducing Burdens for Construction of Infrastructure
Data Interoperability as Innovation Enabler
Impact


XBRL-CET Memo to Homeland Security
Modernizing Energy and Transportation Infrastructure
Emergency Response for Puerto Rico


Comments to California Department of Transportation 
Caltrans SB1 / SB103 Small Business
Reducing Burdens for Construction of Infrastructure
Data Interoperability as Innovation Enabler
Impact


Comments to US Department of Commerce 
   Cross- Agency Priority Goal:
Leveraging Data as a Strategic Asset
Reducing Burdens for Construction of Infrastructure
Data Interoperability as Innovation Enabler
Impact


Comments Submitted Webpage

From: Dixon Wright
Sent: Monday, January 07, 2019 1:55 PM
To: SETO.RFI.BOS@ee.doe.gov
Subject: DOE RFI Challenges and Opportunities for the American Solar Industry - Topic Four - CDX SRC SunSpec Wells Fargo and XBRL Response

January 7, 2019

The U.S. Department of Energy
Office of Energy Efficiency and Renewable Energy
Solar Energy Technologies Office (SETO)
Forrestal Building
1000 Independence Avenue, SW
Washington, DC 20585

Request for Information: Request for Information
Challenges and Opportunities for the American Solar Industry
              Topic Four: Balance of Systems Soft Cost Reduction

Attached please find our response to the RFI, which is an extension of the DOE Orange Button collaboration already in place, and reflects an emphasis for working with various trade associations to synergize with the objective of broaden stakeholder participation, supporting trade association initiatives, and to promote the overall public benefit instead of the focused silo approach to monetize solutions.

 As part of our collaboration, and to continue our efforts at outreach and education on the benefits of open standards based data interoperability as an industry undertaking, this response, as with all our various contributions to the national dialogue, is the on web at Surety Resource Connection, comments submitted section.

While submissions to this RFI concludes on this day, January 7th, the posting our submission for everyone to explore will further the objectives of the RFI and expand the engagement of stakeholders.

We look forward to continuing to contribute, and to help develop policies and procedures that eliminate barriers, reduce soft costs, enables innovation and promotes clean energy by attracting the capital and financial markets with innovation and competition.

Sincerely,

K. Dixon Wright
Surety Resource Connection

Nathan Wood   
Construction Progress Coalition

Tom Tansy
SunSpec Alliance             

Jon Previtali
Wells Fargo Bank

Alfred R. Berkeley
XBRL US

Larry Clopp
Surety Resource Connection                   

Larry Clopp

President / CEO

Surety Resource Connection, Inc.​

Nathan Wood
Founder & Chief Enabling Officer

SpectrumAEC


Executive Director

Construction Progress Coalition (CPC)

SUMMARY:

The U.S. Department of Energy Solar Energy Technologies Office (SETO) seeks information to help inform its research priorities, as part of its annual planning process. The purpose of this Request for Information (RFI) is to solicit feedback from industry, academia, research laboratories, government agencies, and other stakeholders to identify areas of interest related to challenges and opportunities for the American solar industry that are appropriate for federal government funding. This is solely a request for information and not a Funding Opportunity Announcement (FOA).

Notice of Request for Information: Challenges and Opportunities for the American Solar Industry
A Notice by the Energy Department on 12/19/2018

Alfred R. Berkeley
Former Vice Chairman and Acting Chairman of

     the President's National Infrastructure Advisory Council
Former Chairman of XBRL US
Former Director of XBRL International
Former Director of The World Economic Forum USA.

Comments Submitted - Recommended Action Plans

Action Plan - Data Interoperability
Promote the use of XBRL, FIBO and other federally recognized machine readable data standards to stimulate innovation and competition.

Prohibit the use of proprietary data standards for data exchange that constrains innovation and stifles competition for compliance with public laws.

Promote the use of industry trade group published data sets to be synergized with federally recognized machine readable data standards like XBRL and FIBO, and to have the respective trade associations maintain and update their data sets as warranted and under their control, and  for the benefit of their constituency.

Prohibit any industry trade group from imposing any constraints, licensing requirements, or fees of any kind on the use of the trade association data set if that data set is contributed to, and incorporated into, machine open data standards like XBRL and FIBO.

Action Plan – Digital Commerce
Promote the use of secure electronic bonds.  There are a number of competitive companies that already provide the service now and are in place ready to serve.

Prohibit the continued use of expensive and burdensome paper bonds that are subject to fraud.

Promote the use of competitive industry standardized surety bond delivery and administration systems on all public works.

Prohibit public agencies from imposing proprietary bond delivery and administration systems.  Examples are PennDOT and Nationwide Multistate Licensing System and Registry (NMLS)

Action Plan – Multi-agency data interoperability
Require all federal, state and local agencies to adopt federally recognized machine readable data standards like XBRL and FIBO as part of any funding provided by the government under MGT Act, the Federal Information Technology Acquisition Reform Act and others that provide funding for system upgrades.

Prohibit all federal, state and local agencies that receive funding from adopting or implementing a data standard or reporting requirement that does not utilize federally recognized machine readable data standards like XBRL and FIBO, or any requirement that is a “silo approach” to a single industry, trade association, or government entity.​

Action Plan – Cyber
Promote the engagement of stakeholders in best practices for cyber risk mitigation by the federal government providing clear policies and procedures as part of the Cybersecurity Information Sharing Act that when followed provide legal liability cover for all entities and stakeholders.

Provide a national defense posture for providing private entities and stakeholders with a national cyber protection resource, including real time monitoring and threat detection, to establish an offensive approach to mitigating cyber risk.

Provide a clear demarcation of liability resulting from a cyber-attack, where the government assumes liability for consequential liabilities and the entity attacked is only responsible for their internal costs and recovery expenses with the objective of providing the insurance market with a quantified risk and limited exposure to make cyber insurance more affordable and responsive.

Engage with working groups as part of the National Cybersecurity Public-Private Partnership.

Jonathan Previtali
Director of Technology & Technical Services
Wells Fargo Renewable Energy & Environmental Finance

LinkedIn


Board member - Wells Fargo’s Innovation Incubator


     Orange is the New Green (Button)


     2018 Global Climate Action Summit

     UN Sustainable Development Goals

     Wells Fargo

K. Dixon Wright

Senior Vice President - USI Insurance

Chairman - Surety Resource Connection, Inc.