National Smart Meter Programme. Presentation of Energy Use Information CER/13/164 Consultation Paper Response

Transcription

1 National Smart Meter Programme Presentation of Energy Use Information CER/13/164 Consultation Paper Response

2 Introduction The CER has issued this document to seek views and evidence on the presentation of energy information to consumers as part of the National Smart Metering Project. This information will be conveyed via 3 channels, an In Home Display, Smart Bills and a Customer Web Interface. Smart Bill The Smart Bill is defined as the presentation of accompanying information explaining energy usage with a customer s bill. Research with the Smart Meter trial and elsewhere shows that the bill is still the most engaging point of contact for consumers and will drive a large element of the energy reduction. This consultation will define the minimum mandated content to appear on the smart bill taking account of relevant EU and national legislation in this area. Consumers on prepayment will also receive an energy statement. We believe the frequency of billing should be left to the market to decide and that the energy statement need not be paper based. Calendarisation of billing periods may enhance the potential for demand reductions by facilitating product comparisons and making behaviour changes more observable. We agree that all the requirements that the CER are minded to include as defined are appropriate for incorporation in the Smart Bill. In time benchmark comparison information will be provided by the market and we believe it is not appropriate for the CER to mandate this requirement at this stage. Mandated In Home Display The primary purpose of the IHD is to provide consumers with access to real-time consumption information to enable them to understand their energy usage to enable them to modify their behaviour. Bord Gais Energy supports the provision of real time consumption information in the home We have consistently argued against the mandating of such a device as there is little research information to prove its effectiveness and that it does not represent best value for money. Despite this, the CER decided to mandate the requirement for the IHD and the responsibility for the procurement and support for this device rests with ESBN for a period of 2 years. It should also be remembered that ESBN also has the responsibility for the maintenance and support of the Smart Meter and the HAN. ESBN is therefore best placed to support a mandated IHD paired with the Utility HAN. As provider of the Meter/HAN. ESBN will always have to provide ongoing support for pairing any future 3 rd party devices with the HAN.

3 As it is likely to be a multi year roll out of the Smart Meters, we do not believe that 2 year support period for the MIHD will be sufficient. We believe that the mandate should remain in place until such time that the TOU tariff mandate is lifted by the CER. We believe cost information should be included on the MIHD. However it will be vital that customers are made aware that costs are for information only and are indicative in nature i.e. not bill quality. An advisory message on the IHD would be helpful in re-enforcing this. We would expect ESBN would be responsible for the provisioning of cost data onto the MIHD. How this can be achieved needs further discussion. Customer Web Interface Whilst we have not seen much demand from consumers to see their historic Half Hourly consumption data, we agree that it is appropriate that both Networks and suppliers provide access to consumer s consumption information. Networks will allow consumers access to historical consumption data that preceded their contract with a particular supplier. Responsibility for providing access to this data to 3 rd parties should rest with the consumer.

4 1. Evaluation Criteria Question/ Proposal Yes No Comments Q1. Is there anything you would add or remove from these evaluation criteria? No 2. General questions on all requirements Requirement SBR01: Energy Statement Arrangements and Communication Method SBR02: Electricity and Gas Time of Use Information SBR03: Year-on- Year Energy Usage Comparison SBR04: Additional Contact information SBR05: Hints and Tips SBR06: Complimentary Billing Information MIHDR01: Instantaneous Active Electricity Demand (Real- Time) MIHDR02: Up to Date Consumption Position in Time Q2a. What are the respondents views in regards to the definition of each of the requirements below? Are there any requirements that should be dropped?. However the bill might not be most appropriate channel for conveying such information. Q2b. Please provide your views on the relative impact assessment of the different options delivering each requirement in terms of the alignment to the evaluation criteria in the template table provided below. cost efficient: hard to see how purchasing a device with a 2 year lifespan could be an efficient use of money Scalable and future proofed: MIHD by its current definition will not be future proofed. As above

5 Period (Cumulative) MIHDR03: Past Period Consumption Comparison (Historical) CWIR01: Access to Historical Consumption Information in a National Harmonised Format MIHDR01(a): Instantaneous Cost of Demand for the Hour MIHDR02(a): Up to Date Cost Position in Time Period (Cumulative) MIHDR03(a): Past Period Cost Comparison (Historical) MIHDR04: Ambient Feedback of Electricity Time of Use Tariffs MIHDR05: Tariff and Price Information Whilst we agree that access to consumption information is a requirement, we do not agree that the information needs to be provided in harmonised format. This should be left for each provider to specify.. It is important that Suppliers be allowed innovate the format consistent with Customer requirements.. Cost should only be indicative.. Cost should only be indicative.. Cost should only be indicative. There is no evidence to suggest that the provision of accurate tariff and price information is a key driver for change. Indicative pricing will be sufficient. As above Question/ Proposal Comments Q2c. Are there any additional requirements that should be considered, please provide rationale and No.

6 assessment? 3. Questions on specific requirements Question/ Proposal Q3. What would be the least frequent level of data refresh that would be appropriate in order not to adversely affect the ability of the consumer to control their energy consumption effectively? Q4. What are the respondents views in regards to the definition of each of the potential requirements for display of cost and price/tariff information on the MIHD? Q5a. What are the respondents views in regards to the display of cost and price/tariff information on the MIHD for the options described above? Q5b. Is it a viable option for consumers to be asked to update price and/or time band information? Q5c. Would it be appropriate to expect suppliers to provide an alternative device to consumers who opt for alternative tariffs? Q6a. What are the respondents views with regards to the options for access to data for 3rd parties and the minded to position for the Customer to access and pass on this data? Q6b. What are respondents views on the options and minded to position for who is best placed to provide the national harmonised data to Customers? Q6c. Are there any alternative options that should be considered, please provide rationale and assessment? Q6d. Should there be guidance or regulation on how Customers are told that they request this data (e.g. if a Comments We do not believe it is appropriate at this stage to consider this question. This is a design consideration. The definitions are appropriate. It should be called out that the cost should only be indicative and not bill quality. ESBN are responsible for the MIHD. They should also be responsible for the display of cost and price/tariff information on it. We do not believe that our price/tariff data should traverse the SMA. No. This should be left to the market to decide. In time, suppliers/3 rd parties may wish to respond to consumer demand and provide alternative devices. Customer should have control. Suppliers requirement to provide the data should be limited to their customers only and not to 3 rd parties. Suppliers and NWs should provide consumption data, but not necessarily in national harmonised format. It is unlikely that all customers will appreciate the same format. Suppliers should be allowed to tailor formats in accordance with customer preference. This should encourage increased customer interaction with available data. No. Yes.

7 Customer contacts a supplier for data, should the supplier notify Customers they can get data from networks beyond start of contract and/or export data? Q6e. What would be the longest period that it would be appropriate for a consumer to wait to receive data through the web interface? Q6f.What would be the most appropriate national harmonised format for the data download? Q7a. What are the respondents views in regards to not regulating for benchmarking at this stage, but expecting this to happen in the open market and to review and revisit this in the future? Q7b. What are the respondents views on the presentation of micro generation information to the Consumer? What are the options? Too soon to have a view on this. It is too early in the process to define an appropriate format. Agree. This area has not been given due consideration to date and therefore should be left open for now. 4. Questions on other policy considerations Question/ Proposal Q8a. What are your views with regard to a 2 year support period? Should the MIHD be supported for a shorter or longer period of time, to a fixed date or any alternatives? Please provide reasons. Q8b. What are your views with regard to options for supporting the provision of energy usage information within the home post the mandated support period of the MIHD? Q9. What are your views on the benefits to Consumers of the frequency of informative billing? Should this be not less or not more than per Customer type or should it be specific where smart meters are installed e.g. monthly? Comments There seems to a suggestion that suppliers will support the MIHD after the support period is over. This is wholly unacceptable to BGE. ESBN should be required to support the MIHD until such time as the TOU tariff mandate is lifted. ESBN will continue to have a rule to ensure the data is broadcast within the home post the support period and that other devices can be paired to the HAN. We believe that the market (supplier or 3 rd party) will respond to consumer demand for such devices if it manifests itself. It should be left to the market to decide on the appropriate level of billing frequency. Suppliers will respond to customer preference and likely provide a range of billing periods to customers. 1. Data Availability and Protection

8 Question/ Proposal Q10a. What are your views on the data protection approach set out above? Q10b. Are there any other data protection considerations CER should consider in relation to the requirements set out in section Comments This question was dealt with in our response to the PAYG consultation paper. Not they we are aware of.