INTRODUCTION. SSE Airtricity welcomes the opportunity to comment on the CER s paper National Smart Metering Programme - Smart Pay As You Go.

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1 CONSULTATION ON CER NATIONAL SMART METERING PROGRAMME SMART PAY AS YOU GO SSE AIRTRICITY RESPONSE TO THE COMMISSION FOR ENERGY REGULATION 2015

2 INTRODUCTION SSE Airtricity welcomes the opportunity to comment on the CER s paper National Smart Metering Programme - Smart Pay As You Go. SSE Airtricity is the largest independent supplier operating in Ireland with over 800,000 customers served across both electricity and natural gas markets. SSE Airtricity is committed to the development of competition in energy markets in Ireland and to presenting its customers with choice and quality customer services. We continue to be supportive of the NSMP and believe an effective roll out will provide opportunities to directly deliver benefit to our customers, both in terms of the customer experience and optimised energy usage. We see smart metering as a fundamental component in the continued success of the energy retail markets in Ireland. 2

3 GENERAL COMMENTS SSE Airtricity welcomes the opportunity to put forward its views on the Smart Pay As You Go consultation paper published by the CER. The PAYG model has become an increasingly popular model for customers, in particular those seeking ways to control and manage their energy budget and energy related debts. As such, it is essential that the model for PAYG developed for smart metering can adequately meet the needs of customers and is accessible for those who need it most. SSE Airtricity is seriously concerned that the PAYG model proposed by the CER may significantly reduce the level of control and real time information customers currently have access to. We also believe the heavy reliance the current proposed model will have on smart technology and web based applications may exclude a significant number of those customers who need PAYG metering most. With this in mind, SSE Airtricity would like the CER to reconsider the thin meter solution for PAYG and consider having a level of information available to customers at the meter level. We believe that if the programme is implemented in its current format that it may have significant unintentional consequences for both consumers and the industry as a whole and will meet a high level of customer resistance. In this respect, SSE Airtricity supports the statement made by SVP in their January 2014 response to the CER s consultation: SVP believes that the primary objective for smart metering is to enable the customer to manage their energy consumption and related costs more effectively, be they credit or PAYG customers. Providing customers with appropriate choices and information to make decisions will then enable these customers. SVP seeks to ensure that smart metering offers maximum opportunities for vulnerable households to use and pay for energy. SSE Airtricity does not believe the current proposal for PAYG supports this outcome. We are also concerned that when issues are flagged with respect to the PAYG solution they are addressed by adding additional complexity and cost for suppliers rather than reconsidering the principle behind the solution. Our general concerns in this regard our addressed below. 3

4 Technology SSE Airtricity is concerned that the level of interaction customers will need with additional technology such as smart phones and the internet will exclude some customers from using the PAYG model when the switch to smart metering occurs. At the core of the proposals is the inherent idea that customers will now have to openly engage with additional technology types, secondary to their energy usage, in order to effectively use their PAYG smart meter e.g. to request their credit balance they may have to access the internet. This reliance on an alternative technology is outside both the supplier and customer s control. For instance if the customer s credit is low and they want to view their balance they may not have internet access, phone credit or coverage which would allow them to do so. They would also be unable to receive appropriate notification of the disconnection/friendly credit for the same reasons. SSE Airtricity believes the CER should reconsider the way this model is being progressed in order to ensure that customers will continue to be able to use PAYG meters without facing additional cost to do so or the prospect of over complexity. Market Entry Within the context of the decision paper it will become the remit of each individual supplier to appropriately maintain and operate back end systems to facilitate the PAYG model. This may be a barrier to market entry for small suppliers to implement due to the costs associated with the proposed model. In order to prevent competitive barriers it would make more sense for the industry to implement a thick model solution. This would allow for the costs to be spread out far more appropriately and evenly among each supplier. We believe that a thin solution will potentially impede competition. Half hourly data The paper states that the new platform for services will be based on halfhourly meter reading, collected remotely every day with data from the meter also being broadcast securely for access by the customer within the home. However there are still issues in relation to half hourly data that need to be resolved such as various data protection concerns. It is essential that suppliers can access this data in order to update accounts and provide appropriate tariffs to customers. 4

5 Managing Energy Costs Pay as you go meters have played a major role in helping customers budget or avoid being disconnected. They continue to be one of the most effective measures to assist customers in financial difficulty facilitating them to make small and more frequent payments e.g. 5 euro a day. We believe the advent of the proposed smart meters will reduce the ability of customers to continue this behaviour in the same way due to the reliance on additional technology which they may not have. The proposed model provides less information and functionality to what is currently available to customers with PAYG meters. If there is a level of resistance to these PAYG meters from current customers it may reduce the ability of suppliers to provide innovative smart tariffs as an option for customers who need PAYG meters. Consumption Information The only data held by the meter is the recorded energy consumption, and the calculation of the customer s balance will be carried out in the supplier s system. As stated before without secondary technology customers will not be able to make an adequate assessment of the balance which may confuse them when independently calculating the usage. Endurance of the PAYG Model As stated above there are major issues that need to be addressed before implementing smart meters. By removing the functionality in all aspects of the meter to the back office systems, it removes the appeal of the meter to a portion of the customer base that it is primarily directed towards such as customers who are wishing to manage their energy usage more appropriately and who therefore opt for a PAYG option. Customers will not have the same desire to switch to this model in the first instance and therefore the customers choosing this option as a deterrent to excessive usage will decline. We would argue that this goes against the principles of the smart metering programme such as to ensure that PAYG customers are not disadvantaged by their Smart meters. The programme needs to be cautious of creating unintentional consequences, such as making PAYG cost prohibitive and unattractive for suppliers and will not serve customers in the long term. 5

6 SPECIFIC COMMENTS Transfer Credit to PAYG Q1. Do you agree with the above assessment? Please provide rationale. SSE Airtricity would broadly agree with the assessment of change required in this context. We would however request that the CER carefully consider the assessment of the suitability of PAYG for customers as we believe that some types of vulnerable customers may not have been appropriately considered in this context. For instance pending final decisions on the design it is possible that certain customers may not be able to avail of the PAYG model in a smart metering world. Separately we would like to highlight the fundamental change of the requirement for the customer to not opt-out of interval data provision that hasn t been appropriately addressed in the context of this section of the consultation. It is important to note that customers must be obliged to be opt-in to avail of the PAYG services. Without the interval data, suppliers will be unable to provide predictive values in the context of their obligation to provide customer with credit value on demand. We would also ask the CER to consider how a customer will be switched to the PAYG model where they are in debt and not engaging with their supplier. At the moment, if a customer fails to engage or to take a PAYG meter a supplier will move to disconnect the property. Under the smart PAYG model a supplier could remotely switch a customer to PAYG instead of removing supply. This may be preferable to a complete disconnection of the property. Q2. Respondents are invited to provide their views on the interaction between smart PAYG and Budget Controllers as part of the transition to smart PAYG, both from an individual customer perspective and more broadly, in relation to market interactions. SSE Airtricity is concerned that the reduction in functionality under smart PAYG will be less attractive to customers who have opted for a budget controller and anticipate a high level of resistance. Customers elect to have a lifestyle meter for very specific reasons such as self imposed control and budgetary considerations. They also facilitate co-habitation situations and support the customer requirement that all parties share the cost of the fuel 6

7 use. At this point it is unclear how the smart metering programme will deal with this specific customer base. SSE Airtricity does not believe it appropriate to continue with additional budget controller mechanisms following the introduction of smart metering and the smart related PAYG solution. This type of technology can t support the principle aims of smart metering. For instance, if a Smart Meter can be installed but not activated and a lifestyle device remains in situ it is almost certain that the customer will continue to, primarily, interact with the lifestyle device, meaning the customer will continue to see themselves as a PAYG Customer but the supplier will only see them as a credit Customer. In this scenario, it is difficult to determine how a supplier is expected to react to (or interpret) stated smart obligations such as sending low credit/no credit warnings. It is likely that suppliers would have to implement and continue to adhere to a separate Code of Practice for this customer base which would cause confusion for customers and the industry. There are also significant issues currently been discussed in the industry in relation to budget controllers impacting on switching which need to be considered. Therefore it would be premature to make any decision at this point on future scenarios when the current situation remains unresolved. We would also anticipate a level of resistance or inability to install the meter in the premise for other non PAYG customers This is part of a wider issue that needs to be addressed and a comprehensive solution is necessary for people who are resisting meters in general. In this context it is important to address technical difficulties and barriers to switching for particular customers and premises and to provide solutions for the causes. Q3. Do you think that this range accurately depicts the range of possible detailed policy designs in this area that are consistent with the high level design? If no, please explain why. SSE Airtricity does not believe that this question can be answered definitively at this point in time without further debate. Whilst it is clear that all the options presented have merit, each one requires more investigation such as an SWOT analysis in order to appropriately establish the advantages and disadvantages. In this context there are issues around half hourly data that need to be resolved such as the ability to receive it and data protection issues. As a supplier we would be inclined to support the proposals set out in example 1 and argue that it is in the industries best interest to improve 7

8 and embellish the national top-up payment channels so as to provide the customers with the widest possible set of options. In relation to the other examples it is important to take into account the fact that suppliers do not own or control most of the payment channels. For instance we have little influence on the Post Office payment infrastructure. Therefore if specific SLA s are imposed that cannot be facilitated by this channel then it may have to be withdrawn which will disproportionately impact hardship PAYG customers. Furthermore it is important to note that no one can predict what financial regulations may be in place in the future which could potentially impact the processing of payments. Consequently we need to be careful that decisions made in this regard don t lead to an unintentional situation were more payment channels/methods (e.g. visa cards) are under threat by virtue of the fact that the Smart obligations cannot be realised. Therefore SSE Airtricity proposes that that CER adopt a light touch regulatory approach but put a robust monitoring mechanism in place which can be reassessed in the future. Q4. Respondents are invited to provide their views on these examples. SSE Airtricity would argue that SLA s are acceptable in relation to the updating of the customer credit balance and the issuing of a reconnection notice after validation of payment/top-up has been received. In this context we believe that suppliers should be obliged to act accordingly once they have validated the payment. However it must be recognised that they don t have control over most of the channels to influence the lifecycle of the payment notification. When a customer avails of supplier s online top-up service it should result in a near real-time credit update but this cannot be guaranteed for other channels. It is also important to note that if someone is disconnected they may require quicker reconnection based on their specific circumstances. Whilst it is clear what the customer protection intentions of CER are in this regard the points raised in the previous questions remain valid. Credit runs low Q5. Do you agree that further policy detail is required in respect of how the minimum alert levels are set? Please provide rationale. 8

9 SSE Airtricity is of the opinion that further policy or a set of guidelines is appropriate but requires more debate and is a topic that should be addressed at the planned customer focus groups. This is an area where it should be accepted that it is in supplier s best interest to communicate with their customers and keep them advised to the best of their ability on the status of the credit balance. This arrangement is best left between the supplier and the customer to agree as suppliers will want to develop communication channels that are service differentiators and to avoid disconnections as much as possible. Furthermore we believe that making certain communication channels mandatory will always have a degree of futility because you cannot impose an obligation on the customer to have access to a certain technology. For instance certain customers won t have mobile phones and others may not have access to internet due to coverage or social needs considerations. We believe that any notion to impose an obligation on suppliers to provide an in-home solution or alternative device must also allow for cost reflective charging. All of the impeding technical considerations must be factored into any such decision. Another thing to consider in this context is a requirement that the Sound alerts remain a functionality of the meter and they could be triggered by market messages. This would mean that customers that do not have access to technology (mobile phones, internet etc) will retain an inhome experience that they currently enjoy. Q6. Do you think that this range accurately depicts the range of possible detailed policy designs in this area that are consistent with the high level design? If no, please explain why. SSE Airtricity would be of the opinion that minimum period or calculation parameters would not adequately take into consideration the full spectrum of the customer base. The high level design is underpinned by the programme objectives, one of which is, improved customer experience. Whilst it may be prudent to indicate a minimum set of alerts the model of prescriptive regulation will not facilitate a meaningful relationship between suppliers and customers and therefore do nothing to improve customer experience. It is more likely that a prescriptive model will create an inconsistent experience across the customer base. It is also quite evident based on the current model that some customers don t want any alerts as they feel they are an imposition on their life and choose to disregard or disable them. 9

10 Q7. Respondents are invited to provide their views on these examples. SSE Airtricity would be unsupportive of options 3 and 4 as they seem to imply that there is a major issue to be resolved with the current model whilst providing no evidence to substantiate this contention. We would be of the position that if there is a problem it is being created by the thin solution smart meters and these options are an attempt to fill the void being created by a wrong solution for PAYG. SSE Airtricity believes that options 1 and 2 have more merit and are deliverable with reduced need for additional cost and technical complexity. They would allow for supplier and customer discretion and promote innovation in the industry. However we believe that these aspects require further debate and the programme needs to be cautious of creating unintentional consequences such as making the smart PAYG model cost prohibitive and unattractive for suppliers. We need to be careful not to make an incorrect decision at this point which could unnecessarily impede competition in the future. Q8. Do you consider that this is a significant enough issue to require additional regulatory provisions to minimise the possibility of a customer missing an alert? SSE Airtricity believes that this area requires further debate as a large element of this relates to customer responsibility and behaviour that cannot be governed by CER regulation. In this respect it is impossible to appropriately legislate with respect to an energy customer as it is underpinning the notion that a customer will always have a communication device in credit, in proximity and paying attention to the alerts. We believe that any decision in this regard may imply that a supplier would become responsible for the status of a customer s computer or mobile phone. Credit runs out Q9. Do you agree that further policy detail is required in relation to the minimum provisions for customers as their credit runs out? Please provide rationale. SSE Airtricity seeks clarity on whether this question means further policy beyond the Alerts & Friendly Credit policies. If this is the case then we would not envisage or support a requirement for any additional policy in this 10

11 regard. For instance section argues that the customer needs to be protected from running up debt that they cannot pay, and this principle needs to be maintained. Furthermore we believe that customer responsibility means that disconnection has to be a viable process and not one that is fraught with controversy and ambiguity. SSE Airtricity proposes that additional policy is not considered at this time but a robust monitoring regime is put in place to look at the emerging smart experience coupled with the future payment channel solutions and customer behaviours. Q10. Do you think that this range accurately depicts the range of possible detailed policy designs in this area that are consistent with the high level design? If no, please explain why. SSE Airtricity would argue strongly that the proposal of disconnection only when below zero (based on actual reads) is the only fair and equitable model for all stakeholders. We believe that the SLAs from the Networks organisations will play an important role in allowing suppliers fulfil this obligation. Whilst Suppliers will, at a point in time each day, have the reading data it will never be possible to be certain that they have all the appropriate top-up data. As argued previously, suppliers do not own or control all the various payment channels. Q11. Respondents are invited to provide their views on these examples. As per the above, SSE Airtricity would argue that disconnection only when below zero (based on actuals) is the only fair and equitable model for all stakeholders. We believe that disconnection only when Customer consistently fails to top up will be challenging and costly to manage and could be open to abuse. Suppliers only consider disconnecting customers as a last resort and the idea that additional regulatory framework is required is an unfair reflection on the industry. Disconnecting non paying non engaging customers is an unfortunate but nonetheless necessary evil and protects all customers from socialised charges and is an understood part of the commercial relationship between customer and supplier. Furthermore it is important to note that there is already an additional cost on suppliers for maintaining and operating the current credit control PAYG models. The proposals suggest that suppliers will have to build a further secondary credit control process for PAYG smart meters. This would not be an acceptable provision from a supplier point of view and would be contrary 11

12 to the purpose of the PAYG model. Again, the programme needs to be cautious of creating unintentional consequences, such as making PAYG cost prohibitive and unattractive for suppliers and will not serve customers in the long term Q12. Do you believe that these provisions emergency credit and friendly credit periods should remain in place for smart PAYG? SSE Airtricity would be supportive of the retention of emergency credit and friendly credit period provisions. However we believe that some additional debate would be necessary in order to assess how this will function in practice in the context of other technical and policy decisions in order to negate any contradictions. Q13. Should friendly credit provisions be extended to cover gas? SSE Airtricity would also be supportive of the extension of these provisions to cover gas. Q14. Do you think that requirement should be considered for the length of time that it takes the network to deliver the daily meter read? SSE Airtricity does not believe that this topic needs to be addressed within the context of this consultation as we would be of the understanding that this will be the subject of a programme workshop between ESBN and other stakeholders. It has already been determined by the programme that agreed SLAs will be arrived at during the course of these discussions to be scheduled in due course. Q15. Do you think that a requirement should be considered for the length of time that it takes the supplier to apply the meter read to the customers balance? SSE Airtricity seeks clarity on whether it is consumption that is the important parameter in this regard. We believe that it is in supplier s best interest to process all data regarding a PAYG as soon as is it technically possible after it has been received. Implementing additional regulation in this regard will only lead to disagreement and onerous monitoring that will serve no benefit to customers. There are also issues in relation to half hourly data that need to be resolved in this context. SSE Airtricity proposes that all stakeholders would be better served if the network providers are obliged to prioritise the provision of PAYG daily data to suppliers. SSE Airtricity proposes that PAYG data be bundled into market 12

13 messages that only contain data for PAYG customers. This model would facilitate the prioritised processing of PAYG customers data through the process lifecycle. Reconnecting your Supply Q16. Do you consider that some customers may have additional requirements for topping up? And if so, should the regulatory framework make provision for this? Please provide rationale. SSE Airtricity understands that there will always be a set of customers with additional requirements. We suggest against making the process of serving these customers more onerous and costly by applying more regulatory provisions. Suppliers have demonstrated, over the last number of years, a wiliness to work with this customer base and to try and serve all their changing needs such as facilitating them having to make small minimum transactional amounts e.g. 5 euro a day. We believe a more cautionary approach should be adopted with the implementation of more appropriate monitoring practices. Q17. Do you agree that further policy detail is required in relation to the minimum provisions for how quickly PAYG customers are reconnected? Please provide rationale. SSE Airtricity agrees that SLA s are acceptable regarding the issuing of a reconnection notice by suppliers after validation of payment/top-up has been received. In this context suppliers should be obliged to act as soon as technically appropriate after they have validated the payment. However it has to be recognised that they don t have control over most of the channels to influence the lifecycle of the payment notification. When a customer uses the supplier s online top-up service, then this should result in a quicker credit update (dependent on the supplier s arrangements) but this cannot be guaranteed for other channels. There is also an inherent contradiction between consumption and top ups in this regard and it is still unclear as to how this will be resolved in practice. Q18. Do you think that this range accurately depicts the range of possible detailed policy designs in this area that are consistent with the high level design? If no, please explain why. 13

14 SSE Airtricity would be of the opinion that assessing the full range of these options is not the most appropriate question to address in this context. What we need to establish is, which options are practical, equitable and relevant. As per our previous arguments suppliers should be obliged to issue the reconnection notice as soon as technically possible after they have validated a payment or top-up. However it is important to highlight that suppliers have no control over the process from that point forward. Reconnection within a certain time frame depends on whether the process is automated or not and this still needs to be appropriately addressed. Q19. Respondents are invited to provide their views on these examples SSE Airtricity would be of the opinion that there is no real differentiation in the minds of suppliers across the first three examples. It is quite clear that all suppliers desire to get customers reconnected as soon as humanly and technically possible. Suppliers endeavour to educate customers when possible that payment via online channels will result in shortening the process to reconnection notice issue. However there is a general awareness in the industry that not all customers can avail of all the options. It s difficult to see how an additional regulatory framework is going to make this situation any better for customers and it may add unnecessary overhead and costs to the process. In reference to example 4, SSE Airtricity believes that this doesn t need to be separated out. Under any of the other options a customer can contact the supplier and seek to prove that they have made a top-up. In reality there are restricted circumstances in which a customer can prove this remotely but a reconnection in these circumstances is often based on a trust between the agent and the customer. Q20. Do you agree that the question of how to calculate/estimate the top up amount required to reconnect should be considered further in this phase of work? SSE Airtricity would be unsupportive towards any definitive decision in this regard during this phase of work. Whilst it is legitimate to discuss and debate these topics, we would caution against making any imprudent changes were there is no justification or necessity for change. At this point in the programme it is important not to overcomplicate any area where there is an option to review the regulatory framework at a later stage if the expected behaviour or customer experience is not forthcoming. 14

15 Q21. Which of the above methodologies do you consider preferable? Please explain your rationale. SSE Airtricity would be supportive of incorporating and maintaining aspects of the current model which prevent customers from accruing additional debt. From a supplier perspective the process of calculation of top-up and consumption will work on the basic principle that the top-up amount brings the customer above zero which would have accounted for friendly period and subsequent consumption (which may have to be estimated). A minimum top-up amount regime may help to mitigate additional disconnections to follow quickly after the reconnection. We believe that aspects of the current model that prevent a customer from accruing additional debt should be maintained. View Balance Q22. Do you agree that further policy detail is required in relation what the minimum provision of information is to customers when they request their credit balance? Please provide rationale. SSE Airtricity would argue that it is important that the CER sets expectation properly with customers in the context of what is reasonable and possible. In this context we believe that the balance as viewed should be indicative and not necessarily in the format of a bill. We would also argue strongly that On demand needs to be defined more clearly and it should not imply that a customer can request an update continually i.e. every five minutes. In this respect services may need to be automated so not all customers will have access to all solutions all the time. As argued in relation to other elements of PAYG, the more technology the customer has access to, i.e. Smart Phone or internet, the greater the range of options that they can avail of. On this basis it is necessary to argue that a thick smart meter would be a more appropriate solution as it would eliminate the requirement for customers to rely on technology independent of their energy supply to fulfil their energy needs. Suppliers will also have to have due consideration for data protection concerns which may mean robust security protocols that will not translate into optimum experience for all customers 15

16 Q23. Do you think that this range accurately depicts the range of possible detailed policy designs in this area that are consistent with the high level design? If no, please explain why. Notwithstanding the high level design, SSE Airtricity would argue that this range does not appropriately take into account the fundamental issues affecting the PAYG financial hardship customer base. From reviewing the questions and examples posed in this paper it becomes clear that there is an inherent recognition of the many benefits that PAYG customers currently enjoy by having information readily available in the home. On the basis of this we would raise serious concerns as to whether the thin smart solution is the best model for PAYG. Considering the consultation paper is presented in the context of been highly customer centric, it is arguable that a hybrid Smart thick solution for PAYG is the better solution. Q24. Respondents are invited to provide their views on these examples. SSE Airtricity would not be in a position to provide an adequate view on each of these examples as we believe that they cannot be addressed as if they are mutually exclusive. All suppliers want to provide customers with the information they need and will always endeavour to do what is technically practicable, possible and cost effective. It is acceptable to set criteria around the minimum set of data to be provided (this needs further consultation) but there is no discernable need to go beyond that through a regulatory framework. Q25. Do you consider that the on demand balance will be more important for customers in financial hardship to have? And if so, should the regulatory framework make provision for this? Please provide rationale. SSE Airtricity would argue strongly in favour of the benefits of constant balance updates with regard to financial hardship customers using the PAYG model. In this context we believe that it is not only important but essential to this group. Customers in financial hardship generally work out their daily/weekly budget rigorously so they have to have access to their balance to budget for that. Whilst we understand that this point was debated in previous consultations and that a thin solution was agreed upon in the high level final decision, we still believe that a thick solution should have been more strongly considered prior to making the decision. As evidence for this we would point towards other jurisdictions were this type of meter technology is available and has been universally proven to 16

17 provide customers including financial hardship customers with in-home on demand balance. This type of design is clearly a far more inherently customer centric solution and we see no need in deviating from such an accepted model. Moreover, each time questions are posed in this regard it becomes abundantly clear that the wrong decision was made for PAYG and therefore it needs to be strongly challenged. Transfer to Credit (from PAYG) Q26. Do you agree with the above assessment? Please provide rationale. SSE Airtricity agrees with the proposals and would suggest that there is no requirement for regulatory change. We would also agree that the electricity and gas requirements are aligned as much as possible. However we believe that suppliers should be able consider if the customer is in debt before switching these customers between each model. Q27. Do you agree that transferring between smart and non-smart PAYG should be considered as part of the detailed regulatory design? SSE Airtricity would question the merit of posing this question at this juncture on the basis that the CER has consistently stated that Budget Controllers are out of scope for the programme and they have not been part of any consultation to date. We would also note that the whole area of lifestyle/budget controllers has not been appropriately debated since the last consultation on the supplier handbook and therefore requires wider consultation. Q28. Do you agree with the above assessment? Please provide rationale. SSE Airtricity believes that the 2 month refund limit will still be relevant following the introduction of smart metering and that any decision on reducing the time allowed for a supplier to refund a credit balance would require further consultation and should not be decided upon in the context of this decision. Regardless of any changes to data collection timescales, it can still take suppliers time to process refunds. Q29. Do you have any further comments? SSE Airtricity proposes the inclusion of a PAYG flag into the proposed Market Design in order to facilitate the implementation of the smart metering programme with respect to PAYG. This would involve the network provider 17

18 "partitioning" PAYG MPRNs and GPRNs into separate files to credit customers. This would allow for suppliers to prioritise those files rather than have to search and extract PAYG MPRN s and GPRN s from all the combined PAYG/Credit files. We believe that it is a valid requirement that a PAYG flag exists for all technical design solutions to be considered. 18

19 CONCLUSION SSE Airtricity welcomes the opportunity to put forward its views on the Smart Pay As You Go consultation paper published by the CER. We believe that in order for the PAYG model to endure following the smart metering roll out the industry needs to carefully assess how it will work in practice. Whilst we have responded to each of the questions posed in the consultation paper we would still argue strongly that the solution to most of the deficiencies addressed would be the implementation of a thick smart metering model. 19