EAI Response to CER National Smart Metering Programme, Presentation of Energy Usage Information (CSI) and Pay As You Go consultation papers

Transcription

1 EAI Response to CER National Smart Metering Programme, Presentation of Energy Usage Information (CSI) and Pay As You Go consultation papers Electricity Association of Ireland Retail Working Group 127 Baggot Street Lower Dublin 2 EU Transparency Register No:

2 CONTENTS INTRODUCTION... 3 KEY MESSAGES CSI PAPER... 3 KEY MESSAGES PAYG PAPER... 5 SUMMARY AND CONCLUSION

3 The Electricity Association of Ireland (EAI) is the trade association for the electricity industry on the island of Ireland, including generation, supply and distribution system operators. It is the local member of Eurelectric, the sector association representing the electricity industry at European level. EAI aims to contribute to the development of a sustainable and competitive electricity market on the island of Ireland. We believe this will be achieved through cost-reflective pricing and a stable investment environment within a framework of best-practice regulatory governance. Electricity Association of Ireland Tel:

4 Introduction The EAI welcomes the opportunity to respond to the CER s CSI and Pay As You Go consultation papers. These consultation papers are a key part of the work that is being undertaken in Phase 2 of the National Smart Metering Programme (NSMP) and the papers address important design issues that will impact on the success of the programme. A feature of the NSMP consultation process is that stakeholders do not have a full picture of the potential outcomes in the different work streams when providing feedback to these important consultation papers. Due to this uncertainty, the views outlined below are subject to change following material new developments that may emerge from the outcome of future consultation papers and CER decisions. Following the completion of this consultation process, the EAI Retail WG requests that the CER take time to review the feedback that has been provided by stakeholders in this consultation alongside a number of key design issues that also need to be considered at this time. These additional design issues include: The plans and timing for the roll-out of the IHD and introduction of TOU tariffs The appropriate period of support for the mandated IHD Technical solutions for the provision of cost and tariff information to customers in the period prior to commencement of the steady state phase Solutions to the provision of cost and balance information in the home to PAYG customers that request this solution Transition arrangements from the MIHD to enduring solutions where suppliers and others may provide alternative solutions to the MIHD Examination of alternative solutions to a one size fits all approach where the IHD is rolled out on a mandatory basis The supplier members of the EAI will each be providing detailed consultation responses to the CSI and PAYG papers. From discussion among the suppliers we have outlined below the key messages from the paper that all suppliers are in agreement on: Key messages CSI Paper 1. Smart Bill The EAI is broadly in agreement with the proposals for the smart bill. We would encourage the CER to remain flexible to changing consumer preferences when setting the on-going requirements for the smart bill. At the appropriate time, the EAI requests that the CER develops in a more granular level of detail the requirements for provision of information on the smart bill. 3

5 2. Mandated IHD A) Mandated roll-out Suppliers remained concerned that a mandatory IHD may not represent best value for money. IHDs are of interest to a minority of consumers in every other market and this may be the case in Ireland also. Mandating the funding of a device for national rollout that may remain unused by as many as 1.7 million households may undermine programme goals. A key principle of the programme design for suppliers is that if the IHD is rolled out on a mandatory basis this requirement must remain a responsibility of ESBN. ESBN has the enduring and exclusive responsibility for maintenance and support of the Smart Meter and Home Area Network (HAN) created by the Smart Meter. This gives ESBN primary responsibility for pairing and support of the mandated IHD. It also implies an ongoing support requirement for ESBN in pairing any future third party device or smart appliance with the HAN. Suppliers have no access to the meter or HAN from a support perspective. Any roll-out that would place mandatory obligations on suppliers would be impossible to operate in practice, extremely costly and would be likely to result in an unsatisfactory outcome for the consumer. B) Support period for the MIHD The EAI Retail Working Group feels that a 2 year support period for the MIHD following its installation date is not appropriate. The provision of an IHD to all customers is a significant undertaking and if this option is chosen then the IHD needs to be supported on an on-going basis that would cover the roll-out phase and introduction of TOU tariffs. The MIHD should be supported by ESBN to a fixed date after key milestones have been achieved. ESBN must also provide an enduring support capability to allow third party IHDs or smart appliances to communicate with the meter/han. C) Home Area Network The Steady State Model envisages that the MIHD will be replaced by third party IHDs or through an electronic device bridged to the HAN. It is extremely important to the programme design that the HAN is designed so that parties other than ESBN can securely and efficiently access the information that is broadcast on the HAN. The protocol adopted should facilitate a cost effective solution that, to the extent that is possible, will be compatible with emerging technologies and standards that are being developed in this area. The EAI requests that a clear technical solution in this area is developed and agreed by the industry. D) Availability of cost information on the IHD The role of the IHD is to provide real-time signals to consumers in the home to drive energy reduction. The EAI feels that it is important that 4

6 consumers can avail of cost information on the IHD so that they can manage their usage and adapt their behaviour in terms of the cost of their energy usage. The consumer research in this area highlights this preference. The Smart Meter trials demonstrated that consumers are not sensitive to particular price differentials or exact pricing to reduce energy usage. The existence of a price differential drove the reduction. Indicative pricing or ambient price signals are therefore the preferred method for sharing cost signals on the IHD. The provision of more precision makes the IHD overly complex to provision, creates customer confusion and creates an expensive support overhead for suppliers. 3. Customer Web Interface The EAI Retail WG has a concern that third party requests may place additional costs on the industry that provide no additional value to customers. EAI requests that the CER restricts the requirement for suppliers to provide consumption data to their customers and not to third parties. Key messages PAYG Paper The EAI welcomes the flexibility that thin PAYG offers to the market. The key ability for meters to switch between credit and prepay mode is central to the PAYG benefits. EAI acknowledges that multiple PAYG solutions may emerge using a variety of devices or media channels to share cost and balance information with consumers. EAI is however, mindful that some customers prefer to have cost and credit balance information available on display in the home. The EAI acknowledges that the solution potentially offers the flexibility to meet that preference. EAI urges the programme to develop this particular requirement further so that suppliers working with Networks can provide cost effective solutions to meet this demand. Summary and Conclusion The EAI has commented on items arising in the consultation paper where consensus emerged among its members. The points outlined above are important points for the CER to consider so that an optimal solution for the industry can be found within the constraints of the programme cost benefit analysis. The EAI now requests that the CER takes the time to review the current status of the project in light of the feedback received from both sets of consultation papers and also in light of the important design issues that have yet to be addressed. This review should include additional work to address key technical questions that need to be fully understood at this stage of the programme. The EAI also urges the CER to undertake further consultation if any changes are to be considered with regard to suppliers role within the programme. We look forward to working with you further through the Smart 5

7 Metering suppliers forum and the on-going work streams that are already planned. 11 th October