- 1 Introduction
- 2 Smart meter roll-out plans and timetable (incl. opportunities for involvement, data issues, support for vulnerable etc)
- 3 Licensing of different roles in energy system (supply, distribution, meter operation, access to DCC etc)
- 4 Opportunities to mandate ‘smartness’ in new developments and refurbishment
- 5 ‘Space to experiment’ opportunities to operate outside full regulatory regime (Ofgem, DECC etc) – and what could be done
- 6 Privacy (for both individuals and commercial interests) vs public good. Can data be anonymised while still retaining sufficient detail?
- 7 References
The regulatory and policy framework is currently undergoing changes to get up to speed on smart meter roll-out. Changes include updating energy licences and codes, for example requiring energy companies to roll-out smart meters. Additional license-able activity has been introduced including the provision of communication between suppliers and other parties, and smart meters in consumer premises.
Key regulations and licencing
The key regulations governing the UK energy sector are the Electricity Act 1989 and Gas Act 1986, which have been amended many times. The Energy Acts, 2008 and 2011 govern these changes in relation to smart metering. The Acts prohibit activities such as supplying electricity without holding a licence to do so. Licence holders must comply with the Licence conditions and this is enforced by Ofgem, the Gas and Electricity Markets Authority. Under the licence conditions sit the industry codes detailing the technical and commercial obligations.
Data and Communications Company (DCC)
The Data and Communications Company (DCC) was a new licensed entity to the energy supply system in September 2013. The DCC is currently setting up and is expected to be fully operational by April 2016 as the sole provider of remote communications services for smart meters. For the first six months of operation it will be under a contingency period governed by DECC "to enable the DCC’s systems and services to come together with the energy companies’ systems and processes in a coordinated start to the main installation phase"
Smart Energy Code (SEC)
Under the DCC license, the Smart Energy Code (SEC); a new industry code, was established which sets outs the rules, rights and obligations of all parties for the new metering obligations. The SEC is a multiparty contract which sets out the terms for the provision of the DCC’s Smart Meter Communications service, self-governed by a panel of SEC party members and regulated by Ofgem. A consultation of the SEC content and related supply licence amendments was launched in July 2015; responses are expected to be published late 2015.
Timeline of the background smart metering policy development
Below is a timeline of the background policy development, and the development stages (Tranches 1 to 6) relating to Smart Metering.      
Smart meter roll-out plans and timetable (incl. opportunities for involvement, data issues, support for vulnerable etc)
Overall progress and plans
We are currently at the Foundation Stage (since December 2012). We are expected to enter the 'mass-roll out' phase April 2016, which is later than the most recently revised date of December 2015. The delays are caused by difficulties in developing specifications and protocols and there is now further delay in notifying SMETS2 and GBCS which has a knock on effect to the DCC. However, delays are resulting in increased cost, for example energy companies who have invested in training, such as British Gas are keen to keep the momentum going so they can continue to keep the trained installers in work.
DECC have named the current phase the 'Transition phase' of the Smart Metering Implementation Plan (SMIP). This is considered to be the stage where commercial, technical and regulatory plans will enable energy suppliers to roll-out the smart meters, in collaboration with the DCC. The Government are working with industry and consumer groups to develop the regulatory framework.
The role of energy supply companies
Energy companies are responsible fro the roll-out of smart meters, DECC and Ofgem can impose financial penalties if they do not meet targets. The energy companies must sign and work to the Smart Metering Installation Code of Practice (SMICoP). Previously, there was discussion the opportunity for District Network Operators (DNOs) to lead the roll-out as they could easily lead roll-out on a street by street basis, however this could have created issues clarifying ownership and leasing of meters. Also, they do not have a regular customer relationship - except recently through the Priority Services Register customer care.
Previous research by Zoe and Simon, here at CSE identified the risks of energy suppliers delivering smart meters, since many people have a general mistrust of energy suppliers. The key risk they identified was the fact that the programme cost control system relies on "competitive pressures in the energy supply market", which is also intended to ensure benefits will be passed to consumers - highlighted as naive. In addition, they identified potential conflicts with data use; the need for privacy may undermine the potential benefits of having smart meters in the UK.
Smart Metering Installation Code of Practice (SMICoP)
SMICoP is set out in two sections: A: The Code of Practice and B: Code Governance. Section A outlines the legislation relevant during the pre, during and post Smart Meter installation stages:
- Relevant legislation and regulation: including preparing site access, marketing, advertising, Data Protection Act 1998.
- Relevant accreditation: this is for the installers including National Skills Academy for Power and Gas Safe Registration.
- Promoting the code: to build confidence with customers
- Engagement and Customer Awareness: Ensuring that information is clear and concise - also tailored for vulnerable groups with specific needs.
- Scheduling visits: Installers must communicate visit plans effectively with customers.
- Recruitment: installers must be appropriately qualified, safe safe registered pass a DBS check.
- Training and accreditation: Installers must be suitably trained and able to treat vulnerable customers in the correct manner. This includes taking "all reasonable endeavors" to identify vulnerable customers with specific needs "such as visually impaired, hearing impaired, and those with low levels of literacy". Where vulnerable people have not been previously recorded, this should be recorded appropriately; "where appropriate the appointment should be arranged with the carer or person with legal responsibility over the customer, and they should be present during the Installation Visit."
- Relevant legislation and regulation: gas/electricity acts relevnat for safe working practices and quality control, in addition to data protection and consumer protection.
- Relevant codes of practice: Meter Operation Code of Practice (MOCOPA), Meter Asset Manager's Code of Practice (MAMCoP), Ofgem Approved Meter Installers (OAMI) and Safety Net for Vulnerable Customers (which installers become members to)
- Testing the system: installers must test the full system including WAN, HAN and IHD once installed.
- In Home Display (IHD)/newly named: must be offered and located suitably for the occupant - especially if they have mobility problems
- Demonstrating the system to the customer: this section is fairly extensive and sets out clear guidance on ensuring customers understand how to use the system safely and are aware of all the relevant infromation. This includes demonstrations suitable for those with specific needs such as visual impairment, hearing impairments, low levels of literacy and any other known vulnerability.
- Incomplete installations: customers must be aware why the installation is incomplete and all equipment must be left safe with process in place fro re-booking.
- Provision of energy efficiency guidance: Energy efficiency advice must be offered to domestic customers during the installation visits and provided in a format that is suitable for the needs of the customer (incl. visually r hearing impaired, and those with a low level of literacy or otherwise known to be vulnerable.
- Marketing: Customers must consent prior to the installation visit for chargeable products and services. Marketing ends following customer request and is conducted in a fair, honest and transparent manner without pressuring customers or exploiting Customer's inexperience, vulnerability or loyalties.
- Sales: Transactions not to be conducted during domestic visits but okay for micro-business customers, if conducted in a fair and appropriate manner.
- Incomplete installations: For an installation that cannot be completed in one visit the customer must be aware of the reasons why, the site is left safe and processes are in place to re-arrange the visit.
(to be added)
Smart Metering Equipment Specifications (SMETS1 and SMETS2)
The current smart meters are designed to the Smart Metering Equipment Technical Specification 1 (SMETS1). This will be replaced by SMETS2, once finalised.
There are some concerns from energy suppliers, relating to the standard of initial smart meters already installed, such as an example provided by Andrew Ward of Scottish Power:
"Of the initial 30,000 meters that we deployed in 2010, we have had to replace 5,000 of the SIM cards that are in those meters. The understanding we had when we installed the meters was that the SIM cards would be sufficient to last the life of the meter, so that has gone wrong. We have had to interrupt the lives of 5,000 customers and reinstall those meters.”
Concerns were highlighted by the Energy and Climate Change Committee in 2013 on the technical specification development of SMETS2:
"...the fact that the technical specifications that will ultimately need to be met by smart meters—SMETS 2—have not yet been finalised....the need for the Data Communications Company (DCC) and communications system to be up and running for SMETS 2 meters to be fully operational and the need for proper end-to-end system testing before mass roll-out.”
Other concerns relate to inter-operability between SMETS1 and SMETS2 meters. Skanska, a company which installs and maintains meters stated:
“The fact that there is no truly interoperable system or standard “churn” contracts make it very difficult to obtain long term finance. This could result in a newly installed SMETS 2 meter being removed and reinstalled when a customer chooses to move to a new supplier, because there is no mechanism for the rental agreement to be transferred between suppliers".
In addition, SMETS2 have been designed to work with the DCC infrastructure, which may lead to British Gas needing to replace 800,000 meters if they do
Work is being carried out by the Smart Meter Central Delivery Body (SMDB) on finding effective ways to engage with all audiences. However, Jenny Saunders of NEA stated that she was unsure enough was been done and that the scope of 'vulnerable customers' should be extended to include those who have language barriers and caring responsibilities. British Gas have expressed concern in getting customers engaged or interested in the first place. In addition, they find that the lengthy boooking process resulting from regulatory requirements often deters customers. They feel that a broad, consistent message could help with this - one question they are often asked is 'What is a smart meter?'. Smart Energy GB may assist in this area - or may adopt 'advertising campaigns' as oppose to customer engagement ideas.
Licensing of different roles in energy system (supply, distribution, meter operation, access to DCC etc)
The transition stage started in September 2013 with the DCC receiving a licence and the contracts awarded to the Data Service Provider (DSP) and the Communications Service Providers (CSP). This coincided with the start was also the launch of the Smart Energy Code (SEC). The Smart Metering Governance Structure is outlined in the diagram below.
- Smart Metering Steering Group (SMSG): Strategic level of progress. Members include: six main energy suppliers; two smaller energy suppliers; ENA; Energy UK; Consumer Futures; Ofgem; DCC Licensee; SEC Panel; CDB; Critical Friend; DECC SRO and DECC Minister.
- Smart Metering Delivery Group (SMDG): Senior level forum DECC can work with to monitor and deliver the programme. Members: Six large energy suppliers; two smaller energy suppliers; Energy UK; CDB; ENA; DCC Licensee; Ofgem; SEC Panel; metering equipment manufacturers (trade association level). In addition Consumer Futures and the DECC SRO will have a standing invitation to attend.
- Technical and Business Design Group (TBDG): A working forum for resolving technical issues, consisting of: Six large energy suppliers; two smaller energy suppliers; electricity and gas network operators; Energy UK; DCC Licensee; Ofgem; SECAS; energy services providers; metering equipment manufacturers; MAP’s and meter operators (trade association level).
- Implementation Managers Forum (IMF): A working group DECC can work with to monitor and review individual contributor projects. Members: Six large energy suppliers; two smaller energy suppliers; Energy UK; CDB; electricity and gas network operators; DCC Licensee; Ofgem; SECAS; metering equipment manufacturers (trade association level).
How businesses can become DCC users
- Sign up to the Smart Energy Code (SEC) - multiparty agreement defining the rights and obligations of energy suppliers, network operators and other relevant parties involved in the 'end-to end' management of smart metering in the UK.
- To ensure data communications between DCC users and the DCC are secure, DCC users will pay the DCC a one-off charge to install a DCC Gateway Connection and an ongoing annual rental fee for a dedicated connection, so they are essentially leasing a line to DCC systems. The charges will depend on a few variables and can be gained through contacting the DCC.
- DCC users will need to prepare, or buy, IT systems capable of communicating with DCC
- DCC users will need to go through the Smart Metering Key Infrastructure's (SMKI) Registration Authority Policy and Procedures (RAPP). This sets out the steps organisations need to go to gain access to SMKI services.
- DCC users will also go through the DCC Key Infrastructure (DCCKI) RAPP to gain access to the DCC User Gateway and Registration Data Interface.
- Perform SMKI and Repository Entry Process Tests.
- Complete User Entry Process Testing (UEPT).
Further details available here:http://www.smartdcc.co.uk/dcc-users/becoming-a-dcc-user/
Opportunities to mandate ‘smartness’ in new developments and refurbishment
This could be challenging at present due to the uncertainty of whether customers with an early meter installed becoming tied to the supplier who installed the meter, or switching and having a new non-smart meter installed thus creating a 'dummy smart meter'.
‘Space to experiment’ opportunities to operate outside full regulatory regime (Ofgem, DECC etc) – and what could be done
Non-traditional business models
Ofgem recently launched a public consultation on 'non-traditional business models' (NTBMs). They aim to start a public conversation on benefits and risks to consumers of non-traditional business models and how they interact with the regulatory system. Ofgem are keen to ensure regulation does not step in the way of delivering desirable customer outcomes, protects the interests of consumers and allow them to understand the benefits, costs and risks in changing regulation. They may face challenges at present due to their size or the structure of the energy market.
Main aims of NTBMs:
- Help enable the transition to a low carbon supply system
- Allow rapid technological innovation
- Some are disappointed with the consumer engagement and trust they hold in more traditional businesses within the energy sector
- New organisations may have a greater focus on affordability and supporting vulnerable customers
The Competition and Markets Authority recently published an energy market investigation...(details to come :)
Privacy (for both individuals and commercial interests) vs public good. Can data be anonymised while still retaining sufficient detail?
Data provided by Smart Meters will be the property of the consumer who must provide the DCC permission to access their data. Once the DCC have the data they are not permitted to maintain a centralised database of the data. If a company becomes a DCC User, they are permitted to request permission from households to obtain their smart meter data.
...is likely to be:
- Electricity consumption (kWh) and gas consumption(m3) at half-hourly intervals for the previous thirteen months.
- Electricity at half-hourly or hourly intervals over three months (on reactive energy imported and exported: kvarh).
- Daily electricity consumption, or gas for the previous two years.
- Current tariff information (including price, time-of-use matrix and switching times, time-of-use blocks and block thresholds)
- Conversion factors and calorific values of gas.
The DCC will also manage an inventory of meter identification numbers and meter point identifiers (MPxN) associated with premises name/number/postcode.
The beginning of the Internet of Things??
Smart Meters will also have the ability to communicate with Home Area Network (HAN) over a wireless connection within the home in the form of a ZigBee wireless network. This will allow: live energy feedback for householders and the ability to connect with Consumer Access Devices (CADS). CADS are currently able to connect to WiFi and stream data, in future they may develop to communicate with appliances in the home, once they have been paired. Smart Meters must enable live energy feedback to householders and four CAD ports. The CAD can currently access electricity data at ten second intervals and gas meter data at thirty minute interval.
BEAMA Home Area Network
BEAMA have been developing ideas which would enable the Home Energy Network to connect to the following, in addition to energy use:
- Temperature sensors
- Humidity sensors
- Switching controls
- Intelligent controls
- Audible alarms
- External communications
- In-home communications
- Occupancy sensors
- Access control
- Perimeter sensors
- Vital signs monitoring
They are at the stage of informing policy makers for development of regulatory frameworks surrounding these areas.
- DECC, 2013. Smart meters: information for industry and other stakeholders. Available from: https://www.gov.uk/smart-meters-information-for-industry-and-other-stakeholders#regulatory-framework-for-smart-metering.
- Baroness Verma (DECC), March 2015. Smart Metering: Written statement HLWS320. Available from: http://www.parliament.uk/business/publications/written-questions-answers-statements/written-statement/Lords/2015-03-05/HLWS320/
- Energy Act 2008, section 88. Available from: http://www.legislation.gov.uk/ukpga/2008/32/part/5/crossheading/smart-meters.
- HM Government, 2010. The Coalitation: our programme for government, 2010. Available from: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/78977/coalition_programme_for_government.pdf.
- EU Parliament and Council, 2012. Directive 2012/33/EU, Official Journal of the European Journal, available from: http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2012:327:0001:0013:EN:PDF
- EU Parliament and Council, 2012. Directive 2012/27/EU. Official Journal of the European Journal. Available from: http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2012:315:0001:0056:en:PDF. Accessed 15/07/15.
- EU Parliament and Council, 2009. Directive 2009/73/EC. Official Journal of the European Journal, available from: http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:211:0094:0136:en:PDF.
- EU Parliament and Council, 2009. Directive 2009/72/EC. Official Journal of the European Journal, available from: http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:211:0055:0093:EN:PDF.
- EU Parliament and Council, 2012. Directive 2012/27/EU, Official Journal of the European Journal, available from: http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2012:315:0001:0056:en:PDF.
- Smart Metering Working Group, 2014. Smart Metering: conditions for a successful roll-out. Available from: http://www.lowribeck.eu/media/3507/smart-meter-working-group-report_final_july-14.pdf
- DECC, 2014. Transition Governance overview: Smart Metering Implementation Programme. Available from: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/363674/transition_governance_overview.pdf
- Energy and Climate Change Committee, 2013. Smart Meter Rollout: Fourth report of session 2013-14, para. 40, pp. 20. Available from: http://www.publications.parliament.uk/pa/cm201314/cmselect/cmenergy/161/161.pdf
- Roberts, S. and Redgrove, Z. 2011. The smart metering programme: A consumer review. A report for Which? by CSE
- Smart Metering Installation Code of Practice (SMICoP) 2015. Available from: http://www.energy-uk.org.uk/publication.html?task=file.download&id=5040
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- Ofgem, 2015. Non-traditional business models: Supporting transformative change in the energy market. Available from: https://www.ofgem.gov.uk/ofgem-publications/93586/non-traditionalbusinessmodelsdiscussionpaper-pdf
- DECC, 2015. Smart Meters, Smart data, Smart growth. Available from: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/397291/2903086_DECC_cad_leaflet.pdf
- BEAMA, n.d,, Consumer Access Devices. Avaialble from: file:///C:/Users/kates/Downloads/Consumer%20Access%20Devices%20A%20BEAMA%20Guide%20(2).pdf