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Smart Metering Implementation Programme Department of Energy & Climate Change, 3 Whitehall Place, London, SW1A 2AW Tel: 0300 068 6996 Email: [email protected] Consultation reference: URN 12D/024
6th Floor Dean Bradley House 52 Horseferry Road London SW1P 2AF
T +44 (0)20 7706 5100 F +44 (0)20 7706 5101
[email protected] www.energynetworks.org
Registered Office as above 1 June 2012 Dear Sir/Madam, Energy Networks Association Response to the DECC Smart Metering Implementation Programme Consultations – Data Access and Privacy Thank you for the opportunity to respond to your consultation on the proposals for Data Access and Privacy.
As you are aware Energy Networks Association (ENA) is the industry body representing the
UK’s electricity and gas transmission and distribution networks operators. The following
comments are provided by ENA on behalf of its member companies in response to the DECC
consultation on Smart Metering Implementation Programme published on 5 April 2012.
A number of ENA member companies have responded individually to the consultation. The
comments in the appendix accompanying this letter are submitted in support of the individual
submissions provided by our member companies.
If you require further information or you wish to discuss any of the content of this reply please
contact Paul Smith on: 0207 706 5156 or email: [email protected]
Yours faithfully
David Smith
Chief Executive
Energy Networks Association 6th Floor, Dean Bradley House 52 Horseferry Road London SW1P 2AF PA: Mavis Neagle
Tel: + 44 (0) 20 7706 5106
Fax:+ 44 (0) 20 7706 5101
Email: [email protected]
APPENDIX Energy Networks Association Response to: DECC Smart Meter Implementation Programme Consultation: Data Access and Privacy (Reference URN 12D/024)
1. Do you have any comments on the arrangements for consumer access to data through the in-home display, Home Area Network or supplier? Do you foresee any problems with any of these mechanisms? If so, how could any problems be overcome?
We believe that the proposed approach is appropriate as it is important that consumers are able
to obtain both direct and indirect feedback. A concern regarding access to smart meter data via
the HAN by means of a ‘secure’ connection of a consumer device is that it might be possible for
such a connection to be used inappropriately to ‘hack’ the smart metering system. It will be
important therefore that the means of ‘secure’ connection meets the reasonable expectations of
the SMIP Security Technical Expert Group.
2. Is there a need for any additional arrangements to enable consumers easily to access their own energy consumption data directly from their supplier, free of charge and in a common format?
It is important that consumers are able to extract detailed information in a format that enables
straightforward interpretation and can therefore obtain competitive quotations from alternative
suppliers. This should include half-hourly consumption data on request (for example, in order to
enable a consumer to obtain comparative quotations for time-of-use tariffs or to enable a third
party to assess the consumer’s suitability to provide, and be remunerated for, demand side
response services).
3. Do you have any comments on the overall balance and workability of the proposals for supplier access to data?
The proposals strike a reasonable balance between preserving data privacy for consumers whilst
providing suppliers/third parties with the necessary visibility of data to enable products to be
designed which might benefit certain consumers while also benefitting the overall efficiency of
the relevant energy chain (in particular electricity generation, transmissions and distribution).
4. Do you agree with the proposed approach to defining supplier regulated duties, and that suppliers should be able to access monthly (or less granular) energy consumption data for these purposes without customer consent? Would the proposed approach restrict suppliers from undertaking any essential activity, or present any other problems?
We believe that allowing suppliers access to monthly (or less granular data) without consumer
consent is reasonable. However, such non-granular data will be of little benefit to suppliers in
terms of being able to design potentially more innovative products including, for example, time-
of-use based products.
5. Do you agree with the proposal to enable suppliers to access daily (or less granular) energy consumption data, and use this for any purpose except marketing, provided that the customer is made aware of this and given the opportunity to opt out? What would be the implications for consumers and competition of this approach?
Our members generally agree with the proposal to enable Suppliers to access daily (or less
granular) energy consumption data, and use this for any purpose except marketing. Competition
and innovation are paramount to the Smart Energy regime and Suppliers will be using data to
innovate and to demonstrate to Customers the benefits available to them through running a
Smart Meter.
If Suppliers used daily energy consumption data to develop products and services, they would
not be able to market those products and services to their Customers unless those Customers
had agreed in any event and therefore new start up companies will not be unfairly prejudiced
from entering the marketplace.
It is not anticipated that this level of data would cause any breach of privacy, but would allow for
significant benefits in the improvements of services for Customers. The opt-out provision is a
reasonable safeguard for consumers who may have a concern that through visibility of day-to-
day variations in their consumption data (for example weekdays and weekends or weather-
related variations) suppliers might have too great an insight into lifestyle profiles.
6. Do you agree with the proposal to require suppliers to obtain explicit (opt-in) consent from the customer in order to access half-hourly energy consumption data?
An opt-in requirement in respect of half-hourly consumption data should allay any legitimate
concerns that consumers might unwittingly provide consent by failing to opt-out. Should a
consumer wish to take advantage of a product offering such as a time-of use tariff or a product
based on responsive demand, then the consumer would presumably understand the need (or
need to be educated of the need) to opt-in to providing access to more granular data in order for
the supplier or other third party to firstly assess the benefits for the consumer of such a product
and, subsequently, to enable the consumer to be charged (or rewarded) according to
consumption (or response) over designated time periods.
7. Do you agree with the proposal to require suppliers to obtain explicit (opt-in) consent from the customer in order to use energy consumption data for marketing purposes? Do you agree with the proposed definition of marketing, and in particular, that free advice should be excluded from the proposed definition?
An opt-in requirement in respect of marketing material is a desirable safeguard against
consumers unintentionally failing to opt-out. While marketing material (as opposed to sales
initiatives or customer propositions) should not expose consumers to risk, excessive exposure
might lead to bad publicity for the smart metering programme. On the other hand, it is possible
that by failing to opt-in consumers will exclude themselves from potentially valuable information
as to how they might reduce their energy bills.
Realisation of the IA benefits might depend on consumers being made aware of potential energy
and/or energy price saving opportunities. We would therefore advocate consideration being
given in future to relaxing the opt-in requirement (in respect of pure marketing material) in
favour of an opt-out approach. An appropriate time for such a review might (depending on
experience gained) be at either the completion of the Foundation Stage, a mid-point during mass
rollout, or on completion of the initial smart meter rollout in 2019.
8. Do you agree with the Government’s proposed exceptions to the basic framework for supplier access to data – to accommodate theft detection and prevention, accurate billing, customer queries and trials? Are there any other important uses of energy consumption data that need to be covered in exceptions to the basic framework?
The cited exceptions to the basic framework are reasonable though it might be necessary to
define what would constitute ‘reasonable suspicion that theft is being committed’ and, in the
event that the reasonable suspicion proved unwarranted, the process by which the data would
be securely destroyed and the consumer advised of the daily consumption data that had been
accessed. Regarding trials, some of our members disagree with the provision that all trials
should be approved by DECC or OFGEM. This will result in a time consuming and bureaucratic
process and will stifle innovation. Potential participants to a trial will be given sufficient advice
and information about the purpose of the trial and the use of the data and if a Customer is
uncomfortable with the trial, they will simply not participate.
9. Do you agree with the proposal to require suppliers to explain clearly to customers what energy consumption data will be accessed, for which purposes, and the choices that customers have about this, and to provide annual reminders to their customers about this?
The requirement to remind consumers on an annual basis as to the energy consumption data
that is being accessed (and the purpose thereof) is reasonable in principle. There might be
questions as to how such annual reminders would be managed in respect of consumers who
change supplier (a pragmatic approach might be for the incoming supplier to issue such a
reminder at the time of transfer or on issuing the first energy bill).
10. Do you agree with the proposed approach to the way in which suppliers should facilitate opt-out and opt-in choice mechanisms?
The proposal not to require explicit opt-in to be registered in writing is welcome. Such a
requirement would surely be regarded as a burden by many consumers and potentially limit the
number of consumers who would otherwise willingly opt-in. In that regard, a requirement that
the consumer would first receive information ‘in writing’ (which we presume is intended to
mean a written communication addressed to the consumer) might seem overly prescriptive. For
example, if clear information is provided via an internet webpage which explicitly invites the
consumer to read the information before (say) ticking a tick-box, then that would seem to satisfy
the underlying principle of opt-in while making the exercise convenient for consumers.
11. Do you agree with the proposed use of licence conditions to implement requirements relating to supplier access to data? Would any of the detailed arrangements, or any additional measures, be more effectively set out elsewhere, for example in an industry code, a standalone code of practice or guidance?
While we believe that the proposed approach is workable, the consultation rightly notes the
potential for a licence condition approach to offer less flexibility to accommodate potential
improvements than (say) an industry code approach (backed up by the licence-backed SEC).
12. Do you agree that the licence conditions as drafted would effectively implement the proposed policy approach to supplier access to data? Do any specific areas of the draft licence conditions need amendment or clarification?
Notwithstanding our answer to Q11, the licence conditions as drafted appear to be appropriate
to ensure effective implementation of the policy approach to supplier access to data.
13. Is there a need for any consequential changes to existing licence conditions or codes to ensure that the proposed requirements on suppliers work as intended?
We do not perceive any need for consequential changes to licence conditions or codes.
14. Do you have any comments on the proposed approach to timing of implementation of proposals relating to supplier access to data?
We agree that the changes should be implemented as soon as is reasonably practicable and that
the proposed licence changes should be introduced in late 2012 by which time we would
anticipate SMETS1 (or possibly SMETS2) compliant meters becoming available and hence at a
time when suppliers might be seeking to ramp-up numbers of smart meters installed during the
Foundation-Stage.
15. Do you agree with the proposal to allow network operators to access half-hourly energy consumption data, without customer consent, for the purposes of developing and maintaining efficient, co-ordinated and economical systems for the distribution of electricity and gas, if they have had plans for aggregation approved? To what extent would this approach address potential consumer concerns about privacy in relation to network operator access to data? Network operators have made a very strong case for access to half-hourly consumption data in order to perform their statutory and regulatory duties in respect of developing and maintaining efficient, co-ordinated and economical systems for the distribution of electricity. In gas, half hourly data would be of limited value relative to 6 minute information. For gas networks we require the approval to be for 6 minute data. Gas networks model demand on the basis of 6 minute intervals and half hourly data is not sufficient for this purpose. The design for gas meters is for them to be able to record, when requested, four hours of 6 minute readings. We expand on this further in the text below. In respect of electricity, it is the envisaged future changes in daily consumption patterns (and hence daily demand shape) as a consequence of government’s proposals for decarbonisation of electricity production, and electrification of heat and transport, in support of The Carbon Plan that make free access to such data necessary. In the case of electricity, such half-hourly data would be used purely to derive load profiles for distribution networks (particularly low voltage distribution networks which have minimal levels of monitoring) in order to determine whether such networks were continuing to operate within (or approaching) design limits. The general approach would be to aggregate individual half-hourly readings at the network level; that is to say existing MPAN-to-network connectivity models would be used to determine which individual half-hourly consumption data sets should be aggregated in order to derive half-hourly network demand profiles. Aggregation would ensure not only anonymity of individual consumer half-hourly profiles but also eliminate the possibility of tracing of individual MPAN half-hourly profiles. While aggregated data will be appropriate in many situations, we are concerned proposed
arrangements focus too heavily on this and the potential value in some situations may be
diminished if aggregation is always required. We envisage there will be situations where in order
to deliver full network benefits and smarter networks data will be required at individual premise
or site level. We believe the focus should instead be on:
(i) intended use to ensure use is legitimate and within a network’s permitted activities;
(ii) to ensure it will deliver real or potential network benefit; and (iii) data protection and privacy arrangements to ensure customer data and identity is
protected.
We believe further work is required to examine how half-hourly energy consumption data can be
effectively aggregated to provide meaningful information and we will be looking to commission
an assessment in due course to examine how this could be achieved.
Half hourly consumption data would be combined with other non-privacy sensitive data such as
half-hourly reactive energy and circuit voltage profiles (i.e. the voltage profile along a given LV
circuit) in order to provide network operators with the network management information
required to efficiently and economically manage such networks. This is particularly important as
network loadings begin to increase due to electric vehicles and electric heating (in particular heat
pumps) begin to displace conventional forms of transport and space and water heating, and as
network voltage variations begin to increase due to the combined impacts of additional network
loading and micro-generation.
However, the focus should not be on half hourly data only. In gas, half hourly data would be of
limited value relative to 6 minute information. For instance, daily data would allow us to
monitor demand more closely and manage flows and pressures accordingly. 6 minute data
would help us build up a more accurate picture of localised gas use, consumer behaviour
patterns, peak demand and diversity of load and plan and manage the network more efficiently.
However, 6 minute data may only be required for specific locations at specific times, rather than
the entire population at all times. As such arrangements should also allow the network to
sample data based on location e.g. postcode as required. It is therefore very surprising that
while the technical specification for SMETS1 includes 6 minute data, there is no mention of this
in the consultation document on data access. Our gas members believe it should be clearly
included in the scope.
In respect of electric vehicle charging and heat pump installations in domestic premises, there
would be benefits in a procedure which enabled electricity network operators to be notified of
such installations (a broadly equivalent procedure already exists in respect of micro-generation
installations). While this might be regarded as ‘private’ data the requirement would not
necessarily extend to monitoring individual consumption data; it would generally be sufficient
for network operators to know that such installations were planned (or had been completed) so
that they could pay more attention to monitoring aggregated demand and voltage profiles on
the circuits affected in order to ensure continued operation within design limits.
It follows from the above that any missing data sets (of which there might be many if consumers
were permitted to opt-out) would compromise the effectiveness of this approach. The result
would be that network operators would have to invest in network monitoring systems which
would result in additional costs ultimately borne by consumers. Even with all this effort we may
still not be able to obtain the level of granularity of data that would deliver useful information to
network operators in the form of aggregation of consumption, real/reactive energy data and
smart meter-derived voltage measurements.
16. If network operators’ plans for aggregation have not yet been submitted or approved, do you agree that the proposed framework for supplier access to data should also apply to network operators? Would any alternative approach be more effective?
Arrangements need to recognise the activities, obligations, regulatory frameworks and hence
privacy concerns for networks are very different to those for suppliers, as are data requirements.
Data requirements between electricity and gas can also vary e.g. half hourly data is of limited
additional value to a gas network operator but is of significant value to an electricity network
operator. Data access arrangements should be geared towards the user’s role, its needs, the
regulatory framework, the protection this provides and specific risks or concerns. As such we
believe it is appropriate for parties to have different access arrangements.
While the proposed mechanism provides network operators access to data until such time as
plans are submitted and approved, we are concerned they are very onerous for suppliers and
networks and likely to be impractical. Networks will be completely reliant on suppliers for
procuring access rights and data in a timely and accurate manner. Arrangements also raise
additional issues associated with data privacy and protection where the supplier has access to
data that would not otherwise be available to it or other suppliers. This adds another layer of
complexity in relation to the network / supplier / customer relationship and processes and
procedures to manage arrangements. As customers will have the ability to opt-in and out we are
also concerned the value of information collected could be diminished where an incomplete
picture of network use and dynamics is provided.
Energy Networks Association (ENA) on behalf of both electricity and gas network operators has
previously commissioned (and shared with DECC) a Privacy Impact Assessment which provides a
generic approach to ensuring security and privacy of sensitive consumer data. This will be used
to develop more detailed plans for aggregation and secure disposal of half-hourly consumption
data, including options for such aggregation to be undertaken by parties undertaking DCC
related services (such as the data gateway provider) rather than network operators. It is the
intention of ENA and its members to present such plans for approval but we are keen that the
focus should be on data access arrangements being geared towards the user’s role, its needs, the
regulatory framework, the protection this provides and specific risks or concerns.
17. Do you agree with the proposed approach to implementation of requirements relating to network operator access to data? What would be the practical implications of the proposed approach to implementation, and how could any problems be overcome?
Access to data via Suppliers when plans for data aggregation have not been approved will be
difficult to manage given the many different Suppliers that could potentially be required to
access data on behalf of network operators even for relatively small enquiries. It is likely that
such an approach will significantly increase the cost of data, lead to delays and may result in few
Customers agreeing to their data being used.
We also note that while it is proposed that “suppliers should be responsible for procuring the
right to access such data” it is not clear what the framework would be or what obligations or
incentives would exist to ensure suppliers do this in an efficient and timely manner. We believe
a robust yet proportionate industry framework is required. This is something that could be
addressed through CERG OI via Service Level Agreements and Codes of Practice.
It is important to also recognise that as we move towards smarter networks, network operators
may wish to, or need to, develop direct relationships with consumers in order to meet future
network challenges, particularly in electricity where Demand Side Response is seen as a key tool
in the framework for delivery smarter grids. This is something that has been recognised at
European level e.g. in the recent ENTSOe consultation on the Demand Connection Code where it
is envisaged demand could provide essential network services and supports as the volume of
renewable generation increases. It is also being discussed with DECC and Ofgem under the
Smart Grid Forum and associated working groups. Arrangements should not preclude such
relationships and services developing where they are the most efficient and effective solution.
18. Do you agree that the licence conditions as drafted (including the proposed amendment to supply licence condition 22) would effectively implement the proposed policy approach to network operator access to data? Do any specific areas of the draft licence conditions need amendment or clarification?
From a networks perspective, some of our members are concerned as to why the Licence
Conditions apply to domestic supply only. In their view this leaves a significant gap from a
network perspective as we will not have a complete picture e.g. for non-domestic customers or
any other premises that are not connected to the DCC. This could significantly undermine
network benefits.
Paragraph 1
There may be a need to define a Domestic Premise and Smart Metering System. We would
expect the same conditions to apply to meters installed in the Non-Domestic sector where the
data was available via the DCC.
The term ‘quantity of electricity’ could be interpreted to include real and reactive electricity
consumed. It would be helpful to clarify that the data set being considered is limited to real
power imported into a premises.
Paragraph 4
This should refer to relevant defined terms in the gas and electricity transportation licences e.g.
“transportation business”, “Distribution Business” and “permitted purpose” as currently used.
Paragraph 7
A network operator’s obligations and responsibilities in relation to theft are in transportation or
conveyance i.e. upstream of the Emergency Control Valve (ECV) in gas and cut-off in electricity.
As such this paragraph should be in relation to a suspected occurrence of theft or abstraction
upstream of these points, not at the relevant premises as currently specified.
Paragraph 9
9 (a) (i) should apply in respect of one or more periods of less than one day.
9(b) clarification is required in terms of what is intended by “explicit consent”.
Paragraph 10
In order to deliver full network benefits and maximise use of metering system functionality as
currently specified in SMETS1, this should provide for data for a period of less than one month
i.e. daily, half hourly or 6 minute to be provided automatically where plans have been submitted
and approved.
It was not our understanding that this mechanism would provide automatic access on a trial
basis only. To deliver network benefits, particularly associated with economic and efficient
development and operation of the network and the development of smarter networks we
envisage plans would be submitted for data access on a long term or enduring basis, not just a
trial basis.
Further clarification should also be provided in terms of the approval process and enduring
governance arrangements.
We do not agree as suggested under paragraph 10 (c) that after having plans approved the
licensee should be required to give the customer advance notice or that the customer should be
able to opt out of providing data. If a robust case for access and use has been presented to the
Secretary of State or Authority and approved the obligation to then advise the customer and
allow the customer to object undermines the process and potential network benefits. This is
also inconsistent with the description set out in the consultation document.
Paragraph 11
From a network operator perspective, it is important to distinguish between the functions of a
network operator, the market in which they operate and the regulatory framework, relative to
that of a supplier. As such the focus of this paragraph should be on data security and protection
e.g. ensuring data is used for a permitted purpose. It is also important to recognise that in some
cases, to deliver network benefits data will be required on a location or site specific basis. While
this could allow the identity of the customer to be determined it should not create data security
or abuse issues. Providing data is adequately controlled and access protected, it should not be a
concern. This also needs to be considered in relation to wider network licence obligations
relating to business separation, ring fencing, protection of information and obligations to ensure
the licensee manages and operates its business so as not to restrict, prevent or distort
competition or provide any party with an unfair commercial advantage or preferential or
discriminatory arrangements. Timescales for the Secretary of State or the Authority to provide
consent (or rejection) should be specified.
We think that the definition of Gas Consumption Data could usefully be expanded, it currently
reads: “in respect of a relevant premises, the quantity of gas measured by the Gas Meter as
having been supplied to the relevant premises”. We suggest that this could usefully include a
reference to consumption for periods of less than one month and consumption for periods of
less than one day. The definition of Gas Consumption Data could then read: “in respect of a
relevant premises, the quantity of gas measured by the Gas Meter as having been supplied to
the relevant premises including data relating to periods of less than one month and less then one
day”.
19. Is there a need for any consequential changes to existing licence conditions or codes to ensure that the proposed requirements on network operators work as intended?
We are not aware of any further changes required to the licence as a direct result of these
proposals but we believe significant change will be required to industry codes and related
documents to recognise and make full use of new metering systems and data. It is possible that
some further changes may be required to licences as a result of this work.
The reference to the provision to Metering Data in the electricity codes is the data required to
allow the Electricity Distributor to calculate and bill for Distribution Use of System (DUoS)
charges. We do not believe that these references need to change but it is essential that any
proposed changes in this area do not restrict Electricity Distributors calculating DUoS charges.
20. Do you agree that technical data (such as electricity quality and voltage readings) which does not show energy consumption data should be outside the scope of the Government’s data access and privacy framework?
The ENA Privacy Impact Assessment referred to under Q16 above sets out the rationale for
determining the sensitivity of technical data (such as electricity quality and voltage readings).
Such data provides no indication of individual consumer energy consumption patterns and
should not therefore give rise to legitimate concerns over data privacy (indeed quality and
voltage related measurements are essentially network technical data) and therefore should be
outside the scope of the government’s data access and privacy framework.
As set out above, we have concerns that where parties are not required to use the DCC this will
leave a significant gap in data available to the transporter and potentially reduce network
benefits.
21. Do you agree with the proposal to require third parties to take steps to verify that the request for third party services has come from the individual living in the premises in question?
We agree that it will be important to ensure that third parties take reasonable steps to verify
that requests for services emanate from the individual(s) living in the premises in question.
22. Do you agree that the Customer Identification Number (CIN) process would enable third parties
adequately to demonstrate verification of the individual consumer? Which of the two CIN models described is preferable? Would any alternative approach be more effective?
The CIN process would adequately confirm access to the property, but not necessarily the bill
payer. It is possible to conceive of a fraud mechanism whereby someone other than the bill
payer has access to the meter and is able to set up data access.
Furthermore, the process where the CIN is sent only to the property, and not to the third party,
is preferred because it provides a stronger control.
23. Do you agree with the proposal to require third parties wishing to access data via the DCC to self-certify that where it is required, customer consent has been properly obtained?
Where a third party has followed a strong CIN process, the approach suggested for self-
certification would seem adequate.
Any CIN process or equivalent measure would need to be adequately strong because the ability
to detect unauthorised access is very limited.
24. Do you agree with the proposal to require third parties to provide annual reminders to customers from whom they are collecting data on an ongoing basis?
The proposal is consistent with that proposed for suppliers in respect of Q9 above and we
believe is therefore appropriate. However, there needs to be a clear communication with
Customers so that they understand that their data may well be available to third parties for up to
12 months before they are informed.
25. Do you agree with the proposed use of the Smart Energy Code to set out requirements relating to third party access to data?
We agree that the Smart Energy Code is the appropriate mechanism for non-licensed entities
(who would necessarily be signatories to the SEC) to obtain access to data via the DCC.
26. Do you have any comments on the proposed option of the SEC Panel arranging an independent audit function to check third party compliance with data access requirements? Would any alternative approach be more effective?
The SEC panel should arrange the audits and should not be required to provide notice to the
third party in question of the audit.
Customers should also have a direct ability to notify the panel of any complaints they have in
regard to non-consensual access to third party data.
Furthermore there should be a process to actively identify unauthorised third party access to
data, given the risk of up to 12 months of Customer data being accessed before the Customer
detects it.
27. Is there a need for any specific arrangements to enable non-domestic customers to allow third parties to access their data? Should such arrangements apply only to opted-in smart meters or more widely?
For non-domestic smart meters that are opted-in to the DCC we would advocate a similar
approach to that proposed for the domestic sector (subject to our relevant comments above).
For opted-out smart (or advanced) meters the general presumption would be that these
consumers would be larger than profile 3 or 4 consumers and/or part of a larger group. As such,
it might be unnecessary to provide an equivalent degree of protection to that for domestic
consumers or micro-businesses in respect of audits of third parties. However, we believe it is
reasonable for a consumer to require a supplier opting-out of DCC to make available information
to third parties when requested to do so.
28. What would be the advantages and disadvantages of applying the data access framework proposed for domestic customers equally to the non-domestic sector? Should this apply only to opted-in smart meters or more widely?
We believe that a more permissive framework is possible for larger non-domestic consumers but
that an equivalent framework to that applied to domestic consumers should apply to micro-
businesses (currently profile 3 or 4 consumers).
It should be understood that the non-domestic sector will have very different consumption
behaviour, and so the need to model some activity differently will need to be considered.
Furthermore, the non-domestic sector may be a good opportunity for testing, trialling and
development.
29. Is there a need for any additional obligations to ensure that network operators can gain access to non-domestic customers’ energy consumption data and other data, even where meters are opted out of the DCC, or in the case of advanced meters? What would be the practical challenges in facilitating such access?
Meters serving the non-domestic sector have the potential to provide important data to enable
network operators (in particular electricity network operators) to perform their statutory and
regulatory duties in respect of developing and maintaining efficient, co-ordinated and
economical systems for the distribution of electricity (and gas). This is particularly important
given that such consumers will tend to have higher levels of (especially) weekday / daytime
consumption which might significantly impact load shape and contribute to the maximum
demand experienced by a given network. However, it is difficult to see how this can be managed
economically given the many different Suppliers that may be involved in providing such data.
Any obligations regarding provision of data to network operators where meters are opted out of
the DCC should consider the cost for the provision of data. If the arrangements are complex, the
cost of data excessive and access to data timescales are long it is likely that network operators
will be deterred from using such data.
As with domestic data, half-hourly consumption data would be aggregated in order to provide
the required network demand profiles.
For opted-out smart and advanced meters (the latter depending on the available functionality)
there might be opportunities for such data to be provided other than via suppliers providing
basic information. For example it might be feasible for the entity providing a DCC gateway
service to also provide data relating to opted-out smart meters which, again, would obviate the
need for electricity network operators to hold, even temporarily, half-hourly consumption data.
30. Is there a need for any form of information obligation on suppliers to ensure that non-domestic consumers are aware of the potential for particular choices to limit their ability to access their own data or share this with third parties?
Some of our members believe that it is will be important for non-domestic consumers to be
aware of whether their supplier has opted-in or opted-out of DCC in respect of their metered
electricity consumption and any limitations this might place on accessibility by third parties to
their data should they wish third parties to have such access. They believe there is potential for
new products to be offered to non-domestic consumers such as more dynamic time-of-use
tariffs and demand-side response options which might result in either lower energy bills or
rewards for provision of ancillary services.
However, other members believe that the service offered to non-domestic Customers should not
be governed and Suppliers must be able to develop relationships with non-domestic Customers
as they see fit. Any concerns surrounding smaller non-domestic Customers will be covered by
the Data Protection Act, particularly regarding sole traders for example.