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CER National Smart Metering Programme High Level Design – Appendix C

Presentation of Energy Usage Information

DOCUMENT TYPE:

Decision Paper

REFERENCE:

CER/14/046C

DATE PUBLISHED:

14th

October 2014

The Commission for Energy Regulation,

The Exchange, Belgard Square North, Tallaght, Dublin 24. www.cer.ie

http://www.cer.ie/

CER – Information Page

Abstract: This paper outlines the decisions on energy information provision to consumers and

the channels through which this information will be provided.

Target Audience: This paper is for the attention of members of the public, the energy industry, customers

and all interested parties. It is of less relevance to large electricity and gas users

because such customers will not be directly affected by the National Smart Metering

Programme (NSMP).

Related Documents: NSMP documentation is available on the CER website here.

http://www.cer.ie/electricity-gas/smart-metering

Decision on Presentation of Energy Usage Information CER/14/046C 14th October 2014

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Table of Contents 1. Introduction ........................................................................................................................... 5

1.1 Purpose of this Paper .................................................................................................. 5

1.2 Background information ............................................................................................... 5 1.3 Structure of this Paper ................................................................................................. 5

2. Context .................................................................................................................................. 6

2.1 The September 2013 Presentation of Energy Usage Information consultation . 6

2.2 The December 2013 Presentation of Energy Usage Information proposed decision ..................................................................................................................................... 6

3. Overview of Information Strategy ...................................................................................... 7

3.1 Strategic Position .......................................................................................................... 7 3.2 Introduction and Drivers .............................................................................................. 7

3.3 Definitions ...................................................................................................................... 8 3.3.1 In-Home Display Definition .................................................................................. 8

3.3.2 Smart Billing Definition ......................................................................................... 8 3.3.3 Harmonised Downloadable File .......................................................................... 8

3.4 Purpose .......................................................................................................................... 8 3.5 Core Information ........................................................................................................... 9

3.5.1 Supplementary Information................................................................................ 10 3.6 Consumer Interaction ................................................................................................. 10

3.7 Information Timescales.............................................................................................. 11

4. Smart Bill ............................................................................................................................. 13 4.1 Overview ...................................................................................................................... 13

4.2 Summary of Responses ............................................................................................ 13 4.3 CER Decision .............................................................................................................. 13

4.3.1 Summary .............................................................................................................. 14 5. Harmonised Downloadable File ....................................................................................... 16

5.1 Overview ...................................................................................................................... 16


5.3.1 Summary .............................................................................................................. 17

6. Mandated IHD .................................................................................................................... 19

6.1 Overview ...................................................................................................................... 19


6.3.1 Summary .............................................................................................................. 20 7. Appendix C1 - Summary of Consultation Responses .................................................. 22

7.1 Summary of Respondents ......................................................................................... 22 7.2 Smart Bill ...................................................................................................................... 22

7.2.1 Overview ............................................................................................................... 22 7.2.2 CER Response .................................................................................................... 24

7.3 Harmonised Downloadable File ............................................................................... 25

7.3.1 Overview ............................................................................................................... 25 7.3.2 CER Response .................................................................................................... 26

7.4 Mandated IHD ............................................................................................................. 26 7.4.1 Overview ................................................................................................................... 26


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CER Response .................................................................................................... 30 3.1.1


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1. Introduction

1.1 Purpose of this Paper

The purpose of this paper is to set out the decisions on the minimum requirements for the provision of information to consumers regarding their energy usage. The minimum requirement will apply to three primary information channels: Smart Bill, Mandated In Home Display; and Harmonised Downloadable File (previously referred to as Customer Web Interface(s) in CER/13/164). The combined purpose of these different information channels is to encourage more efficient use of energy by consumers and to enable them to take control of their own consumption patterns. This paper sets out CER’s decision for information provision to the consumer through each channel.

1.2 Background information

This paper builds on a significant body of information and analysis conducted by the CER as part of the NSMP and forms a key part of the work that the CER is undertaking in Phase 2 of the programme. Given the volume of information available, a summary of the context for this paper is included in Section 2.

1.3 Structure of this Paper

Section 2: provides the context to the programme.

Section 3: provides an overview of strategy for presentation of energy information to the consumer.

Section 4: describes the information presentation requirements to be delivered by suppliers via the Smart Bill.

Section 5: describes the information presentation requirements related to the Harmonised Downloadable File to be delivered by suppliers and networks.

Section 6: describes the information presentation requirements related to the Mandated IHD.

Section 7 Appendix C1: provides a summary of responses received to the CER consultation on High Level Design – Appendix C (Presentation of Energy Usage Information) CER/13/286C.


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2. Context

2.1 The September 2013 Presentation of Energy Usage Information consultation

The consultation paper published in September 2013 – ‘CER National Smart Metering Programme The Presentation of Energy Usage Information (Smart Billing, Mandated In Home Display and Customer Web Interface)’ (CER/13/164) set out three channels for the presentation of information and the consultation paper focused on what information should be regulated to be provided on these channels, which included an In-Home Display; Smart Billing; and Customer Web Interface(s).

In total the CER received 21 responses to the consultation paper, alongside further analysis conducted by the CER and workshops with industry stakeholders; these responses were used in the process of developing our proposed decision.

2.2 The December 2013 Presentation of Energy Usage Information proposed decision

The paper published in December 2013 – ‘CER National Smart Metering Programme Smart Metering High Level Design Appendix C: Presentation of Energy Usage Information’ (CER/13/286C) set out the CER’s proposed Presentation of Energy Usage Information. The CER would like to thank everyone who to took the time to comment on this proposed decision paper. A total of 16 responses were received and we have taken these into consideration in developing our final decision.


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3. Overview of Information Strategy

3.1 Strategic Position

The CER has reached the following positions after analysis of the consultation1 for the Presentation of Energy Usage Information.

3.2 Introduction and Drivers

Information is planned to be provided to consumers through three primary information

channels2 in the Smart Meter roll-out:

Figure 1 - Information channels

These three channels need to work together so that in unison they provide the different types of information to consumers. The Mandated In Home Display (MIHD) should be focused on easy and near real-time access to information, the Smart Bill provides information explaining energy usage linked to the bill and the associated costs, while the Harmonised Downloadable File should allow consumers access to their historical information, both for their own purposes and to share with third parties (for example, to assist in finding the best tariff for them in the market). In combination the purpose of these different information channels is to encourage more efficient use of energy by consumers and to enable them to take control of their own consumption patterns.

1 CER/13/164 and CER/13/286

2 NB: Other than the presentation of data on the MIHD, this does not consider the availability of energy

data in the home over the Utility Home Area Network (UHAN) that will be accessible to other in-home devices. This aspect was addressed in the Core Design Proposed Decision Paper (CER13/286A), Appendix A3 – “Data and Devices in the Home”.


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3.3 Definitions

3.3.1 In-Home Display Definition

An In-Home Display (IHD) is defined as a device which is located in the consumer’s home; it could be mobile or fixed. It displays information related to the consumption of energy, and cost where practical and useful. Its primary purpose is to give the consumer easy access to this information in such a way as to enable them to understand their energy consumption in order to modify their behaviour3. This document refers to a Mandated In-Home Display (MIHD) as the IHD to be provided and supported by ESB Networks as part of the regulated roll-out, as referred to in the CER Decision of July 20124.

3.3.2 Smart Billing Definition

Smart Billing is defined as the presentation of accompanying information detailing energy usage with a consumer's energy bill. This information details usage associated with different times and tariffs providing easy to understand comparative data. This aims to show the impact of changes in consumer behaviour and encourage energy efficiency.

3.3.3 Harmonised Downloadable File

The Harmonised Downloadable File is defined as a web-based means of providing consumption in a standard harmonised downloadable format on request to consumers.

3.4 Purpose

Each of the three channels has a core purpose and therefore a focus for the

information it provides to the Consumer.

The Mandated In-Home Display should focus on:

- providing near ‘real-time’ information on consumption, and cost where

practical and useful;

- acting as a device to assist consumers in making a step to greater

engagement and understanding;

- simple and easy to use information; and

- Information that relates to periods shorter than the billing window.

The Smart Bill should focus on:

- providing a periodic review of consumption and cost;

- acting as a checkpoint for the consumer at consistent intervals; and

- information that links directly to their bill.

3 Results related to the impact of the IHD from the Customer Behaviour Trials can be found on the CER

website 4

CER/12/008: “In-home displays (IHDs) will be provided to all energy consumers as part of

the full rollout during their electricity smart meter installation.”


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The Harmonised Downloadable File should focus on:

- providing access to historical interval data on import and export

consumption; and

- harmonised presentation of data in a simple format.

In addition, there is the facility for presentation of simple historical analytical information by suppliers on request to consumers using appropriate means (e.g. web, smart bill, app).

3.5 Core Information

There is a core of information to be considered for provision across the three channels which needs to align to their respective purposes. This information is based on three main pillars: consumption, price (tied in with the tariff), and cost. Each of these three pillars provides valuable information to a consumer with: consumption showing the actual energy consumed; price associated with a certain tariff period showing the relative expense of that consumption; and cost showing what the consumer is actually paying for their consumption.

These three pillars can also be used in conjunction with each other so that consumers can understand:

how much they have used at different prices/tariff periods;

how their cost of energy is driven by their consumption; and

how cost is related to different prices/tariff periods.

The information presented can also represent different timescales (see Fig 2 below) as

follows:

Real-time (or near real-time) – continually updated to show the current status;

Periodic – showing a set period of time on a regular basis;

Cumulative – showing ‘to date’ information whether on a daily, weekly, monthly

or yearly basis;

Historical – showing previous periods (day, week, month), including the

equivalent period for the previous year.


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Figure 2 - Core information presented to consumers

3.5.1 Supplementary Information

In addition to this core information about a consumer’s own energy consumption, price and cost, there is also further supplementary information that may assist in achieving the objectives of facilitating behaviour change and realising energy efficiency benefits. These are as follows:

Benchmarking information – which allows consumers to see how their own

energy consumption compares with other energy users;

Hints and tips – to give consumers advice on how to change their behaviour and

realise energy efficiency benefits;

General information – to provide context and background information as well as

contact information for helpful organisations;

Balance information – to show Pay As you Go information related to the

consumer’s PAYG balance. This requirement is part of the PAYG requirements

and therefore excluded from this paper and included in the PAYG paper5.

3.6 Consumer Interaction

The core purpose associated with each information channel is intrinsically linked to an understanding of the different ways the channels are expected to be used and interacted (see Fig 3 below) with by the consumer.

5 PAYG Decision paper CER/14/046D


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The MIHD is expected to be used for quick reference by consumers to check

consumption, thus requiring minimal effort. This may be used regularly, for

example on a daily basis, and therefore should be easy and convenient.

The Smart Bill will be a periodic document requiring some effort from

Consumers to analyse. However, it is still a “push” of information to the

Consumer who is essentially still reactive in receiving the information.

The Harmonised Downloadable File is expected to be a resource that is

available to consumers on request (with response times to be investigated in the

next phase of the NSMP) and which requires proactive effort from them to

access and use. For those consumers that choose to use it, it is also likely to

require a greater investment of time to read, understand and analyse the

available information.

Figure 3 - Consumer interaction with information channels

In order to achieve objectives, it will be important to encourage consumer engagement and interaction with this information so that consumers’ progress from reactive receipt of information to becoming more proactively engaged. It will also be possible for other non-mandated information channels such as smart applications to supplement the provision of information to the consumer in different ways. This decision paper is not intended to constrain other innovative methods of presenting information to consumers over and above the minimum requirements set out in this paper.

3.7 Information Timescales

Based on the characteristics of the different information channels and their identified purposes in achieving consumer information objectives, there is a clear and discrete split of primary timescales associated with each information channel. The Mandated In-


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Home Display should focus primarily on presentation of near ‘real-time’ information and information relating to periods shorter than a billing window, the Smart Bill on the period associated with the bill, and the Harmonised Downloadable File on historic information. However, it may also be desirable to extend each channel to a secondary timescale that supplements the primary in improving consumer awareness and understanding.

Mandated In-home

Display Smart Bill

Harmonised Downloadable

File

Primary Information timescale

Real-time Latest Period (billing period)

Historical

Potential secondary information timescale

Cumulative Past periods shorter than

billing window Past Periods

Figure 4 - Interaction timescales

For the Mandated In-Home Display it is of benefit to consumers to also see a

cumulative view of their consumption for the day, week or month to date, as well

as past periods shorter than the billing window. This can help give a context for

their near real-time consumption as well as enable them to set and keep within

their own targets for consumption over different periods.

The Smart Bill is of benefit to consumers for showing past periods as well as

just the latest billing period to provide a comparison for the last billing period.

The Harmonised Downloadable File contains historical granular information

on their consumption usage, which can be shared with 3rd parties to provide

additional services. It is important that, between them, the information channels

cover all four primary timescales (Real-time, Periodic, Historical and

Cumulative) and this is the case.

The next phases of this program will consider in more detail the implications for relevant retail polices, such as: market processes, codes of practice, service level agreements etc.


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4. Smart Bill

4.1 Overview

Energy suppliers will be required to provide smart billing information alongside the consumer’s energy bill, providing a periodic assessment of energy usage that facilitates customer engagement, and can deliver behavioural change. The requirements focus on the content to be provided and do not set out a specific template for suppliers to follow, provided that the information is provided in a clear and unambiguous manner.

4.2 Summary of Responses

As outlined in section 7.2 there were 4 respondents that had comments on the smart bill proposed decisions, the key areas covered were:

2 respondents had concerns regarding the amount of information required to be presented on the smart bill, while 1 respondent believed it to be an inappropriate medium.

4 respondents aired their concerns regarding the frequency of information being sent to the customer and do not think it should be tied to their billing frequency.

1 respondent was concerned with the terminology used in the universal design principles in relation to the European Communities Regulation 2011.

The CER considers that the information to be provided through the smart bill is appropriate. The CER notes differing views expressed on frequency of billing but sees no definitive reason to change the initial policy position that this should be left to the market to determine, in line with minimum EED requirements. The bundling of the bill and energy statement is considered appropriate for affecting consumer behaviour in relation to their energy usage. In relation to the Universal Design, the CER will support the European Communities Regulation 2011 as required.

4.3 CER Decision

The CER notes the broad support for the proposed information requirements on the Smart Bill, where the Smart Bill is defined as the existing energy bill that consumers receive enhanced by accompanying information explaining the consumer’s energy use.

With regard to views on the presentation of hints and tips and whether these should be more clearly defined or that a minimum requirement should be set, these are noted but it is thought more beneficial that the market decide the most appropriate format for these as part of a competitive offer to consumers. In response to the point that this information could be shown better on a separate information channel, the CER considers that the Smart Bill is the most appropriate channel for this information in making it as easy as possible for consumers to access this information, as well as linking this advice to when a consumer is already considering their bill. However, the


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CER does agree that this can also be usefully supplemented by providing detailed information through other means such as websites.

In response to arguments around the potential to show this information on other information channels as well as, or instead of, the Smart Bill; the CER reaffirms that it feels the core purpose of the Smart Bill is to deliver this type of information, while the possibility of also presenting it elsewhere should be left to competitive market forces to decide. Similarly, in response to points made regarding the presentation format of the Smart Bill, the CER notes the need for suppliers to make provision for vulnerable customers through following universal design principles but more widely prefers for the market to be allowed to innovate competitively in terms of how information is presented as long as the needs of vulnerable customers are met.

The CER notes the widely expressed support for the position proposed on benchmarking information and is of the view that this should not currently be required. Responses that called for minimum standards for benchmarking information have been noted and the option for potentially introducing these at a later stage will be retained on the basis of review.

The CER notes differing views expressed on frequency of billing but sees no definitive reason to change the initial policy position that this should be left to the market to determine, in line with minimum EED requirements that billing information should be made available at least quarterly on request or where the Consumers have opted to receive electronic billing, or else twice yearly (also for PAYG customers). While there is evidence that more frequent billing can lead to a greater energy reduction by consumers (as shown in the Irish trials), this needs to be weighed up against the costs associated with more frequent billing, especially if this is paper-based. The CER considers that the market is best placed to do this.

4.3.1 Summary

In summary, after taking account of the responses received, the CER confirms the following decisions.

Decisions Relating to Smart Billing Requirements

1. An Energy Statement / information must be delivered to the Consumer (both residential and SME) through existing processes free of any transactional charge, as part of the billing document or a separate document, offering the Consumer choice of paper or electronic format.

a. With regards to PAYG Consumers, in order to align with credit Consumers, the frequency of provision of the energy statement / information should be in line with EED 6requirements stating that billing information should be made available at least quarterly on request or where the Consumers have opted

6 Energy Efficiency Directive 2012.: http://eur-

lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2012:315:0001:0056:EN:PDF

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2012:315:0001:0056:EN:PDF

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2012:315:0001:0056:EN:PDF


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to receive electronic billing, or else twice yearly.

2. Suppliers must provide information relating to any time of use tariffs in place for electricity and gas for that Consumer, including a clear overview of the applicable tariffs for the current billing period and any other relevant charges or rebates, as well as information needed to identify the relevant tariff periods and Consumer energy consumption and cost during those tariff periods.

3. The consumption information provided to the Consumer for the current billing period should be made available for comparison on the Smart Bill on an aggregate basis for the same billing period in the previous year, where there is sufficient historical billing information to provide such a comparison.

4. Contact and reference details relating to where the following additional information

can be found, should be provided in an appropriate form to the Consumer in their Smart Bill:

Independent Consumer advice centres;

Energy agencies or similar institutions;

Advice on energy efficiency measures;

Benchmark profiles for their energy consumption; and

Technical specifications for energy using appliances

5. Hints and tips on how to reduce or shift their energy consumption and ultimately cost to the Consumer will be provided in the Smart Bill.

6. Where smart meters are installed complementary energy consumption information will be made available to the Consumer on request, at intervals where billing information has been produced for the previous three years or from the start of the supply contract if this is shorter.


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5. Harmonised Downloadable File

5.1 Overview

The consumer will have the ability to access their energy usage data in a harmonised format to enable them to own and share their data with other parties to take advantage of services they may offer.


As outlined in section 7.3 there were 7 respondents that made comments on the proposed decisions. The key areas were:

1 respondent suggested that a limitation should be put in place regarding the frequency of customer data downloads;

4 respondents were concerned that multiple systems, 1 per supplier/network company, was an ineffective solution; and

The CER acknowledges that further work may be required at a later stage in the programme to determine any potential limitations on download requests. The CER has noted respondent’s views on the responsibility of the service provision however CER considers it appropriate that both networks and suppliers provide access to the HDF.

5.3 CER Decision

The CER acknowledges the broad support for the proposed information requirements on the access to the data by consumers only. The CER recognises the importance of this being a supplier provided service and has noted the potential for some further costs to be incurred from having both networks and suppliers. The requirement for the Consumer to have the ability to access their half hourly interval consumption data on request to allow them to analyse and share their data is explicitly and definitively referenced in the EU Energy Efficiency Directive and therefore these requirements are necessary in order to discharge the EU obligations. The service provision for the Consumer to access their import and export data free of charge will be the responsibility of both Networks and Suppliers on request, for the reasons set out in consultation: Advantages of Network provided services:

Data requested from Networks can be provided beyond the start of supply contracts, providing a richer source of data to Customers regardless of switching activities;

Customers may not want to contact their existing Supplier if they wish to change Supplier or take services from a competitor and the Networks would provide a neutral source of data; and


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This facilitates Customer switching and the energy services market which is consistent with the objectives of the National Smart Metering Programme.

Advantages of Supplier provided services:

This is consistent with the Core Design role for Suppliers maintaining the primary relationship with Customers and this is key; and

This can sit beside innovative Customer offerings for the provision of data and services.

After consideration of the responses, the CER will develop the format and associated SLA’s for provision of the harmonised data download by networks and suppliers in the next phase of the NSMP. The CER also notes the widely expressed views that there should be guidance in place for the Consumer and will look to develop this in the next phase of the programme.

5.3.1 Summary


Decisions Relating to Harmonised Downloadable File Requirements

1. The Consumer will have the ability to access their half hourly interval consumption

data on request via the internet. It will be provided to them in a standard harmonised format to enable them to analyse or share the interval data with an alternative Supplier or Third party offering other services.

2. CER requires both Networks and Suppliers to offer this service. The Consumer

will have access to their consumption data: a. For at least 24 months or from the start of their supply contract,

whichever is shorter (Supplier provided service); or, b. For at least 24 months or from the point of smart meter installation,

whichever is shorter (Networks provided service).

3. It is expected that, where the Consumer requests it and it is available, export data will also be made available to them through the same process.

4. The provision of this information will be provided free of any transactional charges and within a reasonable time frame.

5. The functionality required to fulfil the proposed requirement is as follows:

a. Secure access for the Consumer to a web interface. b. Functionality to provide historical consumption and export data in a

consistent and widely used, standardised format. c. The specification of minimum data presented in the harmonised format for

the historical consumption should contain the MPRN/GPRN and the associated Meter Serial Number (MSN) split by date showing the


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consumption/export in each of the 48 half hourly periods within the day for the selected time period.


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6. Mandated IHD

6.1 Overview

The consumer will be offered an In Home Display (at no additional cost them) to show them information about their energy usage in near real time. The CER see the main objective of the MIHD as an educational tool to encourage Consumer engagement. MIHD requirements cover the minimum of what information should be shown to the consumer within the home on the Mandated In-Home Display.

There will be a proportion of consumers who will not be able to have a MIHD installed because of technical reasons (e.g. no HAN coverage) and the information requirements for those consumers will be further investigated by the CER in the next phase of the NSMP. The CER will work with industry to determine any specific information provision requirements for these consumers.


As outlined in section 7.4 there were 7 respondents that made comments on the proposed decisions, the key areas were:

2 respondents were concerned that ESBN would not be providing enduring support for the HAN post the MIHD lifetime;

2 respondents viewed the MIHD as something that customers could update themselves (with price information), whereas 1 respondent aired concerns that this would not be applicable to all customers;

2 respondents believe that the ambient feedback on the MIHD was overly complex and should be evidenced based;

1 respondent was concerned that the MIHD being offered to a customer cannot therefore be a mandate and was unclear if the customer could elect to delay the provision of the device; and

1 respondent was concerned with the terminology used in the universal design principles in relation to the European Communities Regulation 2011.

To confirm, ESBN are responsible for the enduring communications infrastructure which includes the protocol/channel for data provision via the HAN and the secure pairing of devices to the electricity meter. The feasibility study will explore the potential options for automated updates to the MIHD. While the CER recognises views expressed on the value from ambient feedback, it considers that this is a useful tool for shifting consumption on the basis of TOU bands. The CER would like to clarify that a customer will be able to elect to have an MIHD at any point during the rollout, once they become eligible. In relation to the Universal Design, the CER will support the European Communities Regulation 2011 as required. A number of comments were received regarding the feasibility study as outlined below:


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Some respondents called for an independent body to scope the feasibility study and make the final conclusions/recommendations to the industry prior to its conclusion.

1 respondent suggested that such devices are rapidly becoming obsolete and the CER should explore alternative options.

1 respondent highlighted that the scope of the study should also outline the process for disposal of the device.

Concerns were raised by a number of respondents that it was not appropriate to expect the Consumer to manually enter tariff rates onto the MIHD.

1 respondent suggested that a fourth ‘daily rate / charge’ could be captured on the device to allow for closer bill matching, flexibility and future proofing.

CER will be responsible for the oversight and communications of the feasibility study, the scope and timelines. It is intended that industry stakeholders will have an opportunity to contribute to the feasibility study process. The CER will publish a paper following completion of the study. In summary, after taking account of the responses received, the CER confirms the following decisions.

6.3 CER Decision

6.3.1 Summary


Decisions Relating to Mandated In-Home Display Requirements

1. A MIHD will be offered to all residential customers7.

2. MIHD Functionality will include as a minimum

a. Presentation of Consumption data i. Instantaneous Active Electricity Demand (Real-Time); ii. Up to Date Consumption Position in Time Period (Cumulative gas and

electricity: current day, week and month); and iii. Ambient feedback on the basis of Electricity Time of Use Bands.

b. Presentation of indicative Cost data (not bill quality); i. Instantaneous indicative Cost of Electricity Demand; ii. Up to Date indicative Cost Position in Time Period (Cumulative gas8

and electricity); and iii. Time of Use Bands and Price Information (electricity only).

3. A feasibility study will be commenced during 2014 to identify viable options (from

both a technical & economical perspective) to enable automatic updates of TOU

7 A MIHD will not be offered to SME’s.

8 The MIHD may come preconfigured with an indicative CER approved Calorific Value


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band/tariff rates to the MIHD (via non AMI channels). 4. If the CER is of the view that automation is not feasible, a basic MIHD will be

procured by Networks which delivers the following minimum functional requirements in addition to the above:

a. Has the default TOU bands pre-configured for the ambient feedback; and b. Allows for manual input of tariff rates by Consumers.

5. ESBN will be responsible for:

a. Procuring the MIHD; b. Installing the MIHD during the Meter installation process9 (based on

Consumer acceptance of MIHD offer and technical feasibility of installation e.g. HAN signal)

c. Providing technical support for 2 years from the date of MIHD installation (this may be subject to review when considering transition/implementation & timing of default TOU)

6. Suppliers will be responsible for:

a. Providing support to the Consumer in relation to TOU bands and tariff rates and any activities required to update these on their IHD;

b. Providing historical cost and consumption data to Consumers on request using appropriate means for their Customers (e.g. web; smart bill, app). The CER will develop further guidelines regarding the format and response timing for the provision of this information in the next phase of the NSMP; and

c. If suppliers are offering their Customers non-default TOU products with different time bands, suppliers will offer an appropriate solution to meet minimum information requirements as specified in decision point 2 (in line with the period specified for technical support in decision point 5c).

7. There will be no input / configuring of price data into the MIHD by ESBN. It will be

up to the Consumer to input price data or for the supplier to update this data automatically if feasible. Appropriate guidance regarding inputting price data will be given to the Consumer at MIHD installation.

8. There will be a proportion of Consumers who will not be able to have a MIHD installed because of technical reasons (e.g. no HAN coverage) and the information requirements for those Consumers will be further investigated by the CER in the next phase of the NSMP. The CER will work with industry to determine any specific information provision requirements for these Consumers.

9 The specifics of the rollout strategy will be defined as part of transition planning.


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7. Appendix C1 - Summary of Consultation Responses

7.1 Summary of Respondents

In total the CER received 16 responses to the consultation paper from various stakeholders. Responses were generally supportive of the proposed decisions with focus given only to the areas of concern. Where further information is required in relation to comments received, these will be highlighted in the response summary.

The table below is a summary of the various companies and organisation which responded to the consultation.

Category of response Respondents

Retail Airtricity Bord Gáis Energy (BGE) Electric Ireland Energia Pre Pay Power Electricity Association of Ireland (EAI)

Networks Eirgrid ESB Networks (ESBN) Bord Gáis Networks (BGN)

Consumer Organisations

National Consumer Agency (NCA) National Disability Authority (NDA) Society of St Vincent de Paul (SVP)

3rd Party Providers Echelon Silver Spring Networks TicToc

Other Industry Sustainable Energy Authority Ireland (SEAI)

7.2 Smart Bill

7.2.1 Overview

A total of 4 respondents provided comments directly related to the Smart Bill, the key areas covered were:

2 respondents had concerns regarding the amount of information required to be presented on the smart bill, while 1 respondent believed it to be an inappropriate medium.

4 respondents aired their concerns regarding the frequency of information being sent to the customer and do not think it should be tied to their billing frequency

1 respondent was concerned with the terminology used in the universal design principles in relation to the European Communities Regulation 2011

The CER considers that the information to be provided through the smart bill is appropriate. The CER notes differing views expressed on frequency of billing but sees


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no definitive reason to change the initial policy position that this should be left to the market to determine, in line with minimum EED requirements. The bundling of the bill and energy statement is considered appropriate for affecting consumer behaviour in relation to their energy usage. In relation to the Universal Design, the CER will support the European Communities Regulation 2011 as required. The specific comments received are outlined below: The Amount of information required on the bill

Airtricity: “Airtricity cautiously supports the provision of this information to consumers but are not convinced that placing it on the Smart Bill will be the best way to present this. The natural constraints of space and readability may mean that a reference to the supplier website as to where this information can be found would be more user friendly. Airtricity suggests that CER consider moving this requirement out of the Smart Bill entity and relate to the supplier web sites propositions”

BGE: “believe that the energy statement is not the most appropriate medium

to receive additional energy efficiency information and hints and tips”

Frequency of the Information sent to the customer

Airtricity: “With regards to PAYG Consumers, in order to align with credit Consumers, the frequency of provision of the energy statement / information should be in line with EED requirements stating that billing information should be made available at least quarterly on request or where the Consumers have opted to receive electronic billing, or else twice yearly. “

BGE: “requiring an energy statement to be delivered as part of the billing

document, may be overly costly for suppliers that elect to issue bills, monthly or fortnightly. It might be better to prescribe a minimum number of energy statements to be issued each year as part of the bill.”

Energia: “We disagree strongly that an Energy Statement must be delivered as

part of every billing document and instead propose setting minimum interval requirements for suppliers (e.g. monthly). While we welcome the proposed decision that it can be offered in either paper or electronic format, we urge that the Statement does not need to be produced for every bill.”

Pre Pay Power: “requests that the decision regarding statement frequency for

prepayment customers is clarified so that customers who are offered real-time equivalent information in the home, do not have to “double up” on meeting the Energy Efficiency Directive


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with a costly and pointless support second channel of information to customers.”

Product Design

NDA “On page 41 of Appendix C, it states that ‘Universal Design Principles should inform the procurement process, where practical’. We submit that this statement does not adequately reflect Section 3(3) of S.I. No. 463/2011, European Communities (Internal Market in Electricity and Gas) (Consumer Protection) Regulations of 2011.”

7.2.2 CER Response

The Amount of information required on the bill The CER considers that the information to be provided through the smart bill is appropriate. The CER notes differing views expressed on frequency of billing but sees no definitive reason to change the initial policy position that this should be left to the market to determine, in line with minimum EED requirements. The bundling of the bill and energy statement is considered appropriate for affecting consumer behaviour in relation to their energy usage. Frequency of the Information sent to the customer The CER would like to clarify and confirm their commitment to the Energy Efficiency Directive, with specific reference to Annex VII section 1.1:

In order to enable final customers to regulate their own energy consumption, billing should take place on the basis of actual consumption at least once a year, and billing information should be made available at least quarterly, on request or where the consumers have opted to receive electronic billing or else twice yearly.

CER notes differing views expressed on frequency of billing but sees no definitive reason to change the initial policy position that this should be left to the market to determine, in line with minimum EED requirements that billing information should be made available at least quarterly on request or where the Consumers have opted to receive electronic billing, or else twice yearly (also for PAYG customers). While there is evidence that more frequent billing can lead to a greater energy reduction by consumers (as shown in the Irish trials), this needs to be weighed up against the costs associated with more frequent billing, especially if this is paper-based. With regards to PAYG Customers, the CER can confirm that frequency of billing should be in line with EED requirements stating that billing information should be made available at least quarterly on request or where the consumers have opted to receive electronic billing, or else twice yearly.


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Product Design The CER would like to clarify and confirm their commitment to the European Communities Regulations of 2011 specifically regarding the Section 3.3, which for reference is stated as below:

3.3 Distribution system operators and suppliers shall apply the principles of universal design to—

(a) all products and services offered or provided to final customers, and (b) communications with final customers.

7.3 Harmonised Downloadable File

7.3.1 Overview

A total of 7 respondents provided comments directly related to the Harmonised Downloadable File, the key areas were:

1 respondent suggested that a limitation should be put in place regarding the frequency of customer data downloads;

4 respondents were concerned that multiple systems, 1 per supplier/network company, was an ineffective solution; and

2 respondents were concerned with the granularity of data that is going to be provided

Mixed views were provided on the responsibility for providing the service. The CER acknowledges that further work may be required at a later stage in the programme to determine any potential limitations on download requests. The CER has noted respondent’s views on the responsibility of the service provision however CER considers it appropriate that both networks and suppliers provide access to the HDF. The specific comments received are outlined below: Customer Download Limitations

Airtricity: “suggests that some form of reasonable restriction is available to curtail the downloading of the same data multiple times within a given time frame.”

Duplicate systems providing the Harmonised Downloadable File

BGE: “Whilst we believe that only a minority of very engaged consumers will regularly seek detailed historic consumption data, we agree that it is appropriate that both Networks and suppliers provide access to consumer’s consumption information.”

Energia: “..agree that the customer’s half hourly consumption data is available on

request via the internet. However, we question the apparent need for duplication of infrastructure required to provide that information.”


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PrePayPower: “..requests that the requirement for both suppliers and networks to hold historical data is re-evaluated within the context of the parallel cost gathering exercise ongoing within the NSMP.”

ESBN: “.. believes the provision of consumption data to the customer via a web

interface will be a useful tool for such interested customers. However ESB Networks is concerned at the duplication proposed in the minded-to paper of both Networks companies and Suppliers building similar tools.”

Granularity

BGN: “BGN’s understanding was that the harmonised downloadable file would only contain granular interval data. The Final Decision paper should clarify whether a cumulative view of consumption is required.”

Eirgrid: “EirGrid strongly believes that individual half-hourly data should be

made available to third party service providers on the same basis that it is to suppliers from the outset, provided the consumer has consented.”

7.3.2 CER Response

Customer Download Limitations The CER acknowledges that further work may be required at a later stage in the programme to determine in any potential limitations on download requests.

Duplicate systems providing the Harmonised Downloadable File The CER has noted respondent’s views on the responsibility of the service provision however CER considers this service is best provided by both networks and suppliers. Granularity The granularity of data as outlined in the decision, customers will have the ability to access half hourly interval consumption data in a harmonised format that enables them to analyse or share their information with a supplier or third party as outlined in the Core Design.

7.4 Mandated IHD

7.4.1 Overview

A total of 7 respondents provided comments directly related to the Mandated IHD, the key areas covered were:

2 respondents were concerned that ESBN would not be providing the enduring support for the HAN post the MIHD lifetime;


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2 respondents viewed the MIHD as something that customers could update themselves (with price information), whereas 1 respondent aired concerns that this wold not be applicable to all customers;

2 respondents believe that the ambient feedback on the MIHD was overly complex and should be evidenced based;

1 respondent was concerned that the MIHD being offered to a customer cannot therefore be a Mandate and was unclear if the customer could elect to delay the provision of the device; and

1 respondent was concerned with the terminology used in the universal design principles in relation to the European Communities Regulation 2011

To confirm, ESBN are responsible for the enduring communications infrastructure which includes the protocol/channel for data provision via the HAN, and secure pairing of devices to the electricity meter. The planned feasibility study will explore the potential options for automated updates to the MIHD. While the CER recognises views expressed on the value from ambient feedback, it considers that this is a useful tool for shifting consumption on the basis of TOU bands. The CER would like to clarify that a customer will be able to elect to have an MIHD at any point during the rollout, once they become eligible. In relation to the Universal Design, the CER will support the European Communities Regulation 2011 as required. A number of comments were received regarding the feasibility study as outlined below:

Some respondents called for an independent body to scope the feasibility study and make the final conclusions/recommendations to the industry prior to its conclusion.

One respondent suggested that such devices are rapidly becoming obsolete and the CER should explore alternative options.

One respondent highlighted that the scope of the study should also outline the process for disposal of the device.

Concerns were raised by a number of respondents that it was not appropriate to expect the Consumer to manually enter tariff rates onto the MIHD.

One respondent suggested that a fourth ‘daily rate / charge’ could be captured on the device to allow for closer bill matching, flexibility and future proofing.

CER will be responsible for the oversight and communications of the feasibility study, the scope and timelines. It is intended that industry stakeholders will have an opportunity to contribute to the feasibility study process. The CER will publish a paper following completion of the study. Some of the specific comments received are outlined below: ESBN Feasibility Study

Airtricity “If ESBN is to lead a feasibility study then Airtricity proposes that an independent entity determines the conclusions and recommendations based on the outcome of the study.”


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BGE “We would question the need for a feasibility study to be carried out, when the above will meet the needs of those customers who opt for a device.”

PPP “We welcome ESB Networks’ involvement in this automatic IHD price

study, but we believe that ESBN’s role should be one of coordination and technical support. The study scope, design and findings need to be delivered by an independent organisation not involved in the day-to-day delivery of the programme.”

SEAI ”We particularly welcome that the high level design recognises the

necessity of enabling the cost calculation of real-time consumption. However, given the possibility that the consumer may be required to enter their own tariff information manually in to the mandated IHD, coupled with the fact that the IHD will be essentially an “opt in” device , there is a danger that the potential benefits of the smart meter rollout may not be fully realised.”

Energia “We note with interest that ESBN will conduct a feasibility study to

identify viable options to automate updates to the band/tariff rates. We would be of the opinion that it is important to get as many stakeholders as possible to be involved in such a study and would also call that the findings of the study be compiled and verified independently. “

ESBN On-going support

BGE “It should be called out that although ESBN’s responsibilities fall away after 2 years, they will have an ongoing requirement to support the utility HAN.”

NCA “With regard to providing technical support, it is noted that Electricity

Supply Board Networks will be responsible for “2 years of MIHD installation”. The Agency would recommend that this period should be subject to review taking account of roll-out, transition and migration to the default TOU.”

Updating the MIHD with price information

BGE “We welcome the fact that the MIHD will now be offered to consumers. This should limit the proliferation of these devices within the home and therefore minimise the cost to the programme. The fact that the cost to be displayed on it will be indicative only is also to be welcomed. It is our

view that these devices can be pre‐programmed with indicative cost information and this will obviate the need for manual intervention on the IHD.”


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Energia “Energia strongly disagree that default timebands be pre-configured for

the default TOU tariff only. This is unnecessarily restrictive and we call that the customer can manually change the timebands to allow alternative tariffs to be accommodated. We have found no reasons in the papers concerning why the timebands cannot be programmed by the customer and call for some level of justification concerning this decision”

“We note that suppliers will be responsible for providing support for

customers in relation to TOU bands but question why this is relevant if the bands are pre-programmed”

NCA “The Agency does not view the initial or tentative solution of consumers

manually updating MIHDs with price and tariff information as appropriate in all cases.”

Ambient Feedback functionality

Energia “We believe that providing ambient feedback to the device adds a degree of unnecessary complexity and uncalled for functionality if time bands are to be flexible or the device contains the ability to have these bands reprogrammed.“

PPP “The inclusion of ambient feedback functionality of the MIHD as a

necessary feature should be evidence-based, otherwise it adds unnecessary costs and restriction to the procurement of the MIHD.“

“For suppliers with legacy arrangements for supply of IHDs that can

meet (and beat) the minimum IHD requirements were it not for ambient feedback, the inclusion of ambient feedback as a requirement represents a wasteful stranding of assets.”

Customer take-on

Airtricity “Airtricity observes that ‘offer’ implies the consumer can choose not to have the device therefore it cannot be described as “Mandated”. It is unclear if the offer is a onetime offering or if the customer can elect to delay the provision of the device or if they can change their mind in the future.”

Product Design

NDA “On page 41 of Appendix C, it states that ‘Universal Design Principles should inform the procurement process, where practical’. We submit that this statement does not adequately reflect Section 3(3) of S.I. No.


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463/2011, European Communities (Internal Market in Electricity and Gas) (Consumer Protection) Regulations of 2011.”

7.4.2 CER Response

MIHD Feasibility Study CER will be responsible for the oversight and communications of the feasibility study, the scope and timelines. It is intended that industry stakeholders will have an opportunity to contribute to the feasibility study process. The CER will publish a paper following completion of the study. ESBN On-going support To confirm, ESBN are responsible for the enduring communications infrastructure which includes the protocol/channel for data provision via the HAN and secure pairing of devices to the electricity meter. Updating the MIHD with price information The CER welcomes comments with regards to updating the MIHD with price information. The feasibility study will explore the potential options for automated updates to the MIHD. Ambient Feedback functionality While the CER recognises views expressed on the value from ambient feedback, it considers that this is a useful tool for shifting consumption on the basis of TOU bands. In terms of cost-related information on the MIHD, the CER recognises that its importance has been demonstrated in trials and focus groups, as well as consultation responses. Customer take-on The CER would like to clarify that a customer can choose to have an MIHD at any point during the rollout, once they become eligible. Product Design The CER would like to clarify and confirm their commitment to the European Communities Regulations of 2011 specifically regarding the Section 3.3, which for reference is stated as below:

3.3 Distribution system operators and suppliers shall apply the principles of universal design to—

(a) all products and services offered or provided to final customers, and (b) communications with final customers.