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Article 10 of this Directive also ensures that customers can have easy access to (historical) consumption data, setting rules in relation to the type and amount of consumption information. Furthermore, customers will be able to use new smart technologies to manage their energy consumption and production, or may choose to engage service providers to manage their interface with the energy market9. This underlines the importance of the principles and recommendations in this Advice.
CEER held a public consultation on its draft advice for all interested European stakeholders during the spring of 2014. We received answers from 58 respondents. As a follow up to the comments received, CEER invited all respondents to a hearing in Brussels on 22 September http://www.beuc.org/ Energy Regulation: A Bridge to 2025, Conclusions Paper
DIRECTIVE 2012/27/EU OF THE EUROPEAN PARLIAMENT AND OF THE COUNCILof 25 October 2012 on energy efficiency, amending Directives 2009/125/EC and 2010/30/EU and repealing Directives 2004/8/EC and 2006/32/EC (EUT L 315, 14.11.2012, s. 1, Celex 32012L0027).
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2014. The result of the public consultation as well as the discussionat during hearing form the basis of this final Advice. This document is accompanied by an Evaluation of responses (Ref. C14-RMF-68-03a). All individual responses can be found on the CEER website10, except for 7 which were marked as confidential.
Structure of the document There are several stages to identifying which recommendations are relevant for customer
data management. These stages provide the structure for the remainder of the document:
Chapter 1 – describes the scope and objectives of the Advice Chapter 2 – identifies the relevant stakeholders and their interests in customer data management Chapter 3 – identifies the issues for customer data management today and in the future Chapter 4 – sets out guiding principles with recommendations Chapter 5– provides a summary of the principles and recommendations Chapter 6 – presents the conclusions
1.1 Scoping the issue of customer data management
Customer data management comprises the processes by which data is sourced, validated, stored, protected and processed, and the basis on which it can be accessed. The scope of this advice is not to define any preferred data management model but to provide a set of guiding principles that the design of such a model should be based on.
These principles are as important for existing data management models as for new models.
The guiding principles should therefore apply, regardless of data management model, and the principles used to evaluate current functioning customer data management models. In this respect, the DPIA template11 issued by the Europan Commission in 2014 is also an important tool.
There are a number of aspects of data management that we took into account when defining the guiding principles and the table below provides an overview. These aspects can been seen as stepping stones between the high-level aspects of data management and the more practical guiding principles.
CEER consultation on data management for better retail market functioning, 2014/03/23-2014/05/23 Commission Recommendation of 10 October 2014 on the Data Protection Impact Assessment Template for Smart Grid and Smart Metering Systems
For the purposes of this Advice, we have considered data necessary for the efficient functioning of the retail market for electricity and gas. This includes wider data relevant to the
operation of the retail market. The types of data we consider in this paper are as follows:
Point of delivery identification data – This is data used to identify the meter itself and the point where the meter is installed12.
User and contract data – This is data on the user of the meter (name and address of the user) and the user’s contract data (e.g supplier identification data, first day of supply for each supplier serving that user/point of delivery).
Consumption data – This is data on the usage associated with the meter. Among the forms of data collected can be; real-time energy usage, current and historic consumption and energy efficiency information when available, and micro-generated input data. Smart meters will allow a more granular breakdown of consumption data, possibly including consumption by individual home appliances.
For example, in the UK this is referred to as the Meter Point Administration Number (MPAN); in Spain it is the Universal Point of Supply Code (CUPS).
We refer to these types collectively as “customer meter data”.
Smart meters will be able to handle a wider range of data, for example operational data (such as voltage quality). We are also aware of the fact that there are other market participants involved in data management, such as balance responsible parties. However, this advice focuses on data relevant to retail market functioning and on customer meter data.
Customer data management includes only final industrial and domestic consumers, and does not include commercially distributed generation13 and storage units also defined as commercial data14.
Standardisation regarding data content, data format and systems for exchanging data There are three factors with significant impact on the arrangements for customer meter data management. These are: (1) the content of the data; (2) the format in which this content/data is provided to parties (e.g. the point of delivery identification data and the way the customer meter data is presented); and (3) the systems used for the exchange of this data (e.g. use of centralised systems, databases and delivery points to customers). CEER considers that the adoption of at least national standardised arrangements has significant benefits for
customers. These benefits are reflected in:
Greater certainty – Customers would be more likely to understand the data they receive and how to access it if the presentation and format are similar regardless of their supplier. This makes the information more transparent, reduces the risk of confusion and increases the potential opportunities for using data in a relevant way.
Efficiency – As customers are more likely to understand their data, they are also more likely to use it to make efficient decisions about their consumption; this has wider impacts on the efficiency of the system as a whole.
Enhanced competition – A standardised approach to the provision of data creates a level playing field among stakeholders, which in turn leads to better-positioned customers making decisions about changing tariffs or switching suppliers. National standards could reduce barriers to entry/expansion into different parts of national markets.
A potential example of how customer meter data could be useful to customers is the Green Button15 initiative in the USA, which went live in 2012. Under these arrangements, the companies provide a website from which the customers can click on the “Green Button” and download up to 13 months of their detailed electricity usage data broken down by either 15minute or hourly interval data. The associated opportunities include seeing a breakdown of their energy usage by appliance, getting an immediate comparison of how optional time-ofuse rate plans would affect their bills and calculating their potential savings and payback for installing insulation. Developing a tool in that direction could be an interesting next-step approach for European energy customers.
This generation does not include micro generation.
This specification is useful to understand the difference in perimeter of the CEER papers. In the ongoing CEER work to develop advice on the future role of DSO, the use of “commercial data management” broadens the definition of “customer data management” to include not only final consumers but also distributed generation and storage units.
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standardised content, format and systems for the exchange of data. Key reasons included:
promoting competition in the retail market; the creation of economies of scale; the ability to offer universal solutions and services; it is in the broader interests of consumers as it is more transparent, reduces the scope for confusion and makes it possible for customers to maintain services when switching suppliers. At the same time, there were concerns about the efficiency impact of imposing a single standard and the scope for additional costs reflected in higher prices for final consumers.
In order to develop data formats, one needs first to understand what content should be formatted. Furthermore, we recognise that there are potential cost and efficiency issues for putting standardised arrangements in place. There are different levels of standardisation that can be achieved and different ways in which arrangements can be put in place. We consider that the starting point could be customer meter data, which includes the three areas discussed in the previous section of this paper: point of delivery identification data, user and contract data, and net consumption data. We also consider that there could be various stages to such standardisation.
Standardised customer meter data exchange implies, at a minimum, the need to standardise interfaces and information exchange at distribution system operator (DSO) boundaries;
between customers and market participants. This becomes increasingly important with the introduction of smart meters and would be critical to the introduction of individualised customer information on detailed energy use.
We consider that standardisation is a key element of transparency.
The main objective of this advice is to present guiding principles and recommendations on
which the development of customer data management the retail market should be based:
in relation to electricity and gas markets; and in the current time period as well as in the future, with or without smart metering and smart grids, and regardless of the data model (hub/no hub etc.).
Advice relating to electricity and gas There are specific technical differences between the gas and electricity markets which have implications for the types of data that can be collected. Most issues concerning data management are the same for gas and electricity. In this paper, unless otherwise stated, all sections cover both gas and electricity equally.
With or without smart meters A significant issue for data management is the roll-out of smart meters and the opportunities that this presents, as well as the risks which will need to be managed. However, there are
two reasons why it is important that this advice considers not only a future based on smart
meters but also the current situation:
1. Data management is already a key issue. The availability of good quality data is a crucial facilitator of competition and, in the absence of appropriate arrangements for data management, could be regarded as a potential barrier to competition.
2. Smart meters will not be rolled-out in the same timescale in all countries. The Electricity Directive 2009/72/EC and Gas Directive 2009/73/EC set up the framework for the roll-out of smart meters. The Directives state that MSs should ensure the implementation of smart metering systems to facilitate the active participation of customers in the electricity and gas supply market. For electricity meters, a deadline of 80% of customers by the year 2020 has been set.
The Directives also state that the roll-out may be subject to an economic assessment of longterm costs and benefits. Some countries have already undertaken a cost-benefit analysis and, on that basis, determined that it is not appropriate to roll-out smart meters in the electricity and/or gas markets at this time. For those countries, it is important to continue considering data management in an environment without smart meters.
In this Advice, we use the same definition for customers as is used in the 2020 Vision.
Customers are defined as the European retail customers of electricity, gas and district heating, as well as those that both generate and consume electricity (prosumers). Customers can be households or small enterprises (i.e. very small businesses which are in many ways similar to household customers in their engagement with energy markets). However, district hearing customers are not relevant for the purposes of this paper.
Today, most customers have virtually no control over the customer meter data generated by their use of energy. If the DSO/metering operator reported the data available to the customer through an interface tailored for the customer, there would be more transparency over this data. Furthermore, a customer data management model should provide customers with an opportunity that does not always exist today; to get a review of point of delivery identification data, user and contract data and finally consumption data. At present, customers often experience a lack of transparency according to what a stakeholder can do on the customers' behalf and possibly thereby provide benefits.
In most European countries, electricity and gas suppliers must have bilateral contact with the DSO/metering operator in order to obtain access to information on its customers metering data. Non-discriminatory and smooth accesibility of data is naturally most important, during pre-contractual as well as running contractual situations. The DSO / metering operator should act as a neutral point of contact, from which the supplier can obtain the necessary information to conclude agreements, implement billing or offer tailored energy contracts.