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«Ref: C14-RMF-68-03 19 March 2015 Council of European Energy Regulators asbl Cours Saint-Michel 30a, Box F – 1040 Brussels, Belgium Arrondissement ...»

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The above general information on meter data management should, as a minimum, be published on the website of the relevant body (DSO/metering operator/other) and must be presented in a customer-friendly way.

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Transparency is also important for building customer trust. A customer is more likely to trust meter data and the processes for data management if they can understand how their customer meter data is generated, collected, stored and subsequently used.

THINK report - Shift, Not Drift: Towards Active Demand Response and Beyond, June 2013.

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Recommendation 3: In order to achieve energy efficiency benefits and other potential benefits, the relevant bodies in each country should take active steps to build customer confidence in sharing customer meter data. Those bodies could be the NRAs, the DSO/metering operator, public authorities and consumer organisations.

Active steps to be taken might include information campaigns and the use of energy advisors.

Information can be provided in several ways. A vast majority of the respondents to the public consultation supported an information campaign combined with other options. These options can include the use of an energy advisor. An energy advisor is a person who can give advice to the customer, e. g. on how to save energy or what to do in order to receive wider benefits.

The energy advisor can be employed by the municipality or within the private sector.

4.2.3 Common Standards

A core element of transparency is the format in which data is provided to parties and the systems used for the exchange of that data. As highlighted earlier in this paper, we consider that transparency is enhanced where there is standardised content, format and systems for the exchange of data. This has benefits in terms of providing greater certainty, improved efficiency and enhanced competition.

CEER recognises that Annex 1 of the 3rd Package Directives states that MSs shall ensure that customers “have at their disposal their consumption data, and shall be able to, by explicit agreement and free of charge, give any registered supply undertaking access to its metering data. The party responsible for data management shall be obliged to give those data to the undertaking. Member States shall define a format for the data and a procedure for suppliers and consumers to have access to the data. No additional costs shall be charged to the consumer for that service”.

In addition, Annex 1 also states, with respect to smart meter systems, that “The Member States, or any competent authority they designate, shall ensure the interoperability of those metering systems to be implemented within their territories and shall have due regard to the use of appropriate standards and best practice and the importance of the development of the internal market in electricity”.

By this, we understand that there should be a national common standard for data content, data format and data exchange in the retail market. The appropriate standards in this regard are still not in place in all EU countries. So the first step is to implement these.

Taking into consideration the future internal energy market, also at retail level, we recommend exploring the costs and benefits of harmonising these standards at a broader geographical area, namely at regional and/or European level. In the CEER public consultation, four respondents highlighted concerns with standardisation at a European level due to the high costs incurred and that those costs need to be justified by a full cost-benefit analysis.

26/38 Ref: C14-RMF-68-03 Customer Data Management for Better Retail Market Functioning Provided that MSs have designated NRAs as the competent body, NRAs should ensure that the these common standards are developed. We recommend that the customer meter data to be standardised should, as a starting point, be the point of delivery identification data, the user and contract data and the net consumption data.

Recommendation 4:

Beyond current requirements for a national common standard for data format and exchange, we recommend MSs, or any competent authority they designate, explore the costs and benefits of harmonising these standards at a broader geographical area, namely at regional and/or European level.

If a common European standard for data content, format and exchange is developed, one has to take into account that these changes will have implications for other related topics such as data processes, business processes and basic agreements/contracts.

From the CEER public consultation, there is a consensus that transparency is a key issue for the success of customer data management, but related to this guiding principle there are challenges that need to be faced.

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Data accuracy is an important issue with or without smart meters. Accuracy is crucial for building customer trust, as well as creating accurate energy bills related to usage. It is therefore important that customer meter data, be it from smart or traditional meters, is robust and the processes that are subsequently used to convert that data for the purposes of billing are equally robust. The data management processes should be robust and ensure that meter data is of high quality, that customers receive accurate and timely bills, and as a consequence, that customers have confidence in the quality of their bills.

Parties need to receive useful information in a timely manner. If useful information is not provided and it is not available in a timely manner then the usefulness of that information diminishes, and so does the overall efficiency of the arrangements.

The additional functionality provided by smart meters, including remote reading and interval metering, should increase the quality of customer meter data and thus increase billing accuracy. As a result, customers are likely to engage more actively with their energy usage if they know exactly how much energy they are using.

There are a number of benefits associated with this including, but not limited to:

 scope for customers to save on energy bills;

 making supplier switching more efficient and easy;

 suppliers having better customer meter data to improve service to their customers;

 network operators being able to plan and develop their networks in a better informed manner; and  wider societal benefits stemming from a reduction of greenhouse gas emissions and increases in energy efficiency.

Another key aspect of ensuring accuracy is the quality of industry processes; meaning how the parties involved in communicating data execute that communication. The better the

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processes put in place by industry to ensure accuracy, the better the quality of the information provided. This is relevant with or without smart meters.

No data management model will entirely remove the possibility of data inaccuracy due to technical or manual errors. Therefore, the relevant national body in each country should have arrangements in place to identify inaccuracies and address them as early as possible.

Technical equipment in the meters are in most MSs under the responsibility of electricity (and gas) security authorities. The recommendation below does not refer to failures concerning the technical equipment, but to the right of the customer to know that something with respect to (the reading of) customer meter data deviates from common procedures.

Recommendation 5: The relevant body (DSO/metering operator/other) should communicate to the customer any inaccuracies that might have taken place in relation to customer meter data and inform how these inaccuracies have been addressed (e.g. loss of meter data leading to an estimation of consumption in the bill). The NRA should ensure that measures for addressing these inaccuracies are established in legislation/regulation.

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Accessibility is a crucial area of consideration for the success of data management arrangements. Particularly important is the interaction with the principle of Privacy and Security.

Two of the guidelines oin ERGEG's GGP on Regulatory Aspects of Smart Metering are

directly relevant to data accessibility, namely:

 Recommendation E/G 3 – Access to data on consumption and cost data on customer demand. Specifically it is noted that, on demand, a customer as well as those that both generate and consume electricity should be able to access up-to-date consumption data and costs.

 Recommendation E/G 12 – Interface with the home. In line with the functionalities required under Mandate 44129, smart meters should be equipped with or connected to an open gateway. The service provider(s) chosen by the customer should have access to this gateway, which should have a standardised interface enabling energy management solutions, such as home automation and facilitate delivery of data directly.

There are a number of stakeholders who may have an interest in accessing customer meter data. First and foremost, customers (or a party operating on their behalf) need to be able to access their customer meter data to help manage their energy use. For many customers, it is likely that a third party will have a role in accessing and using this data. The data could be provided through an in-home system or by means of a gateway. If this is the case, that third party must have easy access to the data. This directly benefits customers in terms of the ability to save money, but also has wider potential system benefits in relation to security of supply and environmental benefits through the impact on carbon emissions.

Standardisation mandate to CEN, CENELEC and ETSI in the field of measuring instruments for the development of an open architecture for utility meters involving communication protocols enabling interoperability – March 2009

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Recommendation 6: The customer (or a market participant acting on behalf of the customer) should have easy access to customer meter data. This information should, where reasonable, be made available through an adequate channel of the customer’s choosing (e.g. an in-home system or by means of a gateway).

The Energy Efficiency Directive (Article 11) states that “Member States shall ensure that final customers receive all their bills and billing information for energy consumption free of charge and that final customers also have access to their consumption data in an appropriate way and free of charge”. The question is, however, whether a third party should have access to this data free of charge.

On the one hand, costs associated with accessing customer meter data can act as a barrier to sharing this data and may also discourage third parties who could use it to provide additional services/benefits. On the other hand, in the future there will be even more data, especially where there are smart meters installed, and the more data there is to share the more costs there will be for a DSO/metering operator. So one will have to find a reasonable compromise regarding the frequency of access and the respective costs.

4.5 Guiding Principle: Non-Discrimination

Article 8 paragraph 5 in the Energy Efficiency Directive states that “access of market participants offering energy services shall be based on transparent and non-discriminatory criteria”. The importance of non-discrimination was furthermore highlighted by the THINK report on demand response30. It recognised the importance of “ensuring non-discriminatory access to all segments of electricity markets for all market players” to ensure these markets are contestable and open to all new entrants and new services. The report further recognised the importance of national authorities monitoring non-discriminatory access to data relevant for demand response to prevent the transfer of information from the regulated activities to the deregulated activities in integrated suppliers. In our view, these issues are relevant not only for demand response but also for broader energy services.

CEER agrees with the importance of non-discrimination in order for customer data management arrangements to be effective and enable effective competition. The arrangements should not discriminate between any stakeholders; i.e. where a certain category of stakeholder has access to data, then that data is available on a nondiscriminatory basis to other similar stakeholders. Only by doing so will it be possible to create a level playing field between suppliers and other potential third parties.

The issue of non-discrimination is wider than just data management in respect to customer meter data, but extends to the market more broadly. Specifically, it is important that information is available on a non-discriminatory basis regarding where smart meters are installed and thus where the potential customers for these services are. This might not always be the case in countries where the roll-out of smart meters is DSO-led. There should be non-discriminatory access to this information in order to enable a level playing field between different parties in the market.

One could think of providing the information in which area there are smart meters by publishing the post code (without an address). However, providing detailed information is THINK report - Shift, Not Drift: Towards Active Demand Response and Beyond, June 2013.

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dependent on the customer’s consent; if the customer has given his/her consent, the DSO/metering operator is allowed to provide access to the requested data and the customer can decide whether to receive offers by third parties or not31.

Recommendation 7: To support an effective and competitive market, the data management model should not give undue preference to one stakeholder over another. This is especially important in relation to DSO-led smart meter roll-outs, for which there should be nondiscriminatory access to information when and where such meters are installed.

4.6 Cost and Cost-Efficiency as a Guiding Principle

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