Smart Metering Implementation Programme Department of ...

1 Smart Metering Implementation Programme Department of Energy & Climate Change, 3 Whitehall Place, London, SW1A 2AW Tel: 0300 068 5127 Email: Consultation reference: URN 12D/033 6th Floor Dean Bradley House 52 Horseferry Road London SW1P 2AF T +44 (0)20 7706 5100 F +44 (0)20 7706 5101 Registered Office as above 1 June 2012 Dear Sir/Madam, Energy Networks Association Response to the DECC Smart Metering Implementation Programme Consultations Consumer Engagement Strategy Thank you for the opportunity to respond to your consultation on the proposals for Consumer Engagement Strategy. As you are aware Energy Networks Association (ENA) is the industry body representing the UK s electricity and gas transmission and distribution networks operators.

2 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: 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: APPENDIX Energy Networks Association Response to: DECC Smart Meter Implementation Programme Consultation: Consumer Engagement Strategy (Reference URN 12D/033) 1.

3 Are these the right aims and objectives (paragraphs ) against which to evaluate the Government s consumer engagement strategy for Smart Metering ? Please explain your views. We agree with aims of the consumer engagement strategy with the following proviso. The Smart meter impact assessment indicates that a significant proportion of the benefit to the customer comes from enabling customers to shift the time when they use their energy through Smart grid techniques, rather than simply reducing energy consumption. It might be clearer, and provide a more direct incentive, to the customer if the aim was amended to achieving savings on the energy bill rather than energy savings.

4 2. What are your views on focusing on direct feedback, indirect feedback, advice and guidance and motivational campaigns as behaviour change tools? What other levers for behaviour change should we consider? (See also Appendix 1.) Evidence from research in the UK and abroad indicates the need to keep the messages simple, whether from direct or indirect feedback. Some sort of traffic light system, perhaps related to rate of spend rather than energy use or price level, is likely to be most effective. Valuable learning will also become available from our Low Carbon Networks fund projects that are focusing on customer engagement. The strategy must be flexible enough to enable new learning to influence the approach adopted.

5 6. Do you agree that a centralised engagement Programme , established by suppliers with appropriate checks and balances, is the most practical solution given other constraints? If not, what other practical alternatives are there? We welcome consideration of central engagement for consumers through a central/neutral body. DECC should have an active role but not necessary as chair, as government should have a role in shaping the activity of the central engagement group. Digital UK rollout is a good example of what can be achieved through this approach. One delivery mechanism and umbrella brand for suppliers, networks and other stakeholders as part of a national Programme with an independent brand would be the sensible option.

6 It should be a not for profit organisation working in partnership with suppliers, government, consumer groups, networks, etc. With regards a new brand for this central body, consideration should be given to building upon existing brand of Digital UK through leveraging the trust this body has already gained. 7. Do you think that suppliers should be obliged through licence conditions to establish and fund a Central Delivery Body or would a voluntary approach be preferable? Network operators believe that CDB has a critical role to play in helping to make the Smart Metering roll our Programme a success. It is essential that suppliers work well together in the CDB with common aims and objectives.

7 If there is a risk that this cannot be achieved via a voluntary framework (code of practice etc) then obligations through licence conditions may be more appropriate. 10. Do you have any views on mechanisms for monitoring progress and holding suppliers to account in delivering objectives? It will be necessary to establish what role the Central Delivery Body has in reviewing progress and unforeseen or emerging issues, and proposing solutions or alternative ways forward. 18. What role, if any, should network companies and communications service providers have in central engagement? ENA and it members are of the view that the creation of a central body to manage consumer engagement is the right model to employ.

8 Whilst the vast majority of communications with the consumer will be Supplier focused there will be areas of communication that are delivering messages on behalf of the network companies. Where this is the case we believe it is appropriate that network companies have involvement in the central engagement body in an advisory capacity in order to advise on, and agree, any network specific messages that are to be delivered on their behalf. Representation for the network companies should be managed through Energy Networks Association. 21. Should there be requirements for suppliers to share roll-out plans with the Central Delivery Body, and for the body to take them into account?

9 It is essential that suppliers share rollout plans with CDB as these are key to helping form the central engagement strategy. Supplier roll out plans will also be essential to network operators as it will enable them to plan resource levels for supporting the roll-out.