Cecilie Ingversen,

Consumers & Markets,

Ofgem,

10 South Colonnade,

London,

E14 4PU7

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Dear Cecille,

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RE: Open letter on lessons from Ofgem’s advanced meter rollout (AMR) investigations to considerin respect of the smart meter rollout obligation.

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We thank you for this opportunity to provide feedback on the topic above.

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As you are aware, AIMDA has been actively engaging with BEIS, Ofgem and Elexon on a range of matters relating to the second phase of the SMETS meter rollout. One of our key priorities has been to ensure that all commercial customers continue to have the right to select a vendor of choice for data collection, data aggregation and meter operation services, together with the right to control the type of meter they install at their sites. We recognise the legislative changes that have been made over the last 12 months including:

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1) the ability for commercial customers (non-microbusinesses) to have a meter of their choice installed (SMETS2 or AMR); and,
2) the requirement for suppliers to inform customers of this choice, together with the benefits / costs associated to each to allow for an informed decision.

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Given this, we were rather concerned with the tone of the letter referred to above which was issued on 31st October 2018. The letter emphasises the obligation on suppliers to ensure that ‘all reasonable steps’ are taken to make sure that consumers are offered SMETS meters or face the riskof being fined. While the letter does acknowledge that “consumers are not obliged to have a smartmeter installed” it continues to state, “that suppliers should consider appropriate recontact strategies based on customers preferences, contact history, and reasons for not previously accepting a smart meter.” The tone in this letter seems inherently biased towards suppliers providing SMETS2 and does not reference

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the policy outlined above, which (given that both AMR & SMETS2 count towards rollout obligations) could support and accelerate delivery of a supplier’s roll-out plan. This bias is often repeated in communications and we believe should be addressed immediately to better inform consumers and reflect their right to choose.

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We are aware that suppliers have many different strategies for engaging for with commercial consumers, while some are actively looking to continue to install AMR, others are content with installing SMETS2; however, one emerging theme seems to be a lack of a consistent approach by suppliers to informing non-microbusiness commercial customers of the choice between SMETS / AMR and the associated benefits. To ensure these customers can select the right meter, we would welcome an open letter being issued by Ofgem reminding suppliers of their obligation to inform customers of their choice between an AMR / SMETS meter together with the benefits / costs associated to each.

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We thank you again for the opportunity to provide feedback; if you wish to discuss this subject in greater detail, please contact AIMDA Chairman – Peter Olsen on 07591200805 orpeterolsen@energyassets.co.uk.

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Yours faithfully

 

Peter Olsen

Chair – AIMDA

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AIMDA members - IMServ Europe Limited, Energy Assets Limited, Siemens Managed Services, SMS Plc, Stark Software International Ltd, WPD Smart Metering Ltd, and TMA Data Management Ltd.