Gemserv is pleased to provide our response to the Department for Economy’s 2024 consultation on the Design Plan for the Roll-out of Smart Electricity Meters in Northern Ireland (NI).
Gemserv has a 25-year long history of providing services and solutions to electricity and gas markets in Great Britain (GB) and over 20 years to electricity and gas markets in Northern Ireland. In addition, Gemserv provides professional services and solutions to some of the world’s leading organisations and public authorities.
Our solutions
In NI, we have worked on behalf of the UR on various assurance and price control projects since 2004, conducting supplier audits and advisory projects in gas and electricity markets, necessitating and developing a deep knowledge of market design. Gemserv is currently delivering the RP7 Price Control review of NIE Networks’ IT spend on behalf of the UR, and in recent years has been engaged in NI energy supplier audits and a review of prepay metering risks in both gas and electricity markets.
In the Republic of Ireland (RoI), we designed the Retail Market Assurance Framework which we continued to operate for 17 years, supporting participants through landmark projects such as the National Smart Metering Programme, including an information and cyber security assessment and recommendations for risk mitigation, on behalf of the CRU. Most recently, we drafted RoI’s Smart Meter Data Access Code, which sets out the rules to which suppliers and other authorised persons must adhere in order to access smart meter data.
Within GB, we operate at the heart of the electricity industry, having administered the Master Registration Agreement (MRA) since 1998, until it was stood down and incorporated into the Retail Energy Code (REC) in 2022. Following competitive procurement, we were appointed as Code Manager to the REC in that same year. We have also been the Smart Energy Code administrator since 2013, providing stakeholder engagement and Code Modification support to the SEC, a multi-party Code which defines the rights and obligations of energy suppliers, network operators and other relevant parties involved in the end to end management of smart metering in Great Britain.
Gemserv has been involved in the development of Smart Metering in GB since the inception of the Smart Metering Implementation Programme Phase 1 in 2010. We were subsequently appointed as the Alternative Home Area Network (Alt HAN) Business Support Function provider in 2017, to ensure the programme was developed and delivered to the highest standard, using the most cost-efficient approach, to ensure connectivity for difficult to reach customers across the GB smart metering network.
A Summary of Key Points from our Response
Guiding Principles: We agree with the comprehensive and consumer-centric guiding principles outlined in the consultation. We suggest adding a principle focused on continuous improvement and innovation to ensure adaptability to technological advancements and evolving consumer needs.
Roles and Responsibilities: We support the network-led rollout approach and recommend that the Utility Regulator (UR) take the leading role in overseeing the development of the smart metering programme. Clear definition of responsibilities between the Department for Economy (DfE) and UR is crucial for efficiency.
Consumer Protection and Engagement: Involving consumer representatives in the design of the requirements for new systems and procurement is essential. We recommend strategies such as public awareness campaigns, consumer workshops, and educational resources to build consumer confidence and encourage adoption.
Data Management and Privacy: We understand the importance of robust privacy controls and consumer consent mechanisms. We suggest specifying the legal basis for accessing smart meter data and introducing requirements for consumer validation to prevent unauthorized access.
Functional and Technical Requirements: Industry should lead the development of functional requirements for meters and data systems, with final approval by the Oversight Group. We recommend integrating smart meter data with supplier billing systems to improve billing accuracy and energy management.
Roll-out Strategy: We advocate for prioritising vulnerable consumers, high energy users, and early adopters of low-carbon technologies. Setting clear targets and regular reporting will ensure transparency and accountability throughout the rollout process.
Gemserv is eager to engage with the Department for Economy in Northern Ireland on this consultation topic. We believe our extensive experience and expertise in managing complex market arrangements and regulatory compliance within the energy sector will be valuable in ensuring the successful implementation of the smart metering programme.