eurelectric_response_to_ceer_consultation_on_data_management23062014-2014-2510-0002-01-e.pdf

CEER Draft Advice on Data Management forBetter Retail Market Functioning: electricity& gas – A CEER public consultation paper

A EURELECTRIC response paper

June 2014

Dépôt légal: D/2014/12.105/23

EURELECTRIC is the voice of the electricity industry in Europe.

We speak for more than 3,500 companies in power generation, distribution, and supply.

We Stand For:

Carbon-neutral electricity by 2050

We have committed to making Europe’s electricity cleaner. To deliver, we need to make use of all low-carbon technologies: more renewables, butalso clean coal and gas, and nuclear. Efficient electric technologies in transport and buildings, combined with the development of smart grids and amajor push in energy efficiency play a key role in reducing fossil fuel consumption and making our electricity more sustainable.

Competitive electricity for our customers

We support well-functioning, distortion-free energy and carbon markets as the best way to produce electricity and reduce emissions cost-efficiently.Integrated EU-wide electricity and gas markets are also crucial to offer our customers the full benefits of liberalisation: they ensure the best use ofgeneration resources, improve security of supply, allow full EU-wide competition, and increase customer choice.

Continent-wide electricity through a coherent European approach

Europe’s energy and climate challenges can only be solved by European – or even global – policies, not incoherent national measures. Such policiesshould complement, not contradict each other: coherent and integrated approaches reduce costs. This will encourage effective investment to ensurea sustainable and reliable electricity supply for Europe’s businesses and consumers.

EURELECTRIC. Electricity for Europe.

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A EURELECTRIC Response paper June 2014

KEY MESSAGES

Most customers will only be comfortable sharing their data if they are confident that these arestored securely in a way that safeguards their privacy. Customer meter data protection shouldtherefore be ensured by legislation/regulation

DSOs, metering operators and suppliers need unrestricted access to the data necessary to performtheir tasks, e.g. billing and switching. For any other purposes, access to meter data should only bepossible after explicit consent by the customer

Customers should not be overwhelmed with information. A balance has to be found betweeninformation which has to be provided to all customers and information only provided on request oraccessible through e.g. the customer online account

Retail markets are quite different from country to country in terms of e.g. regulation, marketprocesses, and IT systems. We therefore believe that common standards for data content, dataformats and data exchange should primarily be set at national level

In most EU Member States, when customers have questions or complaints regarding their meterdata, they should primarily contact their supplier. The supplier will then be in touch with themetering operator – the DSO in most member states – behind the scenes to check and correct anypotential inaccuracy

DSOs (or other parties responsible for data collection) should be given proper incentives to ensurehigh quality of data. This is all the more pressing in the future since with smart metering, the amountof data will increase dramatically.

Next to privacy & security, transparency, accuracy, accessibility and non-discrimination, we believecost-effectiveness of data management should be another guiding principle for regulators.

WG Commercial Processes & Customer RelationshipRoel KALJEE

WG Distribution Customers & Grid ManagementRobert DENDA

Contact:

Sébastien DOLIGE, Advisor, Retail Customers Unit –[email protected]

Claire COUET, Advisor DSO’s unit –[email protected]

CEER Draft Advice on Data Management for Better RetailMarket Functioning: electricity & gas

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Public consultation questions

Privacy and security

1. Customer meter data should be protected by the application of appropriate securitymeasures that prevent unauthorised access but which allow access to parties authorised toreceive it, such as DSOs/metering operators. This customer meter data protection should beensured by (tick one box):

X Legislation/regulationContract between customer and relevant partiesCode of conductOther (please specify in the comment box below)No opinion

Comment box (3500 characters maximum)

Most customers will only be comfortable sharing their data if they are confident that these arestored securely in a way that safeguards their privacy. We therefore agree with CEER that customermeter data protection should be ensured by legislation/regulation. We would like to point out thaton top of DSOs and metering operators, also suppliers need unrestricted access to the datanecessary to perform their tasks, e.g. billing and switching. For any other purposes, access to meterdata by both suppliers and third parties (e.g. aggregators, ESCOs) should only be possible afterexplicit consent by the customer.

2. Customers retain the right to control the use of their customer meter data. Specificparties (e.g. DSOs/metering operators and suppliers) should be authorised to access thatdata. However, the authorisation to access that data and the terms on which that data can beused should be ensured by (tick one box):

Legislation/regulationContract between customer and relevant parties

X Other (please specify in the comment box below)No opinion

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National legislation/regulation shall provide access for DSOs to meter data needed to fulfill regulatoryduties and/or duties authorized by law without explicit consumer consent, e.g. data needed for balancingsettlement, monitoring the state of the network and system operation, etc.

Suppliers should also be granted unrestricted access to their customers meter data as these are necessaryto perform the tasks associated with the delivery of energy.

For any other purposes, access to meter data by all market parties (e.g. suppliers, aggregators, ESCOs)should only be possible after explicit consent by the customer and preferably through a contract.

In some Member States, third parties (and authorised parties when they go beyond their legal duties) alsohave to respect a code of conduct on privacy to e.g. guarantee that they will not use data for purposeswhich have not been explicitly agreed with customers.

General comments on the guiding principle: Privacy and Security (maximum 3500 characters)

Transparency

3. The relevant body (NRA/DSO/metering operator/TSO/other) shall ensure that, as a minimum,the customer has knowledge of general information on meter data management: (a) thecustomer’s rights with regards to data management; (b) what type of customer meter dataexists and what it is used for; (c) how customer meter data is stored and for how long; and (d)how both the customer and third parties get access to that data.

X AgreeDisagreeNo opinion

4. The customer meter data which comes out of the data management processes should betransparent to the customer. Transparency should be ensured by the relevant body(NRA/DSO/metering operator/TSO/other) through (tick one or several boxes):

X Providing clarity on how information can be accessedSetting a maximum time period during which a customer has towait to receive that information after having moved into newpremisesOther (please specify in the comment box below)No opinion

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We agree with CEER that transparency is fundamental and that customers should be able to get generalinformation on meter data management: what type of data exists, how long data are stored, etc., However,we think it is important not to overwhelm customers with information and keep in mind that more does notmean better. A balance has to be found between information which has to be provided to all customers andinformation only provided on request or accessible through e.g. the customer online account.

5. The customer meter data should be transparent to a third party, to whom a customer hasprovided such consent. By third party we mean a party that needs customer consent to managedata, hence not a party already authorised by law and/or carrying out regulatory tasks forsystem operation. Transparency should be ensured by the relevant body (NRA/DSO/meteringoperator/TSO/other) through (tick one or several boxes):

Providing the third party clarity on how information can beaccessedSetting a maximum time period during a third party has access tothe informatio



It is important that authorized third parties know how - and for how long – customer meter data can beaccessed. However we would urge CEER to further clarify which data is concerned. CEER draft advice seemsto suggest that this includes information about the contract between a customer and its supplier (“user andcontract data”). We would like to stress that some data may be confidential and should not be accessible toany third party.

6. The relevant bodies in each country should take active steps to build customerconfidence in sharing customer meter data in order to achieve energy efficiency benefits andother potential benefits.

(a) That body or bodies should be (tick one or several boxes):

X NRAX DSO/metering operatorX Other (please specify in the comment box below)

No opinion

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Energy usage data, in particular the anticipated wealth of data from new technology (smart metering, ICT,in-home units) will be a key means of creating new value for customers - tailored products and services(energy efficiency, demand response) but also an efficient and secure grid management.

Data privacy and security measures may vary across member states, but all customers will only becomfortable with access to - and use of - their data if they are confident that these are secured and thattheir privacy is safeguarded.

Market parties, be they suppliers, ESCOs, or third party service providers, have a natural interest in buildingcustomer confidence in the energy market and interest in new services. The regulatory framework shouldthus be clear and solid, whilst remaining flexible enough to allow them to innovate.

Other actors – governments, NRAs, network system operators and consumer groups also have a role to playto build customer confidence:

- EU and national authorities by setting the right regulatory framework and effectively transposingexisting legislation;

- DSOs – as regulated neutral entities in charge of collecting metering data in most EU member states– by ensuring effective and reliable data protection, data security and data management;

- Member states, NRAs, businesses and consumer associations by informing and educatingconsumers to improve their understanding and engagement in retail energy markets.

Finally we would like to point out that – unlike what the question seems to suggest – customers willingnessto take up energy efficiency measures is not only related to their level of confidence in the market. A lack offinancial resources or a lack of monetary gains (e.g. in Finland) can also be potential reasons.

(b) Active steps might include (tick one or several boxes):

X Information campaignUse of energy advisor


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Information campaigns (financed by public bodies) would indeed be very welcome to improve customers’awareness of possible energy savings measures and more generally their understanding of retail energymarkets. Other actions are of course possible and market parties in particular should be free to innovate tofoster customer trust in the energy market and interest in new services.

We are not sure to understand what CEER means with “use of energy advisor”. Whilst proposing energyadvice services should obviously be an option, we are certainly not in favour of creating a new body tospecifically deal with this.

7. There should be a common standard for data content, data formats and data exchange in theretail market.


8. The common standards for data content, data formats and data exchange in the retail marketshould be set on (tick one box):

European levelRegional level (across national borders)

X National levelSub-national levelNo opinion

9. The data that should be standardised should as a minimum/as a starting point be (tick one orseveral boxes):

(a)

X Point of delivery identificationdata

X User and contract data Consumption data

X Other (please specify in the comment boxbelow)No opinion

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All data needed for the implementation of market processes (such as supplier switching) have to beexchanged in standardised data formats in order to enable a non-discriminatory access for all competitors.

Since retail markets are quite different from a country to another in terms of e.g. regulation, marketprocesses, IT systems, level of competition, etc., we believe that common standards for data content, dataformats and data exchange should primarily be set at national level. Whilst EURELECTRIC supports aEuropean approach to energy retail markets, priority should be put on further improving national marketsfirst.

(b) NRA’s should ensure that appropriate arrangements are in place for thedevelopment of common standards for data content, data format and data exchangeand monitoring of compliance.


10. The general information on meter data management (as specified in draft recommendation3) should as a minimum be published on the website of the relevant body (NRA/DSO/meteringoperator/TSO/other), and must be presented in a customer- friendly way.


General comments on the guiding principle: Transparency (maximum 3500 characters):

We think it would be preferable for consumers to get this information through a dedicated (energy)consumer information website - run by the government, NRA or a government led consumer body

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Accuracy

11. Relevant bodies (NRA/DSO/metering operator/TSO/other) should have in placestandardised measures available to the customer to enable any remaining inaccuracy concerningdata management to be addressed. Those measures should include a timetable set out in (tickone box):

Legislation/regulationContractCode of conduct

X Other (please specify in the comment boxbelow)No need for standardisation processes forremaining inaccuracyNo opinion


In most EU Member States, when customers have questions or complaints regarding their meter data,they should primarily contact their supplier. The supplier will then be in touch with the meteringoperator – the DSO in most member states – behind the scenes to check and correct any potentialinaccuracy. There should be standardised service agreements in place between retailers and meteringoperators to make sure the process is as swift as possible.

General comments on the guiding principle: Accuracy (3500 characters maximum):

DSOs (or other parties responsible for data collection and distribution) should be given proper incentives tofollow and improve the quality of data. This is all the more pressing in the future since with smart metering,the amount of consumption data increases dramatically.

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Accessibility

12. The customer (or party acting on behalf of the customer) should have easy access to his/hercustomer meter data. This information should be made available in a way that is standardisedand though a channel of the customer’s choosing (web, paper, etc.). The common standards forprovision to customer of meter data information should be provided at a (tick one box):

European levelRegional level (across national borders)

X National levelSub-national levelNo need to standardise customermeter dataNo opinion

13. The arrangements for accessing customer meter data should be proportionate. Subject tocustomer choice, access should only be provided to a party where it requires that particularcustomer meter data (not just any data) and where they can use it to deliver wider benefits,including to customers.


General comments on the guiding principle: Accessibility (3500 characters maximum):

First of all, we would like to stress that standardizing customer meter data should not be mixed up withstandardising the way data are provided to customers as CEER seems to suggest.

In addition we would – once again - urge CEER to further clarify which data are concerned. CEER draft adviceseems to suggest that this could include information about the contract between a customer and its supplier(“user and contract data”). We would like to stress that some data may be confidential and should not beaccessible to any third party.

Finally, we would welcome further explanation as to what CEER understands with “where they can use it todeliver wider benefits, including to customers.”

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Non-discrimination

14. To support an effective and competitive market, the data management model should notgive undue preference to one stakeholder over another. Specifically in relation to smartmeters, there should be non-discriminatory access to information if and where smart metersare installed.


General comments on the guiding principle: Non-discrimination (3500 characters maximum):

We agree with CEER but believe it is important to keep in mind that specific parties such as DSOs or

suppliers need to have access the data necessary to carry out their tasks. Access to meter data forother purposes should indeed be provided on non-discriminatory basis, depending on the customerconsent.

Existing provisions in EU legislation aimed at achieving network operators’ independence – and themonitoring of their implementation by independent national regulators – provide a soundbasis for the future. These provisions shall also apply in the context of meter data management.

Finally and as a general remark, we want to underline that all the principles put forward by CEER inthis consultation paper should not apply to additional data coming from smart devices provided tocustomers by market parties behind the meter.

Further questions for public consultation

In addition to individual questions on the 14 draft recommendations, we alsoask stakeholders to provide their opinion on the questions below:

1. Do you agree with the list of relevant stakeholders we have identified in Section5.1 of the paper? If not, which other stakeholders do you think should beincluded and why?

The list seems to identify the relevant stakeholders.

2. Do you agree that we have correctly identified the right categories of data –defined as ‘customer meter data’ – in Section 4.2 of the paper, as being relevantto retail market functioning and thus within the scope of our draft advice?

Yes

3. In relation to the 5 proposed guidingprinciples:

a) Do you agree with the proposed guiding principles in Chapter 8 of the paper?Should any be added or

removed?

We believe that the issue of costs has been a bit overlooked. Cost-effectiveness of datamanagement could have been another guiding principle.

b) Do you see any conflicting principles, which can eventually create problems inthe energy market?

4. Do you agree that standardisation of data content, data formats and dataexchange, set out in Section 4.3 of the paper, is important? We welcome anycomments.

Standardisation is a good thing as long as it does not create unreasonable obstacles toinnovation and system costs to the detriment of customers.

EURELECTRIC pursues in all its activities the application ofthe following sustainable development values:

Economic Development

Growth, added-value, efficiency

Environmental Leadership

Commitment, innovation, pro-activeness

Social Responsibility

Transparency, ethics, accountability

Union of the Electricity Industry - EURELECTRIC aisblBoulevard de l’Impératrice, 66 - bte 2B - 1000 Brussels • BelgiumTel: + 32 2 515 10 00 • Fax: + 32 2 515 10 10VAT: BE 0462 679 112 • www.eurelectric.org

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