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CER National Smart Metering Programme The Presentation of Energy Usage Information (Smart Billing, Mandated In Home Display and Customer Web Interface) DOCUMENT TYPE: Consultation Paper REFERENCE: CER/13/164 6 th September 2013 DATE

  1. The Presentation of Energy Usage Information (SB, MIHD and CWI) influence the views in other areas. WorkStream Scope in Context of the National Smart Metering Programme It is important to distinguish between information that needs to be defined in the regulatory framework and information that will be delivered through competitive market offerings and innovation. CER does not want to set inappropriate constraints on how information might be presented in the future, but would want to ensure that an appropriate set of information is regulated to deliver Customer benefits through the definition of minimum information to be delivered on mandated channels. By regulating this minimum information and not prescribing exactly how the information is provided by technology, it is intended that the risk of obsolescence is minimised. The aim is not to restrict the ability of parties to innovate through expanded services or devices (e.g. more interactive web-sites, apps, non-mandated Customer devices). 6

  2. The Presentation of Energy Usage Information (SB, MIHD and CWI) Table of Contents Contents Executive Summary ............................................................................................... 3 Table of Contents ................................................................................................... 7 1 Introduction...................................................................................................... 9 1.1 The Commission for Energy Regulation ................................................... 9 1.2 Purpose of this paper ................................................................................ 9 1.3 Background Information ............................................................................ 9 1.4 Structure of this Paper ............................................................................ 10 1.5 Responding to this Paper ........................................................................ 11 2 Consumer Information Channels ................................................................... 12 2.1 Introduction and Drivers .......................................................................... 12 2.2 Definitions ............................................................................................... 12 2.3 Purpose .................................................................................................. 13 2.4 Core Information ..................................................................................... 14 2.5 Consumer Interaction.............................................................................. 16 2.6 Information Timescales ........................................................................... 17 3 Basis for Requirements ................................................................................. 18 3.1 Introduction ............................................................................................. 18 3.2 Policy drivers .......................................................................................... 18 3.3 Experience from Smart Meter Trials and Programmes ........................... 19 3.4 Requirements Introductions and Context ................................................ 20 3.5 Evaluation Criteria .................................................................................. 24 4 Requirements Definition and Assessment ..................................................... 27 4.1 Introduction ............................................................................................. 27 4.2 Requirements Overview .......................................................................... 27 4.3 Smart Billing Requirements .................................................................... 33 4.4 Mandated In-Home Display (MIHD) Requirements ................................. 39 4.5 Customer Web Interface Requirements .................................................. 48 7

  3. The Presentation of Energy Usage Information (SB, MIHD and CWI) 4.6 Requirements the CER are Minded to Review ....................................... 54 4.7 Requirements the CER are Minded to Exclude ...................................... 57 5 Other Policy Considerations .......................................................................... 59 5.1 Introduction ............................................................................................. 59 5.2 Timescale for MIHD support ................................................................... 59 5.3 Provision of Energy Consumption Data Where Smart Meters Are Not Installed .................................................................................................. 60 5.4 Frequency of Billing ................................................................................ 60 6 Data Availability and Protection ..................................................................... 62 6.1 Introduction ............................................................................................. 62 6.2 Data Protection Approach ....................................................................... 62 Appendix A – Consolidated List of Questions ...................................................... 64 Appendix B – Glossary of Terms ......................................................................... 69 Appendix C - References ..................................................................................... 71 Appendix D – Evidence to Evaluate Only Showing Consumption Information on the MIHD ....................................................................................................... 72 Appendix E – Example Customer Web Interfaces ............................................... 76 Appendix F – The Electricity and Gas Supplier Handbook .................................. 78 Appendix G – NSMP Background ........................................................................ 79 Appendix H – Consultation Development Process............................................... 87 Appendix I – Detail of Policy Drivers .................................................................... 88 Appendix J – Experience from SM Trials and Programmes ................................. 98 Appendix K – Background to Evaluation Criteria ............................................... 115 Appendix L – Time of Use examples ................................................................. 118 8

  4. The Presentation of Energy Usage Information (SB, MIHD and CWI) 1 Introduction 1.1 The Commission for Energy Regulation The Commission for Energy Regulation (‘the CER’) is the independent body responsible for overseeing the regulation of Ireland's electricity and gas sectors. The CER was initially established and granted regulatory powers over the electricity market under the Electricity Regulation Act 1999 . The enactment of the Gas (Interim) (Regulation) Act 2002 expanded the CER’s jurisdiction to include regulation of the natural gas market. The Energy (Miscellaneous Provisions) Act 2006 granted the CER powers to regulate electrical contractors with respect to safety, to regulate the natural gas undertakings involved in the transmission, distribution, storage, supply and shipping of gas and to regulate natural gas installers with respect to safety. The Electricity Regulation Amendment (SEM) Act 2007 outlined t he CER’s functions in relation to the Single Electricity Market (SEM) for the island of Ireland. This market is regulated by the CER and the Northern Ireland Authority for Utility Regulation (NIAUR). The CER is working to ensure that Consumers benefit from regulation and the introduction of competition in the energy sector. 1.2 Purpose of this paper The purpose of this paper is to seek the view of the public and the CER’s stakeholders with regard to the presentation of energy information through Smart Billing, Mandated In Home Displays and Customer Web Interface(s). In order to make an informed and impartial decision on this topic, the CER wishes to obtain comments from members of the public, the energy industry, Consumers and all interested parties. During the consultation period, CER will also be engaging with Consumer organisations and will run Consumer focus groups. The input from these engagements will be considered alongside the responses to this consultation paper. The CER commits to considering all views equally and affording each respondent the opportunity to clarify any issue raised in this paper. 1.3 Background Information This document builds on a significant body of information and analysis conducted by CER as part of the National Smart Metering Programme (NSMP) and forms a key part of the work that CER is undertaking in Phase 2 of the programme. This follows a Phase 1 whi ch was completed in July 2012 with the publication of the paper “Decision on the National Rollout of Electricity and Gas Smart Metering”. The strategic objectives of the NSMP are as follows: 1. Encourage Energy Efficiency 2. Facilitate Peak Load Management (electricity only 3. Support Renewable and Micro Generation (electricity only) 4. Enhance Competition and Improve Consumer Experience 5. Improve Network Services This consultation paper complements three other consultation papers which have been 9

  5. The Presentation of Energy Usage Information (SB, MIHD and CWI) published as part of Phase 2 of the Programme. These cover the following subjects: Time-of-Use (TOU) Tariffs, the Steady State Model (SSM) and Pay as You Go (PAYG). These consultations are available on the CER website here. Given the volume of information available, a summary of the context for this consultation is included in Appendix G – NSMP Background. CER have developed this consultation document in discussion with Industry. This process is explained in more detail in Appendix H – Consultation Development Process. The paper has built on learning and understanding developed through the Irish Smart Meter Customer Behaviour Trials and the associated focus groups that were conducted. Further focus groups considering some of the issues discussed in this paper will be carried out during the consultation period with findings contributing to the response. 1.4 Structure of this Paper This paper is structured as follows:  Section 2 describes and defines the different channels for presentation of information and describes the strategic drivers for the most appropriate channels to use for different information.  Section 3 identifies the basis for requirements defined in this consultation paper, including both the policy drivers (specifically referencing the relevant sections of EU Policy and the July 2012 Decision paper ), and the evidence base derived from international experience and Irish trials to support the derivation and assessment of requirements. This section also describes the evaluation criteria that will be used to evaluate and conclude on a final set of CSI requirements in the December Decision papers  Section 4 is the key section defining the requirements for presentation in different information channels, relating these to policy & strategic drivers, and proposing their inclusion or not, depending on rationale. This section highlights the requirements that are dependent on policy from other consultations (i.e. TOU & SSM) and describes the impact of different conclusions from those consultations.  Section 5 describes additional policy relating to CSI to be consulted on by CER, including the timescale for ESB Networks support of the MIHD and subsequent support arrangements following that period.  Section 6 describes some of the data protection considerations and issues arising Wherever relevant, a list of direct questions related to a topic is included within a particular section. To aid regulatory transparency and assist in the delivery of an efficient consultative and decision making process, the CER asks respondents to address these questions directly in their responses. 10

  6. The Presentation of Energy Usage Information (SB, MIHD and CWI) Appendix A – Consolidated List of Questions contains a summary list of all of the questions, which the CER has asked in this Consultation Paper. This is designed to be a useful aid to respondents when preparing their submissions and can serve as a “short - cut” for respondents who may not have the resources to devote to preparing a full submission. Appendix A is also available separately in Word format. It is recommended using this document as a template for your response if you are using the “short - cut” option. Responses that have availed of the short consultation option will be evaluated equally by the CER, when making its decision. Other Appendices provide reference material used through the document. 1.5 Responding to this Paper CER invites interested parties to comment on the questions raised in this consultation paper by close of business on Friday 11th October 2013. As CER will publish responses in full on the CER website, respondents should include any confidential information in a separate Annex, stating the rationale for not publishing this part of their comments. Please forward submissions on this paper, preferably in electronic format, to: Smart Metering Programme Office Commission for Energy Regulation, The Exchange Building, Belgard Square North, Tallaght, Dublin 24. E-mail: smartmetering@cer.ie 11

  7. The Presentation of Energy Usage Information (SB, MIHD and CWI) 2 Consumer Information Channels 2.1 Introduction and Drivers Information is planned to be provided to Customers through three primary information channels in the Smart Meter roll-out: Figure 1 - Information channels These three channels need to work together so that in unison they provide the different types of information to Consumers. The MIHD should be focused on easy and near real-time access to information, the Smart Bill (which is an enhancement of the existing bill with additional information) on information explaining energy usage linked to the bill and the associated costs, while the Customer Web Interface should allow Consumers access to their historical information, both for their own purposes and to share with third parties (for example, to assist in finding the best tariff for them in the market). The presentation of cost on the MIHD has been included in the Figure above whilst recognising that the way cost information is provided to the MIHD will be dependent on conclusions from the Time-of-Use (TOU) and Steady State Model (SSM) consultations already underway, as demonstrated in this consultation paper later. 2.2 Definitions 2.2.1 In-Home Display Definition An In-Home Display (IHD) is defined as a device which is located in the Consumer ’s home; it could be mobile or fixed. It displays information related to the consumption of energy, and cost where practical and useful. Its primary purpose is to give the Consumer easy access to this information in such a way as to enable them to understand their energy consumption in order to modify their behaviour. This document refers to a Mandated In-Home Display (MIHD) as the IHD to be provided 12

  8. The Presentation of Energy Usage Information (SB, MIHD and CWI) and supported by ESB Networks as part of the regulated roll-out. Smart Billing Definition 2.2.2 Smart Billing is defined as the presentation of accompanying information detailing energy usage with a Customer's energy bill. This information details usage associated with different times and tariffs providing easy to understand comparative data. This aims to show the impact of changes in Consumer behaviour and encourage energy efficiency. 2.2.3 Customer Web Interface Definition The Customer Web Interface is defined as a web-based means of providing information to Consumers and third parties should they wish to access it. 2.2.3.1 Background to Customer Web Interface In the CER July 2012 Decision paper, the CER stated that a data portal will be provided through which suppliers can access data for their customers. Recent investigations have since confirmed that the existing market systems do have the capability to manage the new volumes of granular meter data, and provide it at the required daily frequency to Suppliers for Customer billing and Customer service/management purposes. The original intent of a data portal was not driven by a business need as such; it was believed to be a technical necessity and a viable approach at the time of the assessment. As such its primary purpose was to transfer meter system data to Suppliers. A secondary feature, if it were to be included, was thought to be facilitating Customer access (piggy backing on the primary requirement) hence the reference to ‘ Customer portal’ in the decision paper. It has been confirmed, that the data po rtal / Customer web portal (as originally provisioned for) is no longer a programme requirement of the technical design solution moving forward. In light of this change to the technical design, the requirements are now focused on the access and provision of Consumer energy usage information over the web. Therefore reference to a Customer Web Portal is no longer appropriate and has been replaced by reference to the Customer Web Interface throughout the rest of this document . 2.3 Purpose Each of the three channels has a core purpose and therefore a focus for the information it provides to the Consumer.  The Mandated In-Home Display should focus on: Providing near ‘real - time’ information on consumption, and cost where - practical and useful (depending on conclusions from TOU and SSM consultations); - acting as a device to assist Consumers in making the step to greater 13

  9. The Presentation of Energy Usage Information (SB, MIHD and CWI) engagement and understanding; - simple and easy to use information - Information that relates to periods shorter than the billing window (although the opportunity has been taken to align gas and electricity in historical data presentation).  The Smart Bill should focus on: - providing a periodic review of consumption and cost; - acting as a checkpoint for the Consumer at consistent intervals; - information that links directly to their bill.  The Customer Web Interface should focus on: - providing access to historical interval data on import and export consumption; - harmonised presentation of data in a simple format. 2.4 Core Information There is a core of information to be considered for provision across the three channels which needs to align to their respective purposes. This information is based on three main pillars: consumption, price (tied in with the tariff), and cost. Each of these three pillars provide valuable information to a Consumer with: consumption showing the actual energy consumed; price associated with a certain tariff period showing the relative expense of that consumption; and cost showing what the Consumer is actually paying for their consumption. These three pillars can also be used in conjunction with each other so that Consumers can understand:  how much they have used at different prices/tariff periods;  how their cost of energy is driven by their consumption; and,  how cost is related to different prices/tariff periods. The information presented can also represent different timescales as follows:  Real-time (or near real-time) – continually updated to show the current status;  Periodic – showing a set period of time on a regular basis;  Cumulative – showing ‘to date’ information whether on a daily, weekly, monthly or yearly basis;  Historic – showing previous periods (day, week, month), including the equivalent period for the previous year. 14

  10. The Presentation of Energy Usage Information (SB, MIHD and CWI) Figure 2 - Core information presented to consumers 2.4.1 Supplementary Information In addition to this core information about a Consumer ’s own energy consumption, price and cost, there is also further supplementary information that may assist in achieving the objectives of facilitating behaviour change and realising energy efficiency benefits. These are as follows:  Benchmarking information – which allows Consumers to see how their own energy consumption compares with other energy users. This potential requirement has been considered and proposed for future review, as described in section 4.6.1;  Hints and tips – to give Consumers advice on how to change their behaviour and realise energy efficiency benefits. This requirement is proposed to be included in smart billing as described in section 4.3;  General information – to provide context and background information as well as contact information for helpful organisations. This requirement is proposed to be included in smart billing as described in section 4.3;  Balance information – to show Pay As you Go Customers information related to their PAYG balance. This requirement is proposed to be excluded as described in 4.7.1. 15

  11. The Presentation of Energy Usage Information (SB, MIHD and CWI) 2.5 Consumer Interaction The core purpose associated with each information channel is intrinsically linked to an understanding of the different ways the channels are expected to be used and interacted with by the Consumer.  The MIHD is expected to be used for quick reference by Consumers to check consumption, requiring minimal effort. This may be used regularly, for example on a daily basis, and therefore should be easy and convenient.  The Smart Bill will be a periodic document requiring some effort from Consumers to analyse. Howev er, it is still a “push” of information to the Consumer who is essentially still reactive in receiving the information.  The Customer Web Interface is expected to be a resource that is available at all times to Consumers but which requires proactive effort from them to access and use. From those Consumers that choose to use it, it is also likely to require a greater investment of time to read, understand and analyse the available information. Figure 3 - Consumer interaction with information channels In order to achieve objectives, it will be important to encourage Consumer engagement and interaction with this information so that Consumers progress from reactive receipt of information to becoming more proactively engaged. It will also be possible for other non-mandated information channels such as smart applications to supplement the provision of information to the Consumer in different ways. This consultation is not intended to constrain other innovative methods of presenting information to Consumers over and above the minimum requirements set out. 16

  12. The Presentation of Energy Usage Information (SB, MIHD and CWI) 2.6 Information Timescales Based on the characteristics of the different information channels and their identified purposes in achieving Consumer information objectives, there is a clear and discrete split of primary timescales associated with each information channel. The Mandated In-Home Display should focus primarily on presentation of near ‘ real-time ’ information and information relating to periods shorter than a billing window, the Smart Bill on the period associated with the bill, and the Customer Web Interface on historic information. However, it may also be desirable to extend each channel to a secondary timescale that supplements the primary in improving Consumer awareness and understanding. Figure 4 - Interaction timescales  For the Mandated In-Home Display it may be helpful for Consumers to also see a cumulative view of their consumption for the day, week or month to date, as well as past periods shorter than the billing window. This can help give a context for their near real-time consumption as well as enable them to set and keep within their own targets for consumption over different periods.  The Smart Bill may benefit from showing past periods as well as just the latest billing period. This would help to provide a comparison for the last billing period, either by comparing against the previous period or against the same period from the previous year.  The Customer Web Interface may also benefit from showing a cumulative view of consumption, in addition to its focus on granular historical information. This could be in response to Customer requests, building from granular data. It is important that, between them, the information channels cover all four primary timescales (Real-time, Periodic, Historic and Cumulative), and in particular that cumulative information is covered by either the MIHD or the CWI (it is concluded later in this paper that CER are minded to display cumulative information on the MIHD). 17

  13. The Presentation of Energy Usage Information (SB, MIHD and CWI) 3 Basis for Requirements 3.1 Introduction The process of developing requirements for Customer information has been based on policy drivers, from both Europe and Ireland, and experience from Smart Meter trials and Programmes from Ireland and internationally. CER is a statutory body with powers, duties and function defined in law. It is the duty of CER to carry out its functions and exercise its powers such that the interests of final Customers are protected. While seeking to protect the interests of final Customers and avoid unfair discrimination between industry participants are primary concerns, the CER will seek to promote and have regard to a number of other factors. These include promoting competition, promoting efficiency among industry participants, promoting security of supply, and encouraging the efficient use and production of electricity. This is the legal framework that CER will work within in considering the case for, and formulation of, additional regulatory obligations pertaining to the presentation of Customer information. CER is proceeding on the basis that regulatory obligations to present Customer information have direct relevance to protecting the interests of final Customers, and to a number of the factors that CER is required to have regard to:  Customer information is likely to promote more energy efficient behaviour through making Customers more aware of how much energy they are using;  Giving Customers access to information on their usage should make them better able to make choices regarding which tariff and supplier would be best suited to them, therefore promoting competition;  Presenting information on when Customers are using energy should encourage them to shift usage away from peak times. This can help to reduce system costs over time, and promote the efficient utilisation of electricity supply infrastructure. 3.2 Policy drivers The requirements have been developed based primarily on policy drivers for Customer Information requirements. Existing Irish legislation grants the CER powers to place requirements on energy undertakings in relation to informative billing and energy efficiency tariffing. The following policy was considered in the development of the requirements: 3.2.1 EU Legislation:  3 rd Package: The provisions regarding the installation of intelligent metering systems, with the aim of better informing Consumers of their consumption and helping to increase awareness of energy consumption. 18

  14. The Presentation of Energy Usage Information (SB, MIHD and CWI)  The Energy Efficiency Directive 2012/27/EU 1 : This Directive establishes a common framework of measures for the promotion of energy efficiency within the Union in order to ensure the achievement of the Union’s 2020 20% headline target for energy efficiency and to pave the way for further energy efficiency improvements beyond that date. While the above EU legislation established a framework for data presentation and promotion of energy efficiency, CER are also mindful of the following EU directives and Irish laws that provide protection to consumer’s data .  EU Data Protection Directive 95/46/EC  Data Protection Act 1998 and Data Protection (Amendment) Act 2003  EU General Data Protection Regulation The CER is working closely with the DCENR (The Department of Communications, Energy and Natural Resources) on the transposition of the Energy Efficiency Directive and to ensure there is a clear and robust legal basis for mandating Customer Information requirements. 3.2.2 2012 Electricity and natural Gas Supplier Handbook This provides a Code of Practice on Customer Billing. Smart Billing requirements are incremental to the obligations on Energy Suppliers set out in the code of practice. Provisions of the code of practice potentially relevant to smart billing are identified in Appendix E. 3.2.3 CER July 2012 Decision Paper Sets out the high level policy decisions and framework set out by the CER in Phase 1 of this Programme. These policy drivers are set out in more detail in Appendix I – Detail of Policy Drivers. 3.3 Experience from Smart Meter Trials and Programmes Further to these policy drivers, experience from Smart Meter trials and Programmes, both in Ireland and internationally, has also been considered. In particular, experience has been considered from:  the Irish Customer Behaviour Trials carried out to specifically inform this Programme;  the GB Smart Metering Programme definitions of its MIHD; and,  a cross-range of international trials and Programmes. 1 http://eur-lex.europa.eu/ 19

  15. The Presentation of Energy Usage Information (SB, MIHD and CWI) This experience acts as a support to the assessment and derivation of requirements, in particular where no policy driver exists from the European Energy Efficiency Directive or previous CER decisions. Note that GB is the only other jurisdiction to mandate the IHD as part of a smart meter roll-out with a robust set of requirements which have been notified to the EU, therefore it is a useful parallel market to consider in the development of the requirements for the Irish market whilst recognising that the market model for delivery of smart metering equipment is not necessarily the same. Key findings and conclusions from these trials and Programmes are set out below. More detail and background can be found in Appendix J – Experience from SM Trials and Programmes. 3.4 Requirements Introductions and Context 3.4.1 Smart Billing The provision of billing information to the Consumer is the responsibility of the Supplier as part of the supply contract they have with their Customers. Therefore the requirements in this section will ultimately be delivered by Energy Suppliers. The policy drivers for these requirements come from the CER July 2012 Decision paper (cer12092) 2 in the first instance. Incremental to these are requirements being driven by the Energy Efficiency Directive 2012/27/EU 3 , which are yet to be transposed into Irish legislation. The Energy Efficiency Directive introduces a distinction between bills (which carry the obligation to settle the due amount) and billing information (which do not, and are for information purposes only). Smart Billing presents accompanying information detailing energy usage with the Customer ’s energy bill. This is a periodic assessment of energy usage which requires medium effort for Consumers to engage with in reacting to the “push” of being sent a Smart Bill. Suppliers will not be obliged to follow a specific template for Smart Billing in line with the general principle that requirements will focus on setting out what information should be shown rather that how it should be shown, on the basis that the information is provided in a clear and unambiguous manner as determined by the CER. In addition, how electronic information might be presented is not prescribed as long as it is provided electronically in a consistent approach to electronic billing when the Customer opts-in. 2 http://www.cer.ie/ 3 http://eur-lex.europa.eu/ 20

  16. The Presentation of Energy Usage Information (SB, MIHD and CWI) 3.4.2 Mandated In Home Display (MIHD) The Electricity Distribution Service Operator ESBN is responsible for the procurement and provision of the MIHD to all Consumers as stated in the CER July 2012 Decision paper cer12028 4 (see policy ref IJDP1 of the CER July 2012 Decision Paper). The CER July 2012 Decision paper also states the policy which has driven requirements for the MIHD. It states that there are benefits to be gained by Consumers from having an in-home display in their homes providing near real-time as well as historical information on their energy usage and costs (see policy ref IJDP1, IJDP2, IJDP3 and IJDP5 of the CER July 2012 Decision paper). It is also a requirement of the Energy Efficiency Directive 2012/27/EU 5 that the metering systems shall provide the Consumer with information on their time of use consumption (see policy ref EED01 of the Energy Efficiency Directive). CER has a minded to position that as a minimum this information should be presented to the Consumer through the MIHD. It is recognised that discussion on how this requirement will be met will need to be addressed post the support of the MIHD. Respondents, feedback and suggestions in this regard are requested (Question 10a). The CER has analysed the experience from the Irish trials and internationally, as well as the specification of information to be displayed on the GB IHD in considering what information should be presented on the MIHD (see Appendix J – Experience from SM Trials and Programmes). Irish trials suggested that consumers prefer seeing cost information rather than consumption on the MIHD, as it was easier to understand and could be related back to the bill. Cumulative views of cost (day/week/month) were also appreciated. However, it is dependent on price and tariff information being available at the MIHD in order to show cost, as cost is a product of the active price and consumption. Options as to how price and tariff might be made available at the MIHD and therefore how cost might be displayed are described in further detail in section 4.4.4. However, international experience suggests that consumption information can still be effective in achieving overall energy usage reductions in the absence of cost information (though this may not be true with reference to peak reductions) and therefore a MIHD without cost information may still be an effective device. This is included as a default option in the event that relevant cost information cannot be displayed or can only be displayed at a disproportionate cost. There is further collation of experience to support this position in Appendix D – Evidence to Evaluate Only Showing Consumption Information on the MIHD. Section 4.4.5 asks for respondents’ views on how cost, price and tariff information might be presented to inform CER analysis. International experience suggests multiple types of information on a device having a greater impact than just one type of information. The Empower International Pilot Study states that the three most common feedback information types were up-to-date consumption, historical comparison, and up-to-date cost (see section Appendix J – 4 http://www.cer.ie 5 http://eur-lex.europa.eu/ 21

  17. The Presentation of Energy Usage Information (SB, MIHD and CWI) Experience from SM Trials and Programmes), with a combination of historical and cumulative information being more effective than either on their own. This combination of information is planned for inclusion in the GB IHD, where both the cumulative and historical information is for daily, weekly and monthly periods, and is shown for both consumption and cost. The CER July 2012 Decision paper states that both cost and consumption information should be presented on the MIHD (see policy ref IJDP3 of the CER July 2012 Decision paper as shown in Appendix I – Detail of Policy Drivers. Each of the information types above can be displayed as both cost and consumption information. The following diagram illustrates the preferred set of information to be presented on the MIHD, starting from the regulated provision of instantaneous demand in the top left corner and showing what further information is proposed to be displayed. Electricity Only Electricity (Real-Time) and Gas (Half Hourly) Real-Time Cumulative Cost and Usage Instantaneous In Day In Week In Month Demand kW Demand kWh Demand kWh Demand kWh [ € ]* per Hr [ € ]* [ € ]* [ € ]* Ambient Historical Past Comparisons Day Totals Week Totals Month Totals Demand kW kWh -1 € kWh -1 € kWh -1 € or kWh -2 € kWh -2 € kWh -2 € kWh -3 € kWh -3 € kWh -3 € Prevailing Tariff kWh -4 € kWh -4 € kWh -4 € kWh -5 € kWh -5 € kWh -5 € kWh -6 € kWh -6 € kWh -7 € kWh -7 € kWh -8 € kWh -8 € kWh -9 € kWh -10 € Note* Presentation of cost on the MIHD is kWh -11 € dependent on receiving price/tariff and kWh -12 € consumption data kWh -13 € Figure 5 - MIHD Presentation of Information This diagram shows that as well as an instantaneous view of active demand and an ambient view of either the prevailing tariff (to show which tariff band in a TOU offering the customer is consuming energy on) or consumption (depending on availability of price data, as discussed above); the MIHD would also show cumulative and past period information. Cumulative information includes the day, week and month to date, while the past period comparisons includes information for discrete daily (8), weekly (5) and monthly (13) periods. The past period comparison data is a simple representation of these total figures (so only 26 data items at any one time); it is not a set of granular 22

  18. The Presentation of Energy Usage Information (SB, MIHD and CWI) half hourly data. The display of historical data has been kept as simple as possible to deliver the Customer benefits. The purpose of showing cumulative information is to enable the consumer to see an up to date view of the usage to date so that they can track that usage over different periods and set themselves targets to aim for. Complementing this is the presentation of information showing usage for previous periods. The purpose of this is to allow users to compare their usage with a relevant comparable period, for example, comparing with the same day in the previous week, or the same month in the previous year. The MIHD is the only information channel which can effectively provide instant feedback to the Consumer in their home. The strategic drivers for the presentation of this information through the MIHD are to provide simple and easy near real time feedback to the Consumer regarding their consumption, promoting a high frequency of interaction for a low level of effort and time required. 3.4.3 Customer Web Interface The prospect of an industry web portal, delivered by the Network Companies, was included in the original design architecture (see policy ref CJDP1, CJDP2 and CJDP3 of the CER July 2012 Decision paper), essentially to facilitate the transfer of data between industry participants at a time when the capability of the existing market messaging system (for this purpose) was uncertain. It was considered that this industry data portal could also provide a point of common access for Customers to access their consumption data. The proposal was retained in the CER July 2012 Decision paper cer12028 6 that a data portal (delivered by the Network Companies) will be provided through which Suppliers can access data for their Customers, updated daily, on a push and/or pull basis subject to their requirements (as agreed with the Customer). This has been explored further in Phase 2 to see how this can be facilitated and to ensure that it is technically and economically feasible. Since the decision paper was published in July 2012, it has been firmly established, by ESBN and BGN that the existing market messaging systems can provide adequate capability to efficiently transfer the large volumes of data that will be required to be sent to Suppliers. With this in mind, ESBN and BGN have stated that a separate industry web portal is now no longer required as an integral part of the smart metering design / solution to deliver data to Suppliers. However, there is still the need to support Customer access to data, as stated in the July Decision paper (see policy ref CJDP4, CJDP5 and CJDP6 of the CER July Decision paper). Now that a Network provided data portal does not need to be used by Suppliers to access consumption data, there is a need to assess the different solutions to delivering 6 http://www.cer.ie 23

  19. The Presentation of Energy Usage Information (SB, MIHD and CWI) Consumer and 3rd Party access to data. It is important to define what data is proposed to be made available and how. EED Billing Information (Article 10) also states in section 2b in addition to the decision paper that interval data will be made available to the Consumer via the internet or meter for a period of 24 months and free of charge (see policy ref EED04, EED09, EED10 and EED22 of the Energy Efficiency Directive). The CER is of the view that to give consumers easy access to complimentary information on historical consumption it is proposing that this is delivered via internet access to a national harmonised format of interval data for Customers and 3rd Parties (with Customer consent) and a defined requirement is proposed to fulfil this policy position. In order to facilitate Customer switching it is also proposed to regulate for the provision of data beyond supply contract date by Networks and promote innovation in the energy services market (consistent with the objectives of the National Smart Metering Programme). The strategic drivers for the Customer Web Interface point to a web-based means of providing information to Consumers should they wish to access it. This allows them to own, access and share their interval consumption data. This would mean Consumers being pro-active in choosing to access this data and use it accordingly, requiring a greater level of time and effort than that required for the MIHD and Smart Bill. It is important to state that internet based services are a key area for differentiation and innovation in providing information and services to Customer s. It is not CER’s intention to constrain this innovative market by imposing unnecessary regulation. 3.5 Evaluation Criteria 3.5.1 Introduction This section sets out the proposals for the evaluation criteria and processes for this consultation paper. These are based on the objectives set out by the Programme as well as the principles of the proposed Steady State Model. More detail of the Steady State principles, as well as the Time-of-Use Tariff evaluation criteria, can be found in Appendix K – Background to Evaluation Criteria. 3.5.2 Approach to Evaluation of Requirements The CER has reviewed requirements in light of the below criteria as part of the development process. In doing so, consideration has been given to the information channel strategic drivers, workshop findings, collated Irish and international experience and the experience and knowledge within the programme. In their responses to the consultation, respondents are asked to also consider these evaluation criteria and give constructive qualitative feedback against them to enable conclusions to be drawn and final decisions made. Following the consultation, a quantitative assessment of cost and benefits will be 24

  20. The Presentation of Energy Usage Information (SB, MIHD and CWI) conducted by the NSMP in a programme-wide initiative in order to ensure that a single set of consistent data exists that can be input to the updated programme cost benefit analysis. This will ensure any additional costs, and / or benefits that may be identified as a result of this process, are factored into forward cost / benefit projections. It is expected that a proposed decision will be published which will provide the conclusions of the evaluation process and consultation responses. 3.5.3 Requirement Evaluation The proposed requirements in section 0 will be subject to the following evaluation outlined in the table below. This evaluation criterion is the same used to evaluate the SSM and will be basis for seeking comments and responses through this consultation. Criterion Description Consumer Focused What are the benefits to the Customer with regard to their experience / ease of understanding / engagement & change in behaviour / uptake / rejection / failure points Assessment of whether requirement is consistent with Consistent & Integrated the Steady State Model and any implications of Solution change Assessment of whether requirement is scalable and Scalable & Future- will support future development, competition and Proofed innovation How do the cost efficiencies compare between the outlined solution proposals for implementing the Cost Efficient Customer Experience How do the outlined requirement proposals fit in with Irish Market Context the Irish Gas and Electricity Markets Where does the benefit lie / market / Suppliers / Perceived Benefit regulation / competition / NSMP Strategic objectives Table 1 - Requirement evaluation criteria The evaluation criteria outlined above has been designed using the NSMP programme objectives, Steady State Model Principles and the CSI specific objectives. 25

  21. The Presentation of Energy Usage Information (SB, MIHD and CWI) • Encourage Energy Efficiency • Facilitate Peak Load Management (electricity only) NSMP • Support Renewable and Micro Generation (electricity Programme only) Objectives • Enhance Competition and Improve Consumer Experience • Improve Network Services. • Consumer Focused Steady • Consistent & Integrated solution State • Scalable & Future Proofed Model • Cost Efficient Principles • Irish Market Context Specific • Consumer experience (interaction and operation) Objectives • Cost benefit impacts A quantitative review of the NSMP Cost Benefit Analysis will be carried out by the CER in a programme-wide initiative to ensure any additional costs and / or benefits that may be identified as a result of this process are factored into forward cost / benefit projections. Question 1: Is there anything you would add or remove from these evaluation criteria? 26

  22. The Presentation of Energy Usage Information (SB, MIHD and CWI) 4 Requirements Definition and Assessment 4.1 Introduction This section is broken down into the following sub sections:  An overview of CER “ minded to ” requirements;  A matrix of the requirements and their reference to policy and proposed information channel;  Detailed requirements definition including their rationale and evaluation for: - Smart Billing; - Mandated In Home Display; and, - Customer Web Interface;  Requirements the CER would like to review at a later stage;  Requirements the CER has assessed and are proposing to exclude; and, The following requirements have been developed to find a proposed set of requirements and to ascertain the most appropriate channel to present the Customer information. The structure of each requirement is as follows:  Statement of requirement  Rationale for requirement  Policy drivers  Evaluation of the requirement and / or options  Data Requirement (where applicable)  Requirement Proposition (where applicable) The evaluation of requirements is applied as follows:  Where no policy driver exists, the requirement will be evaluated against the criteria set in section 3.5, these requirements are described as incremental  Where a policy driver does exist the evaluation is only applied on: o Those areas of the policy that are left to interpretation, such as:  the channel on which the information is shown;  the scope of the information;  the source of the data; or,  the responsibility for delivery. Respondents are invited to provide their views on the proposals. 4.2 Requirements Overview The table below provide a reference to show the derivation of the requirements the CER is minded to include for Customer information on the basis of: EU Legislation – these requirements have been derived from statements in the EU 27

  23. The Presentation of Energy Usage Information (SB, MIHD and CWI) legislation set out previously and CER consider these mandatory requirements to be delivered in at least one method of Consumer information presentation. CER Decision – these requirements have been derived from statements in the CER July 2012 Decision paper and therefore are considered mandatory requirements to deliver in at least one method of Consumer information presentation unless the rationale suggests revisiting any previous CER decisions. Incremental Functionality – these requirements are considered to be incremental to the policy baseline and therefore should be subject to incremental positive evaluation to justify their inclusion. Potential Delivery Mechanism – these illustrate the potential information channel the requirement could be delivered through. Some requirements are specific to an individual channel and others could possibly be delivered by more than one channel. CER are Minded to Include – these illustrate requirements the CER is minded to include in the policy framework. Dependent on Other Policy Decisions – these illustrate requirements the CER is minded to include but are dependent on other policy decisions. All requirements apply to both electricity and gas Consumers unless otherwise stated. Additionally the requirements also relate to all Customers regardless of payment method unless otherwise stated. The following Requirements Matrix is an overview of all the requirements the CER is minded to include, review or exclude aligned with the policy drivers and the proposed information channel and any key dependencies. 28

  24. The Presentation of Energy Usage Information (SB, MIHD and CWI) 4.2.1 Requirements Matrix CER CER Minded to Dependent on Other Requirement EU EED SB MIHD CWI REF Decision Include/Exclude Policy • Energy Statement Arrangements and Article10.3(c) 4.3.4.2 √ SBR01 No Dependency Communication Method Annex VII 4.3.9 4(a/b) • Article 10.3(c) √ SBR02 Electricity and Gas Time of Use Information No Dependency 4.3.4.2 Annex VII 1.2(a) • √ SBR03 Year-on-Year Energy Usage Comparison No Dependency Annex VII 1.2(b) • Annex VII 1.2(c) √ SBR04 Additional Contact information No Dependency Annex VII 1.3 • √ Hints and Tips SBR05 No Dependency Article 12 (1) • √ Complimentary Billing Information SBR06 No Dependency Article10.2(a) • Instantaneous Active Electricity Demand (Real- 4.3.3.2 √ MIHDR01 No Dependency Time) 4.3.9/3.d • Time of Use 4.3.3.2 Subject to Instantaneous Cost of Demand for the Hour MIHDR01(a) Steady State Model 4.3.9/3.d • Up to Date Consumption Position in Time Period 4.3.3.2 √ No Dependency MIHDR02 (Cumulative) 4.3.9/3.d • Up to Date Cost Position in Time Period Time of Use 4.3.3.2 Subject to MIHDR02(a) (Cumulative) 4.3.9/3.d Steady State Model • 4.3.3.2 √ Past Period Consumption Comparison (Historical) MIHDR03 No Dependency 4.3.9/3.d • Time of Use 4.3.3.2 Subject to Past Period Cost Comparison (Historical) MIHDR03 Steady State Model 4.3.9/3.d • Time of Use Subject to Ambient Feedback of Electricity Time of Use Tariffs MIHDR04 Incremental Incremental Steady State Model • Time of Use 4.3.3.2 Subject to Tariff and Price Information MIHDR05 Steady State Model 4.3.9/3.d Article 9.2(d) • Access to Historical Consumption Information in a No Dependency √ CWIR01 Article10.2(b) 4.3.9/3.a/b/c National Harmonised Format Article 11(1) Table 2 – Requirement Matrix, CER minded to position with reference to policy

  25. The Presentation of Energy Usage Information (SB, MIHD and CWI) CER CER Minded to Dependent on Other REF Requirement EU EED SB MIHD CWI Decision Include/Exclude Policy • SBR07 Benchmarked Comparisons Review No Dependency Annex VII 1.2 • • • Review 4.6.2 Micro Generation Information No Dependency 3.4/3 • X 4.7.1 Pay as You Go (PAYG) Information N/A Incremental Incremental • X 4.7.2 Text Capability to the MIHD N/A Incremental Incremental • X 4.7.3 CO2 Intensity on the MIHD N/A Incremental Incremental • X 4.7.4 Temperature on the MIHD N/A Incremental Incremental • X 4.7.5 Budget Setting on the MIHD N/A Incremental Incremental • X 0 Illustrative Appliance Consumption N/A Incremental Incremental Table 3 - Requirements Matrix, CER are minded to review or exclude from policy

  26. The Presentation of Energy Usage Information (SB, MIHD and CWI) 4.2.2 Overview of the Requirements the CER is Minded to Include The Smart Billing requirements cover the minimum of what should be covered by information accompanying a Customer ’s bill. This information will be offered to Customers in paper format or electronically if desired, and should include:  Information on the Customer ’s tariff and other charges for the billing period, and a breakdown of the Customer ’s consumption and cost at different time periods associated with the tariff;  A comparison of the latest billing period against the equivalent period for the previous year;  Contact information relating to where additional information can be found such as advice on energy efficiency measures; and,  Hints and tips on how to reduce or shift energy usage in order to be more efficient and make financial savings. In addition there is a requirement for suppliers to make billing information available to Customers for the previous three years, or from the start of the supply contract, depending on which is sooner. MIHD requirements cover the minimum of what information should be shown on the MIHD and include the following:  The level of the Customer ’s current electricity demand in near ‘real - time’;  The Customer ’s cumulative consumption of electricit y and gas for the current day, week and month; and,  The Customer ’s historical consumption by past time period to show the last eight days, five weeks and thirteen months. There are a further five requirements for the MIHD (some of which were mandated in the July 2012 Decision) that are dependent on whether price & tariff information is available from the Steady State Model and the Time Of Use Tariff policies in terms of whether, and how, these requirements are included in the MIHD. These requirements are as follows:  The cost of the Customer ’s current electricity demand in near ‘real - time’;  The Customer ’s cumulative cost of electricity and gas for the current day, week and month;  The Customer ’s historical cost by past time period to show the last eight days, five weeks and thirteen months;  Ambient feedback of the Customer ’s prevailing tariff band (to illustrate peak, mid and low tariff bands in a non-numeric format); and,  A view of the Customer ’s tariff banding and the price associated with each banding. 31

  27. The Presentation of Energy Usage Information (SB, MIHD and CWI) Finally, the Customer Web Interface minded to position is that both Networks and Suppliers provide the Consumer with the ability to access and download their half- hourly interval consumption data on request via the internet in a standard harmonised format. 4.2.3 Consultation Questions There are two generic questions that the CER would like feedback on against each of the individual requirements defined in this consultation paper: Question 2a: What are the respondents’ views in regards to the definition of ea ch of the requirements below? This question provides the CER with assurance that the definition of requirements is accurate and provides a solid baseline for future procurement as well as system and process definition. Question 2b: Please provide your views on the relative impact assessment of the different options delivering each requirement in terms of the evaluation criteria in the template table provided. This question provides the CER with evidence to evaluate whether the current minded to position is reasonable and to confirm policy. There is a further question asked to ensure that CER has considered a full set of reasonable and practical information requirements for each information channel: Question 2c: Are there any additional requirements that should be considered or any proposed requirements that should be dropped, please provide rationale and assessment? Any questions specific to requirements will be asked against those requirements. What follows in the following sub sections is a detailed exposition of requirements setting out their rationale, and in some cases explaining different potential options and their respective evaluation. 32

  28. The Presentation of Energy Usage Information (SB, MIHD and CWI) 4.3 Smart Billing Requirements 4.3.1 SBR01: Energy Statement Arrangements and Communication Method Proposed Statement of Requirement Where Suppliers currently offer electronic billing to their Customer s on an ‘opt in’ basis, it is required that this offering is extended to the energy statement / information through the same process already undertaken by Suppliers. The accompanying information on energy usage linked to the bill may be part of the billing document or contained in a separate document. To reiterate the CER July 2012 Decision, additional energy usage information will be delivered with the Customer ’s existing bill and Customers on PAYG services will also receive energy statements in line with current arrangements for the provision of billing information for PAYG. Rationale for the Requirement The purpose of this requirement is to propose the arrangements by which the Consumer will receive their energy usage information and allow Customers the choice of receiving their energy usage information in the format that they prefer and find easiest to use, as is currently offered by Suppliers for non-smart bills. Policy Drivers As per the CER July 2012 Decision Paper (cer12092) 7 CER has decided that Consumers must receive an energy statement with their energy bills, the frequency of which will be left to the market (see policy ref SJDP1, SJDP2, SJDP3, SJDP4 and SJDP5 of the CER July 2012 Decision paper). Additionally the Energy Efficiency Directive 2012/27/EU has directives covering electronic provision of information and the provision of detailed information at the request of the Consumer other than that which is made for request of payment (see policy ref EED11, EED12 and EED13 of the Energy Efficiency Directive). Evaluation of the Requirement There are clear policy drivers for this requirement to be included in the smart billing obligation. This requirement is specific to billing with no areas left for interpretation and therefore a qualitative assessment of the requirement is not required. Delivery through other information channels is also not an option. 4.3.2 SBR02: Electricity and Gas Time of Use Information Proposed Statement of Requirement This requirement is to provide information relating to any time of use tariffs in place for 7 http://www.cer.ie/ 33

  29. The Presentation of Energy Usage Information (SB, MIHD and CWI) electricity and gas. Where time of use tariffs are in place the Consumer must be provided with: • A clear overview of the applicable tariffs for the current billing period, as well as any other relevant charges or rebates applied to enable Customers to understand the costs of using energy at different times; and, • The ability to identify the relevant tariff periods and Customer energy consumption and cost during those periods. Also, to allow Customers to understand their energy consumption and associated cost at different time periods. Rationale for the Requirement The purpose of the requirement is to provide a clear overview of the applicable tariffs to the Customer, as above. In the Irish trials (see Appendix J – Experience from SM Trials and Programmes) for electricity users, detail on the tariff was considered important with a clear breakdown of how consumption and cost split across different tariff periods. Policy Drivers This requirement is to supplement obligations on Suppliers already set out in The Supplier Handbook cer12081 8 and to support the CER decision to mandate time of use tariffs. Energy Suppliers are already obligated to present clear calculations of the amount due for electricity/gas supplied, (giving units, multipliers, rates etc. where appropriate). This requirement is incremental to that already set out in the Supplier Handbook. The Energy Efficiency Directive 2012/27/EU 9 states that actual prices and actual consumption of energy shall be provided to the Consumer as a minimum (see policy ref EED17 of the Energy Efficiency Directive). Evaluation of the Requirement From the perspective of supporting time of use tariffs the policy drivers for this requirement are clear. Data requirement Suppliers will need access to data for the latest billing period that is granular enough to show levels of consumption at different tariff periods as well as the prevailing prices at those periods. 4.3.3 SBR03: Year-on-Year Energy Usage Comparison Proposed Statement of Requirement 8 http://www.cer.ie 9 http://eur-lex.europa.eu/ 34

  30. The Presentation of Energy Usage Information (SB, MIHD and CWI) The billing information provided to the Consumer for the current billing period should be made available for comparison on the Smart Bill on an aggregate basis for the same billing period in the previous year, where there is sufficient historical billing information to provide such a comparison. It would not be expected for this requirement to be fulfilled until thirteen months after the Smart Meter has been installed in a property. Rationale for the Requirement This is to facilitate Customers in comparing energy consumption and costs between comparable billing periods and to stimulate Customers to implement behavioural change, e.g. to reduce overall demand or shift demand to periods with lower tariffs. Both international experience and experience from the Irish trials (see Appendix J – Experience from SM Trials and Programmes) suggests that a simple month on month comparison may not necessarily be that helpful for a Consumer given difficulties in interpretation given changing weather conditions and other factors. However, a comparison against the same period in the previous year provides a more relevant benchmark/comparison to understand changing usage. Policy Drivers This is an Energy Efficiency Directive 2012/27/EU 10 policy driver which states that Consumers should be provided with comparisons of their current energy consumption with consumption for the same period in the previous year, preferably in graphic form (see policy ref. EED19 of the Energy Efficiency Directive). Evaluation of the Requirement The policy driver for this requirement is clear, however there is the caveat that this information is provided where appropriate. This has been interpreted as where there is sufficient historical billing information to provide such a comparison. If the billing information does not exist then there is no obligation to provide it. As this is billing information there are no other channels to consider in the presentation of this information to the Consumer. There are no areas open to interpretation and therefore there is not a need to undertake a qualitative assessment. Data requirement Suppliers will need access to data showing the aggregate consumption and cost for previous billing periods covering a history of 13 months. 4.3.4 SBR04: Additional Contact Information Proposed Statement of Requirement In addition to the information Suppliers are obligated to provide whilst addressing their 10 http://eur-lex.europa.eu/ 35

  31. The Presentation of Energy Usage Information (SB, MIHD and CWI) Customer s’ needs, this requirement relates to contact information, including web addresses in relation to obtaining independent advice on energy efficiency measures Consumers can take. The following contact information relating to where additional information can be found should be provided in an appropriate form to the Consumer in, or accompanying, their Smart Bill. Additional information related to the following should be provided:  Independent Consumer advice centres;  Energy agencies or similar institutions;  Advice on energy efficiency measures;  Benchmark profiles for their energy consumption; and,  Technical specifications for energy using appliances. It will be left to individual Suppliers to ascertain the most appropriate and effective way to present this information – subject to minimum requirements as set out by the CER. Rationale for the Requirement The purpose of this is to provide Consumers with supplementary information promoting energy efficiency in order that they may benefit from being more aware of the impact they can have on their own energy efficiency as well as exposing them to energy saving products which are available to them. Policy Drivers The Energy Efficiency Directive 2012/27/EU 11 states that contact information for organisations, energy agencies or similar bodies from which energy efficiency information may be obtained is provided as a minimum in Consumer bills (see policy ref EED19 of the Energy Efficiency Directive). This is then extended to wider industry participants providing advice on energy efficiency in accompanying bills and other feedback to the Consumer (see policy ref EED21 of the Energy Efficiency Directive). Evaluation of the Requirement The policy driver is wider reaching than just billing; as such this requirement specific to the Smart Bill only fulfils part of the directive. The wider areas will be subject to transposition into Irish legislation. This requirement is specific to billing information there are no other channels to consider in the presentation of this information to the Consumer. There are no areas open to interpretation and therefore there is not a need to undertake a qualitative assessment. Data requirement 11 http://eur-lex.europa.eu/ 36

  32. The Presentation of Energy Usage Information (SB, MIHD and CWI) Suppliers will need contact information for where Customers can get advice on energy efficiency. 4.3.5 SBR05: Hints and Tips Proposed Statement of Requirement Hints and tips to the Consumer on how to reduce or shift their energy consumption and ultimately cost to the Consumer will be provided in the Smart Bill. For example, these tips could relate to energy efficiency or financial savings or through feedback on the cost/consumption associated with different appliances. Rationale for the Requirement The purpose of providing this information to the Consumer is to inform them, in a very simple way via a familiar information channel, with advice on how they can reduce their energy consumption. The level to which this information is tailored to the individual Consumer will be important in determining how useful it is to the Consumer and could be a differentiator for energy Suppliers. In the Irish trials (see Appendix J – Experience from SM Trials and Programmes) advice on the energy usage statement was largely appreciated and it was felt that hints and tips should take a prominent position to help Consumers looking for guidance on active measures they can take. International experience also suggests that this information is of benefit as it empowers Consumers to save money through their own decisions and actions. Also consumers are most receptive to conservation messages when they receive their utility bill, making them a logical place to insert this type of advice (see section 6.3.4). Policy Drivers The policy drivers for this requirement are from the Energy Efficiency Directive 2012/27/EU 12 , to take appropriate measures to promote and facilitate an efficient use of energy by small energy Customers, including domestic Customers (see policy ref EED23, EED24, EED25 and EED26 of the Energy Efficiency Directive). Evaluation of the Requirement The policy driver is clear from the Energy Efficiency Directive in promoting energy efficiency through the provision of information. The sole purpose of the requirement is to promote energy efficiency via information on the bill as in the trials where there was positive feedback from Consumers. This requirement does not necessarily have to be delivered through the Smart Bill, however it is deemed that this would be the best place to present it because it should be low cost, ensures easy access to consumers with limited effort (as opposed to accessing over the web), and also allows suppliers to differentiate their offering. Data requirement Suppliers will need access to effective and useful tips that will help Customers take 12 http://eur-lex.europa.eu/ 37

  33. The Presentation of Energy Usage Information (SB, MIHD and CWI) action to reduce or shift their energy usage. 4.3.6 SBR06: Complimentary Billing Information Proposed Statement of Requirement Where smart meters are installed complimentary billing information will be made available to the Consumer on request at intervals which billing information has been produced for the previous three years or from the start of the supply contract if this is shorter. This is consumption information for the billing period and its related cost to the Consumer. The CER expect this provision to be discharged by the Supplier. The information will be provided to the Consumer via paper or electronic billing or any other means e.g. separate monthly report sent by mail or electronically by an energy Supplier or 3 rd party acting on behalf of the energy Supplier via a secure web site. Rationale for the Requirement The purpose of the requirement is to ensure all Consumers have access to complementary billing information in the format they prefer. Policy Drivers The policy drivers for the requirement are driven from the Energy Efficiency Directive 2012/27/EU 13 to provide complimentary billing information where smart meters are installed to Consumers for a three year period, or from the start of the supply contract if this is shorter (see policy ref EED08 of the Energy Efficiency Directive). Evaluation of the Requirement The interpretation of this policy driver is that the complementary information is in relation to consumption (e.g. for the billing period) and related costs incurred by the Consumer. This does not refer to the provision of interval data, which is a separate provision in the Directive (see policy ref EED19 of the Energy Efficiency Directive and requirement CWIR01). This provision is a specific billing requirement and there are no other information channels to consider or any element open to interpretation. As it is required to fulfil the Energy Efficiency Directive, it will not be subject to a qualitative evaluation. Data requirement Suppliers will need access to Customer s’ previous billing information for 3 years of history or up to the start of their contract, whichever is shorter. 13 http://eur-lex.europa.eu/ 38

  34. The Presentation of Energy Usage Information (SB, MIHD and CWI) 4.4 Mandated In-Home Display (MIHD) Requirements 4.4.1 MIHDR01: Instantaneous Active Electricity Demand (Real-Time) Proposed Statement of Requirement This electricity only requirement is to present the Consumer with their instantaneous level of electricity demand in kW, in as near real-time as possible, to show the immediate impact of their actions with regard to energy consumption. Data should be refreshed frequently enough to be able to effectively link the Consumer with their current behaviour. Rationale for the Requirement The purpose of this is to enable Consumers to understand the effect they have on their energy consumption in near real time (see policy ref IJDP9 of the CER July 2012 Decision paper). This allows them to react to high energy consumption by turning something off or to see the result of any intentional energy saving acts being reflected on the MIHD. Gas is excluded from this requirement as it is ‘less instant’ by nature and instantaneous data will not be available from the gas meter. The view is that when making decisions on cutting down on gas demand the process is not instant unlike electricity and instantaneous prompts are less effective. Therefore, the cumulative in- day gas position will be shown updated on a half hourly basis. Evaluation of the Requirement Instantaneous demand would contribute collectively with other functions to fulfil this policy objective set out in the CER July 2012 Decision paper cer12092 (see policy IJDP1 and IJDP3 of the CER July 2012 Decision paper) to display real-time cost and consumption information on the MIHD. The presentation of instantaneous information is best achieved by the MIHD as a key attribute of the device is to be able to provide near real time feedback. This cannot be presented in the Customer Web Interface or Smart Bill. It is the CER’s view that the display of instantaneous demand reinforces the learning experience of the Consumer. Instantaneous demand could also be presented through ambient feedback which is proposed as a ‘back stop’ position if the MIHD is unable to provide useful cost/tariff information to Customers due to the complexity and/or variability of TOU tariffs. Data requirement The MIHD will need to access near real-time consumption data from the Metering Infrastructure on demand to fulfil this requirement. 39

  35. The Presentation of Energy Usage Information (SB, MIHD and CWI) Question 3: What would be the least frequent level of data refresh that would be appropriate in order not to adversely affect the ability of the consumer to control their energy consumption effectively? 4.4.2 MIHDR02: Up to Date Consumption Position in Time Period (Cumulative) Proposed Statement of Requirement The Consumer will have the ability to view their cumulative consumption of electricity and gas in kWh (see policy ref IJDP10 of the CER July 2012 Decision paper) to get a near real-time up-to-date view of their consumption by current day, current week and current month (electricity and gas). The consumption data will be updated from the Metering Infrastructure frequently enough to link the Customer with their current behaviour for electricity and every half-hour for gas. Rationale for the Requirement The purpose of presenting the Consumer with the cumulative current position within day, week and month is to enable the Consumer to make more informed decisions regarding their energy consumption and increase their energy efficiency awareness. This gives Consumers a running total of their usage allowing them to judge their performance on an on-going basis against their own targets or against previous period usage. In both the Irish trials (see Appendix J – Experience from SM Trials and Programmes) and the international experience (see section 6.3.3), consumers found it useful to see cumulative information. Evaluation of the Requirement The policy drivers for providing the Consumer with their cumulative consumption information through the MIHD is very clear (see policy ref IJDP1 and IJDP3 of the CER July 2012 Decision paper). Data requirement The MIHD will need to access real-time consumption data from the Metering Infrastructure on demand and store aggregated data to fulfil this requirement. 4.4.3 MIHDR03: Past Period Consumption Comparison (Historical) Proposed Statement of Requirement Historical consumption totals in kWh (see policy ref IJDP10 of the CER July 2012 Decision paper) for past time periods i.e. day, week and month for electricity and gas will be available to the Consumer in a simple and easy to view and understand format for energy usage comparison. The periods for comparison will be as in the diagram in section 3.4 above and as 40

  36. The Presentation of Energy Usage Information (SB, MIHD and CWI) below:  D-1 to D-8 historic Energy Consumption;  W-1 to W-5 historic Energy Consumption; and  M-1 to M-13 historic Energy Consumption Where: D-1 = current Day minus 1, D-2 = current Day minus 2, W-1 = current Week minus 1, M-1 = current month minus 1 etc. The past period comparison data is a simple representation of these total figures (so only 26 data items at any one time); it is not a set of granular half hourly data. The display of historical data has been kept as simple as possible to deliver the Customer benefits. Rationale for the Requirement Simple ‘quick’ comparison of historical consumption time periods allows the Consumer to predict and potentially influence what their energy usage impact will be by looking at what happened in the past and therefore providing the Consumer with the ability to monitor the overall effect on their energy demand of actions to reduce their energy consumption, or help to understand what is increasing their energy demand. Having D-8 enables the same day from the previous week to be compared. Having W-5 enables a similar week from the previous month to be compared. Having M-13 enables the same month from last year to be compared. International experience (see section Appendix J – Experience from SM Trials and Programmes) concludes that the combination of cumulative and historical usage feedback has the greatest impact on Consumer behaviour. The strategic drivers for the MIHD would suggest that near time comparisons i.e. day/week are likely to be the most useful however it was raised through the industry workshops that month is also very useful for sharing seasonal variations, especially in gas. It was thought that this is as important to gas as instantaneous real-time info is to electricity. Whilst the strategic driver for monthly electricity consumption may be more suited to an alternative channel, CER propose to include it in this requirement to be consistent with gas and on the basis that it is a small increment in functionality if it is already being provided for gas. The GB IHD also shows historical periods on a day, week and month basis, as defined above. Evaluation of the Requirement The policy driver is clear in that it states historical information will be available to the Consumer through the MIHD (see policy ref IJDP1 and IJDP3 of the CER July 2012 Decision paper), however it is not prescriptive as to what time periods these comparisons might be. Data requirements for the MIHD can have an impact on its cost and therefore should be optimised. It is the view of the CER that the time periods which are available to the Consumer for cumulative comparisons should be available 41

  37. The Presentation of Energy Usage Information (SB, MIHD and CWI) for past period comparisons. It is believed that this is achievable without putting undue cost implications on the MIHD. Data requirement The MIHD will need to access real-time consumption data from the Metering Infrastructure on demand and store aggregated data to fulfil this requirement. 4.4.4 Requirements for the Presentation of Cost Information on the MIHD The July 2012 Decision paper states that Consumers will receive cost and usage information via the in-home display with functionality being determined during the design stage. Experience from the Irish trial and internationally supports the proposition that relative cost is a key driver and that the majority of Consumers understand and are likely to be more responsive to information presented in monetary terms. However, to show cost information on the MIHD requires price/tariff data to be available. While it may be the case that this data is available from the meter in the Steady State Model, this is currently being considered as an alternative model and there is also an option being considered where it is not. In this case, the price/tariff data can be pre-programmed onto the MIHD but changes to this information would need to be updated manually, for example by the consumer. Therefore, the key questions here are not just about what cost-based information should be shown but also how that price/tariff information should get onto the MIHD and how accurate any updated data might be. The complexity and variability of the TOU tariffs plays an important role in answering these questions. More complex or variable tariffs may make manual update of information on the MIHD more difficult and the resulting information shown may be less robust and accurate. The timing of the implementation of TOU tariffs will also be important, because if this is later than the installation of the MIHD then there will be a period of showing no TOU information and then a need to update price/tariff information on the MIHD. As a result, the nature of the TOU policy will be key in determining the cost requirements that are finally decided upon. As this policy is currently under consultation, this section sets out potential MIHD cost requirements, how price/tariff data might get onto the MIHD given the TOU options, and asks for opinions from consultation respondents. 4.4.5 Potential MIHD Cost Information Requirements under Consideration The preferred position for what data is presented to the Customer on the MIHD is illustrated in section 3.4.2. The potential MIHD requirements under consideration in relation to presenting cost on the MIHD are: 42

  38. The Presentation of Energy Usage Information (SB, MIHD and CWI) 4.4.5.1 MIHDR01(a): Instantaneous Cost of Demand for the Hour Proposed Statement of Requirement An extension of MIHDR01 the requirement for electricity is to present to the Consumer with the instantaneous level of electrici ty demand in € for the current hour in as near real time (see policy ref IJDP9 of the CER July 2012 Decision paper) as possible to show the effect of Consumers’ actions with regard to their consumption of energy. 4.4.5.2 MIHDR02(a): Up to Date Cost Position in Time Period (Cumulative) Proposed Statement of Requirement This again is extending requirement MIHDR02 to include the up-to-date cumulative cost to the Consumer. The Consumer will have the ability to view their cumulative cost of electricity and gas in € to make real time comparisons for the day, week and month (electricity and gas). The consumption data will be updated from the Metering Infrastructure in as near real-time as possible for electricity and the half-hour for gas. 4.4.5.3 MIHDR03(a): Past Period Cost Comparison (Historical) Proposed Statement of Requirement Requirement MIHDR03 is extended to include cost. Historical cost totals for past time periods i.e. day, week and month for electricity and gas will be available to the Consumer in a simple, easy to view format for energy usage comparison. 4.4.5.4 MIHDR04: Ambient Feedback of Electricity Time of Use Tariffs Proposed Statement of Requirement A non-numeric indication / statement of the prevailing tariff band (e.g. Peak; Mid; Low traffic lights) updated in near real-time (see policy ref IJDP9 of the CER July 2012 Decision paper). The MIHD may need to be configurable to support any transition and migration requirements and future changes to time-of-use tariffs. Rationale for the Requirement The purpose of this requirement is to allow the Consumer to immediately recognise the current active tariff band ‘at a glance’. The advantage of the non -numeric presentation is that less mental agility or interpretation is required on the part of the Consumer. It therefore provides better prospect of comprehension at a glance or at a distance. In the Irish trials (see Appendix J – Experience from SM Trials and Programmes) electricity users found the information on tariffs useful, particularly the ambient feedback provided through a traffic light system of red, amber and green. Evaluation of the Requirement The MIHD is the only one of the three channels under discussion that has the capability to show direct ambient feedback. Ambient feedback of the prevailing tariff band constitutes cost information and therefore contributes towards fulfilment of the 43

  39. The Presentation of Energy Usage Information (SB, MIHD and CWI) policy driver to show cost and consumption information on the MIHD. If the evaluation of the options regarding presentation of cost information determines that this will not be displayed then it is proposed to present ambient feedback on consumption, linked to requirement MIHDR01, which displays the instantaneous active demand. This would be an indication of the level of electricity being consumed in a non-numeric way (red- high, amber-medium or green-low). 4.4.5.5 MIHDR05: Tariff and Price Information Proposed Statement of Requirement To support the TOU mandate the Consumer will have a view of the tariff banding linked to the ambient feedback for electricity and the price per band. Rationale for the Requirement The current tariff price is a key influencing factor for the Consumer to modify their behaviour and reduce consumptions proactively or reactively. Making this tariff price visible in relation to the active tariff band will increase awareness and promote action in periods where the unit rate is high, notably helping towards reducing critical peak demand. In the Irish trials (see Appendix J – Experience from SM Trials and Programmes) Consumers made reference to the usefulness of tariff periods being linked to ambient feedback so they could identify their usage in each tariff period and manage it. Evaluation of the Requirement The MIHD is the key means of delivering instantaneous feedback to the Consumer. Again tariff and price constitutes cost information and therefore delivers policy in the presentation of cost and consumption information on the MIHD (see policy IJDP1 and IJDP3 of the CER July 2012 Decision paper). Question 4: What are the respondents’ views in regards to t he definition of each of the potential requirements for display of cost and price/tariff information on the MIHD? 4.4.6 How to Input Price/Tariff Data onto the MIHD to Display Cost The MIHD is dependent on receiving price/tariff and consumption data to successfully show cost information to the Consumer in relation to their energy consumption, as cost is the product of the current price per unit and consumption units. The current view is that there are potential constraints on sourcing price/tariff data from the smart metering infrastructure as the Steady State Model suggests that only consumption data will be available from the Metering Infrastructure. If price/tariff data is not available from the Metering Infrastructure, there is a need to consider how it is input to the MIHD. The source of price/tariff data to the MIHD for consideration could be: 44

  40. The Presentation of Energy Usage Information (SB, MIHD and CWI)  From originating Supplier systems via the Metering Infrastructure;  Pre-configured within the MIHD by ESBN at the point of or in advance of installation, acco rding to Supplier tariff price or “generic” tariff price;  Manually configured by either ESBN / Supplier / 3 rd Party / Consumer during the life of the MIHD. 4.4.7 Key Drivers of Accuracy / Usefulness of Cost Data on the MIHD At best the most accurate view of cost would only reflect that associated with usage and not include any standing charges, VAT, discounts, accurate calorific values, and so on. Therefore, even at its most accurate, cost information is still indicative. Customers must be made aware that cost data on the MIHD is not of billing quality and therefore cannot provide a source to compare or contest a bill. Experience from the trials suggests that Customers are comfortable with this. TOU policy decisions will dictate how frequently price/tariff will need to be updated to maintain accuracy of cost information at the MIHD and also the structure and variability of TOU tariffs will drive how complex the MIHD will need to be to support these tariffs or how inaccurate the data will be if the MIHD doesn’t . Some of the proposed TOU options are likely to make it more complex and potentially costly to show cost information as well as potentially impacting on the accuracy of that information. 4.4.8 Current TOU Examples The range of mandated tariff options currently being considered in the TOU consultation goes from being completely fixed and standardised across all Consumers to being very dynamic and subject to frequent change (i.e. highly variable). Where tariffs are highly variable and the data is not remotely configurable and available from the Metering Infrastructure, it is more difficult to update accurate price information and therefore show cost information on the MIHD. The Time of Use Tariffs 14 consultation (which closes on 6th September 2013) illustrates examples of different approaches to regulate TOU, focusing on the initial migration. These are examples only, and have been chosen to illustrate and seek views on the range of factors that need to be considered in creating an appropriate regulatory framework for TOU. The TOU tariff options and migration examples are set out in more detail in Appendix L – Time of Use examples. An initial assessment of the advantages and disadvantages of each of the examples has been conducted and is set out in the TOU consultation paper. The decisions taken on TOU have implications for what how cost information is presented on the MIHD. This has been assessed in the following sections. The MIHD is only mandated for 2 years and is viewed as a ‘stepping stone’ to a more 14 http://www.cer.ie/GetAttachment.aspx?id=4a85d48a-65e9-437c-a7d1-fdee029afaa0 45

  41. The Presentation of Energy Usage Information (SB, MIHD and CWI) innovative and open market for the Consumer to engage with. It therefore has to be economically viable. This means the functionality is expected to be relatively simple by nature and is unlikely to be highly configurable and scalable. As such, introducing the capability and complexity to support a wide range of variable TOU tariffs may not be economically viable or practical for consumers to configure on the MIHD. The MIHD should not act as a constraint on the long term options for TOU as it is not part of the enduring solution. The implication of this is that the MIHD will only make use of the data that is available to it, as highlighted above. The consideration of TOU is a key dependency in the development of requirements for the MIHD. However, the CER do not know at this stage what the TOU policy will be. Therefore, at this point we are asking for views on the options presented. The CER will need to consider the implications of the TOU decisions and the responses to this consultation in our decision making process. 4.4.9 How Cost Might be Presented for Consideration The following options for presenting cost information on the MIHD are being proposed for consideration. The elements being considered in the options are the TOU examples, potential migration approaches and the source of price/tariff data. This can only be illustrative at this stage, but consultation feedback will inform the CER on respondents’ views on how best to d isplay cost in likely scenarios. 4.4.9.1 Option 1: Price / tariff data sent from the Metering Infrastructure to the MIHD as part of enduring solution or for a limited period aligned with the 2 year mandate. The MIHD could receive the price/tariff data from originating Supplier systems via the Metering Infrastructure. Price data would be configured remotely at the point of installation and updated with any on-going changes to be accurate. Calorific Value data will also have to be sent for gas, but this would not be accurate since today’s CV is only available tomorrow. To retain accuracy of the tariff, this data would require accurate update on any change of tariff or Change of Supplier event. The costs and benefits of mandating price data to be available from the Metering Infrastructure could be assessed. However, it is a programme assumption that the MIHD should not be a driver of Metering Infrastructure services as this is likely to significantly increase the cost of the Smart Metering Infrastructure. The working assumption is that the MIHD will display information that is available from the Metering Infrastructure as defined from Core Smart Services. The MIHD is an interim component of the Smart Metering Infrastructure and not part of the Steady State Model, and therefore to make changes to the Metering Infrastructure to support information presentation is not considered feasible. Under this option, in the event that price/tariff data is available from the Metering Infrastructure, the CER would be minded to display all cost requirements stated above on the MIHD 46

  42. The Presentation of Energy Usage Information (SB, MIHD and CWI) 4.4.9.2 Option 2: No price/tariff data from Metering Infrastructure, standard / default Time of Use tariffs mandated from the point of Smart Meter installation. In this option cost data can be displayed to Customers from the point of installation of the MIHD in co-ordination with the smart meters with a level of accuracy that could be guaranteed by inputting accurate price/tariff data at the time of installation. This option assumes the consumer migrates to a standardised / default TOU once the metering system is installed in their home. The price/tariff data for the MIHD in this option can be pre-configured supporting a standardised / default TOU tariff with fixed time band periods and price rates for each Supplier for at least the mandated MIHD period across all Suppliers. Any future change of price would introduce the need for someone to update the price/tariff at the MIHD, but it should not be unreasonable for the Customer to be able to do this, or if they choose not to, then to have it explained to them by the Supplier changing their tariff that the MIHD will be showing more indicative cost information. Under this option, the CER would be minded to display all cost requirements stated above on the MIHD and provide the Consumer with a means to update price on the MIHD. 4.4.9.3 Option 3: No price/tariff data from Metering Infrastructure, standard/default Time of Use tariffs mandated from a point after smart meter installation In this option, the Customer could be shown cost information in relation to the legacy tariff until migration occurs, at which point TOU tariffs will be programmed into the MIHD (either by the Consumer, Supplier or Network Company) to show TOU related data. This is likely to be more complex than the above Customer update to the MIHD, as it may involve inputting time bands as well as prices, so should there be an expectation the Customer is able to do this, or should Suppliers or Networks be asked to provide additional help? If industry is of a view that it is not practical for a TOU tariff to be input after the MIHD has been installed, then consideration should be given whether only consumption information is shown on the MIHD or whether the MIHD should be installed at a later date to align with the introduction of a TOU tariff. It has been highlighted elsewhere in this consultation paper that there are still benefits of displaying consumption data only as a fall-back option, but this would require a change of policy from the July 2012 Decision paper where display of cost and consumption was defined as a requirement. There is further collation of experience to support this position in Appendix J – Experience from SM Trials and Programmes. 4.4.9.4 Option 4: No price/tariff data from Metering Infrastructure, variable Time of Use tariffs able to be introduced by Suppliers If the tariff structure remains the same as any standard/default tariff, then the considerations captured in the above options apply. However, if variable and more complex tariffs are to be allowed to be introduced by 47

  43. The Presentation of Energy Usage Information (SB, MIHD and CWI) Suppliers, then it should not be unreasonable for Suppliers to bear the cost of providing Customers with information to align with these more complex products and services at the previous level of accuracy. Suppliers could provide an IHD, device, mobile application or alternative means to display all of the defined cost requirements to Customers to align with their more complex offerings. Question 5a: What are the respondents’ views in regards to the display of cost and price/tariff information on the MIHD for the options described above? Question 5b: Is it a viable option for consumers to be asked to update price and/or time band information? Question 5c: Would it be appropriate to expect suppliers to provide an alternative device to consumers who opt for alternative tariffs? 4.5 Customer Web Interface Requirements 4.5.1 CWIR01: Access to Historical Consumption Information in a National Harmonised Format Proposed Statement of Requirement The Consumer will have the ability to access their half hourly interval consumption data on request via the internet. It will be provided to them in a standard harmonised format to enable them to analyse or share the interval data with an alternative Supplier or 3 rd party (subject to the Consumers consent) offering other services. It is CER’s intention to require both Networks and Suppliers to provide this service. The Consumer will have access to at least 24 months data or data from the start of their supply contract (Supplier provided service); or 24 months data or data from the point of smart meter installation (Networks provided service). It is expected that, where the Consumer requests it and it is available, export data will also be made available to them through the same process. The provision of this information will be provided free of any transactional charges and within a reasonable time frame. The functionality required to fulfil the proposed requirement is as follows:  Secure access for the Consumer to a web interface.  Functionality to export historical consumption data in a consistent and widely used, standardised format . The intention is not to restrict data provision to this single format, but the intention is to define a standard format that will always be 48

  44. The Presentation of Energy Usage Information (SB, MIHD and CWI) available.  The specification of minimum data presented in the harmonised format for the historical consumption should contain the MPRN/GPRN and the associated MSN split by date showing the consumption used in each of the 48 half hourly periods within the day for the selected time period. Rationale for the Requirement The purpose of this requirement is to provide the Consumer with access to their historical consumption information to enable them to take ownership of their energy consumption data. This enables them to take advantage of it by engaging with the market by sharing their data with other Suppliers or third-party organisations to gain an alternative quote for their energy supply. The information could also be shared with other parties for advice concerning energy efficiency. This requirement delivers the policy drivers from EED04, EED09 and EED22, as well as the July 2012 Decision paper policies CJDP1 and CJDP6. Evaluation of the Requirement The access provision to detailed half hourly interval data for the Consumer in a harmonised format would be best achieved through a web interface rather than at the meter to keep the cost of the meter down and not to create unnecessary constraints on the Metering Infrastructure. The strategic drivers for the provision of Customer information through a web-based interface are to allow Consumers access to non-real time historical information about their energy usage for analysis and sharing. The policy regarding data ownership and sharing is clear though there are options for who has responsibility for delivering the service: Energy Suppliers, Energy Networks, or both. All three options have advantages and disadvantages associated with them; the following section sets out the options for consideration. Stakeholders have highlighted advantages in providing this data through both mechanisms. The CER is minded to regulate for the provision of this service by both Networks and Suppliers, on request and there is more rationale provided below but broadly: There are the following advantages of Network provided services:  Data requested from Networks can be provided beyond the start of supply contracts, providing a richer source of data to Customers regardless of switching activities;  Customers may not want to contact their existing Supplier if they wish to change Supplier or take services from a competitor and the Networks would provide a neutral source of data; and,  This facilitates Customer switching and the energy services market which is consistent with the objectives of the National Smart Metering Programme. There are the following advantages of Supplier provided services: 49

  45. The Presentation of Energy Usage Information (SB, MIHD and CWI)  This is consistent with the Steady State Model role for Suppliers maintaining the primary relationship with Customers and this is key  This can sit beside innovative Customer offerings for the provision of data and services Data requirement Supplier and Networks may need access to half-hourly consumption information with the time of use of that consumption for 24 months of history, or up to the start of the supply contract for Suppliers if that is shorter. Options Considered for How Customers and 3 rd Parties Access 4.5.2 Interval Data There are options for how Customers and 3rd Parties are granted access to this data by the responsible industry party and these have been considered in the development of the CER “minded to” position: A. Customers could notify the responsible party for the service that they wish to download interval data; this request can be validated against Customer information; and access to an internet based download of data can be provided to that Customer by the responsible party. Responsibility for passing on that data to 3 rd Parties would reside with the Customer. B. 3rd Parties could be granted access to interval data by providing evidence (e.g. letter or email granting access) that they have the Customer ’s permission to access this data; this request/evidence can be validated against Customer information; and access to an internet-based download of data can be provided to that 3rd Party by the responsible party. This is similar to how the current manual systems work for access to business Customer data by 3 rd Parties, but this currently supports a very low volume of current requests (<10 per annum has been suggested by Networks) and is therefore currently supported manually. However, it has considered inappropriate from a data protection perspective for 3 rd parties to have direct access to a consumer’s data as part of a regular process. C. There could also be an option where a centralised regime of access control is established by Networks to validate and control access of data by Consumers and/or 3rd Parties, allowing for a more automated access approach. However, it is likely that there will still be validation of Consumer details required or Consumer permission to automate any access and therefore this is likely to overlay complexity, cost and an administrative burden to option B above. D. There could be an option for Customers and/or 3rd parties to sign up to become recipients of market messages and be recipients of interval consumption via the market messaging services (MMS) from Networks. There is currently no intention to provide this because of the large costs involved. All of these options have potential data protection issues, which would be considered in more detail as part of the Data Protection work described in Section 5. 50

  46. The Presentation of Energy Usage Information (SB, MIHD and CWI) The CER is minded to implement Option A, as described in the Requirement Definition above. 4.5.3 Assessment of Responsibility Options for Providing Data There are 3 options that have been considered in development for who could be responsible for providing interval data in a harmonised format to Customers: 1. Suppliers; 2. Networks; or, 3. both Suppliers and Networks. The CER have assessed these options with an early qualitative analysis against the Evaluation Criteria. The CER would welcome views on the options and comments on the commentary below. 4.5.3.1 Option 1: Supplier Provided Services Advantages Incremental Cost to existing arrangements:  A web interface (for Customers) is likely to be provided by all Suppliers for commercial reasons (differentiation), general product information and account viewing facilities. Extending this to provide detailed consumption history in a consistent and harmonised format would not be a major step and should be relatively economic to apply. However, it is recognised that any development costs would apply to all Suppliers (as opposed to ESBN & BGN for a Networks delivered solution) and therefore could result in a higher cost. Customer Experience:  Customer relationship retained by Suppliers. The Supplier owns and manages the Customer relationship (for regulatory and commercial reasons).  There is a rich source of data for the Consumer in a Supplier provision as they can provide both cost and consumption data (as well as any other Consumer facing data they may have collected/stored).  Customer access (linked to account information) over a common front end could be password protected and linked to existing Customer account information. This would give a common and consistent experience for Consumers. Disadvantages Supporting competition and innovation:  Limit to start of supply contract (not 24 months data)  There may be a conflict of interest in Suppliers providing data to Consumers that may be used by them to obtain a more competitive quote for energy supply. 51

  47. The Presentation of Energy Usage Information (SB, MIHD and CWI) 4.5.3.2 Option 2: Network Provided Services Advantages Customer Experience:  One of the key benefits of Networks implementing a Customer Web Interface would be that 24 months of data or more could be made available without being restricted to the start of supply contracts.  24 months of data or more can be provided to Customers from one source, without recourse to multiple Suppliers for Customers switching within 24 months. Supporting competition and innovation:  Customers requesting data from Supplier-run services could signal the Customer as someone who is considering switching. This is commercially valuable information, and making it systematically available to the incumbent Supplier could distort competition. Protection may be needed to ensure that this information is not inappropriately used. Disadvantages Cost  Costs associated with Network interface development and operation Customer Experience:  Customers have to interact with Networks to download data, potentially confusing them in their relationship with their Supplier and resulting in multiple touch points for Customers.  May be difficult to find a secure way of confirming Customer identification. 4.5.3.3 Option 3: Supplier and Network Provided Services: Advantages Advantages apply as for both options above. Disadvantages Cost:  Potential duplicated costs over and above Network or Supplier only solution. Though in a Network only solution it could be argued that Suppliers would have to develop such services for account presentation/product differentiation anyway. 52

  48. The Presentation of Energy Usage Information (SB, MIHD and CWI) Customer Experience:  Possible confusion over two sources and two different sets of data.  May be difficult to find a secure way of confirming Customer identification for Networks. The CER is minded that both Suppliers and Networks should be responsible for providing interval data in a harmonised format to Customers, as described in the Requirement Definition above. Question 6a: What are the respondents’ views with regards to the options for access to data for 3 rd parties and minded to position for the Customer to access and pass on this data? Question 6b: What are respondents’ views on the options and minded to position for who is best placed to provide the national harmonised data to Customers? Question 6c: Are there any alternative options that should be considered, please provide rationale and assessment? Question 6d: Should there be guidance or regulation on how Customers are told that they request this data (e.g. if a Customer contacts a supplier for data, should the supplier notify Customers they can get data from networks beyond start of contract and/or export data)? Question 6e: What would be the longest period that it would be appropriate for a consumer to wait to receive data through the web interface? Question 6f: What would be the most appropriate national harmonised format for the data download? 53

  49. The Presentation of Energy Usage Information (SB, MIHD and CWI) 4.6 Requirements the CER are Minded to Review 4.6.1 SBR07: Benchmarked Comparisons Proposed Statement of Requirement Benchmark comparison information should be made available to the Consumer in or with bills. This should comprise of a comparative normalised or aggregated benchmark for a group of Customers in the same usage class. Rationale for the Requirement This requirement is to facilitate Customers comparing their energy usage with similar Customers, and to stimulate them to change their behaviour, e.g. to reduce overall demand or shift demand to periods with lower tariffs. To achieve this requirement a sufficient number of appropriate Customers will need to be aggregated into meaningful groups in order to provide a relevant benchmark. This has a value when used as a form of encouragement in providing Customers relativity against other households for judging performance. Policy Drivers This is an Energy Efficiency Directive 2012/27/EU 15 policy driver, stating that wherever possible and useful, comparisons with an average normalised or benchmarked Customer in the same user category are made available in clear and understandable terms (see policy ref EED20 of the Energy Efficiency Directive). Evaluation of the Requirement The directive defines that benchmarking should be used ‘wherever possible and useful’, therefore the CER must assess whether that is the case. International experience suggests mixed results regarding the provision of benchmarking information, with success highly dependent on the relevance of the comparison and the way it is presented. When it is used well it can result in significant energy demand reductions of up to 2%. However, comparison against peers is a subjective exercise; for it to be carried out well, relevant and effective comparison groups must be developed. This requires sophisticated data and the ability to analyse that data effectively to develop meaningful comparisons. A large proportion of consumers revel in being able to compare their energy efficiency behaviour against those of others, such as their neighbours, other consumers in their area, region, country, or simply other Customers that are in some way comparable to them. However, this type of comparison has questionable effectiveness when the categories are inappropriate, such as when households are compared to homes in a neighbourhood including those of a different size, age, type, etc. If comparisons are to 15 http://eur-lex.europa.eu/ 54

  50. The Presentation of Energy Usage Information (SB, MIHD and CWI) be made then it must be to households of a like description. If not done well, the comparison can become irrelevant or even do harm in sending the wrong message to Consumers. Internationally, peer-comparison has been developed on a competitive basis but evidence of the introduction of regulation to mandate this type of comparison could not be found. There is the significant risk that any regulation could constrain more effective competitive innovation in this area and therefore unintentionally reduce Customer benefits. Therefore, benchmarking is a difficult area to mandate due to the relative sophistication of data required to carry out effectively, and the subjectivity involved in assessing what makes an effective benchmark. While there is evidence as to its effectiveness in achieving demand reductions, the key question is how best to ensure it develops while still allowing competition to drive innovation and not constraining development. Mandating and regulating benchmarking would require a clear definition of what categories and segments of Customers will be, which risks both: centrally defining categories/segments too tightly that does not allow innovation and leads to irrelevance; and, wasting effort producing something that is not useful and detracting from potential competitive innovation in the area. If the nature of any potential regulation is considered, the difficulties become evident. A generally stated regulation, which only talks about an “appropriate” benchmark that suppliers must implement could leave too much room for interpretation and result in ineffective comparisons while dampening the competitive incentive. However, a tightly defined requirement which specifies what the standard comparison categories should be, or where they should come from, has the danger of not just leading to overly general and irrelevant groupings, but also of stymieing the innovative development of offerings. It is also dependent on having the richness of data available to allocate Customers to categories accurately. Ideally, the market would innovate to deliver the best benchmarking approach for its Customers. Therefore, the CER believes that the market should deliver this type of information to Consumers on a competitive basis although the CER may wish to introduce minimum guidelines. This should also allow time for data of requisite quality to be collected to enable relevant and effective benchmark categories to be developed. Requirement Proposition The CER are minded to leave the development of benchmarking to the competitive market to be delivered through differentiation between Suppliers, but there is a clear expectation that CER would like to see benchmarking delivered by Suppliers. It is proposed the CER will introduce minimum standards and guidelines, and that the CER will have a have a review point in the future to evaluate if benchmarking has developed. 55

  51. The Presentation of Energy Usage Information (SB, MIHD and CWI) Data requirement Suppliers would need access to a rich dataset concerning consumer characteristics and their associated energy consumption in order to fulfil this requirement. 4.6.2 Micro-generation Information The provision of Micro-generation information has been considered as supporting micro generation is one of the programme objectives. Export energy is to be included in the Customer Web Interface, as defined above, but there are no further proposals to provide separately metered micro-generation information as part of the MIHD or other information channels at this stage as it is not known what information is likely to be available from any micro generation metering or infrastructure. The presentation of micro generation will therefore be kept open for review at a later stage in the programme. Question 7a: What are the respondents’ views in regards to not regulating for benchmarking at this stage, but expecting this to happen in the open market and to review and revisit this in the future? Question 7b: What are th e respondents’ views on the presentation of micro generation information to the Consumer? What are the options? 56

  52. The Presentation of Energy Usage Information (SB, MIHD and CWI) 4.7 Requirements the CER are Minded to Exclude Potential requirements were collected through feedback from the CER July 2012 Decision paper cer12028 16 and industry workshops. It is the view of the CER that the following requirements are excluded from the three channels under discussion as there is no increment benefit. 4.7.1 Pay as You Go (PAYG) Information As the MIHD is only designed to be a temporary device, it could be argued that it may be inappropriate for it to show PAYG information that Consumers might come to rely on. 4.7.2 Text Capability to the MIHD It was raised in the industry workshops that text message capability on the MIHD, to act as a communications channel from Supplier to Customer, would be a useful functionality. However the CER is minded not to mandate such functionality as this is likely to increase the cost of the MIHD and Metering Infrastructure for an interim period. 4.7.3 CO2 Intensity on the MIHD The CER July 2012 Decision paper stated that it would consider the presentation of CO2 intensity on the MIHD in phase 2 of the programme. This has been assessed and the international experience shows there is little or no benefit in changing Consumers behaviour by presenting CO2 intensity, even to the well-informed, therefore the CER are minded to exclude this functionality from the MIHD. 4.7.4 Temperature on the MIHD Showing the current temperature on the MIHD was considered however the conclusion in Industry workshops was this was a useful function but it was seen as a “nice to have” and there is no clear incremental benefit in including this as a mandated requirement therefore the CER is of a view that this is excluded from any regulatory framework if it is available as a func tion ‘out of the box’ then it would be of benefit to the Consumer. 4.7.5 Budget Setting on the MIHD Also a feature in the Irish trials (see Appendix J – Experience from SM Trials and Programmes) Consumers had the facility to set an indicative daily budget which they could measure themselves against. This was part of the design input from the Consumer focus groups and cited as useful by Consumers. It is debatable that including budget setting on the in home display will add to the benefits considering the costs if included in the design . Illustrative Appliance Consumption on the Smart Bill 16 http://www.cer.ie 57

  53. The Presentation of Energy Usage Information (SB, MIHD and CWI) This was a feature of the Energy Statement provided in the Irish trials (see Appendix J – Experience from SM Trials and Programmes). It was noted the lack of knowledge Consumers had with regard to electricity consumed by general household appliances and that Consumers found it useful to have general information on appliance energy usage but would prefer the information to be more accurate regarding the actual appliances they had rather than the average appliance. It was concluded in the industry workshops that there are better more accurate ways of presenting this information to Consumers and offerings from Energy Suppliers’ Energy Services are a more appropriate channel for this information to get to the Consumer. 58

  54. The Presentation of Energy Usage Information (SB, MIHD and CWI) 5 Other Policy Considerations 5.1 Introduction There are a number of policy considerations beyond those already defined in the paper above. In the following section the CER sets out some of these items for discussion. 5.2 Timescale for MIHD support The MIHD will be installed by ESB Networks who will then provide maintenance and support for the device. The period set for this maintenance and support is two years, as set out in the CER July 2012 Decision paper (CER/12/008 p.59 4.3.9 6d&e), which stated that: “The IHD device will be supported for two years after its installation date (i.e. repairing or replacing faulty devices). Over time devices in the home should be able to receive the consumption data from the smart meter”. During the development process, there has been some discussion within the stakeholder workshops regarding both whether that timescale is appropriate and what should happen after that period ends. Suggestions have included:  Rather than having a rolling support and maintenance arrangement from the point of installation, to consider supporting the MIHD up to a fixed strategic date in time when the full solution is in place and the key policy changes have occurred. This could be set as some point after: o both gas and electricity smart meters are installed, and MIHD and TOU is implemented; or, o the last meter has been rolled out; or, o an acceptable level of smart meters has been installed (e.g. 80%)  Suppliers to roll-out their own devices which meet MIHD requirements after the support period has finished; The challenge for the industry is to ensure the continuity of service and positive Customer experience through the transition. In stakeholder discussions there have been mixed views, some of the issues are captured below:  There may be challenges for Suppliers in taking over the support of ESBN assets after any support period (although many MIHDs could still work for several years after the support period has finished); 59

  55. The Presentation of Energy Usage Information (SB, MIHD and CWI)  MIHDs are a network owned asset, therefore there are questions regarding how any transfer of asset ownership would work or whether assets remain under ESBN ownership; and,  Information provided in the home cannot rely solely on the internet to get enriched data on devices other than the MIHD. As previously stated the decision made in the July 2012 Decision paper is to have a 2 year mandate for the support and maintenance of the MIHD. CER are requesting feedback and comments in relation to this mandate. Question 8a: What are your views with regard to a 2 year support and maintenance period? Should the MIHD be supported for a shorter or longer period of time? to a fixed date? Please provide reasons. Question 8b: What are your views with regard to options for supporting the provision of energy usage information within the home post the mandated support period of the MIHD? 5.3 Provision of Energy Consumption Data Where Smart Meters Are Not Installed The Energy Efficiency Directive 2012/27/EU Article 10(3)(a) states that independently of whether smart meters are installed or not, Member States are required to ensure that information on energy billing and historical consumption is available and is made available to the Consumer if they request it. This provision will need to be notified to the EU by 5 th June 2014. The CER will work closely with the DCENR (The Department of Communications, Energy and Natural Resources) on the transposition of the EED. The CER are minded to introduce this obligation into regulation to align with the EU deadline of 5 th June 2014. 5.4 Frequency of Billing The frequency of billing was left open in the CER July 2012 Decision paper, which stated: ‘After taking into account the results of the Customer behaviour trials and associated cost-benefit analyses the CER is proposing to leave it to the market place to determine billing frequency but are cognisant of potential future EU legislative developments in this area.’ The interpretive notes for the transposition of the Energy Efficiency Directive have 60

  56. The Presentation of Energy Usage Information (SB, MIHD and CWI) stated: ‘ Where a smart metering system is available to final Customers, the provisions of the 3rd Internal Market Package for electricity and gas 17 continue to apply. According to an interpretative note published by the Commission on 22 January 2010, where smart metering is available to final Customers, billing information based on actual consumption should be provided on a monthly basis’. The CER intend to review this provision in the transposition of the Energy Efficiency Directive 2012/27/EU 18 . Question 9: What are your views on the benefits to Consumers of the frequency of informative billing? Should this be ‘not less’ or ‘not more than’ per Customer type or should it be specific where smart meters are installed e.g. monthly? 17 Directive 2009/72/EC and Directive 2009/73/EC. 18 http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2012:315:0001:0056:EN:PDF 61

  57. The Presentation of Energy Usage Information (SB, MIHD and CWI) 6 Data Availability and Protection 6.1 Introduction As this consultation concerns the provision of information to consumer, it follows that data, and access to that data, is an essential part of this. There are different data needs associated with the different requirements set out in Section 0, and these are specified in each requirement. Many of those related to Smart Billing and the Customer Web Interface would be satisfied by Suppliers and Networks having access to the Consumer ’ s interval data. Others relate to the need for the MIHD to be able to access real-time consumption data from the Metering Infrastructure on demand. Both of these are key working assumptions set out in the SSM consultation paper. Suppliers already have access to consumer’s energy consumption data through conventional meters and are used to operating within the framework provided by the Data Protection Act 1988 and 2003 (DPA). Similarly, Network operators are required to have policies and procedures in place to ensure the security and integrity of the network is protected at all times. It is of paramount importance to the NSMP to ensure the additional information from Smart Meters is appropriately controlled and accessed and all privacy and security issues are properly addressed. There are also some other Data Protection items under consideration within the NSMP. In particular consideration needs to be given with regard to the data protection considerations of Consumers’ data at change of tena ncy or legal entity where risks exist relating to the potential retention of information presented on the MIHD. If it is deemed that there are data protection risks associated with retention of data (e.g. historical data prior to the Change of Tenancy), then alternative arrangements may need to be sought (e.g. restriction of data provision or re-set of data at the MIHD). In addition, there are options in relation to the provision of the Customer Web Interface (see section 4.5) in that it could be provided by Networks, Suppliers or both but will be accessed by the Consumer and potentially indirectly by 3 rd Parties offering other services to the Consumer. There are likely to be differing data protection considerations depending on where and how the data is accessed. The approach for how data protection considerations will be taken forward is outlined below. 6.2 Data Protection Approach From a data protection perspective, it is the industry participant’s role to ensure that the processing of data complies with the provisions of the DPA. In the NSMP December 2012 Information Paper on Data Protection it was signalled that one of the key areas of focus for the NSMP during Phase 2 will be the development of a set of regulatory policy decision papers, which will include a paper on Data Protection, following intensive key stakeholder engagement. 62

  58. The Presentation of Energy Usage Information (SB, MIHD and CWI) To this end, the NSMP intends to work with industry and stakeholders over the coming months working on Data Protection. One of the key work areas for this stage will be a full review of the requirements for data control and access rights, data storage, data sharing and data use following an intensive period of stakeholder workshop engagement. The NSMP will retain a strong focus on smart metering data protection and one of the key work areas for this stage will be the development of the regulatory policy and framework for data protection underpinning the entire smart metering solution. Question 10a: What are your views on the data protection approach set out above? Question 10b: Are there any other data protection considerations the CER should consider in relation to the requirements set out in section 0? 63

  59. The Presentation of Energy Usage Information (SB, MIHD and CWI) Appendix A – Consolidated List of Questions The aim of this section is to allow for a “short - cut” option for respondents to submit their comments to the CER. The CER invite you to complete the table to indicate your position on the questions asked in this consultation paper. Appendix A is also available in word format on the CER website here. Please note: You are in no way obliged to respond to the questionnaire provided and are welcome to submit comments in your preferred format. When responding, please indicate which question or proposal your text refers to. 1. Evaluation Criteria Question/ Proposal Yes No Comments Q1. Is there anything you would add or remove from these evaluation criteria? 2. General questions on all requirements Q2a. What are the respondents’ views Q2b. Please provide your views on the in regards to the definition of each of relative impact assessment of the the requirements below? Are there any different options delivering each Requirement requirements that should be dropped? requirement in terms of the alignment to the evaluation criteria in the template table provided below. SBR01: Energy Statement Arrangements and Communication Method SBR02: Electricity and Gas Time of Use Information SBR03: Year-on- Year Energy Usage Comparison SBR04: Additional Contact information SBR05: Hints and Tips 64

  60. The Presentation of Energy Usage Information (SB, MIHD and CWI) SBR06: Complimentary Billing Information MIHDR01: Instantaneous Active Electricity Demand (Real- Time) MIHDR02: Up to Date Consumption Position in Time Period (Cumulative) MIHDR03: Past Period Consumption Comparison (Historical) CWIR01: Access to Historical Consumption Information in a National Harmonised Format MIHDR01(a): Instantaneous Cost of Demand for the Hour MIHDR02(a): Up to Date Cost Position in Time Period (Cumulative) MIHDR03(a): Past Period Cost Comparison (Historical) MIHDR04: Ambient Feedback of Electricity Time of Use Tariffs MIHDR05: Tariff and Price Information 65

  61. The Presentation of Energy Usage Information (SB, MIHD and CWI) Question/ Proposal Comments Q2c. Are there any additional requirements that should be considered, please provide rationale and assessment? 3. Questions on specific requirements Question/ Proposal Comments Q3. What would be the least frequent level of data refresh that would be appropriate in order not to adversely affect the ability of the consumer to control their energy consumption effectively? Q4. What are the respondents’ views in regards to the definition of each of the potential requirements for display of cost and price/tariff information on the MIHD? Q5a. What are the respondents’ views in regards to the display of cost and price/tariff information on the MIHD for the options described above? Q5b. Is it a viable option for consumers to be asked to update price and/or time band information? Q5c. Would it be appropriate to expect suppliers to provide an alternative device to consumers who opt for alternative tariffs? Q6a. What are the respondents’ views with regards to the options for access to data for 3rd parties and the minded to position for the Customer to access and pass on this data? Q6b. What are respondents’ views on the options and minded to position for who is best placed to provide the national harmonised data to Customers? Q6c. Are there any alternative options that should be considered, please provide rationale and assessment? Q6d. Should there be guidance or regulation on how Customers are told that they request this data (e.g. if a 66

  62. The Presentation of Energy Usage Information (SB, MIHD and CWI) Customer contacts a supplier for data, should the supplier notify Customers they can get data from networks beyond start of contract and/or export data? Q6e. What would be the longest period that it would be appropriate for a consumer to wait to receive data through the web interface? Q6f. What would be the most appropriate national harmonised format for the data download? Q7a. What are the respondents’ views in regards to not regulating for benchmarking at this stage, but expecting this to happen in the open market and to review and revisit this in the future? Q7b. What are the respondents’ views on the presentation of micro generation information to the Consumer? What are the options? 4. Questions on other policy considerations Question/ Proposal Comments Q8a. What are your views with regard to a 2 year support period? Should the MIHD be supported for a shorter or longer period of time, to a fixed date or any alternatives? Please provide reasons. Q8b. What are your views with regard to options for supporting the provision of energy usage information within the home post the mandated support period of the MIHD? Q9. What are your views on the benefits to Consumers of the frequency of informative billing? Should this be ‘not less’ or ‘not more than’ per Customer type or should it be specific where smart meters are installed e.g. monthly? 1. Data Availability and Protection 67

  63. The Presentation of Energy Usage Information (SB, MIHD and CWI) Question/ Proposal Comments Q10a. What are your views on the data protection approach set out above? Q10b. Are there any other data protection considerations CER should consider in relation to the requirements set out in section 0? Evaluation criteria template table for reference N/A – to be covered in programme wide cost benefit analysis Cost Impact Benefit Customer Experience Consistency with Steady State Model Scalable, Future Proof & flexible in supporting competition and innovation 68

  64. The Presentation of Energy Usage Information (SB, MIHD and CWI) Appendix B – Glossary of Terms Term Description Metering The Metering Infrastructure relates to the components Infrastructure to be procured by Networks. The scope of the Metering Infrastructure includes all the components required to facilitate data processing from and including the Meter Data Management Systems (MDMSs) to the Meters and MIHD (inclusive). BGN Bord Gáis Networks CSI This is the workstream responsible for delivering this consultation paper and CSI stands for:  Consumer Web Interface  Smart Billing  [Mandated] I n-Home Display CWI Consumer Web Interface DCENR Department of Communications, Energy and Natural Resources ESBN Electricity Supply Board Networks ESM Electricity Smart Meter G4 G4 Gas Meter Category GSM Gas Smart Meter. Communicates to the ESM over the U-HAN IHD In-Home Display MIHD Mandated In-Home Display as provided and supported by ESBN. Communicates with the ESM via the U-HAN. Non-Utility HAN / In-Home communication between devices not Consumer-HAN associated with the ESM or the Metering (C-HAN) Infrastructure. Real-Time This reflects the near real-time indication of information on the MIHD, called real-time to reflect the dynamically updated nature of the information. NSMP National Smart Metering Programme SME Small to Medium Enterprise SSM Steady State Model Time of Use – relates to tariffs that are charged at TOU different prices for different periods (e.g. day, week, month, season, etc.). A separate workstream in the TUoS Transmission Use of System Utility-HAN In-Home communication between the ESM and (U-HAN) specific securely paired devices. WAN Wide Area Network (a communication method from devices in the field to a central collection point) 69

  65. The Presentation of Energy Usage Information (SB, MIHD and CWI) 70

  66. The Presentation of Energy Usage Information (SB, MIHD and CWI) Appendix C - References Decision Paper CER/12/008 Smart Metering Decision Paper cer12092.pdf Smart Metering Information Paper and Appended Reports: Smart Metering Information Paper and Appended Reports Smart Metering Trial Data Publication. Gas Smart Metering Reports: Smart Metering Information Paper 5 cer11180.pdf Gas Customer Behaviour Trials Findings Main Report cer11180 Gas Customer Behaviour Trials Findings Report- Appendix 1 cer11180 Dual Fuel Technology Trials Findings Report cer11180 Gas Cost-Benefit Analysis Report cer11180 Electricity Smart Metering Reports: Smart Metering Information Paper 4 cer11080.pdf Electricity Smart Metering Technology Trials Findings Report cer11080 Electricity Smart Metering Cost-Benefit Analysis (CBA) Report (CBA) Report, Smart Metering Customer Behaviour Trails (CBT) Findings Report (part 1) (CBT) Findings Report (part 1), Customer Behaviour Trials Findings Report (Part 2) (Part 2), Empower Demand Report – European Smart Metering Industry Group (ESMIG) The potential of smart meter enabled programs to increase energy and systems efficiency: a mass pilot comparison. 71

  67. The Presentation of Energy Usage Information (SB, MIHD and CWI) Appendix D – Evidence to Evaluate Only Showing Consumption Information on the MIHD Introduction Information requirements for the MIHD can be split into those showing cost related information and those showing only consumption related information. In the requirements currently under consideration, those based on cost are as follows:  Instantaneous cost based on active electricity demand for the hour;  Cumulative cost for a defined time period (day, week, month);  Past period cost comparisons (day, week, month);  Ambient and numerical feedback of the prevailing tariff (this would show consumption level if cost information not available); and,  Tariff and Price information with tariff banding linked to the ambient feedback. While those based on non-cost information are:  Instantaneous active electricity demand (kW);  Cumulative consumption for a defined time period (day, week, month); and,  Past period consumption comparisons (day, week, month). The ability to show accurate cost related information is dependent on the ability to source price data from the Metering Infrastructure and on the decisions to be made on Time of Use tariffs, specifically how unconstrained and variable they may be. These dependencies and the options associated with them are explored in the “MIHD Presentation of Cost” Discussion Paper. As set out in that paper, there is a possibility that it will be difficult or costly to obtain sufficiently robust and accurate price/tariff data for the MIHD to show cost information and therefore it is important to understand whether there is still evidence of benefits to support a MIHD even if it cannot show cost related information. Analysis of Available Evidence There are three key sources of evidence used in our consideration of requirements on the MIHD:  the Irish Customer Behaviour Trials carried out to specifically inform this Programme;  the GB Smart Metering Programme which is currently on-going; and,  a cross-range of international trials based on the Empower report produced by VaasaETT. 72

  68. The Presentation of Energy Usage Information (SB, MIHD and CWI) Irish Trials The Irish trials used an electricity IHD that showed current consumption and cost, current tariff period through colour-coded ambient feedback (red for peak, amber for shoulder, green for off-peak) and cost for the month so far, as well as including a budget setting mecha nism. The gas IHD showed the last half hour’s consumption and cost as well as a graph showing consumption over the day by half-hour. While it is possible to say that the IHD overall had a positive impact on energy reduction, it is not possible to quantitatively split out the relative impacts of cost and non-cost based information. A qualitative evaluation of the trial based on feedback from participants found that cost was seen as a more useful indicator than energy consumption as it was easier for Consumers to understand and could be related back to the bill which was of prime concern. In particular Consumers found it useful to see the current cost of consumption as well as some cumulative view of cost for the last day, week or month – cost since the last bill was also seen as useful. Information on tariffs was seen as key by electricity users with Consumers liking the use of ambient feedback for showing a RAG status of tariff periods. While the feedback suggests that cost was much preferred to consumption in the trial, it should be noted that cost was the primary method of feedback based on the outcomes of focus groups before the trials which determined the design of the trial IHD. GB SMETS 2 Requirements In GB the SMETS version 2 set out the following information requirements, all of which include cost information except for ambient feedback which is based on consumption.  Active tariff price  Cumulative consumption & cost  Historic consumption & cost  Instantaneous Active Power Import – demand & cost  Ambient feedback of consumption (indication of active power as high, medium or low Therefore in GB, it is clear that cost is seen as an important driver of a successful IHD. However, it should be borne in mind that in GB price information is available from the meter as this is a key requirement due to the regulatory model and retail market structure. International Experience The VaasaETT Empower report is an international pilot study comparison which includes 30 trials that tested IHDs. This report found that cumulative consumption (100% of trials), cumulative cost (56%), and past period comparisons of consumption (53%) were the most commonly used functionalities. The qualitative assessment questions the value of consumption-only data due to the difficulty for Consumers in 73

  69. The Presentation of Energy Usage Information (SB, MIHD and CWI) understanding values in kWh and because cost is what matters to Consumers. However, it seems that the principle that lowering consumption is likely to reduce cost is something that Consumers should be able to grasp, and therefore a basic understanding of the association between the kWh value changing and their cost changing is certainly feasible. This assessment seems to be supported by the quantitative data where different IHD trials are assessed against each other as shown in the Figure 1 below. While trials that presented all three of the most common information types had the largest reduction (10%), trials that only showed cumulative consumption still managed to save an average of 7%, compared with just 6% for trials that showed cost as well. Furthermore trials that showed cumulative and historical consumption (with no cost) saved an average of 9%. While these results should be caveated by the fact that individual circumstances in the trials would have differed and that other information would also have been shown on the IHD in some of the trials, these results suggest that there is a significant benefit associated with IHDs even without cost related data being shown. However, it is important to note that this only refers to overall reduction, rather than peak reduction, and that cost may still be more effective than consumption in reducing peak usage in combination with TOU tariffs. Figure 6 - Assessment of different IHD feedback combinations by energy conservation Examples of a non-cost approach to the IHD include the following two trials:  The Dutch Home Energy Management System Trials were conducted in 2008, for 15 months with 304 participants. Participants had an IHD showing 74

  70. The Presentation of Energy Usage Information (SB, MIHD and CWI) cumulative consumption and past period consumption comparisons. This was combined with education and surveys through the trial. The consumption reduction over the course of the trial was 7.8%.  Sacramento’s Residential Energy Use Behaviour Change Pilot was also carried out in 2008, over 20 months with a total of 35,000 residents. The feedback format was the IHD which presented information on cumulative consumption, historical comparison, and peer comparison. In this case the overall consumption reduction in the trial was 2.5% Conclusion The Irish trials and GB requirements both provide limited evidence for the consideration of non-cost information on the IHD. A qualitative assessment of the Irish trials suggests a strong preference for cost information but this is based on an IHD that was driven by initial focus group feedback that stated this preference, so that consumption based feedback was not really tested properly. GB requirements include cost and consumption data for all information requirements other than ambient feedback. However, international trial experience does support the case that an IHD only showing consumption based data can deliver significant reductions in overall energy consumption (though this does not necessarily apply to peak reductions), especially if combined with past period comparisons also based on consumption. Trials in Sacramento and the Netherlands offer further detail of where this has been successful. Therefore, in summary, while there is good evidence that Customers prefer to see cost information if possible, it would seem that there is also strong evidence of benefits to support a MIHD based only on non-cost related information. 75

  71. The Presentation of Energy Usage Information (SB, MIHD and CWI) Appendix E – Example Customer Web Interfaces Regarding the Customer Web Interface we have drawn on the experience of other countries where web interfaces are used to enable Consumers to make informed decisions regarding their energy consumption. The cases we have used are services offered by Origin Energy 19 in Victoria, Australia and PG&E 20 in California. Both offer web based services to domestic Consumers to manage their energy consumption. Origin Energy offers their Customers a free online service called Origin Smart Energy Manager. To be eligible for the service you need to have an active smart meter installed. Features include: PG&E offer My Energy to its Customers to manage their usage which is a free service 19 Origin Energy – Victoria, Australia http://www.originenergy.com.au/4204/Features 20 PG&E California http://www.pge.com/myhome/myaccount/welcome/ 76

  72. The Presentation of Energy Usage Information (SB, MIHD and CWI) offered to their Customers who have a smart meter. Features Include: Access to Energy Consumption Information PG&E responded to the challenge from the White House to design a standard format for Customers to access energy usage data online. PG&E launched what's called the Green Button in 2011. It is one of the first utilities in the country to provide these services. They state that “making detailed energy usage information available in a standardised format encourages awareness of energy usage as well as innovation among third parties for new Customer- focused applications”. Green Button allows Customers to download their personal energy usage data as well as allowing developers and third parties to receive energy usage data from Customers in machine-readable form. On the matter of access for 3rd parties the aspiration is that allowing access to Consumer energy usage data will encourage app developers to create innovative ways for Consumers to relate to and manage their energy usage. “PG&E’s goal is to make authorized, recurring, machine -to-machine, programmatic data access available to Customers and their authorized third- party service providers.” 77

  73. The Presentation of Energy Usage Information (SB, MIHD and CWI) Appendix F – The Electricity and Gas Supplier Handbook The Electricity and Gas Suppliers Handbook 21 places obligations on Suppliers and provides a Code of Practice on Customer Billing. Provisions of the code of practice potentially relevant to smart billing include the following: Ref Ref in Statement Source Paper SBSH 12.1 Suppliers will ensure that all bills, scheduled or otherwise, are accurately calculated based on one of the following: a) Actual readings provided by the Electricity Network Operator/Gas Network Operator, or b) Customer Readings, where appropriate (where Suppliers receive Customer meter readings directly they are to be forwarded to the Electricity Network Operator/Gas Network Operator), or c) Supplier or MRSO/GPRO generated estimates, where appropriate (where a Supplier chooses to generate their own estimates that Supplier must be able to demonstrate that information provided by the Electricity Network Operator and the Gas Network Operator has been used to ensure estimates are as accurate as possible). SBSH 12.1.6 Where a Supplier offers electronic billing to Customers, a Customer must opt into this type of billing format unless specified in the Supplier’s terms and conditions of supply. SBSH 12.3.1 Changes in tariffs will be clearly indicated on the bill and the method of application will be explained on the bill or in an accompanying insert (this may be an electronic notice where a Customer has chosen this method of billing). Historical consumption information – in line with the industry code for SBSH 12.4.3 (a) presentation of historical consumption information. SBSH 12.4.3 (g) Clear calculations of the amount due for electricity/gas supplied, (giving units, multipliers, rates etc. where appropriate), including any rebates or penalties, etc., standing charge and any other amounts being invoiced being clearly separated (e.g. servicing). SBSH 12.5.2 If the Supplier presents information on electricity and natural gas charges on one bill, each charge must be clearly identifiable. SBSH 12.5.3 Where charges for electricity and natural gas are presented on two separate bills a cover statement summarising the total amount on the account may be included. The cover statement should clearly show the total amount due and the date payment is due. SBSH 12.5.6 Where a Supplier offers a dual fuel account, it must be clear to the Customer how payment is allocated against the account for gas and/or electricity. The Supplier must make it clear to the Customer how their account will be managed in the event that the Customer does not pay their bill in full. Table 4 - The Electricity and Gas Supplier Handbook 21 CER Electricity and Natural Gas Supplier Handbook http://www.cer.ie/GetAttachment.aspx?id=46ddf3e2-90d3-4f18-8191-c02f46ee1304 78

  74. The Presentation of Energy Usage Information (SB, MIHD and CWI) Appendix G – NSMP Background The National Smart Metering Programme A smart meter is an electronic device that can measure the consumption of energy, record and store more information than a conventional meter and provide real time information to the Consumer on usage. In addition to European energy efficiency targets, there are a number of key EU legislative instruments which require that Consumers are properly informed of actual energy consumption and costs frequently enough to enable them to regulate their energy consumption. Smart meters can contribute to these targets by: 1. facilitating improved energy efficiency by empowering Consumers with more detailed, accurate, and timely information regarding their energy consumption and costs; 2. reducing overall energy bills by shifting any discretionary electricity usage away from (more expensive) peak consumption times; 3. reducing overall energy consumption thereby helping the environment. The CER, working closely with the Department of Communications, Energy and Natural Resources (DCENR) and industry, established Phase 1 of the Smart Metering Programme (NSMP) in late 2007. Phase 1 included a plan to conduct a nationally representative smart metering trial in order to assess the costs and benefits of smart meters and to inform decisions relating to the full rollout of an optimally designed universal National Smart Metering Programme. This work was completed in 2011 and the results are available on the CER website here. Strategic Objectives of the NSMP The National Smart Metering Programme has the following strategic objectives (which apply to both electricity and gas unless stated otherwise): 6. Encourage Energy Efficiency - encourage end-use energy efficiency via enhanced information and pricing signals, resulting in reductions in overall energy usage and thus reduced emissions of carbon dioxide, nitrogen oxides and sulphur oxides as a measure to combat climate change and reduce pollution 7. Facilitate Peak Load Management (electricity only) - Reduce demand for peak electrical power, with consequential electricity generation savings and improved security of supply. This can be achieved via pricing signals such as Time of Use tariffs, where the price of electricity varies at different times of the day to reflect the costs of producing electricity at those times. Other options include automated demand side management and direct load control (via aggregators). 79

  75. The Presentation of Energy Usage Information (SB, MIHD and CWI) 8. Support Renewable and Micro Generation (electricity only) - Assist in achieving of Ireland’s stated national targets for renewable electricity generation (40% by 2020) by facilitating demand response solutions that will complement increasing levels of intermittent wind generation on the electricity grid and to facilitate the wider take up of micro generation. 9. Enhance Competition and Improve Consumer Experience - Support more timely and efficient change of Supplier process for Consumers, and promote competition by enabling Suppliers to offer:  accurate billing;  accurate, detailed and more frequent information on their energy consumption and costs;  more innovative products to Consumers to support the efficient use of electricity (balanced by the need to protect Consumers from a proliferation of complex tariff products leading to confusion); and  a more diverse service offerings to Consumers from Suppliers including in the area of PAYG product offerings 10. Improve Network Services - Improve services to Consumers, particularly in areas such as meter reading, fault monitoring and electrical power quality. Significantly improve theft prevention and measure losses more accurately. EU Legislation There are a number of key EU legislative instruments promoting smart metering, which include the instruments listed below in this section. In this consultation paper, the CER have identified the EU instruments more targeted on the presentation of information to Customers and referenced them to our identified requirements where relevant. a) Third Legislative Package for Further Liberalisation of the Electricity and Gas Markets 22 The 3rd Package contains provisions regarding intelligent metering systems, with the aim of better informing Consumers of their consumption and helping to increase awareness of energy consumption. The implementation of those metering systems may be subject to an economic assessment of all the long-term costs and benefits to the market and the individual Consumer or of which form of intelligent metering is economically reasonable and cost-effective and which timeframe is feasible for their installation. The general principle is that Consumers must have access to their consumption data. National Regulatory Authorities (NRAs) must ensure access to Consumer consumption data, and the existence of a nationwide harmonised format for consumption data and a process for Suppliers and Consumers to access the data must be defined. Intelligent metering systems are promoted twice in the Directives: first, with the aim to 22 Third package for Electricity and Gas markets: http://ec.europa.eu/energy/gas_electricity/legislation/third_legislative_package_en.htm 80

  76. The Presentation of Energy Usage Information (SB, MIHD and CWI) promote energy efficiency and demand side management measures; second, with the aim to ensure active participation of Consumers in the market. Different provisions apply for electricity and for gas – details below. There are also a number of EU Interpretive Notes which cover smart metering published on these directives. i) Electricity - Directive 2009/72/EC (Annex 1) 23 This directive states that: 1. (i) [Member States shall ensure that Consumers] are properly informed of actual electricity consumption and costs frequently enough to enable them to regulate their electricity consumption’ 2. ‘Member States shall ensure the implementation of intelligent metering systems that shall assist the active participation of Consumers in the electricity supply market. The implementation of those metering systems may be subject to an economic assessment of all the long-term costs and benefits to the market and the individual Consumer or which form of intelligent metering is economically reasonable and cost-effective and which timeframe is feasible for their distribution. Such assessment shall take place by 3 September 2012’. Subject to that assessment, Member States or any competent authority they designate shall prepare a timetable with a target of up to 10 years for the implementation of intelligent metering systems. Where rollout of smart meters is assessed positively, at least 80 % of Consumers shall be equipped with intelligent metering systems by 2020. An EU Retail Markets Interpretive Note 24 on Electricity Directive 2009/72/EC highlights a European Commission Declaration 25 which clarifies that: “It is understood that in the case no economic assessment of the long -term costs and benefits is made, at least 80% of all Consumers have to be equipped with intelligent metering systems by 2020.” ii) Gas - Directive 2009/73/EC (Annex 1) 26 This directive states that: 23 Third Package Electricity Directive 2009/72/EC http://eur- lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:32009L0072:EN:NOT 24 Commission staff working paper - interpretative note on directive 2009/72/EC concerning common rules for the internal market in electricity and directive 2009/73/EC concerning common rules for the internal market in natural gas - retail markets - 22 January 2010 http://ec.europa.eu/energy/gas_electricity/interpretative_notes/doc/implementation_notes/2010_0 1_21_retail_markets.pdf 25 Council document 10814/09 ADD 1 REV 1 http://register.consilium.europa.eu/pdf/en/09/st10/st10814- ad01re03.en09.pdf 26 Third Package Gas Directive 2009/73/EC http://eur- lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:32009L0073:EN:NOT 81

  77. The Presentation of Energy Usage Information (SB, MIHD and CWI) 1. (i) [Member States shall ensure that Consumers] are properly informed of actual gas consumption and costs frequently enough to enable them to regulate their own gas consumption. 2. Member States shall ensure the implementation of intelligent metering systems that shall assist the active participation of Consumers in the gas supply market. The implementation of those metering systems may be subject to an economic assessment of all the long-term costs and benefits to the market and the individual Consumer or which form of intelligent metering is economically reasonable and cost-effective and which timeframe is feasible for their distribution. Such assessment shall take place by 3 September 2012. Subject to that assessment, Member States or any competent authority they designate, shall prepare a timetable for the implementation of intelligent metering systems. Proposed Energy Efficiency Directive 27 b) On 22 June 2011 the European Commission adopted a proposal for an Energy Efficiency Directive to establish a common framework for the promotion of energy efficiency across the EU, ensure the achievement of the Union's target of 20% primary energy savings by 2020 and pave the way towards the realisation of further energy efficiency beyond that date. The Directive on Energy Efficiency will amend and subsequently repeal the Cogeneration Directive (2004/8/EC, CHP Directive) and the Energy Services Directive (2006/32/EC, ESD) 28 . Given the assessment that the Union is unlikely to achieve its energy efficiency target of 20% primary energy savings by 2020 based on the current policy mix, the Commission is proposing to take a much firmer line with Member States. While there are no binding targets in the draft there are a number of binding measures. The European Commission’s proposal for a Directive on Energy Efficiency (COM(2011)370) has direct implications for the activities of regulators, who have to ensure that Consumer interests are always taken into account and that competition is not distorted. The Energy Efficiency Directive covers a range of areas including; Energy Efficiency Obligation Schemes (Article 6), Metering and informative billing (Article 8), Promotion of efficiency in heating and cooling (Article 10) and Energy Transmission and Distribution (Article 12). Directive 2005/89/EC – Security of Supply 29 c) This Directive specifies that member states may encourage “the adoption of real -time 27 EC Proposal for new Energy Efficiency Directive http://ec.europa.eu/energy/efficiency/eed/eed_en.htm 28 Article 13 of DIRECTIVE 2006/32/EC OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 5 April 2006 on energy end-use efficiency and energy services and repealing Council Directive 93/76/EEC http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2006:114:0064:0064:en:pdf 29 Article 5 (2.d.) of DIRECTIVE 2005/89/EC OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 18 January 2006 concerning measures to safeguard security of electricity supply and infrastructure investment www.energy.eu/directives/l_03320060204en00220027.pdf 82

  78. The Presentation of Energy Usage Information (SB, MIHD and CWI) demand management technologies, such as advanced metering systems” to maintain balance between electricity demand and supply. Directive 2004/22/EC - Measuring Instruments 30 d) The Directive 2004/22/EC of the European Parliament and of the Council of 31 March 2004 on measuring instruments (MID) establishes the requirements that measurement devices and systems have to satisfy before being put on the market and/or put into use. Each measuring instrument must meet the essential requirements (laid down in Annex I of the Directive) and in the relevant instrument-specific Annex. The CER July 2012 Decision Paper In July 2012, following significant consultation, analysis and trials, the CER concluded phase 1 and confirmed their decision to proceed to Phase 2 of the NSMP. The CER based this decision on the positive results of the electricity and gas smart metering trials and associated cost-benefit analyses published during 2011. The decision is further underpinned by relevant European and national legislation, which promote smart metering and outline specific related requirements. The CER July 2012 paper - 'Decision on the National Rollout of Electricity and Gas Smart Metering' (CER12092) - is available on the CER website here, and highlights a number of key policy decisions:  Rolling out electricity smart metering to all electricity residential and business Consumers currently on non-interval meters;  Rolling out gas smart metering to all gas residential Consumers and business Consumers in the G4 meter category;  Gas smart metering will leverage the electricity smart metering communications infrastructure;  Mandating the rollout of in-home display (IHD) devices to all electricity Consumers – the IHD will be capable of displaying gas information also for dual fuel Consumers;  Mandating energy usage statements (containing detailed consumption and cost information) to be provided by Suppliers to their Consumers with their electricity and gas bills;  Mandating time of use electricity tariffs for all electricity Consumers;  Enabling broader and easier access to PAYG services for electricity and gas Consumers. The paper also outlined the objectives of the NSMP and high-level requirements for the functionality of the end-to-end solution. The timeline for Phase 2 (i.e. the current phase) of the programme was also set out. 30 DIRECTIVE 2004/22/EC OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 31 March 2004 on measuring instruments http://eur- lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2004:135:0001:0080:EN:PDF 83

  79. The Presentation of Energy Usage Information (SB, MIHD and CWI) Figure 7 - NSMP Programme timeline The December 2012 Information Paper In December 2012, the CER published an Information Paper - National Smart Metering Programme Information Paper Programme Update and Initial Phase 2 Deliverables (CER/12/213) - giving further details of the programme organisation, governance, approach and timelines for the NSMP. This paper is available on the CER website here. The information paper also gave an overview of some of the completed deliverables from Phase 2 of the NSMP, namely a number of papers, which were produced as part of the High Level Design Stage 1. NSMP Work Stream Structure To facilitate the detailed requirements gathering and definition required in Phase 2 (High Level Design Stage Two), the CER identified the following work streams, which are on-going and include representation from Industry stakeholders: 1. Time of Use tariffs – seeks to define the time of use tariff mandate. 2. Consumer Web Interface, Smart Billing and [Mandated] IHD (CSI) – seeks to define the requirements required to affect Consumer consumption behaviour and the optimal communication channel to deliver these requirements. 3. Pay As You Go (PAYG) – seeks to define the requirements and optimal model for deliveri ng the ‘smart’ PAYG Consumer product. 4. Networks Led – seeks to define the core smart services to be delivered by the Networks organisations (i.e. ESBN and BGN) plus provide a high level impact analysis on the Retail Market processes. 5. NSMP Programme Team (Programme Manager, Design Authority & Market Systems Subject Matter Expert) – leveraging the working assumptions from 84

  80. The Presentation of Energy Usage Information (SB, MIHD and CWI) the above work streams; this function seeks to define an integrated smart metering solution. 6. Consumer Engagement – seeks to identify and develop Consumer interaction methods to enable the realisation of the benefits of the NSMP. 7. Data Protection – seeks to ensure data protection considerations are addressed in the design of the integrated smart metering solution. A set of decision papers representing a consistent design across all the above work streams is planned to be issued in December 2013, which will provide the next level of detail to the smart metering design in Ireland. Relevant Consultation Papers TOU Tariffs Consultation Paper Following the decision in the CER July 2012 paper to mandate time of use tariffs for all electricity Consumers, and the information report published in December, CER initiated a time of use tariff work stream, as outlined above, with the specific aim of defining the shape of the time of use tariff mandate. In advance of this Consultation Paper, the CER published CER/13/152 “Time of Use Tariffs” which seeks the views of the public and CER Stakeholders with regard to a time of use mandate for electricity tariffs, and also considers the issues and opportunities related to time of use tariffs in gas . CER/13/152 also sets out examples of how the mandate could be shaped . The conclusions of the TOU consultation is a key input to the requirements to be defined for CSI, as identified in this consultation paper. The TOU consultation is available on the CER website here. Steady State Model Paper The CER also issued a consultation on the Steady State Model (SSM) which outlines an initial ‘top down’ view of what an end -to-end Smart Metering solution may look like. The SSM has been developed based on a high level analysis of the following: 1. Identification of the strategic role which each stakeholder could perform to deliver the NSMP objectives. These ‘to - be’ roles are aligned to the current stakeholder ‘as - is’ roles and business processes. 2. Identification and alignment with a set of five Design Principles including a principle of Customer focus and a principle to acknowledge the context of the Irish Market context when defining a SSM. 85

  81. The Presentation of Energy Usage Information (SB, MIHD and CWI) 3. Review of the issues, options and requirements gathered to date across all the NSMP work streams with participation from Industry stakeholders. 4. Acknowledgement of the technology component level requirements as outlined in the July 2012 Decision paper and options considered in the December 2012 Information Papers . 5. Consideration of best practice in the design of complex technology solutions with a focus on delivering appropriate technical solutions which will minimise capital and operating cost. We are consulting on the SSM at this early stage in the Design phase to provide context and consistency across the work streams and to facilitate the development of more detailed designs in each of the other work streams over the coming months. The SSM consultation is available on the CER website here. PAYG Consultation Paper Following the decision in the CER July 2012 paper to enable broader and easier access to PAYG services and the information report published in December, CER established a work stream to determine the requirements and design for a PAYG solution. The PAYG consultation is scheduled to be issued in August 2013 in parallel or shortly after this consultation and will inform subsequent developments relating to this CSI consultation, as described and referenced in this consultation paper. The PAYG consultation is available on the CER website here. Data Protection Smart metering will deliver a step change in relation to the amount, quality and timeliness of Consumers’ (electricity and natural gas) consumption information. This increase in available data results in a number of key questions that need to be addressed regarding data protection. There are a number of key assumptions that will need to be assessed, particularly the requirement for energy consumption data recorded at half hourly intervals and provision to Suppliers on a daily basis . A number of Data Protection issues and assumptions relating to this CSI consultation are highlighted in section 6 of this paper. 86

  82. The Presentation of Energy Usage Information (SB, MIHD and CWI) Appendix H – Consultation Development Process The CER have developed this consultation document in discussion with Industry. The CER have taken the approach of gathering requirements in as unconstrained a way as possible before gathering those requirements in this document and assessing them. Originally this development work was split into three separate workstreams: for Mandated In-Home Display, Smart Bill and Customer Web Interface, but the requirements were related and therefore brought together into a consolidated workstream. Figure 8 - Requirements development process 87

  83. The Presentation of Energy Usage Information (SB, MIHD and CWI) Appendix I – Detail of Policy Drivers Relevant EU Policy The following section details relevant policy from the Energy Efficiency Directive (EED) 2012/27/EU 31 in the consideration of the requirements for Smart Billing, MIHD and Customer Web Interface. The provisions of the EED on metering and billing information take over some of the provisions of earlier Directives. Directive 2006/32/EC on energy end-use efficiency and energy services 32 (which is repealed by the EED) required Member States to ensure that final Customers are provided with competitively priced individual meters that accurately reflect their actual energy consumption and provide information on actual time of use. The directives are still subject to transposition into Irish legislation which has to be complete by June 2014. Article 9 - Metering Where, and to the extent that, Member States implement intelligent metering systems and roll out smart meters for natural gas and/or electricity in accordance with Directives 2009/72/EC and 2009/73/EC: Ref Ref in Statement Requirement Source Ref Paper EED01 Article 9 (a) they shall ensure that the metering systems provide MIHDR01 to final Customers information on actual time of use MIHDR02 and that the objectives of energy efficiency and MIHDR03 benefits for final Customers are fully taken into CWIR01 account when establishing the minimum functionalities of the meters and the obligations imposed on market participants; EED02 Article 9 (b) they shall ensure the security of the smart meters N/A and data communication, and the privacy of final Customers, in compliance with relevant Union data protection and privacy legislation; EED03 Article 9 (c) in the case of electricity and at the request of the N/A final Customer, they shall require meter operators to ensure that the meter or meters can account for electricity put into the grid from the final Customer ’s premises; 31 http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2012:315:0001:0056:EN:PDF 32 Directive 2006/32/EC of the European Parliament and of the Council of 5 April 2006 on energy end-use efficiency and energy services and repealing Council Directive 93/76/EEC, OJ L114, 24.4.2006, p.64. 88

  84. The Presentation of Energy Usage Information (SB, MIHD and CWI) Ref Ref in Statement Requirement Source Ref Paper EED04 Article 9 (d) they shall ensure that if final Customers request it, CWIR01 metering data on their electricity input and off-take is made available to them or to a third party acting on behalf of the final Customer in an easily understandable format that they can use to compare deals on a like-for-like basis; EED05 Article 9 (e) they shall require that appropriate advice and N/A information be given to Customers at the time of installation of smart meters, in particular about their full potential with regard to meter reading management and the monitoring of energy consumption. Table 5 - Article 9: Metering Article 10 – Billing Information Ref Ref in Statement Requirement Source Ref Paper EED06 Article 10 (1) Where final Customers do not have smart meters N/A as referred to in Directives 2009/72/EC and 2009/73/EC, Member States shall ensure, by 31 December 2014, that billing information is accurate and based on actual consumption, in accordance with point 1.1 of Annex VII, for all the sectors covered by this Directive, including energy distributors, distribution system operators and retail energy sales companies, where this is technically possible and economically justified. EED07 Article 10 (2) Meters installed in accordance with Directives N/A 2009/72/EC and 2009/73/EC shall enable accurate billing information based on actual consumption. Member States shall ensure that final Customers have the possibility of easy access to complementary information on historical consumption allowing detailed self- checks. Table 6 - Article 10: Billing Information Complementary information on historical consumption shall include: Ref Ref in Source Statement Requirement Paper Ref EED08 Article 10 2(a) cumulative data for at least the three previous years or the SBR06 period since the start of the supply contract if this is shorter. The data shall correspond to the intervals for which frequent billing information has been produced; and 89

  85. The Presentation of Energy Usage Information (SB, MIHD and CWI) Ref Ref in Source Statement Requirement Paper Ref EED09 Article 10 2(b) detailed data according to the time of use for any day, CWIR01 week, month and year. These data shall be made available to the final Customer via the internet or the meter interface for the period of at least the previous 24 months or the period since the start of the supply contract if this is shorter. Table 7 – Article 10: Complimentary billing information Independently of whether smart meters have been installed or not, Member States: Ref Ref in Source Statement Requirement Paper Ref EED10 Article 10 3(a) shall require that, to the extent that information on the CWIR01 energy billing and historical consumption of final Customers is available, it be made available, at the request of the final Customer, to an energy service provider designated by the final Customer; EED11 Article 10 3(b) shall ensure that final Customers are offered the option of SBR01 electronic billing information and bills and that they receive, on request, a clear and understandable explanation of how their bill was derived, especially where bills are not based on actual consumption; EED12 Article 10 3(c) shall ensure that appropriate information is made SBR01 available with the bill to provide final Customers with a comprehensive account of current energy costs, in accordance with Annex VII; EED13 Article 10 3(d) may lay down that, at the request of the final Customer, SBR01 the information contained in these bills shall not be considered to constitute a request for payment. In such cases, Member States shall ensure that Suppliers of energy sources offer flexible arrangements for actual payments; EED14 Article 10 3(e) shall require that information and estimates for energy N/A costs are provided to Consumers on demand in a timely manner and in an easily understandable format enabling Consumers to compare deals on a like-for-like basis. Table 8 – Article 10: Billing Information regardless of smart meter installation Annex VII - Minimum requirements for billing and billing information based on actual consumption Minimum requirements for billing: Ref Ref in Source Statement Requirement Paper Ref 90

  86. The Presentation of Energy Usage Information (SB, MIHD and CWI) Ref Ref in Source Statement Requirement Paper Ref EED15 Annex VII 1.1 Billing based on actual consumption N/A In order to enable final Customers to regulate their own energy consumption, billing should take place on the basis of actual consumption at least once a year, and billing information should be made available at least quarterly, on request or where the Consumers have opted to receive electronic billing or else twice yearly. Gas used only for cooking purposes may be exempted from this requirement. EED16 Annex VII 1.2 Minimum information contained in the bill N/A Member States shall ensure that, where appropriate, the following information is made available to final Customers in clear and understandable terms in or with their bills, contracts, transactions, and receipts at distribution stations: EED17 Annex VII 1.2(a) current actual prices and actual consumption of energy; SBR02 comparisons of the final Customer ’s current energy EED18 Annex VII 1.2(b) SBR03 consumption with consumption for the same period in the previous year, preferably in graphic form; contact information for final Customer s’ organisations, EED19 Annex VII 1.2(c) SBR04 energy agencies or similar bodies, including website addresses, from which information may be obtained on available energy efficiency improvement measures, comparative end-user profiles and objective technical specifications for energy-using equipment. EED20 Annex VII 1.2 In addition, wherever possible and useful, Member SBR07 States shall ensure that comparisons with an average normalised or benchmarked final Customer in the same user category are made available to final Customers in clear and understandable terms, in, with or signposted to within, their bills, contracts, transactions, and receipts at distribution stations. 91

  87. The Presentation of Energy Usage Information (SB, MIHD and CWI) Ref Ref in Source Statement Requirement Paper Ref EED21 Annex VII 1.3 Advice on energy efficiency accompanying bills and SBR04 other feedback to final Customers When sending contracts and contract changes, and in the bills Customers receive or through websites addressing individual Customers, energy distributors, distribution system operators and retail energy sales companies shall inform their Customers in a clear and understandable manner of contact information for independent Consumer advice centres, energy agencies or similar institutions, including their internet addresses, where they can obtain advice on available energy efficiency measures, benchmark profiles for their energy consumption and technical specifications of energy using appliances that can serve to reduce the consumption of these appliances. Table 9 - Annex VII: Minimum requirements for billing and billing information Article 11 – Cost of access to metering and billing information Ref Ref in Source Statement Requirement Paper Ref EED22 Article 11 (1) Member States shall ensure that final Customers CWIR01 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. Table 10 – Article 11: Cost of access to Consumer information Article 12 - Consumer information and empowering programme Ref Ref in Source Statement Requirement Paper Ref EED23 Article 12 (1) Member States shall take appropriate measures to SBR05 promote and facilitate an efficient use of energy by small energy Customers, including domestic Customers. These measures may be part of a national strategy. EED24 Article 12 (2) For the purposes of paragraph 1, these measures shall SBR05 include one or more of the elements listed under point (a) or (b): EED25 Article 12 (2)(a) a range of instruments and policies to promote SBR05 behavioural change which may include: (iii) Information provision 92

  88. The Presentation of Energy Usage Information (SB, MIHD and CWI) Ref Ref in Source Statement Requirement Paper Ref EED26 Article 12 (2)(b) ways and means to engage Consumers and Consumer SBR05 organisations during the possible roll-out of smart meters through communication of: (i) cost-effective and easy-to-achieve changes in energy use; (ii) information on energy efficiency measures. Table 11 - Article 12: Consumer engagement Key Points from the CER July 2012 Decision Paper The following excerpts are the relevant key statements of intent from the 4 th July 2012 Decision Paper (CER12092.pdf 33 ) for the three methods highlighted for Consumer information presentation. We have split these decision paper references between the three different policy areas so that the CER can assess the optimum solution for each. Note: the references in the table below have been added to aid the cross referencing within this document and to demonstrate coverage of all decisions in our requirements Smart Billing Related Decisions Ref Ref in Statement Requirement Source Ref Paper “The CER welcomes the general support for the SJDP1 4.3.4.2 4.3 proposal to mandate energy statements for Consumers with their bills but notes that some Suppliers expressed concerns, preferring to retain control and flexibility in terms of billing and energy information provision to their Customer s” SJDP2 4.3.9 (4a.) Consumer must receive an energy statement with 4.3 their energy bills – minimum content requirements will be determined during the Design stage, taking into account requirements from relevant EU and national legislation 33 CER July 2012 Decision Paper http://www.cer.ie/GetAttachment.aspx?id=f679ca6a-e20b-42a9-abea-a2df95a8c3cd 93

  89. The Presentation of Energy Usage Information (SB, MIHD and CWI) Ref Ref in Statement Requirement Source Ref Paper SJDP3 4.3.9 (4b.) Following trial results and associated CBAs, the 4.3 CER has decided to leave it to the market place to determine billing frequency subject to ongoing review and cognisant of potential future EU legislative development in this area SJDP4 4.3.4.2 The CER would like to once again reiterate that 4.3 provision of energy statements need not be paper- based. If a Consumer opts in to receive there bill electronically then the energy statement would also be electronic. SJDP5 4.3.4.2 The CER would like to clarify that Consumers on 4.3 prepayment Services would also receive energy statements as part of the mandate. Table 12 - Smart billing related decisions In Home Display Related Decisions Ref Ref in Statement Requirement Source Ref Paper IJDP1 4.3.3.2 Primarily by the fact that the combined electricity 4.4 and gas cost-benefit analyses have demonstrated that there is an incremental positive net benefit to be achieved from including an IHD as part of the national rollout of smart metering i.e. the additional costs involved in purchasing, rolling out and supporting (for a limited period) IHDs is more than outweighed by the additional benefit to be gained by Consumers from having such a device in their homes providing near real-time, as well as historical, information on their energy usage and costs. IJDP2 ES (iii) Mandating the rollout of in-home display (IHD) 4.4 devices to all electricity Consumers – the IHD will be capable of displaying gas information also for dual fuel Consumers. IJDP3 4.3.9 3d Consumers will receive cost and usage based 4.4 consumption information via in home displays (IHD) and energy statements (with their bills). IJDP4 4.3.9 6a In-home displays (IHDs) will be provided to all 4.4 energy Consumers as part of the full rollout during their electricity smart meter installation. IJDP5 4.3.9 6b The IHDs will cater for dual fuel Consumers. 4.4 Definition of the IHD’s minimum functionality will IJDP6 4.3.9 6c 4.4 be determined during the Design stage. IJDP7 4.3.9 6d The IHD device will be supported for two years 5.2 after its installation date (i.e. repairing or replacing faulty devices). 94

  90. The Presentation of Energy Usage Information (SB, MIHD and CWI) Ref Ref in Statement Requirement Source Ref Paper IJDP8 4.3.9 6e Over time other devices in the home should be To be able to receive the consumption data from the considered in smart meter. SSM2 consultation IJDP9 5.2 It will also provide additional functionality to 4.4 provide near real-time communications (one-way and two-way) between an in-home display (IHD), or equivalent device, and smart metering systems. IJDP10 5.2.2.3 The gas meter may also be required to provide 4.4 energy usage interval data (in kWh) for the IHD depending on the final detailed design. IJDP11 5.2.2.3 Calorific Value where required (can be used by in- N/A home ancillary equipment or IHD for the conversion of volume output data from the meter into energy values - kWh) IJDP12 5.3.1.3 The IHDs will be procured on an ownership or N/A service provision basis. IJDP13 5.3.1.3 The CER will approve the minimum functional N/A requirements and the procurement strategy. IJDP14 5.3.1.3 ESB Networks will own the contract for the IHD N/A and be responsible for their procurement for all Consumers. IJDP15 4.3.3.2 Regarding the request for the IHD to be able to 0 cater for CO2 intensity of electricity data (and energy statements) this can be explored further during the design stage of Phase 2. However, as noted previously, catering for displaying consumption data of other fuels (oil/LPG) and water are out of scope and hence the request for these to part of the IHD data requirements cannot be accommodated. IJDP16 4.3.3.2 Provision of an IHD will also provide the potential N/A for an instant positive impact to be made on Consumers from the installation of smart metering The CER views the MIHD as a ‘stepping stone’ IJDP17 4.3.3.2 N/A channel that will kick-start active Consumer interest and engagement in accessing energy information available from smart metering. IJDP18 4.3.3.2 It should also be reiterated that the smart metering To be solution will not preclude the secure connection of considered in other ‘non - mandated’ IHDs to the smart metering SSM2 data. Suppliers or other third parties are free to consultation offer Consumers higher spec’ IHD models. Table 13 - In Home Display related decisions Customer Web Interface Related Decisions Ref Ref in Statement Requirement Source Ref Paper 95

  91. The Presentation of Energy Usage Information (SB, MIHD and CWI) Ref Ref in Statement Requirement Source Ref Paper CJDP1 4.3.2.2 The proposal is retained that a data portal will be 4.5 provided through which Suppliers can access data for their Customers, updated daily, on a push and/or pull basis subject to their requirements. Phase 2 will be used to explore further how this can be facilitated and ensure that it is technically and economically feasible. CJDP2 4.3.2.2 The details of the data portal(s) and how it caters 4.5 for Suppliers and/or Consumers requirements will be elaborated upon in Phase 2. CJDP3 4.3.9 2a Data portal will be provided through which 4.5 Suppliers can access data for their Customers, updated daily, on a push and/or pull basis subject to their requirements (assuming this is technically and economically feasible – Design stage of a full rollout would explore this further, as well as the fair processing requirements of the Data Protection Acts). CJDP4 4.3.9 3a The Consumer owns their consumption data 4.5 generated by smart metering and they should have access to the information in relation to their historical consumption data in a national harmonised format, free of charge – this may be via the same data portal assumed to be used by Suppliers (design stage of a full rollout would explore this further). CJDP5 4.3.9 3b Consumers will have the right to provide their 4.5 detailed historical consumption data to other Suppliers in order to get an alternative quote for their supply (design stage of a full rollout would explore how this is facilitated). CJDP6 4.3.9 3c Consumers can give permission to other third 4.5 parties to access their detailed historical consumption data e.g. for energy management services (design stage of a full rollout would explore how this is facilitated). CJDP7 5.3.1.3 Model for procurement and management of the N/A wide area network (WAN) and back-end IT systems (including meter data management system (MDMS) and Web portal): CJDP8 5.2.4 The back-end IT Systems to manage smart N/A metering will consist of systems to manage the meters and communications infrastructure including: • A local data collector or concentrator • A Head End System(s) to manage the communications infrastructure • A Meter Data Management System (MDMS) - the MDMS system will interface with all other systems via a Middleware Hub or Enterprise Service Bus solution. 96

  92. The Presentation of Energy Usage Information (SB, MIHD and CWI) Ref Ref in Statement Requirement Source Ref Paper CJDP9 5.2.4 The back-end IT systems issues and requirements N/A will be driven by the outcomes of decisions made in relation to the functional requirements. This area was therefore not a subject for consultation proposals as part of CER/11/191. The Design stage of Phase 2 will examine the requirements for back-end IT systems functionality in greater detail. Table 14 - Customer Web Interface related decisions 97

  93. The Presentation of Energy Usage Information (SB, MIHD and CWI) Appendix J – Experience from SM Trials and Programmes Irish Customer Behaviour Trials Approach The Irish National Smart Meter Programme ran pilot trials to understand the potential for Smart Meter technology to affect measurable change in Consumer behaviour in order to reduce peak and overall demand. In terms of Consumer information, the results of the Customer behaviour trials were used to inform the requirements gathering process for the MIHD and the Smart Bill in particular, in addition to other aspects such as Time of Use tariffs. The specification of the Customer Behaviour Trials 34 for Electricity and Gas measured the potential reduction in peak and overall demand realisable through the use of smart meters in combination with detailed billing on a bi-monthly or monthly frequency, in conjunction with detailed energy statements, IHDs and overall load reduction (OLR) incentive and Web access (to SMEs for electricity). Deployment of time of use tariffs was central to the trials. The trial approach was as follows:  Initially, focus groups were run with non-trial participants in order to assist in design of communications and the information supports such as the energy usage statement and the IHD.  A pre-trial survey of trial participants was carried out to inform the participant allocation and provide a benchmark for any subsequent change in behaviour which might be observed at the end of the trial.  A post-trial survey of the same participants was carried out to compare the change in attitude, equipment or gas usage versus the pre-trial findings.  Further information was gained through a non-response survey of those who chose not to respond to the invitation letter and an attrition survey of those who left the trial after allocation. The Electricity Residential Customer Behaviour Trials 35 The electricity residential Customer behaviour trials tested a variety of different demand-side management stimuli. Participants were split into four groups. The energy usage statement and time-of-use tariffs were common to all groups with the first group receiving this with a bi-monthly bill, the second with a monthly bill, the third with a bi- monthly bill and IHD, while the fourth also had a bi-monthly bill but this time combined with an overall load reduction incentive. These groups were also tested against four different week-day tariffs as well as a weekend tariff. A control group provided the 34 http://www.cer.ie/en/information-centre-reports-and-publications.aspx?article=5dd4bce4-ebd8-475e-b78d- da24e4ff7339 35 http://www.cer.ie/en/information-centre-reports-and-publications.aspx?article=5dd4bce4-ebd8-475e-b78d- da24e4ff7339 98

  94. The Presentation of Energy Usage Information (SB, MIHD and CWI) basis for comparison and control. Energy usage reduction for different groups and tariffs was measured both overall and at peak. There were 4,300 participants in the trial. The Gas Residential Customer Behaviour Trials 36 The gas Customer residential behaviour trials tested similar stimuli, again with four groups split in the same way as the electricity trials except that the fourth group in this case combined the energy usage statement and bi-monthly bill with the IHD and a special variable tariff. The other three groups meanwhile all stayed with the existing gas tariff. Overall there were 1,927 participants in the trial. Summary of Overall Results Results overall showed a statistically significant reduction in energy usage across both the electricity and gas trials in nearly all groups tested . The Electricity Trial Results The Electricity trials showed a significant reduction in overall use in all groups except for group 1 (combination of bi-monthly billing with energy usage statement) where there was still a reduction but not a statistically significant one. The trials also showed a significant reduction in peak usage across all groups. Overall the reduction in usage across groups was 2.5% with the combination of bi-monthly billing, energy usage statement and IHD showing the largest reduction of 3.2%. This combination was also the most effective in reducing peak usage with an 11.3% reduction compared with an average of 8.8% across the groups. The use of bi-monthly billing with an energy usage statement alone led to a 1.1% overall reduction and 6.9% reduction at peak. While the trials did not test the effect of the electricity monitor independent of the energy usage statement, the additional impact of the IHD could be interpreted as being a further 2.1% overall energy reduction and a further 4.4% at peak. However, it is not possible from the trial results to completely isolate the impact of the IHD on its own as the combination of its use with the energy usage statement may have additional effects which impact on the reduction achieved. 36 http://www.cer.ie/en/information-centre-reports-and-publications.aspx?article=5dd4bce4-ebd8-475e-b78d- da24e4ff7339 99

  95. The Presentation of Energy Usage Information (SB, MIHD and CWI) Figure 9- Electricity Customer behaviour trial results The Gas Trial Results There was a statistically significant reduction in overall energy usage across the four gas trial groups with an overall reduction of 2.9%, however no individual stimulus was seen to be significant over the others. In this case the impact of the IHD appears to have been less significant but there still seems to have been an additional 0.7% demand reduction caused by its use (though again this is caveated by potential interaction effects as in the electricity trial). The combination of bi-monthly bill, energy usage statement, IHD and variable tariff led to the greatest reduction of 3.6% although this was not statistically different from the reduction achieved by the groups exposed to other stimuli combinations. Figure 10 - Gas Customer behaviour trial results The most significant changes in usage occurred in the low consumption months and in particular June, July, August and September. This diminished considerably at the start of October and the relative percentage reduction remained comparatively lower until April-May However, the greatest volume reduction occurred during the High Usage period (from October to March inclusive) and this accounted for 70% of the overall reduction 100

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