1. CAPACITY IN WHICH I (Colin Boughton Smith) AM RESPONDING AND BACKGROUND
I am the Managing Director of Energy Metering Technology Ltd (EMT), and am responding due to my passionate believe that automatic meter reading, and the awareness it brings to the consumer, is fundamental to achieve utility resource use efficiency. I have taken the lead from Lord Kelvin who said something along the lines of “if you don’t measure it, you don’t know much about it”.
My company has been one of the UK’s pathfinders in the whole concept of automatic utilities auditing (also known as aM&T by MMG ESTA) in the C&I market and has been developing new concepts and associated electronics (DATA BIRD) and software (DYNAMAT) in this area since the 1980’s during which time my company has received several awards for both innovation and specific project achievement.
Amongst other related matters we were the instigators of the Carbon Trust Field Trials and also the initial MPU agreement with Transco; the latter after our complaints to Ofgas/Ofgem when AMR interface to fiscal gas meters took up to 6 month of bureaucratic hassle.
Since the 1980’s, my company has stayed in business based on offering “turn key” automatic meter reading systems and services for cost, consumption and carbon savings. Originally we had to sell the whole concept of aM&T to our potential customers before we sold our turn key offering. Now most C&I consumers understand the benefits of aM&T and we sell our equipment in a hot, competitive and innovative market.
We have been lobbying at many levels for the adoption of aM&T since the mid-1980’s and are delighted that it has now been accepted as the modern way to manage utilities.
Despite this fantastic progress of the acceptance and adoption of aM&T, in the C&I market, the barrier to roll out remain the intransigence of the energy and water supplier industry and Ofgem and Ofwat to embrace the new concept that, when automatically read, a fiscal meter can be a work horse for consumption/carbon management rather that just an idle asset for fiscal management by the supply industry.
After many years lobbying Ofgem in many forms including as a member of the now defunct New Metering Technology Working Group, I am a little sceptical of “Ofgem of old’s” motives since, despite their claim that they are Promoting choice and value for all gas and electricity customers, I have found them intransigent, pigeon holed and riddled with motives just to support the Energy Supply industry.
Although approached with distrust, to say I was delighted to read the new Ofgem’s aspirations espoused in the prospectus, is an understatement. Are we talking about the same organisation here I asked myself?
At this juncture, to be positive and putting all the negative experiences behind me, I must assume the visions outlined in the prospectus are sincere. On this basis, but tainted with my past experience, I make this response.
I attach no confidentiality to any of the content of this document.
5. WHAT IS GOING TO HAPPEN IN THE TRANSITION YEARS BEFORE THE SMART METERING ROLL OUT?
It is a “no brainer” that utility consumption management is best in the hands of the consumer rather than organisations supplying utilities. It is very refreshing to see this fundamental understanding embedded in the Smart Metering Implementation Programme Prospectus, in particular the recognition of the meter as a tool for consumption/carbon management by the consumer and the empowerment of the consumer to control access to meter data.
Unfortunately the rollout programme and all that is needed to change the emphasis from the meter being an instrument under the control of the utility industry, and for fiscal management, to, under the control of the consumer, and for carbon management, is going to take at least four years. But UK Carbon Savings need to be accelerated. So what is going to happen between then and now to smart metering to facilitate this?
The answer is there needs to be a quick, urgent and balanced review of the Supplier Licence Conditions to adjust them to recognise a meter is now an important tool for carbon management with changes made to reduce, as far as possible, the current barriers to enable meters to be automatically read by consumers.
However, this needs to be preceded by an aligning of attitudes and policies within both Ofgem and DECC in regard to the current use of the meter as both an instrument for fiscal management and carbon management.
A further requirement for the Transition period is that there needs to be acceptance that as a minimum requirement the provision of the common simple, basic pulse output from fiscal meters be facilitated for consumer data access until the standard meter interface to which the Prospectus aspires is developed and available.
5.2 Evolvement of aM&T for Carbon Management
In the C&I market, due to technical advances since the early 1990’s, the use of the meter, particularly automatic reading of the meter through aM&T systems, has been evolving to be a major tool to assist management of utility consumption and therefore carbon. When any utility meter (gas, water electricity, oil etc) is automatically read and the data analysed as part of an aM&T systems, this effectively turns a meter from being an “idle asset” for fiscal supply management into a “work horse” for carbon management.
In the C&I market, the first strategy to deploy aM&T (The Carbon Trust guides refer) is to automatically read all main incoming utility meters (fiscal meters) to enable quantification and analyses of the total consumptions, and therefore total carbon, which are coming across a consumers boundary. In larger organisations subsequent phases of aM&T sub-metering would be deployed and connected to the aM&T system to assist the pinpointing of wastage and/or inefficiency again a strategy The Carbon Trust Guides endorse but also Part L2 Building Regulations mandate. The monitoring and analyses of all utilities based carbon that comes across the boundary in this way has been recognised as the main management tool for administration of on going carbon saving programmes, it is, for example, the starting process under CRC. Further, as understood from Prospectus, this is recognised as the fundamental reason for the smart metering roll out.
Whilst The Carbon Trust state the application of aM&T will save between 5% and 7% in its own right, we do not believe aM&T should be regarded as simply a carbon saving measure in its own right but the strategic tool above consumption saving measures to manage consumers’ ongoing Carbon Reduction programmes.
Many aM&T systems that have been installed on C&I sites since the 1990 and the roll out continues at an accelerating pace. During this time many thousands of tonnes of CO2 will have been saved due to the enhanced consumption management provided by aM&T; but there is a lot more to do and hence a lot more savings to be made. NB. Did you know DECC completed their head office aM&T in July this year – see their WEB site!
5.3 Large Organisations Often Have Large Supply Points as Well As a Plethora of Smaller Supply Points
The Prospectus divides smart metering roll out into domestic and smaller non-domestic sites – (electricity profile class 3 and 4 and non domestic gas sites with consumption less than 732 Mwh per annum) believing that existing arrangements and recent EU Directives will cater for larger establishments. However, the situation is not as simple as this. Larger organisations, particularly public sector organisations such as hospital, universities and local authorities that have grown their estates over many years, often have a mix of large utility supply points and a plethora of smaller supply points some of which are at small domestic level, for example, a Professors’ Flat or a Nurses’ Residence etc.
Indeed in some C&I premises the summation of the carbon in utility supply to the plethora of these smaller premises is often greater than the main supply points.
A growing number of these organisations encouraged by CRC and other schemes, are install aM&T across their premises to assist the consumption/carbon management. They are generally installing multi-utility automatic meter reading/data analysis systems; they do not want the confusion and complexity of having different aM&T systems for different utilities, and in doing so need to interface, not only to the main utility supply point meters, but also to the plethora of small premises supply point meters to capture all the supplies coming across their boundary.
Whilst compliance participation to the CRC scheme is governed by the main electricity supply points (COP5 metering) in the subsequent reporting phases the scheme encourages the capture of all carbon coming across site boundaries.
Due to the current Utility supply licence conditions, there are serious barriers to enabling organisations to have aM&T interface to the main fiscal supply meters by which they are charged particularly the smaller supply meters.
5.4 Current Licence Conditions – a Barrier
The current licence conditions were written some time ago based on the meter just being an instrument for fiscal management; they have no recognition or conditions facilitating the meter being automatically read by consumers to effect consumption/carbon management. Therefore, there are no conditions forcing the supply industry to assist consumers with aM&T interface to the meters by which they are charged.
In the past 15 years or so, as aM&T has evolved and customers have wanted interface to “their” fiscal meters, the utility companies (and associated MOP/MAMS) have facilitated interface in an arbitrary, uncontrolled way but it must be said extremely reluctantly; for a customer to get aM&T interface to “their” fiscal meters can be described as “pulling teeth”. Ultimately by sufficient tenacity and pressure by the consumer (or, the consumers aM&T agent) and in a need for the suppliers to limit exposure under their Corporate Environmental Responsibility policy, an interface is facilitated/allowed by the supplier/MOP.
During the evolving years of aM&T it has been extremely difficult to arrange for such meter interfaces; the MPU agreement for interface to National Grid Gas meters was as a result of it taking a bureaucratic 6 months to get simple gas meter interface going through The Supplier Hub and is effectively a short cut to deal directly with the MAM. The MPU agreements for interface to gas meters that have now evolved by the different MAMs are not dictated or covered by any Supply Licence Conditions.
A similar situation arises when a Consumer wants interface to “their” fiscal electricity meter with their multi-utility aM&T system. Due to the poor design of current digital meters used in the supply industry in this regard (interface outputs are behind the meter seal), an external to the meter “CAT box” (Customer Access Terminal) is required to be installed by the supplier/MOP. Again there are no formal, uniform arrangements; to find someone at a supplier who understands what is required is difficult let alone the arrangements for getting a CAT box fitted by the MOP is fraught. Whilst the fundamental reason for the CAT box is a simple meter design issue, the Consumer pays for the fitting of CAT boxes and is willing to do so to get interface to their aM&T system.
aM&T interface to water meters has a similar tortuous path with one water company now attempting to levy an annual charge for the pleasure!
Recently, some suppliers/MOPs jumping on what they see as “a lucrative AMR roll-out band wagon”, are refusing to provide consumers with aM&T interface stating, firstly, they have their own
AMR solution, and, secondly, the provision of the consumer aM&T interface is not a Supply Licence requirement.
OFGEM has been made aware of the above situation for many years; they where made aware of it continuously during the years, commencing with formal complaints, when they were Ofgas, continuously during their chairing of the defunct Ofgem/ELEXON New Metering Technology Working Group, of late continuously, due to a stream of cases when they asked for specific cases rather than anecdotal evidence to be brought to their attention and just recently when they were informed of a specific case when a supplier/MOP has refused totally to provide aM&T outputs for an NHS consumer.
In the past Ofgem has simply turned scorn on suggestions to change licence conditions to accommodate suppliers providing meters with the necessary interface outputs for customers and saying “leave it to market forces”. Of late however, and with the knowledge of DECC, the latest remark from Ofgem is all this will be sorted out under the AMR Implementation programme which in the next breath they say will take at least “4 years” to implement.
5.5 Ofgem Polarisation – “Promoting Choice And Value For All Gas And Electricity Consumers”?
The above describes the struggle both in the past and now that consumers have to get aM&T interface to their fiscal meters to effect consumption/carbon management. Ofgem has in the past been totally inept on this issue; fundamentally they just have not recognised, or been willing to recognise, that a meter these days is not just for fiscal management. With the support and knowledge of DECC, amazingly, this regime still carries on in Ofgem now!
Yet here we have Ofgem E-Serve* espousing in the Smart Metering Implementation Programme prospectus, customer focus, promotion of the meter as an instrument to assist the low carbon economy and meter interface standardisation!
* In the Prospectus OFGEM E-Serve is described as being “responsible for Ofgem’s support and delivery function.
Clearly for the UK PLC Carbon Programme, as a precursor to coping with the transition years between now and deliver of the Smart Metering, the two totally different policy streams existing within OFGEM need aligning and together with joined up thinking within DECC itself.
5.6 Need for Facilitating a Basic, Simple, Minimum Common Meter Interface During the Transition
The Prospectus outlines the development of meter standardisation and in particular a common open interface to meters as fundamentals to the Smart Metering Implementation Programme; a matter we fully endorse. But this is at least four years away.
To date meter manufactures have development many complex meter interface methods that are, in summary, simply incompatible with one another.
There is only one basic but simple common multi-utility interface method currently available and this is the basic meter pulse output. It is on the simple meter pulse output by far the majority of current multi-utility aM&T systems are based, including DECC’s own head office aM&T system.
Whilst it is recognised this is inferior to the disparate electronic methods of serial meter interface many of the meter manufacturers have develop, it is the only common multi-utility interface method available and should be provided as a minimum requirement on all fiscal meter until a common standard has been evolved and implemented.
Unfortunately, despite lobbying on this issue to Ofgem over many years it is understood that the specification for the COP 10 meter does not include the pulse output.
NB. Whilst gas and water meters are available with non mechanical methods of flow measurement, it is likely on just pure cost grounds that gas and water meters for the foreseeable future will still be based on mechanical methods of measuring flow with the pulse remaining as the basic meter output; some accessory/gadget being added to provide the common output HAN interface.
Recieved and fowarded from the below expert:
T. +44 (0) 1628 600271 | M. +44 (0) 7730 059405 | E. Colin@meteringtech.com
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