There follows our entire response to DECC request for Consultation on Smart Metering  - enjoy!

Q1 Do you have any comments on the Government’s preference for the Central Communications model?

A1 FibreStream is broadly supportive of the thinking and desired outcomes that the Central Communications model is envisaged to deliver.

There is room within a common interoperability framework to facilitate a more localised implementation that has significant additional benefits as regards the ultimate effectiveness of Smart Grids in the key context of delivering low to zero carbon supplyside improvements, essentially by matching supply and consumption particularly by fostering innovative supply relationships between microgenerators and individual consumers via secure virtually transparent market mechanisms.

Furthermore, it is important to separate the requirement for a single common interoperable set of communication protocols on the national level from assuming that this necessitates a single communications provider, particularly if this supplier is a commercial entity.

This consultation rightly recognises that there will be certain unavoidable monopoly aspects that will be created by building a national two way smart metering communications, which is why it is FibreStream’s strong preference to see the establishment of a set or singular mutually-owned and/or community-interest entity(ies) to deliver the required communications service set.

Properly structured mutual ownership is intrinsically self regulating in the interests of its members, who can also be its consumers and optionally suppliers, particularly in the micro-generation sense.

Q2 Do you have any comments on the analysis and conclusions on the delivery model contained in this consultation document, the reports prepared by Baringa Partners, or the Consultation Impact Assessment?

 A2 No Comments

Q3 Do you agree the Central Communications model effectively facilitates ‘end to end’ management of the electricity networks system needed for smart grids?

 A3 Yes and there is always room for subsidiarity – this is an important consideration both in terms of domestic consumer buy-in to the principle of Smart Metering per se on the firm basis of informed consent and also in terms of the most efficient adoption of micro-renewables (due to 240 VAC input, microgen ideally needs to supply consumers within closest available proximity to source to minimise transmission losses)

 This leads to interesting implications in terms of pricing energy in terms of supply chain distance as well as time of day and absolute quantity of usage – Think Air Miles, Food Miles, Energy Miles.

 From an individual consumer perspective, whether domestic or non-domestic SME, “Smart” does not necessarily equate with nationally centralised connectedness. Localised wireless meter reading would provide the benefit of elimination of estimated meter reading and requirement of the consumer to be at home for meter reading to take place. Similarly, cars have had real time displays of fuel efficiency available for many years that operate entirely in-vehicle and do not require remote communications capability.

 Where centralised communications really offers benefit is in the context of the convergence of supplier and consumer through the mechanism of domestic and SME micro-generation of electricity

 - specifically offering the means to balance the upload and download ratios between supply and consumption in real time on a local community basis.

 - providing the metrics to enable an effective and efficient market that creates the conditions for renewable micro-generated energy to flourish.

 - providing both a significant contribution towards reducing the nation’s carbon footprint and also engaging the general public as active participants and economic beneficiaries in the wider transition towards a low carbon economy.

 Remotely-accessible two way communications always have privacy and national security considerations to take into account, particularly in the circumstances where home networks are capable of the remote disablement and remote activation of individual energy-consuming appliances.

 This is not to dismiss the real benefits of consumers choosing to take a partially or wholly interuptable supply service – the key messages here are choice, informed consent, willing buy-in.

 FibreStream believes that with effective community/consumer engagement this necessary consent can be generated and concerns of invasive remote monitoring can be put to rest.

Q4 Do you consider that Government should adopt measures to promote co-ordination of roll-out at local level? If so, what measures would you support?

 A4 FibreStream believes Government should use policy position to set the broad framework then allow subsidiarity to flourish. Clear guidance to the Civil Service at national, regional and local levels to cooperate and promote roll-out is most practical way for central government to offer support.

 With the emergence of NextGenUs FttH networks owned in the community interest there is a great opportunity for locally coordinated deployments of joined-up Next Gen Utility transformation packages which offer the benefit of a single visit to each home to perform the necessary work with minimum disruption and disturbance.

Q5 Should any particular policy considerations be taken into account in considering whether there should be priority target groups for early deployment of smart meters?

 A5 Preventable Deaths, running at up to 75000 elderly people per winter is a national disgrace and warrants intervention to ensure vulnerable elderly people and others experiencing fuel poverty benefit early in the deployment cycle.

 Similarly and often related to the above, those homes identified as being least energy efficient should also be a priority both in terms of providing the tools for those consumers to realise their energy usage footprint and in terms of providing the greatest quick-win carbon output reductions as consumers then act to reduce their energy consumption.

Q6 Do you have any comments on the merits of alternative approaches under which electricity and gas network businesses take on responsibility for aspects of smart metering?

 A6 As a Utility Network business itself, FibreStream recognises certain commonalities between telecommunications and electricity/gas transit – it is arguable that the structural separation that existing in the energy sector and that is largely lacking in present-day telecommunications sector is something worth ensuring we capture the value of in the context of Smart Metering – namely, that energy delivery can be simply described as a three phase process:

 Supply/Generation

Transit/Delivery

Demand/Consumption

 This process can be further separated into technical and commercial elements; in the current energy market, the transit networks focus on technical operations and efficient network maintenance and retail suppliers perform the commercial/billing aspects that sustain the supply-transit-demand chain.

Q7 Do you agree with the functionality proposed for electricity meters? Please explain your reasons and if possible give evidence for your comments.

 A7 Functions A, B, F – Yes

For the above functions, due consideration is required to address both Consumer Privacy and National Security implications; furthermore, these functions represent a huge shift in control of domestic energy from consumer to suppliers and therefore require careful consideration to ensure the appropriate checks and balances are in place to protect the consumer interest.

Functions C, E – Yes and as these functions are drilling down within the home to an appliance level and are therefore highly intrusive then there must be clear choice for the consumer to opt-in on the basis of informed consent including appropriate economic incentives

Functions D, G, H – Yes and with effective marketing these provide compelling reasons for consumers to buy into the entire Smart Metering ethos.

Q8 Are there any additional requirements that will be needed to facilitate smarter network management, efficient energy management and the development of “smart grids”? Please provide analysis, particularly on costs and benefits, where possible.

 A8 Open Access to micro trading hooks are essential to enable consumers to buy directly (in reality virtually and managed through a more flexible arrangement with their existing retail supplier perhaps acting as honest broker/intermediary) from local microgen suppliers (which might include a neighbour in the next street for example).

 There is exciting potential here to allow real-time energy trading on a localised micro-level which provides direct economic reasons for consumers to fully buy into Smart Metering at a grassroots level.

Q9 Do you agree with the functionality proposed for gas meters? Please explain your reasons and if possible give evidence for your comments.

 A9 Please refer to A7 above – due to the combustible nature of gas there is an addition strong health and safety case for remote valve shut-off capability eg. in the circumstances of a gas explosion or localised firestorm.

Q10 Is there significant scope for retrofitting non-valve functionality to gas meters? What are the costs and how many meters are capable of being retrofitted?

 A10 Assuming question actually means retrofitting valve functionality to currently non-valved gas meters, then the obvious answer to this question is to mandate that the remotely controllable valve is part of gas smart meters.

Q11 Are there any additional maintenance, administrative or management costs associated with having all gas smart meters with a valve?

 A11 Need to be mindful of risks arising from remote cut-off and reinstatement especially for gas supply – wide spectrum of concerns from individual privacy to national security implications.

Q12 Do you agree with the Government’s position that a standalone display should be provided with a smart meter?

 A12 Yes and please see A14 for FibreStream’s recommendations for additional consumer informational interfaces

Q13 Do you have any comments on what sort of data should be provided to consumers as a minimum to help them best act to save energy (e.g. information on energy use, money, CO2 etc)?

 A13 Absolute energy use, real time and historic, cost of that energy consumption, advice on how changes to usage habits would provide direct savings, carbon content of supply, time of day and partially interruptable supply being three examples, also consideration of “Energy Miles” as it relates to transmission loss mitigation.

 There is exceptional value to be had in providing each home with a real-time and historical comparison of its energy footprint compared with the local neighbourhood, both in terms of consumers understanding what their relative consumption patterns are and also, perhaps as part of a Home Information Pack, providing useful guidance to potential purchasers as to the energy efficiency of the property.

Q14 Do you have comments regarding the accessibility of meters/display units for particular consumers (e.g. vulnerable consumers such as the disabled, partially sighted/blind)?

 A14 Yes as flagged in A12 above, FibreStream sees there is a clear need for additional accessibility options above and beyond a meter-mounted display device – the most flexible and effective means to deliver this outcome is an open API and publicly exported set of real time and historical metrics that provide for both home intranet and remote secure internet presentation of information. This approach leverages extensive existing assistive technologies designed for vulnerable consumers eg Bobby, screen readers etc

Q15 Do you agree with the Government’s proposal to extend to the small and medium non-domestic sector the minimum functionality that we will require for smart meters in the domestic sector, with certain exceptions to allow for individual consumer requirements?

 A15 Yes agree that in the objective context of Smart Grids then it makes sense to standardise the minimum functionality sets for SME sector with Domestic sector – unclear to FibreStream what any valid exceptions might be at this time.

Q16 Do you have any comments on how such a requirement, and the exceptions to it, should be framed?

 A16 Focus on desired policy outcomes and thereby place the onus on service providers to meet those requirements.

Q17 Do you have any comments on how the proposed new requirements should work in the context of the current developments in metering in this sector?

 A17 No Comments

Q18 Do you have any comments on the implications of the Government’s proposed approach in this sector for the future development of smart grids?

 A18 Smart Grids require ubiquitous two way real time comms to most efficiently balance supply and demand for energy – Government’s proposed approach is well placed to facilitate effective Smart Grids

Q19 Do you have any comments on the revised Consultation Impact Assessment for this sector?

 A19 No Comments

Q20 Do you have any comments on the implications for the non-domestic sector of the options identified for a domestic delivery model?

 A20 There is merit and simplicity in treating non-domestic SME and domestic sectors according to broadly the same options.

Q21 Do you agree with the Government’s approach to promoting interoperability in the non-domestic market? Do you have particular views about the interaction between the Government’s proposals for the non-domestic sector and the domestic smart meter roll-out?

 A21 Broadly yes in agreement that interoperability is essential and that Government’s approach is sensible.

Q22 Has Government identified the right issues for the immediate next steps? Are there other activities or key issues which you think should be addressed at this stage of the preparations for roll out?

 A22 Broadly yes – as covered in A4, there are opportunities to join up Smart Metering deployment with Next Gen FttH and these should be factored into the preparatory stages for maximum ultimate effect.

Q23 Do you have any other comments or evidence on issues relating to this consultation document or the accompanying Consultation Impact Assessments?

 A23 Community Interest Ownership and/or Mutual Ownership makes sense by offering a compelling mechanism to prevent anti-competitive and functional inefficiencies through the governance and structural self-regulatory safeguards that mutuality intrinsically offers vis a vis commercial delivery with external post facto regulation, where there is an unavoidable tension between supplier and consumer interests.

 Though smaller in scale than the GB market taken a a single whole, experience in the Nordics with neighbourhood and municipal scale energy suppliers has relevance for ther future of the Great Britain energy market when considered on a regional/local scale with GB wide interoperability protocols for both communications and service provider transfer.

 - in a practical sense, microgeneration works most efficiently when transmission losses are minimised between supply source and demand destination

 - ie keeping microgeneration local and incentivising the same is a great way to encourage the development and deployment of microgeneration in the home, eg. smart PV roofing materials and wind turbines.

 This helps create the conditions for the consumer to choose to opt-in to smart metering a direct economic benefit, providing people with reasons to choose to connect, with direct material benefits available in exchange for personal information given on the principle of least loss of privacy for given value offered backed by transparent limitations against scope creep.

 Providing consumers with ability to remote view their own smart meters eg when on holiday or, given additional consent, to monitor eg elderly relatives’ smart meters would be another effective way to reassure people of the benefits of Smart Metering.

 Careful consideration of the risks to privacy is essential and the “need to know” principle is a sensible policy position as regards external stakeholders.

 Network security strength is based around need to know basis and minimal connectivity with effective access control mechanisms – individual and national security risk potential for malicious hacking of a centralised remotely controllable smart grid demand careful design and ongoing management.

 FibreStream recognises that there are interesting opportunities to use EVs and PHEVs as domestic and non-domestic SME local energy storage buffers that with intelligent design will make interruptable supply (ideal for maximising the value from the variable nature of eg wind-powered renewable generation) more attractive to the consumer.

 Converging energy and telcommunications utility sectors opens up exciting possibilities to create a real time supply pool of energy which consumers can either directly (online auction mechanism) or indirectly (via virtual energy broker) contract into for peak/temporary demand – charging the EV/PHEV being the obvious requirement.

 In terms of the actual roll-out deployment of smart meters, it is worth being aware of the parallel transformation of telecommunications access network delivery and looking to converge the two in-home access requirements into a single Smart Utility Upgrade Programme.

 The existing energy utility supply paradigm shares similarities with broadcast TV – a real time one way supply of service across a transport network to each consumption location.

 Smart Grids with their requirement for two way communication share similarities with broadband services in that some form of upload capability is involved, particularly where grid supply from micro-generation of renewable energy is involved.

 As a utility operator itself, FibreStream recognises the commonality of resource/value flow ratios inherent in both the energy and telecommunications utility sectors.

 In response to section 1.17 is true that there are exemplars on smaller scale elsewhere and these are directly applicable to Britain, so long as we apply a subsidiarity policy approach with interoperability addressing the national scale factors. In the telecommunications sector, interoperability is assured via peering between networks that operate according to agreed protocols – this process is directly transferable to smart metering remote communications requirements.

 In the context of telecommunications, FibreStream supports the NextGenUs Community Interest monopoly asset ownership model and this approach has direct applicability to energy utility delivery as Smart Metering is where each of the utility sectors naturally converges.

 In response to section 2.24 FibreStream suggests that Government revisits its current acceptance that there will inevitably be costs associated with the early removal of existing meters and questions whether removal is actually required as there are options to in-line fit smart meters leaving the existing devices in situ which might then provide a backup in case of smart meter malfunction and also ease the transition by giving consumers confidence in the new system by parallel running with the old approach.

 In response to section 2.25 FibreStream welcomes that Government is not persuaded at this juncture to commit to establishing a compensation scheme as it is our sense that any intervention will be better applied instead to incentivise accelerated Smart Meter deployment.

 FibreStream thanks Government for the opportunity to respond to this important consultation and looks forward to contributing to the future planning and deployment of Smart Metering in Great Britain as part of the move to a low carbon economy.