CEER Draft Advice on Data Management for

Better Retail Market Functioning: electricity

& gas – A CEER public consultation paper

A EURELECTRIC response paper

June 2014
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EURELECTRIC. Electricity for Europe.

Dépôt légal: D/2014/12.105/23

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

A EURELECTRIC Response paper June 2014

KEY MESSAGES

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

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

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

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

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

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

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

Contact:
WG Commercial Processes & Customer Relationship
Roel KALJEE Sébastien DOLIGE, Advisor, Retail Customers Unit –
sdolige@eurelectric.org
WG Distribution Customers & Grid Management
Claire COUET, Advisor DSO’s unit –
Robert DENDA ccouet@eurelectric.org

3
Public consultation questions

Privacy and security

1. Customer meter data should be protected by the application of appropriate security

measures that prevent unauthorised access but which allow access to parties authorised to
receive it, such as DSOs/metering operators. This customer meter data protection should be
ensured by (tick one box):

X Legislation/regulation
Contract between customer and relevant parties
Code of conduct
Other (please specify in the comment box below)
No opinion

Comment box (3500 characters maximum)

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

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

Legislation/regulation
Contract between customer and relevant parties
X Other (please specify in the comment box below)
No opinion

4
 Comment box (3500 characters maximum)

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

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

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

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

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

Transparency

3. The relevant body (NRA/DSO/metering operator/TSO/other) shall ensure that, as a minimum,

the customer has knowledge of general information on meter data management: (a) the
customer’s rights with regards to data management; (b) what type of customer meter data
exists and what it is used for; (c) how customer meter data is stored and for how long; and (d)
how both the customer and third parties get access to that data.

X Agree
Disagree
No opinion

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

X Providing clarity on how information can be accessed

Setting a maximum time period during which a customer has to
wait to receive that information after having moved into new
premises
Other (please specify in the comment box below)
No opinion

5
 Comment box (3500 characters maximum)

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

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

Providing the third party clarity on how information can be

accessed
Setting a maximum time period during a third party has access to
the informatio
X Other (please specify in the comment box below)
No opinion

Comment box (3500 characters maximum)

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

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

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

X NRA
X DSO/metering operator
X Other (please specify in the comment box below)
No opinion

6
 Comment box (3500 characters maximum)

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

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

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

Other actors – governments, NRAs, network system operators and consumer groups also have a role to play
to build customer confidence:
- EU and national authorities by setting the right regulatory framework and effectively transposing
existing legislation;
- DSOs – as regulated neutral entities in charge of collecting metering data in most EU member states
– by ensuring effective and reliable data protection, data security and data management;
- Member states, NRAs, businesses and consumer associations by informing and educating
consumers to improve their understanding and engagement in retail energy markets.

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

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

X Information campaign
Use of energy advisor
X Other (please specify in the comment box below)
No opinion

7
 Comment box (3500 characters maximum)

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

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

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

X Agree
Disagree
No opinion

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

European level
Regional level (across national borders)
X National level
Sub-national level
No opinion

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

(a)

Point of delivery identification

X
data
X User and contract data Consumption data
Other (please specify in the comment box
X
below)
No opinion

8
 Comment box (3500 characters maximum)

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

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

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

X Agree
Disagree
No opinion

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

X Agree
Disagree
No opinion

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

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

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Accuracy

11. Relevant bodies (NRA/DSO/metering operator/TSO/other) should have in place

standardised measures available to the customer to enable any remaining inaccuracy concerning
data management to be addressed. Those measures should include a timetable set out in (tick
one box):

Legislation/regulation
Contract
Code of conduct
Other (please specify in the comment box
X
below)
No need for standardisation processes for
remaining inaccuracy
No opinion

Comment box (3500 characters maximum)

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

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

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

10
 Accessibility

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

European level
Regional level (across national borders)
X National level
Sub-national level
No need to standardise customer
meter data
No opinion

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

X Agree
Disagree
No opinion

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

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

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

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

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Non-discrimination

14. To support an effective and competitive market, the data management model should not
give undue preference to one stakeholder over another. Specifically in relation to smart
meters, there should be non-discriminatory access to information if and where smart meters
are installed.

X Agree
Disagree
No opinion

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

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

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

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

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

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 Further questions for public consultation

In addition to individual questions on the 14 draft recommendations, we also

ask stakeholders to provide their opinion on the questions below:

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

The list seems to identify the relevant stakeholders.

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

Yes

3. In relation to the 5 proposed guiding

principles:

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

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

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

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

Standardisation is a good thing as long as it does not create unreasonable obstacles to

innovation and system costs to the detriment of customers.
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