DECC’s consultation on amending Smart Meter In-home Display Licence Conditions
Citizens Advice welcomes this opportunity to respond to DECC’s consultation on amending smart meter In Home Display (IHD) licence conditions
Citizens Advice and its predecessor bodies Consumer Futures/Focus have been extensively involved in the smart meter rollout since its beginnings and IHDs represent the ‘face’ of smart metering for the majority of consumers. The benefits of IHDs compared to other methods of consumer feedback have also been repeatedly demonstrated in studies across the globe and are likely to represent the mechanism by which the vast majority of the consumer benefits identified in DECC’s impact assessment are delivered. As such IHDs are, and are likely to remain, a critical element of the smart meter rollout for consumers.
The benefits of consumer tools making use of smart meter data have consistently been shown to be cumulative, that is to say that while historical research has consistently shown IHDs to be the best single tool to help consumers, a combination of tools has often been demonstrated to be even more beneficial.
As such these tools should not be viewed as an either/or choice for consumers but rather the opportunity to find the best combination of tools. An either/or approach will preclude such personalisation and suppliers will have a clear incentive to provide simply the cheapest, rather than most beneficial, intervention. It should also be noted that any interventions involving access to the internet through phones, tablets or PCs will, by their very nature be of no use to the digitally excluded.
Citizens Advice shares the government’s goals to learn more about the potential benefits of additional approaches, particularly newer models like online energy ‘apps’ for consumers. Comparing new tools to IHDs seems a reasonable approach. Apps may well be a welcome addition to IHDs for consumers and one that energy suppliers and third parties have a clear incentive to develop given that such apps would allow them access to much more detailed consumer data.
The consultation document refers to new tools as potential “alternatives” to an IHD. While specific trials seeking to compare new approaches to IHDs may need to pitch them as an ‘either/or’ prospect for methodological reasons, Citizens Advice expects any new approaches to be treated as “additional” during the the wider rollout and beyond.