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Citizens Advice's response to DECC consultation on changes to equipment installation requirements and the governance arrangements for technical specifications

27 June 2014

Introduction

We welcome the opportunity to comment on the proposed changes to equipment installation requirements in the smart meter roll-out and future governance arrangements for SMETS. Citizens Advice has a particular interest in this programme having taken on the statutory duty to protect and promote the needs of energy consumers, formerly held by Consumer Futures.

The provision of equipment such as communications hubs, PPMIDs and HCALCSs will be of almost as great importance in the roll-out as smart meters themselves. We are pleased to see the detailed consideration being given to their availability, but it is hoped that steps will be taken to ensure that there are no barriers to obtaining this equipment where it would be beneficial. Doing so might risk jeopardising the large expenditure on the smart meter programme as a whole for the sake of a relatively small saving. Any arrangement in which suppliers are given responsibility for choosing which equipment is installed in which premises should be closely scrutinised to ensure that suppliers do not have an incentive to minimise what is provided in order to avoid expenditure.

The governance arrangements around SMETS need to be arranged in a way that is sustainable in the long term, but they should also be kept on a footing that is as accessible as possible. Making them and their modification process too complex might make it harder to adapt them in future, either to allow for new innovation or solve problems as they emerge. They should be approachable to new market actors and consumer groups as well as a small pool of industry code experts.