1
Energy Billing and
Metering
–
Changing
Customer Behaviour
CONSULTATION ON IMPLEMENTATON OF
ELECTRICITY AND GAS
METERING
AND
BILLING
PROVISIONS OF THE
ENERGY EFFICENCY
DIRECTIVE
(
2012/27/EU)
October 2013
December 2009
Consultation
Energy
2
Department of Enterprise, Trade and Investment
Page
32
1
Introduction
Pages 2
-
4
2
Metering
Pages 5
-
7
3
Smart Metering and Billing
Pages 8
-
9
4
Billing Information
Pages 10
-
18
5
Cost of Access to Metering and Billing Information
Pages 19
-
20
Glossary
Page 21
Annexes
A
-
D
Pages 22
-
45
Contents
2
Introduction
1.1
In this consultation paper the Department of Enterprise, Trade and Investment (the
Department
) seeks
initial views and comments on the
implementation in Northern Ireland of certain requirements of
Directive 2012/27/EU of the European Parliament and of the Council on energy efficiency (the
Energy
Efficiency Directive or the
Directive
).
The Directive was published in the Official Journal
of the European
Union on 14
November 2012 and entered into force 20 days later, on 04
December 2012. The Directive
can be accessed at
http://eur
-
lex.europ
a.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2012:315:0001:0056:EN:PDF
THE ENERGY EFFICIENCY DIRECTIVE
1.2
The new Energy Efficiency Directive
establishes a common framework of measures for the promotion of
energy efficiency within the EU in order to ensure
the achievement of the EU’s 2020 20 % headline target
on energy efficiency and to pave the way for further energy efficiency improvements beyond that date. It
lays down rules designed to remove barriers in the energy market and overcome market failures tha
t
impede efficiency in the supply and use of energy, and provides for the establishment of indicative
national energy efficiency targets for 2020
. Whilst the Directive imposes a wide range of requirements on
Member States in relation to energy efficiency
,
this consultation focuses specifically on its requirements
relating to metering and billing of energy use (Articles 9
-
11).
TIMETABLE FOR IMPLEMENTATION
1.3
T
he overall deadline for transposition
of the requirements of the Directive
is 5 June 2014. However,
different requirements have different implementation dates and
, where they are relevant,
these are noted
in the main text of this consultation.
IMPLEMENTATION OF THE DIRECTIVE IN NORTHERN IRELAND
1.4
T
he Directive is wide
-
ranging
and h
as many and varied requirements:
Annex
D
contains
an outline of
the
transposition plans for those Articles not included in
this consultation.
1.5
Many of the requirements
in the Directive
fall to the Member State as a whole
. Where this is the
case,
the Department
of Energy and Climate Change has responsibility for compliance with the Directive.
Northern Ireland will contribute to the UK’s energy efficiency targets and to the National Energy Efficiency
Action Plan required under the Directive.
1.6
For the purposes of
the
implementation of Articles 9
-
11 in the United Kingdom, the Directive will be
transposed separately in Great Britain and Northern Ireland. In Northern Ireland, the Directive will be
transposed into national law by the Department
(DETI)
. In Great Britain, transposition will be undertaken
by the Secretary of State for Energy and Climate Change.
1
3
This Consultation paper
1.7
This consultation focuses on Article 9(1), 9(2), 10(1), 10(2), 10(3), 11(1),
and Annexes VII
.
Article 13, which
deals with penalties, also bears on Articles 9
-
11.
1.8
The requirements in Article 9(1) and (3) and 11(2) as they touch on district heating, district cooling and
domestic hot water will be dealt with in a separate consultation, possibly UK
-
wide.
1.9
The struc
ture of this consultation paper is as follows:
Chapter 2
of this paper looks in detail at the metering requirements of the Energy Efficiency Directive;
Chapter 3
examines the requirements in relation to Smart Metering and Billing;
Chapter 4
examines the requirements in relation to Billing Information;
Chapter 5
examines the requirements in relation to the cost of access to metering and billing information;
The
Glossary
contains a list of definitions
;
Annex A
contains a link to the full
text of the Energy Efficiency Directive, as well as other relevant
European legislation
;
Annex B
contains a summary of proposals for parts of the Directive which are not covered in this
consultation
;
Annex C
focuses on Equality Screening
; and
Annex D
fo
cuses on the
partial Regulatory Impact Assessment
.
How to respond to this consultation
1.10
The Department would welcome your views and comments on the proposals set out in this consultation
paper, including the questions throughout the consultation; the
draft equality sc
reening form attached at
Annex C; and
the partial RIA at Annex
D
.
Because of the tight timelines associated with transposing the
Directive, the Department cannot be flexible about the closing deadline and, indeed, would be most
grateful
for earlier submissions.
1.11
The consultation period will close on
Friday 6 December
2013
. Responses to this consultation should
reach the Department on or before that date, and should be forwarded to
energyefficiencydirective@detini.gov.uk
OR by post to:
Energy Efficiency Directive
Department of Enterprise, Trade and Investment,
Room 47
Netherleigh House,
Massey Avenue,
Belfast.
Telephone: 028
9052
9581
Fax Number:
028
90
52
9549
Textphone: 028
9052
9304
4
Confidentiality & Data Protection
1.12
Your response may be made public by DETI. If you do not want all or part of your response or name made
public, please state this clearly
in the response by marking your response as ‘CONFIDENTIAL’. Any
confidentiality disclaimer that may be generated by your organisation’s IT system or included as a general
statement in your fax cover sheet will be taken to apply only to information in you
r response for which
confidentiality has been specifically requested.
1.13
Information provided in response to this consultation, including personal information, may be subject to
publication or disclosure in accordance with the access to information regi
mes (these are primarily the
Freedom of Information Act 2000 (FOIA) and the Data Protection Act 1998 (DPA)). If you want other
information that you provide to be treated as confidential, please be aware that, under the FOIA, there is a
statutory Code of P
ractice with which public authorities must comply and which deals, amongst other things,
with obligations of confidence.
1.14
In view of this, it would be helpful if you could explain to us why you regard the information you have
provided as confidential.
If we receive a request for disclosure of the information we will take full account
of your explanation, but we cannot give an assurance that confidentiality can be maintained in all
circumstances. An automatic confidentiality disclaimer generated by yo
ur IT system will not, of itself, be
regarded as binding on the Department.
Copies of the Consultation
1.15
This Consultation document is being produced primarily in electronic form and may be accessed on the
DETI Energy website:
www.energy.detini.gov.uk
1.16
If you require access to this consultation in hard copy, or in a different format
–
e.g. Braille, disk, audio
cassette
–
or in a minority ethnic language please contact Peter Bri
ggs on
028
9052
9581
and
appropriate arrangements will be made as soon as possible.
5
Metering
Directive
Requirement
2.1
Under Article
9(1) of the Directive, Member S
tates
shall
ensure that,
so far as it is
technical
ly possible,
financial
ly reasonable and proportionate in relation to the potential energy savings,
final customers for
electricity, natural gas, district heating, district cooling and domestic hot water are provided with
competitively priced
individual
mete
rs that accu
rately reflect the final customer’s
actual energy
consumption and that provide information on actual time of use.
2.2
S
uch
a competit
ively priced individual meter shall
always
be
provided when
:
(a)
an existing meter is replaced, unless this is technically
impossible or not cost
-
effective in relation to the
estimated potential savings in the long term;
(b)
a new connection is made in a new
building or a
building undergoes major renovations, as set out in
Directive 2010/31/EU (on the energy performance of build
ings).
C
urrent
Position and Policy Proposals
2.3
Currently in Northern Ireland, there are legislative provisions and licence conditions in place that set out
the
rules in relation to metering.
In relation to electricity,
the
Electricity (NI) Order 1992 (Article 34 and
Schedule 7)
require
s
that “Where a customer of an electricity supplier is to be charged for his supply
wholly or partly by reference to the quantity of electricity supplied, the supply shall be given through, and
the quantity of electricity shall be ascertained by, an appropriate meter.
”
Schedule 7 of the Electricity
Order also applies both to licence holders and to those who are authorised to supply under an
exemption
1
.
2.4
The
distribution licence held by NI
E
contains requirements for NIE to have in force and comply with a
Distribution code which must include “insofar as necessary, a metering code setting out requirements
and procedures for metering”
and that it must establish,
operate and maintain the Market Registration
Service, allocating and recording a unique meter point registration number for each meter point when it
first becomes registered
.
Additionally, NIE is also required under its distribution licence, when offerin
g
terms for connection to the distribution system, to make detailed provision regarding the installation of
appropriate meters (if any) required to enable the licensee to measure electricity being accepted into the
distribution system.
2.5
In addition,
e
lectricity supply licence
s
require
licensee
s
to, on application,
enter into an agreement for the
provision for any relevant metering equipment.
There are further requirements for all electricity supply
licensees in relation to persons who are of pensionab
le age or disabled or chronically sick that require
licensees to assist such persons with meter readings at least once each quarter and inform the customer
of that reading. The licensee also must use all reasonable endeavours to
take an actual meter readi
ng in
1
http://www.legislation.gov.uk/nisr/2013/93/introduction/made
2
6
respect of each of its Customers (save insofar as he receives an unmetered supply) on at least an annual
basis.
2.6
In relation to gas, the legislative provisions in relation to metering are much more restricted. Article 22 of
the Gas (Northern Ireland) Order 1996
has provisions relating
to meter testing and stamping. The
existing gas distribution licences in Northern
Ireland contain requirements for the licensee to provide, on
request from gas suppliers wishing to supply premises, standard gas meters. In addition, gas suppliers
are required to “make such arrangements with the relevant network operator
for the provisi
on and
installation of a gas meter ... to any customer to whom the licensee supplies gas.
”
Although these
provisions may be said to require the accuracy of gas meters, they do not appear to go as far as the
requirements of the Directive to ensure competit
ively priced meters, reflecting actual energy consumption
and providing information on actual time of use.
2.7
Domestic and business premises in Northern Ireland that are served by licensed gas and electricity
suppliers are provided with indivi
dual gas
and electricity meters
which can accurately record the
customer
’
s actual consumption.
Under the standard terms of gas and electricity supply licences, there is
a requirement to inspect, read and, in the case of gas, ensure that meters and associated instal
lations
are inspected at intervals of not more than two years.
These meters are subject to certification
procedures in respect of safety and accuracy.
In addition, the Meters (Approval of Pattern or Construction
and Manner of Installation) Regulations (N
I) 1998
2
ensures that electricity meters are accurate.
2.8
Whether the majority of current credit meters are compliant with the requirements of the Directive
relates
on the interpretation of “actual time of use”.
We believe that actual time of use in this instance means
“actual usage” and that the majority of meters in Northern Ireland are likely to be compliant.
2.
9
E
ven if
current electricity and gas
meters are in practice sufficient to meet the requirements
of the
Directive,
the
current
legislative provisions and licence conditions
do not appear
sufficient to meet
some
of
the specific re
quirements of Article 9(1)
: i.e.
explicitly stating
that meters much be:
(a) competitively priced;
(
b
) reflecting
final customer’s actual energy consumption; and
(d) provide information on actual time of use
.
The Department is of the
preliminary
view that a legal obligation w
ould
need to be introduced
t
o ensure
that meters meet the specific requirements of Article
9(1
)
.
CONSULTATION QUESTION
2.1
(a)
Do you agree that the current legislative provisions and licence conditions are
not
sufficient to
ensure compliance with Article 9(1)? If you disagree, please ensure that you explain your
answer fully.
(b)
What
other
issues, if any,
would
arise from the proposal to put in place legislation to ensure
that the requirements of Article 9(1) are met in full?
(c)
What are the implications, if any, arising from including requirements on metering to those
currently exempt from
holding an electricity supply licence?
(d)
What costs and benefits might arise from putting in place additional requirements in relation to
gas and electricity metering.
Other requirements of Article 9
2.14
Article 9(2) introduces requirements
specifically in relation to where Member States have implemented
intelligent metering systems and rolled out smart meters for natural gas and/or electricity in accordance
with Directives 2009/72/EC and 2009/73/EC. The requirements of 9(2), the current pos
ition in
Northern Ireland and the policy proposals for implementing these requirements are therefore covered
separately in Section 3 of this document.
2
http://www.legislation.gov.uk/nisr/1998/443/introduction/made
7
2.15
In relation to the district heating and cooling and hot water
aspect
s
of Article 9(1),
it is antic
ipated that
the Department of Energy and Climate Change will be issuing a public consultation on the policy options
for installing heat meters before the end of 2013. It is expected that this consultation will be carried out
on a UK wide basis, and the
as
pects of Article 9
relating
to
heating, cooling and domestic hot water
are
therefore not considered in this
section
.
8
Smart metering and billing
Requirements
Article 9(2)
3.1
Where, and to the extent that, Member States
implement intelligent metering systems and roll out smart
meters for natural gas and/or electricity
in accordance with Directives 2009/72/EC and 2009/73/EC
:
(a) they shall ensure that the metering systems provide to final customers information on actual
time of
use and that the objectives of energy efficiency and benefits for final customers are fully taken into
account when establishing the minimum functionalities of the meters and the obligations imposed on
market participants;
(b) they shall ensure th
e security of the smart meters and data communication, and the privacy of final
customers, in compliance with relevant Union data protection and privacy legislation;
(c) in the case of electricity and at the request of the final customer, they shall requi
re meter operators to
ensure that the meter or meters can account for electricity put into the grid from the final customer’s
premises;
(d) they shall ensure that if final customers request it, metering data on their electricity input and off
-
take
is made
available to them or to a third party acting on behalf of the final customer in an easily
understandable format that they can use to compare deals on a like
-
for
-
like basis;
(e) they
shall require that appropriate advice and information be given to customers at the time of
installation of smart meters, in particular about their full potential with regard to meter reading
management and the monitoring of energy consumption.
Article 1
0(2)
3.2
Article 10(2)
requires that
smart meters
installed in accordance with Directives 2009/72/EC and
2009/73/EC
must enable accurate billing based on actual consumption
. Member States shall ensure
that
final customers have the possibility of easy access to complementary information on their own
historical consumption
, allowing detailed self checks
.
The complementary information on historical
consumption shall include
:
i. Cumulative data
for at least th
e three previous years or the period since the start of the supply contract
if this is shorter. The data shall correspond to
the intervals for which frequent billing information based
on actual consumption has been produced.
ii. Detailed data
according
to the time of use for any day, week, month and year.
These
data sh
all
be
made available to the final customer
via the internet or the meter interface
for the period of at least 24
months or the period since the start of the supply contract if this is shorter.
3
9
Current position
3.3
Smart meters offer opportunities for customers to manage their energy consumption and lower their bills.
It is a key enab
ling technology for managing energy systems more efficiently and will aid network planning
and development, including future smart grids.
3.4
In July 2012
,
DETI announced that Northern Ireland would proceed with an electricity
-
only smart meter
roll
-
out
in the domestic sector
by 2020 and would look again at the case for gas smart metering in 2015.
A c
onsultation on the nature and timescale of a smart meter rollout for the domestic electricity consumer
is planned by the Utility Regu
lator.
The Utility Re
gulator has indicated in
its
Forward Work Programme the
commitment to undertake this consultation in 2014
. Following the Utility Regulator consultation, issues
such as
data access and privacy considerations will also have to be assessed at Departmental le
vel.
3.6
An initial Smart Metering Pilot project, carried out by the University of Ulster, which focused mainly on the
customer perspective commenced in 2010, is now complete. NIE
is
currently conducting a larger trial of
200 customers, which considers
both smart grid and smart metering.
Proposed policy for transposing
Article
s
9(2)
and 10(2)
3.7
The requirements of Article
s
9(2)
and 10(2)
apply when a Member State
is
implement
ing
intelligent
metering systems and roll
ing
out smart meters for
electricity and/or
natural gas.
It
will be necessary to
ensure that the smart meters that are introduced
in Northern Ireland in due course are required to
comply with the requirements of Article
s
9(2)
and 10(2)
as a minimum.
3.8
We propose that any
regul
ations
would
require compliance
with
Articles 9(2) and 10(2) for
the
planned
rollout
of electricity smart meters, as well as
any future rollout of gas smart meters
that might arise from a
future cost benefit analysis for gas smart meters post
-
2015.
That way, legislation for the minimum
requirements of gas smart meters would be in place regardless of the outcome of the CBA.
It is
anticipated that
regulations and
any necessary
relevant licence conditions would
be in place by 5 June
2014, in accordan
ce with the timetable for transposition laid out in the Directive. This
would
not impact
on the timetable for the introduction of smart meters, which would continue as originally planned.
In
effect, the transposition of the EED would create minimum requi
rements for smart meters on which any
further consultation on the roll
-
out of smart meters would build.
3.9
While there might appear to be timing issues with the requirement to ensure transposition of the Directive
by 5 June 2014
and the planned UR consultation on nature and timescale of domestic smart meter roll
-
out
, in practice
the EED requirement will be
come
the
minimum requirement
of the smart meter roll out
and there should be no conflict between that and more detailed work t
o determine how the domestic
electricity smart meter roll out progresses in Northern Ireland. DETI and UR will work closely to ensure
that feedback from this consultation is taken on board in any further work on smart meters.
3.10
Article 10(3) introduc
es requirements that apply to meters independently of whether smart meters have
been installed or not. These requirements, and the proposals for their implementation, are covered
separately in
Chapter 4
of this document.
CONSULTATION QUESTION
3.1
(a)
What
issues arise or might arise from implementation of the requirements of the Energy
Efficiency Directive in relation to electricity and gas smart meters?
(b)
What are the potential cost implications
and benefits
of implementing the requirement of the
Energy Eff
iciency Directive in relation to smart metering and billing?
10
Billing
Information
Requirements
Article 10(1)
4.1
W
here final customers
do not have
smart meters
as referred to in Directives 2009/72/EC and
2009/73/EC, Member States shall ensure
,
by
31 December 2014
,
that billing
information
is accurate
and based on actual consumption
, in accordance with point 1.1 of Annex VII, for all the sectors covered
by this
Directive, including energy distributors, distribution system operators and retail energy sales
companies, where this is technically possible and economically justified
.
Point 1.1
of Annex VII states that b
illing based on actual consumption must take place at least once a
year, and billing information must be provided to final customers at least twice a year, or at least quarterly
at the customer’s request or if they are billed electronically.
4.2
This ob
ligation
may
be fulfilled by
a system of regular self
-
reading by the final customers whereby they
communicate
readings from their meter to the energy supplier.
Only when the final customer has not
provided a meter reading for a given billing
interval shall
billing be based on estimated consumption or a
flat rate.
4.3
The consumption of natural gas can be exempted from the above requirements when it is used for
cooking purposes only.
Article 10(2)
4.4
This requirement relates to smart metering and is covered by
chapter
3
.
Article 10(3)
4.
5
Article 10(3)
states that independently
of whether smart meters are available or not
, Member States:
(a)
shall require that,
to the extent that
information on the energy billing and historical consumption of
final customer
s is available, it
be made available
, at the request of the final customer,
to an energy
service provider designated by the final customer.
(b)
shall ensure that f
inal customer
s
are
offered the option of electronic billing information and bills
and
that t
hey receive, on request, a clear and understandable explanation of how their bill was derived,
especially where bills are not based on actual consumption.
(c)
shall
ensure that a
ppropriate information
is
made available with
the bill
to provide final customers with
a comprehensive account of current energy costs
, in accordance with Annex VII
;
(d)
may lay
down that, at the request of the final customer, the informatio
n contained in these bills shall
not be considered to constitute a request for payment. In such cases, Member States
shall
ensure that
suppliers of energy sources offer flexible arrangements for actual payments.
4
11
(e)
shall require that i
nformation and estimates for energy costs
are
provided to consumers on demand in
a timely manner and in an easily understandable format enabling consumers to compare deals on a like
-
for
-
like basis.
Annex VII
4.6
Annex VII is closely related to the requirements of Article 10, and sets out the minimum requirements for
billing and billing information based on actual consumption. The
minimum
requirements
for billing
contained wit
hin Annex VII are set out below:
1.1.
Billing based on actual consumption
In order to enable final customers to regulate their own energy consumption, billing should take place on
the basis of actual consumption at least once a year, and billing information should be made available at
least
quarterly, on request or where the consumers have opted to receive electronic billing or else twice
yearly. Gas used only for cooking purposes may be exempted from this requirement.
1.2. Minimum information contained in the bill
Member States shall ensur
e that, where appropriate, the following information is made available to final
customers in clear and understandable terms in or with their bills, contracts, transactions, and receipts at
distribution stations:
(a) current actual prices and actual consum
ption of energy;
(b) comparisons of the final customer’s current energy consumption with consumption for the
same period in the previous year, preferably in graphic form;
(c) contact information for final customers’ organisations, energy agencies or simi
lar bodies,
including website addresses, from which information may be obtained on available energy
efficiency improvement measures, comparative end
-
user profiles and objective technical
specifications for energy
-
using equipment.
In addition, wherever pos
sible and useful, Member States shall ensure that comparisons with an
average normalised or benchmarked final customer in the same user category are made
available to final customers in clear and understandable terms, in, with or signposted to within,
thei
r bills, contracts, transactions, and receipts at distribution stations.
1.3. Advice on energy efficiency accompanying bills and other feedback to final customers
When sending contracts and contract changes, and in the bills customers receive or through
websites
addressing individual customers, energy distributors, distribution system operators and retail energy
sales companies shall inform their customers in a clear and understandable manner of contact
information for independent consumer advice centres,
energy agencies or similar institutions, including
their internet addresses, where they can obtain advice on available energy efficiency measures,
benchmark profiles for their energy consumption and technical specifications of energy using appliances
that
can serve to reduce the consumption of these appliances.
Current Position
and Policy Proposals
Article 10(1)
4.7
There are a number of rules governing metering and meter readings within Northern Ireland through
licence
conditions
governing
gas and electricity supply.
The
licence
conditions that are relevant to the
requirements of A
rticle 10(1) are outlined below:
In relation to electricity, the following licence conditions are relevant:
requirement on suppliers to send
domestic
customers
a bill or stateme
nt on at least an annual basis;
requirement to make reasonable endea
vours to take an actual reading;
requirement to show amount of elect
ricity consumed since last bill;
requirement to provide customer informatio
n on energy consumed on req
uest
(in each case by reference
to a meter reading)
;
and
requirement to calculate bill via a meter read or estimate when read not available.
In relation to gas, the following licence conditions are relevant:
suppliers shall send bill or statement on at l
east an annual basis to
domestic
customers
;
requirement to use reasonable endeavours to take an actual meter readi
ng on at least an annual basis;
requirement for bill or statement to show the amount of gas which has been consumed sin
ce the last bill
or sta
tement;
r
equirement to provide customer informatio
n on energy consumed on request;
and
12
r
equirement to calculate bill based on a meter reading or if no meter read available based on an
estimate.
4.8
As these licence conditions make clear, some key pad,
or pre
-
payment, customers do not receive bills,
but do receive annual statements. In this consultation, the term “bill” should also be taken to cover the
statement received by key pad/ pre
-
payment customers. Consultation questions also ask for specific
i
nformation about how the requirements of the Directive can apply to these customers.
4.9
It
appears that Northern Ireland
is
partially
compliant with
some
of the requirements of Article 10(1)
through these licence conditions.
However, there are requirements cont
ained within Article 10(1) which
are not fully met
by existing licence conditions: o
ne aspect of Article 10(1)
(Annex VII
)
where Northern
Ireland
is not
fully compliant is the requirement to provide billing information
to final customers on a bi
-
annual
(i.e.
twice yearly
)
basis
: currently, e
lectricity
and gas suppliers are
only required to provide this
information to final customers on an annual basis.
If this requirement is to be met through the system of
regular self
-
reading which is permitted in the second paragraph of Article 10(1), it is likely that a more
explicit system will need to be specified in law.
I
n addition, it can be argued that the requirement to
ensure that billing information is accurate and based on
actual consumption goes beyond what is
currently required of gas and electricity suppliers through existing licence conditions
.
4.10
In order to ensure
that the
requirements of Article
10(1) are fully met in Northern Ireland
, i
t is likely that
legislati
on
that would amend the Electricity
and Gas
Order
s
requiring
licence
s
to include conditions to
ensure any activity authorised by it is carried out in compliance with the relevant requirements laid down
by Articles 10(1) and 10(3) of the EED in relation to billing information.
The conditions included in
new
and existing
ele
ctricity
and gas
licence
s
are likely to
require the licence holder to ensure that:
billing information is provided to
all
customers
(not just domestic customers)
twice yearly;
the option for a consumer to submit a self
-
reading is offered before a bill bas
ed on an estimate of the
licence holder is issued;
information on the energy billing and historical consumption of final customers is provided to energy
service providers as well as suppliers;
final customers are offered the option of electronic billing in
formation and bills; and
compliance with billing guidance, as prepared and published by the Authority from time to time, is
mandatory.
4.11
T
he requirement of Article 10(1) has a different date from the overall transposition date of 5 June 2014:
the requirement is to ensure that billing from 31 December 2014 conforms to the requirement of the
Directive. The Department has taken the view that d
oes not mean that the legislation does not need to
come into force until 31 December, but rather that any bill issued from 31 December onwards must
conform to the requirements of the Directive.
CONSULTATION QUESTION
4.1
(a)
What issues arise from the
proposal to put in place legislation to support the su
pply licence
conditions
to
meet the requirements set out in
para
graph
4.10
?
(b)
What are the particular issues connected with extending requirements to cover non
-
domestic
customers?
(c)
What are the
particular issues connected with these changes for keypad customers?
(d)
What costs
and benefits might arise as a result of the proposed
changes
?
Pl eas e gi ve f ul l
det ai l s.
Ar t i cl e 10( 3)
4.12
Ar t i cl e 10( 3) i nt r oduces a number of r equi r ement s i n r el at i on
t o bi l l i ng i nf or mat i on t hat must be met,
whet her smar t met er s hav e been i nst al l ed or not. The cur r ent ar r angement s i n r el at i on t o each of t he
i ndi vi dual r equi r ement s ar e set out bel ow, al ong wi t h t he Depar t ment ’ s vi ew on whi ch of t hese
r equi r ement s ar e al
r eady met by ex i st i ng l i cence condi t i ons, and whi ch r equi r ement s wi l l need f ur t her
modi f i cat i on t o gas and el ect r i ci t y suppl y l i c ences i n or der t o be abl e t o demonst r at e f ul l compl i ance.
13
4.13
The Electricity and Gas (Billing) (No. 2) Regulations
(Northern Ireland) 2010
3
require electricity and gas
suppliers to provide information to domestic consumers comparing their gas or electricity use in one
period with the same period in the previous year.
Licensed gas and electricity suppliers already prov
ide
domestic
, but not non
-
domestic,
customers with bills that show current actual prices and energy
consumption
(either actual or estimated)
. In addition, all of the operating licensed electricity and gas
suppliers have
, as far as is known,
online billing
and account functions available to customers. Under
electricity licence
conditions
, the licence holder is required to send a bill or statement, by way of a paper
hard copy or in such other form as agreed with the customer. However, there is no explicit
req
uirement for
online billing.
4.1
4
In order to ensure compliance with the Third Package, modifications were made to supplier licences.
These modifications introduced a requirement for suppliers to provide regular billing information to
customers, includi
ng:
the name and address of the supplier;
the meter number applicable to the customer’s premises;
information on the tariff;
all relevant consumption data for the current billing period and consumption for the same period for
the previous year (if with the
same supplier);
the total charges (including and excluding VAT) applicable for the period;
Fuel Mix information (electricity only);
information about customer’s rights in relation to complaints and contact details for the Consumer
Council of Northern Irel
and;
whether the bill is based on an estimate or actual consumption;
for estimated bill, details of how the customer can register a self read;
a reminded that the customer can change supplier and information about where the customer can
obtain further info
rmation about changing supplier;
information about the Code of Practice which sets out the services, advice and assistance it provides
to customers who may be having difficulty in paying for their electricity or gas.
10(3)(a)
4.15
In relation to electricity,
an
existing licence
condition
of electricity supply licences
, entitled
“
Provision of
Information to Electricity Suppliers
”
, requires
that within 5 working days of receiving a Customer
Informat
ion Request from a supplier the
supplier must provide that information if they are currently
supplying electricity or have done so at any time in the 12 months prior. The supplier requesting
information must have the consent of the customer to obtain the information.
In relation to ga
s, the
requirements outlined above are placed on suppliers through Condition 2.28 of gas supply licences.
However, there is no requirement under the electricity and gas licence conditions that information is
made available, at the request of the final cust
omer, to an energy service provider designated by the final
customer.
4.1
6
In light of this,
licence
conditions
will be needed
to ensure that the authorised activities comply with
the EED in relation to billing information
under
Article 10(1) of the EED
and Annex VII of the EED.
CONSULTATION QUESTION
4.2
(a)
What issues might arise from new
or amended
licence condition
s
requiring electricity
and gas
suppliers to provide the required information to an energy service company designated by the
final customer
?
(b)
What are the particular issues connected with these changes for keypad customers?
(c)
What are the particular issues connected with extending requirements to cover non
-
domestic
customers?
(d)
Do you anticipate any additional costs or benefits arising as a
result of the proposed
modification?
If so, please give as much detail as possible.
3
http://www.legislation.gov.uk/nisr/2010/27/contents/made
14
10(3)(b
)
4.17
Electricity and gas supply licence condition
s
contain requirements for electricity and gas bills to show the
name of tariff, unit rate, any discount or premium applied, total charges applicable setting out clearly any
standing charges and showing charges both inclusive and exclusive of VAT, the amoun
t of electricity
/gas
consumed since the last bill or statement, and information on self reads and if the bill has been
estimated. The Department believes that these
existing
licence conditions are sufficient to ensure that
final
customers receive a clear
and understandable explanation
of how their bill was derived, and does
not propose to take any further action to transpose
this
aspect
of Article 10(3)(b).
4.18
However, Article 10(3)(b) of the EED
also
includes a requirement for customers to be offere
d online billing
services
. A
lthough electricity and gas suppliers in NI do appear to offer
online billing
in practice
,
there is
no explicit requirement in the electricity or gas supply licence conditions for them to do so. Under the
electricity and gas li
cence conditions, suppliers are required to send a bill or statement, by way of a paper
hard copy or in such other form as agreed with the customer
-
there
is no explicit reference to online
billing.
4.19
R
egulations and licence
conditions
will need to be introduced in order to obligate suppliers to offer the
option of online billing. A rollout of online billing could also strengthen compliance with various other
aspects of Article 10 of the Directive, as depending on the functionality of
such websites, customers may
be afforded online access to electricity usage at any time and graphical comparisons of household energy
usage for specific periods.
CONSULTATION QUESTION
4.3
(a)
Do you think that the existing supply licence conditions outlined
above are sufficient to ensure
that final customers receive a clear and understandable explanation of how their bill was
derived?
If not, what more could be done to achieve this end? Please give details
(b)
What
issues arise from
an obligation on suppliers to offer online billing services?
(c)
What are the particular issues connected with these changes for keypad customers?
(d)
What are the particular issues connected with extending requirements to cover non
-
domestic
customers?
(e)
Do you
anticipate any additional costs or benefits arising as a result of the proposed
modification? If so, please give as much detail as possible.
10(3)(c
)
4.20
There do not appear any
specific
supply licence conditions currently in place for gas and electricity which
would ensure compliance with
Article 10(3)(c)
(information on current energy costs)
.
Regulations and
licence modifications will need to be introduced in order to
ensure that gas an
d electricity suppliers are
obliged to provide to final customers, with their bill, a comprehensive account of current energy costs in
accordance with Annex VII
(see below)
.
Annex VII is considered in detail separately
with
in this
chapter
of
the consultat
ion document
and separate consultation questions are associated with it
.
10(3)(d)
4.
21
Under Article 10(3)(d), Member States have the option of laying down that, at the request of the final
customer, the information contained in these bills shall not be considered to constitute a request for
payment.
There does not currently appear to be an
ything in place in Northern Ireland, either in legislation
or in gas or electricity supply licence conditions, that
differentiates between information that is provided
with the bill and the actual demand for payment.
4.22
Article 10(3)(d) also requires M
ember States, if they choose to implement the first
part of
10(3)(d), to
ensure that suppliers of energy sources offer flexible arrangements for actual payments. Although the
first
part of 10(3)(d)
is not currently implemented in Northern Ireland, there a
re gas
and electricity supply
licence conditions
in place that
ensure that
standard terms and conditions of contracts provide a choice
15
of payment methods. In addition, licence condition
s
ensure that suppliers’ Codes of Practice include
arrangements for customers
with payment
difficulties.
4.23
UK t
ransposition guidance indicates that the
minimum requirements
of European Directives should be
implemented, unless there are exceptional circ
umstances justified by a cost
-
benefit analysis and
consultation with stakeholders.
We welcome stakeholders views as to the benefits and drawbacks of
action to implement
Article 10(3)(d)
, and any potential costs of doing so
.
If there is enough compelling
evidence that the implementation of Article 10(3)(d) would be of benefit to Northern Ireland, DETI would
consider transposing the measure into legislation.
CONSULTATION QUESTION
4.4
(a)
Do you think that there are any exceptional circumstances that would
necessitate transposition
of Article 10(3)(d)?
What would be the costs and benefits of doing so?
(b)
What would be the particular issues connected with extending requirements to cover non
-
domestic customers and keypad customers?
10(3)(e)
4.24
Electricity
and gas
supply licence condition
s
place r
equirements on gas and electricity suppliers to
provide information
to
domestic
customers, as part of standard terms and conditions,
that allows the
customer to identify the applicable tariff and the un
it rate.
Electricity and gas suppliers are also required
to provide a customer, on request,
information on the qua
ntity of electricity which the l
icensee’s re
cords
show as consumed by that c
ustomer.
In addition, suppliers are required by licence
condition to ensure
that customers are informed of the “Consumer Checklist”
4
which provides information to consumers
about how to compare deals and what information they would need to so.
However, it is not likely that
the consumer checklist is accessible
enough to consumers to ensure compliance.
4.25
It is unlikely that the licence conditions outlined above will be sufficient to meet the requirements of
Article (3)(e). Specifically, it is not clear that the information that must be provided under these
conditions
is
:
sufficient to enable customers to compare deals on a like
-
for
-
like format;
provided in a timely manner;
provided in
an easily understandable format;
sufficient
to ensure that the Directive’s requirements are met in relation to non
-
domestic
customers.
The Department is of the view that
legislation requiring
licence condition modifications will be necessary
to ensure that the information that must be provided meets these criteria.
CONSULTATION QUESTION
4.5
(a)
What specific information do you think would be necessary to ensure that customers are able
to
compare deals on a like
-
for
-
like basis?
(b)
What
conditions would constitute “
in a timely manner
”
?
(c)
What, in your view, would be the best
and most cost effective
way to present the relevant
information “
in an easily understandable format
”?
(d)
What are the
particular issues connected with these changes for keypad customers?
(e)
What are the particular issues connected with extending requirements to cover non
-
domestic
customers?
(f)
What potential costs and benefits do you think are associated with the
se requiremen
ts
?
4
http://www.uregni.gov.uk/uploads/publications/EU_Consumer_Checklist_December_2012.pdf
16
Annex VII
There will inevitably be some overlap between consideration of issues raised above through the core text of Article
10 and consideration of issues under Annex VII: DETI appreciates the time taken by consultees to go through the
text in
detail and to consider each issue. Where the issues overlap with answers given to questions above, please
feel free to refer to the separate answer to a specific consultation question.
1.1
–
Billing based on actual consumption
4.
26
There are a number of rules
currently
governing billing and billing information within Northern Ireland
through the conditions
in
gas and electricity supply licences. The conditions that are relevant to the
requirements of 1.1 Annex VII are outlined
in pa
ra
graph
4.6
above
.
4.2
7
The
se
conditions are not sufficient to meet the requirements of 1.1 of Annex VII.
New licence conditions
will be necessary in order to ensure that:
b
illing takes place on the basis of actual consumption at least once a year;
b
illing
information is made available:
at least quarterly on request or where the customer has opted to
receive electronic billing; or else
twice yearly.
CONSULTATION QUESTION
4.6
(a)
What potential costs and benefits do you think are associated with the
requirements
?
(b)
What are the particular issues connected with these changes for keypad customers?
(c)
What are the particular issues connected with extending requirements to cover non
-
domestic
customers?
1.2
–
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(a)
Do you think that comparisons between current and previous energy consumption should be in
graphic form, and
if
so
,
what would be your preferred format and why?
Please give full details.
(b)
If you do not believe that a graphic format would be best, please outline how you believe the
comparison should be made with full details.
(c)
What are the particular issues connecte
d with these changes for keypad customers?
(d)
What are the particular issues connected with extending requirements to cover non
-
domestic
customers?
(e)
What potential costs and benefits do you think are associated with the proposed licence
condition modificatio
ns?
(f)
This section of Annex VII is qualified by the words “where appropriate”
–
are there any
17
circumstances where this requirement is not appropriate? Please give full details.
4.30
Electricity and gas suppliers are required to p
repare, submit to and have approved by the Authority a code
of practice setting out the ways in which the Licensee will make available to Customers information and
guidance on the efficient use of electricity. However, the requirement is not as specific a
s that contained
in the Directive and
t
he Department and the Utility
believe that f
urther
licence
conditions
will be needed
in order to ensure that compliance with this requirement is achieved. It is proposed that the conditions
that will be modified in order to achieve this are in relation to “Provision of information to customers”, and
“Code of Practice on ef
ficient use of electricity/gas”.
CONSULTATION QUESTION
4.8
(a)
What issues arise from a new requirement to provide energy efficiency information with bills
etc?
(b)
What potential costs and benefits do you think are associated with the proposed licence
condition modifications?
(c)
What are the particular issues connected with these changes for keypad customers?
(d)
What are the particular issues connected with extending requirements to cover non
-
domestic
customers?
(e)
This section of Annex VII is qualified by th
e words “
where appropriate
”
–
are there any
circumstances where this requirement is not appropriate? Please give full details.
4.31
In relation
to
the final paragraph
of 1.2 of Annex VII,
(enabling comparisons with average normalised or
benchmarked final customer), there
is currently nothing in place in legislation or licence conditions which
requires suppliers to provide this information to customers.
DETI is aware of the existence of
onl
ine tools
that provide this type of information, for example, Compare My Energy
5
, which is provided by Energy UK
and provides limited information for Northern Ireland. DETI
will need
to bring forward
legislation to
support new
licence
condition
s to ensure
that the requirements of the paragraph are met in Northern
Ireland.
CONSULTATION QUESTION
4.9
(a)
What issues arise from an obligation on suppliers to provide this information to customers
along with their bills?
(b)
What are the particular issues connected
with these changes for keypad customers?
(c)
What are the particular issues connected with extending requirements to cover non
-
domestic
customers?
(d)
What costs
and benefits
are associated with the requirement to provide the necessary
information along with
gas and electricity bills?
Please give full details of how this requirement
could be met a least cost.
(e)
What are your views on whether the requirements of this paragraph are “possible and useful”?
1.3
–
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they can find the “Consumer Checklist” referenced above, which does include information about where
5
http://www.comparemyenergy.org.uk/
18
energy efficiency advice can be loc
ated.
6
Again, h
owever, it is not likely that the consumer checklist is
accessible enough to consumers to ensure compliance.
Licence
conditions
may
be required to introduce
this requirement. The licence condition that has been identified as the most appr
opriate condition to
amend in relation to this requirement is “Provisi
on of Information to Customers”.
4.33
This
requirement also explicitly applies to distribution system operators.
Currently, DETI is not aware that
the electricity DSO bills final cust
omers, but the gas DSO might bill a customer for moving a meter, but
would more usually bill the supplier who would pass on the charge.
In order to ensure that the
requirement is fully met, a licence modification to
electricity and gas
distribution syst
em operator licence
s
may
also be necessary
to cover the eventuality of a distribution system operator billing a final customer
.
CONSULTATION QUESTION
4.10
(a)
What issues arise from an obligation on suppliers
and distribution system operators
(
if and
when
they are billing final customers)
to provide this information to final customers along with
their bills?
(b)
What are the particular issues connected with these changes for keypad customers?
(c)
What are the particular issues connected with extending requirement
s to cover non
-
domestic
customers?
(d)
What costs and benefits are associated with the requirement to provide the necessary
information along with gas and electricity bills?
Other requirements of Article 10
4.34
Article 10(2) introduces requirements specifically in relation to where meters have been installed in
accordance with Directives 2009/72/EC and 2009/73/EC. The requirements of 10(2), the current
position in Northern Ireland and the policy proposals for im
plementing these requirements are therefore
covered separately in
chapter 3
of this document.
4.35
The requirements of 10(1) and 10(3) apply to all of the sectors covered by the Energy Efficiency Directive
in relation to metering
.
DETI, having taken app
ropriate advice, believes that this covers electricity, gas,
hot water, district heating and cooling.
This
chapter has
consider
ed
the requirements
of Article 10(1) and
(3)
as they apply to electricity and gas.
In relation to the district heating and cool
ing and hot water
aspects of Article 10(1) and 10(3), it is anticipated that the Department of Energy and Climate Change
will be issuing a public consultation on the policy options for installing heat meters before the end of
2013. It is expected that thi
s consultation will be carried out on a UK wide basis, and the requirements of
the Energy Efficiency Directive in relation to heat metering are therefore not considered in this document.
6
http://www.uregni.gov.uk/uploads/publications/EU_Consumer_Checklist_December_2012.pdf
19
Cost of Access to Metering and Billing information
(Article 11
(1)
)
Requirements
5.1
Under Article 11(1),
Member States
shall
ensure that
final customers receive all their bills and billing
information for energy consumption free of charge
and that
f
inal customers also have access to their
consumption data in an appropriate way and free of charge.
Current Position
and Proposals
5.2
In the context of Article 11(1), there are two possible interpretations of the phrase “free of charge.” This
could
be read either as meaning that:
t
here cannot be a separate charge for any customer who receives a bill, billing information or
consumption data. Under this interpretation, customers collectively would still have to meet the cost of
producing the informati
on but because that would be shared around all customers, no
-
one would be
relieved of the costs by opting not to receive the information; or
t
he supplier must itself absorb the cost of the information and must not pass it on to the customers
in
anyway,
eve
n collectively.
5.3
The Department is of the view that the intended
meaning here
is that there cannot be a separate charge
for any customer who receives a bill, billing information or consumption data,
as
t
his interpretation
appears to be more consistent
with the apparent purpose of the Directive in giving customers the right to
the information in question, and ensuring that there is no disincentive to a customer receiving the
informa
tion to which they are entitled. This also reflects current practice in
Northern Ireland for the
majority of cases.
5.
4
The existing rules for suppliers relating to the provision of information to customers are set out under the
current gas
and electricity supply licences.
Currently, gas and electricity suppliers are
obliged to provide
details of all the tariffs, charges and other payments which are required to be paid by the customer in a
manner that enables the customer to, amongst other things, identify any other charge or payment.
However, there is currently no ex
plicit requirement on gas and electricity suppliers to provide customers
with bills and billing information free of charge
at the point of request
, or to provide consumption data
free of charge.
5.
5
In relation to electricity and gas, suppliers will need
to be more explicitly obliged to provide the
information required under Article 11(1) to customers free of charge.
Supply licence
conditions
will also
be necessary to ensure that the requirements of Article 11(1), in particular in relation to the provisio
n of
information to the customer free of charge, are fully met in Northern Ireland.
5
20
CONSULTATION QUESTION
5.1
(a)
What issues arise from an explicit requirement to ensure no separate charges are made for
bills, billing information and consumption data
?
(b)
What costs
and benefits
do you believe would be associated with these amendments?
Please
give details
to support your assertion
.
(c)
Under Article 11(1), customers must be given access to their consumption data in an
appropriate way. What would you consider
to be an appropriate means of providing
consumption data?
Other Requirements of Article 11
5.6
In relation to the requirements of Article 11 with regard to heating and cooling, it is anticipated that the
Department of Energy and Climate Change will
be issuing a public consultation on the policy options for
installing heat meters before the end of 2013. It is expected that this consultation will be carried out on a
UK wide basis. The heating and cooling aspects of Article 11 are therefore not consid
ered in this
document.
21
GLOSSARY
The Department
means the Department of Enterprise, Trade and Investment.
DECC
means the Department of Energy and Climate Change
The Directive
means Directive 2012/27/EU of the European Parliament and of the
Council of 25 October 2012
on energy efficiency
.
DSO
means
Distribution System Operator
a
natural or legal person
responsible for operating, ensuring the maintenance of and, if
necessary, de
veloping the distribution system in a given area and,
where applicable, its interconnections with other systems and for
ensuring the long
-
term ability of the system to meet reasonable
demands for the distribution of electricity
Electricity Directive
means Directive
2009/72/EC of the European Parliament and of the
Council
of 13 July 2009
concerning common rules for the internal
market in electricity and repealing Directive 2003/54/EC
Electricity Order
means
the Electricity (Northern Ireland) Order
1992.
Energy Order 2003
means
The Energy (Northern Ireland) Order 2003
(S.I.
2003 No. 419
(N.I. 6))
Gas Directive
means Directive
2009/73/EC of the European Parliament and of the
Council
of 13 July 2009 concerning common rules for the internal
market in natural gas and repealing Directive 2003/55/EC
Utility Regulator
means the Northern Ireland
Authority for
Utility Regulat
ion
NIE
means Northern Ireland Electricity plc.
Ofgem
means the Office of Gas and Electricity Markets.
Third Package
means the
third European package on market liberalisation in the
energy sector
22
Annex A
-
Relevant links
Link to the full text of the Energy Efficiency Directive
http://eur
-
lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2012:315:0001:0056:EN:PDF
Link to t
wo Directives concerning common rules for the internal market in gas and electricity (the new gas
Directive and the new Electricity Directive)
The Gas Directive
http://eurlex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:211:0094:0136:en:PDF
The Electricity Directive:
http://eur
-
lex.europa.eu/LexUriServ/L
exUriServ.do?uri=OJ:L:2009:211:0055:0093:EN:PDF
23
Annex
B
–
Other actions in relation to the Directive
This Annex sets out a summary of the action that is planned
to ensure Northern Ireland transposes and
complies
with other requirements of the Energy Efficiency Directive.
Article 4
–
Building Renovation
DETI, DSD, DFP and Invest NI are working with DECC and
the Department of Communities and Local Government
on research to establish a UK
-
wide strategy f
or mobilising investment in the renovation of the national stock of
residential and commercial buildings, both public and private as required by the Directive. The strategy must be
published by 30 April 2014.
Articles 5
–
Exemplary role of public bodies’ buildings and Article 6
–
Purchasing by public bodies
The Department of Finance and Personnel (DFP) is responsible for the implementation of these
Articles
for
Northern Ireland.
Article 7
–
Energy Efficiency Obligation
Schemes
Northern Ireland will contribute to the achievement of the 1.5% annual energy savings target for the UK through
policy measures allowed for under Article 7(9).
Article 8
–
Energy audits and energy management systems
DECC has published a consu
ltation on the implementation of Article 8(4), the requirement for mandatory energy
audits of large enterprises, which covers the whole of the UK:
https://www.gov
.uk/government/consultations/energy
-
savings
-
opportunity
-
scheme
The consultation
close
d
on 3
October 2013. Other requirements of Article
8
will be dealt with within Northern Ireland.
Article 12
–
consumer information and empowering programme
DETI is wo
rking with DSD, DFP and Invest NI to ensure that Northern Ireland is in compliance with the consumer
information and empowering programme requirements of Article 12.
Article 13
-
penalties
Article 13 requires member states to lay down rules on penalties applicable in the case of non
-
compliance with
national provisions adopted pursuant to Articles 7 to 11 and Article 18(3).
Article 14
–
Promotion of efficiency in heating and cooling
DETI is
working with DECC to ensure that the requirement for an assessment of the potential for high
-
efficiency co
-
generation and efficient district heating and cooling is carried out on a UK
-
wide basis by 31 December 2015.
Regulations to ensure that the require
ments of Article 14(5)
-
(9) are implemented are being worked on by the
Department of Environment.
Article 15
–
Energy transformation, transmission and distribution
DETI is working with the Utility Regulator to bring forward a separate consultation
on this
issue
.
Article 16
–
Availability of qualification, accreditation and certification schemes
DETI is working with DFP and DECC in considering whether the level of technical competence across the UK is
adequate.
Article
17
–
Information and training
DETI
is working with DSD, DFP and Invest NI to ensure information on energy efficiency mechanisms is available
as required.
Article 18
–
Energy services
DETI is working with DECC to ensure implementation for Northern Ireland.
24
Article
19
–
Other measures to
promote energy efficiency
DETI, DSD, DFP and Invest NI are working with DECC and DCLG on research to evaluate regulatory and non
-
regulatory barriers to energy efficiency in Northern Ireland. The requirements of Article 19(1)(b) fall to DFP in
Northern I
reland.
25
Annex C
–
Draft Equality S
creening
If you believe that DETI has overlooked any material factor in relation to the equality screening of the policies
associated with Articles 9
-
11, please respond as part of the consultation.
Part 1.
Policy scoping
The first stage of the screening process involves scoping the policy under consideration. The purpose of policy
scoping is to help prepare the background and context and set out the aims and objectives for the policy, being
screened. At th
is stage, scoping the policy will help identify potential constraints as well as opportunities and will
help the policy maker work through the screening process on a step by step basis.
Public authorities should remember that the Section 75 statutory duti
es apply to internal policies (relating to
people who work for the authority), as well as external policies (relating to those who are, or could be, served by
the authority).
Information about the policy
Name of the policy
–
das 慮a 敬散er楣楴y b楬汩湧i
慮a m整er楮i 慳p散es 潦⁴桥⁅湥ngy b晦fc楥湣y
a楲散e楶e
fs t桩h 慮a數楳t楮iI r敶楳敤e潲 愠湥n po汩捹㼠
q桥⁅湥ngy b晦ic楥湣y a楲散e楶攠楳 愠d敶敬opm敮琠潦o
pr散敤楮e br 汥杩g污l楯渠i渠e湥ngy m慴t敲sK
坨慴 楳 楴 try楮i t漠慣桩敶政
楮i敮摥搠
慩asL潵oc潭敳e
ㄮ
The aim of the requirements are broadly to empower final customers, both business and
domestic, by ensuring that they have the necessary access to information though meters
and bills to take control of their energy use. The requirements
are:
Article 9(1), on metering, will require that final customers of electricity and gas are
provided with competitively priced individual meters that accurately reflect the final
customer’s actual energy consumption and that provide information on actual
t業攠潦e畳攻
Articles 9(2) and 10(2), on smart metering and billing, set out requirements that must be
complied with where, and to the extent that, Member States implement intelligent
metering systems and roll out smart meters in accordance with the Third
Package;
Article 10(1), 10(3), Annex VII, on billing information i.e. that customers may request that
their consumption and billing information is made available to an energy service provider;
that customers are offered the option of electronic billing; t
hat certain information is made
available with the bill to provide final customers with a comprehensive account of current
energy costs; that information and estimates for energy costs are provided to consumers
on be made in a timely manner and in an easil
y understandable format enabling
consumers to compare deals on a like
-
for
-
like basis;
Article 11(1)) requires
Member States to ensure that
final customers receive all their bills
and billing information for energy consumption free of charge and that final
customers
also have access to their consumption data in an appropriate way and free of charge.
The policy will introduce requirements on the Northern Ireland Utility Regulator (‘the Utility
Regulator’) to ensure that gas and electricity supply companies
慮a d楳tr楢畴楯渠iyst敭e潰敲慴ors
c潭p汹 w楴栠t桥hqu楲敭敮瑳 潦⁁rt楣汥s V
-
NN 慮a A湮數 sff 潦⁴桥⁅湥n杹gb晦楣楥湣y air散e楶攠慳
t桥h r敬慴攠e漠o慳 慮a 敬散eric楴y b楬汩湧i慮a m整敲楮iK
坨楬i t桥⁒敧畬慴楯湳 睩汬⁴ra湳p潳攠e桥慳 慮a 敬散er楣楴y b楬汩
湧 慮a m整敲i湧 req畩rem敮瑳 潦o
t桥⁅湥r杹gb晦楣楥湣y a楲散e楶攠楮e漠潢汩条l楯湳 畮u敲 湡ni潮慬慷Ⱐ晵汬fp汥m敮瑡t楯i 睩汬 慬a漠
r敱畩u攠e桥hp潳楴楯渠潦iappr潰r楡i攠汩捥湣攠e潮摩o楯湳 o渠敮ergy c潭p慮楥sK 剥op潮s楢楬楴y 景f
t桥楣敮捥潮摩o楯湳 晡汬f
t漠o桥⁕h楬楴y 剥杵污o潲I 慬a桯畧栠t桥⁄数慲tm敮琠睩汬 r整e楮i潶er慬氠
r敳灯湳楢楬楴y 景f e湳畲楮i th攠eeq畩u敭敮es 潦⁴桥⁅n敲杹 b晦楣楥湣y air散e楶攠慲攠晵汬l tr慮ap潳敤e
26
Are there any Section 75 categories which might be expected to
benefit
from the intended policy?
If so, explain how.
All consumers, including section 75 categories, are expected to benefit to increased information
about their energy use from energy billing and metering.
Who initiated or wrote the policy?
The overall
policy is determined by the European Commission and the Department has an
obligation to ensure that Directive is implemented in full. DETI is undertaking a number of
consultations on the implementation of the Energy Efficiency Directive. Where the Directi
ve allows
Member States discretion with regards to aspects of its implementation, the Department will take
into account the views of respondents to those consultation exercises in developing the policy.
Who owns and who implements the policy?
DETI is ve
sted with the ownership of the policy and is responsible for making the Regulations
required to give effect to the measures contained in the Energy Efficiency Directive and for overall
implementation of the Directive. However, the Utility Regulator is res
ponsible for practical
implementation of many elements of the Directive, for example in taking forward the licence
conditions to ensure energy companies comply with the measures set out in the Energy Efficiency
Directive.
Implementation factors
Are there any factors which could contribute to/detract from the intended aim/outcome of the policy/decision?
If yes, are they
financial
legislative
other, please specify _________________________________
Main stakeholders affected
Who are the internal and external stakeholders (actual or potential) that the policy will impact upon?
staff
service users
other public sector organisations
voluntary/community/trade unions
other, please specify:
energy supply companies and consumers will be affected by implementation
Other policies with a bearing on this policy
•
what are they?
Relevant legislation that has been introduced by DETI includes the
Electricity (NI) Order 1992, the Gas (Northern
Ireland) Order 1996, and the Electricity and Gas (Billing) (No. 2) Regulations (Northern Ireland) 2010. Gas and
electricity suppliers are also subject to licence conditions introduced by the Utility Regulator.
•
who owns them?
As above
Available evidenc
e
Evidence to help inform the screening process may take many forms. Public authorities should ensure that their
screening decision is informed by relevant data. What evidence/information (both qualitative and quantitative)
have you gathered to inform th
is policy? Specify details for each of the Section 75 categories.
27
There is no relevant data in respect of Section 75 groups.
This measure aims to improve domestic and non
-
domestic gas and electricity bills by improving both the information that is
available to all customers and the
means by which it is made available. The Department believes that this will contribute to a greater understanding
of energy usage which will present all customers with a greater opportunity to realize savings on gas and
electricity
bills equally across all of the Section 75 categories.
Section 75
category
Details of evidence/information
Religious
belief
N/A
–
卥攠慢潶攠
m潬楴楣慬
潰楮i潮
kLA
–
卥攠慢潶e
剡o楡氠ir潵p
kLA
–
卥攠慢潶e
A来
kLA
–
卥攠慢潶e
䵡j楴慬a
st慴畳
kLA
–
卥攠慢潶e
卥硵xl
潲楥湴慴楯i
kLA
–
卥攠慢潶攠
䵥渠慮a
睯m敮
来湥ga汬l
kLA
–
卥攠慢潶攠
a楳慢楬楴y
kLA
–
卥攠慢潶攠
a数敮摡湴s
kLA
–
卥攠慢潶攠
ke敤eI 數p敲i敮捥e 慮a pri潲楴楥s
q慫楮i 楮i漠慣c潵湴 t桥湦潲m慴楯渠i敦err敤et漠慢ov攬e睨慴 慲攠e桥楦晥ie湴 湥ndsI 數p敲i敮捥e 慮a pr楯r楴楥s 潦o
敡捨 潦⁴桥潬汯睩湧 c慴敧潲楥sI 楮ir敬慴楯渠i漠o桥⁰hrt楣畬慲 p潬楣yLd散楳楯渿i印散楦y d整e楬i 景f 敡捨 潦⁴桥h
卥ct楯渠iR c慴敧潲楥s
kLA
-
q桥h攠楳 湯nr敬敶慮a dat愠楮ir敳灥ct 潦⁓oct楯渠iR 杲潵osK
p散e楯渠iR
c慴敧ery
a整ei汳 潦敥dsLe硰敲i敮捥eLpr楯r楴楥s
剥汩杩潵o
b敬楥f
kLA
–
卥攠慢潶攠
m潬楴楣慬
潰楮i潮
kLA
–
卥攠慢潶攠
剡o楡氠ir潵p
kLA
–
卥攠慢潶攠
A来
kLA
–
卥攠慢潶e
䵡j楴慬ast慴畳
kLA
–
卥攠慢潶攠
卥硵xl
潲楥湴慴楯i
kLA
–
卥攠慢潶e
䵥渠慮a
睯m敮
来湥ga汬l
kLA
–
卥攠慢潶攠
28
Disability
N/A
–
See above
Dependants
N/A
–
See above
Part 2. Screening questions
Introduction
In making a decision as to whether or
not there is a need to carry out an equality impact assessment, the public
authority should consider its answers to the questions 1
-
4 detailed below.
If the public authority’s conclusion is
none
in respect of all of the Section 75 equality of opportunity
and/or good
relations categories, then the public authority may decide to screen the policy out. If a policy is ‘screened out’ as
having no relevance to equality of opportunity or good relations, a public authority should give details of the
reasons for th
e decision taken.
If the public authority’s conclusion is
major
in respect of one or more of the Section 75 equality of opportunity
and/or good relations categories, then consideration should be given to subjecting the policy to the equality
impact assess
ment procedure.
If the public authority’s conclusion is
minor
in respect of one or more of the Section 75 equality categories and/or
good relations categories, then consideration should still be given to proceeding with an equality impact
assessment, or t
o:
•
measures to mitigate the adverse impact; or
•
the introduction of an alternative policy to better promote equality of opportunity and/or good relations.
In favour of a ‘major’ impact
愩⁔桥 p潬楣y 楳 s楧i楦楣慮a 楮it敲ms 潦os str慴敧楣 業p潲ta湣e
;
bF m潴敮瑩e氠lq畡汩uy 業p慣ts 慲攠畮e湯睮Ⱐb散慵e攬e景f e硡xp汥I t桥h攠楳 楮i畦晩u楥湴 d慴愠異潮⁷桩o栠t漠o慫攠慮e
慳s敳em敮琠潲 b散慵e攠e桥h 慲攠e潭pl數I 慮a 楴 睯畬搠b攠慰eropr楡i攠e漠o潮摵ot 慮a敱畡u楴y 業p慣t
慳s敳em敮琠楮i潲d敲 t漠o整e敲 慳s敳e t桥h;
cF m潴敮瑩e氠lq畡u楴y 慮aL潲 g潯d r敬慴楯湳 業p慣ts 慲攠汩e敬y t漠o攠慤v敲s攠er 慲攠e楫敬y t漠o攠數per楥湣敤e
d楳pr潰潲t楯i慴敬y by gr潵ps 潦⁰oop汥 i湣汵摩湧 t桯h攠睨漠慲o m慲杩g慬楳敤e潲 d楳慤v慮a慧敤e
dF 䙵ct桥r 慳s敳em敮琠潦晥os 愠v慬畡a汥 睡y t漠數慭i
n攠e桥h楤敮捥湤 d敶敬op r散潭m敮摡e楯湳 楮ir敳e散e 潦o
愠p潬楣y 慢o畴 睨楣栠t桥h攠慲攠e潮捥o湳 慭潮杳t 慦a散e敤e楮i楶楤畡汳 慮a repr敳敮e慴楶攠ero異sI 景f e硡xpl攠
楮ir敳e散e 潦畬u楰汥 楤敮瑩ei敳e
攩 qh攠e潬楣y 楳 汩l敬y t漠o攠eh慬汥湧敤eby 睡w 潦畤i
c楡氠牥v楥眻
昩†q桥⁰潬楣y 楳 s楧i楦楣慮a 楮it敲ms 潦硰敮摩e畲攮
In favour of ‘minor’ impact
愩⁔桥 p潬楣y 楳 湯n 畮污睦畬uy d楳cr業楮慴潲y 慮a 慮a r敳ed畡氠p潴敮瑩e氠業p慣ts 潮⁰e潰汥 ar攠橵e来g t漠o攠
湥杬楧楢汥;
bF q桥⁰潬楣yI or c敲t慩渠prop潳慬a
睩w桩渠楴I 慲攠e潴敮瑩e汬y 畮污睦畬uy d楳cr業楮慴潲yI b畴 t桩h p潳s楢楬楴y c慮ar敡摩汹
慮a 敡e楬i b攠敬業i湡n敤eby m慫楮i 慰ar潰r楡i攠e桡湧敳 t漠o桥⁰h汩捹r by 慤潰t楮i 慰ar潰r楡i攠e楴楧it楮i
m敡e畲敳e
cF Any 慳ymm整物捡氠eq畡汩uy 業p慣ts c慵a敤eby t桥⁰
潬楣y 慲攠楮e敮瑩潮e氠l散慵e攠e桥h 慲攠ep散楦楣慬ay d敳楧湥搠
t漠灲潭潴攠eq畡u楴y 潦pport畮楴y 景f p慲t楣畬ur 杲gups 潦楳慤v慮a慧敤ep敯p汥;
dF 䉹 慭敮摩湧 t桥⁰h汩ly t桥h攠er攠e整e敲 opp潲t畮楴楥s t漠o整e敲 pr潭潴攠eq畡汩uy 潦o潰p潲t畮楴y 慮aLor 杯潤g
牥
污l楯湳K
f渠晡v潵r 潦o湥
愩⁔桥 p潬楣y 桡s 湯敬敶慮a攠e漠敱畡汩uy 潦oport畮楴y or 杯潤gre污l楯湳K
bF q桥⁰潬楣y 楳 pur敬y t散e湩c慬a楮i湡n畲攠慮e 睩汬 桡v攠e漠o敡e楮i 楮it敲ms 潦os 汩l敬y 業p慣t 潮q畡汩uy 潦o
潰p潲t畮楴y 潲 杯潤gr敬慴楯湳 景f pe
潰l攠睩e桩渠t桥q畡汩uy 慮a 杯潤gre污l楯湳 c慴敧潲i敳e
q慫楮i 楮i漠慣c潵湴 t桥h楤敮捥⁰r敳敮e敤e慢ov攬ec潮oid敲 慮a c潭m敮琠潮⁴桥楫e汹 業p慣t 潮q畡汩uy 潦o
潰p潲t畮楴y 慮a 杯潤or敬慴楯湳 景f t桯h攠慦e散e敤eby t桩h p潬楣yI 楮i慮a 睡yI 景f 敡捨 o映th
攠敱畡汩uy 慮a 杯潤o
r敬慴楯湳 c慴敧潲楥sI by 慰p汹楮i t桥cr敥湩湧 q略ut楯湳 d整e楬id b敬潷 慮a 楮i楣慴攠e桥敶敬 潦op慣t 潮⁴桥h
杲g異 椮攮em楮潲I m慪ar 潲 湯湥n
29
Screening questions
1
What is the likely impact on equality of opportunity for those aff
ected by this policy, for each of the
Section 75 equality categories? minor/major/none
Section 75
category
Details of policy impact
Level of impact?
minor/major/none
Religious
belief
There is likely to be no significant impact on this
group
None
Political
opinion
There is likely to be no significant impact on this
group
None
Racial
group
There is likely to be no significant impact on this
group
None
Age
There is likely to be no significant impact on this
group
None
Marital
status
There is
likely to be no significant impact on this
group
None
Sexual
orientation
There is likely to be no significant impact on this
group
None
Men and
women
generally
There is likely to be no significant impact on this
group
None
Disability
There is likely
to be no significant impact on this
group
None
Dependants
There is likely to be no significant impact on this
group
None
.
2
Are there opportunities to better promote equality of opportunity for
people within the Section 75 equalities categories?
Section 75
category
If
Yes
, provide details
If
No
, provide reasons
Religious
belief
There are no specific measures that could promote
equality of opportunity within the billing and metering
requirements of the Energy Efficiency Directive
Political
opinion
There are no specific measures that could promote
equality of opportunity within the billing and metering
requirements of the Energy Efficiency Directive
Racial
group
There are no specific measures that could promote
equality of opportunity
within the billing and metering
requirements of the Energy Efficiency Directive
Age
There are no specific measures that could promote
equality of opportunity within the billing and metering
requirements of the Energy Efficiency Directive
Marital
status
There are no specific measures that could promote
equality of opportunity within the billing and metering
requirements of the Energy Efficiency Directive
Sexual
orientation
There are no specific measures that could promote
equality of opportunity wit
hin the billing and metering
requirements of the Energy Efficiency Directive
Men and
women
generally
There are no specific measures that could promote
equality of opportunity within the billing and metering
requirements of the Energy Efficiency
Directive
Disability
There are no specific measures that could promote
equality of opportunity within the billing and metering
requirements of the Energy Efficiency Directive
Dependants
There are no specific measures that could promote
30
equality of op
portunity within the billing and metering
requirements of the Energy Efficiency Directive
3
To what extent is the policy likely to impact on good relations between people of different religious
belief, political opinion or racial group?
Section 75
category
Details of policy impact
Level of impact
minor/major/none
Religious
belief
No impact
None
Political
opinion
No impact
None
Racial
group
No impact
None
4
Are there opportunities to better promote good relations between
people
of different religious belief, political opinion or racial group?
Good
relations
category
If
Yes
, provide details
If
No
, provide reasons
Religious
belief
There are no specific measures that could
promote equality of opportunity within the
billing
and metering requirements of the
Energy Efficiency Directive
Political
opinion
There are no specific measures that could
promote equality of opportunity within the
billing and metering requirements of the
Energy Efficiency Directive
Racial
group
Ther
e are no specific measures that could
promote equality of opportunity within the
billing and metering requirements of the
Energy Efficiency Directive
Additional considerations
Multiple identity
Generally speaking, people can fall into more than one
Section 75 category. Taking this into consideration, are
there any potential impacts of the policy/decision on people with multiple identities?
(
For example; disabled minority ethnic people; disabled women; young Protestant men; and young lesbians, gay
an
d bisexual people).
No, this policy will apply equally to all.
Provide details of data on the impact of the policy on people with multiple identities. Specify relevant Section 75
categories concerned.
None, this policy will apply equally to all.
31
Part 3. Screening decision
If the decision is not to conduct an equality impact assessment, please provide details of the reasons.
If the decision is not to conduct an
equality impact assessment the public authority should consider if the policy
should be mitigated or an alternative policy be introduced.
If the decision is to subject the policy to an equality impact assessment, please provide details of the reasons.
All public authorities’ equality schemes must state the authority’s
arrangements for assessing and consulting on
the likely impact of policies adopted or proposed to be adopted by the authority on the promotion of equality of
opportunity. The Commission recommends screening and equality impact assessment as the tools to be
utilised
for such assessments. Further advice on equality impact assessment may be found in a separate Commission
publication: Practical Guidance on Equality Impact Assessment.
Mitigation
When the public authority concludes that the likely impact is ‘m
inor’ and an equality impact assessment is not to
be conducted, the public authority may consider mitigation to lessen the severity of any equality impact, or the
introduction of an alternative policy to better promote equality of opportunity or good relat
ions.
Can the policy/decision be amended or changed or an alternative policy introduced to better promote equality of
opportunity and/or good relations?
If so, give the
reasons
to support your decision, together with the proposed changes/amendments or al
ternative
policy.
The Regulations to implement the Energy Efficiency Directive will have positive benefits for all
energy customers, includ
ing the section 75 groups.
Much of the detailed aspects of implementation of the billing and metering aspects of the
Energy Efficiency Directive will fall to the Utility Regulator who will be responsible for developing
the licence conditions required und
er the Regulations. The Utility Regulator is also obliged to
bear in mind its obligations with respect to the section 75 groups in developing those conditions
and will consult further upon its proposals.
As it is not considered that the policy impacts negatively on any of the section 75 groups, the
Department does no
t consider that the policy should be amended.
N/A
It is not considered appropriate to amend or propose alternative policy as the implementation of
the Energy Efficiency Directive is expected to have a positive impact for all energy consumers.
32
Timetabling and prioritising
Factors to
be considered in timetabling and prioritising policies for equality impact assessment.
If the policy has been
‘screened in’
景f 敱畡汩uy 業p慣t 慳s敳em敮琬 t桥渠灬h慳攠慮e睥r t桥潬汯睩湧wq略ut楯湳 t漠
d整敲m楮攠楴s pri潲楴y 景f t業et慢汩湧lt桥h畡汩uy
業p慣t 慳s敳em敮琮
l渠愠sc慬攠潦‱
-
PI 睩w栠N b敩湧 t桥潷hst pri潲楴y 慮a P b敩湧 t桥楧i敳eI 慳s敳e t桥⁰h汩ly 楮it敲ms 潦os pr楯r楴y
景f eq畡汩uy 業p慣t 慳s敳em敮琮
mri潲楴y cr楴er楯i
剡o楮i
⠱
-
㌩
b晦散t 潮q畡汩uy 潦o潰p潲tu湩ny 慮a 杯潤g
re污l楯湳
kLA
卯c楡氠ie敤
kLA
Effect on people’s daily lives
kLA
Relevance to a public authority’s functions
kLA
k潴攺eq桥⁔潴h氠l慴楮i 卣pr攠s桯畬搠b攠畳敤et漠灲楯i楴楳攠e桥⁰h汩ly 楮ir慮a ord敲 睩w栠ot桥h p潬楣i敳escr敥n敤e楮i景f
敱畡u楴y 業p慣t
慳s敳em敮琮 q桩h 汩lt 潦⁰o楯i楴i敳e睩汬 慳s楳t t桥⁰畢汩挠慵a桯h楴y 楮it業整eb汩湧l a整e楬i 潦⁴桥h
Public Authority’s Equality Impact Assessment Timetable should be included in the
quarterly Screening Report.
Is the policy affected by timetables estab
lished by other relevant public authorities?
No
If yes, please provide details
Part 4. Monitoring
Public authorities should consider the guidance contained in the
Commission’s Monitoring Guidance for Use by
Public Authorities (July 2007).
The
Commission recommends that where the policy has been amended or an
alternative policy introduced, the public authority should monitor more broadly than for adverse impact (See
Benefits, P.9
-
10, paras 2.13
–
2.20 of the Monitoring Guidance).
Effective moni
toring will help the public
authority identify any future adverse impact arising from the policy which may lead the public authority to conduct
an equality impact assessment, as well as help with future planning and policy development.
Part 5. Disability
Duties
Under the Disability Discrimination Act 1995 (as amended by the Disability Discrimination (Northern Ireland) Order
2006), public authorities, when exercising their functions, are required to have due regard to the need:
to promote positive attit
udes towards disabled people; and
to encourage participation by disabled people in public life.
5.
Does this policy/legislation have any potential to contribute towards promoting positive
attitudes towards disabled people or towards encouraging participa
tion by disabled people in
public life? If yes, please give brief details.
No.
33
Annex D
-
PARTIAL REGULATORY IMPACT ASSESSMENT
The consultation asks a number of questions about the potential costs and benefits of each
requirement
, as
well as for evidence that would help inform a decision on those requirements
which are conditional on an assessment of cost effectiveness, proportionality to energy savings
achieved and technical possibility
.
While the Department anticipates that legisla
tion and new licence conditions will be needed in
order to fully demonstrate compliance with the Directive, without further evidence from
consultees it is hard to gauge the cost of implementing new billing and metering provisions.
DETI would be grateful if
consultees could provide as much information as possible to help with
the assessment of costs and benefits of the proposals.
Information provided on costs and
benefits can
, at the request of the provider,
be kept confidential to th
e Department and
separa
te from the provider’s overall
consultation response, on the basis of commercial in
confidence.
In particular, the Department is interested in gauging the impact on businesses that will be
affected by the requirements, either directly (as gas or electrici
ty companies), or indirectly as
customers of these businesses, or other businesses offering energy services.
Where any of those businesses are small businesses, it would be very helpful to know if there
are particular issues arising from the proposals.
The Department’s initial view is that the
impact on small businesses is likely to be:
For electricity and gas suppliers, few companies are small businesses, but, where they
are, the requirements of the Directive must still be complied with as they are ma
ndatory
and few exceptions are envisaged;
For small businesses which are the customers of electricity and gas suppliers, the
measures should increase the amount of information available to them which should
“strengthen the empowerment of final customers”
7
in relation to energy savings and
therefore be beneficial to this group;
For small businesses offering energy services, the additional information required by
the Directive should help assist them in helping other businesses find energy savings.
IMPLEMEN
TATION OF THE METERING AND BILLING PROVISIONS OF THE ENERGY EFFICIENCY
DIRECTIVE (2012/27/EU) IN NORTHERN IRELAND
1.
Title of proposal
1.1 The Department proposes to bring forward regulations (provisionally entitled the
Electricity and Gas (Metering and B
illing) Regulations (Northern Ireland) 2014) which will
transpose the higher level requirements of the Energy Efficiency Directive relating to
metering and billing of electricity and gas into Northern Ireland law. These regulations will
cover the metering
requirements (Article 9(1)), smart metering and billing requirements
(Article 9(2) and 10(2)), billing information (Article 10(1), 10(3) and Annex VII), and cost of
access to metering and billing information (Article 11(1)).
1.2 This partial Regulatory
Impact Assessment (RIA) supports the implementation in
Northern Ireland of the Energy Efficiency Directive, in particular of:
7
Recital 33 of the Energy Efficiency Directive
34
Article 9(1), on metering, will require that final customers of electricity and gas are
provided with competitively priced
individual meters that accurately reflect the final
customer’s actual energy consumption and that provide information on actual time
of use;
Articles 9(2) and 10(2), on smart metering and billing, set out requirements that
must be complied with where, and
to the extent that, Member States implement
intelligent metering systems and roll out smart meters in accordance with Directives
2009/72/EC and 2009/73/EC;
Article 10(1), 10(3), Annex VII, on billing information;
Article 11(1)) requires
Member States to e
nsure that
final customers receive all
their bills and billing information for energy consumption free of charge and that
final customers also have access to their consumption data in an appropriate way
and free of charge.
1.3 It should be noted that the
requirements of Article 9(1) also apply to final customers for
district heating, district cooling and domestic hot water. It is anticipated that the
requirements as they relate to these sectors will be addressed through separate legislation
on a UK
-
wide b
asis.
2.
Purpose and intended effect of measure
2.1 Objective
Metering (Article 9(1))
The objective of the policy in relation to metering is to improve results achieved to date
through the implementation of Directives 2006/32/EC, 2009/72/EC and 2009/73/E
C
which, according to the Directive (recital 32), have had a limited impact on energy
saving. Specifically, the Directive aims to ensure, in accordance with Article 9(1) of the
Directive, that so far as it is technically possible, financially reasonable a
nd
proportionate in relation to the potential energy savings, final customers for electricity
and natural gas are provided with competitively priced individual meters that accurately
reflect the final customer’s actual energy consumption and that provide i
nformation on
actual time of use. It should be noted that Article 9(1) also requires that the same
conditions are applied to final customers for district heating, district cooling and
domestic hot water. The requirements of 9(1) in relation to these sect
ors are being
addressed separately, possibly through the introduction of UK wide legislation.
Smart Metering and Billing (Article 9(2), 10(2))
The objective of the policy in relation to metering is to improve results achieved to date
through the
implementation of Directives 2006/32/EC, 2009/72/EC and 2009/73/EC
which, according to the Directive (recital 32), have had a limited impact on energy
saving to date. The policy aims to do this by ensuring that when smart metering is rolled
out, the meter
s meet the following criteria:
(a) the metering systems provide to final customers information on actual time of use
and that the objectives of energy efficiency and benefits for final customers are fully
taken into account when establishing the minimum fu
nctionalities of the meters and the
obligations imposed on market participants;
(b) the security of the smart meters and data communication, and the privacy of final
customers, in compliance with relevant Union data protection and privacy legislation, is
ensured;
35
(c) in the case of electricity and at the request of the final customer, meter operators
are required to ensure that the meter or meters can account for electricity put into the
grid from the final customer’s premises;
(d) that if final customer
s request it, metering data on their electricity input and off
-
take
is made available to them or to a third party acting on behalf of the final customer in an
easily understandable format that they can use to compare deals on a like
-
for
-
like basis;
(e)
that appropriate advice and information be given to customers at the time of
installation of smart meters, in particular about their full potential with regard to meter
reading management and the monitoring of energy consumption.
The policy also aims to
do achieve its objective by ensuring that, when
smart meters are
installed in accordance with Directives 2009/72/EC and 2009/73/EC, they must
enable accurate billing based on actual consumption. Member States shall ensure that
final customers have the pos
sibility of easy access to complementary information on
their own historical consumption, allowing detailed self checks. The complementary
information on historical consumption shall include:
i. Cumulative data
for at least the three previous years or the
period since the start of
the supply contract if this is shorter. The data shall correspond to the intervals for
which frequent billing information based on actual consumption has been produced.
ii. Detailed data
according to the time of use for any da
y, week, month and year. These
data shall be made available to the final customer via the internet or the meter
interface for the period of at least 24 months or the period since the start of the supply
contract if this is shorter.
Billing Information (
Article 10(1), 10(3), Annex VII)
The objective of the policy as it relates to
Article 10(1) and (3) and Annex VII is “to
strengthen the empowerment of final customers as regards access to information from
the metering and billing of their individual energ
y consumption”
8
.
The Directive seeks
to achieve this policy as it relates to billing information is to ensure that, w
here final
customers do not have smart meters as referred to in Directives 2009/72/EC and
2009/73/EC, billing information for gas and ele
ctricity
is accurate and based on actual
consumption, in accordance with point 1.1 of Annex VII where this is technically possible
and economically justified. Point 1.1 of Annex VII states that billing based on actual
consumption must take place at least
once a year, and billing information must be
provided to final customers at least twice a year, or at least quarterly at the customer’s
request or if they are billed electronically. This obligation may be fulfilled by a system of
regular self
-
reading by t
he final customers whereby they communicate readings from
their meter to the energy supplier. Only when the final customer has not provided a
meter reading for a given billing interval shall billing be based on estimated
consumption or a flat rate. The c
onsumption of natural gas can be exempted from the
above requirements when it is used for cooking purposes only. It should be noted that
the requirements of Article 10(1) extend to “all the sectors covered by this Directive.”
These proposals deal only with
the gas and electricity aspects of this requirement, and
other sectors are being dealt with separately.
8
Recital 33 of the EED
36
The Directive also achieves the policy’s objectives as it relates to billing information to
ensure, in accordance with
Article 10(3), that independen
tly of whether smart meters
are available or not:
(a) to the extent that information on the energy billing and historical consumption of
final customers is available, it be made available, at the request of the final customer,
to an energy service provide
r designated by the final customer.
(b) final customers are offered the option of electronic billing information and bills and
that they receive, on request, a clear and understandable explanation of how their bill
was derived, especially where bills are
not based on actual consumption.
(c) appropriate information is made available with the bill to provide final customers
with a comprehensive account of current energy costs, in accordance with Annex VII;
(d) consideration
is given to laying down that, at the request of the final customer, the
information contained in these bills shall not be considered to constitute a request for
payment. In such cases, Member States shall ensure that suppliers of energy sources
offer flex
ible arrangements for actual payments.
(e) information and estimates for energy costs are provided to consumers on demand in
a timely manner and in an easily understandable format enabling consumers to
compare deals on a like
-
for
-
like basis.
Finally, the
policy is achieved by ensuring that the requirements of Annex VII are met,
which relate to the minimum requirements for billing and billing information based on
actual consumption. The requirements contained within Annex VII are that:
In order to enable
final customers to regulate their own energy consumption,
billing should take place on the basis of actual consumption at least once a year,
and billing information should be made available at least quarterly, on request or
where the consumers have opted t
o receive electronic billing or else twice yearly.
Gas used only for cooking purposes may be exempted from this requirement.
Member States shall ensure that, where appropriate, the following information is
made available to final customers in clear and un
derstandable terms in or with
their bills, contracts, transactions, and receipts at distribution stations:
(a) current actual prices and actual consumption of energy;
(b) comparisons of the final customer’s current energy consumption with
consumption for
the same period in the previous year, preferably in graphic form;
(c) contact information for final customers’ organisations, energy agencies or
similar bodies, including website addresses, from which information may be
obtained on available energy effic
iency improvement measures, comparative
end
-
user profiles and objective technical specifications for energy
-
using
equipment.
In addition, wherever possible and useful, Member States shall ensure that
comparisons with an average normalised or benchmarked f
inal customer in the
same user category are made available to final customers in clear and
understandable terms, in, with or signposted to within, their bills, contracts,
transactions, and receipts at distribution stations.
When sending contracts and cont
ract changes, and in the bills customers
receive or through websites addressing individual customers, energy distributors,
distribution system operators and retail energy sales companies shall inform
their customers in a clear and understandable manner of
contact information for
independent consumer advice centres, energy agencies or similar institutions,
including their internet addresses, where they can obtain advice on available
energy efficiency measures, benchmark profiles for their energy consumption
and technical specifications of energy using appliances that can serve to reduce
the consumption of these appliances.
37
Cost of Access to Metering and Billing Information (Article 11(1))
The objective of the policy as it relates to
Article 11(1) is the “e
mpowerment of final
customers as regards access to information from the metering and billing of their
individual energy consumption”
9
i.e. that final customers are not dis
-
incentivised to
receive information that may help them to make decisions about
energy efficiency and
cost savings.
The Directive achieves this by ensuring that
final customers receive all
their bills and billing information for energy consumption free of charge and that final
customers also have access to their consumption data in an
appropriate way and free
of charge
.
The
proposals are
aimed at addressing market failure in as much as although energy price
signals should prompt both businesses and domestic customers to install energy efficiency
measures at a significant rate, there is no evidence to show that this is happening
at the
rat
e required to meet EU 2020 objectives
. Many factors, including inertia or “hassle” factor,
time, knowledge and cost barriers are preventing NI as a whole from addressing the
following very significant issues:
tackling energy costs through increased energy
savings,
increasing security of supply
–
it is very hard to quantify the benefits of security of
supply and this RIA does not attempt to do this, however, it is usually
acknowledged that there is an issue with lack of control of costs where fossil fuels
are imported and with the potential for lack of availability of fuels where there is
global competition for a decreasing resource
;
tackling carbon and other GHG emissions and pollutants
-
an
externality exists
where those
who emit do not have to bear dire
ctly the full cost of their actions.
The price of energy does not always reflect these external costs. For example, VAT
on gas is low (5%) and there is no carbon price attached to residential gas use,
whereas electricity prices include the cost of carbon d
etermined in the EU
Emissions Trading System. Therefore, investment decisions which are cost
effective to society may not appear as cost effective to consumers;
benefiting from the “green economy” through increase in jobs in installing
measures
–
data on e
xpected economic benefits are found in the independent
study referred to below
;
tackling fuel poverty and associated health issues
(see DSD publications for
further detail on these);
consumer inertia
–
t
he presence of real, but “hidden” costs, for example
the real
costs of devoting the time required to assess potential investment options
or to
clearing out lofts to allow for installation measures
, will also explain some inaction.
However, cultural and other psychological factors are likely to have a role t
o play.
Information campaigns from trusted sources, should help to nudge some behavioural
change. Increasing take up of measures should lead to some momentum to
overcome inertia as many consumers obtain their most trusted information from
others in their c
ircle of friends, family and local community
;
lack of information
-
a market failure preventing the take up of cost effective
measures is the lack of trusted information for consumers (including
businesses) who do not have easy access to, or a full underst
anding of,
information on the range of energy efficiency measures available to them.
9
Recital 33 of the EED
38
Information barriers are likely to be exacerbated where the energy efficiency
measure is a relatively new or technical product, and consumers are also likely
to have a low
level of trust in providers of goods that are, in many cases, once
in a lifetime purchases. Given these characteristics, consumers may not feel
confident in assessing the risk of buying a poor quality service and may prefer
to withdraw from the market or
heavily discount the claimed savings from
energy efficiency measures
;
i
nformation bias
-
without controls there is a risk that expert advice would be offered
by those with incentives to promote a partic
ular industry or installer;
m
isaligned incentives
–
r
ents may be largely determined by factors such as location
and number of bedrooms, and not the energy efficiency of the property. Where this is
the case the landlord has little incentive to invest as only the tenants receive the
benefit of lower fuel bills
. It is likely that the take up of cost
-
effective abatement
measures will remain relatively low in the private rented market
unless this can be
tackled; and
other market failures.
The
EU proposals chime well with the thrust of Northern Ireland’s Strategic
Energy
Framework
10
which states that: “
DETI recognises the pivotal role that energy efficiency
plays in maximising the value we get from the energy we use. Everyone benefits when
energy is used more efficiently
–
consumers save money, demand is reduced
and
environmental impacts are minimised.”
2.2 Background
Metering (Article 9(1))
Currently in Northern Ireland, there are legislative provisions and licence conditions in
place that set out the rules in relation to metering. In relation to electricity,
the Electricity
(NI) Order 1992 (Article 34 and Schedule 7) requires that “Where a customer of an
electricity supplier is to be charged for his supply wholly or partly by reference to the
quantity of electricity supplied, the supply shall be given through
, and the quantity of
electricity shall be ascertained by, an appropriate meter.” The distribution licence held
by NI contains requirements for NIE to have in force and comply with a Distribution code
which must include “insofar as necessary, a metering co
de setting out requirements
and procedures for metering”. In addition, electricity supply licences require the
licensee to, on application, enter into an agreement for the provision for any relevant
metering equipment.
In relation to gas, existing legisla
tive provisions in relation to metering are much more
restricted. Article 22 of the Gas (Northern Ireland) Order 1996 confines itself to meter
testing and stamping. The existing gas distribution licences in Northern Ireland) contain
requirements for the
licensee to provide, on request from gas suppliers wishing to
supply premises, standard gas meters. In addition, gas suppliers are required to “make
such arrangements with the relevant network operator for the provision and installation
of a gas meter ...
to any customer to whom the licensee supplies gas.”
Smart Metering and Billing (Article 9(2), 10(2))
In July 2012, DETI announced that Northern Ireland would proceed with an electricity
-
only smart meter rollout in the domestic sector by 2020 and would
look again at the
case for gas smart metering in 2015.
A consultation on the nature and timescale of a
smart meter rollout for the domestic electricity consumer is planned by the Utility
10
http://www.detini.gov.uk/strategic_energy_framework__sef_2010_
-
3.pdf
39
Regulator. The Utility Regulator has indicated in its Forward Work
Programme the
commitment to undertake this consultation in 2014. Following the Utility Regulator
consultation, issues such as data access and privacy considerations will also have to be
assessed at Departmental level.
Billing Information (Article 10(1),
10(3), Annex VII)
A number of requirements are currently in place on gas and electricity suppliers through
their gas and electricity supply licences.
Electricity suppliers, through various licence conditions, are required to:
send customers a bill or s
tatement on at least an annual basis;
make reasonable endeavours to take an actual reading;
show amount of electricity consumed since last bill.
provide customer information on energy consumed on request
calculate bill via a meter read or estimate when rea
d not available.
Similarly, gas suppliers are required under their licence conditions to:
shall send bill or statement on at least an annual basis to customers
use reasonable endeavours to take an actual meter reading on at least an
annual basis.
Ensure
that the bill or statement shows the amount of gas which has been
consumed since the last bill or statement
provide customer information on energy consumed on request
calculate bill based on a meter reading or if no meter read available based on an
estimat
e.
Cost of Access to Metering and Billing Information (Article 11(1))
The existing rules for suppliers relating to the provision of information to customers are
set out under the current gas and electricity supply licences (condition 38(2) of
electricity
supply licences, condition 2(19)(2) of gas supply licences) Currently, gas and
electricity suppliers are obliged to provide details of all the tariffs, charges and other
payments which are required to be paid by the customer in a manner that enables the
c
ustomer to, amongst other things, identify any other charge or payment. However,
there is currently no explicit requirement on gas and electricity suppliers to provide
customers with bills and billing information free of charge at the point of request, or
to
provide consumption data free of charge.
2.3 Risk Assessment
The Department is obliged under European Community Law to implement the Energy
Efficiency Directive. Failure to do so would be a breach of such legal obligations and
would expose the UK, as
Member State, to infraction proceedings and Northern Ireland
to significant financial penalties.
Failure to transpose the Energy Efficiency Directive in Northern Ireland would also mean
that the objectives of the Directive would not be achieved in respec
t of Northern Ireland.
In those circumstances the wide range of energy efficiency metering and billing
arrangements would not be put in place. This would have the effect of putting Northern
Ireland energy consumers at a disadvantage in comparison with cons
umers in other
Member States where full transposition had been achieved, resulting in NI consumers
being less likely to achieve the benefits of energy efficiency and energy (potentially
40
resulting in cost) savings because they would have less information on
which to base
informed decisions.
3. Options
Option 1
–
a漠湯瑨楮o
q桥漠湯瑨楮朠潰瑩潮o敬e
-
數p污湡瑯特
⸠K
䍯C瑳t
–
Clearly there would be no initial costs from not implementing the Directive.
However, u
nder EC law, Member States are obliged to
implement the requirements of
European Directives.
Therefore, after 5 June 2014 (and 5 December 2014 for Article
10(1)) there would be a very high risk of fines falling to the UK from a judgment from the
European Courts that the UK had not fully transpose
d the Directive. If the infraction
were due to NI alone not transposing the Directive, the costs would be passed on in full
to NI, with a negative effect on the budget for this region.
Benefits
–
the potential benefits (increased energy savings, lower en
ergy costs etc) of
increased information to final customers through improved billing and metering
arrangements would not be realised.
The do nothing option is therefore not being brought forward for consultation.
Option 2
–
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牥r畩牥m敮瑳tEp牥r敲牥搩
䥭p汥le湴n 瑨攠 湥c敳s慲a 汥杩l污瑩癥v c桡湧hs 瑯t 敮s畲u 瑨慴 慬氠 潦 瑨攠 湥c敳s慲a
潢汩条l楯湳 慲攠p污l敤e潮o条g 慮搠敬散e物r楴y c潭p慮楥a 瑨牯畧t 瑨攠汩l敮c攠c潮摩瑩潮o
業p汥l敮瑥t
by 瑨攠
r瑩汩ly 剥杵污瑯l
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41
4. Benefits
Option 2
–
Minimum Implementation of EU requirements
This measure aims to improve domestic and
non
-
domestic gas and electricity bills by
improving both the information that is available to customers and the means by which it
is made available. The Department believes that this will contribute to a greater
understanding of energy usage and consequen
tly an increase in the uptake of energy
efficiency measures and a reduction in gas and electricity bills. This will provide an
opportunity for financial savings for both domestic and non
-
domestic gas and electricity
customers.
The Department also believes
that the preferred option is the most effective way of
ensuring that Northern Ireland provisions are in line with EU requirements, and to
mitigate the risk of possible infraction proceedings and the associated proportionate
financial fine.
4.2 Business S
ectors affected
These regulations will primarily affect the electricity and gas suppliers in Northern
Ireland. The Department does not believe that the regulations will have a material
impact upon competition as the requirement applies equally to all lice
nsed electricity
and gas suppliers. It is very unlikely to affect the market structure, and is unlikely to
lead to significantly higher set
-
up costs or present any new barriers to market entry for
new or potential suppliers because the requirements, while
additional to existing
requirements, do not represent a step change in the billing and metering requirements
as a whole.
4.3 Other impact assessments
Legal Aid
The requirement will not introduce new criminal sanctions or civil penalties for
those eligib
le for legal aid, and would not therefore, increase workload of courts or
demand for legal aid.
Sustainable Development
The requirements are designed to reduce energy use and promote energy
efficiency. As such, it should therefore have a positive effect o
n issues such as air
quality, carbon emissions, security of supply and so on. The new requirements will
provide customers with additional information that they can use to help manage
their energy consumption, enabling them to take greater personal responsi
bility
for environmental impacts of their own behaviours and contribute to the need to
live within environmental limits.
Carbon Assessment
The implementation of Directive 2012/27/EU should lead to overall energy
reductions in Northern Ireland to the exten
t that there are consequential and
directly related carbon dioxide emission reductions with the energy savings.
Health
The proposals raise no apparent health issues.
Race Equality
After initial screening as to the potential impact of this regulation on rac
e,
disability, and gender equality it has been decided that there will not be a major
42
impact upon minority groups in terms of numbers affected or the seriousness of
the likely impact, or both.
Gender Equality
The proposals raise no apparent gender equality
issues.
Human Rights
The proposals raise no apparent human rights issues.
Rural Proofing
The proposals raise no apparent issues for people living and working in rural
areas.
5. Costs
T
he Department is seeking the views of companies about the costs that m
ay be
associated with the proposals in relation to the implementation of Article 9
–
11
in order
to inform the final Regulatory Impact Assessment
. While the Department anticipates
that legislation and new licence conditions will be needed in order to full
y demonstrate
compliance with the Directive, without further evidence from consultees it is hard to
gauge the cost of implementing new billing and metering provisions.
As a general principle, in order to minimise the costs to businesses of implementing th
e
Billing Information aspects of the Directive, the Department has adopted the “minimum
requirements” approach set out by the UK government.
In particular:
the Department does not anticipate that the legislative amendments implementing the
requirements
of Article 9 of the Energy Efficiency Directive, or any subsequent gas and
electricity supply licence modifications, will require gas and electricity supply companies
to implement significant changes to their existing arrangements in relation to the
meteri
ng
requirements of Article 9(1)
;
the Energy Efficiency Directive
clarifies
that where Member States do introduce smart
metering, then the conditions detailed in Articles 9(2) and 10(2) must be met. This
being the case, the Smart Metering and Billing elements of the proposals will not result
in any immediate costs on energy supp
liers. There may, however, be additional costs as
a result of these measures to electricity and gas suppliers associated with any future
rollout of smart metering systems. In the Department’s public consultation on the billing
and metering aspects of the
Energy Efficiency Directive, the views of these suppliers are
being sought on the level of cost associated with these measures in the context of any
future smart meter rollout;
the Billing Information aspects of the Directive (Article 10(1), 10(3), Annex V
II) will
introduce new requirements on gas and electricity supply companies. It is likely that
these new requirements will result in some additional costs to these businesses. The
level of costs that will be associated with the implementation of these pr
ovisions has
not yet been ascertained. The Department is seeking the views of these companies in
its public consultation and hopes to gain a better understanding of the costs through
the responses to the consultation provided by these companies. Specific
ally, in line
with guidance relating to gold plating, the Department does not propose, subject to
stakeholders’ views, to implement Article 10(3)(d). The Department anticipates that this
will result in a reduced regulatory burden on gas and electricity su
pply companies and
consequently lower costs as a result of implementation.
In addition, the Department is
43
seeking information about making use of potential exemptions around the use of the
words “where appropriate” in paragraph 1.2 of Annex VII.
There is
currently no requirement on gas and electricity supply companies to provide all
bills and billing information to final customers free of charge
(Cost of Access to Metering
and Billing Information (Article 11(1)). In order to ensure compliance with the Dire
ctive,
it will be necessary to introduce this requirement. In its public consultation, the
Department is seeking the views of gas and electricity supply companies on the level of
cost that will be associated with the implementation of Article 11(1).
6.
C
onsultation with small business: The Small Business Impact Test
The implementation of the metering and billing requirements of the Energy Efficiency
Directive will primarily affect electricity and gas suppliers, and some aspects also affect the
Distribut
ion System Operator for Northern Ireland (NIE).
In particular, the Department is interested in gauging the impact on businesses that will be
affected by the requirements, either directly (as gas or electricity companies), or indirectly
as customers of t
hese businesses, or other businesses offering energy services.
Where any of those businesses are small businesses, it would be very helpful to know if
there are particular issues arising from the proposals. The Department’s initial view is that
the imp
act on small businesses is likely to be:
For electricity and gas suppliers, few companies are small businesses, but, where they
are, the requirements of the Directive must still be complied with as they are mandatory
and few exceptions are envisaged. The
re will therefore be costs falling on small
businesses which are electricity or gas suppliers;
For small businesses which are the customers of electricity and gas suppliers, the
measures should increase the amount of information available to them which sho
uld
“strengthen the empowerment of final customers”
11
in relation to energy savings and
therefore be beneficial to this group;
For small businesses offering energy services, the additional information required by the
Directive should help assist them in hel
ping other businesses find energy savings and
therefore be beneficial to this group.
The main aim of the provisions of Articles 9
-
11 is to improve domestic and non
-
domestic
gas and electricity bills by improving both the information that is available to c
ustomers,
including small businesses, and the means by which it is made available. In the broader
context of small businesses as a whole across Northern Ireland, the measures may help
these businesses improve their ability to assess their energy usage and
identify areas
where energy bills could be reduced. This is likely to lead to reduced energy costs for small
businesses in Northern Ireland.
In the consultation, the Department is seeking the views of consultees on whether they
agree with the Department
’s view on the level of impact that the proposals will have on
small businesses.
7. Enforcement and Sanctions
Most of the requirements of Articles 9
-
11 will come into force on 30 June 2014, with the
exception of Article 9(1) which must be introduced by 3
1 December 2014. In line with UK
guidance on transposition of European Directives in relation to “gold
-
plating”, the
11
Re
cital 33 of the Energy Efficiency Directive
44
Department does not intend to introduce the requirements prior to the deadlines set out in
the Directive.
Article 45 of the Energy (NI) O
rder 2003 provides for the Utility Regulator to impose a
penalty where it is satisfied that a licence holder has contravened or is contravening “any
relevant condition or requirement”. Compliance with gas and electricity supply licences is
therefore enfor
ced by the Utility Regulator who has the power to impose financial penalties
of up to 10% of the turnover of the licensees in the event of a breach.
8. Monitoring and Review
The Department will liaise with the Northern Ireland Authority for Utility
Regulation who will
monitor the operation of Northern Ireland gas and electricity companies to ensure that they
adopt the new regime and adhere to the new requirements introduced as a result of the
Energy Efficiency Directive.
9. Consultation
Within Go
vernment
The Department has worked closely with the Northern Ireland Utility Regulator in developing
the proposals. The Department will also be consulting with a number of other public
bodies.
Public Consultation
The consultation document relating to
the proposals in relation to transposition of Articles
9
-
11 of the Directive can be found on the Department’s website at the following link:
http://www.detini.gov.uk/deti
-
energy
-
index.htm
Whe
re the requirements of the Directive are being met through new or amended gas and
electricity supply licence conditions, the Utility Regulator will also be consulting with licence
holders, in line with the normal procedures for modification of these licenc
es at a later
time.
The Department will continue to liaise with the Utility Regulator, the energy industry and
consumer organisations as part of the outworking of the provisions set out in the
legislation, licence conditions and industry codes associated
with the implementation of the
Energy Efficiency Directive.
10. Summary and Conclusions
Currently DETI has insufficient evidence to draw firm conclusions about the full costs of
implementing these requirements of the
However, information on the
potential benefits
11. Declaration
[to be completed when the RIA reaches its final stage]
45
Contact Point
Energy Efficiency Directive
Renewable Energy Branch
Department of Enterprise, Trade and Investment
Netherleigh
Massey Avenue
Belfast
BT4 2JP
Email:
energyefficiencydirective@detini.gov.uk
Fax: 02890 529549
Department of Enterprise, Trade and Investment
Page
32
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