Our response to the consultation on the design plan for the roll-out of smart electricity meters in Northern Ireland

Yes, we agree with the guiding principles for the programme.

Consumers must be at the heart of the roll out of smart metering to ensure a just transition that is inclusive of all demographics. Consumer benefits must be the driving philosophy of smart meter rollout as target-driven approaches can place unwelcome pressure on consumers.

It is encouraging to see smart metering supporting the low carbon transition as a guiding principle. Smart meters will allow households to become more aware of their energy consumption patterns, as well as empower them to benefit from lower prices at times of excess renewable generation and participate in demand flexibility to support balancing out peaks in demand as we increase the number of renewables on the grid. Given that 82% of renewable electricity generation in Northern Ireland is from wind energy, demand flexibility represents a significant opportunity to reduce curtailment (a local issue).

A 2022 report by the University of Ulster concluded that this has the potential to drive a 67% reduction in constraint and a 74% reduction in curtailment,which will be mutually beneficial to generators and households.

Increased uptake of smart meters will also support consumers to feel the benefits of other low carbon technologies, such as electric vehicles and heat pumps, by enabling them to take advantage of smart tariffs which can provide lower electricity costs at certain times. We have already seen the availability of these tariffs in GB. Lessons can be learned from the Republic of Ireland, where there is still relatively slow adoption of smart tariffs, which has limited the full benefits of the roll out being realised. Whilst there are more tariffs being introduced to encourage improved engagement with Time of Use tariffs, it is important to consider how these can support microgeneration and demand side response measures in the design stages of the rollout.

We also welcome the commitment to ensure costs and benefits are fair, equitable and transparent. In particular, the commitment to ensure all consumers, including the vulnerable, are able to participate and benefit is encouraging.

Yes, we agree that consumer representatives should be involved in the co-design of the requirements for data systems and procurement to ensure that the perspectives of different types of consumers are considered.

Yes, we agree that the language used should be reviewed by consumers. This will ensure that the messaging around the smart meter rollout resonates with consumers, is sensitive to their concerns and motivates them to act. The language used should also be clear and simple so that the general public can understand and engage.

Lessons can be learned here from international examples around testing messaging and language with different types of consumers to ensure that they resonate and are sensitive to public concerns. The ‘Reduce Your Use’ information campaign in the Republic of Ireland (ROI) offers an example of best practice. This campaign was delivered at a challenging time for government communications due to negative sentiments about energy costs. The campaign therefore had to raise awareness about ways of reducing energy, but only where it was safe for people to do so. The campaign managed to strike this difficult balance by testing messaging before it was released widely. Messaging was also tracked so that it could be adjusted according to public sentiment.

Such an approach will be crucial for any messaging around smart meters aimed at consumers to ensure it lands well and is sensitive to their concerns.

Yes, we agree that the smart-meter roll-out needs to be sensitive to the needs of different groups, particularly those who may have limited scope to benefit from a smart meter by varying their energy usage, outlined in our response to Question 8.

We also agree that the Oversight Group, along with consumer representatives, should review all aspects of consumer protection, again paying particular attention to the specific needs of those vulnerable groups outlined in our response to Question 8.

Yes, we agree that there will be some consumers who may have limited scope to reduce their energy consumption or use a smart meter.

Our response first lists the types of consumers who may have difficulty in reducing their consumption, before discussing the key recommendations that could support these consumers.

Consumers with limited scope to reduce their energy consumption

Users with Medical Conditions

In 2023, evaluation of the Demand Flexibility Service (DFS) in Great Britain found that households with long term health conditions may have difficulty reducing their energy consumption because of their reliance on vital electrical medical equipment. The specific health needs of these households may require appliances to be used at certain times of the day. There are also practical concerns for these consumers around needing support to manage appliances. For example, they may be reliant on a carer, who is only available at certain times of the day, to turn an appliance on or off. In the DFS evaluation, some respondents reported that participating could put them directly at risk as to participate, they would have had to compromise their health.

Limited Connectivity

A 2023 Public Accounts Committee report on the ‘Update on the rollout of smart meters’ highlighted lower uptake rates of smart meters in rural areas, often due to limitations related to communications technology to bridge the distance between the central network infrastructure and individual smart meters, or between individual smart meters and their in-home displays.

Demographic Groups

The report by the Public Accounts Committee also found that females, young people, low-income households and private renters had lower uptake of smart meters, so efforts to increase rollout should be especially focused on removing barriers for these populations.

Pay-as-You-Go (PAYG) Users

To support widespread uptake of smart meters, it is important that innovative products and services are made available to support uptake among PAYG prepayment meter users and empower them to reduce their energy consumption. This is particularly important given that PAYG prepayment meters account for 46% of electricity consumers in Northern Ireland, substantially higher than in GB or Europe.

Recommendations to support these consumers

It is necessary that smart meters are accessible to all consumers, regardless of location, electricity meter type, electricity needs, and demographic. Lessons can be learnt from the smart meter rollout in GB regarding engaging vulnerable consumers.

Access to comprehensive, tailored advice and support

According to the Public Accounts Committee the approach in GB to the roll out of smart meters has placed too little emphasis on understanding and supporting the behavioural change required. A more successful approach would be to ensure households have access to comprehensive, trusted and tailored advice, which would help to increase people’s confidence to install a smart meter. This was a key recommendation of a 2023 evaluation into household engagement with the DFS in GB. We are therefore encouraged to see a recognition of the importance of impartial advice delivered by an independent body in this consultation. We talk further about the importance of an advice service in our response to Question 11.

We welcome the government’s commitment within the ‘Energy Strategy for Northern Ireland’ to create a flexible, smart and digitised energy system and the recognition of the role of a One Stop Shop approach to advice delivery in supporting this. We know from our experience delivering Home Energy Scotland on behalf of the Scottish Government, the positive impact that a One Stop Shop approach can have on improving people’s understanding of how much energy they use which in turn encourages them to adopt behavioural changes and can also lead to the installation of a smart meter.

To further increase confidence, lessons can also be learned from the Green Homes Network, which we run in Scotland, which allows people to search for someone nearby who has installed energy saving measures, including smart meters and other low carbon technologies and also go and see the technologies in people’s homes.

In the context of smart meters, this could be replicated in Northern Ireland to allow households to see smart meters successfully installed and working in homes similar to theirs, increasing trust in the technology, raising awareness of the benefits and helping to drive the necessary behavioural change to encourage uptake of smart meters.

More innovative approaches to PAYG

In relation to PAYG prepayment meters, lessons can be learned from the ROI on delivering more innovative approaches to deliver PAYG to support the successful roll out of smart meters. For example, the engaging interactivity of the ‘Smarter Pay As You Go’ (SPAYG) meter has contributed to high adoption rates and satisfaction levels in ROI.

The SPAYG meter comes with an in-home monitor, allowing households to track their electricity usage. Consumers can also choose to top-up their electricity via an app, using a top-up card or via text.

Yes, we agree that the needs of small and medium-sized enterprises (SMEs) should be reviewed to identify solutions to the specific challenges they face around smart meter installation.

Regarding longer term support for SMEs, particularly those who are not in scope of schemes delivered by InvestNI, lessons can be learned from the Business Energy Scotland (BES) service we deliver on behalf of the Scottish Government. BES delivers expert, tailored advice to small businesses to support them to upgrade their buildings and save energy. Financial support in the form of grants and loans is also available through the service to support SMEs to overcome the financial barriers to installing energy efficiency and low carbon technologies and making improvements to help businesses reduce their energy usage.

Yes, we agree that suppliers should develop time of use (ToU) and dynamic tariffs to enable consumers to save money by using energy when the cost of electricity is lower. However, it is important that there are adequate protections in place to ensure vulnerable are not disadvantaged by the introduction of such tariffs.

Benefits of ToU tariffs

Electricity ToU tariffs will be crucial for households to realise the potential benefits of low carbon technologies such as heat pumps, electric vehicles (EVs) and electric batteries. The availability of ToU tariffs will ensure that those who have installed these technologies can maximise bill savings.

ToU tariffs will also enable a flexible future energy system by encouraging households to use more electricity at times of peak renewables. This will support the integration of high proportions of variable renewables and limit excess and expensive buildout of the grid. In recent periods of high renewable generation in GB some wholesale prices have gone negative. In some instances, suppliers have offered low electricity costs or even allowed consumers to consume electricity free of cost.

Risks associated with ToU tariffs

Not all households will be able to engage with ToU tariffs. The benefits of ToU tariffs will initially mostly accrue to households who have a smart meter and are able to purchase low carbon technologies, such as heat pumps and EVs. The government will need to consider how it can incentivise uptake of low carbon technologies for all households so that they are also able to benefit from ToU tariffs. In this context, we welcome the Department for the Economy’s current consultation on support for low carbon heating in residential buildings and look forward to sharing our response in due course.

There will be risks for some consumers being placed on ToU tariffs if they are not fully able to flex their energy usage. For example, low-income households that are unable to shift their electricity usage away from peak hours risk facing significant bill increases if they are placed on a ToU tariff that is not suitable for them. Households without a smart meter will also be unable to take advantage of smart ToU tariffs. It is particularly important that as ToU tariffs are being developed, households that have been unable to install a smart meter are not penalised due to this.

We welcome the consultation’s acknowledgement that consumers should not suffer detriment from tariff choices. We would stress the importance of ensuring suppliers have an obligation to ensure households are on a tariff that is suitable for their individual circumstances. We also agree with Aldersgate Group’s recent report which stated that ToU tariffs should not “be seen as an immediate solution for affordable energy bills for all” but they should still be “available for households that desire them.”

It is also important to note that to maximise the benefits of the smart meter roll out and ToU tariffs, financial support must be made available to support the installation of heat pumps and other low carbon technologies. As noted above, we therefore welcome the ongoing consultation on support for low carbon heating in residential buildings. This support should match or exceed that offered in the Republic of Ireland (EUR 6,500) and ideally match the £7,500 offered in England and Wales through the Boiler Upgrade Scheme.

In Scotland, grant funding for heat pumps is also up to £7,500, or £9,000 for households who qualify for the rural uplift to account for the increased installation costs. Households can then take out an optional interest-free loan to cover a certain amount of the remaining cost. The remainder of funding requested can be taken up as.

Going even further than this, lessons can be learned from the French national retrofit scheme, Ma Prime Renov, which offers households tiered financial support depending on their income level. This ensures greater equity, providing greater support to those who need it most, whilst still ensuring the additional market value of demand from those on higher incomes.

Yes, comprehensive advice and support will be vital to ensure households experience a smooth consumer journey that will increase their confidence in smart meter technology. We therefore welcome the commitment to deliver a co-ordinated plan to deliver advice from initial engagement to post-installation support. We have included recommendations below on how this plan should be delivered and what it could focus on.

Deliver impartial, tailored advice through a one stop shop

We would stress the need for smart meter advice to be integrated into the development of a One Stop Shop (OSS) in Northern Ireland. Although an OSS was recognised within the ‘Energy Strategy for Northern Ireland‘ to support the creation a flexible, smart and digitised energy system, it has not been mentioned within the consultation.

It is important that consumers have access to impartial, tailored advice through a OSS to help them choose the right products or services that suit their needs or preferences. As smart meters are relatively new in Northern Ireland, people are likely to be unsure where to go for trusted information about what they are, how to get one and the benefits of getting one. This will improve people’s understanding and trust in smart meters and give them the confidence to install one, leading to an increase in uptake.

Advice and support services should also anticipate the challenges vulnerable households may face and how to overcome these. Ensuring support is tailored to these groups will ensure they are not left behind and feel empowered to use their smart meters confidently.

An OSS can also support those considering installing retrofit and low carbon technologies. From our experience of delivering Home Energy Scotland on behalf of the Scottish Government, a One Stop Shop approach can empower households to upgrade their homes, accelerating retrofit rates and the deployment of low carbon technologies. For example, 42% of customers installed at least one energy efficiency, low carbon heat or renewable energy improvement after receiving advice from a Home Energy Scotland advisor and 42% of customers were planning to install at least one improvement over the next 12 months. Supporting households to install low carbon technologies will also be essential to enable them to realise the benefits of smart meters and use energy more flexibly.

Policy developments in Europe also demonstrate the widespread acknowledgement of the importance of the One Stop Shop approach. For example, the EU Parliament has adopted the recast ‘Energy Performance of Buildings Directive’ which includes a provision for member states to facilitate the rolling out of one stop shops. Member states must now ensure one stop shops are available to support homeowners and SMEs to upgrade their buildings. Progress is already well underway in certain countries. For example, the French national retrofit scheme has advice at its core. The service has sought to make the customer journey as simple as possible and offers advice through online tools, assessments, retrofit management support and lists of accredited installers.

Increase confidence about data security

A survey commissioned by the Consumer Council in 2023 found that 51% of respondents would not trust an external company with information about when they use appliances, turn their heating on or charge their EVs. This concern about data control and cybersecurity should be considered when developing the customer journey to ensure consumers feel confident to install a smart meter and are aware of consumer protections that are in place. This can also be improved through an effective awareness raising campaign, as explored next.

Integrate advice with a nationwide awareness raising campaign

As part of the coordinated plan, there must be a nationwide awareness raising campaign to inform households on the actions they can take to support progress to net zero. A 2023 survey commissioned by the Consumer Council found that 84% of consumers have little to no knowledge of low-carbon heating systems, and 57% were unsure if they would install a smart meter within two years. This highlights the importance of an effective campaign which improve public awareness around smart meters and low carbon technologies to motivate them to act or find out more.

It will also be important to communicate the benefits of smart meters and low carbon technologies more broadly. People must see the steps they are being asked to take as working for them rather than an imposition. Any nationwide awareness raising campaign should also signpost to any impartial advice service to create a seamless customer journey. It will be important to address any new or existing myths around smart meters, particularly in a context where consumers may be sceptical or have low trust due to negative stories they have seen or heard.

There are significant lessons to be learned from international examples of awareness raising campaigns, such as the ‘Reduce Your Use’ in the Republic of Ireland. This campaign focused on reducing energy demand during the energy crisis and exposed 99% of the population to the messaging. What is notable about this campaign was the careful design of the messaging (discussed in our response to Question 6).

Any awareness raising campaign in Northern Ireland will need to firstly understand what framing and narratives land with different demographics to ensure external messages resonate with different groups and motivate them to act. Such messaging should also be flexible and updated where it has been identified that this will improve engagement. A checkpoint review, similar to the one implemented in the Republic of Ireland during the rollout, could also help shape the development of an awareness raising campaign (see our response to Question 19 for more information).

We welcome the recognition of the importance of consumer consent and that consumers are fully informed about the types of data being collected, how it will be used and who will have access to it.

We would also underline the importance of ensuring all processes are simple for the consumer, e.g. embedded within a ‘live’ process such as during the sign up and ‘get started’ process. It will also be important for consumers to know that they can change their mind and are made aware of how they can do this. We also support the suggested measures that will be put in place to protect data privacy.

We agree with the proposal to allow trusted organisations to have access to aggregated and anonymised data from smart meters.

We would stress the importance of any framework for sharing data with trusted organisations not to include insurmountable barriers to accreditation, at the risk of limiting the value this data can deliver to consumers. We have experience as a user of smart meter data in GB (via Smart DCC) and the costs associated with auditing and managing consent frameworks eventually prevented us from providing a smart meter data driven advice service to our users. We would stress the importance of not placing excessive demand on trusted third-party organisations who may not have the resources to meet these.

Yes, the objective should be for all consumers to have smart meters. The rollout of smart meter technology has the potential to encourage large scale behavioural change and significantly reduce household carbon emissions, but it will not be effective if the benefits are only felt by only a portion of the population. To ensure a just transition, it will therefore be important to ensure vulnerable households are supported to engage with smart meters.

Please see our response to Question 8 for details of those vulnerable households that may need greater support to benefit from a smart meter.

We would point to the successful roll out of smart meters in the ROI, where 1.8 million smart meters have been installed to date, out of around 2.4 million. When designing the roll out, the ROI considered lessons learned from GB. These included:

• The need to provide solutions to those households where smart meters cannot be installed (e.g. due to network challenges).
• The need for post installation advice to prevent the customer journey being negatively impacted (trusted organisations will be pivotal to encourage vulnerable groups to take up smart meters)
• The importance of consistent advice and information to inform households how smart meters can benefit them and the transition to net zero (with 27% of customers in GB not recalling receiving any advice on how to use their smart meters to save energy according to a National Audit Office Report).

One particular aspect of the approach in ROI which has worked well is the phased roll-out of installations which has avoided situations where someone’s neighbour receives a smart meter but they can’t have one because they are with a different energy supplier with a separate roll out approach, as has been seen in GB.

However, there are also lessons to be learned from the ROI’s roll out, with regard to prioritising certain groups. During the initial phase one of the rollout, those who requested a smart meter or who need theirs replaced were prioritised. Whilst we would be supportive of prioritising households who request a smart meter, in order to maximise early adoption and normalise the use of smart meters in Northern Ireland, it is important that more vulnerable groups are also actively engaged with to ensure they are not left behind. This includes those who may face challenges when thinking about energy use (including older people and those who have medical conditions).

Following the success of the checkpoint review in the Republic of Ireland, which ensured the lessons learned from the initial roll out (phase 1) informed the next phase’s activities, including a similar measure in the design plan for Northern Ireland could be beneficial in accelerating adoption and ensuring a just transition for all households. The purpose of this would be to consider the impact of any legislative and regulatory changes, customer sentiment, adoption rates and any changes in technology.

Whilst this is not intended to reopen previous policy decisions, it will help identify disengaged groups that may need additional support prior to adopting smart meters, as well as enhanced after installation support.

Regarding the non-domestic sector, we would underline the need to start the smart meter roll out with SMEs. hey may also need specific advice and support to make the most of their smart meter and other actions they can take to reduce their energy consumption. Lessons can be learned from the Business Energy Scotland service as discussed in our response to Question 9.

Yes, we agree that the Oversight Group should set targets and monitor and report on the pace of installation.