This post is an extract from Wattwatchers’ submission to the Australian Energy Market Commission (AEMC) Review of the Regulatory Framework for Metering Services draft rule consultation paper, lodged earlier this month. The AEMC, as the rule-maker for the national electricity market, is seeking to accelerate the roll-out of utility ‘smart meters’ for completion by 2030 – over two decades since it began, and following the Power of Choice metering reforms formulated nearly a decade ago.
WATTWATCHERS’ TAKE: CREATE SPACE FOR REAL CONSUMER PARTICIPATION
Ultimately, today’s customers mainly want electricity that is affordable, always-on and of good quality to power and protect their appliances and electronics, keeping the lights on, but doing a lot more too. They expect to be billed fairly and accurately. Many also expect good environmental attributes. Others – the prosumers – want to maximise the value of their own energy investments, such as the one third-plus of Australian households with rooftop solar, and often are willing to invest in their own additional remote metering, monitoring and control solutions.
Choice is critical to meeting all of these needs, and universal metering for billing and market reconciliation (i.e. ‘settlement meters’) should provide a minimum, entry-level of support to customers to participate in the electricity market, while leaving clear space for innovation, premium services, and for new competition and market entrants, rather than being positioned as the platform for all energy transactions. A secondary market for customer-facing energy services, as is envisaged in the AEMC’s current flexible trading consultation (Unlocking CER benefits through flexible trading – ERC0346), is an opportunity to allow greater diversity of solution providers, technologies and service/business models behind-the-utility-meter.
Data from utility digital metering should be readily available to support the customer’s experience, including power quality data, just as it is or most likely will be available to more traditional industry players; and customers should have the choice and the capability – via supporting technologies such as APIs – to share their utility meter data with third-party service providers of their own choice, for their purposes (which could, for example, include getting expert advice on the power quality they are receiving, and whether poor quality supply is impacting on them e.g. affecting rooftop solar performance or damaging expensive home and business electronics).
Recommendation 1: Make energy data more ‘open’ than is currently envisaged by the draft report. The current metering review proposals favour traditional energy players, including billing meter manufacturers and management services, and the proposals don’t do enough to genuinely empower customers, nor to support innovation by emerging technology providers. The recent Consumer Data Right/Open Energy reforms are a step in the right direction, but a lot more can and should be done, and utility metering is a key part of the equation. For example, customers should not only have local access to their utility meter data, but they also should have the clear right and effective capability – at no cost to them, considering they already paid for the metering and the electricity – to share it with third-party service providers of their choice, for their purposes, through the cloud (e.g. API).
Recommendation 2: Recognise that as with electrons, energy data has value, and costs to supply, and that in the case of utility metering this value is based on data that customers have paid for to have collected and held by the industry, with no real choice in the matter; and that billing data primarily reflects their use of electricity from the grid that they are paying for; and in some cases it also reflects clean electricity that they are supplying to the grid from their own rooftop solar generation, or services they may provide such as demand response, or sharing data from their energy assets. If data from utility metering also delivers value for industry players, such as network businesses, then it would be fair that they pay something for the part of the data ‘value stack’ that they use (e.g. voltage, current, power factor) and that customers are credited with at least part of that additional value as cost relief. Certainly the full value of data services built on customers’ data should not be pocketed by metering interests.
Recommendation 3: The AEMC should more overtly recognise the functional limitations of the utility metering currently being deployed under its ‘minimum specifications’, and that this necessarily limits the customer benefit which such metering is able to provide or support. That said, it is submitted that some aspects of the current minimum specifications, such as remote disconnection and reconnection capability, may be counterproductive to achieving lowest cost for customers for a baseline level of utility billing and market reconciliation. In a market with choice, it is reasonable that customers who need or want more functionality than the entry-level baseline provides should pay for this themselves, including via non-utility third-party solution providers. If utility meter providers want to offer energy customers premium services, including digital metering with higher levels of performance and granularity of data, then consumers also should have choices to get such enhanced services from alternative providers such as new technology companies.
Recommendation 4: The current approach to data from utility metering is highly constrained, with even intra-industry sharing being quite restricted, and a selective approach to what data (and at what cost) is shared with customers, researchers and third-party service providers. Taking into account legitimate privacy, security and cybersecurity concerns and concepts, multi-sourced data nonetheless needs to be more accessible, shareable and portable (a scenario which Wattwatchers is exploring through a number of grant projects). As with electrons in an electricity system with a lot of CERs, where electricity flows bi- or multi-directionally, in a two-sided marketplace data flows also should be multi-directional (e.g. data from the regulated market should be able to flow to non-regulated use cases, and vice versa where this benefits customers), and commercial arrangements should align with this to allow value to be shared fairly across the expanding energy data ecosystem.
We submit there remains an opportunity to begin creating the space for a competitive marketplace for energy data in the Final Report of the AEMC’s metering review.
(Wattwatchers will include a link to our full submission when it is published on the AEMC’s website.)