Consultation on Proposed National Rollout of Electricity and Gas Smart Metering

Transcription

1 Consultation on Proposed National Rollout of Electricity and Gas Smart Metering RESPONSE FROM: Elster Metering Ltd RESPONSE SUBMISSION DATE: 12 th December 2011 DOCUMENT TYPE: Consultation Paper REFERENCE: CER11191 DATE PUBLISHED: 15 th November 2011 CLOSING DATE: 13 th December 2011 RESPONSES TO: Gary Martin

2 CER Information Page Abstract: This consultation outlines the proposed decision by the CER to proceed with the national rollout of electricity and gas smart metering to all residential consumers and a significant proportion of small-tomedium enterprise (SME) consumers. This proposed decision is based on the positive results of the recently completed electricity and gas smart metering trials and associated cost-benefit analyses. The consultation outlines the proposed high level design, functionality and implementation approach of the national smart metering rollout and invites feedback on these proposals. Target Audience: This paper is for the attention of members of the public, the energy industry, energy consumers and all interested parties. Responses to this consultation should be returned by Tuesday 13 th December 2011 via , post or fax and marked for the attention of Gary Martin (gmartin@cer.ie) at the CER. The CER intends to publish all submissions received. Respondents who do not wish part of their submission to be published should mark this area clearly and separately or enclose it in an Appendix, stating the rationale for not publishing this part of their comments. 2

3 Appendix A List of Substantive Questions Appendix A provides a list of questions asked throughout this consultation paper - these questions are presented in the table below. The aim of this section is to allow for a short-cut option for respondents to submit their comments to the CER. Respondents are invited to complete the table to indicate their position on the questions being asked. Respondents should outline YES or NO answers to each of the questions listed. If they have a further comment which will clarify their answer, this should be included in the Comments box. Appendix A will be published alongside the consultation paper in Word format. Please note: Respondents are in no way obliged to respond to the questionnaire provided and are welcome to submit comments in their preferred format. When preparing responses respondents should indicate which question or proposal their text refers to. Please note also that, as the majority of questions posed in this consultation address both electricity and gas smart metering issues, respondents should make it explicit in their responses if their comments are applicable to electricity, gas or both. Question Yes No Comments Q1. Respondents are invited to comment on the proposed decision by the CER to proceed with the national rollout of electricity and gas smart metering as outlined in Section 2. Are you in favour of this proposal? Outline reasons for agreement or disagreement. Yes Elster Metering are in agreement with the idea of National Rollout for electricity and gas smart metering. We are pleased to see that the results of the CBT trials for both electricity and gas gave positive results and that the technology trials also showed viable technology availability for a rollout. Given these factors and the resultant positive CBA which is vital to justify the rollout of such an infrastructure. 3

4 Q2. Respondents are invited to comment on the proposed objectives of the National Smart Meter Programme outlined in Section 3. Are you in favour of the proposals? Outline reasons for agreement or disagreement. Yes Elster metering believes the objectives stated for the National Smart Metering Programme are appropriate and inline with European directives. All the key benefits from a Smart rollout have been identified and we are pleased to see the possible inclusion of Water Metering. Q3. Respondents are invited to comment on the proposed working assumptions outlined in Section 4 relating to data ownership, display and provision. Are you in favour of the proposals? Yes Elster believe the availability of data is a key part of the introduction of a Smart Metering and believe the suggested granularity is appropriate. The provision of this data will enable the key items identified in the consultation document i.e., provision of data for supplier and customer. However Elster would like to make the following observations:- - Privacy and security are a key element as identified in the consultation; CER should take account of the working that is being undertaken by the European Commission Task Force for Smart Grid in particular the work by Expert Group 2 - Prepayment: while both thin and thick have been considered in the consultation, we believe it is important to understand the pros and cons of both systems and consider other proposed rollout of substantial prepayment systems such as the UK. - In-Home displays, the CBT trials have shown very positive results and therefore incorporating a method of showing real time data to consumers should be considered as a mandated part of the rollout. Q4. Respondents are invited to comment on the proposals outlined in Section in relation to the electricity smart meter functionality Yes The high level functional requirements of the Electricity meter are very sensible. Substantial detail will be required during the design phase to ensure suitable products are available for 4

5 requirements. Are you in favour of the proposals? Q5. Respondents are invited to comment on the proposals outlined in Section in relation to the gas smart meter functionality requirements. Are you in favour of the proposals? Outline reasons for agreement or disagreement. rollout`. The following requirements may need to be considered more carefully to ensure that they are achievable at a suitable cost:- - Three types of tariffs. This can be achieved in a variety of ways and it is important to consider all elements of the system requirements associated with this feature. - Product life can be estimated / calculated in a number of ways, given these products are going to be complex products with integrated communications a 15yr product life is probably a realistic estimation. Yes Elster have reviewed the gas specification and believe this is a very good basis for the detailed work during the design phase. Storage of half hour or hourly data along with relevant status information is a good foundation for the future. The requirements for valve operation, tariffs, security etc are very closely aligned to the proposals being discussed in the UK.Given the gas meter register is a battery operated device then the provision of data for auxiliary devices needs to be considered carefully, both in terms of frequency and quantity of data. Q6. Respondents are invited to comment on the proposals outlined in Section in relation to the Wide Area Network (WAN) functionality and technology. Are you in favour of the proposals? Yes Elster supports the proposed functionality of the WAN communications technology. The review of the available technical solutions appears very sound and has taken into account the environmental aspects of the ESB network such as the large number of transformers deployed in rural areas. Elster would fully support the suggestion that OFDM technologies should be monitored as large scale rollout of these will occur over the next year / 18 months. 5

6 It is also important to note that the functional requirements may need to be enhanced to cover the real time data transferred of data which will be required for prepayment. General Note throughout the document the terms PLC and DLC are used interchangeably, we believe a single term should be used throughout as we believe these terms refer to a single solution. Generally the term used in Europe is PLC for a solution which can not pass through the substation transformers. Q7. Respondents are invited to comment on the proposals outlined in Section in relation to the Home Area Network (HAN) functionality and technology. Are you in favour of the proposals? Some concerns Elster fully support the introduction of a secure HAN for the Utility HAN and believe that the non-utility HAN also needs to be part of the secure HAN environment. While this is highlighted in point 1 we believe that this is not emphasised throughout the section 5.2.5, some of the references to the fact that the non-utility HAN should allow easy installation does not imply the need for central control of this joining mechanism which will be essential to maintain security and privacy. Elster would support further investigation during the design stage. Q8. Respondents are invited to comment on the proposals outlined in Section in relation to the procurement model. Are you in favour of the proposals? In particular, which of the two IHD provision responsibility options outlined do you prefer? Outline reasons for agreement or disagreement. Yes Elster is in support of the proposed procurement model for Electricity, Gas meters and the WAN technology. The area that is not clearly defined is the management of the HAN infrastructure which will be required for a secure HAN. Elster believe that the IHD should be procured by ESB for the following reasons:- - if the Electricity meter is installed first then availability of the data on the IHD should be implemented at the same time. - ease of installation and support, installers and support 6

7 systems will need to be set up to allow rapid deployment, this will be achieved much more easily if a limited number of IHDs were to be installed in the field. - Alternative IHDs may be offered by suppliers, but these should be from a selected range supported by ESB. Q9. Respondents are invited to comment on the proposals outlined in Section 6 relating to the implementation approach and timelines. Are you in favour of the proposals? Outline reasons for agreement or disagreement. No Elster believe that the proposed phases and timelines will unduly delay the roll out of Smart Metering and the benefits it brings to: consumers, utilities and overall CO2 savings. Rollouts of many of the suggested technologies are already underway and therefore this experience should be utilised in determining the most suitable approach for Ireland. Detailed technical definition is also available from an number of other markets and therefore may form a useful base for the detailed design stage. By using these approaches may help speed up some of the decisions that need to be made before rollout. Metering design can also be specified to reduce risk associated with earlier rollout; this can be done by firmware download and modular meter design. Both of these key features should be considered, not only do they allow an earlier rollout but they also allow for any changes in functionality or communications technologies that may be required in the future. END 7