Dedicated Issue Resolution Expert Group (IREG) May Update
IREG met on 20th May 2016 for a dedicated discussion regarding smart prepayment Customer change of Supplier issues associated with the Debt Assignment Protocol. The meeting was agreed to be convened when discussing MRA Issue Form (MIF) 198 at the April meeting.
The MIF highlighted that the definition of the term ‘pre-payment meter’ does not refer to smart meters operating in a pre-payment mode. This contradicts the Supplier obligations in the Ofgem Electricity Supply Standard Licence Conditions (SLCs), which includes any meter that operates in a mode that allows the Customer to be charged in advance of the Supply of electricity. IREG considered that changes to MRA Clause 30 and MAP 13 could be made in order to reference the SLC definition of ‘pre-payment meter’, which would enable Suppliers to meet all pre-payment related obligations under the MRA.
IREG noted that the New Supplier cannot currently identify whether DAP needs to be initiated when they receive an Objection for Customers with smart meters, as the New Supplier has no indication whether the Customer’s meter was operated in prepayment mode with the Old Supplier.
The Group further discussed that the Electricity Supply Standard Licence Conditions (SLCs) did not explicitly state whether DAP needs to be applied to all Customers whose smart meters were operated in prepayment mode with their Old Supplier, irrespective of whether the Customer had chosen a credit or prepayment tariff with the New Supplier, and irrespective of whether the New Supplier would be able to support a prepayment tariff for a Customer on a pre-Smart Meter Equipment Technical Specification (SMETS) 2, non-Data and Communications Company (DCC) enrolled smart meter.
Suppliers noted that in the absence of clarity in the SLCs and the absence of indication as to the Customer’s smart meter operating mode with the Old Supplier, DAP would need to be instigated for every Objection received when registering new Customers, which would not be feasible considering the DAP was currently a manual process.
IREG discussed that the checking of Customer names as a first step during the DAP was currently the most work-intensive and manual part of the process, and identified that this was mainly due to names being provided in one Data Item whose format was not structured and therefore made it impossible to apply automated validation. One attendee noted that the DAP workgroup at Energy UK had considered statistics around the rejection reasons for DAP, which had indicated that 86% of DAP rejections were due to name mismatches in surname alone. IREG therefore considered that splitting the current J0375 (Customer Name) Data Item into Title, Given name (or Initial) and Surname for use in DAP Data Flows would allow Suppliers to at least partially automate the name checking process and eventually enable an automated end-to-end DAP process. The Group further noted that to streamline the process, the current DAP Data Flows should be reviewed to ensure they only contained information essential for DAP.
IREG lastly considered the work currently ongoing in various Ofgem groups with regards to Objections and the smart change of Supplier process, noting that no clear indication had as yet been given by Ofgem on whether DAP processes would continue in their current form. Parties were divided over whether any amendments to the DAP processes should be considered now, with some parties suggesting to wait until Ofgem decisions had been published, and others advocating to prepare DAP improvements now and to try and influence discussions at Ofgem.
IREG agreed to issue an RFI to obtain wider input regarding a number of discussion items, whilst awaiting the further policy development that is currently being considered by Ofgem under its Switching Programme and its review of the Objections process.
IREG also agreed to progress a housekeeping change proposal in order to update the definition of a ‘pre-payment meter’ in MAP 13 and MRA Clause 30. IREG declared that MIF 198 could be closed.
IREG will next meet on 8th June 2016