Draft Implementing Regulation on the Access to Electricity Metering & Consumption Data Requirements
- We are concerned about the mandatory implementation of the proposed reference model, with many aspects as currently drafted coming into force within 20 days. The reference model should be used for mapping of national practices to achieve interoperability and not to harmonise national practices, following the negotiations of the Clean Energy Package. We understand Member States have not seen this model prior to the publication of this draft, and furthermore we propose an implementation period of no less than 24 months to allow all Member States to implement any specific requirements.
- The proposed reference model has been based off the retail market for household and small and medium enterprise (SME) customers, but the IR refers to “final customers,” which could be interpreted to include large industrial customers as well. The consumer protection rules in the retail markets for household and SME customers are significantly different from the consumer protection rule for large industrial customers. We would propose that the language scoping the proposed reference model be clarified to include only household and SME customers. The spirit of directive 2019/944, for example recitals 54, 55 and 56, is providing Smart Metering and access to Smart Metering data to consumers. The data exchange between large industrial customers and high voltage network operators is already well established and requiring similar approach to this data exchange as to residential consumers metering data could create unnecessary bureaucracy.
- Since metering and consumption data is related specifically to distributed energy and the connection between final customers and the grid, we feel that it is unnecessary to include ENTSO-E in collecting the reports and making the data practices available. We find this is outside of the scope of their responsibilities.
- The IR will significantly impact the work of system operators, and they have been well-included in the operation of the IR, but it will also significantly impact the operations of energy suppliers, and we feel that suppliers and service providers should be on equal footing with the functionality of the IR.
- The wording consent versus permission should be carefully considered in the context of other horizontal EU Data legislation such as GDPR and the Data Act.